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February 2006

WILPINJONG

COAL

PROJECT

��

ENVIRONMENTALMANAGEMENTSTRATEGY

ENVIRONMENTALMANAGEMENTSTRATEGY

February 2006

Wilpinjong Coal Project

Environmental Management Strategy

Wilpinjong Coal Project – Environmental Management Strategy

Wilpinjong Coal Project - Environmental Management Strategy Revision No. EMS-R01-A Last Reviewed: Page i Document ID: Environmental Management Strategy Authorised:

TABLE OF CONTENTS

1.0 INTRODUCTION ...................................................................... 1

1.1 PURPOSE AND SCOPE ............................................................................1

1.2 AUTHORISATION, REVISION AND DISTRIBUTION CONTROL ..............4

1.3 REVISION STATUS REGISTER.................................................................4

1.4 DISTRUBUTION REGISTER......................................................................5

2.0 DEFINITIONS........................................................................... 6

3.0 STATUTORY REQUIREMENTS .............................................. 7

3.1 PROJECT APPROVAL REQUIREMENTS.................................................7

3.2 ENVIRONMENTAL PROTECTION LICENCE ............................................9

3.3 MINING LEASE ..........................................................................................9

3.4 REGULATORY AUTHORITIES AND REQUIREMENTS............................9

4.0 PROJECT DESCRIPTION ..................................................... 11

4.1 LAND DESCRIPTION AND BRIEF ENVIRONMENTAL CONTEXT.........11

4.2 OVERVIEW OF WILPINJONG COAL PROJECT.....................................11

4.2.1 Approved Operations .....................................................................11

4.3 EXTERNAL STAKEHOLDERS ................................................................12

4.4 ENVIRONMENT AND COMMUNITY ASPECTS AND IMPACTS .............12

5.0 ENVIRONMENTAL MANAGEMENT SYSTEM ...................... 13

5.1 WILPINJONG COAL ENVIRONMENT AND COMMUNITY POLICY........13

5.2 CONTRACTUAL COMMITMENTS...........................................................14

6.0 ENVIRONMENTAL ASPECTS AND IMPACTS ..................... 14

7.0 ENVIRONMENTAL OBJECTIVES AND TARGETS............... 14

7.1 ENVIRONMENTAL MANAGEMENT PROGRAMS ..................................14

7.2 STRUCTURE AND RESPONSIBILITY.....................................................15

7.3 ORGANISATIONAL CHART ....................................................................15

7.4 POSITION RESPONSIBILITIES...............................................................15

8.0 RESOURCES AND OPERATIONAL CONTROL ................... 17


Wilpinjong Coal Project - Environmental Management Strategy Revision No. EMS-R01-A Last Reviewed: Page ii Document ID: Environmental Management Strategy Authorised:

9.0 INCIDENT AND EMERGENCY PREPAREDNESS................ 17

9.1 EMERGENCY RESPONSE ......................................................................17

9.2 INCIDENTS...............................................................................................17

10.0 TRAINING .............................................................................. 18

11.0 COMMUNICATION ................................................................ 19

11.1 INTERNAL COMMUNICATION................................................................19

11.2 EXTERNAL COMMUNICATION...............................................................19

11.2.1 Community Consultative Committee ..............................................20

11.2.2 Complaints Management ...............................................................20

11.3 DISPUTE RESOLUTION ..........................................................................21

11.3.1 Community.....................................................................................21

11.3.2 Operations .....................................................................................21

12.0 MEASUREMENT AND EVALUATION................................... 22

12.1 ENVIRONMENTAL MONITORING...........................................................22

12.1.1 Inspections.....................................................................................23

12.2 CORRECTIVE AND PREVENTATIVE ACTION .......................................23

12.3 EMS RECORDS AND INFORMATION MANAGEMENT ..........................24

12.4 AUDITS ....................................................................................................24

12.4.1 Internal Audits ................................................................................24

12.4.2 Project Approval Independent Audit ...............................................24

12.4.3 External Audits ...............................................................................25

12.5 MANAGING CUMULATIVE IMPACTS .....................................................25

13.0 REVIEW AND IMPROVEMENT ............................................. 27

13.1 MANAGEMENT REVIEW.........................................................................27

14.0 REFERENCES ....................................................................... 27


Wilpinjong Coal Project - Environmental Management Strategy Revision No. EMS-R01-A Last Reviewed: Page iii Document ID: Environmental Management Strategy Authorised:

FIGURES 1.1 Locality Map..............................................................................................2 1.2 Project General Arrangement..................................................................3 7.1 Wilpinjong Coal Project Organisation Chart ........................................16 12.1 Dispute Resolution Process ..................................................................22


Wilpinjong Coal Project - Environmental Management Strategy Revision No. EMS-R01-A Last Reviewed: Page 1 Document ID: Environmental Management Strategy Authorised:

1.0 INTRODUCTION The Wilpinjong Coal Project (WCP) is located in the Western Coalfields of New South Wales, approximately 40 kilometres north of Mudgee (Figure 1.1). The WCP is owned and managed by Wilpinjong Coal Pty Ltd (WCPL) which is a wholly owned subsidiary business unit of Excel Coal Limited (Excel). The WCP consists of the design, construction and mining of an open cut coal mine (Figure 1.2). Both construction and mining are being conducted by Thiess Pty Ltd (Thiess) under a Contract with WCPL. On the 1st February 2006, WCPL was granted Project Approval for Application No. 05-0021 by the Minister for Planning, which allows for the construction and operation of the WCP. This Project Approval was granted under Part 3A of the Environmental Planning and Assessment Act 1979. The Mining Lease is expected to be granted by the Minister for Mineral Resources in February 2006 and Environment Protection Licence (EPL) 12425 issued by the Department of Environment and Conservation (DEC) under the Protection of Environment Operations Act 1997 in February 2006.

1.1 PURPOSE AND SCOPE This Environmental Management Strategy (the Strategy) has been developed to minimise environmental impacts from the WCP by providing the strategic context for environmental management across the site. The Strategy is formulated from the requirements of Project Approval 05-0021 and sets out to:

• Identify the statutory requirements that apply to the WCP; • Describe how:

o environmental performance is monitored and managed; o the local community and relevant agencies will be kept informed about the

operation and environmental performance; o complaints will be received, handled, responded to and recorded; o disputes will be resolved; o non-compliance issues will be responded to; o cumulative impacts will be managed; and o emergencies will be responded to.

• Describe the roles, responsibilities, authority and accountability of all the key

personnel involved in environmental management of the WCP. In addition to the Project Approval, the Strategy is consistent with the WCP Environmental Management System (EMS). The EMS is based on the Thiess Management System, which has certification under ISO14001 (2004). As a public document, the Strategy has been developed as an auditable management tool for the site and government agencies, and provides the community with information relating to environmental management at the WCP. The Strategy also sets out the procedures for periodic review, auditing and where necessary revision of the Strategy, so that it is maintained to reflect current mining operations to the satisfaction of the Director-General of the Department of Planning (DoP).

MERRIWAMERRIWA

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CUDGEGONG

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CUDGEGONG

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Wilpinjong Creek Wollar

CreekMurragamba

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Moolarben

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6 440 000N

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Home RuleHome Rule

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Project Location

UarbryUarbry

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ood

LEGENDMining Lease Boundary

Local Government Boundary

0 102

Kilometres

ENVIRONMENTAL MANAGEMENT STRATEGY

Locality MapFIGURE 1.1

WIL-05-05 EMS_001B

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WilpinjongCreek

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WOLLAR

Gou lburn R i ve r Na t i ona l ParkGou lburn R i ve r Na t i ona l Park

Realignment ofUlan-Wollar Road

Realignment ofUlan-Wollar Road

Relocation of 11kVElectricity Transmission Line

RelocatedRoad-RailCrossing

New Intersectionat Wollar Road

Mine Access Road

Product CoalStockpiles/

Handling Area

TrainLoad-out

Bin

MineFacilities Area

CHPP

ROM Pad

Cumbo CreekRelocationCorridor

RelocatedRoad-RailCrossing

CHPP WaterSupply Storage/Initial TailingsDisposal Area

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TemporaryAccess Road

Kilometres

1 20

LEGENDMining Lease Boundary

Outline of Project Open Pits

Existing 11kV Electricity Transmission Line

Dwelling

Proposed Water Supply Bore

Enhancement and Conservation Area (ECA)

V

Source: WCPL (2005), Thiess (2005) and Australasian Groundwaterand Environmental Consultants (2005)

Project General ArrangementFIGURE 1.2

WIL-05-05 EMS_002B

ENVIRONMENTAL MANAGEMENT STRATEGY



1.2 AUTHORISATION, REVISION AND DISTRIBUTION CONTROL The Strategy is subject to regular revision as described in the EMS. As a minimum, revision of the Strategy shall be undertaken within 3 months of the completion of the Independent Environmental Audit (Condition 2, Schedule 5 of Application 05-0021). Revision of the Strategy shall be undertaken by the Environmental Coordinator and approved by the WCPL General Manager and the WCP Operations Manager. The revision status of the Strategy is shown on each copy of the Strategy document. The Revision Status Register is shown in Section 1.3 of this document. The control of documentation associated with the Strategy is to be undertaken in accordance with the EMS. The distribution list for controlled copies of the Strategy is shown in Section 1.4 of this document. Revisions to any documents listed within this Strategy will not necessarily constitute a revision of this document. The Environmental Management Strategy has the full support and commitment of WCP senior management. Signed: ___________________________________ Date: _________

Operations Manager – Thiess Pty Ltd, WCP Signed: ___________________________________ Date: _________

General Manager – WCPL

1.3 REVISION STATUS REGISTER

Section/ Page/ Annexure

Revision No.

Amendment/Addition Authorised Approved Date

All A0 Original 8 Feb 2006



1.4 DISTRUBUTION REGISTER Copies of the Strategy have been issued to the holders nominated in Table 1.1. Where possible, electronic copies have been made available to holders in preference of hardcopies. Electronic copies are considered controlled and may only be updated by the WCPL Environmental Co-ordinator. The Thiess Environmental Management Representative will ensure holders listed below who utilise electronic availability:

• have their access confirmed at job commencement and following major IT upgrades; and

• are notified of the Strategy revisions by email. Hardcopies have been issued to those holders where electronic availability cannot be organised. Holders of these copies will be given updates by email or post and expected to update their hardcopy as appropriate.

Table 1.1: Distribution Register

Copy No. Holder

1 General Manager WCPL

2 Environmental Management Representative (Thiess)

3 Environmental Co-ordinator (WCPL)

4 Operations Manager (Thiess)

5 Department of Planning

6 Mid-Western Regional Council

7 WCP Community Consultative Committee

E Mine Manager (Thiess)

E Mine Superintendent (Thiess)

E Maintenance Superintendent (Thiess)

E CHPP Superintendent (Thiess)

E OHS&E Committee Chairperson

E – indicates a controlled electronic copy will be emailed to the recipient.

In addition to the holders listed above, WCP employees with local computer network access will be able to view the controlled electronic version of this Strategy on the WCP local area network. A copy of the Strategy has also been supplied to Mid-Western Regional Council, and the WCP Community Consultative Committee as required by Condition 12 in Schedule 5 of the Project Approval. A copy will also to be placed on the WCP website. The Environmental Co-ordinator shall not be responsible for maintaining uncontrolled copies beyond ensuring the most recent version is maintained on the site’s computer system and website.



2.0 DEFINITIONS continual improvement process of enhancing the environmental management system

to achieve improvements in overall environmental performance that are consistent with the WCP environmental policy

environment surroundings in which WCP operates, including air, water,

noise, land, flora, fauna, natural resources, humans and their interaction

environmental aspect element of WCP activities, products or services that can

interact with the environment Environment and Community Officer

WCPL Environmental Representative.

environmental impact any change to the environment, whether adverse or beneficial, wholly or partially resulting from WCP activities, products or services

Environmental Management Strategy (The Strategy)

This document, which has been developed for compliance with and in accordance with Condition 1 of Schedule 5 of the Project Approval 05-0021, dated 1 February 2006.

Environmental management system (EMS)

From ISO 14001

environmental management system audit

systematic and documented verification process of obtaining and evaluating evidence to determine objectively whether WCP environmental management system conforms to the environmental management system audit criteria set by WCP, and communication of the audit findings to senior management

Environmental Co-ordinator

WCPL site environmental representative

environmental objective

overall environmental goal, arising from the environmental policy, that WCP aims to achieve, and which is quantified where practicable

environmental performance

measurable results of the environmental management system, related to WCP control of its environmental aspects, based on environmental policy, objectives and targets

environmental policy statement of WCP intentions and principles in relation to

overall environmental performance, which provides a framework for action and for setting of its environmental objectives and targets



environmental target detailed performance requirement, quantified where practicable, applicable to WCP or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives

Environmental Representative

Thiess site person responsible for environmental management

external stakeholder individual or group concerned with or affected by the

environmental performance of WCP near hit An incident that had the potential to cause environmental

harm, but harm was avoided personnel all staff and contractors that perform work for WCP prevention of pollution use of process, practices, materials or products that avoid,

reduce or control pollution, which may include recycling, treatment, process changes, control mechanisms, efficient use of resources and materials substitution

Project Approval Project Approval 05-0021 granted by the Minister for Planning

on 1 February 2006 subject to Part 3A of the Environmental Planning and Assessment Act 1979.

WCP Wilpinjong Coal Project; includes the design, construction and

operation of the Mine at the Wilpinjong site. NB: definitions sourced from ISO14000 series, where available

3.0 STATUTORY REQUIREMENTS

3.1 PROJECT APPROVAL REQUIREMENTS This Strategy provides the framework for environmental management at the WCP. It also addresses the requirements of the Wilpinjong Project Approval. This Strategy builds upon the information provided in the Wilpinjong Coal Project Environmental Impact Statement (WCPL, 2005). This Strategy has been prepared in accordance with Condition 1 of Schedule 5 of the Wilpinjong Coal Project Approval (Table 3.1). Copies of this Strategy will be provided to Mid-Western Regional Council (MWRC), Department of Primary Industries - Minerals Resources (DPI-MR), and the WCP Community Consultative Committee within three months of approval by the Director-General of DoP.



Table 3.1: Checklist of Requirements for the Environmental Management Strategy

Project Approval Condition

Schedule 5 – Condition 1

Prior to carrying out any development, the Proponent shall prepare and implement an Environmental Management Strategy for the project to the satisfaction of the Director-General. This strategy must:

(a) provide the strategic context for environmental management of the project;

(b) identify the statutory requirements that apply to the project;

(c) describe in general how the environmental performance of the project would be monitored and managed during the project;

(d) describe the procedures that would be implemented to:

• keep the local community and relevant agencies informed about the operation and environmental performance of the project;

• receive, handle, respond to, and record complaints;

• resolve any disputes that may arise during the course of the project;

• respond to any non-compliance;

• manage cumulative impacts; and

• respond to emergencies;

(e) describe the role, responsibility, authority, and accountability of all the key personnel involved in environmental management of the project; and

(f) be updated following each Independent Environmental Audit required by Condition7.

Schedule 5 – Condition 2

Within 6 months of the completion of the Independent Environmental Audit (detailed in Condition 7), the Proponent shall review, and if necessary revise, the Environmental Management Strategy to the satisfaction of the Director-General.

In addition to this strategy, a number of plans have been prepared in accordance with Project Approval to facilitate the management of specific environmental aspects of the WCP (Table 3.2). These plans form part of the WCP EMS.

Table 3.2: Wilpinjong Coal Project Environmental Management Plans

Environmental Management Plans and Programs Timing Consultation / Satisfaction of

Environmental Management Strategy Prior to carrying out any development Satisfaction of DG DoP

Environmental Monitoring Program Within 6 months of Approval Consultation with DNR, DEC, DPI-MR / Satisfaction of DG DoP

Noise Monitoring Program Prior to carrying out any development Satisfaction of DG DoP

Blasting Management Plan Prior to carrying out any blasting Satisfaction of DG DoP

Air Quality Monitoring Program Prior to carrying out any development Satisfaction of DG DoP

Site Water Management Plan

a) Cumbo Creek Relocation Plan

b) Site Water Balance

c) Erosion and Sediment Control Plan

d) Surface Water Management and Monitoring Plan

e) Ground Water Monitoring Program

f) Surface and Ground Water Response Plan

Prior to carrying out any development Consultation with DNR / Satisfaction of DG DoP

Rehabilitation and Landscape Management Plan

(a) Rehabilitation Management Plan

(b) Final Void Management Plan

(c) Mine Closure Plan

Within 6 months of Approval Consultation with DNR, DEC, DPI-MR / Satisfaction of DG DoP

Aboriginal Cultural Heritage Management Plan Prior to carrying out any development Consultation with DEC and Aboriginal Communities / Satisfaction of DoP



Condition 9 of Schedule 2 allows the Proponent, with the approval of the Director-General, to prepare and submit any management plan or monitoring program required by the Approval on a progressive basis. Where a management plan or monitoring program is required before carrying out any development, or stage of development, the plans/programs may be prepared and submitted in relation to either discrete components of the project or for a specified time period.

3.2 ENVIRONMENTAL PROTECTION LICENCE Environmental Protection Licences (EPL) are administered by the Department of Environment and Conservation (DEC). EPL No. 12425 is expected to be issued in February 2006 for the WCP. Licence compliance requirements are summarised in the site’s EMS within the Obligations Register. Monitoring requirements of the WCP EPL’s will be detailed in the WCP Monitoring Program.

3.3 MINING LEASE The Mining Lease is expected to be granted by the Minister for Mineral Resources in February 2006. This Lease provides for the extraction of coal from the WCP area for a period of 21 years. An Interim Mining Operations Plan (MOP) has been submitted as a condition of the Lease to the DPI-MR for the construction of infrastructure and initial mining until the 6 February 2007. A further MOP will be submitted in January 2007.

3.4 REGULATORY AUTHORITIES AND REQUIREMENTS In order to maintain regulatory compliance, it is necessary to identify and understand the regulatory and other requirements applicable to activities at the WCP. A register of these federal, state and local government legislative instruments is contained within the site EMS. The EMS also contains an obligation register of all conditions attached to Approvals, Licences, Permits, etc that relate to this Project. The primary Authorities relevant to environmental management of the WCP are identified in Table 3.3.

Table 3.3: Statutory Authorities Relevant to Wilpinjong Coal Project

Authority

Department of Planning

Department of Primary Industries – Mineral Resources

Department of Natural Resources

Department of Environment and Conservation

Australian Rail Track Corporation

NSW Heritage Office

Mid-Western Regional Council



It is the responsibility of the Environmental Co-ordinator and the Environmental Representative to be aware of changes to relevant legislation, policy and guidelines, and to notify the Operations Manager and General Manager of changes that may significantly affect WCP. Means by which the Environmental Co-ordinator will keep up to date with changes in legislation, policy and guidelines include:

• review of NSW Minerals Council Environment Committee minutes and

attendance at Committee meetings;

• liaison with government agencies;

• legal opinion, as required;

• advice from environmental consultants; and

• participation in professional development seminars. Should a change in legislation be identified that has the potential to impact on the operations of the WCP, the Change Management process will be followed to ensure the appropriate review and changes to the sites operations are communicated and undertaken. A number of approvals, licences, permits and agreements relate to the WCP. These approvals and agreements are listed in the EMS Licence Register. Specific requirements of these approvals are summarised in an Obligation Register contained within the site EMS. This information includes the holder, date of approval, date of renewal, reporting requirements, last reporting date and next reporting date for each approval held by for the WCP. Dependent on the holder of the relevant approval, WCPL or Thiess, it is the responsibility of the WCPL Environmental Co-ordinator or the Thiess Environmental Representative to ensure that these approvals are renewed, as required, and that reporting requirements are met. It is the responsibility of the Operations Manager to ensure that the WCP meets its obligations under these approvals and the relevant legislation. It is the responsibility of the Environmental Representative to advise the Operations Manager of his/her obligations under these approvals, and to prepare the necessary documentation to demonstrate compliance with the requirements of regulatory authorities. This Strategy document forms part of the sites Environmental Management System (EMS). The Strategy is an overview document for the EMS and details key components of the system as required by the Project Approval.



4.0 PROJECT DESCRIPTION

4.1 LAND DESCRIPTION AND BRIEF ENVIRONMENTAL CONTEXT The WCP is located within the Western Coalfields near Wollar in the Upper Hunter Valley of New South Wales (NSW), approximately 40 kilometres northeast of Mudgee (Figure 1.1). The Project area is owned by WCPL, which is a subsidiary of Excel Coal Limited (Excel). The Project is being constructed and will be operated by Thiess Pty Ltd under a 5 year contract. Grazing and nature conservation are the predominant land uses in the vicinity of the WCP. An existing mining operation (Ulan Mine) lies approximately 10 km to the west. Other land uses within the surrounding area include the Goulburn River National Park and Munghorn Gap Nature Reserve, and grazing enterprises. The WCP is located within the Wilpinjong Creek catchment, which is a sub-catchment of Wollar Creek and the Goulburn River. The only other major watercourse within the Project Area is Cumbo Creek. The WCP occupies mainly cleared land between the steep sandstone escarpments of the National Park and Nature Reserve. While the majority of the Project area has been extensively cleared, areas of remnant vegetation, including the White Box / Yellow Box / Blakely’s Red Gum endangered ecological community remain.

4.2 OVERVIEW OF WILPINJONG COAL PROJECT

4.2.1 Approved Operations On the 1 February 2006 Project Approval for Application No. 05-0021 was granted for the construction and operation of the Wilpinjong Coal Mine. The approval is for 21 years of mining at a rate of up to 13 million tonnes or ROM coal per year, including approval to process up to 8.5 million tonnes of ROM through the coal handling and preparation plant. Approved infrastructure works include:

• Access road and intersection upgrade;

• Rail spur line;

• Coal handling and preparation plant;

• Run of mine and product stockpiles;

• Workshop and fuel handling facilities;

• Mine water dams;

• Establishment of a borefield for on-going water supply;

• Tailings dams; and

• Office and employee facilities, including bathhouse. Additional approved works include:

• Establishment of Enhancement and Conservation Areas;

• Wilpinjong Creek restoration works; and

• Diversion of Cumbo Creek.



4.3 EXTERNAL STAKEHOLDERS An electronic database of all identified external stakeholders is maintained on site. This includes but is not limited to;

• Neighbouring Residents;

• Community Groups;

• Regulatory Bodies;

• Aboriginal Groups; and

• Environmental Groups. Stakeholders are provided with regular updates on the operational, environmental and social performance of the WCP, through various communication channels detailed in the WCP Community Plan. These include a community and employee newsletter and the site’s website. Relevant stakeholders are also consulted prior to commencement of significant new developments undertaken by WCP.

4.4 ENVIRONMENT AND COMMUNITY ASPECTS AND IMPACTS

The Wilpinjong EIS and the Independent Hearing and Assessment Panel (IHAP) addressed the potential impact of the Project on the environmental and community aspects, including:

• Air quality

• Water quantity and quality, both surface water and ground water

• Noise emissions

• Blasting vibration, overpressure and air emissions

• Native flora and fauna

• Aboriginal cultural heritage and archaeology

• European heritage

• Surrounding landuses

• Project traffic

• Local employment.

The EIS comprehensively addressed these issues and is the reference for further information. Potential impacts and controls and are contained in the environmental management plans and programs. These include

• Air Quality Monitoring Program

• Noise Monitoring Program

• Blast management plan

• Aboriginal Cultural Heritage Management Plan

• Site Water Management Plan

• Rehabilitation and Landscape Management Plan

• Mining Operations Plan.



An environmental aspects and impacts register is maintained within the EMS for all activities undertaken as part of the Project. Controls to meet regulatory obligations and reduce identified impacts are contained in site Work Procedures. Task specific risks and controls are also identified as part of the Job Safety and Environment Assessment process that is a fundamental component of work on the site.

5.0 ENVIRONMENTAL MANAGEMENT SYSTEM The components of the WCP EMS are:

• Environmental Management Strategy (this document);

• Environmental Management Plan and Annexures;

• Site document management system, including; work procedures, training records, monitoring results, inspections and audits and reports; and

• Environmental Management Sub Plans (Plans generally required by the sites Project Approval and based on environmental aspects).

The WCP EMS is consistent with the Thiess Management System. The components of the EMS are consistent with the principles of ISO 14001 (2004) and comprise:

• Environmental Commitment and Policy

• Legal and other Requirements

• Identification of Environmental Aspects and Impacts

• Environmental Objectives and Targets

• Environmental Management Programs

• Resources and Responsibility for Implementation of the EMS

• Emergency Preparedness and Response

• Communication and Reporting

• Measurement and Evaluation

• Review and Continual Improvement.

5.1 WILPINJONG COAL ENVIRONMENT AND COMMUNITY POLICY The WCP Environment and Community Policy is currently under development and will define the environmental and community commitments and principles of WCPL & Thiess and the direction for improvements in environmental performance. The policy will be reviewed following any major operational or legislative changes and as a minimum annually as part of the Environmental Management Plan Review. All WCP personnel will be inducted in relation to the policy. The policy will be displayed prominently in all site offices and workforce amenities and distributed to the public on request. A copy of the Environment and Community Policy will be included in the Annual Environmental Management Plan Report.



5.2 CONTRACTUAL COMMITMENTS A contractual relationship exists between WCPL as owner of WCP and Thiess as principal constructor and mining operator. This contract requires Thiess to comply with all environmental and planning legislation and all Approvals, Licences, etc. pertaining to the Project. Both WCPL and its Contractors and Thiess and its Contractors will work under the site EMS. Environmental management will be a consideration to the award of any contract let on the WCP.

6.0 ENVIRONMENTAL ASPECTS AND IMPACTS Identification of the sites environmental aspects and impacts is an integral part of the Wilpinjong Project’s EMS. Risk identification is undertaken in accordance with the sites Risk Management Procedure. In accordance with this document an environment and community broad brush risk assessment (Environment and Community Aspects Register) is maintained within the site EMS. Ongoing job specific risk assessments are also regularly undertaken in accordance with site procedures. Where necessary, results from these are incorporated into the WCP aspects register. Where appropriate the results of the aspects register and ongoing risk reviews are incorporated into the mine planning and maintenance programs, environmental objectives and targets, management programs and site work procedures.

7.0 ENVIRONMENTAL OBJECTIVES AND TARGETS A register of objectives and targets is maintained within the WCP EMS. Development of these objectives and targets takes into consideration:

• legal and other requirements;

• significant environmental aspects;

• stakeholder views;

• technical capability; and

• other company requirements including consistency with the Environment and Community Policy.

These objectives and targets are progressively achieved through implementation of the environmental management programs and site procedures. Environmental objectives and targets are reviewed and updated on an annual basis for continual improvement. They form an integral part of the WCP EMS and are contained with in an Objectives and Targets register contained within the EMS. The Objectives and Targets will reflect the commitment to continual improvement embedded in ISO14001 compliant environmental management systems.

7.1 ENVIRONMENTAL MANAGEMENT PROGRAMS Environmental management programs are maintained within the sites EMS. These programs provide a structure to achieve set objectives and targets. They detail responsible personnel, budget requirements, and timeframes for achievement.



7.2 STRUCTURE AND RESPONSIBILITY Management at all levels and supervisory personnel are to lead by example and set the highest standards for environmental management. They are to act immediately to correct any nonconforming conditions or behaviours and promote environmental awareness, good environmental behaviours and continual improvement at every opportunity.

7.3 ORGANISATIONAL CHART The organisational structure of the WCP is regularly reviewed by the project management team and maintained within the site monthly operations report. A copy of the Organisational Chart is included as Figure 7.1.

7.4 POSITION RESPONSIBILITIES Environmental management responsibility is shared between WCPL and Thiess in accordance with the terms of the Contract. All parties represented on the WCP are bound to comply with environmental and planning legislation relating to the Project. A mutually agreed matrix of environmental responsibility assigning tasks between the owner and the operator is to be maintained within the EMS. In summary:

• The General Manager, representing the owner, is responsible to ensure the overall compliance of the WCP with Legislation and Approvals, and to ensure that the Strategy and EMS are appropriately resourced.

• The Operations Manager, representing the operating contractor, has primary responsibility for ensuring that works are conducted in accordance with legislation and approvals and that adequate resources are assigned to achieve the objectives of the Policy and EMS.

• The General Manager and Operations Manager jointly have responsibility to ensure this Strategy is complied with and implemented across the WCP.

• Line managers and Supervisors have responsibility to ensure activities under their control are completed in accordance with this Strategy and the site EMS related sub-plans, procedures, and programs.

• Operational personnel engaged in field activities must comply with the requirements of this Strategy and the sites EMS.

• the site Environmental Co-ordinator and the Environmental Representative shall jointly to the extent provided for in the site’s Responsibilities Matrix ensure all staff are inducted and trained in the requirements of the site EMS, that the EMS is reviewed and maintained in a current state and that all works are carried out in an environmental competent manner.

The environment and community related responsibilities of all staff are detailed in individual position descriptions. Responsibilities are also described in the various WCP work procedures. No personnel are permitted to undertake a task unless they have undertaken the required training, are competent and confident that the task can be conducted in an environmentally safe manner, with minimal impact on the community.



Figure 7.1 WCP Organisational Chart

Wilpinjong Coal Pty Limited General Manager

Wilpinjong Coal Pty Limited Construction Project

Manager

Wilpinjong Coal Pty Limited Commercial Manager

Wilpinjong Coal Pty Limited Community &

Environmental Coordinator

Thiess Pty Limited Project Director

Thiess Pty Limited Manager Mining Operations

Thiess Pty Limited Construction Team

Thiess Pty Limited Safety Manager

Thiess Pty Limited Commercial Manager

Production Superintendent

Maintenance Superintendent

Technical Services Superintendent

CHPP Operations



8.0 RESOURCES AND OPERATIONAL CONTROL Controls on activities conducted at the WCP are to be undertaken in accordance with WCP environmental procedures and environmental management plans and programs. Responsibility is to be delegated to the most effective level of supervision to ensure compliance. Site work procedures will be reviewed regularly to ensure all significant aspects of the WCP operation are appropriately controlled within the standard site operating procedures. A register of procedures is maintained as required by the WCP Management System. Procedures are communicated to all relevant personnel and are reviewed at least every two years and updated as required. Allocation of financial resources for achieving WCP environmental objectives and targets is documented within the sites annual budgeting process. This includes resources to maintain environmental controls in a proper and efficient condition.

9.0 INCIDENT AND EMERGENCY PREPAREDNESS

9.1 EMERGENCY RESPONSE Emergency response actions and responsibilities are detailed in the site Emergency Response Plan. This plan documents the responsibilities of key WCP personnel in the event of an emergency and the contact details for appropriate emergency services. During the conduct of the catastrophic risk reviews, identification of all potential emergency situations that could result in significant environmental impacts is undertaken. A list of potential high risk catastrophic environmental incidents is maintained in the site risk register. Emergency responses to these potential situations are to be incorporated into subsequent reviews and updates of all emergency procedures. An appropriate level of preparedness is maintained relative to the level of risk for each identified potential emergency situation. All personnel receive an appropriate level of emergency preparedness and response training. The site maintains a dedicated emergency response team who undergo regular training and operational drills involving identified high risk activities. Relevant managers are to consider emergency preparedness drills for such events. Any changes to emergency procedures are to be documented and communicated to all personnel.

9.2 INCIDENTS The WCP will maintain an Incident management procedure within the management system. In the event of an environmental incident, the cause of the incident is to be identified and the incident recorded in accordance with site procedures. The definition of an incident is to include a “near hit”. Reporting will be in accordance with Legislative and Corporate requirements.



Incident recording forms are located across the site and completed forms are to be forwarded to the Environmental Representative and the Environmental Co-ordinator. Completed forms are to be filed in and retained for a period of at least four years. The Environmental Representative is to conduct an investigation into each environmental incident, which shall include reporting requirements and recommendations for corrective or preventative action. All actions arising from the investigation are to be signed off by the nominated management representative within the timeframe specified. A review of the effectiveness of the corrective or preventative action is to be undertaken within one month of the occurrence of the incident and the relevant procedures are to be updated as required. Any changes to procedures as a result of these reviews are to be documented as per the sites Change Management Procedures and communicated to all personnel.

10.0 TRAINING Training forms an integral part of environmental management. All personnel and contractors at the WCP undergo Environmental Induction Training before being allowed to commence work on site. This includes specified training in cultural heritage and flora and fauna issues. For contractors to WCPL or Thiess this induction is renewed annually, and includes:

• the importance of conformance with the Environment and Community Policy and procedures and the relevant requirements of the EMS;

• Risk assessment and incident reporting;

• relevant legal and other requirements;

• the potential environmental impacts for their associated work activities;

• their roles and responsibilities in achieving conformance with the environmental policies and requirements, including emergency preparedness and response requirements; and

• the potential consequences of non-compliance with environmental policy. Competency-based Environmental Awareness training is conducted regularly and attended by all staff and permanent full-time contractors. The training includes;

• the environment and community context within which the WCP operates;

• the environmental policies and the importance of conformance;

• relevant legal and other requirements;

• the significant environmental aspects and impacts associated with the operation and relevant operational controls;

• their roles and responsibilities in achieving conformance with the environmental policies and requirements of the Environmental Management System, including emergency preparedness and response requirements;

• the potential consequences of non-compliance with environmental policy and environmental requirements;

• community involvement / relations; and

• cultural awareness.



Employees and permanent full-time contractors also undergo specific training undertaken as tool-box talks. This type of training is provided on an as-needed basis, for example, following the identification of a new environmental risk, relevant changes in legislation or a change in operations. The WCP Environmental Representative in consultation with the Environmental Co-ordinator undertakes the identification of environmental training needs of personnel and the delivery method, including source material as appropriate. Allocation of resources to provide these training needs shall be incorporated into the environmental management programs and the training needs matrix. The responsibility for co-ordination of environmental training for WCP personnel is vested in the delegated training co-ordinator, who consults with the Environmental Representative on the priority. These responsibilities include development of training modules and toolbox talks for aspects of WCP that may potentially result in significant environmental impacts. Environmental training is incorporated into the broader training program for the site including health, safety and operational training. Training module documentation and records of all training provided shall be maintained in the WCP Environmental filing system. The effectiveness of training modules and sessions shall be periodically reviewed and the training modules updated as required.

11.0 COMMUNICATION

11.1 INTERNAL COMMUNICATION Internal communication is to be conducted in accordance with the site’s communication procedure, which is incorporated in the Operations Management System. This procedure is periodically reviewed and updated as required. The WCP Environment and Community Policy and general responsibilities under the EMS are communicated to all personnel during an induction prior to commencement of work at WCP. Specific environmental impacts associated with particular activities are discussed during regular toolbox talks. All personnel are to report environmental incidents and non-conformances to their immediate supervisor who will then complete an incident/complaint form and forward the details of the incident or non-conformance to the Environmental Representative for investigation and corrective and/or preventative action. The Environmental Representative is to assist the relevant functional manager to investigate the incident or complaint and prepare an investigation report, which includes recommendations for preventative and/or corrective action. Communication of complaints or incidents to the relevant managers will be undertaken as per the site incident reporting requirements.

11.2 EXTERNAL COMMUNICATION All external reporting of environmental matters associated with WCP, including Incident and Complaints reporting and the Annual Environmental Management Report (AEMR), shall be undertaken by the Environmental Co-ordinator.



An environmental reporting schedule is maintained as part of the WCP EMS by the site Environmental Co-ordinator. The schedule includes the timeframe for communicating the WCP environmental activities and performance to statutory authorities. The Environmental Co-ordinator also maintains an obligations register within the site EMS. This register summarises conditions to be meet in relation to Project Approvals, permits and licences, including communication and reporting requirements. External stakeholders identified in the site’s stakeholder database are kept informed of the operational, environmental and social performance in accordance with the WCP Community Plan. Communication with these stakeholders on environmental matters is to be undertaken in accordance with the agreed community engagement protocol. WCP will produce a newsletter, which will be distributed to all identified internal and external stakeholders. This newsletter details current operational, environmental and community issues, initiatives and site activities. A blasting hotline will also be operated to provide up to date information on blasting at the WCP to the community. The WCP website will be maintained as part of the site’s Project Approval requirements. The website will provide the wider community with access to the sites monitoring results, details of current activities, proposed blast times, policies, environmental management plans and monitoring programs and any other information in relation to the site operation that may be considered of interest to the community. It is the responsibility of the Environmental Co-ordinator to maintain the Website.

11.2.1 Community Consultative Committee A community consultative committee (CCC) is to be established for the WCP in accordance with the sites Approval conditions. This will replace the Project Development CCC which has been in existence during the assessment phase of the project. The CCC comprises at least two community members, a representative from Council and an independent chairperson. The CCC shall meet at least twice per year. It is the responsibility of the Environment Co-ordinator to ensure minutes of the Committee meetings are taken and that these minutes are made available for public inspection and forwarded to the DG of DOP within one month of the meeting.

11.2.2 Complaints Management The WCP will maintain a telephone line for receiving complaints. The site Environmental Co-ordinator is responsible for ensuring that the currency and effectiveness of the service is maintained. Notifications of complaints received are to be provided as soon as possible to the site Environmental Co-ordinator and the WCP Production Supervisor on-shift. The General Manager, Operations Manager and Environmental Representative are to be advised on the next business day.



Complaints and enquiries do not have to be received via the telephone line and may be received in any other form. Any complaint or enquiry relating to environmental management or performance is to be relayed to the Environmental Co-ordinator as soon as practical. All employees are responsible for ensuring the prompt relaying of complaints. Complaints are managed in accordance with the WCP Complaints Management Procedure. The site Environmental Co-ordinator is responsible for ensuring that all complaints are appropriately investigated, actioned and that information is fed back to the complainant, unless requested to the contrary. WCPL reporting requirements as detailed in the WCPL Complaints Management Procedure shall also be complied with. This includes:

• A summary of complaints received is reported in the Monthly Operations Report.

• A summary of complaints received and actions taken is presented to the WCP CCC as part of the operational performance review.

• A summary of complaints received and actions taken is included in the Annual Environmental Management Report and the Annual Return to the DEC.

11.3 DISPUTE RESOLUTION

11.3.1 Community In the event of a disagreement between the WCP and a member of the community, the Environmental Co-ordinator and, as necessary, the WCPL General Manager, will undertake the necessary liaison to reach a resolution. This could will involve an offer for a one on one meeting with the resident to discuss the issue. Where relevant, negotiations will be initiated in accordance with the Project Approval conditions. In relation to a dispute over acquisition of a property, if the matter cannot be resolved between the company and the resident, the matter is to be referred to the Director-General of DoP for resolution, in accordance with the Approval Conditions.

11.3.2 Operations Procedures for dispute resolution, in relation to areas of environmental management, are specified in the Approval conditions. The Independent Dispute Resolution Process from the WCP is shown in Figure 12.1.



Figure 12.1: Independent Dispute Resolution Process

12.0 MEASUREMENT AND EVALUATION

12.1 ENVIRONMENTAL MONITORING Environmental monitoring to determine conformance of WCP with the EMS, including Licences and Approvals, is to be managed by the WCP Environmental Co-ordinator. Monitoring is undertaken in accordance with the Environmental Monitoring Program and individual Management plans and programs prepared in accordance with the Approval Conditions. A schedule of environmental monitoring undertaken is also contained within the site EMS along with an environmental monitoring site location plan. The purpose of this monitoring is to provide a measure of the performance of the operation, which can be compared against the objectives, targets and performance criteria specified in the WCP Licence’s, Approval Conditions and with the EIS predictions. All monitoring is undertaken using standard monitoring techniques and calibrated equipment operated by trained personnel. Analysis of samples is to be undertaken in accordance with the Project Approval and EPL conditions.

Independent Dispute Resolution Process (Indicative only)

Matter referred to Independent Dispute Facilitator appointed by DoP in consultation with Council

Independent Facilitator meets with parties concerned to discuss dispute.

Dispute resolved Dispute not resolved

Facilitator consults relevant independent experts for advice on

technical issues

Facilitator meets with relevant parties and experts

Dispute Resolved Dispute not resolved

Facilitator consults DoP and final decision

made

Agreed Outcome



All monitoring results are to be filed by the Environmental Co-ordinator within the document control system and maintained on site for at least four years. Monitoring results are compared against Project Approval, licence and permit conditions and any non-conformance recorded against the monitoring result. In the event of a non-conformance the Environmental Co-ordinator is to investigate the cause of the non-conformance and recommend corrective and/or preventative action. The effectiveness of the corrective and/or preventative action is to be assessed by analysis of the next available monitoring results and during the next monthly site inspection. Any changes to work procedures as a result of the corrective or preventative action are to be documented and communicated as per the sites change management procedure. Modifications to operations arising from monitoring results, either short or long term, are to be reported in the AEMR. Calibration records are kept of the monitoring equipment used. Calibration will be undertaken in accordance with the equipment manufacturer’s recommendations. Where monitoring is outsourced, the consulting body is responsible for maintaining calibration and supplying the relevant documentation. WCP is responsible for verifying the calibration is conducted.

12.1.1 Inspections Regular environmental inspections of WCP operations are conducted. These inspections are to determine, in conjunction with the environmental monitoring and incident/complaint reporting procedures, on-site compliance with the EMS. Site inspections are to be conducted by the Environmental Representative or his/her delegate and the inspection results recorded on the inspection form. Any non-conformances are to be recorded on the inspection form and the cause of the non-conformance investigated by the Environmental Representative. Corrective and/or preventative action is to be recommended by the Environmental Representative and the effectiveness of the corrective and/or preventative action assessed at the next inspection. Serious non-conformances are to be corrected as a matter of urgency.

12.2 CORRECTIVE AND PREVENTATIVE ACTION On receipt of an incident/complaint reporting form, site inspection form, hazard report or monitoring result that indicates a potential or actual non-conformance of the WCP with the EMS, the Environmental Representative is to undertake an investigation and recommend corrective or preventative action. Details of the required action(s) are to be communicated to the relevant supervisor of the specific operations area and a copy of the communications kept with the investigation report. The effectiveness of the requested action is to be assessed within one month of the non-conformance. Corrective and preventative actions relating to environmental aspects specifically identified within the Approval are addressed within the dedicated Environmental Management Plans and Programs as required by the Approval.



12.3 EMS RECORDS AND INFORMATION MANAGEMENT A master copy of the EMS including the Strategy, plans, procedures and supporting information is held in the office of the Environmental Co-ordinator and Environmental Representative. This documentation contains a register of all controlled copies of the EMS as well as registers of the distribution of controlled copies of each appendix. The sites document control officer maintains a distribution register of the EMS. The EMS is to be reviewed for relevance and effectiveness annually and updated, as required. Changes resulting from revised risk identification or legislative change are to be made as soon as practical.

12.4 AUDITS

12.4.1 Internal Audits Internal EMS audits will be undertaken to assess whether the EMS has been properly implemented and maintained and conforms to the environmental policy, objectives and targets of WCP. These internal audits are to be conducted in accordance with the Thiess Management System procedures and the WCPL’s Auditing standard. The results are communicated to senior management in accordance with these procedures. WCPL also undertakes a regular audit program to assess the sites implementation of corporate standards and the implementation of the Environmental Management System. Internal auditors are to be selected on the basis of their understanding of environmental management principles and mining operations. Internal auditors shall be suitably qualified and experienced and be capable of impartially and objectively auditing the WCP EMS. A schedule of Environmental Audits is maintained within the site EMS.

12.4.2 Project Approval Independent Audit As per Condition 7, Schedule 5 of the Approval, at the end of year 2 of the development, and every 3 years thereafter, unless the Director-General directs otherwise, an Independent Environmental Audit of the development shall be undertaken. This audit shall;

• be conducted by a suitably qualified, experiences and independent person whose appointment has been endorsed by the Director-General;

• assess the environmental performance of the development, and its effects on the surrounding environment;

• assess whether the development is complying with the relevant standards, performance measures and statutory requirements;

• review the adequacy of the Applicants Environmental Management Strategy and Environmental Monitoring Program; and

• if necessary, recommend measures of actions to improve the environmental performance of the development, and/or the environmental management and monitoring system.



Within three months of commissioning this audit, a copy of the audit report shall be submitted to the Director-General of DIPNR, with a response to any of the recommendations contained in the audit report. This audit is also to trigger a review of management plans and programs required under the Approval.

12.4.3 External Audits Other external environmental audits of the WCP may be conducted as required by WCPL, Excel or Thiess. External auditors are to be selected on the basis of their understanding of environmental management principles and mining operations. External auditors shall be suitably qualified and experienced and be capable of impartially and objectively auditing the WCP. The selection of external auditors will be the responsibility of the Environmental Co-ordinator. The audit findings are to be reported to senior management for review. Internally initiated external audits may be conducted under legal privilege. An external WCPL compliance audit may be conducted in conjunction with the Project Approval Independent Audit (section 13.4.3).

12.5 MANAGING CUMULATIVE IMPACTS The Wilpinjong Coal Project is situated approximately 10 km to the east of the Ulan Coal Mines (underground and open cut operations). Potential cumulative impacts with respect to the Ulan Coal Mines (including the as yet undeveloped components of Stage 2 which it is understood are proposed to be developed as part of the Moolarben Coal Project) were considered where relevant in the Wilpinjong Coal Project Environmental Impact Statement (WCPL, 2005), for example: • the Surface Water Assessment considers potential cumulative impacts with Ulan Coal

Mines on Wilpinjong Creek and on the Goulburn River (Section 5.4 of Appendix A, Volume 2 of the EIS);

• the Groundwater Impact Assessment considers potential cumulative impacts with Ulan Coal Mines (Section 13.1 of Appendix B, Volume 2 of the EIS);

• the Construction, Operation and Transportation Noise and Blasting Impact Assessment considers potential cumulative impacts with Ulan Coal Mines (Section 9 of Appendix D, Volume 2 of the EIS);

• the Air Quality Impact Assessment considers potential cumulative impacts with Ulan Coal Mines (Section 9 of Appendix E, Volume 2 of the EIS);

• the potential cumulative impacts on flora and terrestrial fauna are considered in Sections 4.7.1 and 4.8.1, Volume 1 of the EIS, respectively;

• the Community Infrastructure Assessment considers potential cumulative impacts with Ulan Coal Mines (Section J4.6 of Appendix J, Volume 5 of the EIS);

• the Road Transport Assessment considers potential cumulative impacts with Ulan Coal Mines (Section K6.7 of Appendix K, Volume 5 of the EIS); and

• the Visual Impact Assessment considers potential cumulative visual impacts with Ulan Coal Mines, including potential cumulative night-lighting impacts (Section K6.7 of Appendix K, Volume 5 of the EIS).



Mitigation measures proposed in the EIS are presented in more detail in the various environmental management plans and monitoring programmes and have been developed with consideration to the cumulative impacts identified in the EIS.

It should be noted that the Moolarben Coal Project is not yet approved. It is understood that the proponent of the Moolarben Coal Project (White Mining Limited owned by Felix Resources) is currently preparing an environmental assessment. The environmental assessment requirements (EARs) issued for the Moolarben Coal Project by the Director-General of the Department of Planning requires the environmental assessment to consider “… potential cumulative impacts (particularly on surface and groundwater, flora and fauna, noise, and air quality) that may arise from the combined operation of the mine, together with the Ulan Coal Mine and the Wilpinjong Coal Mine.”

As described in Section 12.1, a number of approved monitoring programmes have been established to allow for the measurement of cumulative impacts and would be updated/revised as required to include the Moolarben Coal Project (if approved). Procedures have been developed within the monitoring programmes (i.e. air quality, noise, surface water and groundwater) to allow the management of key potential cumulative impacts as follows:

Air Quality – The approved Air Quality Monitoring Programme (AQMP) stipulates the (cumulative) impact assessment criteria for deposited dust, PM10 and total suspended particulates (AQMP Section 3). The AQMP includes a data handling procedure, air quality protocols and describes the air quality mitigation and management measures for the Project (AQMP Sections 6.5, 7 and 8). The AQMP will be maintained so as to capture any change in the potential cumulative environment.

Noise – The approved Noise Monitoring Programme (NMP) states the cumulative noise criteria (NMP Section 2.2). The NMP includes a data handling procedure, noise protocols and describes the noise control and management measures for the Project (NMP Sections 4.4, 5 and 6). The NMP will be maintained so as to capture any change in the potential cumulative environment.

Surface Water – The approved Surface Water Management and Monitoring Plan (SWMMP) has been developed to establish surface water trigger levels and conditions based on baseline surface water monitoring data (SWMMP Section 4). The SWMMP describes data management and reporting procedures including surface water impacts reviews (SWMMP Section 8).

Groundwater – The approved Groundwater Monitoring Programme (GWMP) has been developed to establish groundwater impact assessment criteria and triggers based on baseline groundwater monitoring data and groundwater prediction validation processes (GWMP Sections 5 and 6). The GWMP also describes groundwater impact investigation procedures and contingency measures (GWMP Sections 7 and 8).

Surface and Ground Water Response Plan - The Surface and Ground Water Response Plan will be prepared within six months of Project Approval and include a protocol for the investigation, notification and mitigation of any exceedances of the surface water, stream health assessment and groundwater impact assessment criteria and procedures that would be followed if any unforeseen impacts are detected during the project, including potential cumulative impacts.



13.0 REVIEW AND IMPROVEMENT

13.1 MANAGEMENT REVIEW Periodic review and revision of the EMS is to be undertaken by senior management. The EMS review will include:

• review of audit findings;

• results of monitoring programs;

• achievement of objectives and targets;

• relevance of the Policy, objectives and targets to current and future conditions; and

• information and concerns of stakeholders. Reviews will be undertaken annually and may be incorporated into the WCP Operations Management System Review Process. The General Manager and Operations Manager should both participate in this review.

14.0 REFERENCES Wilpinjong Coal Pty Ltd (2005) Wilpinjong Coal Project Environmental Impact Statement. Thiess Pty Ltd Management System (2004).

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