Springvale MPPS Water Treatment Project - Veolia · SWMS Safe Work Method Statement WTF Water Treatment ... known as the Springvale MPPS Water Treatment ... treated water from the

Springvale MPPS Water Treatment Project

Construction Environmental Management Plan

SMPPS-O-00-M13-00-03

DOCUMENT CONTROL

Rev Date Revision Comments Prepared by Reviewed by Approved by

0 18/08/2017 Draft for internal review Elena Ivanova

Project Manger

Jonas Ball

Linchpin Environment

1 27/10/2017 Final Elena Ivanova

Project Manger

Jonas Ball

Linchpin Environment

Huw Thomas

HSEQ Lead

Page: Page 2 of 50 Document: SMPPS-O-00-M13-00-03 Date: 27.10.2017

PLAN Construction Environmental Management Plan

Printed documents are uncontrolled versions. Check printed copies against the current electronic version for validity.

CONFIDENTIALITY CONDITIONS All information whether oral, electronic, printed or graphic contained in this document or obtained by you from VANZ (Information) is confidential to VANZ and shall not be used by you other than for the purpose of reviewing this document and the proposal contained herein. You shall not copy or reproduce any Information except when, and then only to the extent, reasonably necessary for the purpose of reviewing this document and the proposal contained herein. Upon receiving notice that our proposal has not been accepted, and if notified by VANZ, you shall destroy, in a secure manner, this document and any Information. You shall ensure that any employee or any other person to whom you supply the Information is bound by the terms of these conditions.




DEFINITIONS AND ACRONYMS Table 1 – Definitions and Acronyms

Term Definition

AIMS Abergeldie’s Integrated Management System

AHIMS Aboriginal Heritage Information Management System

BCSI Baseline Contaminated Site Investigation

BMP Biodiversity Management Plan

BMS Business Management System

CoDC Conditions of the Development Consent

DP&E Department of Planning and Environment

EIS, 2016 Environmental Impact Statement

EI&C Electrical, Instrumentation & Controls

EMP Contractor’s Environmental management Plan

EMS Environmental Management System

EP&A Act Environmental Planning and Assessment Act 1979

EPA NSW Environment Protection Authority

EPL Environmental Protection Licence

JSEA Job Safety & Environment Analysis

CEMP Construction Environmental Management Plan

Contractor Abergeldie Contractors Pty Ltd

CLM Act Contaminated Land Management Act 1997

Customer Springvale Coal Pty Ltd and NSW EnergyAustalia Pty Ltd

ML/day mega litres a day

MPPS Mount Pipe Power Station

PAC Planning Assessment Commission

POEO Act Protection of the Environment Operation Act 1997

SMPPS WTP or Project Springvale MPPS Water Treatment Project

PM Project Manager

PMP Project Management Plan

REA Reject Emplacement Area

SWMS Safe Work Method Statement

WTF Water Treatment Facility

WTS Water Treatment System

VANZ or Veolia Veolia Australia and New Zealand

WARR Act Waste and Resource Recovery Act 2001

WHS Act Work Health and Safety Act 2011




TABLE OF CONTENTS

Section 1 Introduction ..................................................................................................... 6

1.1 Background ....................................................................................... 6 1.2 Scope and Objectives........................................................................ 7 1.3 Supporting Management Plans ......................................................... 8 1.4 Veolia’s Overall Management System ............................................... 8

Section 2 Statutory and Policy Considerations .......................................................... 11

2.1 Relevant Environmental Legislation ................................................ 11

2.2 Other Requirements ........................................................................ 14

2.3 Summary of Licensing and Permit Requirements ........................... 15

2.4 Conditions of Development Consent ............................................... 15

Section 3 Project overview ........................................................................................... 18

3.1 Project Overview ............................................................................. 18 3.2 Project Location ............................................................................... 18 3.3 Project Phases ................................................................................ 20 3.4 Construction Hours .......................................................................... 21

3.5 Predicted Construction Impacts ....................................................... 21

Section 4 Implementation of the CEMP ....................................................................... 27

4.1 Roles and Responsibility ................................................................. 27 4.2 Subcontractor Management ............................................................ 29

4.3 Training and Awareness .................................................................. 30

4.4 Stakeholder Management Plan ....................................................... 30 4.5 Incident and Emergency Response ................................................. 31 4.6 Notification and Action Protocol ....................................................... 32

4.7 Emergency Contacts ....................................................................... 33 4.8 Pollution Incident Management ....................................................... 34

4.9 Environmental Performance Criteria ............................................... 35 4.10 Contingency Plan ............................................................................ 36 4.11 Performance Reporting ................................................................... 36

Section 5 Monitoring and Review of the CEMP .......................................................... 38

5.1 Monitoring and Inspections .............................................................. 38

5.2 Auditing ........................................................................................... 38 5.3 Review of the CEMP ....................................................................... 39

5.4 Corrective Action ............................................................................. 40

Appendices ..................................................................................................................... 41

Appendix A - Copy of the Development Consent .......................................... 41

Appendix B1 - Water Management Plan ........................................................ 42 Appendix B2 - Biodiversity Management Plan ............................................... 43 Appendix B3 - Aboriginal Cultural Heritage Management Plan ..................... 44 Appendix B4 - Construction Noise Management Plan ................................... 45 Appendix B5 - Construction Traffic Management Plan .................................. 46 Appendix B6 - Stakeholder Management Plan .............................................. 47 Appendix B7 - Construction Waste Management Plan .................................. 48 Appendix C - EPL requirements – EPA Clarifications .................................... 49

Appendix D - Pre-Construction Compliance Report ....................................... 50




TABLES Table 1 – Definitions and Acronyms .............................................................................................. 3

Table 2 – Licencing and Permitting Requirements ....................................................................... 15

Table 3 – Development Consent Requirements .......................................................................... 16

Table 4 – Construction Operating Hours ..................................................................................... 21

Table 5 – Air Control Measures ................................................................................................... 24

Table 6 – GHD Mitigation Measures ............................................................................................ 26

Table 7 – Visual Mitigation Measures .......................................................................................... 26

Table 8 – Summary of Key Roles and Responsibilities ................................................................ 28

Table 9 – Training and Awareness Methods ................................................................................ 30

Table 10 – Environmental Risks .................................................................................................. 32

Table 11 – Communication Mechanism ....................................................................................... 33

Table 12 – Project Emergency Incident Reporting Contacts ........................................................ 34

Table 13 – Environmental Performance Criteria .......................................................................... 35

Table 14 – Summary of Contingency Measures .......................................................................... 36

Table 15 – Summary of Monitoring and Inspections .................................................................... 38

FIGURES Figure 1 – Integrated Services Management Flowchart ................................................................. 9

Figure 2 – Project Overview ........................................................................................................ 18

Figure 3 – Project Location .......................................................................................................... 19

Figure 4 – Land Ownership ......................................................................................................... 19

Figure 5 – Incident Response Flow Chart .................................................................................... 34




SECTION 1 INTRODUCTION

1.1 Background

This Construction Environmental Management Plan (CEMP) and supporting management plans

have been prepared to comply with the Conditions of Development Consent granted on 19 June

2017 (CoDC) for the construction of the Water Transfer System (WTS) from existing Springvale Mine

dewatering facilities on the Newnes Plateau to a new Water Treatment Facility (WTF) located at the

Mount Piper Power Station (MPPS).

Springvale Coal Pty Ltd has collaborated with EnergyAustralia Pty Ltd to develop the above, which is

known as the Springvale MPPS Water Treatment Project (SMPPS WTP) (Project).

The Project includes the following major elements:

A system to transfer (approximately 15 km ) up to 42 mega litres a day (ML/day) of dewatered

mine water from the existing gravity tank forming part of the approved dewatering facilities on

the Newnes Plateau to a new WTF to be located at the MPPS site (see Figure 2 below).

A WTF incorporates desalinisation processes to reduce the salinity in mine water to a

standard suitable for either industrial reuse or environmental release.

Transfer of treated water from the water treatment plant to the MPPS cooling water to

contribute to the demand for make-up water.

Transfer via a new 2.4 km pipeline and discharge of any excess treated water not able to be

reused within the MPPS cooling water system to Thompsons Creek Reservoir.

Transfer of residual material from the pre-treatment process to the existing reject

emplacement area (REA) at the Western Coal Services Site.

Installation of a crystalliser to provide further treatment of the additional salt load generated

within the MPPS cooling water blowdown system.

The project would remove the current need to discharge a large amount of mine water to the drinking

water catchment, and provide a beneficial reuse of this water in the operation of the MPPS. This

project will improve environmental outcomes and water quality within the upper Cox’s River

catchment area.

Veolia has been selected as specialist water services company to finance, design, construct, test and

commission, operate and maintain the Project. The duration of the operations and maintenance

phase is 15 years. This arrangement is documented under a Water Treatment Services Contract to

be entered into between the Springvale Coal Pty Ltd, NSW EnergyAustalia Pty Ltd (Customer) and

Veolia.

Veolia has selected Abergeldie Complex Infrastructure Pty Ltd (Contractor) as the construction

subcontractor for the Project. Abergeldie will be responsible for the design, construction and

commissioning of the WTS, including the Mine Water Transfer Pipeline, Residuals Transfer Pipeline,

Treated Water Pipeline connecting to Thompsons Creek Dam and a new WTF. Abergeldie shall also

be responsible for the design and construction of the civil and buildings portion of the WTF as well as

the mechanical and EI&C construction, based on Veolia’s design.

The NSW Department of Planning and Environment (DP&E) has assessed the State Significant

Development (SSD 7592) in accordance with section 89(C) of the Environmental Planning and

Assessment Act 1979 (EP&A Act). DP&E has delegated SSD 7592 to the Planning Assessment

Commission (PAC) for determination under the Minister’s delegation of 14 September 2011. The

PAC determined the development application for the Project on 19 June 2017 as well as two




modifications associated with the Project: Wester Coal Services – Residuals Emplacement

Modification (SSD 5579 MOD1) and Springvale Mine Extension Project (SSD 5594 MOD2).

This CEMP has been prepared to detail the processes and procedures adopted by Veolia to identify,

manage and control construction environmental aspects and impacts associated with the Project.

The project area contains significant environmental values, including threatened flora species,

aboriginal artefacts and significant amounts of native vegetation.

1.2 Scope and Objectives

This CEMP responds to the Environmental Management Strategy (EMS) required under CoDC

Schedule 4, condition 1 for construction phase of the Project. Approval has been obtained from the

Secretary under CoDC Schedule 4, condition 3 to phase the submission of the EMS. Three stages

have been approved namely construction, commissioning and operations.

This Construction EMS includes:

the strategic framework for environmental management of the Project;

identification of the statutory approvals that apply to the Project;

description of the role, responsibility, authority and accountability of all key personnel

involved in the environmental management of the Project;

describe the procedures that will be implemented to:

o keep the local community and relevant agencies informed about the construction and

environmental performance of the Project;

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

o resolve any disputes that may arise;

o respond to any non-compliance;

o respond to emergencies;

copies of any plans required under the CoDC; and

a clear plan depicting all the monitoring to be carried out in relation to the Project

construction.

While the Environmental Management Strategy is predominantly an externally oriented document,

containing commitments to specific stakeholders, this CEMP is the chief internal document for

environmental management of construction and commissioning of the Project.

The objectives of this CEMP are to:

Provide a working environmental management tool to follow during the construction phase

of the Project;

Comply with relevant environmental legislation, including the Conditions of Development

Consent (refer to Appendix A) relating to the construction phase of the Project and the

recommendations provided in the Licensing Guide (EPA NSW, 2016);

Provide a means of implementing the recommended mitigation measures for the key

environmental issues, associated with construction of the Project, identified in the

Environmental Impact Statement (EIS) prepared by GHD in 2016;

Define roles and responsibilities of the project management team and contractors during the

construction phase of Project;




Provide a guide for the interaction with relevant government authorities and other relevant

stakeholders, including the community during the construction phase of the Project.

This CEMP and supporting management plans have been prepared to provide the management

measures to be implemented to minimise potential adverse impacts on the environment during the

construction phase of the Project.

This CEMP is a live document and outlines the management strategies and control measures which

will be reviewed and updated, where necessary, to reflect changes introduced by the construction

project team, site specific outcomes, non-conformances and recommendations arising out of

inspections, meetings and audits.

1.3 Supporting Management Plans

The Project has planned to take actions to address significant environmental aspects, compliance

obligations and the risks and opportunities they present, as well as its objectives. These have been

incorporated in the supporting management plans to provide the management and control measures

to be implemented to minimise potential adverse impacts on the environment.

These plans are listed below and presented as separate documents in Appendix B.

Water Management Plan (Refer to Appendix B1);

Biodiversity Management Plan (Refer to Appendix B2);

Aboriginal Cultural Heritage Management Plan (Refer to Appendix B3);

Construction Noise Management Plan (Refer to Appendix B4);

Construction Traffic Management Plan (Refer to Appendix B5);

Stakeholder Management Plan (Refer to Appendix B6);

Construction Waste Management Plan (Refer to Appendix B7).

1.4 Veolia’s Overall Management System

Veolia has developed and implemented a Business Management System (BMS) to assist in meeting

the corporate objective of its water operations through sustainable development.

In the case of the CEMP and environment programs in Veolia generally, ISO 14001:2004 and ISO

31000:2009 are used as the base standards when constructing environmental systems for each

project. Veolia has an excellent environmental management record of accomplishment and will bring

to the project companies and personnel with substantial experience of delivering outstanding

environmental performance.

The integrated structure is described in Figure 1 below.




Figure 1 – Integrated Services Management Flowchart

Contractor will manage construction works under Abergeldie’s Integrated Management System

(AIMS). AIMS brings together and cross-references safety management, environmental management

and quality management systems, which are all third party certified to ISO and AS/NZS standards.

Contractor’s environmental obligations for the Project include compliance with applicable

environmental legislation and guidelines including Veolia’s environmental policies and procedures,

and requirements and commitments of the project governance documents outlined in this plan.

1.4.1 Environmental policies

Veolia’s business strategy is guided by five elements: our business, our customers, our people, our

environment and our community. These elements shape all aspects of Veolia’s current and future

performance. Its corporate policies and practices are linked to delivering excellence in one or more of

these elements.

Veolia has developed a suite of company-wide policies in support of the sound management of its

facilities. All policies have been endorsed by Veolia’s Executive Committee and are reviewed

periodically. All Veolia employees are required to commit to the implementation of these policies.

Veolia environmental policies support minimisation of emissions to land, air and water and the wise

use of natural resources. This commitment is documented in Veolia’s environmental and

sustainability policies (see below).

1.4.1.1 Environment policy

Veolia is committed to minimising the environmental impacts of its operations and continually

improving its environmental performance within a framework of sustainable development by:

effectively managing our significant environmental impacts, monitoring progress and

reviewing environmental performance against objectives and targets on a regular basis

driving continual improvement, and meeting the requirements of ISO 14001 environmental

management systems standard as part of the integrated business management system




complying with applicable environmental legislation, contractual and other necessary

requirements related to our activities and assist customers and suppliers to use products

and services in an environmentally sensitive way

striving to ensure that our policies, objectives and achievements are communicated to all

persons working for and on behalf of the business and to educate and train employees and

ensure competence in environmental issues and the environmental effects of their activities

preventing pollution and harm to the natural, heritage and built environments and to reduce

the use of all raw materials, energy and supplies

consulting with relevant stakeholders, taking into account local environmental conditions and

working with local communities to achieve shared and lasting outcomes.

All managers, employees, contractors and visitors are responsible for being aware of, and complying

with this policy.

1.4.1.2 Sustainability policy

For Veolia, sustainable development means adopting business strategies and activities that meet the

needs of Veolia and its stakeholders today, while protecting, supporting and enhancing the human

and natural resources that will be needed in the future. This outcome is expressed clearly in Veolia’s

Sustainability Policy:

Being ethically responsible, to create value in what we do, and to use sound risk and hazard

management principles in conducting our business. As part of its ‘non-negotiables’ Veolia

will comply with all relevant legislation including pollution prevention and will strive to

develop and improve our integrated business management system to support a consistent

and disciplined approach to business processes. We will ensure that appropriate resources

(both internally and externally) are utilised to assist in achieving our goals.

Partnering in innovation and to understand and support our customers in achieving their

business objectives.

Attracting and retaining diverse and talented employees. This will include providing

development opportunities so our employees are continually learning, communicating,

providing workplace consultation, and creating an ‘Always Safe’ workplace, with an

aspiration of no workplace injury or illness for our employees, visitors and contractors.

Continually designing and implementing sustainable solutions to develop access to

resources and to protect and replenish them. Additionally, Veolia is committed to providing

environmental leadership in its operations and solutions, which includes the management of

its own environmental impacts, improving waste, water, energy and carbon outcomes, as

well as protecting and conserving biodiversity and natural capital.

Working closely with local communities to achieve shared and lasting outcomes. Additionally

Veolia will engage with government, policy makers, advocacy groups, industry associations

and other stakeholders in the areas which we operate to create better value and outcomes

in sustainable practices.




SECTION 2 STATUTORY AND POLICY CONSIDERATIONS

This section provides an overview of the environmental planning and statutory context for the

construction of the Project. It also provides a discussion of the Project construction in the context of

Veolia’s corporate environmental and sustainability policies.

Veolia is committed to complying with all of its legal obligations and other voluntary commitments

made by the company. Compliance to applicable regulatory requirements concerning the

construction of the Project will be achieved through:

identifying and accessing legal and other requirements which are directly applicable to the

organisation;

consulting and involving relevant government agencies;

internally communicating relevant information regarding legal and other requirements;

continually auditing, reviewing and upgrading company systems, management plans and

supporting documentation; and

providing relevant training.

2.1 Relevant Environmental Legislation

2.1.1 Acts and regulations

This CEMP has been developed in the context of the following key NSW legislation:

2.1.1.1 Environmental Planning and Assessment Act 1979

PAC reviewed this State Significant development (SSD 7592) and the two related modifications and

granted Development Consent for the ‘State Significant’ development on 19 June 2017 in

accordance section 89(E) of the Environmental Planning and Assessment Act 1979 (EP&A Act).

These conditions are required to:

prevent, minimise, and/or offset adverse environmental impacts including economic and

socials impacts;

set standards and performance measures for acceptable environmental performance;

require regular monitoring and reporting;

provide for the ongoing environmental management of the Project.

2.1.1.2 Protection of Environment Operations Act 1997

The main object of the Protection of Environment Operations Act 1997 (POEO Act) is to regulate air,

noise, water and land pollution. As well as imposing a general requirement not to cause pollution, the

Act also allows pollution to occur through a system of licensing. Both the mines and power station

are licenced under the POEO Act.

The EIS confirms that the Project will require the modification of existing Environment Protection

Licences (EPL) held for the Springvale Mine, Angus Place Colliery and the MPPS.

The EPL modifications are required to allow the transfer of mine water to the new WTF and for the

transfer and management of residuals and brine to the Springvale Coal Services Site and MPPS.

The Springvale Mine EPL will also be required to be modified to amend the timeframes to achieve

Mine Water discharge limits for the Springvale Mine (which replicate the modification being sought in

relation to the Springvale Mine Extension Planning Approval discussed in the EIS).




Consultation has been undertaken with the EPA regarding EPL requirements for the Project and the

EPA has confirmed that the EPL is not required for the construction and operation of the Project

under Schedule 1 of the POEO Act. As noted above the Project will result in modifications to the

existing EPLs of MPPS and mining facilities. (Refer to Appendix C – The EPA’s email with

clarification).

2.1.1.3 Water Management Act 2000

The Water Management Act 2000 aims to facilitate the sustainable and efficient use of water in such

a way that benefits the environment and communities.

The Water Management Act 2000 provides for the preparation of water management plans that

outline arrangements for water sharing, water source protection and drainage management. The

Proposal site is located within the area covered by the 2010 Metropolitan Water Plan (NSW Office of

Water, 2010); the key aims of which are to:

provide a secure supply of water to meet the medium-term needs of Sydney, while planning

for long-term goals;

protect the health of Sydney’s rivers;

ensure water supplies are adequate throughout drought.

The construction of the Project will have a minimal impact on the quality and quantity of water

discharged from the Site, and will minimise the demand for potable water at the Site.

2.1.1.4 Waste Avoidance and Resource Recovery Act 2001

The Waste and Resource Recovery Act 2001 (WARR Act) is the principal piece of legislation

governing waste and resource management in NSW. The Act seeks to maximise the utility of

resources including waste, and minimise disposal of resources to landfill. A Waste Management Plan

has been prepared in consideration of the objectives of the WARR Act including:

encouraging the most efficient use of resources;

reducing environmental harm;

ensuring that resources are managed against the waste hierarchy of avoidance, resource

recovery, and then disposal;

diversion of waste from landfill;

ensuring industry takes part in reducing and dealing with waste;

achieving integrated, state-wide waste and resource management planning and service

delivery.

2.1.1.5 Contaminated Land and Management Act 1997

The principal object of the Contaminated Land Management Act 1997 (CLM Act) is to establish a

process for investigating and, where appropriate, remediating land that the Environmental Protection

Authority (EPA) considers to be contaminated significantly enough to require regulation. Under the

CLM Act, contamination of land is defined as:

“the presence in, on or under the land of a substance at a concentration above the concentration at

which the substance is normally present in, on or under (respectively) land in the same locality, being

a presence that presents a risk of harm to human health or any other aspect of the environment”

(CLM Act, s5).




Land may be considered contaminated even if it became contaminated partly, or entirely, by the

migration of contaminants into, onto or under the land from other land.

The soil at the WTF site shows elevated levels of some contaminants and further investigations into

the site are planned including the installation of groundwater monitoring wells. Based on the results

of further investigations the WTF site may require some remediation before construction. A

Remediation Action Plan will be developed and implemented if required.

2.1.1.6 Roads Act 1993

The objectives of the Roads Act 1993 are to:

set out the access rights to public roads;

establish procedures for opening and closing public roads;

provide for the classification of roads;

establish the Roads and Maritime Services and confer functions associated with road works

and maintenance to the Roads and Maritime Services and other roads authorities.

The Act regulates the carrying out of various activities on public roads. Approval under the Act would

be required for any pipeline crossings of public roads and for any temporary modifications to traffic

arrangements (eg. lane closures) to allow construction to be undertaken.

2.1.1.7 Forestry Act 2012

The main objective of the Forestry Act 2012 is to authorise forestry activities and for the management

of Crown timber land and land owned by the Forestry Corporation of NSW.

As the pipeline will be partially located on land owned by the Forestry Corporation of NSW, an

occupation permit (or a modification to the existing permit) will be required.

2.1.1.8 Work Health and Safety Act 2011

The main object of the Work Health and Safety Act 2011 (WHS Act) is to provide for a balanced and

nationally consistent framework to secure the health and safety of workers and workplaces by:

protecting workers and other persons against harm to their health, safety and welfare

through the elimination or minimisation of risks arising from work or from specified types of

substances or plant;

providing for fair and effective workplace representation, consultation, cooperation and issue

resolution in relation to work health and safety;

encouraging unions and employer organisations to take a constructive role in promoting

improvements in work health and safety practices, and assisting persons conducting

businesses or undertakings and workers to achieve a healthier and safer working

environment;

promoting the provision of advice, information, education and training in relation to work

health and safety

securing compliance with this Act through effective and appropriate compliance and

enforcement measures;

ensuring appropriate scrutiny and review of actions taken by persons exercising powers and

performing functions under this Act;

providing a framework for continuous improvement and progressively higher standards of

work health and safety;




maintaining and strengthening the national harmonisation of laws relating to work health and

safety and to facilitate a consistent national approach to work health and safety in this

jurisdiction.

The Act requires that workers and other persons should be given the highest level of protection

against harm to their health, safety and welfare from hazards and risks arising from work or from

specified types of substances or plant as is reasonably practicable.

2.1.2 Project Specific Applicable Regulatory Requirements

An Environmental Impact Statement (EIS) for Project has been prepared by GHD Pty on behalf of

Springvale Coal Pty Ltd and NSW EnergyAustralia Pty Ltd to support the development application.

The EIS has been prepared using a risk-based assessment approach to identify and evaluate

environmental, social and economic aspects associated with the Project.

This has been achieved through a process of ongoing engagement with stakeholders from

government agencies and the community, risk assessment to identify and scope key environmental

assessments of the impacts and development of appropriate safeguards to mitigate any such

impacts for the Project.

2.2 Other Requirements

2.2.1 Relationship of the CEMP to ISO 14001:2004

As discussed in Section 1.4, this CEMP forms the basis of the EMS for the construction phase of the

Project. The CEMP is consistent with ISO 14001:2004 Environmental management systems -

Requirements with guidance for use.

2.2.2 Other Requirements

In addition to the requirements discussed above, this CEMP is being developed in accordance with

the Guideline for Preparation of Environmental Management Plans (DIPNR, 2004). Other

environmental standards, guidelines and documentation are included in the relevant supporting

management plans, which are included as appendices to the CEMP.




2.3 Summary of Licensing and Permit Requirements

Table 2 provides a summary of the Licence and Permits that will require, in addition to Development Consent for the Project construction.

Table 2 – Licencing and Permitting Requirements

Legislation/ Guideline Approval/ Licence

Assessment Authority

Status Responsibility

Road Act 1993

(section 138) Approval RMS

Approval to construct pipeline across highway reserve

Contractor

Road Act 1993

(section 183)

Consent

(Road Occupancy Licence)

RMS

Contact RMS to determine if the Licence is required.

If required, the Licence to be issued prior to works commencing within three (3) metres of the travel lanes in the Castlereagh Highway

Contractor

Road Act 1993

(section 138) Approval

Lithgow City Council

Approval to construct pipeline across local road reserve

Contractor

Road Act 1993

(section 183)

Consent

(Road Occupancy Permit)

Lithgow City Council

Permit to be issued prior to works commencing on Wolgan Rd

Contractor

Crowns Land Act 1989 Approval Lithgow City Council

Approval to be issued prior to any groundwater extraction

Contractor

Forestry Act 2012

(section 60)

Occupational Permit

Forest Corporation

Permit to be issued prior to works commencing within Newnes State Forest

Customer

Water Management Act 2000 and Water Act 1912

Approval NSW Office of Water

Approval to be issued prior construction of pipeline infrastructure within 40m of water source

Contractor

Inclosed Lands Protection Act 1901

Consent/Lease Agreement

Owner of the Land (Janette Winifred Hunt)

Consent to assess the land to be issued prior construction of pipeline infrastructure

Customer



Owner of the Land (Springvale Centennial)

Consent to assess the land to be issued prior construction

Customer



Owner of the Land (EnergyAustralia)

Consent to assess the land to be issued prior construction

Customer

2.4 Conditions of Development Consent

Refer to Appendix A for the conditions of the Development Consent for the Project. Conditions of approval relevant to the construction phase have been incorporated within this CEMP.

A Pre-Construction Compliance Report (refer to Appendix D) details the relevant conditions of

consent addressed in each supporting management plans which address the management and

control measures to be implemented in a manner to minimise adverse impacts on the environment

during construction phase.




Condition 1 and 2 of Schedule 4: Environmental Management and Reporting of the Development Consent provide details regarding the Environmental Management Strategy and Management Plan Requirements for the Project, as outlined in Table 3 below.

Table 3 – Development Consent Requirements

Relevant Conditions of Consent

(Schedule 4) Definition

CEMP Document Reference

Environmental Management Strategy

1

Prior to the commencement of construction, the Applicant must prepare an Environmental Management Strategy for the development to the satisfaction of the Secretary. This strategy must:

1 (a) provide the strategic framework for environmental management of the development Section 1.2

1 (b) identify the statutory approvals that apply to the development Section 2

1 (c) describe the role, responsibility, authority and accountability of all key personnel involved in the environmental management of the development Section 4.1

1 (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 development;

receive, handle, respond to, and record complaints;

resolve any disputes that may arise;

respond to any non-compliance;

respond to emergencies

Sections 4.4-4.8

1 (e)

and include:

copies of any plans approved under the conditions of this consent; and

a clear plan depicting all the monitoring to be carried out in relation to the development.

Section 1.3

Section 5

1 Following approval, the Applicant must implement the Environmental Management Strategy Section 1.1

Management Plan Requirements

2 The Applicant must ensure that the management plans required under this consent are prepared in accordance with any relevant guidelines, and include:

2 (a) detailed baseline data Section 1.1

2 (b)

a description of:

the relevant statutory requirements (including any relevant approval, licence or lease conditions);

any relevant limits or performance measures/criteria;

the specific performance indicators that are proposed to be used to judge the performance of, or guide the implementation of, the development or any management measures

Section 2

Section 4.9

Section 4.9

2 (c) a description of the measures that would be implemented to comply with the relevant statutory requirements, limits, or performance measures/criteria Section 3.5

2 (d)

a program to monitor and report on the:

impacts and environmental performance of the development;

effectiveness of any management measures (see c above)

Section 5.1

2 (e) a contingency plan to manage any unpredicted impacts and their consequences Section 4.10

2 (f) a program to investigate and implement ways to improve the environmental performance of the development over time Sections 5.2

2 (g)

a protocol for managing and reporting any:

incidents;

complaints;

non-compliances with statutory requirements; and

exceedances of the criteria and/or performance criteria; and

Section 4.6




Relevant Conditions of Consent

(Schedule 4) Definition

CEMP Document Reference

2 (h) a protocol for periodic review of the plan. Section 5.3

Annual Review

5

By the end of March each year, the Applicant must submit a review of the environmental performance of the development for the previous calendar year to the satisfaction of the Secretary. This review must:

Section 4.11.2

5 (a) describe the development (including any rehabilitation) that was carried out in the past year, and the development that is proposed to be carried out over the next year; Section 4.11.2

5 (b)

include a comprehensive review of the monitoring results and complaints records of the development over the past year, which includes a comparison of these results against the:

relevant statutory requirements, limits or performance measures/criteria;

monitoring results of previous years; and

relevant predictions in the EIS.

Section 5.3

5 (c) identify any non-compliance over the last year, and describe what actions were (or are being) taken to ensure compliance; Sections 5.2&5.4

5 (d) identify any trends in the monitoring data over the life of the development; Section 5.3

5 (e) identify any discrepancies between the predicted and actual impacts of the development, and Section 5.3

5 (f) analyse the potential cause of any significant discrepancies; and Section 5.3

5 (g) describe what measures will be implemented over the next year to improve the environmental performance of the development Section 5.3

Progress Reporting

7 The applicant must monitor the status of the development and submit a quarterly progress report to the Secretary. The Report must:

7 (a) be submitted within 3 months of 19 June 2017 and every 3 months thereafter until the opration of the Water Treatment Plan; Section 4.11.1

7 (b) describe the development (including any construction) that was carried in the past 3 months, and development that is proposed to be carried out over next year; Section 4.11.1

7 (c) Identify any poetical delays and describe measures to ensure that the Water Treatment Plan is operational by July 2019: and Section 4.11.1

7 (d) Be made publically available on the Applicant’s website;

to the satisfaction of the Secretary Section 4.11.1




SECTION 3 PROJECT OVERVIEW

3.1 Project Overview

The Project includes the following major elements:

A system to transfer (approximately 15 km ) up to 42 ML/day of dewatered mine water from

the existing gravity tank forming part of the approved dewatering facilities on the Newnes

Plateau to a new WTF to be located at the MPPS site (see Figure 2 below).

A WTF incorporates desalinisation processes to reduce the salinity in mine water to a

standard suitable for either industrial reuse or environmental release.

Transfer of treated water from the water treatment plant to the MPPS cooling water to

contribute to the demand for make-up water.

Transfer via a new 2.4 km pipeline and discharge of any excess treated water not able to be

reused within the MPPS cooling water system to Thompsons Creek Reservoir.

Transfer of residual material from the pre-treatment process to the existing reject

emplacement area (REA) at the Western Coal Services Site.

Installation of a crystalliser to provide further treatment of the additional salt load generated

within the MPPS cooling water blowdown system.

Figure 2 – Project Overview

3.2 Project Location

Springvale Mine is underground coal mine located in the western coalfield of NSW, approximately 15

kilometres (km) west of Lithgow. The MPPS located about 8 km west of the Springvale Mine pit top

at Lot 363 Boulder Road, Blackmans Flat, NSW (see Figure 3).




Figure 3 – Project Location

3.2.1 Property

The remainder of the Project is located within land owned or under access agreements with the

Springvale (unincorporated joint venture with participants Centennial Springvale Pty Limited (as to

50%) and Springvale SK Kores Pty Limited (as to 50%)) and land owned by Energy Australia Pty Ltd.

Construction of the pipeline for the Project is predominantly located on Springvale owned lands as

shown in Figure 4 some section of the pipeline will across land owned by Forestry Corporation of

NSW, Crown lands and privately owned property. Approval for access these lands will be obtained

subject to compliance of this Plan (Refer to section 2.2).

Figure 4 – Land Ownership




3.2.2 The Project Application Area

The Project Application area comprises a number of infrastructure elements primarily including a

10m wide linear pipeline corridor extending between the existing Gravity Tank on Newnes Plateau

and the Water Treatment Plant location within the MPPS site.

The Project application area is partially situated within the Newnes State Forest, extending from the

east on Newnes Plateau to west into lower lying vegetated and disturbed lands. In these portions of

the Project application area, connected vegetation occurs for a distance of greater than two

kilometres to the north, east and south-east. Being a State Forest in these portions of land, the native

vegetation is periodically selectively logged but there are no areas of clear felling of native

vegetation.

The Newnes State Forest is connected to the Gardens of Stone National Park and Wollemi National

Park to the north, Blue Mountains National Park to the east and Ben Bullen State Forest to the north-

west.

The western half of the Project application area is situated on largely disturbed lands due to existing

farming lands, roads, easements and mining lands. Remnant vegetation exists to the south of the

pipeline, which tentatively connects to the northern side. Castlereagh Highway creates a wide

disconnection between vegetation tracts further north, and that situated to the north of these western

portion of the Project application area.

The proposed water treatment plant site at MPPS has been extensively cleared and modified for

construction of the power station and associated infrastructure.

3.3 Project Phases

The implementation of environmental controls for specific risks will be applied through various

phases of the Project. Key project phases, where environmental controls and opportunities will be

assigned to implementation, are:

Pre-construction: planning, design and procurement phases (August 2017–October 2017);

Construction: delivery phase of the project, includes vegetation removal and earthworks

(October 2017–December 2018).

Commissioning: commissioning phase of the project includes testing of all systems and

components of industrial plant to according to the operational requirements (January 2019–

May 2019);

Operation: operational phase of the project includes accepting and treating mine water at the

water treatment facility according to the operational requirements (June 2019–June 2034).

Post-construction; occurs in sections of the project area which are no longer required for construction

activities. At this stage, project areas will be re-instated to their previous condition, including re-

instatement of vegetated areas.

The Construction period of the Project would be approximately 19 months, commencing in October

2017.




3.4 Construction Hours

The proposed construction activities will be restricted to the construction hours specified in Table 4.

Table 4 – Construction Operating Hours

Activity Day Hours

Construction

Monday - Friday 7:00am – 6:00pm

Saturday 8:00am – 1:00pm

Sunday & Public Holidays At no time

3.5 Predicted Construction Impacts

Construction environmental impacts for the project were identified and evaluated in the EIS through

reviewing the Project in the context of the existing environmental and operational settings within

western coalfields; engagement with government and community stakeholders and through a

preliminary environmental risk assessment process.

A summary of the key potential environmental impacts that will require management prior to, during

and post-construction of the project, are listed below and form the basis of the environmental risk

assessment.

3.5.1 Surface Water Quality

Sensitive receptors located in proximity to the Project application area include Wangcol Creek and

Coxs River. Erosion and sediment controls will be developed for the both the WTF site and for

installation of the WTS in accordance with Managing Urban Stormwater: Soils and construction 4th

edition. “The Blue Book”. Erosion and sediment controls will be implemented to avoid pollution of

waterways and the MPPS stormwater system.

To ensure suitable control are addressed during the construction, management strategies for

disturbance of soil on site, sedimentation and erosion control measures have been detailed in the

Water Management Plan (Refer to Appendix B1).

3.5.2 Biodiversity

A comprehensive biodiversity assessment was undertaken for Project as part of the EIS, which

included survey effort, desktop analysis.

The key biodiversity impacts of the project relate to the clearing of vegetation in a 10 m wide linear

pipeline corridor extending between the existing Gravity Tank on Newnes Plateau and the WTF.

Project will trigger the following direct impacts:

removal or modification of up to 27.84 ha of native vegetation and associated habitat for

threatened fauna species with potential to occur in a 10 m wide linear pipeline corridor;

removal of approximately 67 hollow bearing trees.

The impact assumptions will be confirmed prior to construction through the completion of

preclearance surveys to validate offsetting requirements.

However, by observing careful construction techniques through the course of Project construction

opportunity (i.e. use of pre-clearance surveys and minor route adjustment) exists to avoid impacts on

individual threatened plants and hollow-bearing trees. Biodiversity management strategy is described

in a Biodiversity Management Plan (Refer to Appendix B2).




3.5.3 Aboriginal Cultural Heritage

Based on the aboriginal cultural heritage assessment undertaken in the EIS, seven Aboriginal

Heritage sites were found in the vicinity of the Project application area. These include three artefact

scatters, three isolated finds and one scarred tree site. These are located within 30 meters of the

Project application area boundary; however, none is in the Project application area.

The project alignment has been modified since the EIS was prepared and now intersects with one of

the artefact scatter (AHIMS # 45-1-0237). Where the project alignment intersects with AHIMS # 45-1-

0237, the Project consists of a subsurface pipeline, approximately 8 metres underground. The

pipeline will be constructed with a directional drilling machine that will be launched approximately 300

metres away from the site. AHIMS #45-1-0237 will therefore be avoided by the Project. A ‘no go

zone’ will be installed around the site to ensure its protection from potential surface impacts.

The significance of these sites is low and no Aboriginal Heritage sites would be impacted by the

Project. Nonetheless, details of control measures to minimise potential impact on the aboriginal

cultural heritage are outlined in the appended Aboriginal Cultural Heritage Management Plan (Refer

to Appendix B3).

3.5.4 Noise and Vibration

A noise and vibration impact assessment was undertaken in the EIS for the construction phase of the

Project associated with construction activities at potentially affected receivers.

The noise levels are predicted to meet the Interim Construction Noise Guideline, (DECC, 2009) at all

the times and at all identified residential receiver locations.

Based on EIS modelling, it is not anticipated that excessive noise impacts will occur at residential

receivers throughout the construction program. Any likely exceedance has been identified to be

limited to the receivers located along pipeline route subject to short-term elevated noise levels during

pipeline trenching and construction.

In the event of noise exceedances or complaints received, a review of construction activities, plant

and equipment will be undertaken to resolve the issue. Noise management and mitigation measures

are outlined in the appended Construction Noise Management Plan (Refer to Appendix B4).

No vibration impacts on human comfort and structural damage are expected. Nonetheless, details of

control measures to minimise potential vibration impacts are outlined in the appended Construction

Noise Management Plan (Refer to Appendix B4).

3.5.5 Traffic and Transport

An assessment of the traffic and transport impacts was undertaken as part of the EIS for the

construction phase of the Project. The Project will generate additional vehicles movements on the

Castlereagh Highway, Chifley Road, Newnes State Forest Road and it is considered to have

negligible traffic impacts.

The Castlereagh Highway is expected to continue to operate within the Roads and Maritime Services

recommended operating performance standards.




A risk assessment will be undertaken for the site to identify the potential traffic hazards by the

Contractor at the commencement construction works, and any changes required to the management

strategies will be reported. The risk assessment will be updated as required during the construction

works. Traffic management strategies outlined in the appended Construction Traffic Management

Plan (refer Appendix B5).

3.5.6 Other Environmental Impacts

3.5.6.1 Soils and Contamination

The Project construction includes boring, pipeline trenching and clearing, regrading and building

infrastructure for the WTF and WTS. The WTF application area contains significant amount of fill

(mine overburden).

Jacobs was commissioned by Veolia to undertake a Baseline Contaminated Site Investigation (BCSI)

for portions of land to be occupied by the WTF and the WTS associated with the Project in August

2017.

The objective of the BCSI was to assist Veolia in obtaining sufficient information to assess baseline

soil and groundwater contamination conditions of the site (comprising the WTF and the WTS) to

support both the lease agreement and ongoing environmental monitoring requirements during

operation of the WTF and WTS. The BSCI assumed that the WTF sites will be considered a

commercial industrial land use. For the WTS there would a variety of different land uses from

commercial/industrial in the coal services areas and to natural land uses in the Newnes State Forest.

Based on the results of the fieldwork program, site observations and results of the laboratory

analysis, contamination was not identified in soils beneath the WTF or the WTS that would impact

upon construction and/or operation of the project in consideration of a commercial / industrial land

use.

Based on the results of the BCSI, the risk of existing significant contamination being present at the

WTF site areas that will be disturbed by construction and operations of the facility is considered to be

low. Should surplus material be generated during construction of the project and requires off-site

disposal, this material will be classed the NSW Waste Classification Guidelines (EPA, 2014) and

disposed to a licensed facility.

Groundwater beneath the WTF sites contains elevated concentrations (i.e. concentrations above the site acceptance criteria) of some heavy metals and hydrocarbon compounds. This is likely to be from groundwater coming in contact with overburden material containing remnants of coal, however, this can not be conclusively determined. At the time of the BSCI, groundwater was only encountered in two groundwater wells (7 wells installed) to the limit of the investigation (approximately 10m bgl). These wells were located in the northern most portion of the WTF within the operational areas of the MPPS and therefore dewater in unlikely to be required.

However if groundwater levels increase and dewatering of groundwater is required to facilitate

construction, this water will need to be managed to prevent discharge and impacts to the fresh water

ecosystems of the Coxs River and associated tributaries (Wangcol Creek and Sawyers Swamp

Creek). Prior to any discharge of water (if encountered) during construction, water quality

investigations be undertaken to quantify actual risks (if present) to receptors and to assist in the

selection of appropriate disposal options.

In addition, the disturbed areas during construction phase will be progressively rehabilitated except

those areas where permanent access roads are being established.




To ensure suitable control are addressed during the construction, management strategies for

disturbance of soil on site, sedimentation and erosion control measures have been detailed in the

Water Management Plan (Refer to Appendix B1).

3.5.6.2 Bushfire Risk

Based on the assessment of bushfire risk undertaken as part of the EIS, it was defined as high risk of

fire being experienced during construction phase of the Project. The bushfire risk of the Project has

been reduced through incorporation of mitigation measures and avoidance measures in the design.

In addition, a Bushfire Risk Management Plan for construction phase of the Project has been

developed and outlined in the Biodiversity Management Plan (Refer to Appendix B2).

3.5.6.3 Construction Waste

Construction of the Project will generate waste in the form of packaging and excess materials,

wastewater and sewage from the worksites. Waste generated during commissioning of the WTF will

be managed in accordance with a Brine and Residuals Disposal Plan, which will be prepared to

satisfaction of the Secretary prior to the WTF commissioning.

Management strategies for waste generated during the construction phase of the Project is aimed at

implementing effective controls, correct classification and disposal methods including reuse and

recycling where possible and are detailed in the Construction Waste Management Plan . Any

materials deemed beyond their useful life shall be disposed at the appropriately licensed facility.

A Construction Waste Management Plan has been prepared in consideration of the Waste

Avoidance and Resource Recovery Act 2001 and is attached as Appendix B7.

3.5.6.4 Air Quality

There is potential for construction activities to cause impacts to the community, residential areas and

other dust sensitive receptors. However, the majority of dust generating activities will be undertaken

a significant distance from any sensitive receivers. Control measures, outlined in Table 5 below, will

be undertaken by Contractor to minimise dust emissions during construction of the Project and do

not result in nuisance to adjoining properties, significantly impact neighbouring amenity and health, or

result in excessive community complaints.

Environmental Site Inspection Forms will be used to report on effectiveness of dust control measures

and any additional mitigation measures that may need to implemented during adverse meteoroidal

weather conditions (high wind conditions).

Table 5 – Air Control Measures

Control Measures and Safeguards Responsibility Timing/ Frequency

Targets:

No community complaints regarding nuisance or health impacts resulting from dust generated by construction activities;

zero environmental fines or prosecutions relating to dust and air emissions.

Identify dust generating activities and dust-sensitive adjacent land uses prior to commencement of construction.

Environment Nominee Prior to commencement of construction

Prior to commencement of construction ensure appropriate mitigation measures are implemented for identified dust generating activities.


Provide advance notice to residents prior to commencing dust generating activities. Environment Nominee A minimum of five days in advance of planned dust generating activities.

Cesate of dust generating activities during adverse weather conditions Construction During high wind conditions





Mangers/Engineers

Limit vehicles to specified routes to construction sites and ensuring speed limits are adhered to.

Construction Mangers/Engineers

During construction

Use of dust suppression techniques if required such as watering to maintain moist conditions of exposed areas, works area and stockpiles.


During construction

Maintenance of any excavated soil stockpiles and handling areas in a condition which minimises windblown or traffic generated dust.


During construction

Stockpiles are to be located as far as practicable from sensitive receptors. Construction Mangers/Engineers

During construction

Construction equipment will be properly maintained to control smoke emissions from motor vehicles, which will not exceed 10 seconds after start up. Hire agreements will contain provisions to stand down equipment which has excessively smoky exhaust as defined by DECC.


Prior to commencement of construction

Minimise disturbed areas as much as possible Construction Mangers/Engineers

During construction

Progressively rehabilitate/seal disturbed areas to minimise the potential for windblown dust.


Immediately after working areas and access roads are constructed

monitoring and cleaning of roads as required by street sweepers; Construction Mangers/Engineers

During construction

Cover all loads leaving the site and importing materials to site in a manner which ensures that no dust or other material is emitted from the truck.

Foreman During construction

Switch off engines of plant parked next to residents and areas of sensitivity such as schools when not in operation.


Start-up of vehicles will, where practicable or relevant be undertaken away from areas of sensitivity such as schools.


Ensure that there is no open burning or incineration. Foreman During construction

In the event complaint is received regarding air quality, the Environment Nominee will conduct an

investigation to determine the potential parameters of influence that could have led to the

exceedance.

The investigation will examine:

the quantity of exposed areas, which may potentially generate dust;

whether there is potential to revegetate these areas;

whether there were any identified days of excessive high wind during this period;

the number of water-trucks operating within the area during the this period; and

an examination of construction activities conducted during this period.

If deficiencies are identified and non-compliances with the environmental requirements observed, an

Environmental Inspection Report or Environmental Improvement Notice will be issued and relevant

actions/mitigations will be enforced.

3.5.6.5 Greenhouse Gas

A Greenhouse Gas Assessment was undertaken in the EIS to identify activities and measure

emissions from the Project. Green gas emissions associated with the construction phase have not

been quantified. Nevertheless, the mitigation measures have been identified to minimise energy

usage during construction phase.




Mitigation measures, outlined in Table 6 below, will be undertaken by Contractor to minimise energy

usage during construction of the Project.

Table 6 – GHD Mitigation Measures


Targets:

To comply with National Greenhouse and Energy Reporting Scheme (2011).

Prior to commencement of construction ensure that earthmoving equipment and on-site vehicles are be fitted with exhaust controls in accordance with the Protection of the Environment Operations (Clean Air) Regulation 2010.


Ensure that the exhaust systems of construction plant, vehicles and machinery will be

maintained in accordance with manufacturer specifications. Construction Mangers/Engineers During construction

Ensure that the all trucks leaving the Site carrying waste will be filled to the maximum

amount allowable, depending on the truck size, to reduce the number of traffic movements

required.

Construction Mangers/Engineers During construction

Make certain that the only lighting left on overnight around the Site office will be security or

emergency/access lighting. Construction Mangers/Engineers

During construction

In accordance with the National Greenhouse and Energy Reporting Scheme (2011), the Contractor

or site nominee will also record all fuel, utility and materials used during the construction phase for

Veolia’s emissions reporting obligations.

3.5.6.6 Visual

Potential visual impacts and changes to the local amenity, as a result of the construction phase of the

Project, were assessed in the EIS.

This assessment indicated that during construction the visual impact would be minimal. Construction

works associated with the pipeline will move along the route and have potential impact on any one

area for a short period of time. Compounds and set down areas will be small in scale and established

for short durations.

The WTF infrastructure will not be visible form any towns including Portland and will be visible from

mine and MPPS sites.

Mitigation measures, outlined in Table 7 below, will be undertaken by Contractor to minimise visual

impacts during construction of the Project.

Table 7 – Visual Mitigation Measures


Targets

To ensure that outlined mitigation measures are implemented accordingly.

Design WTS to incorporate non-reflective material to help them blend into existing

environment. Project Manager Prior to commencement of construction

Complete construction work in accordance with construction program to minimise any

delays. Construction Mangers/Engineers During construction

Remove all waste generated by proposed work from site as soon as it is practicable and

disposed appropriately. Construction Mangers/Engineers During construction

Rehabilitate trenched section of pipeline on the Newnes Plateau as soon as practicable

following pipeline installation. Construction Mangers/Engineers

During construction

Replace, repair, re-instate or restore a surface and/ or property disturbed or damaged by

the proposed works to pre-existing or better conditions prior to works re-commencing. Construction Mangers/Engineers

During construction





Remove all vehicles, construction equipment, material and refuse relating to the works on

completion of works. Construction Mangers/Engineers

At the completion of construction

Maintain the site in an orderly manner and ensure the construction site is kept tidy and

rubbish free. Foreman During construction

Minimise the spread of materials stockpiles, waste and vehicle parking. Construction Mangers/Engineers

During construction

Prior to commencement of construction ensure that finishing and colours for WTF will be

similar to existing buildings at the MMPS to assist with blending into its setting. Project Manager

Prior to commencement of construction

3.5.6.7 Non - Aboriginal Cultural Heritage

A review of applicable State and Federal heritage register was undertaken to identify any non-

aboriginal heritage items within vicinity of the proposed site. There are two historic non-aboriginal

heritage items identified in or abutting the Project application area: the Cottage (I191) and the

European Surveyor’s Tree (EST JN1).

Based on the assessment of construction impacts on any non-aboriginal heritage has been

undertaken as part of the EIS, it was noted that these items of heritage significance adjoin to the

project application area and thus are unlikely to be directly impacted by the Project. Mitigation

measures, outlined below, will be undertaken to minimise impacts to no-aboriginal heritage during

construction of the Project.

Should an item of non-aboriginal heritage significance, or suspected significance, be discovered

during construction, all work in the vicinity of the area will cease and the Project Environmental

Nominee will be contacted as soon as possible to determine the subsequent course of action. In the

event that suspected human skeletal remains are discovered, all works will cease and the NSW

Police and the NSW Coroner’s office will be contacted.

3.5.6.8 Socio-Economic

Based on the assessment of construction impacts on any socio-economic has been undertaken as

part of the EIS, it was noted that construction of Project may have the potential impacts on local

residents located within 650 meters of the WTS construction through temporary increase in noise

and dust levels. The community engagement strategy and communication pathways have been

developed and are outlined in section 4.4 of this Plan.

SECTION 4 IMPLEMENTATION OF THE CEMP

It is essential that all personnel associated with the construction phase of the Project comply with the

legal, contractual and environmental requirements in this CEMP and other plans and legislation.

All necessary approvals with respect to the planning and implementation of the construction phase of

the Project will be obtained by Veolia and/or by the Contractor as directed in section 2.2 of this Plan.

All relevant conditions of licences, permits, consents and approvals are to be adhered to during

construction phase. Copies of all licences, consents, permits and approvals will be held on site.

4.1 Roles and Responsibility

Environmental management is the responsibility of all individuals and organisations involved with the

Project. Project personnel and subcontractors will be made aware of environmental issues for the




Project and their responsibilities through induction, training and awareness methods detailed in

Section 4.3 below.

The roles and responsibilities of personnel specifically responsible for implementation of this CEMP

are summarised in Table 8 below. This includes the Environment Nominee, who is appointed by the

Project Manager to control implementation of this CEMP. The Environment Nominee is granted

authority by the Project Manager to stop a particular task or activity in circumstances where

environmental controls have not been implemented to prevent harm to the environment, or

environmental controls have been shown to be ineffective or inadequate. In such circumstances, the

Environment Nominee will prescribe corrective action that will be implemented before work

recommences.

Consultants (e.g. Egologist, Environmental Planner, and Designer) will be appointed for the duration

of the Project when required to work alongside environmental personnel, construction personnel

WTF designers and engineers to advise on aspects of WTF and WTS design/construction, culverts,

chutes, drains, lining materials and timing and assist with environmental issues.

Table 8 – Summary of Key Roles and Responsibilities

R – Responsible, A – Accountable, C – Consult, I ‐ Informed

Responsibilities and Accountabilities P

roje

ct M

anag

er (

PM

)

En

viro

nm

ent

No

min

ee

Co

nst

ruct

ion

Man

ger

s/E

ng

inee

rs

Su

per

viso

rs/

Su

per

inte

nd

ent/

Fo

rem

an

Wid

er p

roje

ct T

eam

Ultimately responsible for environmental management performance of the Project R A C C I

Review, authorise and ensure implementation of the CEMP R R C I I

Assign environmental responsibilities to project personnel I R A C I

Ensure appropriate environmental training is identified and training is provided to project personnel where required C R C I I

Monitor environmental performance to ensure compatibility and continued effectiveness with the policy and objectives

A R C I I

Participate in the review of the Project's Environmental Management System C R A I I

Ensure correct and ongoing implementation of CEMP C R A C I

Liaise with project staff for ongoing monitoring and maintenance of environmental controls C R A C C

Ensure reporting of near misses, non‐conforming incidents and practices C R A A C

Conduct and report regular inspections and monitoring requirements I R C C I

Ensure actions relating to environmental non‐conformances, incidents and/or inspections are

actioned and closed out in a timely manner I R C C I

Actively participate in and facilitate SQE Risk Management workshops I R C I C

Assist with updating of CEMP as required I R C I I

Prepare Project monthly environmental reports I R C I I

Liaise with client environmental representative C R A I C

Manage and track compliance with all statutory requirements, environmental approvals, licences, and permits relating to the project

C R A I C




R – Responsible, A – Accountable, C – Consult, I ‐ Informed

Complaints management in consultation with Community and Stakeholder Manager, where it related to complaints of an environmental nature.

I R C I C

Ensure environmental controls are established prior to commencement of construction activities C R A A C

Ensure ER participates in the preparation of SQE Risk Management documentation I R C I A

Identify and report environmental non‐conformance I R C C C

Ensure and verify that corrective action is taken when required for non‐conforming work I R A A A

Ensure that CEMP requirements are communicated to all personnel under his/her control C R C C C

Be aware of all approval/contractual conditions relating to his/her area of work R R R R R

Perform surveillance and monitoring of environmental controls to ensure that they are established and maintained

I R A A C

Ensure rectifications of environmental controls are carried out as required I R C C C

Comply with project approval and environmental management conditions C R A A C

Ensure no reuse of any materials into a receiving environment without prior approval I R A C C

4.2 Subcontractor Management

The relationship between Veolia, Contractor and subcontractors will be managed through an

overarching Project Management Plan (PMP). The PMP has been prepared by Veolia to cover all

activities from design to operations.

All Contractor and subcontractor personnel share responsibility with the Project team for

environmental management and performance. Veolia will ensure that relevant plans, procedures and

other documentations associated with the Environmental Management System are made available to

Contractor and subcontractors as required to fulfil any responsibilities they may have, and to

communicate any requirements or responsibilities to subcontractors.

All parties will manage their respective responsibilities for the ongoing implementation of the PMP

until the end of the project.




4.3 Training and Awareness

Environmental training and awareness will be provided as detailed in Table 9.

Table 9 – Training and Awareness Methods

Training Outcomes Responsibility

Inductions

Project personnel (including subcontractors) will undergo a Site Induction prior to commencement on site Inductions will include but are not limited to:

Purpose, objectives and key issues of the CEMP

Conditions of environmental licences, permits and approvals

Emergency response procedures and reporting processes for environmental incidents

Responsibilities and key contacts

Induction records will be maintained to confirm that all relevant personnel have been appropriately inducted

Inductions will be regularly reviewed and updated as required e.g. when significant changes occur on-site or within the environmental management framework of the project

Project Manger

Pre-start meetings

Pre-start meetings will be undertaken at the beginning of each day before work commences with all project personnel (including subcontractors as required) and managed by Contractor

Specific environmental issues relevant to the day’s work, e.g. working hours, will be raised and discussed at these meetings as required, and included in all SWMS/JSEA’s

Contactor

Toolbox meetings

Environmental awareness training will be provided to the workforce (including subcontractors) via weekly held toolbox meetings

Toolbox meetings will be recorded in the Project Pack

Any relevant outcomes or findings of environmental site inspections or audits shall be communicated to on ground personnel for improvements to be made

Positive feedback shall also be presented at these meetings

Contractor

Specialised Training

Spill prevention and control procedure

Erosion and sediment control plans

Vegetation clearing procedures

Awareness of waste management and the procedures to follow for proper waste recycling and disposal

Contractor

Internal Training Risk Based Investigation. Environment

Nominee

SQE Alerts. Distributed at tool box meetings and posted on notice boards Project Manager

4.4 Stakeholder Management Plan

Veolia is committed to meaningful stakeholder engagement. Key external stakeholders for the project

are state and local government departments and statutory authorities that are responsible for issuing

relevant environmental approvals and permits as well as community groups. Liaison with these

stakeholders at each phase of the project is critical to ensure that all of the legislative and statutory

obligations are met, all received complaints are investigated and addressed. Key stakeholders have

been consulted in the pre-planning phase and will continue to be consulted during, and in some

cases, after construction.




Ongoing consultation with the community will be undertaken to ensure that timely information is

provided to assist in minimising disruption or inconvenience. The Project Manager and Contractor will

be responsible for providing advance notice of changed traffic conditions, which may affect the local

community.

Given the minor nature of works external to the site, communication methods, which may be

considered, include:

letterbox drops to the local neighbourhood;

public notices in local newspapers;

direct consultation for individual properties identified as directly affected.

Details in relation to community liaison, complaints handling, reporting and record keeping,

applicable to the construction phase can be found in Stakeholder Management Plan (Refer to

Appendix B7).

4.5 Incident and Emergency Response

A key objective of this CEMP is to identify potential risks, and to develop, and maintain measures to

manage them. Notwithstanding this, Veolia recognises that unforeseen incidents can arise.

Veolia operates under an Emergency Response Plan whenever a major incident, emergency or crisis

could lead to public health, safety or environmental issues.

Veolia’s approach to incident and emergency response management includes:

Risk Analysis - The identification of hazards and risks that could impact the community,

environmental and operational implications.

Prevention – The planning and documentation of prevention and mitigation activities for all

major hazards, and allocation of responsibility for their implementation.

Preparedness – The development, implementation and review of specific incident

management plans and processes to manage identified risks, the training of staff, and

establishment of facilities to ensure the company can respond effectively to an incident.

Response – The issue of warnings and establishment of processes for effective notification

of incidents, and mobilisation of resources to combat the incident or threat.

Recovery – The return to normal operations, management of debriefs, and implementation

of lessons learnt from the response process.

The following priorities are adopted when combating an incident / crisis:

protection of human life and welfare;

protection of the environment; and

protection of Veolia’s assets.

4.5.1.1 Risk Assessment

The Veolia Board and executive management team are committed to a coordinated approach to risk

management throughout the company’s operations, ensuring any issues that could affect the

company’s and stakeholder’s performance, values, or reputation are identified and addressed.

The environmental risk management process used by Veolia is consistent with ISO 31000:2009 –

Risk Management and Veolia’s Risk Management procedure (PR-ANZ-13-444-2). The process is




implemented throughout the business and is focused on the following major environmental risks

categorise in Table 10.

Prior to the commencement of the construction works, Contractor will undertake a risk assessment to

identify the potential hazards and environmental risks and document in the Safe Work Method

Statement/ Job Safety & Environment Analysis (SWMS/JSEA) required work methods.

The risk assessment will be updated as required during the construction works and any changes

required to the management strategies shall be reported to Veolia.

Table 10 – Environmental Risks

Hazard Impacts (human

health&/or environment) Inherited

Risk Level Pre-emptive Actions

Residual Risk Level

Sediment laden water off site, including mud tracked onto roadways

Environment Medium Construction Environmental Management Plan (CEMP) - implement controls identified in the ESCPs (as detailed in the WMP)

Low

Pollution of land or stormwater from hydrocarbon spills from machinery or fuel storage

Human Health and/or Environment

Medium Plant Hazard Assessments;

Daily plant checklists ;

CEMP and supporting management plans implementation.

Low

Generation of dust from mobile equipment/vehicles and exposed areas


Medium Cessation of dust generating activities during adverse weather conditions (e.g. strong winds);

Limiting vehicles to specified routes to construction sites and ensuring speed limits are adhered to;

Dust suppression on site at all times ;

Trucks to cover loads.

Low

Impacts to local receivers (High School, properties, businesses) due to noise, vibration and visual pollution


Medium Comply with approved construction hours Communicate with staff and community the approved hours of work/ program;

Implement controls identified in the CNMP.

Low

Bushfire Human Health and/or Environment

High Implement management controls identified in the Bushfire Risk Management Plan

Medium

4.5.1.2 Incident Investigation

All incidents will be documented, and where required, due to the severity or ongoing nature of the

incident, investigations conducted and action plans established in order that the event does not occur

again by Contractor. Further guidance on when investigations are required is detailed in Figure 5

below; Veolia representative will be appointed to participate in an incident investigation as required.

Where lessons are learnt from the investigation or current procedures are identified as being

ineffective, the CEMP will be revised by ER to include the improved procedures or requirement. An

environmental investigation includes the following basic elements:

identifying the cause, extent and responsibility of the incident;

identifying and implementing the necessary corrective action;

implementing or modifying controls necessary to avoid a repeat occurrence of the incident;

identifying the personnel responsible for carrying out the above actions;

recording any changes in written procedures required.

4.6 Notification and Action Protocol

Any notifiable environmental incidents or potential incidents associated with the Project construction,

with actual or potential significant impacts on people or the biophysical environment, will be notified




as soon as practicable to DP&E, Lithgow City Council, other relevant agencies and Customer. This

notification will be followed by a written report within 7 days of the incident.

A notifiable environmental incident is a pollution incident where there is a risk of causing or

threatening material harm to the environment. A pollution incident includes a leak, spill or escape of a

substance or circumstances where this is likely to occur. Material harm includes onsite and offsite

actual or potential harm to:

the health or safety of humans;

the environment; or

property damage resulting in significant costs to remediate

If a notifiable environmental incident occurs, Veolia staff and Contactor will immediately notify one or more of the following personnel (refer Section 4.6.1.1 Emergency Contacts):

Project Manager

Environment Nominee

That person/s will then decide whether to notify Customer, DP&E or both. The Customer will notify

the EPA. Where these regulators are notified, other regulatory authorities that require notification

include:

Lithgow City Council within which jurisdiction the incident has occurred;

Ministry of Health;

Rural Fire Service;

Office of Environment and Heritage;

Forestry Corporation of NSW; and

Any other relevant authorities.

Table 8 below lists the mechanisms to be followed in the event that a pollution incident has the

potential to impact the surrounding community, in order to minimise the risk of harm.

Table 11 – Communication Mechanism

Pollution Incident Scenario

Potential Impacts What to do Who to Notify Communication

Mechanism

Sediment laden water, mine water, hydrocarbon or chemical entering stormwater drain/ discharge to environment

People and waterways environment

Bund area, block stormwater drain to prevent further pollution

Environment Nominee, Customer, Lithgow City Council, Immediately during clean-up of incident

Door knock

Telephone/ E-mail

Dust Air quality issues, loss of amenity

Cease works immediately Environment Nominee, Customer, adjacent businesses and school

Door knock

Telephone/ E-mail

Noise/Vibration Noise/Vibration, loss of amenity

Cease works immediately Environment Nominee, Customer, adjacent businesses and school, Lithgow City Council

Door knock

Telephone/ E-mail

Fire People and environment Cease works immediately Environment Nominee, Customer, Rural Fire brigade

Telephone

Door knock

4.7 Emergency Contacts

The following are the internal emergency contacts for the project construction, refer to Table 12 below.




Table 12 – Project Emergency Incident Reporting Contacts

Position Name Phone Number Email

Project Director Nick Stokes-Hughes +61 428 672 115 [email protected]

Project Manager Tom Roche +61 438 880 470 [email protected]

Environmental Representative Elena Ivanova +61 4155 566 20 [email protected]

4.8 Pollution Incident Management

Incidents will be responded to as outlined in the incident response flow chart (Figure 5).

In summary:

1. STOP WORK and NOTIFY INTERNAL Supervisor and Environment Reprsentative

2. PREVENT further environmental contamination/ spillage / pollution etc. (if safe to do so)

3. CONTAIN environmental contamination/ spill / pollution

4. CLEAN UP environmental contamination/ spill / pollution

5. NOTIFY EXTERNAL as described in section 4.6 of this Plan.

Figure 5 – Incident Response Flow Chart

Incident Occurs

Person who caused or discover the incident

Contact Project Manger, ER or Construction Manager and advise nature, extent and

exact location of incident

If it is safe to do so, attempt to control the incident, otherwise move to a safe location

and await further instruction

Assess Response Capability/ Notify external assistance if required

Log the incident and complete appropriate reporting measures via Vault, Veolia’s SHEQ

system/ Contactor incident management system

Proceed external notification, if required

Complete Incident Investigation and Reporting process

Review contingency measures and implement changes from the lesson

Ensure site is remediated/ clean up

mailto:[email protected]






4.9 Environmental Performance Criteria

The installation and maintenance of physical environmental controls on site will be the responsibility

of the Contractor, Project Manager and Supervisors. The environmental objectives and performance

criteria described in section 2 of this Plan are addressed in the supporting management plans for key

specific environmental aspect the Project. The objectives and performance criteria have been

developed based on Federal, State and Local Legislation, the Customer’s Project Scope

Requirements, the CoDC. They guide management and mitigation measures that minimise impacts

to identified environmental and social values, and guide performance, monitoring and contingency

plans for the project are outlined in Table 13.

Table 13 – Environmental Performance Criteria

Environmental Aspects

Objectives Performance Criteria

Aboriginal Cultural Heritage discovery of Aboriginal cultural heritage.

Comply with approved Cultural Heritage Management Plan (CHMP). Prevent accidental harm to previously undiscovered items of Aboriginal heritage items.

All pre – construction, during construction and post construction management recommendations within approved CHMP to be implemented. Follow contingency requirements set out within approved CHMP in the event of unexpected discovery of Aboriginal cultural heritage.

Water Quality

Minimise impacts to surface water.

Minimise erosion and sedimentation on site. Prevent sediment-laden water or material from site entering nearby environmental receptors including waterways, stormwater and vegetated areas.

Comply with Water Management Plan.

Integrate Water Sensitive Urban Design opportunities into the design to manage stormwater runoff from project site and Implement sediment controls in accordance with Managing Urban Stormwater: Soils and construction 4th edition. “The Blue Book”.

Implement the Water Management Plan.

Biodiversity Minimise impacts to native vegetation and fauna.

Restrict native vegetation removal to only that identified for approval.

Minimise impacts to fauna by using an appropriately qualified wildlife handler.

Minimise impacts to Tree Protection Zones for trees to be retained.

No increase in diversity or coverage of weed species within the construction corridor and immediate area.

Maintain habitat connectivity in surrounding landscape.

Implement the Biodiversity Management Plan which includes weed management mitigation measures.

Follow Vegetation Clearance Procedure.

Noise and vibration Minimise amenity impacts to local community/residents Implement noise and vibration control measures associated with construction in accordance with the Construction Noise Management Plan (CNMP). Follow contingency requirements set out within approved CNMP in the event of non-compliance and then additional noise mitigation measures are assessed as being required.

Traffic and Transport Minimise impacts to the local community and traffic flow. Implement Construction Traffic Management Plan.

Contamination Beneficial reuse of contaminated soil on site to occur where possible.

Avoid contaminating soil, groundwater and surface water as a result of the project works.

Reuse of contaminated soil to be in accordance with the National Environmental Protection (Assessment of Site Contamination) Measure.

Test any waste soil in accordance with a Waste Classification Guideline and disposed of soil at appropriate licenced facilities if required.

Implement on site controls for identified soil contamination and in accordance with EPA Guidelines relating to contamination.

Construction Waste

Minimise generation of waste. Monitor waste levels and ensure diversion of materials from landfill where possible.

Implement Waste Management Plan

Air Quality

Mitigate hazards and prevent nuisance and unnecessary interference or disturbance with people or property.

Minimise the environmental impact and effect of the works on local community groups.

Implement dust control measures discussed in section 3.5.6.4 of this Plan.

Monitor dust levels to occur and implement mitigation measures as required.




Environmental Aspects

Objectives Performance Criteria

Bushfire Risk Minimise bushfire risk Incorporate mitigation measures and avoidance measures into design

4.10 Contingency Plan

Where significant risks to environmental or heritage values, that were previously unknown, are

identified during Project works, then contingency measures will be implemented to ensure impacts

are minimised.

A summary of contingency measures detailed in the supporting plans to the CEMP are outlined in

Table14 below. Table 14 – Summary of Contingency Measures

Risk Contingency Measures Plans references Responsibilities

Removal of mature vegetation providing habitat and community benefit.

An ecologist will conduct pre-construction surveys to confirm if any additional threatened species are present other than that already approved

If new threatened species are located other than previously identified, the vegetation will be fenced off with “no go zone” signage and approval requirements will be confirmed in consultation with OEH. If required, approval will be sought from relevant regulators.

Section 4.3of the Biodiversity Management Plan

Environment Nominee Project Manager / Contractor

Noise exceedance

Vibration impact

Elevated levels of noise or vibration may be identified either by receipt of a noise complaint from a third party suggesting that there is an excessive noise from the Project Construction or by detection of noise as a result of the routine monitoring by site personnel.

Monitor noise and vibration levels to confirm validity of amenity impacts/complaint and implement further noise and vibration controls if required.

Section 3.5 of the Construction Noise Management Plan


Discovery and/or accidental damage to items of Aboriginal cultural heritage significance

Implement contingencies set out within approved Aboriginal Cultural Heritage Management Plan, including ‘stop work’ upon discovery/damage to item.

Sections 6.2&6.3 of the Aboriginal Cultural Heritage Management Plan


Erosion of exposed areas mobilises sediment into environment

During periods of high rainfall monitor and maintain erosion and sediment controls frequently determine if further controls are required to increase effectiveness.

In the event sediment laden water enters the environment, control and contain the source to prevent further pollution of stormwater.

Section 5.3 of the Water Management Plan


Dust Emissions If visible dust is evident from the project area, review the use of dust suppression measures during periods of dry weather and implement more effective controls.

Cessation of dust generating activities during adverse weather conditions (e.g. strong winds).

Section 3.5.6.4 of this CEMP


4.11 Performance Reporting

During the construction phase of the Project, the Contractor/ Environment Nominee or site nominee

will collect and record all environmental performance data for Veolia’s reporting obligations. Veolia

will provide report to the Customer relating to compliance with contractual and Customer

requirements under the contract obligations.




4.11.1 Progress Reporting

The progress of the Project will be communicated to Secretary (DP&E), predominantly through the

quarterly progress reports. The Project Manager will be responsible for preparing the progress

reports including:

detailed summary of the construction activities were been completed in the past three

months (as built report);

forecast completion date including indication of any poetical delays;

year look-ahead program including mitigation measures to ensure that WTF is operational

by July 2019;

progress photographs.

The quarterly progress reports will be published on the Veolia website (http://www.veolia.com/anz/)

and will be available for all interested parties.

4.11.2 Annual Reporting

By the end of March each year, Veolia’s suitable qualified person will prepare annual review of the

Project environmental performance (refer to sections 5.3 and 5.4 of this plan) for the previous

calendar year and prepare an Annual Report, which will be submitted to Secretary (DP&E).

http://www.veolia.com/anz/




SECTION 5 MONITORING AND REVIEW OF THE CEMP

5.1 Monitoring and Inspections

The Project’s environmental performance will be tracked through monitoring and inspections as detailed in Table 15.

Table 15 – Summary of Monitoring and Inspections

Type of Control Actions

Inspection Environmental Nominee will perform daily informal environmental inspections during the site establishment, construction and site demobilisation phases. Throughout construction at a minimum one weekly documented environment and sustainability inspection is to be completed.

Inspection checklists and any corrective actions identified will be recorded in the Project Management System.

Monitoring Environmental Nominee will perform weekly environmental monitoring during the site establishment, construction and site commissioning phases.

Details of specific monitoring requirements is included in the supporting management plans attached to this CEMP.

Monitoring results and any corrective actions identified will be recorded in the Project Management System.

Calibration of monitoring equipment

Monitoring equipment will be calibrated in accordance manufacturing instruction

Monitoring equipment will be calibrated prior to use

Any equipment identified as having doubtful accuracy or precision will be removed from use and recalibrated

Where any monitoring equipment is found to be out of calibration, the validity of the previous monitoring results will be assessed and documented

Records of equipment will be recorded via Project Management System.

Specialist surveys, inspections and monitoring

Certain specialist environmental inspections, performed by consultants and sometimes third parties are required prior to or during certain Project activities including but not exclusive to:

Pre-clearance surveys of the Project area by a qualified ecologist to demine flora species to be removed;

Baseline contamination assessment by a qualified consultant to assess level of contamination presented on site;

Soil sampling and analysis of contamination status;

Monitoring of tree clearing and inspection of trees for presence of fauna requiring capture and relocation, veterinarian care or euthanasia,

Weed identification and eradication services. A qualified subcontractor visits the Project area at least annually, preferably during times when weed growth is most common such as autumn and spring and identifies the presence of any weeds;

Noise monitoring if required in response to noise complaints.

5.2 Auditing

5.2.1.1 Internal audits

Business system audits are conducted to support continuous improvement by ensuring that the

management system and the business process are regularly assessed in a consistent and

systematic manner and in accordance with Audit Procedure (PR-ANZ-1-475). These audits include

the EMS.

The CEMP compliance audits will be undertaken by suitably qualified and experienced Veolia Safety, Health, Environment and Quality personnel not directly associated with the project and in accordance with the audit schedule.

The audits will verify:

effectiveness of the system to meet business objectives;

whether the actions carried out conform to the stated intention of the management system;




adequacy of implemented controls to minimise high risk activities;

compliance with company policies, legislation and industry standards;

compliance with contractual and Customer requirements;

whether the stated objectives in policy documents are being met;

identify areas for continuous improvement.

5.2.1.2 External audits

As part of Veolia’s commitment to having each of its operational sites certified to ISO 14001, external

certification and surveillance audits will be conducted by a registered certification body.

5.2.1.3 Audit findings

Audit findings will be reported to management and management system representative(s) of the

Project for inclusion in the management review processes.

Non-conformances and opportunities for improvement identified through internal and external audit

processes will be recorded, reported and responded to via the company’s electronic issues

management system.

5.3 Review of the CEMP

Annual management reviews of the Project CEMP and the environmental performance of the Project

will assess the continuing suitability, compliance with legislative requirements, adequacy and

effectiveness of the on-site environmental management measures implemented.

The inputs to the management review process will include (but not be limited to):

internal and external audits findings;

incidents management and investigation of non-conformance events, incidents, near misses

and management of all complaints received;

implementation of all compliance and legislative changes as identified at a corporate level; and

training and awareness;

monitoring results of the previous year; and

analysis of potential cause of any significant discrepancies between the predicted and actual

impacts of the Project construction phase.

The output of management review will include any decisions and actions related to:

possible changes to the management plans, procedures, practices, objectives and targets

associated with the environmental management of the Project construction;

improvement of the effectiveness of the EMS and its processes; and

resource needs.

System reviews are carried out at least annually by the Veolia’s suitable qualified person, which will

include a desktop review of the Project and CEMP and supporting plans, with the same agenda as

the Management Review and presented to the Project Manager.

The CEMP may be reviewed more regularly due to a change in construction activities, where

objectives are not achieved.

The updated plan will approved internally by the Project management and if it deems necessary, the

CEMP will be provided to relevant stakeholders for review and comment if required and forwarded to

the Secretary of DP&E for approval.




5.4 Corrective Action

Corrective and preventative actions may be identified from inspections, audits, non-conformances,

incidents, management reviews and complaints. Once identified an Action Plan could be developed

as an overarching document that will provide complex direction for improvement of different elements

of the Project (e.g. quality, safety, and environment) or be specific for Project Environmental

Management (FM-ANZ-2-231 Action Plan – Veolia template).

Management reviews are scheduled to assess the progress of implemented corrective action, its

adequacy and effectiveness. Reviews are undertaken in accordance with the corporate Business

Planning Activity Timeline outlined in the Business Planning Procedure (PR-ANZ-2-442).

http://www.vwanz.net/docs/ControlledDocuments/PR-ANZ-2-442.docx




APPENDICES

Appendix A - Copy of the Development Consent




Appendix B1 - Water Management Plan




Appendix B2 - Biodiversity Management Plan




Appendix B3 - Aboriginal Cultural Heritage Management Plan




Appendix B4 - Construction Noise Management Plan




Appendix B5 - Construction Traffic Management Plan




Appendix B6 - Stakeholder Management Plan




Appendix B7 - Construction Waste Management Plan




Appendix C - EPL requirements – EPA Clarifications




Appendix D - Pre-Construction Compliance Report