independent environmental audit of project approval

Woodlawn Mine

507 Collector Road

TARAGO NSW 2580

Heron Resources Limited (Subject to Deed of Company Arrangement)

1 of 1

ABN: 30 068 263 098

17 March 2022

Katrina O’Reilly Team Leader – Compliance NSW Planning Industry & Environment 4 Parramatta Square 12 Darcy Street PARRAMATTA NSW 2150 Dear Katrina,

Woodlawn Mine Project (MP07_0143) – Independent Environmental Audit – Submission of Audit Report

I refer to your letters dated 14 October, 23 November 2021 and 7 March 2022 regarding the 2021 Independent Environmental Audit (IEA) to be carried out at Woodlawn Mine by Senversa Pty Ltd. Senversa have completed the IEA and a copy is enclosed in accordance with Schedule 6, Condition 9 of project approval MP07_0143 Should you have any questions regarding the IEA please contact Zoe Read at email [email protected] or telephone 0407 270 073. Yours sincerely Tim Dobson CEO Enclosure: Senversa Independent Environmental Audit of Project Approval Conditions 07_0143 MOD 2 EP&A Act dated 17 March 2022

mailto:[email protected]

Independent Environmental Audit of Project Approval Conditions 07_0143 MOD 2 EP&A Act Woodlawn Mine, Tarago NSW

17 March 2022

Document Information

S19346_003_RPT_Rev1_Environmental Audit 2021 i


Independent Environmental Audit of Project Approval Conditions 07_0143 MOD 2 EP&A Act, Woodlawn Mine, Tarago NSW Prepared by:

Senversa Pty Ltd

ABN: 89 132 231 380 Level 24, 1 Market Street, Sydney NSW 3000 tel: + 61 3 9606 0070; fax: + 61 3 9606 0074 www.senversa.com.au Prepared for:

Heron Resources Ltd, Subject to a Deed of Company Arrangement

C/ - FTI Consulting

Level 22, Gateway, 1 Macquarie Place

Sydney, NSW 2000

Revision Date Author Reviewed Approved Detail

0 - Draft 04/03/2022 Michelle Agnew Jason Clay Jason Clay Draft for comment

1 - Final 16/03/2022 Michelle Agnew Jason Clay Jason Clay Final

Project Manager: Michelle Agnew

Project Director: Jason Clay

Disclaimer and Limitations:

This document is confidential and has been prepared by Senversa for use only by its client and for the specific purpose described in our proposal which is subject to limitations. No party other than Senversa’s client may rely on this document without the prior written consent of Senversa, and no responsibility is accepted for any damages suffered by any third party arising from decisions or actions based on this document. Matters of possible interest to third parties may not have been specifically addressed for the purposes of preparing this document and the use of professional judgement for the purposes of Senversa’s work means that matters may have existed that would have been assessed differently on behalf of third parties. Senversa prepared this document in a manner consistent with the level of care and skill ordinarily exercised by members of Senversa’s profession practising in the same locality under similar circumstances at the time the services were performed. Permission should be sought before any reference (written or otherwise) is made public that identifies any people, person, address or location named within or involved in the preparation of this report. Senversa requires that this document be considered only in its entirety and reserves the right to amend this report if further information becomes available. This document is issued subject to the technical principles, limitations and assumptions provided herein in Section 8.0.

© Senversa Pty Ltd 2022 Senversa acknowledges the traditional custodians of the land on which this work was created and pay our respect to Elders past and present. Senversa is a carbon neutral company and accredited BCorp.


S19346_003_RPT_Rev1_Environmental Audit 2021 ii

Executive Summary

Project Approval 07_0143 under Section 75J of the Environmental Planning and Assessment Act 1979 for the Woodlawn Mine Project was issued on 4 July 2013 to TriAusMin Ltd for the development and operation of a lead, copper and zinc mine in Tarago, NSW. Since the approval of the mine, a number of modifications have been made to reduce environmental impact and improve operations. The NSW Planning Assessment Commission approved Modification 2 in July 2017 with revised conditions of approval issued.

Construction works commenced on 14 September 2017 and were completed in mid-2019.

Condition 9 of Schedule 6 of the Project Approval requires an Independent Environmental Audit every three years from the commencement of construction. The objectives of the audit are to undertake the works to assess compliance with Project Approval, Environment Protection Licence and Mining Lease conditions since the completion of the previous independent environmental audit on 30 June 2018, up to 30 June 2021, in accordance with the following relevant guidelines and Australian Standards:

• NSW DPIE Independent Audit – Post approval requirements, May 2020 • AS/NZS ISO 19011:2014 Guidelines for auditing management systems.

The audit scope included assessment of the adequacy of environmental management strategies and plans. Consultation on the requirements of the audit was undertaken with stakeholder agencies and mine site personnel were interviewed during the site inspection conducted on 17 and 18 February 2022. The findings and recommendations for improvements are documented in this audit report.

The audit identified eight non-compliances with the conditions of the Project Approval, Environmental Protection Licence and Special Mining Licence. Recommendations have been made to rectify these and improve the overall environmental performance of the project. These non-compliances are largely minor. Review of the management plans and approval by the Department/Secretary prior to implementation requires action. In addition, recommendations for improvement related to seven conditions have been provided where the operational intent was compliant.

Contents

S19346_003_RPT_Rev1_Environmental Audit 2021 iii

Contents

Executive Summary ............................................................................................................................................................................................................... ii

List of Acronyms ................................................................................................................................................................................................................... v

1.0 Introduction and Objectives ............................................................................................................................................................................ 1

1.1 Background ............................................................................................................................................................................................................... 1

1.2 Audit Objectives..................................................................................................................................................................................................... 2

1.3 Audit Scope .............................................................................................................................................................................................................. 2

1.4 Guidelines .................................................................................................................................................................................................................. 2

1.5 Audit Period ............................................................................................................................................................................................................. 2

2.0 Methodology ............................................................................................................................................................................................................ 3

2.1 Audit Team ............................................................................................................................................................................................................... 3

2.2 Audit Methodology............................................................................................................................................................................................... 3

2.2.1 Stakeholder Consultation .............................................................................................................................................................................................. 3

2.2.2 Project Documentation .................................................................................................................................................................................................. 3

2.2.3 Site Personnel Interviews ............................................................................................................................................................................................... 4

2.2.4 Site Inspection ....................................................................................................................................................................................................................... 4

2.2.5 Compliance Ratings ........................................................................................................................................................................................................... 4

3.0 Previous Audit Findings ...................................................................................................................................................................................... 5

4.0 Environmental Management ............................................................................................................................................................................ 8

5.0 Environmental Performance ......................................................................................................................................................................... 10

5.1 Complaints ............................................................................................................................................................................................................. 10

5.2 Incidents................................................................................................................................................................................................................... 10

5.3 Notices ..................................................................................................................................................................................................................... 10

5.4 Rehabilitation ........................................................................................................................................................................................................ 11

5.5 Performance against Environmental Assessment Predictions ..................................................................................................... 11

6.0 Audit Findings ....................................................................................................................................................................................................... 12

7.0 Conclusion ............................................................................................................................................................................................................. 15

8.0 Principles and Limitations of Investigation ............................................................................................................................................. 16

Contents

S19346_003_RPT_Rev1_Environmental Audit 2021 iv

Tables in Text

Table 2-1: Stakeholder Agency Consultation ......................................................................................................................................................... 3

Table 2-2: Site Personnel Interviews ........................................................................................................................................................................... 4

Table 2-3: Compliance Status Descriptors .............................................................................................................................................................. 4

Table 3-1: Recommendations of 2017-2018 Independent Environmental Audit (EES 2021) ..................................................... 5

Table 4-1: Environmental Management Plans Summary ................................................................................................................................... 8

Table 6-1: Summary of Compliance with Approval and Licence Conditions .................................................................................... 12

Appendices Table 1: Project Approval 07_0143 MOD 2 Conditions dated July 2017

Table 2: EPL 20821 issued 29 March 2017, latest version 18 January 2019 Conditions

Table 3: SML20, latest version 21 January 2015 Conditions

Table 4: Proponent Response Table

Appendix A: Audit Team Supporting Documents

Appendix B: Stakeholder Consultation

Appendix C: Site Photographs

List of Acronyms

S19346_003_RPT_Rev1_Environmental Audit 2021 v

List of Acronyms

Acronym Definition

ANZECC Australian and New Zealand Environment and Conservation Council

AQMP Air Quality Management Plan

AS/NZS ISO Australian Standard/New Zealand Standard Industry Standard Organisation

AWT Alternative Waste Treatment

CCC Community Consultative Committee

CEMP Construction and Environmental Management Plan

CEP Community Engagement Plan

C&M Care and Maintenance

DA Development Approval

DPE Department of Planning and Environment

DPIE Department of Planning, Industry and Environment

DPI Department of Planning and Infrastructure

DRG Division of Resources and Geoscience

DSC Dams Safety Committee

EA Environmental Assessment

EES Environmental Earth Sciences

EMP Environmental Monitoring Plan

EMS Environmental Management Strategy

EPC Environmental Performance Conditions

EPA Environment Protection Authority (NSW)

EP&A Act Environmental Planning & Assessment Act (1997)

EPL Environment Protection Licence

FTI FTI Consulting Pty Ltd

HMP Heritage Management Plan

List of Acronyms

S19346_003_RPT_Rev1_Environmental Audit 2021 vi

Acronym Definition

IBC Intermediate Bulk Container

MOD Project Approval Modification

MOP Mining Operations Plan

NBMP Noise and Blast Management Plan

NC Non-Compliance

NSW New South Wales

OEH Office of Environment and Heritage (NSW)

PCD Pollution Control Dam

PFMP Paste Fill Management Plan

PIRMP Pollution Incident Response Management Plan

PM10 Particulate Matter < 10 µm

POEO Act Protection of the Environment and Operations Act 1997

ROM Run-of-Mine

SML Special Mining Lease

TARP Trigger Action Response Plan

TCLP Toxicity Characteristic Leaching Procedure

TDS Tailings Dam South

TDW Tailings Dam West

TMP Transport Management Plan

TSF Tailings Storage Facility

VMS Volcanogenic Massive-Sulphide

VRMP Vegetation and Rehabilitation Management Plan

WMP Water Management Plan

WRD Waste Rock Dam

WRMP Waste Rock Management Plan

Introduction and Objectives

S19346_003_RPT_Rev1_Environmental Audit 2021 | Independent Environmental Audit of Project Approval Conditions 07_0143

MOD 2 EP&A Act 1

1.0 Introduction and Objectives

1.1 Background

Senversa Pty Ltd was engaged by Heron Resources Ltd (Heron), to conduct an Independent Environmental Audit (audit) of its Woodlawn Mine. Woodlawn Mine is a high-grade, zinc, copper and lead volcanogenic massive-sulphide (VMS) deposit situated in Tarago, New South Wales (NSW), approximately 50 km north-east of Canberra and 250 km south-west of Sydney. Construction of the site under the latest planning approval commenced in September 2017 and was completed in mid-2019. During the period of the audit, mining activity comprised the construction of the underground access box cut and ramp (decline) and reprocessing existing tailings. Although some copper, lead and zinc bearing ore had been extracted as the development of the upper mine levels were completed along with some initial production stoping, the primary focus of the underground operation was the development of the access to the main Kate lens orebody and the establishment of the underground mine infrastructure rather than full scale production. Mine operations were suspended on 25 March 2020.

The following approvals and licences relate to the audit:

• Department of Planning and Infrastructure (DPI) Project Approval Number 07_0143, dated 4 July 2013 (modified July 2017) (07_0143-MOD02).

• NSW Environment Protection Authority (EPA) Environment Protection Licence (EPL) Number 20821 (Licence Variation Notice Number: 1572566, dated 18 January 2019).

• Special Mining Lease 20 (SML 20), dated 15 August 2013 (renewed 21 January 2015).

The purpose of the audit was to satisfy Condition 9 of Schedule 6 of the Project Approval (reference number 07_0143MOD2), which states:

‘Within one year of commencing construction of the project, and every three years thereafter, unless the Secretary directs otherwise, the Proponent shall commission and pay the full cost of an Independent Environmental Audit of the project.’

It is understood that FTI Consulting were appointed voluntary administrators over Heron in addition to its wholly owned subsidiary Tarago Operations Pty Ltd on 16 July 2021 and that the mine has been placed in care and maintenance (C&M) while new owners are sought. Heron (and subsequently Deed Administrators on 25 February 2022) owns the mineral rights and a portfolio of exploration tenements adjacent to the site. TriAusMin Ltd is the holder of the Project Approval. On 25 February 2022 a Deed of Company Arrangement (DOCA) was executed by Heron and Develop Global Limited (Develop). Pursuant to the DOCA, Develop will acquire the shares in Heron, subject to the satisfaction of various condition precedents. It is expected that this transaction will be completed in April or May 2022. Following completion, Develop will own and have day to day control of Heron and its subsidiaries, including Tarago Operations Pty Ltd.

It should be noted that the mine operates in and around another licensed premises, which is a Veolia waste operation including a landfill (in a former open pit), waste treatment/recovery facility and an associated network of leachate treatment systems. While the two businesses operate in some senses synergistically, they are separate and distinct and other than where Veolia operations impact/influence Heron operations they are not considered in this audit. There is also a windfarm adjacent to the site owned by Iberdrola.

Introduction and Objectives


MOD 2 EP&A Act 2

1.2 Audit Objectives

The objectives of the works were to undertake an Independent Environmental Audit under Schedule 6 Condition 9 of the Project Approval Conditions – Modification 2 to assess the environmental performance of the project including assessment of compliance with the requirements under the Project Approval, EPL and SML, and review the adequacy of management strategies and plans.

1.3 Audit Scope

The land subject to the audit is identified in Appendix 2 of the Project Approval.

The scope of work for the Independent Environmental Audit comprised:

• Department of Planning Industry and Environment (DPIE) approval of the audit team. • Consultation with relevant stakeholder agencies. • Desktop review of available information relating to the approval conditions, EPL, SML, and

associated environmental management plans or monitoring programs • Site inspection and interviews with staff. • Preparation of this independent environmental audit report detailing the findings of the audit.

1.4 Guidelines

The independent environmental audit was undertaken in accordance with the following auditing standards and guidance:

• AS/NZS ISO 19011 (2014), Guidelines for Auditing Management Systems. • DPIE (2020), Independent Audit Post-Approval Requirements, May 2020.

1.5 Audit Period

The following previous independent environmental audit has been undertaken, the findings of which have not been included in this independent environmental audit report:

• Environmental Earth Sciences (EES) (2021), Independent Environmental Audit, Woodlawn Mine, NSW, Rev 1.1, 20 August 2021, (EES, 2021).

As part of the compliance audit program undertaken by the Regulator, an audit of the mining operations associated with the Woodlawn Mine was undertaken on 7 November 2019:

• NSW Resources Regulator (2020), Compliance Audit Program: Woodlawn Mine, Tarago Operations Pty Ltd, Rev RR20/1163, February 2020, (DPE, 2020).

This independent environmental audit addresses development activities undertaken since the last independent environmental audit (EES, 2021) which was completed up until 30 June 2018, and covers up to 30 June 2021. It is noted that EES (2021) was published three years after the audit period. It should also be noted that this audit follows on from that as is required in the approval. The audit therefore does not cover the recent (December 2021) environmental incident involving the discharge of surface water into the tailings dam west and from there off-site to the south. We understand the Environment Protection Authority (EPA) has been informed and is reviewing the situation currently.

Methodology


MOD 2 EP&A Act 3

2.0 Methodology

2.1 Audit Team

The audit team comprising of Mr Jason Clay and Dr Andrei Woinarski of Senversa Pty Ltd who were approved by the DPIE as possessing the required skills and experience to undertake the independent environmental audit. The audit team was assisted by Ms Michelle Agnew of Senversa. The details of the audit team qualifications and experience are included in Appendix A.

2.2 Audit Methodology

The audit involved consultation with stakeholder agencies, review of project documentation and records and the conduct of a site inspection by members of the audit team on 17 and 18 February 2022. Management and operations personnel were interviewed as part of the audit. The findings of the audit have been documented in this Independent Environmental Audit Report and the Declaration of Independence is provided in Appendix A.

2.2.1 Stakeholder Consultation

The stakeholder agencies consulted, and their responses, are presented in Table 2-1.

Table 2-1: Stakeholder Agency Consultation

Stakeholder Agency Response

Department of Planning, Industry and Environment See response in Appendix B.

NSW Resources Regulator See response in Appendix B.

Water NSW See response in Appendix B.

Natural Resource Access Regulator No response.

Environment Protection Authority A virtual discussion was held on 11 February 2022 between Jason Clay of Senversa and Janine Goodwin and Amanda Fletcher of the EPA. The main point of discussion was that the EPA wanted to be sure that the audit team was aware of the TDW surface water incident in December 2021. It later transpired that the date of the incident was outside the audit period.

The elements of the Project Approval requested to be addressed by the DPIE and Resources Regulator have been covered in the audit.

2.2.2 Project Documentation

Project documentation and records reviewed as part of the audit are listed in the audit review Tables 1

to 3. Adequacy of documentation was assessed by review against the Project Approval conditions and comparison with site records, where appropriate.

Methodology


MOD 2 EP&A Act 4

2.2.3 Site Personnel Interviews

Site personnel interviewed are presented in Table 2-2.

Table 2-2: Site Personnel Interviews

Position Name Audit Elements

Environmental Officer Zoe Read General environmental compliance

Site Manager/Statutory Mining Engineering

Manager

Tim Brettell Maintenance records and mining operations

2.2.4 Site Inspection

A site inspection was conducted by Jason Clay and Michelle Agnew on 17 and 18 February 2022. All required areas were accessible for the inspection. Key photos from the site inspection are included in Appendix C.

2.2.5 Compliance Ratings

The compliance ratings used to record the level of compliance of the Project with the licence and approval conditions at the time of the audit are summarised in Table 2-3 below.

Table 2-3: Compliance Status Descriptors

Rating Compliance Status

Compliant Where the auditor has collected sufficient verifiable evidence to demonstrate that the intent and all elements of the requirement of the regulatory approval have been complied with within the scope of the audit.

Non-compliant Where the auditor has collected sufficient verifiable evidence to demonstrate that the intent of one or more specific elements of the regulatory approval has not been complied with within the scope of the audit.

Not triggered A regulatory approval requirement has an activation or timing trigger that had not been met during the audit period, therefore a determination of compliance could not be made.

Previous Audit Findings


MOD 2 EP&A Act 5

3.0 Previous Audit Findings

The previous Independent Environmental Audit Woodlawn Mine (EES, 2021) conducted over the period of 1 July 2017 to 30 June 2018 concluded that ‘no features were identified as being “non-compliant” for the Audit period’.

Recommendations made by EES (2021) in relation to the findings of the 2017-2018 independent environmental audit are presented in Table 3-1. The EES audit had not been received at the time of the 2020-2021 Annual Review and a number of recommendations had not been addressed. Outstanding recommendations of the previous audit remain active.

Table 3-1: Recommendations of 2017-2018 Independent Environmental Audit (EES 2021)

Condition Comment/Audit Findings 2017-2018 Audit Compliance Status

2018-2021 Audit Status

Schedule 3 Condition 1 (g)

and (h):

Tailings Dams

Performance Measures

(a) Note update to Dams Safety Act 2015 and NSW Department of Planning, Industry and Environment (2020), Dam Safety NSW, Guideline - Mining near declared dams. Future Mining Operations Plans (MOPs) and relevant plans should be updated to reflect changes. (g) Coffey (2017), Heron Resources Limited, South Tailings Dam Inspection Report, Tailings Storage Facilities at Woodlawn Mine, Tarago, NSW (dated 2 August 2017 reference: NTLGE201385AA), undertook inspection of Tailings Dam South (TDS) and determined seepage was occurring through foundations and toe drains since the dam was commissioned and recommend a clay blanket or synthetic liner with clay liner. (h) Ensure existing seepage collection area is lined with a low permeability geotextile membrane within 1 year of completing the repair work on Tailings Dams South, to the satisfaction of the Secretary.

Compliant Not yet complete.

Review of MOP and management plans scheduled prior to mining operations reestablishment.

Schedule 3 Condition 2:

Tailings Rehabilitation

Strategy

Recommend that requirements: (f) confirm the capping material would not result in any additional adverse environmental consequences; and (g) confirm that manner in which the compost from the Veolia Alternative Waste Treatment (AWT) is proposed to be used on the site is covered by a valid exemption issued by the EPA. [sic] are addressed and developed through progression of rehabilitation trials upon commencement of tailings reprocessing.


Review of the Vegetation and Rehabilitation Management Plan (VRMP) is scheduled prior to mining operations reestablishment.



MOD 2 EP&A Act 6



Schedule 4 Condition 4

(e):

Water Management Plan

(WMP)

No discussion on compensating potentially affected landowners (including compensatory water supply if required). Audit Team understands data sharing undertaken with Veolia Bioreactor facility, including surface and groundwater monitoring. Understood Trigger Action Response Plans (TARPs) for surface water and groundwater developed over time with the Department of Planning and Infrastructure (DPI) and relevant authorities. Due to scale and complexity of Woodlawn facility (mine and landfill), Auditor recommends separate independent surface water and groundwater monitoring and performance management reviews undertaken every three (3) years to support Independent Audit processes (i.e. Development Approvals (DA) and approvals) for both facilities.

Compliant once measures to mitigate and/or compensate potentially affected landowners (including compensatory water supply if required), is addressed.

Complete.

WMP revision (Rev) 11 Table 5.2 details remedial measures to address impacts from mining operations on groundwater supply for all affected landholders.


Waste Rock Management

Plan WRMP)

(a) No evidence consultation with Division of Resources and Geoscience (DRG), EPA and DPI – Water 1.6 Consultation: states Schedule 4 Condition 19 of the Project Approval requires this WRMP to be prepared in consultation with DRG, EPA and DPI-Water prior to being submitted to the Secretary of Department of Planning and Environment (DPE) for approval. (c) Recommendation: - trigger levels for any material that has oxidised to the extent that it cannot be placed underground without impacting groundwater quality, and procedures for adequate capping and sealing of such material at the surface. It is expected 5% cut-off grades will be developed by Heron (and independently peer reviewed) and be integrated with Paste Fill Management Plan processes.

Compliant Complete.

(a) The WRMP has been submitted to DRG, EPA and DPI since the 2017-2018 audit. c) Procedures for management and disposal of waste material are incorporated in the WRMP and Paste Fill Management Plan (PFMP).


Dangerous Goods Access

Road and Intersection

Construction Monitoring

of Concentrate Transport

Recommendation: examples of tracking and registering the date and time of loaded heavy vehicle movements from the site be provided as part of plan(s) in future.


Inclusion of tracking template documents may be considered during review of the Transport Management Plan (TMP), scheduled prior to mining operations reestablishment.


Road Transport Protocol

Recommendation: procedures for ensuring compliance with and enforcement of the Code be further developed in future plan(s).


Review of the TMP is scheduled prior to mining operations reestablishment.



MOD 2 EP&A Act 7




Environmental

Management Condition -

Heritage

Recommendation: Develop and include programs/procedures and management measures for appropriate identification, management, conservation and protection of both Aboriginal and non-Aboriginal heritage items identified on the site.

Compliant No action required.

Aboriginal Stakeholder involvement was sought during the Environmental Assessment (EA). The Site has no known heritage value. The Heritage Management Plan (HMP) will be reviewed prior to mining operations reestablishment.


Environmental

Management Condition -

Visual

Noted that commitment to plant visual tree screen along Collector Road in 11.1 Planned Activities for 2018-19 Reporting Period. Check in future audits.

Compliant Completed. Screen along Collector Road was planted in 2019 and observed as part of this audit.


Notification of

Landowners

Recommendation: Noise and Blast Management Plan (NBMP) Part 4.3 Public Access to Information (Noise and Blast Management Plan): should specify that Heron will notify affected landowners and/ or tenants in writing for noise and blast activities pertinent to these receptors.


Review of the NBMP is scheduled prior to mining operations reestablishment.

Environmental Management


MOD 2 EP&A Act 8

4.0 Environmental Management

Various conditions under the Project Approval 07_0143 and EPL 20821 specify requirements for environmental management plans for the project. A review and assessment of any revisions to the various management plans since the last independent environmental audit and overall adequacy with consideration of site conditions has been undertaken and is presented in this section.

Schedule 6 Condition 1 of Project Approval 07_0143 requires the preparation and implementation of an Environmental Management Strategy (EMS) for the Woodlawn Mine (Heron, Revision 6, 31 July 2018) to the satisfaction of the Secretary. The document provides the strategic framework for environmental management of the project and includes various management plans as required by the Project Approval.

The EMS was submitted to DPI on 10 May 2018, and comments from the Department/Secretary assessment were incorporated into Revision 6. Evidence of approval of Revision 6 was not available.

A review of the overall adequacy of the EMS management plans is summarised in Table 4-1.

Table 4-1: Environmental Management Plans Summary

Management Plan Project Approval conditions

Rev last issued to DPE

Rev last approved by DPE

Audit findings

Construction Environmental

Management Plan (CEMP)

(Rev 8, 16/09/2016)

- Rev 8 16/92016

Not required The CEMP Rev 8 predates the project approval 07_0143MOD2 issued July 2017 and will require review prior to further construction activities.

Community Engagement

Plan (CEP)

(Rev 3, 13/09/2016)

Schedule 6 Condition 6 & 11

Rev 3 13/09/2016

Not required -

Pollution Incident Response

Management Plan (PIRMP)

(Rev 5, 26/2/2021)

Part 5.7A of the POEO Act requires all licensees to prepare, keep, test and implement a PIRMP.

Not required Not required It is recommended that the plan be provided to the EPA.

Extraction Plan

(Rev 8, 29/8/2019)


Rev 7 30/7/2019

Rev 7 30/7/2019; Letter dated 29/8/2019.

No comments were provided with DPE approval letter dated 29/8/2019; Rev 7 appears to be the latest revision. Amend Extraction Plan document control.

Noise and Blast

Management Plan (NBMP)

(Rev 9, 2/8/2017)

Schedule 4 Conditions 5 to 12; Schedule 5 Condition 1

Rev 6 13/9/2016

Rev 6 13/9/2016; Letter dated 12/5/2017.

Schedule 4 Condition 7 and 12 require that the NBMP be approved by the Secretary prior to undertaking construction and blasting.

Environmental Management


MOD 2 EP&A Act 9

Management Plan Project Approval conditions

Rev last issued to DPE

Rev last approved by DPE

Audit findings

Air Quality Management

Plan (AQMP)

(Rev 8, 1/8/2017)

Schedule 4 Conditions 11, 13 to 15, 17 & 18; Schedule 5 Condition 1

Rev 5 13/9/2016

Rev 513/9/2016; Letter dated 12/5/2017.

It is recommended that the plan be revised to include notification of air quality criteria exceedances to affected landowners if wind data confirms the mine is likely to have contributed to the elevated level. Application to amend project approval Schedule 5 Condition 1 to apply only when the mine is the likely source of dust (i.e. not in the case of regional bushfire and dust storm events) should be included in the MOD 3 application. Schedule 4 Condition 17 requires that the AQMP be approved by the Secretary prior to undertaking construction.


(WMP)

(Rev 11, 6/11/2018)

Schedule 4 Condition 4; Schedule 6 Condition 3

Rev 7 20/2/2017

Rev 7 20/2/2017; Letter dated 12/5/2017.

Schedule 4 Condition 4 requires that the WMP be approved by the Secretary prior to undertaking mining operations.

Vegetation and

Rehabilitation Management

Plan (VRMP)

(Rev 8, 2/8/2017)

Schedule 3 Conditions 1-2 & 6; Schedule 4 Conditions 20-22 & 28

Rev 5 12/9/2016

Rev 5 12/9/2016; Letter dated 12/5/2017.

Schedule 4 Condition 20 and 22 require that the VRMP be approved by the Secretary prior to undertaking construction and mining operations. Rehabilitation trials are underway on TDN (see discussion in the audit table) but rehabilitation of the former waste rock dump is required. It is eroding, topsoil has washed off and the slopes are deteriorating. Acidic seepages were observed around the entrance to the underground mine; these are collected to leachate ponds but are indicative of a wider acid drainage issue.

Heritage Management Plan

(HMP)

(Rev 6, 31/07/2017)


Rev 3 13/9/2016

Rev 3 13/9/2016; Letter dated 12/5/2017.

Schedule 4 Condition 27 requires that the HMP be approved by the Secretary prior to undertaking construction.

Transport Management Plan

(TMP)

(Rev 7, 2/8/2017)


Rev 6 13/6/2017

Not available.

Schedule 4 Condition 26 requires that a Road Transport Protocol (addressed by the TMP) be approved by the Secretary prior to undertaking any development.

Paste Fill Management Plan

(PFMP)

(Rev 7, 19/7/2019)

Schedule 3 Conditions 3 & 5

Rev 7 19/7/2019

Rev 7 19/7/2019; Letter dated 29/8/25019.

Recommendations for review of the PFMP are detailed in Table 6-1.

Waste Rock Management

Plan (WRMP)

(Rev 6, 19/7/2019)


Rev 2 20/5/2018

Rev 2 20/5/2018

Schedule 4 Condition 19 requires that the WRMP be approved by the Secretary prior to undertaking underground mining operations.

Environmental Monitoring

Plan (EMP)

(Rev 0, 30/1/2019)

- - Not required -

Environmental Performance


MOD 2 EP&A Act 10

5.0 Environmental Performance

5.1 Complaints

A complaints register is maintained on the Heron website, and complaints were reported in the Annual Review reports. Two complaints were recorded during the audit period:

The first complaint was received on 4 August 2018. The complaint related to rubbish on Currawang Road. The complaint was actioned by removing the rubbish on 12 August 2018 and raising the issue with site contractors. The corrective action has been closed.

The second complaint was received on 9 July 2019. The complaint related to cracks in a house, thought to have been the result of mine blasts. The complaint was actioned by inspecting the house and undertaking additional noise and vibration monitoring on the property. A report of the monitoring was provided to the landowner, dated 1 November 2019, which found no evidence that vibrations associated with blasting extended beyond the SML boundary. The corrective action has been closed.

The complaints phone line is not active during C&M.

5.2 Incidents

One environmental incident was reported during the audit period, recorded in the 2020-2021 Annual Review. The incident related to the pollution control dam overflowing, resulting in a release of stormwater off-site during a heavy rainfall event on 9 August 2020. Heron advised that the incident was reported by phone to the EPA within 7 days. Discharge point and downstream water samples were collected to inform an investigation report, dated 4 September 2020. The investigation concluded that environmental impact from the discharge was minimal and did not extend beyond the SML boundary.

There were no reportable air quality incidents during the reporting period. Exceedances of the dust assessment criterion were recorded throughout January 2019 to December 2020. Heron concluded that assessment of wind direction and the occurrence of multiple dust storms and bushfire events over this period indicated that the dust was unlikely to have been derived from the project. Consequently, Heron advised that the EPA were notified of the dust exceedances within 7 days, however the events did not constitute reportable incidents and affected property owners were not notified of the exceedances.

The audit team note that the dates in the 2019-2020 Annual Review Table 13: Dust deposition gauge – rolling average should be reviewed and amended to July 2019 to June 2020.

5.3 Notices

DPE issued a $15,000 Penalty Notice and two $6,000 Penalty Notices to Heron in February 2020. The $15,000 Penalty Notice was issued for the construction of the box cut (the entry point to the underground mine) and a waste rock storage area in locations which were not consistent with the development consent (07_0143-MOD02). Heron advised the changes will be included in the MOD 3 project approval application, to be resolved prior to reestablishment of mining operations.

Two $6,000 Penalty Notices were issued to Heron for the construction of the Processing Plant Office and the Concentrate Building on the site without having first obtained construction and occupation certificates as required under the Environmental Planning and Assessment Act 1979. Heron has since provided construction certificates for the buildings.

Environmental Performance


MOD 2 EP&A Act 11

5.4 Rehabilitation

Site rehabilitation trials are underway to test various forms of tailings dam cover systems on tailings dam north (TDN). A Veolia product Woodlawn organic outputs (WOO) is currently being used under an EPA Resource Recovery Exemption (RRE); this material was observed in-situ as containing a significant amount of broken glass, it was also stated as being a poor substrate or growth medium. It may, therefore, only be suitable as a cover or bulking material between tailings and a growing medium. However, there is a significant shortage of topsoil type material and provision of a suitable volume of growing medium will be a challenge going forward. A large volume of material will be required to provide an adequate thickness of cover over the tailings dams. Trials include layering materials in different sequences and thicknesses, the testing of soil moisture at various depths and vegetation testing to find that best suited for use. Trail results are not available yet, but results should be reported in the Annual Review.

While the top of the former waste rock dump seems to be in a stable condition, sections, of the slopes particularly, have suffered from erosion and denuding of topsoil. Some of the slopes constitute bare earth with erosional channels. The regrading of these slopes and provision of topsoil was discussed but is not likely to be a priority until mining operations are well underway.

The waste rock dump was giving rise to obvious seepages, especially around the underground mine entrance, which appeared acidic in nature and gave rise to crystalline deposits. General seepage from the waste rock dump was reportedly collected in the waste rock dam and exhibited a low pH. From there it can be pumped back up to treatment lagoons. The plan to build a passive treatment system (wetland) to reduce the impacts of acid drainage is behind schedule currently and not in compliance with the approvals.

Tailings dam rehabilitation trials are underway but are at an early stage, while the WOO is not an optimal material it is potentially available in a large volume and could be a suitable break layer between tailings and topsoil.

Further efforts are required to address issues with waste rock dump erosion/rehabilitation.

5.5 Performance against Environmental Assessment Predictions

An Environmental Assessment (EA) (Heron, 20121) was completed in support of project approval under Part 3A of the Environmental Planning and Assessment Act 1979. Assessment of the compliance between actual and predicted impacts documented in the EA was undertaken in each of the Annual Reviews.

Dust levels consistently exceeded the EA predictions for on-site generated dust during the audit period. However, Heron concluded that the elevated concentrations were the result of multiple dust storms and bushfire events over this period and unlikely to be significantly site-derived, as detailed in Section 5.2. Heron reported that operating systems were modified to include additional dust management activities including the use of molasses in the water cart water, and strict enforcement of the site vehicle speed limits.

The locations of the waste rock dump and box cut were moved from those specified in the EA and will be addressed in the proposed MOD3 Project Approval application, as detailed in Section 5.3.

1 Heron (2012), Environmental Assessment, TriAusMin Woodlawn Project, Rev D, 04 April 2012.

Audit Findings


MOD 2 EP&A Act 12

6.0 Audit Findings

Compliance of the project has been assessed against the Project Approval Modification 2, EPL and SML conditions, presented in Tables 1, 2 and 3 respectively.

A summary of the main findings and recommendations are presented in Table 6-1. The proponent’s response to these findings is presented in Table 4.

Table 6-1: Summary of Compliance with Approval and Licence Conditions

Condition Comment/Audit Finding/Recommendation Compliance Status

Project Approval 07_0143-MOD02


Tailings Dams

Heron identified during the site inspection stormwater drainage pipes that direct water from the south into Tailings Storage Facility 4 (TSF4) in non-compliance with this condition. Heron advised that plans are underway to redirect this clean water over TSF4 and discharge to the north. While the non-compliance results in higher water levels within TSF4, it is considered to pose a low risk of environmental harm. Recommendation: Implement redirection of stormwater.

Non-

Compliant


Tailings Dams Tailings reprocessing operations commenced in TDS in March 2019. The source of the seepage has not yet been identified and repaired and it is anticipated that this condition will be Non-Compliant by March 2022. This will subsequently delay lining of the existing seepage collection area. Recommendation: Review the timing of this condition in 07_0143-MOD03 prior to recommencement of mining operations.

Not

Triggered


Underground Mining

Extraction Plan Section 4.2.1 details an exclusion zone of 200 m around the existing open cut (Woodlawn Landfill). Heron confirmed that construction operations conformed with the approved design including the 200 m exclusion zone, verified by a design review and sign-off process. Recommendation: Include a process to verify compliance with this condition in the next revision of the Extraction Plan.

Compliant


Underground Mining The PFMP includes results of the paste fill chemical analysis trial, approved by the Department/Secretary on 29/8/2019. It also requires the backfill to be physically and chemically stable and non-polluting. Toxicity characteristic leaching procedure (TCLP) results from the paste fill trial indicate that the concentration of the majority of metals in leachate, including lead (46 mg/L), copper (4.84 mg/L) and zinc (13.9 mg/L), exceeded the adopted site-specific trigger values. These results indicate that the paste fill is potentially polluting. Recommendation: Reassess the method of paste fill testing and the adopted trigger values prior to paste plant recommissioning. Ongoing testing of the paste will be required following paste plant recommissioning. Consider further leachate testing including ASLP.

Non-

Compliant

Audit Findings


MOD 2 EP&A Act 13




Paste Fill The PFMP includes results of the paste fill chemical analysis trial and was approved by the Department/Secretary on 29/8/2019. The PFMP Section 3.3 committed to the provision of operational paste fill testing results to the Department/Secretary in the first Annual Review. Testing results were not included in the 2019-2020 Annual Review. Recommendation: Include paste monitoring results as described in the PFMP in the Annual Review reports. Ongoing monitoring of the paste fill and paste fill water will be required following paste plant recommissioning.

Compliant


Existing Acid Drainage

Approval 07_0143 is dated 4/7/2013 and this condition became non-compliant from 4/7/2018. A passive treatment system has been proposed for the Waste Rock Dam (WRD) and the WRMP specifies implementation of the system by the end of mining operations. Recommendation: Align the timeframe for the passive treatment system implementation between the WRMP and proposed 07_0143MOD3.

Non-

Compliant



Recommendation: Include consultation with Veolia and Infigen Energy in Appendix 4 of the WMP.

Compliant

Schedule 4 Condition 4A Water Management


WMP Section 3.4: Erosion and sedimentation control. Erosion was observed on the western side of the Rehabilitated Waste Rock Dump during the site inspection. Heron advised that due to drought conditions and the timeframe for slope regrading, replanting works have had limited success in this area. Erosion control matting was also observed on this slope. Recommendation: Continue/recommence rehabilitation of the waste rock dump and include erosion control measures as practicable across the site.

Compliant


Blasting Hours

Blasting at the box cut commenced on 25 September 2018. Blast times were not reported in the Annual reviews. Heron advised the blasting hours were compliant with Table 6. Recommendation: Report blasting hours in the Annual Reviews.

Compliant


Blast Management Plan

Recommendation: Include consultation with Veolia and Infigen Energy. Compliant


Waste 200 L metal drums and cut-off intermediate bulk containers (IBCs) containing waste grease were observed south of the Processing Plant, stored on pallets. The containers were unlabelled, uncovered and were not stored within a bund. A large amount of demolition material (including reinforced concrete) was present on the western edge of TDS. Recommendation: Characterise, store, handle and dispose of these containers appropriately, ideally should be stored in a bunded and covered area. The long-term plan for the use/placement of the demolition material should be expressed in the EMS.

Non-

Compliant


Notification of Landowners Air quality exceedances were recorded during the audit period. Investigation concluded the exceedances to be the result of regional dust storms and bushfires and consequently did not inform affected landowners. Recommendation: Review this condition as part of Project Approval MOD 3 such that notification of landowners is not required in the case of off-site generated dust exceedances.

Non-

Compliant

Audit Findings


MOD 2 EP&A Act 14




Revision of Strategies,

Plans and Programs

Recommendation: Clarify document control sections for each management plan to differentiate between document reviews, revisions and submissions to stakeholders. Make clear which stakeholders have been consulted in development of the plans. A number of management plans are non-compliant for approval from the Department/Secretary following the latest revisions. It is noted that a review of the management plans is proposed prior to recommencement of mining operations. Management Plans must be approved by the Department/Secretary prior to implementation and the approval letter should be attached to each plan.

Non-

Compliant

Environmental Protection Licence 20821

R1.5 and R1.7

Annual Return Documents Annual return documents must be retained for a period of at least 4 years. Non-

Compliant

Special Mining Lease 20

3. Mining Operations Plan

and Rehabilitation Report

The location of the waste rock dump was moved from the approved location. The approved location was an existing vegetated area and rather than remove the vegetation, the dump was moved to an already cleared location a short distance away. Heron notified the DPIE of the breach and the non-compliance was reported in the NSW Resources Regulator Compliance Audit (Feb 2020). The location of the box cut mine entry was also altered and was the subject of a penalty notice. Heron advised that the new locations will be included in the Project Approval MOD 3 application.

Non-

Compliant

Conclusion


MOD 2 EP&A Act 15

7.0 Conclusion

This independent environmental audit has been undertaken as per the requirements of Project Approval 07_0143-MOD02 Schedule 6 Condition 9, required every three years following commencement of construction of the Woodlawn Mine project.

The audit assessed the environmental performance of the project against the conditions of the Project Approval, EPL and SML, and the adequacy of management strategies and plans currently in place. Project documentation and records provided by Heron were reviewed and a site inspection was conducted as part of the audit on 17 and 18 February 2022.

This audit reviewed activities undertaken since the last independent environmental audit was completed on 30 June 2018, until 30 June 2021. Recommendations from the previous independent environmental audit generally related to management plan revisions, required prior to recommencement of site operations. Outstanding recommendations from the previous audit have been retained.

Consultation was undertaken with stakeholder agencies. Responses were received from the DPIE and the NSW Resources Regulator. The issues requested to be addressed were consistent with requirements under the Project Approval and have been incorporated in the audit.

The EMS and associated environmental management plans that form the strategy have been reviewed and assessed as being generally adequate to address the approval and licence requirements. It is understood that the EMS and management plans are scheduled for review in preparation for modification 3 of the project approval and mining operations recommencement. All revisions of the plans will require Department/Secretary approval prior to implementation.

A review of compliance with the approval and licence conditions was undertaken in accordance with the DPIE (2020) Independent Audit Post Approval Requirements and identified several non-compliances. While most non-compliances were minor in nature, review of the management plans and approval by the Department/Secretary prior to implementation requires action. In addition, recommendations for improvement for seven conditions have been provided where the intent of the conditions was compliant.

Principles and Limitations of Investigation


MOD 2 EP&A Act 16

8.0 Principles and Limitations of Investigation

This independent environmental audit report was prepared for Heron Resources Pty Ltd in accordance with the Environmental Planning and Assessment Act 1979 (EP&A Act). The audit report has been prepared to demonstrate that the conditions of approval under the EP&A Act for the site have been complied with or to demonstrate where this is not the case.

The scope of work performed as part of the audit process may not be appropriate to satisfy the needs of any other person. Any other person’s use of, or reliance on, the audit document and report, or the findings, conclusions, recommendations or any other material presented to them, is at that person’s sole risk.

The audit is based on a review of the condition of the site at the time of assessment and as described in the supporting documentation viewed as part of the audit and site inspections conducted by the audit team.

The audit and this report are limited by and rely upon the review’s scope and the information provided to the audit team through the documents listed herein. The auditor’s conclusions presented in this report are therefore based on the information made available and on observations made during the audit. The auditor used reasonable care to avoid reliance upon data and information that may be inaccurate.

Table 1: Project Approval 07_0143 MOD 2 Conditions dated July 2017

Approval ID Evidence Comments / Audit Findings / RecommendationsCompliance

Status

Unique Identification on Noncompliance

2 - Assessed below. -

4 - Assessed below. -

7 Personnel interview. Heron confirmed transport routes met this condition. Compliant

7am to 10pm, 7 days per week

Requirement

SCHEDULE 2 ADMINISTRATIVE CONDITIONS

Terms of Approval

1

The Proponent shall carry out the project generally in accordance with the:

-

(a) any strategies, plans, programs, reviews, audits, reports or correspondence that are submitted in accordance with this approval; and

(b) the implementation of any actions or measures contained in these documents.

In addition to meeting the specific performance criteria established under this approval, the Proponent shall implement all reasonable and feasible measures to prevent and/or minimise any material harm to the environment that may result from the construction, operation or rehabilitation of the project.

Limits on Approval

5

Mining Operations

Assessed below. -(a) Environmental Assessment (EA); and

(b) conditions of this approval.

If there is any inconsistency between the above documents, the most recent document shall prevail to the extent of the inconsistency. However, the conditions of this approval shall prevail to the extent of any inconsistency.

3

The Proponent shall comply with any reasonable requirement/s of the Secretary arising from the Department’s assessment of:

- Assessed below. -

Tonnages below extraction and processing conditions. Compliant(a) process more than 1.5 million tonnes of tailings and/or ore on the site in a calendar year; or

(b) transport more than 150,000 tonnes of concentrate from the site in a calendar year.

- Applicable upon cessation of mining operations. Not Triggered

The Proponent may carry out mining operations on the site until 31 December 2034.

Note: Under this approval, the Proponent is required to rehabilitate the site and perform additional undertakings to the satisfaction of both the Secretary and the Department of Resources and Energy. Consequently, this approval will continue to apply in all other respects other than the right to conduct mining operations until the rehabilitation of the site and these additional undertakings have been carried out satisfactorily.

Ore Extraction and Processing

Transportation

The Proponent shall transport all concentrate from the site via Collector Road (east of the site), the Tarago-Bungendore Road (north of Collector Road), Braidwood Road and the Hume Highway.

Hours of Operation

8

The Proponent shall comply with the operating hours in Table 1.

Personnel interview.

6

The Proponent shall not:

2018-2019 and 2019-2020 Annual Reviews, Table 4.1.

Heron confirmed hours of operation met this condition. Compliant

Table 1: Operating Hours

Activity Operating Hours

Construction and rehabilitation 7am to 7pm, 7 days per week

Mining, maintenance and processing operations 24 hours, 7 days per week

Transportation of ore concentrate from the site


Status


Requirement

10 Personnel interview.Heron confirmed no demolition works were undertaken during the audit period.

Not Triggered

9

The Proponent shall ensure that all new buildings and structures, and any alterations or additions to existing buildings and structures, are constructed in accordance with the relevant requirements of the Building Code of Australia (BCA) and the Dams Safety Committee (DSC).


Processing Plant Office Building Information Certificate No.BC/0017/1920.

Concentrate Building Construction Certificate No.CC/0357/1718.

Coffey (Sep 2018) Construction Report, Tailings Storage Facility 4 - Stage 1.DSC letter of approval

The following non-compliances related to this condition were noted in the 2020-2021 Annual Review:- Carrying out building work for the processing plant office without a construction certificate.- Occupation or use of the new concentrate building prior to obtaining an occupation certificate.

Construction certificates were retrospectively provided for these structures.

Compliant

Notes:

Under Part 4A of the EP&A Act, the Proponent is required to obtain construction and occupation certificates for the proposed building works. Part 8 of the EP&A Regulation sets out the requirements for the certification of the project; and

Under the Dams Safety Act 1978, the Proponent will require a further approval for the project’s new tailings storage facility (TSF4).

STRUCTURAL ADEQUACY

OPERATION OF PLANT AND EQUIPMENT

12

The Proponent shall ensure that all the plant and equipment used at the site, or to transport materials from the site, is: Personnel interview, Maintenance Records sighted during site inspection.

- Compliant(a) maintained in a proper and efficient condition; and

(b) operated in a proper and efficient manner.

The Proponent shall ensure that all demolition work is carried out in accordance with Australian Standard AS 2601-2001: The Demolition of Structures, or its latest version.

PROTECTION OF PUBLIC INFRASTRUCTURE

11

Unless the Proponent and the applicable authority agree otherwise, the Proponent shall:

Personnel interview.Heron confirmed no repair or relocation of public infrastructure was required during the audit period.

Not Triggered(a) repair, or pay the full costs associated with repairing, any public infrastructure that is damaged by the project; and

(b) relocate, or pay the full costs associated with relocating, any public infrastructure that needs to be relocated as a result of the development.

STAGED SUBMISSION OF ANY STRATEGY, PLAN OR PROGRAM

13

With the approval of the Secretary, the Proponent may:

Personnel interview. Heron advised an application for MOD3 (modification 3) of the Project Approval will be submitted prior to recommencement of operations. No staged submissions were submitted during the audit period.

Compliant

(a) submit any strategy, plan or program required by this approval on a progressive basis; and

(b) combine any strategy, plan or program required by this approval with any similar strategy, plan or program required for the project.

Notes:

While any strategy, plan or program may be submitted on a progressive basis, the Proponent will need to ensure that the operations on site are covered by suitable strategies, plans or programs at all times; and

If the submission of any strategy, plan or program is to be staged, then the relevant strategy, plan or program must clearly describe the specific stage to which the strategy, plan or program applies, the relationship of this stage to any future stages, and the trigger for updating the strategy, plan or program.

DEMOLITION


Status


Requirement

Environmental Assessment (EA) Vol 1, 4/4/2012

Chapter 4 - Section 4.2.2: Dams Safety Act 1978.

Coffey (Sep 2018) Construction Report, Tailings Storage Facility 4 - Stage 1.DSC letter of approval dated 15/11/2018.

TSF4 construction was assessed during the previous audit period.

Coffey (Feb 2019) Scour damage, TSF4- mitigation recommendations.

Tailings Dams North, South and West did not require repair during the audit period. TSF4 was scoured during a rain event. The remedial recommendation letter issued by Coffey satisfied the requirements of this condition.

- Tailings dams are not yet capped.

Douglas Partners (Oct 2019) Intermediate Surveillance Report 2019.Douglas Partners (Apr 2021) Intermediate Surveillance Report 2020.

Annual Reviews.

Dam surveillance reports found all dams to be in good condition and Heron advised that dams were maintained with a minimum freeboard of 600 mm, reported in the Annual Reviews.The Pollution Control Dam (PCD) overtopped on 9/8/2020 due to a high rainfall event. This is addressed in Schedule 4 Condition 2.

Site inspection.

Personnel interviews.

Heron identified during the site inspection stormwater drainage pipes that direct water from the south into TSF4 in non-compliance with this condition. Heron advised that plans are underway to redirect this clean water over TSF4 and discharge to the north. While the non-compliance results in higher water levels within TSF4, it is considered to pose a low risk of environmental harm.

Non-Compliant NC1

(a) design of all tailings dams on the site is in accordance with the requirements of the Dam Safety Committee (DSC) under the Dams Safety Act 1978 ;

Compliant

(b) lining of the floor and walls of Tailings Storage Facility 4 (TSF4) achieves a permeability of no less than 1 x 10-9 m/s to a depth of at least 900 millimetres of clay (or equivalent) in accordance with the EPA’s Environmental Guidelines for Solid Waste Landfills;

Compliant

(a) a minimum annual road maintenance payment of $0.043 per kilometre per tonne for product transported along Council maintained roads in accordance with Council’s Section 94 Development Contributions Plan 2009 Amendment No. 2 (indexed to inflation); and

(b) a community enhancement payment of $1.26 million over the life of the project in accordance with Council’s Section 94A Development Contributions Plan 2009 Amendment No. 2 , to the satisfaction of Council.

DEVELOPER CONTRIBUTIONS

14

Prior to the commencement of operations on the site, and during the operational life of the project, unless otherwise agreed by the Secretary, the Proponent shall pay Council:


Annual Reviews.

Heron advised that no road maintenance payments were made during the audit period. Given the limited tonnage of product transported, this condition is not yet considered triggered.

The 2018-2019 and 2019-2020 Annual Reviews listed community sponsorships undertaken within the audit period. Heron additionally advised that a $10,000 grant was provided to a local childcare centre for upgrades during the audit period and forms part of the community enhancement payment condition.

(c) material used to repair the facilities achieves a permeability of no less than 1 x 10-9 m/s to a depth of at least 900 millimetres of clay (or equivalent) if the floor and walls of Tailings Dams North, South and West require repairing;

(d) capping of the tailings dams is generally consistent with the site capping requirements contained in the EPA’s Environmental Guidelines for Solid Waste Landfills , and achieves a final landform that is safe, long term stable, and suitable for achieving the

(e) tailings and evaporation dams are maintained with a minimum freeboard of 600 mm or a minimum freeboard sufficient to accommodate a 1 in 100-year ARI, 72-hour rainfall event without overtopping at all times, whichever is greater;

(f) the clean water diversion around Tailings Storage Facility 4 shall be designed, constructed and maintained to prevent the flood waters (up to the probable maximum flood level) from entering the facility;

1

The Proponent shall ensure that the:

SCHEDULE 3 ENVIRONMENTAL PERFORMANCE CONDITIONS

TAILINGS DAMS



Status


Requirement

- - Not Triggered

Consultation sought with DPE - Division of Resources and Geoscience (DRG).

The VRMP Rev 5 was approved by DP&E on 12/5/2017. The plan was subsequently revised with comments from DP&E and with amendments for MOD2. Approval for Rev 8 has not been received by the auditor. This is addressed in Schedule 6 Condition 5.

RRE and RRO have been issued for the Veolia AWT compost (WOO).

Section 4.2.1 includes contingency for use of clay capping material. Additional alternative materials are being trialled, as described by Heron personnel and observed during the site inspection.

Subsidence monitoring reported no trigger value exceedances.

It is noted that the subsidence Trigger Action Response Plans (TARPs) outlined in the Extraction Plan allow for some surface displacement. The Extraction Plan assessed that the use of paste backfill would result in minimal subsidence, beyond the capability of accurate survey. No measurable surface damage was predicted. This conclusion is supported by an independent subsidence prediction and impact assessment included in the Extraction Plan.

Woodlawn organic outputs (WOO) is currently being used in a series of tailings dam rehabilitation trials being conducted on TDN. WOO was obsevred to contain a signfiicant amount of broken glass, it was also stated as being a poor substrate or growth medium; it may therefore only be suitable as a cover or bulking material below a growing medium. However, there is a significant shortage of topsoil type material and alternative materials, in varying strata are being tested in the trial. Trail results are not available yet.

Section 4.1.2: Proposed rehabilitation methods. WOO trial is currently underway to confirm suitable physical capping characteristics.

(g) source of seepage from Tailings Dam South is identified and repaired within 3 years of commencing tailings reprocessing operations on the site; and Site inspection.


Tailings reprocessing operations commenced in March 2019. The source of the seepage has not yet been identified and repaired and it is anticipated that this condition will be Non-Compliant by March 2022. This will subsequently delay lining of the existing seepage collection area. Review of this condition is recommended with recommencement of mining operations.

Not Triggered

(h) existing seepage collection area is lined with a low permeability geotextile membrane within 1 year of completing the repair work on Tailings Dams South, to the satisfaction of the Secretary.

Alternative permeability and thickness standards for the lining and capping of tailings dams may be acceptable following completion of an appropriate risk assessment undertaken in accordance with the Environmental Guidelines – Management of Tailings Storage Facilities (VIC DPI, 2004) - or equivalent, with the written agreement of the Dam Safety Committee, EPA and the Secretary.

2

The Proponent shall prepare and implement a Tailings Rehabilitation Strategy for the project to the satisfaction of the Secretary. The strategy must:

Vegetation and Rehabilitation Management Plan (VRMP) Rev 8, 2/8/2017.

NSW EPA (2020) Resource Recovery Exemption (RRE): Woodlawn organic outputs acid mine tailings trial exemption 2020.

NSW EPA (2020) Resource Recovery Order (RRO): Woodlawn organic outputs acid mine tailings trial order 2020.

(a) be prepared in consultation with DRG;

(b) be submitted to the Secretary for approval prior to commencement of construction on the site;

(c) confirm there would be sufficient capping material to rehabilitate the tailings and evaporation dams;

(d) confirm this material would be available in time for the progressive rehabilitation of the tailings and evaporation dams;

(e) confirm that the physical characteristics of the capping material would be able to achieve the rehabilitation objectives for the tailings dams and the evaporation dams;

(f) confirm the capping material would not result in any additional adverse environmental consequences;

(g) confirm that manner in which the compost from the Veolia AWT is proposed to be used on the site is covered by a valid exemption issued by the EPA; and

(h) include contingency measures to be implemented if the organic material proves to be unsuitable, including detailed plans

The Proponent shall ensure that:

(a) there is no measurable subsidence caused by underground mining beneath the Woodlawn Landfill, tailings dams, and evaporations dams on the site;

Compliant


Tailings Rehabilitation Strategy

UNDERGROUND MINING


Status


Requirement

Extraction Plan Section 4.2.1 details an exclusion zone of 200 m around the existing open cut (Woodlawn Landfill). Heron confirmed that construction operations conformed with the approved design including the 200 m exclusion zone, verified by a design review and sign-off process.

It is recommended that a process to verify compliance with this condition be included in the next revision of the Extraction Plan.

Production stoping commenced during the 2019-2020 review period. The paste plant was also commissioned to generate paste for void backfilling.

Heron personnel advised that daily geochemical testing was undertaken on the paste fill to confirm physical stability.

Subsidence monitoring reported no trigger value exceedances.

The PFMP includes results of the paste fill chemical analysis trial, approved by the Department on 29/8/2019.

TCLP results from the paste fill trial indicate that the concentration of the majority of metals in leachate, including lead (46 mg/L), copper (4.84 mg/L) and zinc (13.9 mg/L), exceeded the adopted site-specific trigger values. These results indicate that the paste fill is potentially polluting.

It is recommended that the method of testing and adopted site specific trigger values are reassessed prior to paste plant recommissioning and paste fill adjusted as required to ensure it is non-polluting. Ongoing testing of the paste will be required following paste plant recommissioning. Consider also using an ASLP leach test.

Non-Compliant NC2

-

Rev 7 approved; no changes apparent in Rev 8 and date coincides with approval date.

Section 2.2: Development of the mine plan.

Performance indicators and actions are addressed in Section 3.9 which details Trigger Action Response Plans (TARPs) for subsidence, water quality and paste fill.

Compliance with Condition 3 is supported by management measures in the Paste Fill and Water Management Plans.

Section 5: Subsidence monitoring program.

- Not Triggered

- Not Triggered

4

The Proponent shall prepare and implement an Extraction Plan for all underground mining at the Woodlawn Mine, to the satisfaction of the Secretary. Each Extraction Plan must:

Extraction Plan Rev 8, 29/8/2019.

DPIE Extraction Plan approval letter, dated 29/8/2019.

DPE Approval of Experts letter, dated 18/10/2016.

Compliant

3


Extraction Plan Rev 8, 29/8/2019.

Paste Fill Management Plan (PFMP) Rev 7, 19/7/2019.

DPIE PFMP approval letter dated 29/8/2019.

Annual Reviews.

Compliant

(a) be prepared by suitably qualified and experienced persons whose appointment has been endorsed by the Secretary;

(b) be approved by the Secretary before the Proponent carries out any underground mining (excluding construction of the underground access decline) at the Woodlawn Mine that is covered by the Extraction Plan;

(c) include detailed plans of existing and proposed underground workings and any associated surface development;

(d) describe in detail the performance indicators and the actions that would be undertaken to ensure compliance with the performance measures in Condition 3 above, and manage or remediate any impacts and/or environmental consequences to meet the rehabilitation objectives in Condition 6 below; and

(e) include a Subsidence Monitoring Program to assist with the management of the risks associated with subsidence, which validates the subsidence predictions, analyses the relationship between the predicted and resulting subsidence effects, and informs contingency planning and the adaptive management process in the underground workings.

The Proponent shall pay all reasonable costs incurred by the Department to engage suitably qualified, experienced and independent experts to review the adequacy of any aspect of an Extraction Plan.

Notes: In accordance with Condition 13 of Schedule 2, the preparation and implementation of Extraction Plans may be staged, with each plan covering a defined area of underground workings. In addition, these plans are only required to contain management plans that are relevant to the specific underground workings that are being carried out.

(b) apart from the access decline, no underground mining is undertaken within 200 m of the perimeter of the Woodlawn Landfill;

(c) remnant underground voids are long term stable to prevent subsidence; and

(d) material used to backfill underground voids is physically and chemically stable and non-polluting.

Extraction Plan


Status


Requirement

Section 4 reports the results of a paste fill chemical analysis trial, completed prior to commissioning of the new paste plant.

Section 5 details a program of ongoing paste fill testing.

The PFMP includes results of the paste fill chemical analysis trial and was approved by the Department on 29/8/2019.

The PFMP Section 3.3 committed to the provision of operational paste fill testing results to the Department in the first Annual Review. Testing results were not included in the 2019-2020 Annual Review.

It is recommended that paste monitoring results as described in the PFMP are included in the Annual Review reports. Ongoing monitoring of the paste fill and paste fill water will be required once mining operations recommence.

(c) prepare a report on the findings of trials and testing, and submit the report to the Secretary for approval prior to the commencement of underground mining operations on the site (excluding construction of the underground access decline).

The Proponent shall rehabilitate the site to the satisfaction of the Secretary. This rehabilitation must be generally consistent with the proposed rehabilitation plan described in the Environmental Assessment (EA) (and reproduced in Appendix 4), and comply with the rehabilitation objectives in Table 2.

5

The Proponent shall commission a suitably qualified expert, whose appointment has been endorsed by the Secretary to:

Paste Fill Management Plan (PFMP) Rev 7, 19/7/2019.

DPE PFMP approval letter dated 29/8/2019.


Annual Reviews.

(a) carry out trials and testing to clarify the physical and leaching characteristics of the paste fill;

Compliant

(b) prepare a program for the ongoing testing of the paste fill to ensure it meets the performance measures in Condition 3 above; and

Rehabilitated slopesAll rehabilitated slopes to be less than 10 degrees and free draining (except for the dam walls which are permitted to have a final slope of up to 18 degrees)

Underground workingsNo measurable subsidence effects on the Woodlawn Landfill, evaporation dams and tailings dams on the site

Surface infrastructure To be decommissioned and removed, unless otherwise agreed with the Secretary

Waste rock dumps Any seepage from the waste rock dumps to be contained and treated on the site

Feature Objectives

Mine site (as a whole)

Safe, stable and non-polluting with no final voids on the surface

Integrated with the rehabilitation of the Woodlawn Landfill

Revegetated with plant species characteristic of Western Tablelands Dry

Forest vegetation community

Drainage linesHydraulically and geomorphologically stable, with vegetation that is in the same condition or better than that which existed prior to mining under this approval

Revegetation areaEstablish at least 71 hectares of the Western Tablelands Dry Forest vegetation community shown in Appendix 3.

6

Annual Reviews.

Site inspection.


Progressive rehabilitation undertaken during the audit period is outlined in the Annual Reviews and included:- WOO trials.- Maintenance of vegetative screen along Collector Road.- Seeding of Hickory's Paddock in early 2019 and March 2020. - The existing waste rock dump has eroded and top soil has washed off it. A plan needs to be formed for regraded and laying of top soil and planting.

Compliant

Tailings dams

All tailings contained within low permeability structures with no seepage to surrounding areas from tailings dams

Final landform and vegetation cover to be stable, self sustaining, free draining and consistent with surrounding rehabilitated areas

Evaporation damsFinal landform and vegetation cover to be stable, self sustaining, free draining and consistent with surrounding rehabilitated areas

Paste Fill

REHABILITATION OBJECTIVES


Status


Requirement

WAL28983WAL42034Annual Reviews

Water licences are held by Heron for extraction from the Lachlan Fold Belt and Goulburn Fractured Aquifer. Water usage is outlined in the Annual Reviews.

Compliant

1

Annual Reviews.

Water Management Plan (WMP) Rev 11, 6/11/2018.

Sufficient water was available for operations during the audit period. Compliant

2

Annual Reviews.


Heron (Sep 2020) Woodlawn Mine Site Pollution Control Dam - Overflow Event 9 August 2020.

No water was discharged from the site during the audit period, with the exception of overtopping of the Pollution Control Dam (PCD) on the 9/8/2020. The dam breach was reported to the EPA on the 4/9/2020.

Water quality in the PCD and measured downstream following the breach indicated the breach did not result in pollution of water.

Compliant

3Waste Rock Management Plan (WRMP) Rev 6, 19/7/2019.

Approval 07_0143 is dated 4/7/2013 and this condition became non-compliant from 4/7/2018. A passive treatment system has been proposed for the Waste Rock Dam (WRD) and the Waste Rock Management Plan (WRMP) outlines implementation of the system by the end of mining operations.

It is recommended that the timeframe for the passive treatment system implementation be aligned between the WRMP and proposed 07_0143MOD3.

Non-Compliant NC3

The WMP Rev 7 was approved by DP&E on 12 May 2017. The plan was subsequently revised with comments from DP&E and with amendments for Project Approval Modification 2. Evidence of approval of the latest version, Rev 11 dated 6 November 2018, was not available. This is addressed in Schedule 6 Condition 5.

Consultation has been recorded with DPI-Water, DP&E, EPA and Water NSW. Heron advised that Veolia and Infigen Energy were also consulted. It is recommended that consultation with these parties be included in Appendix 4 of the WMP.

SCHEDULE 4

ENVIRONMENTAL MANAGEMENT CONDITIONS

WATER RESOURCES

Under the Water Act 1912 and/or the Water Management Act 2000, the Proponent is required to obtain all necessary water licences for the project.

Water Supply

The Proponent shall ensure that it has sufficient water for all stages of the project, and if necessary, adjust the scale of mining operations to match its available water supply, to the satisfaction of the Secretary.

Community Minimise the adverse socio-economic effects associated with mine closure

(b) a Surface Water Management Plan, which includes:

Water Discharges

Except as may be expressly provided by an EPL, the Proponent shall comply with Section 120 of the POEO Act during the carrying out of the project.

Existing Acid Drainage

Within 5 years of the date of this approval, the Proponent shall identify the passive system to treat seepage from the existing Waste Rock Dump in consultation with DRG, and implement the preferred system to the satisfaction of the Secretary.


The Proponent shall prepare and implement a Water Management Plan for the project to the satisfaction of the Secretary. This plan must be prepared in consultation with EPA, DPI – Water, WaterNSW, Infigen Energy and Veolia, by suitably qualified and experienced persons whose appointment has been approved by the Secretary, and submitted to the Secretary for approval prior to the commencement of mining operations under this approval. This plan must include:

baseline data on surface water flow and quality in natural waterbodies that could be affected by the project;

a detailed description of the surface water management system on the site, including the:

- clean water diversions;

(a) a Site Water Balance that includes details of:

Section 2: Site water balance.

sources of water supply;

water use on site, including any potable water use;

water transfers to/from the site; and

any off-site water discharges;


Status


Requirement

It is noted that revision of the WMP is proposed in preparation for mining recommencement.

Compliant

Section 3: Surface water management plan.

4


DPE Management Plans approval letter dated 12/5/2017.


(c) design objectives and performance criteria for the following:

- the surface water management system;

- tailings and evaporation dams; and

- waterbodies that could be affected by the project;

a program to monitor:

- the effectiveness of the water management system;

- erosion and sediment controls;

- water storage structures; and

- tailings and evaporation dams;

- surface water flows, quality, and impacts on other water users;

- potential acid rock drainage from the waste rock dumps;

- potential seepage from tailings and evaporation dams; and

- post-closure water quality;

(d) a Groundwater Management Plan, which includes:

baseline data of all groundwater levels, yield and quality of any privately-owned groundwater

bores that could be affected by the project;

groundwater assessment criteria;

definition of areas of existing groundwater contamination;

- potential seepage from tailings and evaporation dams; and

- the effectiveness of the seepage collection, treatment and storage system associated with the tailings dams, waste rock dumps, evaporation dams and all other water storages that receive contaminated or salt-laden water;

reporting procedures for the results of the monitoring program;

(e) a Surface and Ground Water Response Plan that includes:

Section 3.9 and 4.6 Trigger Action Response Plans (TARPs).

trigger levels for investigating any potential adverse surface water and groundwater impacts of the project, including but not limited to seepage of contaminated water from the tailings dams, waste rock dumps, evaporation dams and the Woodlawn Landfill;

a protocol for the investigation, notification and mitigation of existing groundwater contamination on the site and any exceedances of the surface water and groundwater assessment criteria;

measures to mitigate and/or compensate potentially affected landowners (including compensatory water supply if required);

the procedures that would be followed to determine any appropriate action to be taken to mitigate or offset any surface or groundwater impacts caused by the project that constitute material harm to the environment.

Section 4: Groundwater management plan.

a program to monitor:

- existing groundwater contamination identified on the site;

- impacts on the groundwater supply of potentially affected landowners;

- the volume of groundwater inflow into the underground workings;

- regional groundwater levels and quality in potentially affected aquifers;

- potential groundwater quality impacts from paste fill operations;

Note: The effectiveness of the Water Management Plan is to be reviewed and audited in accordance with the requirements in Schedule 6. Following this review and audit the plan is to be revised to ensure it remains up to date (see Condition 5 of Schedule 6).

- potential acid rock drainage;


Status


Requirement

WMP Section 3.4: Erosion and sedimentation control.

Erosion was observed on the western side of the Rehabilitated Waste Rock Dump during the site inspection. Heron advised that due to drought conditions and the timeframe for slope regrading, replanting works have had limited success in this area. Erosion control matting was also observed on this slope. It is recommended that erosion control measures are continued as practicable across the site.

Bunding and plant equipment appeared to be in suitable condition during the site inspection.

Day/Evening /Night Night

(LAeq(15-minute)) (LA1(max))

All residential receivers

35 45

6

Noise and Blast Management Plan (NBMP) Rev9, 2/8/2017.

Construction and Environmental Management Plan (CEMP) Rev8, 16/9/2016.

NBMP Section 3.1 and CEMP Section 3.5 outline noise mitigation measures.

No exceedances of noise criteria were reported during the audit period.

Compliant

Feature Performance Measure

Erosion and Sediment - GeneralDesign, install and maintain erosion and sediment controls generally in accordance with the series Managing Urban Stormwater: Soils and Construction – Volume 1 and Volume 2E Mines and Quarries

Paste Fill Plant

Design, install and maintain the paste fill plant to minimise potential for uncontrolled flows of tailings, materials, chemicals or waters (including but not limited to bunding of the tailings storage tanks) in accordance with the relevant Australian Standards.

Water Management Performance Measures

4A

The Proponent shall comply with the performance measures in Table 3 to the satisfaction of the Secretary.

Site inspection.


Annual Reviews.


Table 3: Water Management Performance Measures

Compliant

Table 4: Noise Criteria dB(A)

Receivers

Note: After the first review of any EPL granted for this project under Section 78 of the POEO Act, nothing in this approval prevents the EPA from imposing stricter noise limits on the mining operations on site under the EPL.

Appendix 6 sets out the meteorological conditions under which these criteria apply, and the requirements for evaluating compliance with these criteria.

However, these criteria do not apply if the Proponent has an agreement with the relevant owner(s) to exceed the criteria, and the Proponent has advised the Department in writing of the terms of this agreement.

Operating Conditions

NOISE

Noise Criteria

5

The Proponent shall ensure that the noise generated by the project does not exceed the criteria in Table 4 at any residence on privately-owned land.

Annual Reviews. No noise criteria exceedances or noise complaints were reported during the audit period.

Compliant

The Proponent shall implement best management practice, including all reasonable and feasible noise mitigation measures, to minimise the construction, operational, low frequency and road noise from the project, to the satisfaction of the Secretary.


Status


Requirement

Appendix F of the Plan outlines consultation with the EPA.

The NBMP Rev 6 was approved by DP&E on 12/5/2017. The plan was subsequently revised with comments from DP&E and with amendments for MOD2. Approval for Rev 9 has not been received by the auditor. This is addressed by Schedule 6 Condition 5.

It is noted that the current Plan primarily applies to the construction phase of the project and review will be required prior to commencement of mining operations. While processing operations (tailings reclamation) were undertaken within the audit period, the Plan is considered suitably protective for these works.

Section 3.1: Noise mitigation measures.

Section 3.3: Integration with Woodlawn landfill.

Any Time 120 10 0%

Evening - 2

(b) describe the measures that would be implemented to minimise noise generated by the project, including road noise at the St Andrews Anglican Church;

(c) include a monitoring program that:

Section 5: Monitoring program. uses attended monitoring to evaluate the performance of the project; includes a protocol for determining exceedances of the criteria identified in Table 3;

evaluates and reports on the effectiveness of the noise management system on site; and

(d) describe how noise management and monitoring on the site would be integrated with the Woodlawn Landfill.

Noise Management Plan

7

The Proponent shall prepare and implement a Noise Management Plan for the project to the satisfaction of the Secretary. The plan must:

Noise and Blast Management Plan (NBMP) Rev 9, 2/8/2017.


Compliant

(a) be prepared in consultation with the EPA, and submitted to the Secretary for approval prior to commencing construction on the site;

Table 5 – Blasting Criteria

Location Time of BlastingAirblast overpressure (dB(Lin Peak))

Ground vibration (mm/s) Allowable exceedance

BLASTING

Blasting Criteria

8

The Proponent shall ensure that blasting on the site does not cause exceedances of the criteria in Table 5.

Annual Reviews.

2019 Complaints Register.

Letter dated 1/11/2019, Vibration Monitoring 1238 Taylors Creek Road: 10 July - 19 October 2019.

No blast criteria exceedances were reported during the audit period. One vibration complaint was reported during the audit period and was actioned through additional vibration and noise monitoring. The results were provided to the affected landowner, and indicated no evidence of project-related vibrations beyond the SML.

Compliant

Residence on privately owned land

Day 115 5 5% of the total number of blasts over a period of 12 months

Night, and all day on Sundays and public

holidays- 1 0%

Note: All blasts are to be designed by a suitably qualified and experienced blasting engineer.

Blasting Hours

9

The Proponent shall comply with the blasting hours in Table 6.

Annual Reviews.


Blasting at the box cut commenced on 25 September 2018. Blast times were not reported in the Annual reviews. Heron advised the blasting hours were compliant with Table 6. It is recommended that blasting hours are reported in Annual Reviews.

Compliant

Table 6: Blasting Hours

Activity Blasting Hours

Surface blasting. 9am – 5pm Monday to Friday, excluding public holidays

Underground blasting Anytime


Status


Requirement

Section 3.2: Blast Management.

Section 3.2: Blast Management.

Section 5: Monitoring program.

13Site inspection.


Heron advised that no significant doour-generating activities are undertaken on site, confirmed by the site inspection.

Compliant

14Air Quality Management Plan (AQMP) Rev 8, 1/8/2018.

Section 2.3: Greenhouse Gas Emissions. Compliant

10

In relation to above ground blasting, the Proponent may carry out a maximum of 1 blast per day, unless an additional blast is required following a blast misfire.

Annual Reviews.


Blasting frequency was not reported in the Annual Reviews. Heron advised that blasting frequency was compliant with this condition. Above ground blasting has concluded for the project.

CompliantThis condition does not apply to blasts required to ensure the safety of the site or its workers, and to minor additional blasts required during the construction of the box cut to access the underground workings.

Note: For the purpose of this condition, a blast refers to a single blast event, which may involve a number of individual blasts fired in quick succession in a discrete area of the site.

Blasting Frequency


11

During operation of the project, the Proponent shall implement best management practice to:


- Compliant

(a) protect the safety of people and livestock in the surrounding area;

(b) protect public or private infrastructure/property in the surrounding area from any damage; and

(c) minimise the dust and fume emissions from any blasting; and

to the satisfaction of the Secretary.

(c) describe the blast mitigation measures that would be implemented to ensure compliance with the blasting criteria in Table 4; and

(d) include a blast monitoring program to evaluate the performance of the project.

AIR QUALITY

Odour

The Proponent shall ensure that no offensive odours generated by the project are emitted from the site, as defined under the POEO Act.

Greenhouse Gas Emissions

Blast Management Plan

12

The Proponent shall prepare and implement a Blast Management Plan for the project to the satisfaction of the Secretary. This plan must:



Compliant

(a) be prepared in consultation with the Veolia and Infigen Energy, and submitted to the Secretary for approval prior to commencing blasting on the site;

(b) describe the process for incrementally developing and monitoring blasting design;

The Proponent shall implement all reasonable and feasible measures to minimise the release of greenhouse gas emissions from the site to the satisfaction of the Secretary.

Heron confirmed that Veolia and Infigen Energy were consulted in the preparation of the Plan. It is recommended that this consultation is included in Appendix F: Consultation Log.

The NBMP Rev 6 was approved by DP&E on 12/5/2017. The plan was subsequently revised with comments from DP&E and with amendments for MOD2. Approval for Rev 9 has not been received by the auditor. This is addressed in Schedule 6 Condition 5.

It is noted that the current Plan primarily applies to the construction phase of the project and review will be required prior to commencement of mining operations.


Status


Requirement

Averaging Period

d Criterion

Annual a 90 μg/m3

Annual a 30 μg/m3

Averaging Period

d Criterion

24 hour a 50 μg/m3

Maximum total

deposited dust level

c Deposited dust

Annual a 4 g/m2/month

Particulate matter < 10 μm (PM10)

Table 8: Short term impact assessment criterion for particulate matter

Pollutant

Particulate matter < 10 μm (PM10)

Air Quality Criteria

15

The Proponent shall ensure that all reasonable and feasible avoidance and mitigation measures are employed so that particulate matter emissions generated by the project do not exceed the criteria listed in Tables 7, 8 and 9 at any residence on

Air Quality Management Plan (AQMP) Rev 8, 1/8/2018.

Annual Reviews.

Exceedances of depositional dust criteria were recorded throughout January 2019 to December 2020. Heron concluded that the events were related to extraordinary events exempt from this condition (dust storms and bushfires). Dust mitigation measures were reviewed as a result of the exceedances. Mitigation measures included dust suppression of unsealed roads with molasses mixed with water, and ongoing revegetation works.

Compliant

Table 7: Long term impact assessment criteria for particulate matter

Pollutant

Total suspended particulate (TSP) matter

Notes to Tables 6, 7 and 8:

a Total impact (i.e. incremental increase in concentrations due to the project plus background concentrations due to all other sources);

b Incremental impact (i.e. incremental increase in concentrations due to the project on its own);

c Deposited dust is to be assessed as insoluble solids as defined by Standards Australia, AS/NZS

3580.10.1:2003: Methods for Sampling and Analysis of Ambient Air - Determination of Particulate Matter -Deposited Matter - Gravimetric Method; and

d Excludes extraordinary events such as bushfires, prescribed burning, dust storms, fog, fire incidents or any other activity agreed by the Secretary .

Table 9: Long term impact assessment criteria for deposited dust

Pollutant Averaging Period Maximum increase in deposited dust level

b 2 g/m2/month

However, the criteria listed in Tables 6, 7 and 8 do not apply if the Proponent has an agreement with the relevant owner(s) to exceed the criteria, and the Proponent has advised the Department in writing of the terms of this agreement.


16

The Proponent shall:

Annual Reviews. - Compliant(a) implement best practice air quality management on site, including all reasonable and feasible measures to minimise the off-site odour, fume and dust emissions generated by the project; and

(b) minimise any visible air pollution generated by the project; to the satisfaction of the Secretary.


Status


Requirement

Consultation was sought with the EPA.

AQMP Rev 5 was approved by DP&E on 12/5/2017. Approval for Rev 8 has not been received by the auditor. This is addressed in Schedule 6 Condition 5.

Section 3.1: Dust and air quality management initiatives.

Section 3.2: Greenhouse gas mitigation and management.

18Annual Reviews. Website.

An ALS Weather Station is operated onsite by Veolia and data are available on the Heron website and Annual Reviews.

Compliant

Consultation was sought with DP&E, EPA and DPI-Water. It is recommended that future revisions include a consultation record consistent with the other management plans.

WRMP Rev 2 was submitted to DP&E on 20/5/2018. Approval of Rev 6 has not been received by the auditor. This is addressed in Schedule 6 Condition 5.

Section 3.2.3: Disposal and stockpiling of waste rock (PAF). Section 3.2.4: Treatment of PAF waste rock.

Section 3.4: Future management of acid leachate.

Section 4.3: Interpretation and assessment of monitoring results.

(b) describe the measures that would be implemented to ensure compliance with Conditions 13 to 16 above;

(c) include an air quality monitoring program that:

uses a combination of high volumes samplers and dust deposition gauges to evaluate the performance of the project; and NSW Government 13 Department of Planning and Infrastructure

includes a protocol for determining exceedances of the relevant conditions of this approval; and

(d) describe the measures that would be implemented to minimise the release of greenhouse gas emissions from the site

Meteorological Monitoring

Air Quality Management Plan

17

The Proponent shall prepare and implement an Air Quality Management Plan for the project to the satisfaction of the Secretary. This plan must:



Compliant

(a) be prepared in consultation with the EPA, and be submitted to the Secretary for approval prior to commencing construction on the site;

Section 5.1: Environmental monitoring. Section 5.2: Action trigger levels.

(a) be developed in consultation with DRG, EPA and DPI – Water;

(b) be submitted for the approval of the Secretary prior to commencing underground mining operations;

(c) include a detailed description of the procedures to be implemented to monitor and manage potential acid forming material, including:

testing for potentially acid forming waste rock prior to it being brought to the surface;

prioritising the relocation of potential acid forming material to suitable underground locations prior to oxidation;

using all reasonable and feasible measures to prevent waste rock emplaced underground from further oxidising or causing impacts on groundwater;

For the life of the project, the Proponent shall ensure that there is a suitable meteorological station operating in the vicinity of the site that complies with the requirements in the Approved Methods for Sampling of Air Pollutants in New South Wales guideline.

LAND MANAGEMENT

Waste Rock Management Plan

19

The Proponent shall prepare and implement a Waste Rock Management Plan to the satisfaction of the Secretary. The plan must:

Waste Rock Management Plan (WRMP) Rev 6, 19/7/2019.

CompliantSection 3.2: Waste rock management.

trigger levels for any material that has oxidised to the extent that it cannot be placed underground without impacting groundwater quality, and procedures for adequate capping and sealing of such material at the surface;

effective isolation and/or neutralisation of potential acid forming material in waste rock dumps; and

(d) reflect the groundwater and surface water monitoring programs to monitor potentially acid forming waste rock and any leachate generated, including appropriately designed detection and response systems for acid generation (covering monitoring methods, trigger levels and proposed management and/or treatment actions).


Status


Requirement

Rev 6 of the VRMP was approved by the DP&E on 12/5/2017. Approval of Rev 8 has not been received by the auditor. This is addressed in Schedule 6 Condition 5.

Consultation was sought with OEH.

Section 3.2: Vegetation offset

Section 3.4.1: Density and structure.

Section 3.8: Resource salvage.

Section 3.8.4: Seed collection.

Section 3.11: Bushfire management.

Section 3.9: Weed management. Section 3.10: Feral animal control.

Section 5.1: Rehabilitation and vegetation monitoring.

Section 1.3.1: Responsibility.

Vegetation Management Plan

20

The Proponent shall prepare and implement a Vegetation Management Plan for the project to the satisfaction of the Secretary. This plan must:

Vegetation and Rehabilitation Management Plan(VRMP) Rev 8, 2/8/2017.


Compliant

Section 3.3.: Revegetation methods.Section 3.5: maintaining remnant vegetation.

Section 2.2.: Fauna. This section includes measures to minimise impact on fauna including pre-clearance surveys. Section 3.7: Habitat enhancement.

establishing a revegetation planting density that is consistent with the rehabilitation objectives in Table 2 of Schedule 3;

maximising the salvage of resources within the approved disturbance area – including vegetative and soil resources – for beneficial reuse in the rehabilitation of the site;

collecting and propagating seed;

bushfire management;

controlling weeds, feral pests, erosion and access to the revegetation areas; and

(e) include a seasonally-based program to monitor and report on the effectiveness of these measures, and progress against the detailed performance and completion criteria; and

(a) be prepared in consultation with OEH and submitted to the Secretary for approval prior to commencing construction;

(b) describe how the additional 71 hectares of revegetation area (shown in Appendix 3) would be integrated with the overall rehabilitation of the site;

(c) describe the short, medium, and long term measures that would be implemented to:

manage the remnant vegetation and habitat on the site and in the revegetated area/s; and

implement revegetation, including detailed performance and completion criteria;

(d) include a detailed description of the procedures to be implemented for:

minimising the impacts on fauna on site, including pre-clearance surveys;

enhancing the quality of existing vegetation and fauna habitat;

restoring native vegetation and fauna habitat on the revegetated area through focusing on assisted natural regeneration, targeted vegetation establishment and the introduction of fauna habitat features, including establishing and maintaining bat habitat for the Eastern Bent-wing Bat and Yellow-bellied Sheathtail-bat;

(f) include details of who would be responsible for monitoring, reviewing and implementing the plan.


Status


Requirement

Consultation was sought with DPE, OHE, EPA, Water NSW and Council.

Rev 6 of the VRMP was approved by the DP&E on 12/5/2017. Approval of Rev 8 has not been received by the auditor. This is addressed in Schedule 6 Condition 5.

Section 1.4: Legislative requirements.

Section 4: Rehabilitation management.

Section 5.1: Rehabilitation and vegatation monitoring.

Section 4.1.2: Proposed rehabilitation methods.

Section 4.4.3: Completion criteria.

Section 5: Verification and adaptive management.

Section 5.1: Rehabilitation and vegetation monitoring. Section 5.2: Reporting procedures.

23Transport Management Plan (TMP) Rev 7 2/8/2017

Site personnel advised that no incidents were reported during the audit period in relation to transportation of dangerous goods.

Compliant

24 - Completed during previous audit period. Compliant

Progressive Rehabilitation

21

The Proponent shall carry out rehabilitation of the site progressively, that is, as soon as reasonably practicable after disturbance. All reasonable and feasible measures must be taken to minimise the total area exposed for dust generation at any time. Interim rehabilitation strategies shall be employed when areas prone to dust generation cannot be permanently rehabilitated until later in the project life.

Annual Reviews.

Site inspection.


Progressive rehabilitation undertaken during the audit period is outlined in the Annual Reviews and included:- WOO trials.- Maintenance of vegetative screen along Collector Road.- Seeding of Hickory's Paddock in early 2019 and March 2020.

Compliant

Note: It is accepted that some parts of the site that are progressively rehabilitated may be subject to further disturbance at some later stage of the project.

Rehabilitation Management Plan

22

The Proponent shall prepare and implement a Rehabilitation Management Plan for the project to the satisfaction of the Director- General. This plan must:

Vegetation and Rehabilitation Management Plan (VRMP) Rev 8, 2/8/2017.


Compliant

(a) be prepared in consultation with the DRG, EPA, DPI – Water, WaterNSW and Council;

(h) describe the measures that would be implemented to ensure compliance with the relevant conditions of this approval, and address all aspects of rehabilitation including mine closure, final landform, and final land use; and

(i) include a program to monitor, independently audit and report on the ongoing effectiveness of the measures and progress towards the detailed performance and completion criteria.

TRANSPORT

Dangerous Goods

Transportation of all dangerous goods to or from the site shall be undertaken in strict accordance with Australian Code for the Transport of Dangerous Goods by Road and Rail.

Access Road and Intersection Construction

(b) be submitted to the Secretary for approval prior to carrying out mining operations on the site;

(c) be prepared in accordance with any relevant DRG guideline;

(d) outline the procedures to be implemented to achieve the rehabilitation objectives in Condition 6 of Schedule 3;

(e) outline the operational procedures (including testing, monitoring and performance criteria) used to verify the ongoing suitability of the compost material to be used in rehabilitation;

(f) include detailed designs for the short term and long term rehabilitation of tailings and evaporation dams, including surface water management and capping design which takes into account total predicted settlement;

(g) include detailed performance and completion criteria for evaluating the performance of the rehabilitation of the site;

The Proponent shall construct the site access road for heavy vehicles, and associated intersection of this access road, prior to commencing construction of other components of the project on the site. The intersection shall be designed and constructed to the satisfaction of Council and in accordance with the applicable AUSTROADS standards.

Monitoring of Concentrate Transport

25


Vehicle bulk movement manifests were sighted during site inspection.

Annual Reviews.

- Compliant

(a) keep accurate records of the:

amount of copper, lead and zinc concentrate transported from the site (on a monthly basis); and

the date and time of loaded heavy vehicle movements from the site; and

(b) provide the Secretary with a summary of these heavy vehicle movements in the Annual Review.


Status


Requirement

Consultation sought with RMS and Council.

Rev 6 of the TMP was submitted to DP&E on 13/6/2017. Approval of Rev 7 has not been received by the auditor. This is addressed in Schedule 6 Condition 5.

- Compliant

200 L metal drums and cut-off intermediate bulk containers (IBCs) containing waste grease were observed south of the Processing Plant, stored on pallets. The containers were unlabelled, uncovered and were not stored within a bund. A large amount of demolition material (including reinforced concrete) was present on the western edge of TDS.Recommendation: Characterise, store, handle and dispose of these containers appropriately, ideally should be stored in a bunded and covered area. The long term plan for the use/placement of the demolition material should be expressed in the EMS.

Non-Compliant NC4

- Compliant

Road Transport Protocol

26

The Proponent shall prepare and implement a Road Transport Protocol for the project, to the satisfaction of the Secretary. The protocol shall:

Transport Management Plan (TMP) Rev 7, 2/8/2017.

Compliant

Section 3: Transport code of conduct. Section 2.1: Road network.

(a) be prepared in consultation with the Roads and Maritime Services (RMS) and Council;

(b) be submitted to the Secretary for approval prior to carrying out any development on the site;

(c) include a detailed Transport Code of Conduct that addresses:

measures to ensure that heavy vehicles adhere to the designated haulage route in Condition 7 of Schedule 2;

staggering of heavy vehicle departures in consultation with Veolia to minimise impacts on the road network;

driver behaviour including adherence to speed limits, safe overtaking, and maintaining appropriate distances between vehicles;

contingency plans when the designated haulage route is disrupted; and

procedures for ensuring compliance with and enforcement of the Code.

HERITAGE

27

The Proponent shall prepare and implement a Heritage Management Plan for the project to the satisfaction of the Secretary. The Plan must:

Heritage Management Plan (HMP) Rev 6, 31/7/2017.


Rev 6 of the HMP was reviewed during the previous Audit (EES 2021) and found to be compliant. The plan was prepared in consultation with OEH. The Aboriginal stakeholders are yet to be nominated.

Rev 3 was approved by DP&E on 12/5/2017, however evidence of approval of Rev 6 was not available. This is addressed in Schedule 6 Condition 5.

Compliant

(a) be prepared in consultation with OEH and the Aboriginal stakeholders (in relation to the management of Aboriginal heritage values);

(a) establish a vegetation screen along the fence line next to Collector Road within 6 months of commencement of construction;

(b) implement all reasonable and feasible measures to minimise the visual impacts of the project; and

(c) ensure that all external lighting associated with the project complies with Australian Standard AS4282 (INT) 1995 – Control of Obtrusive Effects of Outdoor Lighting, to the satisfaction of the Secretary.

(b) be submitted to the Secretary for approval prior to commencing construction on site;

(c) include consideration of the Aboriginal and non-Aboriginal cultural context and significance of the site;

(d) include programs/procedures and management measures for appropriate identification, management, conservation and protection of both Aboriginal and non-Aboriginal heritage items identified on the site.

VISUAL

28


Site inspection.

Environmental Management Strategy (EMS) Rev 6, 31/7/2018.

Maintenance of the vegetation screen along Collector Road was observed during the site inspection and Heron advised that irrigation is ongoing.

Site personnel confirmed that lighting associated with the project complies with AS4282.

Compliant

WASTE

29


Environmental Management Strategy (EMS) Rev 6, 31/7/2018.

Annual Reviews.

Site inspection.

(a) minimise the waste generated by the project;

(b) ensure that the waste generated by the project is appropriately characterised, stored, handled and disposed of in accordance with the Waste Classification Guidelines (EPA, 2009), or its latest version; and

(c) manage on-site sewage treatment and disposal in accordance with the requirements of Council, to the satisfaction of the Secretary


Status


Requirement

Noise and Blast Management Plan Rev 9, 2/8/2017.

Annual Reviews.

No noise exceedances were reported within the audit period. Not Triggered

Air Quality Management Plan Rev 8, 1/8/2017.

Annual Reviews.


Air quality exceedances were recorded during the audit period. Investigation concluded the exceedances to be the result of regional dust storms and bushfires and consequently did not inform affected landowners.

It is recommended that this condition be reviewed as part of Project Approval MOD3 such that notification of landowners is not required in the case of regional or off-site generated dust exceedances.

Non-Compliant NC5

BUSHFIRE MANAGEMENT

30

The Proponent shall: Environmental Management Strategy (EMS) Rev 6, 31/7/2018.

Annual Reviews.

- Compliant(a) ensure that the project is suitably equipped to respond to any fires on site; and

(b) assist the Rural Fire Service and emergency services as much as possible if there is a fire in the surrounding area.

SCHEDULE 5

ADDITIONAL PROCEDURES

NOTIFICATION OF LANDOWNERS

1

Within two weeks of obtaining monitoring results showing:

(a) an exceedance of any relevant noise criteria in Schedule 4, the Proponent shall notify affected landowners and/ or tenants in writing of the exceedance, and provide regular monitoring results to each of these affected parties until the project is again complying with the relevant criteria; and

If the Secretary is satisfied that an independent review is warranted, then within two months of the Secretary’s decision the Proponent shall:

(a) commission a suitably qualified, experienced and independent person, whose appointment has been approved by the Secretary, to:

consult with the landowner to determine his/ her concerns;

conduct monitoring to determine whether the project is complying with the relevant criteria in Schedule 4; and

if the project is not complying with these criteria then identify measures that could be implemented to ensure compliance with the relevant criteria.

(b) give the Secretary and landowner a copy of the independent review.

(b) an exceedance of any relevant air quality criteria in Schedule 4, the Proponent shall send the affected landowners and/ or tenants a copy of the NSW Health fact sheet entitled “Mine Dust and You” (as may be updated from time to time).

INDEPENDENT REVIEW

2

If an owner of privately-owned land considers the project to be exceeding the relevant criteria in Schedule 4, then he/she may ask the Secretary in writing for an independent review of the impacts of the project on his/her land.

- - Not Triggered

(a) implement all reasonable and feasible mitigation measures, in consultation with the landowner and appointed independent person, and conduct further monitoring until the project complies with the relevant criteria; or

(b) secure a written agreement with the landowner to allow exceedances of the relevant criteria, to the satisfaction of the Secretary.

3If the independent review determines that the project is complying with the relevant criteria in Schedule 4, then the Proponent may discontinue the independent review with the approval of the Secretary.

- - Not Triggered

4

If the independent review determines that the project is not complying with the relevant criteria in Schedule 4, then the Proponent shall:

- - Not Triggered


Status


Requirement

SCHEDULE 6

ENVIRONMENTAL MANAGEMENT, REPORTING AND AUDITING

ENVIRONMENTAL MANAGEMENT

Environmental Management Strategy

receive, handle, respond to, and record complaints;

1

The Proponent shall prepare and implement an Environmental Management Strategy for the project to the satisfaction of the Secretary. This strategy must:

Environmental Management Strategy (EMS) Revision 6 31/7/2018.

Rev 5 of the EMS was issued to DP&E on 10/5/2018 and subsequently revised. Evidence of approval of Rev 6 was not available. This is addressed in Schedule 6 Condition 5.

Compliant

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

respond to any non-compliance;

respond to emergencies; and

(f) include:

Where any exceedance of these criteria and/or performance measures has occurred, the Proponent shall, at the earliest opportunity:

(a) take all reasonable and feasible measures to ensure that the exceedance ceases and does not recur;

(b) consider all reasonable and feasible options for remediation (where relevant) and submit a report to the Department describing those options and any preferred remediation measures or other course of action; and

(c) implement remediation measures as directed by the Secretary, to the satisfaction of the Secretary.

copies of any strategies, plans and programs approved under the conditions of this approval; and

a clear plan depicting all the monitoring required to be carried out under the conditions of this approval.

Adaptive Management

2

The Proponent shall assess and manage project-related risks to ensure that there are no exceedances of the criteria and/or performance measures in Schedules 3 and 4. Any exceedance of these criteria and/or performance measures constitutes a

Annual Reviews. - Compliant

(a) be submitted for approval to the Secretary within 12 months of this approval;

(b) provide the strategic framework for the environmental management of the project;

The EMS (Rev 6) was assessed during the previous audit and found to be compliant.

(c) identify the statutory approvals that apply to the project;

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

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

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

Management Plan Requirements

3

The Proponent shall ensure that the management plans required under this approval are prepared in accordance with any relevant guidelines, and include:

Management Plans as referenced in the Audit Report

All management plans were found to contain the required elements in accordance with this condition.

Compliant

(a) a description of:

effectiveness of any management measures (see b above);

(d) a contingency plan to manage any unpredicted impacts and their consequences and to ensure that ongoing impacts reduce to levels below relevant impact assessment criteria as quickly as possible;

(e) a protocol for managing and reporting any:

incidents and complaints;

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 project or any management measures;

(b) a description of the measures that would be implemented to comply with the relevant statutory requirements, limits, or performance measures/criteria;

(c) a program to monitor and report on the:

impacts and environmental performance of the project;


Status


Requirement

non-compliances with statutory requirements and exceedances of the impact assessment criteria and/or performance criteria; and

(f) a protocol for periodic review of the plan.

Note: The Secretary may waive some of these requirements if they are unnecessary for particular management plans.

Annual Review

4

By the end of December each year (or other such timing as agreed by the Secretary), the Proponent shall review the environmental performance of the project to the satisfaction of the Secretary. This review must:

2018-2019 Annual Review



It is noted that paste monitoring results were not included in the 2019-2020 Annual Review; this has been addressed under Schedule 3 Condition 5.

Compliant

(d) identify any trends in the monitoring data over the life of the project;

(e) identify any discrepancies between the predicted and actual impacts of the project, and analyse the potential cause of any significant discrepancies; and

(f) describe what measures will be implemented over the next year to improve the environmental performance of the project.

(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;

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

the relevant statutory requirements, limits or performance measures/criteria;

requirements of any plan or program required under this approval;

the monitoring results of previous years; and

the relevant predictions in the EA;

(c) identify any non-compliance over the past year, and describe what actions were (or are being) taken to ensure compliance;

Revision of Strategies, Plans and Programs

5

Within three months of:

Management Plans as referenced in the Audit Report

It is recommended that document control sections for each management plan are clarified to differentiate between document reviews, revisions and submissions to stakeholders. A number of management plans are Non-Compliant for approval from the Department/Secretary following the latest revisions. It is noted that a review of the management plans is proposed prior to recommencement of mining operations.

Non-Compliant

(a) the submission of an annual review under Condition 4 above;

(b) the submission of an incident report under Condition 7 below;

(c) the submission of an audit under Condition 9 below; or

(d) any modification to the conditions of this approval (unless the conditions require otherwise), the Proponent shall review, and if necessary revise, the strategies, plans, and programs required under this approval to the satisfaction of the Secretary.

Note: This is to ensure the strategies, plans and programs are updated on a regular basis, and incorporate any recommended measures to improve the environmental performance of the project.

NC6

Community Consultative Committee

6

The Proponent shall establish and operate a CCC for the project in general accordance with the Guidelines for Establishing and Operating Community Consultative Committees for Mining Projects (Department of Planning, 2007, or its latest version), and to the satisfaction of the Secretary. This CCC must be operating prior to commencing construction of the project.

Community Engagement Plan (Rev3, 13/9/2016)

Website

CCC meeting minutes provided on the website demonstrate compliance with the operation of a CCC and appropriate representation from the proponent, Council and the local community. Nine committee meetings were recorded during the audit period.

CompliantNotes:

The CCC is an advisory committee. The Department and other relevant agencies are responsible for ensuring that the Proponent complies with this approval; and

In accordance with the guideline, the Committee should be comprised of an independent chair and appropriate representation from the Proponent, Council, recognised environmental groups and the local communit y.


Status


Requirement

7

Heron (2020) Woodlawn mine site pollution control dam- overflow event 9 August 2020, 4 September 2020.

Incidents reported to the EPA comprised: breach of the Pollution Control Dam (PCD). Heron advised that the incident was reported to the EPA by phone within 7 days of occurrence.

A detailed report was provided to the EPA regarding the PCD breach within 1 month of the incident. As water quality testing was required for the investigation, the condition timeframe of 7 days in not considered applicable. Evidence of notification to the Department was not available.

Compliant

8Website

The 2018-2021 Annual Reviews are provided on the Heron website. Compliant

10 -

REPORTING

Incident Reporting

The Proponent shall notify the Secretary and any other relevant agencies of any incident associated with the project as soon as practicable after the Proponent becomes aware of the incident. Within seven days of the date of the incident, the Proponent shall provide the Secretary and any relevant agencies with a detailed report on the incident.

Regular Reporting

The Proponent shall provide regular reporting on the environmental performance of the project on its website, in accordance with the reporting arrangements in any approved plans of the conditions of this approval.

INDEPENDENT ENVIRONMENTAL AUDIT

(a) be conducted by a suitably qualified, experienced and independent team of experts (including a mine site rehabilitation and water quality expert) whose appointment has been endorsed by the Secretary;

(b) include consultation with the relevant agencies;

(c) assess the environmental performance of the project and assess whether it is complying with the requirements in this approval and any relevant EPL or Mining Lease (including any assessment, plan or program required under these approvals);

(d) review the adequacy of strategies, plans or programs required under the abovementioned approvals; and

(e) recommend appropriate measures or actions to improve the environmental performance of the project, and/ or any assessment, plant or program required under the abovementioned approvals.

Note: This audit team must be led by a suitably qualified auditor and include experts in any fields specified by the Secretary.

9

Within one year of commencing construction of the project, and every three years thereafter, unless the Secretary directs otherwise, the Proponent shall commission and pay the full cost of an Independent Environmental Audit of the project. The audit must:

2018-2021 Audit Report.

-

Compliant

Within six weeks of the completion of this audit, or as otherwise agreed by the Secretary, the Proponent shall submit a copy of the audit report to the Secretary, together with its response to any recommendations contained in the audit report.

ACCESS TO INFORMATION

11

Prior to the commencement of construction on the site, the Proponent shall:

Website

Community Engagement Plan (Rev3, 13/9/2016)

- Compliant

(a) make copies of the following publicly available on its website:

the annual reviews required under this approval;

any independent environmental audit of the project, and the Proponent’s response to the recommendations in any audit;

any other matter required by the Secretary; and

(b) keep this information up-to-date,

the documents referred to in Condition 1 of Schedule 2;

all relevant statutory approvals for the project;

all approved strategies, plans and programs required under the conditions of this approval;

a comprehensive summary of the monitoring results of the project, reported in accordance with the specifications in any approved plans or programs required under the conditions of this or any other approval;

a complaints register, which is to be updated on a monthly basis;

minutes of CCC meetings;


Status


Requirement

APPENDIX 1: SCHEDULE OF LAND

25

14

30

86

91

Mine Site (SML 20)

Lot DP

19

82758821

20

APPENDIX 2 : PROJECT LAYOUT

70

754919

88

92


Status


Requirement

APPENDIX 3: REVEGETATION AREAS


Status


Requirement

APPENDIX 4: REHABILITATION PLAN


Status


Requirement

2 Annual Reviews. - Compliant

3 Annual Reviews. - Compliant

Determination of Meteorological Conditions

Except for wind speed at microphone height, the data to be used for determining meteorological conditions shall be that recorded by the meteorological station located on the site.

Compliance Monitoring

Unless otherwise agreed with the Secretary, monthly attended monitoring is to be used to evaluate compliance with the relevant conditions of this approval.

4

Unless otherwise agreed with the Secretary, this monitoring is to be carried out in accordance with the relevant requirements for reviewing performance set out in the NSW Industrial Noise Policy (as amended from time to time), in particular the requirements relating to:

Noise and Blast Management Plan Rev9, 2/8/2017.

Compliant

(a) monitoring locations for the collection of representative noise data;

1

The noise criteria in Table 3 of the conditions are to apply under all meteorological conditions except the following:

Noise and Blast Management Plan Rev9, 2/8/2017.

- Compliant

(a) during periods of rain or hail;

(b) average wind speed at microphone height exceeds 5 m/s;

(b) meteorological conditions during which collection of noise data is not appropriate;

(c) equipment used to collect noise data, and conformity with Australian Standards relevant to such equipment; and

(d) modifications to noise data collected, including for the exclusion of extraneous noise and/or penalties for modifying factors apart from adjustments for duration.

(c) wind speeds greater than 3 m/s measured at 10 m above ground level; or

(d) temperature inversion conditions greater than 3°C/100 m.

APPENDIX 5: NOISE COMPLIANCE ASSESSMENT

Applicable Meteorological Conditions

Table 2: EPL 20821 issued 29 March 2017, latest version 18 January 2019 Conditions

Approval ID

Evidence Comments / Audit Findings / RecommendationsCompliance Status


A1.1 - - -

`

Concrete works

Contaminated groundwater

Crushing, grinding or separating

Mineral processing

Mineral processing

Mining for minerals

Requirement

1. ADMINISTRATIVE CONDITIONS

A1 What the licence authorises and regulates

This licence authorises the carrying out of the scheduled development work listed below at the premises listed in A2: Infrastructure and facilities to support mining including construction of buildings and ancillary equipment..

A1.2

This licence authorises the carrying out of the scheduled activities listed below at the premises specified in A2. The activities are listed according to their scheduled activity classification, fee-based activity classification and the scale of the operation. Unless otherwise further restricted by a condition of this licence, the scale at which the activity is carried out must not exceed the maximum scale specified in this condition.

Annual ReviewsTonnages were below extraction, processing and waste conditions.

Compliant

Fee Based Activity

Mineral processing > 500000 - 2000000 T annual processing capacity

Mineral waste generation > 100 T annual volume of waste generated or stored

Mining for minerals > 100000 - 500000 T annual production capacity

Scale

Concrete works > 50000 m3 annual production capacity

Contaminated groundwater treatment Any annual handling capacity

Crushing, grinding or separating > 500000 - 2000000 T annual processing capacity

A2 Premises or plant to which this licence applies

A2.1

The licence applies to the following premises:

- - -

Premises Details

WOODLAWN MINE PROJECT

507 COLLECTOR ROAD

TARAGO

a) the applications for any licences (including former pollution control approvals) which this licence

replaces under the Protection of the Environment Operations (Savings and Transitional) Regulation 1998; and

b) the licence information form provided by the licensee to the EPA to assist the EPA in connection with the issuing of this licence.

NSW 2580

THE PREMISES IS DEFINED IN THE MAP "ATTACHMENT 1 WOODLAWN SITE EPL - MONITORING SITES" SUBMITTED BY THE LICENSEE TO THE EPA ON 17 MARCH 2017. DRAWN BY DEAN OLIVER 17-03-2017, DRAWING NO. TOP - G - 001

A3 Information supplied to the EPA

A3.1

Works and activities must be carried out in accordance with the proposal contained in the licence application, except as expressly provided by a condition of this licence.

- - Compliant

In this condition the reference to "the licence application" includes a reference to:

Approval ID



Requirement

EPA identification

no.

1 Dust Monitoring

2 Dust Monitoring

4 Dust Monitoring

5 Meteorological

25 Dust Monitoring

26 Dust Monitoring

P1.2

EPA identification

no.

6 Surface Water Monitoring





11 Ground Water Monitoring













2. DISCHARGES TO AIR AND WATER AND APPLICATIONS TO LAND

Dust Monitoring DG28 - located at Pylara farmDust Monitoring DG22 - eastern side of the EPL 11436 Bioreactor voidDust Monitoring DG33 - (EPL 20476 dust deposition monitoring point 7)Meteorological station located at the EPL 11436 premises.Dust Monitoring DG34 - western side of the EPL 11436 Bioreactor voidHigh Volume Air Sampler HVAS1 – Pylara Farm

P1 Location of monitoring/discharge points and areas

P1.1

The following points referred to in the table below are identified in this licence for the purposes of monitoring and/or the setting of limits for the emission of pollutants to the air from the point.

Type of Monitoring PointType of Discharge Point

Location Description

Environmental Monitoring Plan (EMP) Rev 0, 30/1/2019

Locations are consistent with the EMP. Compliant

Site 115 - Allianoyonyiga Creek

Site 105 - Crisps CreekSite 100 - Woodlawn/Willeroo Boundary South, below Waste Rock Dam.Site 109 - Pylara Boundary below South Tailings Dam.

Site 300 - Processing Plant Pollution Control Dam. Final dam below the new processing facility

MB4

The following utilisation areas referred to in the table below are identified in this licence for the purposes of the monitoring and/or the setting of limits for any application of solids or liquids to the utilisation area.

Type of Monitoring PointType of Discharge Point

Location Description

MB15 - measures seepage from Rehabilitated Waste Rock Dump

Evaporation Dam 2 (ED2)

Tailings Storage Facility 4 (TSF4)

MB11 - below ED2 dam wall



MB5 - southern face of the rehabilitated waste rock dump

MB6 - adjacent to mine entryMB8 - adjacent to Collector Road and downstream of proposed processing plant siteMB12 - below ED2 dam wall

MB13 - western premises boundary

MB14 - background ground water quality site

24 Mine Water MonitoringAt the discharge point into the holding dam being used at the time of monitoring

Approval ID



Requirement

L1.1

Annual Reviews.



No water was discharged from the site during the audit period, with the exception of overtopping of the Pollution Control Dam (PCD) on the 9/8/2020. The dam breach was reported to the EPA on the 4/9/2020.

Water quality in the PCD and measured downstream following the breach indicated the breach did not result in pollution of water.

Compliant.

L2 Noise limits

L2.1 Annual Reviews.No noise criteria exceedances were reported during the audit period.

Compliant

L3 Blasting

Location Time of BlastingAirblast overpressure (dB(Lin Peak))

Ground vibration (mm/s)

Allowable Exceedance

Anytime 120 10 0%

Day 115 55% of the total number of blasts over a period of 12 months

Evening - 25% of the total number of blasts over a period of 12 months

Activity Operating Bours

Construction 7am to 7pm, 7 days per week.

Blasting (underground) Any time

Except as may be expressly provided in any other condition of this licence, the licensee must comply with section 120 of the Protection of the Environment Operations Act 1997.

Noise from the premises must not exceed an LAeq,15 minute noise level of 35 dB(A) at any sensitive receivers.

L2.2

For the purpose of Condition L2.1:

3. LIMIT CONDITIONS

L1. Pollution of waters

Noise and Blast Management Plan (NBMP) Rev 9, 2/8/2017

- Compliant

'Day' is defined as the period from 7am to 6pm Monday to Saturday and 8am to 6pm Sunday and Public Holidays; 'Evening' is defined as the period from 6pm to 10pm on any day; and

'Night' is defined as the period from 10pm to 7am Monday to Saturday and 10pm to 8am Sunday and Public Holidays.

L2.3

The noise emission limits identified in Condition L2.1 apply under meteorological conditions of:

a) Wind speeds up to 3 m/s at 10m above ground level; or

b) temperature inversion conditions of up to 3 °C/100m and wind speeds up to 2 m/s at 10m above ground level

L2.4

Determining Compliance

To determine compliance:

a) with the Leq(15 minute) noise limits in Condition L2.1, the noise measurement equipment must be located:

i) approximately on the property boundary, where any dwelling is situated 30 metres or less from the property boundary closest to the premises; or

ii) within 30 metres of a dwelling façade, but not closer than 3m, where any dwelling on the property is situated more than 30 metres from the property boundary closest to the premises; or, where applicable

L3.1

The licensee must ensure that the airblast overpressure level from blasting at the project does not exceed the criteria in the below table at any residence on privately owned land:

Annual Reviews.No blast criteria exceedances were reported during the audit period.

Compliant

Night, and all day on Sundays and public holidays

- 1

Residence on any privately-owned land

0%

L4 – Hours of Operation

L4.1

Construction activities at the premises must only be conducted between the times specified in the table below:

Personnel interviews. Heron confirmed hours of operation met this condition.

Compliant

Blasting (surface)9am to 5pm Monday to Friday, excluding public holidays

Approval ID



Requirement

L6.1Personnel interviews.

EPL11436 Veolia's licence.

Water use on site was confirmed during personnel interviews.

Compliant

O3.1


Personnel Interviews.

Annual Reviews.

Heron investigated dust exceedances and concluded that generation from site was unlikely and that the events were the result of regional dust storms and bushfires.

Compliant

O4.1

Coffey (Sep 2018) Construction Report, Tailings Storage Facility 4 - Stage 1.DSC letter of approval dated 15/11/2018.

TSF4 construction was assessed during the previous audit period.

Compliant

M1.1

L5 – Potentially Offensive Odour

L5.1

No condition of this licence identifies a potentially offensive odour for the purposes of section 129 of the Protection of the Environment Operations Act 1997.

Site inspectionConsistent with this condition, no offensive odours are expected to be emitted from the project operations.

CompliantNote: Section 129 of the Protection of the Environment Operations Act 1997, provides that the licensee must not cause or permit the emission of any offensive odour from the premises but provides a defence if the emission is identified in the relevant environment protection licence as a potentially offensive odour and the odour was emitted in accordance with the conditions of a licence directed at minimising odour.

L6 -Other Conditions (Use and transfer of waters)

Only treated leachate, treated and untreated mine water, stormwater runoff, raw water from the Woodlawn Dam and water from the Waste Rock Dam may be utilised on-site or discharged to the premises defined in EPL 11436. The discharges and transfers permitted are those shown in Attachment 2 Woodlawn Site EPL Water Transfers, held by the EPA as DOC17/172868.

4. OPERATING CONDITIONS

O1 - Activities must be carried out in a competent manner

O1.1

Licensed activities must be carried out in a competent manner.

Heron (July 2020) Monitoring Operations Plan (MOP) for the Care and Maintenance (C&M) of the Woodlawn Mine Site.

Heron (2015) Woodlawn Mine SML20 Mine Operations Plan.

- Compliant

This includes:

O3 Dust

All operations and activities occurring at the premises must be carried out in a manner that will minimise the emission of dust from the premises.

O4 Waste Management

The liner for Tailings Storage Facility 4 must achieve a permeability of no less than 1x10 ⁻⁹metres per second to a depth of at least 900mm of clay (or equivalent accordance with the EPA's Environmental Guidelines - Solid Waste Landfills (2016)

5. MONITORING AND RECORDING CONDITIONS

M1 Monitoring Records

a) the processing, handling, movement and storage of materials and substances used to carry out the activity; and

b) the treatment, storage, processing, reprocessing, transport and disposal of waste generated by the activity.

O2 Maintenance of plant and equipment

O2.1

All plant and equipment installed at the premises or used in connection with the licensed activity: Maintenance records sighted.

Personnel Interviews. - Complianta) must be maintained in a proper and efficient condition; and

b) must be operated in a proper and efficient manner.

The results of any monitoring required to be conducted by this licence or a load calculation protocol must be recorded and retained as set out in this condition.

M1.2

All records required to be kept by this licence must be:

a) in a legible form, or in a form that can readily be reduced to a legible form;

b) kept for at least 4 years after the monitoring or event to which they relate took place; and

c) produced in a legible form to any authorised officer of the EPA who asks to see them.

Monthly monitoring records sighted.

- Compliant

Approval ID



Requirement

M2.1

Pollutant Unit of Measure Frequency Sampling Method

BOD ] milligrams per litre Quarterly Grab sample

Conductivity microsiemens per centimetre Quarterly Grab sample

Dissolved Oxygen milligrams per litre Quarterly Probe

Nitrogen (ammonia) milligrams per litre Quarterly Grab sample

pH pH Quarterly Grab sample

Potassium milligrams per litre Quarterly Grab sample

Redox potential millivolts Quarterly Grab sample

Total dissolved solids milligrams per litre Quarterly Grab sample

Total organic carbon milligrams per litre \ Quarterly Grab sample


Alkalinity (as calcium carbonate)

milligrams per litre Quarterly Grab sample

Aluminium milligrams per litre Quarterly Grab sample

Arsenic milligrams per litre Quarterly Grab sample

Barium milligrams per litre Quarterly Grab sample

Benzene milligrams per litre Yearly Grab sample

Cadmium milligrams per litre Quarterly Grab sample

Calcium milligrams per litre Quarterly Grab sample

Chloride milligrams per litre Quarterly Grab sample

Chromium (hexavalent) milligrams per litre Yearly Grab sample

Chromium (total) milligrams per litre Quarterly Grab sample

Cobalt milligrams per litre Quarterly Grab sample

Copper milligrams per litre Quarterly Grab sample

Ethyl Benzene milligrams per litre Yearly Grab sample

Fluoride milligrams per litre Quarterly Grab sample

Lead milligrams per litre Quarterly Grab sample

Magnesium milligrams per litre Quarterly Grab sample

Manganese milligrams per litre Quarterly Grab Sample

Mercury milligrams per litre Quarterly Grab sample

Nitrate milligrams per litre Quarterly Grab sample

Nitrite milligrams per litre Quarterly Grab sample

Nitrogen (ammonia) milligrams per litre Quarterly Grab sample

M1.3

The following records must be kept in respect of any samples required to be collected for the purposes of this licence:

a) the date(s) on which the sample was taken;

b) the time(s) at which the sample was collected;

c) the point at which the sample was taken; and

d) the name of the person who collected the sample

M2 Requirement to monitor concentration of pollutants discharged

For each monitoring/discharge point or utilisation area specified below (by a point number), the licensee must monitor (by sampling and obtaining results by analysis) the concentration of each pollutant specified in Column 1. The licensee must use the sampling method, units of measure, and sample at the frequency, specified opposite in the other columns:

Water and/ or Land Monitoring Requirements

POINT 6,7,8,9,10,19,20

POINT 11,12,13,14,15,16,17,18,21,22,23

EPA Annual Returns.

Samples could not be collected from monitoring points 7, 8 and 9 on all occasions due to the creek being dry.

ED2 monitoring point 19 has been superseded by monitoring point 24 due to changed operational role of ED2. Mine dewatering ceased on 19 June 2020 during C&M. Monitoring will resume when dewatering of mine water is recommenced. Recommend update of EPL to remove point 19.

Compliant

EPA Annual Returns.

There was insufficient water in monitoring point 13 for a sample to be obtained for monitoring in the quarter Oct-Dec 19 and in 2021.

Compliant

Approval ID



Requirement

Organochlorine pesticides milligrams per litre \ Yearly Grab sample

Organophosphate pesticides

milligrams per litre ]\ Yearly Grab sample

pH pH Quarterly Grab sample

Chromium (hexavalent) milligrams per litre Yearly Grab sample

Polycyclic aromatic hydrocarbons

milligrams per litre Yearly Grab sample

Potassium milligrams per litre Quarterly Grab sample

Sodium milligrams per litre Quarterly Grab sample

Standing water level Metres Quarterly In Situ

Sulphate milligrams per litre Quarterly Grab sample

Toluene milligrams per litre Yearly Grab sample

Total dissolved solids milligrams per litre Quarterly Grab sample

Total organic carbon milligrams per litre Quarterly Grab sample

Total petroleum hydrocarbons

milligrams per litre Yearly Grab sample

Total phenolics milligrams per litre Yearly Grab sample

Xylene milligrams per litre Yearly Grab sample

Zinc milligrams per litre Quarterly Grab sample


Alkalinity (as calcium carbonate)

milligrams per litre Monthly Grab sample

Ammonia milligrams per litre Monthly Grab sample

Arsenic milligrams per litre Monthly Grab sample

BOD milligrams per litre Monthly Grab sample

Cadmium milligrams per litre Monthly Grab sample

Calcium milligrams per litre Monthly Grab sample

Chloride milligrams per litre Monthly Grab sample

Copper milligrams per litre Monthly Grab sample

microsiemens per

centimetre

Iron milligrams per litre Monthly Grab sample

Lead milligrams per litre Monthly Grab sample

Magnesium milligrams per litre Monthly Grab sample

pH pH Monthly Grab sample

Potassium milligrams per litre Monthly Grab sample

Sodium milligrams per litre Monthly Grab sample

Sulfate milligrams per litre Monthly Grab sample

Total dissolved solids milligrams per litre Monthly Grab sample

Total organic carbon milligrams per litre Monthly Grab sample

Zinc milligrams per litre Monthly Grab sample

M2.2

POINT 24

Mine dewatering ceased on 19 June 2020 during C&M. Monitoring of point 24 will resume when dewatering of mine water is recommenced.

CompliantEPA Annual Returns.Electrical conductivity Monthly Grab sample

Note: Unless otherwise specified, groundwater metals are measured as total, while surface water metals are measured as dissolved.

Approval ID



Requirement

M3.1Environmental Monitoring Plan (EMP) Rev 0, 30/1/2019

- Compliant

M4.1

M4.3

M4.4

M5.1Complaints register. Personnel interviews.

Two complaints were received via the phone line during the audit period. The line is not operational during C&M.

M5.2 Website -

M5.3 - -

- Compliant

Subject to any express provision to the contrary in this licence, monitoring for the concentration of a pollutant discharged to waters or applied to a utilisation area must be done in accordance with the Approved Methods Publication unless another method has been approved by the EPA in writing before any tests are conducted.

M4 Recording of pollution complaints

The licensee must keep a legible record of all complaints made to the licensee or any employee or agent of the licensee in relation to pollution arising from any activity to which this licence applies.

M4.2

The record must include details of the following:

a) the date and time of the complaint;

b) the method by which the complaint was made;

M3- Testing methods - Concentration limits

Complaints register. - Compliant

M5 Telephone complaints line

The licensee must operate during its operating hours a telephone complaints line for the purpose of receiving any complaints from members of the public in relation to activities conducted at the premises or by the vehicle or mobile plant, unless otherwise specified in the licence.

The licensee must notify the public of the complaints line telephone number and the fact that it is a complaints line so that the impacted community knows how to make a complaint.

The preceding two conditions do not apply until 3 months after the date of the issue of this licence

6 – Reporting Conditions

R1 Annual return documents

c) any personal details of the complainant which were provided by the complainant or, if no such details were provided, a note to that effect;

d) the nature of the complaint;

e) the action taken by the licensee in relation to the complaint, including any follow-up contact with the complainant; and

f) if no action was taken by the licensee, the reasons why no action was taken.

The record of a complaint must be kept for at least 4 years after the complaint was made.

The record must be produced to any authorised officer of the EPA who asks to see them.

Compliant

6. a Statement of Compliance - Requirement to Publish Pollution Monitoring Data; and

7. a Statement of Compliance - Environmental Management Systems and Practices.

At the end of each reporting period, the EPA will provide to the licensee a copy of the form that must be completed and returned to the EPA.

R1.2

An Annual Return must be prepared in respect of each reporting period, except as provided below.

R1.1

The licensee must complete and supply to the EPA an Annual Return in the approved form comprising:

Not triggered. a) in relation to the surrender of a licence - the date when notice in writing of approval of the surrender is given; or

b) in relation to the revocation of the licence - the date from which notice revoking the licence operates.

Note: The term "reporting period" is defined in the dictionary at the end of this licence. Do not complete the Annual Return until after the end of the reporting period.

R1.3

Where this licence is transferred from the licensee to a new licensee:

- - Not triggered.

a) the transferring licensee must prepare an Annual Return for the period commencing on the first day of the reporting period and ending on the date the application for the transfer of the licence to the new licensee is granted; and

b) the new licensee must prepare an Annual Return for the period commencing on the date the application for the transfer of the licence is granted and ending on the last day of the reporting period.

1. a Statement of Compliance,

2. a Monitoring and Complaints Summary,

3. a Statement of Compliance - Licence Conditions,

4. a Statement of Compliance - Load based Fee,

5. a Statement of Compliance - Requirement to Prepare Pollution Incident Response Management Plan,

2018-2019 form sighted on EPA portal website, but copy report not available for review.

2019-2020 Annual Return.

2020-2021 Annual Return.

Note: An application to transfer a licence must be made in the approved form for this purpose.

R1.4

Where this licence is surrendered by the licensee or revoked by the EPA or Minister, the licensee must prepare an Annual Return in respect of the period commencing on the first day of the reporting period and ending on:

- -

Approval ID



Requirement

R1.5 eConnect EPA portal eConnect EPA portal with completed returns sighted. Compliant

R1.6 - 2018-2019 Annual Return missing in hard/digital copy Non-compliant

R2.2

R3.2

R3.4

Incidents reported to the EPA comprised breach of the PCD and dust trigger level exceedances. Heron advised that incidents were reported to the EPA by phone within 7 days of occurrence.

A detailed report was provided to the EPA regarding the PCD breach within 1 month of the incident. As water quality testing was required for the investigation, the condition timeframe of 7 days in not considered applicable.

Dust event detailed reports were provided to the EPA on 8/1/2020, 14/1/2020, 16/1/2020, 20/1/2020, 21/1/2020, 10/2/2020, and 14/2/2020. Reports were not provided to the auditor for exceedances recorded from January 2019 to December 2020. However, the events were not considered to comprise 'environmental harm' caused by site operations, but rather the result of extraordinary events (dust storms and bushfires).

Heron (2020) Woodlawn mine site pollution control dam- overflow event 9 August 2020, 4 September 2020.

Heron (Jan-Feb 2020) Dust event letters.

Compliant

Non-compliant

R2 - Notification of environmental harm

R2.1

Notifications must be made by telephoning the Environment Line service on 131 555.

Note: The licensee or its employees must notify all relevant authorities of incidents causing or threatening material harm to the environment immediately after the person becomes aware of the incident in accordance with the requirements of Part 5.7 of the Act.

The licensee must provide written details of the notification to the EPA within 7 days of the date on which the incident occurred.

The Annual Return for the reporting period must be supplied to the EPA via eConnect EPA or by registered post not later than 60 days after the end of each reporting period or in the case of a transferring licence not later than 60 days after the date the transfer was granted (the 'due date').

The licensee must retain a copy of the Annual Return supplied to the EPA for a period of at least 4 years after the Annual Return was due to be supplied to the EPA.

R1.7

Within the Annual Return, the Statements of Compliance must be certified and the Monitoring and Complaints Summary must be signed by:

-Could not verify for 2018-2019 Annual Return. Copy of 2019-2020 Annual Return is not signed.

a) the licence holder; or

b) by a person approved in writing by the EPA to sign on behalf of the licence holder.

R3 – Written Report

R3.1

Where an authorised officer of the EPA suspects on reasonable grounds that:

Personnel interviews. The audit team are not aware of a request for a written report from the EPA. Investigation reports were provided to the EPA consistent with the PIRP.

Not triggered.

a) where this licence applies to premises, an event has occurred at the premises; or

b) where this licence applies to vehicles or mobile plant, an event has occurred in connection with the carrying out of the activities authorised by this licence, and the event has caused, is causing or is likely to cause material harm to the environment (whether the harm occurs on or off premises to which the licence applies), the authorised officer may request a written report of the event.

The licensee must make all reasonable inquiries in relation to the event and supply the report to the EPA within such time as may be specified in the request.

R3.3

The request may require a report which includes any or all of the following information:

a) the cause, time and duration of the event;

b) the type, volume and concentration of every pollutant discharged as a result of the event;c) the name, address and business hours telephone number of employees or agents of the licensee, or a specified class of them, who witnessed the event;d) the name, address and business hours telephone number of every other person (of whom the licensee is aware) who witnessed the event, unless the licensee has been unable to obtain that information after making reasonable effort;

e) action taken by the licensee in relation to the event, including any follow-up contact with any complainants;

f) details of any measure taken or proposed to be taken to prevent or mitigate against a recurrence of such an event; and

g) any other relevant matters.

The EPA may make a written request for further details in relation to any of the above matters if it is not satisfied with the report provided by the licensee. The licensee must provide such further details to the EPA within the time specified in the request.

NC7

Approval ID



Requirement

G1.1 Hard copy of licence sighted. - Compliant

G1.2 - - Not triggered.

G1.3 Hard copy of licence sighted. Accessible next to sign in sheet. Compliant

E1.1 - - -

E1.2 - Stage 3 was commenced within the audit period. -

E1.3Heron (May 2019) Dewatering Progress Report.

Dewatering commenced on 20/11/2018. Mine dewatering ceased on 19 June 2020 during C&M. Monitoring of point 24 will resume when dewatering of mine water is recommenced.

Compliant

E1.4

Personnel Interviews.Annual Reviews. Curtis (undated) Woodlawn Dam Cell 3 ED2 CQA Report.Curtis (undated) Woodlawn Dam Cell 4 ED2 CQA Report.

The 2019-2020 Annual Review reported that mine water was contained within ED2 only. Construction quality assurance reports were available for cells 3 and 4 which demonstrate compliance with the EPA guidelines.

Compliant

8. SPECIAL CONDITIONS

E1. Mine dewatering

The licensee submitted a methodology for the removal, treatment and storage of underground mine water to the EPA on 10 April 2017. The EPA provided

written approval of the methodology in writing on the 9th of May 2017.

The licensee may carry out Stage 3 of dewatering of the underground mine workings in accordance with the proposal contained in the document “Application Under Condition 8 E1.1 of EPL 20821 – Mine Dewatering”, submitted to the EPA on 10 April 2017 (DOC17/221071).

The licensee must submit a report to the EPA every six months regarding the monitoring required under Condition M2, undertaken for Monitoring Point 24 (as defined in Condition P1.3). The first report will be due 6 months following the commencement date of Stage 3 of the dewatering strategy.

Any mine water obtained through any stage of the dewatering strategy must be contained in appropriately lined cells within both ED1 and ED2. The lining of those cells must conform to the EPA's Environmental Guidelines for Solid Waste Landfills (2016).

7. GENERAL CONDITIONS

G1 – Copy of licence kept at the premises or plant

A copy of this licence must be kept at the premises to which the licence applies

The licence must be produced to any authorised officer of the EPA who asks to see it

The licence must be available for inspection by any employee or agent of the licensee working at the premises.

Table 3: SML20, latest version 21 January 2015 Conditions

Approval ID Requirement EvidenceComments / Audit Findings / Recommendations

Compliance Status


(a) Within a period of three months from the date of grant/renewal of this mining lease, the lease holder must serve on each landholder a notice in writing indicating that this mining lease has been granted/renewed and whether the lease includes the surface. A plan identifying each landholder and individual land parcel subject to the lease area, and a description of the lease area must accompany the notice.

(b) If there are ten or more landholders, the lease holder may serve the notice by publication in a newspaper circulating in the region where the lease area is situated. The notice must indicate that this mining lease has been granted/renewed; state whether the lease includes the surface and must contain a plan and description of the lease area. If a notice is made under condition 1(b), compliance with condition 1(a) is not required.

2. Rehabilitation Any disturbance resulting from the activities carried out under this mining lease must be rehabilitated to the satisfaction of the Minister.Annual Reviews.

Site inspection. Progressive rehabilitation underway. Compliant

(a) The lease holder must comply with an approved Mining Operations Plan (MOP) in carrying out any significant surface disturbing activities, including mining operations, mining purposes and prospecting. The lease holder must apply to the Minister for approval of a MOP. An approved MOP must be in place prior to commencing any significant surface disturbing activities, including mining operations, mining purposes and prospecting.

Non-Compliant NC8

(b) The MOP must identify the post mining land use and set out a detailed rehabilitation strategy which:

(i) identifies areas that will be disturbed;

(ii) details the staging of specific mining operations, mining purposes and prospecting;

(iii) identifies how the mine will be managed and rehabilitated to achieve the post mining land use;

(iv) identifies how mining operations, mining purposes and prospecting will be carried out in order to prevent and or minimise harm to the environment; and

(v) reflects the conditions of approval under:

the Environmental Planning and Assessment Act 1979;

the Protection of the Environment Operations Act 1997; and

any other approvals relevant to the development including the conditions of this mining lease.

(c) The MOP must be prepared in accordance with the ESG3: Mining Operations Plan (MOP) Guidelines September 2013 published on the Department's website at www.resources.nsw.qov.au/environment

(d) The lease holder may apply to the Minister to amend an approved MOP at any time.

(e) It is not a breach of this condition if:

(i) the operations which, but for this condition 3(e) would be a breach of condition 3(a), were necessary to comply with a lawful order or direction given under the Environmental Planning and Assessment Act 1979, the Protection of the Environment Operations Act 1997, the Mine Health and Safety Act 2004 I Coal Mine Health and Safety Act 2002 and Mine Health and Safety Regulation 2007 I Coal Mine Health and Safety Regulation 2006 or the Work Health and Safety Act 2011; and

(ii) the Minister had been notified in writing of the terms of the order or direction prior to the operations constituting the breach being carried out.

(f) The lease holder must prepare a Rehabilitation Report to the satisfaction of the Minister. The report must:

(i) provide a detailed review of the progress of rehabilitation against the performance measures and criteria established in the approved MOP;

(ii) be submitted annually on the grant anniversary date (or at such other times as agreed by the Minister); and

(iii) be prepared in accordance with any relevant annual reporting guidelines published on the Department's website at www.resources.nsw.qov.au/environment.

Note: The Rehabilitation Report replaces the Annual Environmental Management Report.

3. Mining Operations Plan and Rehabilitation Report

MINING LEASE CONDITIONS 2013

1. Notice to Landholders - - Not Triggered

Not Triggered

Heron (July 2020) Monitoring Operations Plan (MOP) for the Care and Maintenance (C&M) of the Woodlawn Mine Site.

NSW Resources Regulator Approval of Mining Operations Plan and Assessment of Security Deposit letter dated 13/10/2021.

Heron (2015) Woodlawn Mine SML20 Mine Operations Plan.

NSW Recources Regulator (Feb 2020) Compliance Audit Program, Woodlawn Mine.

The location of the waste rock dump was moved from the approved location. The approved location was an existing vegetated area and rather than remove the vegetation, the dump was moved to an already cleared location a short distance away. Heron notified the DPIE of the breach and the non-compliance was reported in the NSW Resources Regulator Compliance Audit (Feb 2020). The location of the box cut mine entry was also altered and was the subject of a penalty notice.Heron advised that the new locations will be included in the Project Approval MOD 3 application.

Compliant

Annual Reviews Rehabilitation is reported in the Annual Reviews. Compliant


Compliance Status


The lease holder must submit a Compliance Report to the satisfaction of the Minister. The report must be prepared in accordance with any relevant guidelines or requirements published by the Minister for compliance reporting.

(b) The Compliance Report must include:

(i) the extent to which the conditions of this mining lease or any provisions of the Act or the regulations applicable to activities under this mining lease, have or have not been complied with;

(ii) particulars of any non-compliance with any such conditions or provisions,

(iii) the reasons for any such non-compliance;

(iv) any action taken, or to be taken, to prevent any recurrence, or to mitigate the effects, of that non-compliance.

(c) The Compliance Report must be lodged with the Department annually on the grant anniversary date for the life of this mining lease.

(d) In addition to annual lodgement under condition 4(c) above, a Compliance Report:

(i) must accompany any application to renew this mining lease under the Act;

(ii) must accompany any application to transfer this mining lease under the Act; and

(iii) must accompany any application to cancel, or to partially cancel, this mining lease under the Act.

(e) Despite the submission of any Compliance Report under (c) or (d) above, the titleholder must lodge a Compliance Report with the Department at any date or dates otherwise required by the Minister.(f) A Compliance Report must be submitted one month prior to the expiry of this mining lease, where the licence holder is not seeking to renew or cancel this mining lease.

5. Environmental (a) The lease holder must notify the Department of all:

Incidence Report (i) breaches of the conditions of this mining lease or breaches of the Act causing or threatening material harm to the environment; and

(ii) breaches of environmental protection legislation causing or threatening material harm to the environment (as defined in the Protection of the Environment Administration Act 1991), arising in connection with significant surface disturbing activities, including mining operations, mining purposes and prospecting operations, under this mining lease. The notification must be given immediately after the lease holder becomes aware of the breach.

Note. Refer to www.resources.nsw.gov.au/environment for notification contact details.

(b) The lease holder must submit an Environmental Incident Report to the Department within seven (7) days of all breaches referred to in condition 5(a)(i) and (ii). The Environmental Incident Report must include:

(i) the details of the mining lease;

(ii) contact details for the lease holder;

(iii) a map identifying the location of the incident and where material harm to the environment has or is likely to occur;

(iv) a description of the nature of the incident or breach, likely causes and consequences;

(v) a timetable showing actions taken or planned to address the incident and to prevent future incidents or breaches referred to in S(a).

(vi) a summary of all previous incidents or breaches which have occurred in the previous 12 months relating to significant surface disturbing activities, including mining operations, mining purposes and prospecting operations under this mining lease.

Note. The lease holder should have regard to any relevant Secretary's guidelines in the preparation of an Environmental Incident Report. Refer to www.resources.nsw.gov.au/environment for further details.

(c) In addition to the requirements set out in conditions S(a) and (b), the lease holder must immediately advise the Department of any notification made under section 148 of the Protection of the Environment Operations Act 1997 arising in connection with significant surface disturbing activities including mining operations, mining purposes and prospecting operations, under this mining lease.

6. Resource Recovery The lease holder must optimise recovery of the minerals that are the subject of this mining lease to the extent economically feasible. Annual Reviews. - Compliant

Compliant

No incidents causing or threatening material harm to the environment were reported during the audit period.

Breach of the Pollution Control Dam (PCD) occurred in August 2019, however the water quality was assessed to present minimal environmental impact. A report was submitted to the EPA following water testing, in September 2019.

Annual Reviews.


4. Compliance Report Compliance is reported in the Annual Reviews. Compliant


Compliance Status


The lease holder is required to provide and maintain a security deposit to secure funding for the fulfilment of obligations of all or any kind under the mining lease, including obligations of all or any kind under the mining lease that may arise in the future.

The amount of the security deposit to be provided has been assessed by the Minister at

$6,077,000.00.

The additional security amount of $3,577,000.00 is to be lodged prior to commencement of any on ground activity.

The Department shall hold the current security of $2,500,000.00 against this lease for a period of five years as stated in the letter co-signed by Veolia Environmental Services (Australia) Pty Ltd and TriAusMin Minerals Limited dated 24 September 2013.

The lease holder must make every reasonable attempt, and be able to demonstrate its attempts, to enter into a cooperation agreement with the holder(s) of any overlapping title(s). The cooperation agreement should address but not be limited to issues such as: access arrangements

operational interaction procedures

dispute resolution

information exchange

well location

timing of drilling

potential resource extraction conflicts; and

rehabilitation issues.

Note: Exploration Reports (Geological and Geophysical)

The lease holder must lodge reports to the satisfaction of the Minister in accordance with section 163C of the Mining Act 1992 and in accordance with clause 57 of the Mining Regulation 2010.

Reports must be prepared in accordance with Exploration Reporting: A guide for reporting on exploration and prospecting in New South Wales (Department of Trade and Investment; Regional Infrastructure and Services 2010).

Not Triggered7. Security - Prior to audit period.

8. Cooperation Agreement Personnel interviews. A cooperation agreement is in place with Veolia. Compliant

Exploration Reporting

Heron (Dec 2019, Dec 2020, Nov 2021) Environmental and Rehabilitation Compliance Report EL72572018.

Heron (Dec 2018, Dec 2019, Dec 2020, Nov 2021) Annual Report, Woodlawn Regional Project EL7257.

- Compliant


Compliance Status


SPECIAL CONDITIONSNote: The standard conditions apply to all mining leases. The Division of Resources & Energy (DRE) reserves the right to impose special conditions, based on individual circumstances, where appropriate.

(A) Notwithstanding any Mining Operations Plan, the lease holder must not mine within any part of the lease area which is within the notification area of the Woodlawn Notification Area which surrounds the Woodlawn Mine Evaporation 1, Woodlawn Mine Evaporation 2, Woodlawn North Tailings, Woodlawn South Tailings and Woodlawn West Tailings Dams without the prior written approval of the Minister and subject to any conditions he may stipulate.

(B) Where the lease holder desires to mine within the notification area he must:

(i) at least twelve (12) months before mining is to commence or such lesser time as the Minister may permit, notify the Minister of the desire to do so. A plan of the mining system to be implemented must accompany the notice; and

(ii) provide such information as the Minister may direct.

(C) The Minister must not, except in the circumstances set out in sub-paragraph (ii), grant approval unless sub-paragraph (i) of this paragraph has been complied with.

(i) This sub-paragraph is complied with if:

(a) the Dams Safety Committee as constituted by Section 7 of the Dams Safety Act 1978 and the owner of the dam have been notified in writing of the desire to mine referred to in paragraph (B).

(b) the notifications referred to in clause (a) are accompanied by a description or plan of the area to be mined.

(c) the Director-General has complied with any reasonable request made by the Dams Safety Committee or the owner of the dam for further information in connection with the mining proposal.

(d) the Dams Safety Committee has made its recommendations concerning the mining proposal or has informed the Minister in writing that it does not propose to make any such recommendations; and

(e) where the Dams Safety Committee has made recommendations the approval is in terms that are: in accordance with those recommendations; or where the Minister does not accept those recommendations or any of them - in accordance with a determination under sub-paragraph (ii) of this paragraph.

(ii) Where the Minister does not accept the recommendations of the Dams Safety Committee or where the Dams Safety Committee has failed to make any recommendations and has not informed the Minister in writing that it does not propose to make any recommendations, the approval shall be in terms that are, in relation to matters dealing with the safety of the dam:

(a) as determined by agreement between the Minister and the Minister administering the Dams Safety Act 1978; or

(b) in the event of failure to reach such agreement - as determined by the Premier.

(D) The Minister, on notice from the Dams Safety Committee, may at any time or times:

(i) cancel any approval given where a notice pursuant to Section 18 of the Dams Safety Act 1978 is given.

(ii) suspend for a period of time, alter, omit from or add to any approval given or conditions imposed.

9. Prescribed Dam Prior to audit period. Compliant

NSW Planning & Environment Resources Regulator (April 2017a) Heron Resources Ltd application to mine within the Woodlawn Notification Area: Woodlawn - 1.

NSW Planning & Environment Resources Regulator (April 2017b) Heron Resources Ltd application to mine within the Woodlawn Notification Area: Woodlawn - 2.

Table 4: Proponent Response Table

Condition Number Compliance Requirement Independent Audit Finding/RecommendationCompliance Status


Proponent's Proposed Action/Response Proposed Action Due Date

Schedule 3 Condition 1Tailings Dams

The Proponent shall ensure that the:(f) the clean water diversion around Tailings Storage Facility 4 shall be designed, constructed and maintained to prevent the flood waters (up to the probable maximum flood level) from entering the facility;

Heron identified during the site inspection stormwater drainage pipes that direct water from the south into Tailings Storage Facility 4 (TSF4) in non-compliance with this condition. Heron advised that plans are underway to redirect this clean water over TSF4 and discharge to the north. While the non-compliance results in higher water levels within TSF4, it is considered to pose a low risk of environmental harm.

Recommendation: Implement redirection of stormwater.

Non-Compliant NC1

Design works for diversion of stormwater away from TSF4 will be commenced when resources become available following the sale of Woodlawn Mine.The timing of the construction of the diversion will be undertaken based on risk assessment that considers pollution to the environment and TSF embankment stability.In the meantime stormwater is effectively managed by pumping water out of TSF4 into TDS as part of the site water management strategy during care and maintenance.

As early as practicable following the sale of Woodlawn Mine.

Schedule 3 Condition 1Tailings Dams

The Proponent shall ensure that the:(g) source of seepage from Tailings Dam South is identified and repaired within 3 years of commencing tailings reprocessing operations on the site; and(h) existing seepage collection area is lined with a low permeability geotextile membrane within 1 year of completing the repair work on Tailings Dams South, to the satisfaction of the Secretary.

Tailings reprocessing operations commenced in TDS in March 2019. The source of the seepage has not yet been identified and repaired and it is anticipated that this condition will be Non-Compliant by March 2022. This will subsequently delay lining of the existing seepage collection area.

Recommendation: Review the timing of this condition in 07_0143-MOD03 prior to recommencement of mining operations.

Not Triggered Agree.The Proponent will seek an amendment to this condition.Following the recent discovery of the original design documentation for TDS and a subsequent inspection by a tailings dam engineer the dam has been deemed to be operating as designed. That is, the seepage discharge visible at the southern toe of TDS is as expected and consequently there is no leak. Additionally the engineer has advised that as the dam is operating as designed there is no leak to repair. In view of this new revelation, it is planned to obtain further detailed independent expert advice. The likely outcome will be a request to modify the Consent by removal of Schedule 3, Condition 1(g) and a modification to the required time-line for the lining of the seepage collection dam detailed in Schedule 3, Condition 1(h).


Schedule 3 Condition 3Underground Mining

The Proponent shall ensure that the:(b) apart from the access decline, no underground mining is undertaken within 200 m of the perimeter of the Woodlawn Landfill;

Extraction Plan Section 4.2.1 details an exclusion zone of 200 m around the existing open cut (Woodlawn Landfill). Heron confirmed that construction operations conformed with the approved design including the 200 m exclusion zone, verified by a design review and sign-off process.

Recommendation: Include a process to verify compliance with this condition in the next revision of the Extraction Plan.

Compliant

Agree.The current Life of Mine Plan (conceptual mine design) completed in 2020/2021 complies with this condition.The underground excavation design approval processes (final design for execution) will be revised to incorporate a specific check of the planned excavation against this condition and formal documentation of this process will be incorporated into the Extraction Plan.


Schedule 3 Condition 3Underground Mining

The Proponent shall ensure that the:(d) material used to backfill underground voids is physically and chemically stable and non-polluting.

The PFMP includes results of the paste fill chemical analysis trial, approved by the Department on 29/8/2019. It also requires the backfill to be physically and chemically stable and non-polluting.Toxicity characteristic leaching procedure (TCLP) results from the paste fill trial indicate that the concentration of the majority of metals in leachate, including lead (46 mg/L), copper (4.84 mg/L) and zinc (13.9 mg/L), exceeded the adopted site-specific trigger values. These results indicate that the paste fill is potentially polluting.

Recommendation: Reassess the method of paste fill testing and the adopted trigger values prior to paste plant recommissioning. Ongoing testing of the paste will be required following paste plant recommissioning. Consider further leachate testing including ASLP.

Non-Compliant NC2

Agree.The PFMP will be reviewed prior to resumption of paste fill operations.Monitoring during paste fill production operations will be undertaken on an ongoing basis as detailed in the PFMP.

Prior to the resumption of paste fill placement in underground voids and ongoing monitoring thereafter.

Schedule 3 Condition 5Paste Fill

The Proponent shall commission a suitably qualified expert, whose appointment has been endorsed by the Secretary to:(c) prepare a report on the findings of trials and testing, and submit the report to the Secretary for approval prior to the commencement of underground mining operations on the site (excluding construction of the underground access decline).

The PFMP includes results of the paste fill chemical analysis trial and was approved by the Department on 29/8/2019.The PFMP Section 3.3 committed to the provision of operational paste fill testing results to the Department in the first Annual Review. Testing results were not included in the 2019-2020 Annual Review.

Recommendation: Include paste monitoring results as described in the PFMP in the Annual Review reports. Ongoing monitoring of the paste fill and paste fill water will be required following paste plant recommissioning.

Compliant

Monitoring during paste fill production operations will be undertaken on an ongoing basis as detailed in the PFMP.

Following the resumption of paste fill placement in underground voids.

Schedule 4 Condition 3Existing Acid Drainage

Within 5 years of the date of this approval, the Proponent shall identify the passive system to treat seepage from the existing Waste Rock Dump in consultation with DRG, and implement the preferred system to the satisfaction of the Secretary.

Approval 07_0143 is dated 4/7/2013 and this condition became non-compliant from 4/7/2018. A passive treatment system has been proposed for the Waste Rock Dam (WRD) and the WRMP specifies implementation of the system by the end of mining operations. Recommendation: Align the timeframe for the passive treatment system implementation between the WRMP and proposed 07_0143MOD3.

Non-Compliant NC3

Agree.The Proponent will seek a Mod to Approval 07_0143 to align with the WRMP following completion of the Woodlawn Mine sale process.

As early as possible following the sale of Woodlawn

Project Approval




Schedule 4 Condition 4Water Management Plan

The Proponent shall prepare and implement a Water Management Plan for the project to the satisfaction of the Secretary. This plan must be prepared in consultation with EPA, DPI – Water, WaterNSW, Infigen Energy and Veolia, by suitably qualified and experienced persons whose appointment has been approved by the Secretary,

Recommendation: Include consultation with Veolia and Infigen Energy in Appendix 4 of the WMP.

Compliant

Agree.Water management on site is constantly being reviewed at an operational level in consultation with Veolia. Additionally, in accordance with the Cooperation Deed with Veolia established as a condition of the SML20 Licence, water management is a critical operational issue. Therefore consultation is regular and ongoing. Details of the consultation will be included in future revisions of the WMP. Consultation with Iberdrola (formerly Infigen) regarding site water management will be

Incorporate into next revision of WMP.

Schedule 4 Condition 4AWater Management Performance Measures

Design, install and maintain erosion and sediment controls generally in accordance with the series Managing Urban Stormwater: Soils and Construction – Volume 1 and Volume 2E Mines and Quarries

Erosion was observed on the western side of the Rehabilitated Waste Rock Dump during the site inspection. Heron advised that due to drought conditions and the timeframe for slope regrading, replanting works have had limited success in this area. Erosion control matting was also observed on this slope. Recommendation: Continue/recommence rehabilitation of the waste rock dump and include erosion control measures as practicable across the site.

Compliant

Agree. N/A

Schedule 4 Condition 9Blasting Hours

The Proponent shall comply with the blasting hours in Table 6.

Blasting at the box cut commenced on 25 September 2018. Blast times were not reported in the Annual reviews. Heron advised the blasting hours were compliant with Table 6.

Recommendation: Report blasting hours in the Annual Reviews.

Compliant

Agree. It is advised that records of all blast events were included in the Monthly Environmental Report.

For further clarification - the blasting at the box cut that commenced on 25 September 2018 was for the Portal of the underground Decline. Surface blasting was completed prior to September 2018.When operations recommence, underground blasting is likely to occur mutiple times per day at any time (as permitted in the Project Approval).

Schedule 4 Condition 12Blast Management Plan

The Proponent shall prepare and implement a Blast Management Plan for the project to the satisfaction of the Secretary. This plan must:(a) be prepared in consultation with the Veolia and Infigen Energy, and submitted to the Secretary for approval prior to commencing blasting on the site;

Recommendation: Include consultation with Veolia and Infigen Energy.

Compliant

Agree.Blast monitoring on site undertaken in consultation with Veolia. Additionally, in accordance with the Cooperation Deed with Veolia established as a condition of the SML20 Licence, vibration monitoring is a critical operational issue. Therefore consultation is regular and ongoing. This consultation with Veolia will be included in further revisions of the Blast Management Plan.Consultation with Iberdrola (formerly Infigen) regarding blast management will also be included in future revisions to the BMP.

Incorporate into next revision of BMP.

Schedule 4 Condition 29Waste

The Proponent shall:(b) ensure that the waste generated by the project is appropriately characterised, stored, handled and disposed of in accordance with the Waste Classification Guidelines (EPA, 2009), or its latest version; and

200 L metal drums and cut-off intermediate bulk containers (IBCs) containing waste grease were observed south of the Processing Plant, stored on pallets. The containers were unlabelled, uncovered and were not stored within a bund. A large amount of demolition material (including reinforced concrete) was present on the western edge of TDS.

Recommendation: Characterise, store, handle and dispose of these containers appropriately, ideally should be stored in a bunded and covered area.in The long term plan for the use/placement of the demolition material should be expressed in the right plan. Accordance with the Waste Classification Guidelines.

Non-Compliant NC4 * The six 200L grease drums and 3 cut-off IBCs have been retained on site because the cost of disposal was prohibitive during the constrained financial situation at Woodlawn. The containers have now been relocated to a more suitable storage area. The waste grease will be disposed of appropriately utilising a licensed contractor when funding becomes available.

* The reinforced concrete material on TDS is understood to be from the demolition of the original processing plant infrastructure removed from the original Woodlawn Mine. The material has been in its present location for many years. It is planned that the material to be incorporated into the tailings dam prior to final capping.

*Agree. The details for management of waste on site is presently contained in the "Construction Environmental Management Plan". The details will be incorporated into the next revision of the Environmental Management Strategy.


Schedule 5 Condition 1Notification of Landowners

Within two weeks of obtaining monitoring results showing:(b) an exceedance of any relevant air quality criteria in Schedule 4, the Proponent shall send the affected landowners and/ or tenants a copy of the NSW Health fact sheet entitled “Mine Dust and You” (as may be updated from time to time).

Air quality exceedances were recorded during the audit period. Investigation concluded the exceedances to be the result of regional dust storms and bushfires and consequently did not inform affected landowners.

Recommendation: Review this condition as part of Project Approval MOD 3 such that notification of landowners is not required in the case of off-site generated dust exceedances.

Non-Compliant NC5

Agree.This recommendation will be included in MOD 3 to the Project Approval.


Schedule 5 Condition 5Revision of Strategies, Plans and Programs

... the Proponent shall review, and if necessary revise, the strategies, plans, and programs required under this approval to the satisfaction of the Secretary.

Recommendation: Clarify document control sections for each management plan to differentiate between document reviews, revisions and submissions to stakeholders. Make clear which stakeholders have been consulted in development of the plans.A number of management plans are non-compliant for approval from the Department following the latest revisions. It is noted that a review of the management plans is proposed prior to recommencement of mining operations. Management Plans must be approved by the Department/Secretary prior to implementation and the approval letter should be attached to each plan.

Non-Compliant NC6

Agree.We will consult with the Department during the imminent revisions that are necessary in view of the forthcoming sale of Woodlawn Mine.





R1.5 and R1.7Annual Return Documents

The licensee must retain a copy of the Annual Return supplied to the EPA for a period of at least 4 years after the Annual Return was due to be supplied to the EPA.

Within the Annual Return, the Statements of Compliance must be certified and the Monitoring and Complaints Summary must be signed by:a) the licence holder; orb) by a person approved in writing by the EPA to sign on behalf of the licence holder.

Signed Annual Return documents must be retained for a period of at least 4 years.

Non-Compliant NC7

Agree.A raw digital version of the 2018/19 return can be accessed on the EPA Connect website. However, the signed version cannot be located following the suspension of operations at Woodlawn in March 2020 and associated loss of personnel involved in the signing of the return. On-site document control has been revised and improved by the introduction of the document management system "The HUB". The HUB is designed to minimise the risk of 'losing' documentation in the future.

N/A

3. Mining Operations Plan and Rehabilitation Report

(a) The lease holder must comply with an approved Mining Operations Plan (MOP) in carrying out any significant surface disturbing activities, including mining operations, mining purposes and prospecting. The lease holder must apply to the Minister for approval of a MOP. An approved MOP must be in place prior to commencing any significant surface disturbing activities, including mining operations, mining purposes and prospecting.

The location of the waste rock dump was moved from the approved location. The approved location was an existing vegetated area and rather than remove the vegetation, the dump was moved to an already cleared location a short distance away. Heron notified the DPIE of the breach and the non-compliance was reported in the NSW Resources Regulator Compliance Audit (Feb 2020). The location of the box cut mine entry was also altered and was the subject of a penalty notice.Heron advised that the new locations will be included in the Project Approval MOD 3 application.

Non-Compliant NC8

Agree.These changes will be included in the MOD 3 application.


Environment Protection Licence 20821

Special Mining Licence 20

Appendix A: Audit Team Supporting Documents

4 Parramatta Square, 12 Darcy Street, Parramatta 2150 | dpie.nsw .gov.au | 1

Heron Resources LimitedAttention: Dr Zoe Read609 COLLECTOR ROADTARAGO New South Wales 2580

23/11/2021

Dear Dr Read

Woodlawn Mine Project - (MP07_0143)Independent Environmental Audit - Audit Team Endorsement Request

I refer to your application submitted to the Department of Planning, Industry and Environment (theDepartment) on 15 November 2021, seeking the Secretary’s approval of the IndependentEnvironmental Audit (IEA) audit team in accordance with Schedule 6 Conditions 9 for theWoodlawn Mine Project MP07_0143 (the Consent).

The Department has reviewed the nomination and information you have provided and is satisfiedthat Senversa Pty Ltd IEA team is suitably qualified and experienced. Consequently, I can advisethat the Secretary approves the appointment of the audit team to undertake the IEA and prepare theIEA Report. In accordance with the Consent and the Independent Audit Post ApprovalRequirements, the Secretary has agreed to the following Senversa Pty Ltd audit team consisting of:

Mr Jason Clay – Lead Auditor/Director

Ms Roxanne McKinnon – Audit Manager

Dr Andrei Woinarski – Surface Water Expert

Please ensure this correspondence is appended to the IEA report.

In addition to the audit team listed above, and in accordance with Schedule 6 Condition 9 of theConsent, the Planning Secretary requests that experts in the field of mine site rehabilitation andgroundwater, are also included in the audit team and endorsed by the Planning Secretary.

The IEA must be prepared, undertaken, and finalised in accordance with the requirements ofAS/NZS ISO 19011-2014: Guidelines for Auditing Management Systems and have regard for theIndependent Audit Post Approval Requirements. Failure to meet these requirements will requirerevision and resubmission.

The Department reserves the right to request an alternate auditor or audit team for future audits.Notwithstanding the agreement for the above listed audit team for this Project, each respectiveproject approval or consent requires a request for the agreement to the auditor or audit team besubmitted to the Department, for consideration of the Secretary. Each request is reviewed anddepending on the complexity of future projects, the suitability of a proposed auditor or audit team willbe considered.

In accordance with Schedule 6 Condition 10 of the Consent, within six weeks of the completion ofthe audit, or otherwise as agreed to by the Secretary, Heron Resources is to submit a copy of theaudit report to the Planning Secretary, together with its response to any recommendationscontained in the audit report and a timetable to implement the recommendations. Prior to submitting

http://www.dpie.nsw.gov.au/

the audit report to the Planning Secretary, it is recommended that Heron Resources review thereport to ensure it complies with the relevant condition of approval.

If you wish to discuss the matter further, please contact Jennifer Rowe on 0242471851.

Yours sincerely

Katrina O'ReillyTeam Leader - ComplianceCompliance

As nominee of the Planning Secretary

Department of Planning and Environment

4 Parramatta Square, 12 Darcy Street, Parramatta NSW 2150 | Locked Bag 5022, Parramatta NSW 2124 | dpie.nsw .gov.au | 1

Dr Zoe ReadSustainability Lead Woodlawn Mine609 Collector RoadTARAGO NSW 2580

07/03/2022

Dear Dr Read

Woodlawn Mine Project - (MP07_0143)Independent Environmental Auditor

I refer to your letter of 4 March 2022 to the Department of Planning and Environment (theDepartment) seeking Secretary's approval of Ms Michelle Agnew of Senversa Pty Ltd as analternative member of the audit team for the upcoming Independent Environmental Audit ofWoodlawn Mine Project (the development), in accordance with Schedule 6, Condition 9 of projectapproval MP07_0143, as modified (the approval).

Having considered the qualifications and experience of Ms Agnew, the Secretary endorses theappointment of Ms Agnew to undertake the audit in accordance with Schedule 6, Condition 9 of theapproval. This approval is conditional on Ms Agnew being independent of the development.

The audit is to be conducted in accordance with AS/NZS ISO 19011 Australian/New ZealandStandard: Guidelines for quality and/or environmental management systems auditing and you maywish to consider the Independent Audit Guideline dated October 2015. A copy of this guideline canbe located athttp://planning.nsw.gov.au/Policy-and-Legislation/Mining-and-Resources/Integrated-Mining-Policy.

The audit report is to include the following: 1. consultation with the relevant agencies; 2. a compliance table indicating the compliance status of each condition of approval and any

relevant EPL; 3. not use the term “partial compliance”; 4. recommend actions in response to non-compliances; 5. review the adequacy of plans and programs required under this consent; and 6. identify opportunities for improved environmental management and performance.

Within six weeks of the completion of this audit, Woodlawn is to submit a copy of the audit report tothe Secretary, together with its response to any recommendations contained in the audit report anda timetable to implement the recommendations. Prior to submitting the audit report to theSecretary, it is recommended that Woodlawn review the report to ensure it complies with therelevant consent condition.

http://planning.nsw.gov.au/Policy-and-Legislation/Mining-and-Resources/Integrated-Mining-Policy

Department of Planning and Environment

4 Parramatta Square, 12 Darcy Street, Parramatta NSW 2150 | Locked Bag 5022, Parramatta NSW 2124 | dpie.nsw .gov.au | 2

Should you have any enquiries in relation to this matter, please contact Georgia Dragicevic, SeniorCompliance Officer, on (02) 4247 1852 or by email to [email protected].

Yours sincerely

Katrina O'ReillyTeam Leader - ComplianceComplianceAs nominee of the Planning Secretary


NSW Department of Planning, Industry and Environment |

Independent Audit

Appendix E – Independent Audit Report Declaration Form Template

Independent Audit Report Declaration Form

Project Name

Consent Number

Description of Project

Project Address

Proponent

Title of Audit

Date

I declare that I have undertaken the Independent Audit and prepared the contents of the attached Independent Audit Report and to the best of my knowledge:

i. the audit has been undertaken in accordance with relevant condition(s) of consent and theIndependent Audit Compliance Requirements (Department 2019);

ii. the findings of the audit are reported truthfully, accurately and completely;iii. I have exercised due diligence and professional judgement in conducting the audit;iv. I have acted professionally, objectively and in an unbiased manner;v. I am not related to any proponent, owner or operator of the project neither as an employer,

business partner, employee, or by sharing a common employer, having a contractual arrangementoutside the audit, or by relationship as spouse, partner, sibling, parent, or child;

vi. I do not have any pecuniary interest in the audited project, including where there is a reasonablelikelihood or expectation of financial gain or loss to me or spouse, partner, sibling, parent, or child;

vii. neither I nor my employer have provided consultancy services for the audited project that weresubject to this audit except as otherwise declared to the Department prior to the audit; and

viii. I have not accepted, nor intend to accept any inducement, commission, gift or any other benefit(apart from payment for auditing services) from any proponent, owner or operator of the project,their employees or any interested party. I have not knowingly allowed, nor intend to allow mycolleagues to do so.

Notes: a) Under section 10.6 of the Environmental Planning and Assessment Act 1979 a person must not

include false or misleading information (or provide information for inclusion in) in a report ofmonitoring data or an audit report produced to the Minister in connection with an audit if theperson knows that the information is false or misleading in a material respect. The proponent of anapproved project must not fail to include information in (or provide information for inclusion in) areport of monitoring data or an audit report produced to the Minister in connection with an audit ifthe person knows that the information is materially relevant to the monitoring or audit. Themaximum penalty is, in the case of a corporation, $1 million and for an individual, $250,000; and

b) The Crimes Act 1900 contains other offences relating to false and misleading information: section307B (giving false or misleading information – maximum penalty 2 years imprisonment or 200penalty units, or both)

Woodlawn Mine Tarago

07_0143 MOD 2 EPL 20821 Special Mining Lease 20

Three yearly independent audit of approval conditions

Woodlawn Mine, 507 Collector Road, Tarago NSW 2580

Heron Resources Pty Ltd

Independent Env Audit of Project Approval Conditions 07_0143 MOD 2

17 March 2022

NSW Department of Planning, Industry and Environment |

Independent Audit

Name of Auditor

Signature

Qualification

Company

Company Address

Jason Clay

NSW EPA site auditor (08/01) Principal Environmental Auditor (EARA)

Senversa Pty Ltd

Level 24, 1 Market Street, Sydney, NSW, 2000

6. Appendices

Appendix A – Declaration of Independence Form Template

Declaration of Independence - Auditor

Project Name

Consent Number


Project Address

Proponent

Date

I declare that:

i. I am not related to any proponent, owner, operator or other entity involved in the

delivery of the project. Such a relationship includes that of employer/employee, a

business partnership, sharing a common employer, a contractual arrangement outside

an Independent Audit, or that of a spouse, partner, sibling, parent, or child;

ii. I do not have any pecuniary interest in the project, proponent or related entities. Such

an interest includes where there is a reasonable likelihood or expectation of financial

gain (other than being reimbursed for performing the audit) or loss to the auditor, or

their spouse, partner, sibling, parent, or child;

iii. I have not provided services (not including independent reviews or auditing) to the

project with the result that the audit work performed by themselves or their company,

except as otherwise declared to the Department prior to the audit;

iv. I am not an Environmental Representative for the project; and

v. I will not accept any inducement, commission, gift or any other benefit from auditee

organisations, their employees or any interested party, or knowingly allow colleagues

to do so.

Notes: a) Under section 10.6 of the Environmental Planning and Assessment Act 1979 a person must not

include false or misleading information (or provide information for inclusion in) in a report ofmonitoring data or an audit report produced to the Minister in connection with an audit if theperson knows that the information is false or misleading in a material respect. The proponent of an

Independent Audit Compliance Requirements |

Independent Environmental Audit Woodlawn Mine

07_0143MOD2

Environmental Compliance Audit

507 Collector Road, Tarago, NSW, 2580

Heron Resources

15 November 2021

approved project must not fail to include information in (or provide information for inclusion in) a report of monitoring data or an audit report produced to the Minister in connection with an audit if the person knows that the information is materially relevant to the monitoring or audit. The maximum penalty is, in the case of a corporation, $1 million and for an individual, $250,000; and

b) The Crimes Act 1900 contains other offences relating to false and misleading information: section307B (giving false or misleading information – maximum penalty 2 years imprisonment or 200penalty units, or both)

Name of Proposed Auditor

Signature

Qualification

Company

19

Jason Clay

NSW EPA Site Auditor, IEMA Principal Auditor

Senversa Pty Ltd

6. Appendices

Appendix A – Declaration of Independence Form Template

Declaration of Independence - Auditor

Project Name

Consent Number


Project Address

Proponent

Date

I declare that:

i. I am not related to any proponent, owner, operator or other entity involved in the

delivery of the project. Such a relationship includes that of employer/employee, a

business partnership, sharing a common employer, a contractual arrangement outside

an Independent Audit, or that of a spouse, partner, sibling, parent, or child;

ii. I do not have any pecuniary interest in the project, proponent or related entities. Such

an interest includes where there is a reasonable likelihood or expectation of financial

gain (other than being reimbursed for performing the audit) or loss to the auditor, or

their spouse, partner, sibling, parent, or child;

iii. I have not provided services (not including independent reviews or auditing) to the

project with the result that the audit work performed by themselves or their company,

except as otherwise declared to the Department prior to the audit;

iv. I am not an Environmental Representative for the project; and

v. I will not accept any inducement, commission, gift or any other benefit from auditee

organisations, their employees or any interested party, or knowingly allow colleagues

to do so.

Notes:

a) Under section 10.6 of the Environmental Planning and Assessment Act 1979 a person must not include false or misleading information (or provide information for inclusion in) in a report of monitoring data or an audit report produced to the Minister in connection with an audit if the person knows that the information is false or misleading in a material respect. The proponent of an

Independent Audit Compliance Requirements |

Independent Environmental Audit Woodlawn Mine07_0143 MOD2

Environmental Compliance Audit

507 Collector Road, Tarago, NSW 2580

Heron Resources

17 March 2022

approved project must not fail to include information in (or provide information for inclusion in) a report of monitoring data or an audit report produced to the Minister in connection with an audit if the person knows that the information is materially relevant to the monitoring or audit. The maximum penalty is, in the case of a corporation, $1 million and for an individual, $250,000; and

b) The Crimes Act 1900 contains other offences relating to false and misleading information: section 307B (giving false or misleading information – maximum penalty 2 years imprisonment or 200 penalty units, or both)

19

Andrei Woinarski

Senversa Pty Ltd

Name of Proposed Auditor

Signature

Qualification

Company

Andrei.Woinarski

Typewritten text

PhD, BE, CEnvP SC

Valid with proof of relevant current membership of IEMA

Certificate of Registration

This is to certify that

Jason Clay

is registered as a

Principal Environmental

Auditor

of IEMA

Valid from March 2003

______________________

SHAUN McCARTHY OBE

CHAIR OF PROFESSIONAL STANDARDS COMMITTEE

Jason_Clay_CV_Heron October 21 Page 1 of 3

Jason Clay Senior Principal, Site Auditor, Expert Witness Qualifications & Certifications

BSc(Hons): Environmental Science, 1991 MSc: Water Environment, 1994

Career Profile

Jason Clay is a Senior Principal in the Sydney office of Senversa. He has been an environmental consultant for more than 25 years and specialises in environmental auditing and risk-based assessment and remediation of soil and groundwater contamination.

Jason is a state accredited Contaminated Site Auditor in NSW and WA and is a Certified Environmental Practitioner and Specialist in Contamination (CEnvP SC). Jason is a registered Principal Environmental Auditor (EARA UK). He has since gained significant experience in chlorinated solvents, PFAS and hydrocarbons on sites in Australia, New Zealand, Europe, Asia and South America. Jason has lived in Australia since 2004.

Jason has been an accredited Contaminated Site Auditor since 2006 and since that time has completed more than 100 successful site audits. Audits have included major infrastructure projects such as metropolitan rail links and stadiums, offshore oil and gas facilities, service stations, asbestos impacts, tailings dams, major manufacturing sites, landfills and airports/bases.

Jason is currently auditing the closure and rehabilitation of a number of former gold mine batteries in Western Australia. These are Lake Darlot, Mulline, Bamboo Creek and Twenty Mile Creek gold mines. The audit includes assessment the status of tailings dams and reviewing mine closure and rehabilitation planning. The audit is conducted in conjunction with the requirements of the Department of Water and Environmental Regulation (DWER) WA on behalf of the Department of Mines, Industry Regulation and Safety (DMIRS) WA.

Jason has acted as expert witness in NSW Land and Environmental Court on behalf of Transport of NSW, the NSW Minister for Planning, Penrith City Council, Liverpool City Council, Wollondilly Shire Council and Lawrence Dry Cleaners. He has also acted as expert in Environment Court, Wellington, New Zealand on behalf of Exide Batteries.

Jason recently conducted the State Significant Development post approval audit for Pace Chickens in West Wyalong and was endorsed by the Department of Planning and Environment to do so.

Jason has completed previous Dargues mine SD, LEC and EPBC compliance audits in December 2016, June 2017 and February 2020.

Jason has published many papers on the assessment of the impact of chemicals in the environment on health and environment.

Senversa has a SafeWork NSW, class B, non-friable asbestos removal licence (AD212847) and Jason is the SafeWork nominated supervisor.

Expertise

Environmental auditing.

Statutory contaminated site auditing

Risk based land and groundwater contamination assessment, management and remediation

Key Industry Sectors

Mining

Property

Manufacturing

Legal and finance

Employment History

Aug 2015 (current): Senversa Pty Ltd

Aug 2009 to Aug 2015: AECOM Australia Pty Ltd

Aug 2004 to Aug 2009: ERM Australia Pty Ltd

Dec 1997 to Aug 2004: Dames & Moore/URS

1993-997 Parkman and HMIP

Memberships

NSW EPA Accredited Site Auditor WA DWER Accredited Contaminated Sites Auditor Certified Environmental Practitioner Specialist in Contamination (CEnvP SC) Principal Environmental Auditor (EARA) Fellow of the Institute of Environmental Assessment and Management (FIEMA). Fellow of the Chartered Institute of Water and Environmental Management (FCIWEM) Chartered Environmentalist (CEnv.) Chartered Scientist (CSci.) Member of the Australasian College of Toxicology and Risk Assessment NSW Justice of the Peace Graduate of the Australian Institute of Company Directors (GAICD)

Jason Clay Senior Principal


Professional Training & Development

• Battelle International Conference on Remediation of Chlorinated and Recalcitrant Compounds 2016, 2014, 2012

• Clean-up 2017, 2015, 2013, 2011, 2009, 2007

• Eco-Forum 2018, 2014, 2012, 2010

• Todd Wiedemeier – Monitored Natural Attenuation two-day ACLCA course

• Steve Wilson – Landfill Gas two-day ACLCA course.

• 24 Hour Hazwoper, (27-29 Nov 2002) plus numerous 8-hour refreshers

• Baseline Security Clearance 31 October 2014 (652950)

• NSW Health and Safety Induction (White Card) (29 March 2004)

• Asbestos Awareness (17 April 2007)

• Tropical Basic Offshore Safety Induction and Emergency Training (TBOSIET) 23-24 June 2014.

Project Experience

• Site Auditing. – Jason has successfully completed over 100 site audits and is currently involved in more than 30 on-going. Jason has successfully audited major infrastructure projects, leaking UST sites, landfills, industrial complexes, market gardens and major oil and gas infrastructure.

• Department of Mines Industry Regulation and Safety (WA) – Four gold mine audits are currently underway. These are Lake Darlot, Mulline, Bamboo Creek and Twenty Mile Creek gold mines. The audit includes assessment of the status of tailings dams and reviewing mine closure planning for largely derelict state battery sites associated with historic gold mines.

• Public Transport Authority-Perth Airport Link - WA DER contaminated site auditor for this major piece of tunnel infrastructure linking the CBD of Perth to the airport. The audit includes significant PFAS issues related to impacts at the airport.

• Fire and Emergency Services Australia – WA DER contaminated site auditor for the demolition and redevelopment of a major fire station in Perth CBD contaminated with PFAS as a result of contamination with AFFF. Impacts have migrated off-site creating significant stakeholder consultation issues as part of this audit.

• Minister for Planning – Expert witness in NSW LEC on the proposals to remediate 5,000 m3 of illegally dumped material in Western Sydney.

• WestConnex Delivery Authority – Expert witness on the contamination aspects of the compulsory purchase of the Alexandria Landfill, St Peters, for use for construction of the St Peters Interchange.

• Exide Power Systems - Expert Witness in Environment Court, Wellington, New Zealand. Represented Exide Power systems on a resource consent hearing relating to the health impacts of fugitive lead emissions from a lead smelter.

• Lawrence Dry Cleaners. Director of an Enhanced In-situ bioremediation (EISB) of PCE DNAPL in the Botany Sands aquifer in Sydney. This project is highly successful, is currently meeting the requirements of the Management Order and is one of the first schemes of its kind in Australia. Expert witness in NSW Land and Environment Court (LEC) for the first appeal of an EPA Management Order.

• British Gas - Coxside Gasworks Remediation. Site engineer on a 12-month remediation project for a 4-hectare gas works site in Plymouth UK. Remediation of three tar wells and four infilled gas holder bases was complicated by UK waste laws. Remediation included groundwater treatment and soil solidification. The site was eventually re-developed into a Multiplex cinema.

• Reckitt Benckiser - Director of the investigation, remediation and decommissioning of a former pesticide manufacturing facility in Sydney contaminated with chlorinated solvents and TPH.

• Petronas Malaysia. Investigation and remedial feasibility studies at an ethylene dichloride (EDC) manufacturing plant in Malaysia contaminated with chlorinated solvents including vinyl chloride.

• TRW Automotive – Adelaide. TCE DNAPL/plume remediation. Directed a project to assess and remediate a plume of chlorinated solvents in a South Australian sand aquifers using In-Situ Chemical Oxidation.

• Ecolab – Hale St, Botany. Directed the risk assessment of chlorinated solvent plume in the Botany Aquifer to derive remedial criteria for a steam injection system.

• 3M St Marys. Directed the risk-based remediation of a site contaminated by TPH and fire-retardant materials.

• Dana – Director of the $4M remediation of a manufacturing facility in western Sydney. Remediation involved excavation under a building to remove spilled oil and chlorinated compounds and gained a Site Audit Statement at the end of the process.

• Syngenta – Pendle Hill, Sydney. A former chlorinated compound manufacturing facility in Sydney was remediated using a combination of techniques including thermal desorption and ex-situ bioremediation. Risk-based screening levels were derived to allow remedial compliance to be tested for a number of pesticide derivatives in groundwater.

Jason Clay Senior Principal


• Syngenta – Asia. Jason has assisted Syngenta with a number of issues on sites in India, Korea, Indonesia and China. Issued have included compliance auditing, soil and groundwater contamination and remedial engineering.

• Hunters Hill Radium Hill Company. Expert advice provided in relation to the radiological contamination of private residences located adjacent to a former radium processing plant.

• Boliden Mining - Los Frailes Environmental disaster, Seville, Spain. Setting risk based remedial objectives and designing the sampling strategy to monitor subsequent remedial compliance over 800 hectares of land contaminated with mine tailings.

Publications

• Clay, J. (1997). Portsmouth Problem Investigated – Contaminated Land Investigation and Risk Assessment. Environmental Excellence Vol. 4, No.2, June 1997.

• Clay, J. (1997). Groundwater Risk Assessment Model Aberaman Phurnacite Works. In Yong, R. N.; Thomas, H. R.; (Eds). Geo-environmental Engineering, Contaminated Ground: Fate of Pollutants and Remediation, Conference Proceedings 514 - 520.

• Clay, J., MacKay, S., Enright, J., Loose, H.; (2001). The Implications of the Current Contaminated Land Regime on the Water Industry. Report 01/WW/24/1. UKWIR, London.

• Clay, J. (2006). The Australian risk-based approach to assessing and remediating MGPs. Land Contamination & Remediation, Vol. 14 No. 2. EPP Publications.

• Clay, J., Harris, M.E. (2002) Risk Based Corrective Action of Hydrocarbon Contamination at a former Major Urban Petroleum Storage Site in the U.K. Soil and Sediment Contamination, 11(5):701-718. AEHS

• Clay, J., Ellis, W., Lavelle, P. (2006). The risk-based remediation of a site contaminated with 2,4,5-T, 2,4-D and organochlorine pesticides. Enviro-06, Proceedings. Melbourne.

• Clay, J and Thompson B.A.W. (2007). Issues in Contaminated Land Management Risk Assessment Toxicology. Journal of Toxicology and Environmental Health. Part A, 70: 1635-1637.

• Clay, J; Illing, P. and Perrett K. (2007). The Applicability of Traditional Health Risk Analysis and Ill-Health Models in the Investigation of Medically Unexplained Physical Symptoms. Journal of Toxicology and Environmental Health. Part A 70, 1664-01669.

• Thompson, B.A.W & Clay, J (2007) Human health risk assessment of mercury impacts at a former thermometer factory in India: a probabilistic approach. Proceedings Contamination CleanUp07, Hilton Hotel Adelaide, 24-28 June.

• Clay, J, Thompson, B.A.W & Chau A. (2007). Review and Promotion of Risk-Based Remediation Goals as Contaminated Land Standards for Hong Kong. Proceedings Contamination CleanUp07, Hilton Hotel Adelaide, 24-28 June.

• Mc Keown, S; Clay, J. (2007) Remediation of a Chlorinated Solvent Contaminated Site in South Australia Using In-Situ Chemical Oxidation (ISCO). Proceedings Contamination CleanUp07, Hilton Hotel Adelaide, 24-28 June.

• Clay, J. (2007) A Peculiar Incident at Melbourne Airport – A Case of Environmental Related Illness or Mass Psychogenic Illness? Proceedings Contamination CleanUp07, Hilton Hotel Adelaide, 24-28 June.

• Perrett K.; Illing, P. and Clay, J (2007). An unusual problem in a primary school: a case of idiopathic environmental illness? Chemical Hazards and Poisons Report. Chemical Hazards and Poisons Division, May 2007, Issue 9. Health Protection Agency, London.

• Clay, J. (2008). Removing solvents in sand aquifers. Water Engineering Australia. Volume 2, Number 4, June 2008

Andrei Woinarski_CV_May2019 Page 1 of 8

May 2019

Dr Andrei Woinarski Principal, CEnvP SC

Qualifications & Certifications

Certified Environmental Practitioner (Contamination Specialist) Doctor of Philosophy, University of Melbourne, 2004 Bachelor of Engineering (Environmental; Hons 1), University of Wollongong, 1999

Career Profile

Andrei Woinarski is an environmental engineer / hydrogeologist approaching 20 years’ experience working in the contaminated land management / remediation and research industry. Andrei has been largely based in Sydney, though has worked on projects throughout Australia, southeast Asia and California, USA

As a consultant, he has fulfilled the role of project manager, hydrogeologist, technical or project director on hundreds of small to large scale contaminated land assessment projects, with a particular focus on conceptual site model development and contaminant hydrogeology. These have included a range of natural site settings and media, and contaminants including: chlorinated hydrocarbons, petroleum hydrocarbons; heavy metals; nutrients; asbestos; and, recalcitrant compounds such as per- and poly-fluorinated alkyl substances.

Andrei has been involved as the hydrogeologist or managed assessment and remediation works including the large-scale hydraulic containment systems at Orica Botany, in situ geochemical fixation, containment walls/cells, soil excavation, in situ bioremediation, natural source zone depletion, natural attenuation, chemical oxidation and numerous small-scale pump-and-treat systems. With his scientific and engineering background, he has a diverse skillset and range of experience, often providing internal technical support to projects and external advice to clients across a range of environmental issues for pre-purchase and divestment due diligence purposes, including identification of liabilities and opportunities, provision of management strategies and probabilistic cost estimation.

Andrei has worked across most industry sectors including infrastructure, industrial, mining and minerals processing, defence, land development and petroleum sectors in Australia. Examples include assessment of contamination issues at a portfolio of properties for Suez, Orica Botany groundwater clean-up and mercury remediation, Orica Kooragang Island arsenic and nutrient assessment and remediation, Port Kembla Copper, Chatree Goldmine risk advice, and Glencore Townsville Copper Refinery assessment and closure planning.

More recently, Andrei has provided technical peer review or independent advice, including: supporting Audits of former Akzo Nobel site at Camellia, Nyrstar Port Pirie, various sites at Kwinana, WA and Veranus Island, WA; assessment of Pasminco Cockle Creek liabilities; expert witness support in Land and Environment Court NSW proceedings.

Expertise

Contamination land assessment

Contaminant hydrogeology

Contamination management/remediation

Technical auditing and peer review

Key Industry Sectors

Mining and Minerals Processing

Industrial / Manufacturing

Land Development & Infrastructure

Petroleum

Government – local, State, Federal

Employment History

Jun 2016 (current): Senversa Pty Ltd

Jul 2014 to May 2016: JBS&G Australia Pty Ltd

Feb 2010 to Jun 2014: Golder Associates Pty Ltd

2008 to Jan 2010: URS Corporation (USA)

2004 to 2008: URS Australia Pty Ltd

2000 to 2002: Australian Antarctic Division and Queens University

Memberships

Australian Land and Groundwater Association (ALGA)

ALGA Special Interest Group – Groundwater Fate and Transport

International Association of Hydrogeologists (IAH)

Professional Training & Development

• HAZWOPER 24 Hour Health and Safety Training, 2004

• General construction OHS training, SafeWork NSW, 2004 (White Card)

• Peer reviewer for various publications, including Cold

Regions Science and Technology

Dr Andrei Woinarski Principal Environmental Engineer


May 2019

Project Experience

CONTAMINANT FATE AND TRANSPORT

Andrei has been responsible for and/or provided technical direction in developing conceptual site models and undertaking contaminant hydrogeology and geochemistry assessments at numerous sites to support risk assessment and management/remediation. These have considered contamination by heavy metals, arsenic, hexavalent chromium, recalcitrant organic compounds (including solvents), petroleum hydrocarbons and nutrients. Key projects include:

• Busselton, WA (2019): Technical direction for development of a hydrogeological conceptual model and preliminary fate and transport modelling for contaminants associated with a landfill.

• Robertson Barracks, NT (2017-ongoing): Internal peer review of hydrogeological assessment plans and documentation of interpretations, and provision of technical support to field staff conducting works, for a large-scale PFAS assessment at the Defence site.

• RAAF Base East Sale, VIC (2016): Internal hydrogeological review and technical support to field staff in assessing and interpreting hydrogeology and geochemistry for a large-scale PFAS assessment at the Defence site.

• Technical peer review, various sites (2016- ongoing): Provided contaminant hydrogeology expert advice supporting Site Auditor / Technical Advisor reviews for multiple projects. This has included peer review of: groundwater modelling and conceptual site model (CSM) for RAAF Base Pearce; nutrient assessment and modelling and remediation planning/design at Bis Industries,

Kwinana WA; CSM for Alcoarefinery, Kwinana WA; Iluka Narngulu fate and transport model (for B, NH4 +, TDS); LNAPL fate and transport at retail petroleum sites in Armadale WA, Caltex Brighton SA, BP Frankston South VIC; hydrogeology and LNAPL behaviour at Veranus Island and Barrow Island, WA; review of background soil and groundwater concentrations and application in assessing ecological risks at Barrow Island, WA.

• Nyrstar, Port Pirie, SA (2016-ongoing): Assisting the audit of contamination assessment and remediation program at the operating smelter by providing technical review of documents in relation to source characterisation, hydrogeology, hydrology, contaminant fate and transport, and water treatment/management. Contaminants included zinc, lead, cadmium and acidic groundwater, with key issues relating to groundwater migration, assimilative capacity of the aquifer and groundwater – surface water interactions.

• Former gasworks, Newcastle, NSW (2016): Contaminant hydrogeologist with responsibility to develop a CSM and conduct a Tier 1/2 environmental risk assessment associated with potential migration of contaminants in groundwater and discharge into a surface water system for the former gasworks to meet requirements of a VMP and support remediation planning.

• Chatree goldmine, Thailand (2014-2015): Conducted a technical review of environmental and community health monitoring data, site inspections and an audit of the monitoring program at an operating gold mine in Thailand. The objectives of the work were to assess whether arsenic in the local community/environment was related to mine activities, which had resulted in forced mine closure. Developed a program of works to assess community health, and worked with the client’s community consultation team to communicate actual risks. Involved leading technical aspects of collaborative work with the client, Thai universities and health experts, with particular consideration of Thai political and social frameworks, within a high-pressure work environment.

• Orica Kooragang Island, Newcastle, QLD (2010-2014): Former operations at the facility had resulted in arsenic and ammonium nitrate impacts to groundwater. Acted in various roles either acting as technical lead/peer review on behalf of the client or providing technical direction as a hydrogeologist and remediation engineer:

Assessment of fate and transport mechanisms of arsenic in the subsurface at the ammonium nitrate manufacturing facility. This included: developing or reviewing site investigation and remediation feasibility assessment programs; conducting and reviewing monitoring programs; assessment of geochemistry, assimilative capacity, and groundwater – surface water interactions.

Responsible for the assessment of fate and transport mechanisms of nutrients and acids in the subsurface at the facility.

Reviewed numerical groundwater flow and solute transport models.

Responsible for, and key author of, a CSM for arsenic and nutrient contamination at the site. The model has been used to support subsequent risk assessments, remediation works and ongoing management of contamination issues.

• Xstrata/Glencore copper refinery, Townsville, QLD (2012-2013): Project manager / principal investigator in work supporting closure planning of a copper refinery in North Queensland. Tasks and roles included:

Characterisation and assessment of contamination sources, fate and transport of heavy metals, arsenic, ammonium and other contaminants as part of a program of site investigation and closure planning.

Developing a CSM for metals, nutrients and other physicochemical vectors.



May 2019

Project Experience

• Orica Botany, NSW (2006-ongoing): Long-term site hydrogeologist assisting the client to assess and manage various groundwater contamination issues associated with former operations at the Orica Botany chemical manufacturing facility. Roles and works in relation to fate and transport have included:

Prepared a CSM focusing on hydrogeology, fate and transport of DNAPL, soil and dissolved phase chlorinated compounds and mercury to support risk assessments, investigations and remediation planning (most recent version in Sep 2017).

Hydrogeological assessment of aquifer assimilation capacity for chlorinated compounds, including fate and transport mechanisms.

Reviewed groundwater flow and solute (chlorinated solvents, mercury) transport models prepared by other consultants.

Conducted contaminant mass and flux assessments.

• Former RailCorp site, Turrella, NSW (2015): Developed a CSM for a PCE/TCE contaminated site leased as a chemical distribution facility to assist RailCorp with their corporate risk management and meet regulator expectations.

• Orica Yarraville, VIC (2011): Hydrogeologist who was one of two key authors in preparing a CSM for a large chemical/industrial site with DNAPL, soil and dissolved phase pesticides, nitrogenated organics and chlorinated compounds. The model was used to support the CUTEP process.

• Modelling (various projects): Reviewed groundwater flow and solute transport models at various sites, and have undertaken basic fate and transport or geochemical models/tools (e.g. PHREEQC, BIOCHLOR, BIOPLUME, BIOSCREEN, SourceDK) and aquifer tests (Aqtesolve).

REMEDIATION

Andrei has been involved with numerous groundwater remediation projects typically as project manager, remediation engineer and/or hydrogeology lead, particularly at the front-end of projects (i.e. strategy, planning and design phases). In recent years, Andrei has also acted as project director. Key projects include:

• Former gasworks, Wollongong NSW (2018-ongoing): Technical direction for the project to conduct site investigations, a HHERA, remediation trial (stabilisation) and develop a RAP. Also directed remediation works for stockpiled legacy materials. The site is subject to a site audit.

• Former industrial waste disposal site, Lucas Heights, NSW (2017-ongoing): Provision of technical hydrogeological and remediation support via review of documents, participating in workshops to develop remedial and procurement strategies. Documents reviewed have included monitoring plans, responses to Auditor comments, and options assessments.

• Former industrial facility, Wickham NSW (2017-ongoing): Project manager of investigation and groundwater monitoring works in relation to remediation of metals and petroleum hydrocarbon impacts for redevelopment of the former warehousing and wool store site. The project is made more complex by the presence of LNAPL impacts associated with off-site sources, and additional work has included review of third-party reports and provision of technical advice in relation to project risks from the LNAPL.

• Lawrence Dry Cleaners, NSW (2016-ongoing): Project manager and remediation engineer for an enhanced in situ bioremediation system to remediate chlorinated solvent impacts associated with a former dry-cleaning facility. Responsible for all aspects of the project including: operation and maintenance of a pump and treat system; surface water, groundwater, soil vapour, ambient air and personnel monitoring; key author for all reports; stakeholder engagement including the client, client’s legal team, tenant’s and regulators; targeted site investigations; in situ bioremediation works and remediation trials. The site is subject to regulation by the EPA.

• Port Kembla Copper, NSW (2017-ongoing): Remediation engineer supporting works assessing residual contamination in surface water, stormwater, sediments and shallow groundwater to support closure of the former smelter and associated slag landfills. This has included acting as project manager and developing, in conjunction with the project director: surface water, groundwater and soil assessment work plans and subsequent implementation; monitoring programs; data review; and assessment of remedial/management options. The site is subject to regulation by EPA.

• Technical peer review, various sites (2016- ongoing): Provided remediation expert advice supporting Site Auditor / Technical Advisor reviews for multiple projects. This has included peer review of: remediation planning/design at Bis Industries, Kwinana WA; review of RAP for former Akzo Nobel site at Camelia NSW; LNAPL pumping tests and analyses at Varanus Island, WA; review of LNAPL remediation system and costing at Wickham, NSW; groundwater remediation and management plans at Nyrstar Port Pirie, SA.

• Western Sydney Stadium, NSW (2017): Provided due diligence advice to Lend Lease in relation to contamination liabilities with the site and development for their bid. Reviewed the RAP and validation SAQP, and ongoing involvement in troubleshooting and auditor engagement. The site is subject to a site audit.



May 2019

Project Experience

• Former fire-fighting training facility, VIC (2016-2017): Reviewed site information in relation to PFAS impacts at a large-scale former fire-fighting training facility. On the basis of this, conducted a desktop remedial options feasibility assessment following USEPA CERCLA and State guidance to identify a preferred remedial/management approach – this approach has been applied by the client at other sites across Victoria. This has supported further remediation planning and design work for a containment type remediation approach. The site was subject to a site audit and EPA involvement.

• Carpet manufacturing site, VIC (2016 - ongoing): Strategic review of management/remediation approaches for a former carpet manufacturing site in Melbourne impacted with PCE in soil and groundwater, and subject to a site audit. Developed a remediation/management approach and conducted probabilistic cost estimation using Monte Carlo methods to assess likely costs.

• Australian Technology Park, NSW (2015-2016): Project director for project providing remediation planning and approvals due diligence advice at the client’s bid stage; and directed/reviewed subsequent contamination investigation, quantitative risk assessment and RAP for the redevelopment of the former industrial site. Developed an approach that saved significant remediation costs which enabled the client to win the development project tender. Remediation consists of on-site retention of impacted materials. The site was subject to a site audit.

• Former Orica site, Villawood NSW (2014-2015): Project director for remediation validation, asbestos clearance and monitoring services for a large-scale DDX, VOC, mercury and asbestos soil remediation (on-site thermal desorption) project at the former pesticide manufacturing facility. Key author for the draft remediation validation report.

• Former Email site, Pagewood NSW (2014): Project manager for the finalisation of a RAP, supporting contamination assessments and provision of ad-hoc advice in relation to remedial for a proposed redevelopment at a former PCE/TCE impacted industrial site.

• Barangaroo Central, Sydney NSW (2014): Assisted in providing advice to BDA for site contamination issues and assistance with remediation planning and tendering process for Barangaroo Central.

• Boral Nelsons Ridge, NSW (2014): Project manager and finalisation of remediation planning documents and supporting soil, groundwater and soil vapour assessments of VOC and TPH impacts for site redevelopment. Also responsible for auditor engagement.

• Former Akzo Nobel site, Sydney NSW (2012-2014): Project manager and remediation engineer for various projects managing issues associated with hexavalent chromium and chlorinated hydrocarbon contamination in soil, groundwater and stormwater at a former industrial facility. Tasks/roles included: review of site information and provision of technical advice to support long-term site management and property divestment strategies; managing and conducting operation and maintenance of a groundwater treatment plant; managing compliance monitoring of stormwater, groundwater and treatment plant discharge.

• Xstrata/Glencore copper refinery, Townsville QLD (2012-2013): Project manager / principal investigator in work supporting closure planning of a copper refinery in North Queensland. Remediation tasks and roles included:

Assessing current remediation systems, which included a containment cell, and pump and treatment system.

Developing cost forecasts for various remedial/management scenarios.

Supported the client’s environment team in internally communicating the findings of this project and closure planning.

• Integral Energy depot, Fairfield NSW (2010): Project managed targeted site investigations of soil, soil vapour and groundwater and prepared a RAP for creosote soil contamination beneath residential properties associated with a former adjacent electrical substation depot.

• Orica Botany, NSW (2005-2016):

2012-ongoing: Presenter and participant in various stakeholder workshops/seminars, and collaborative work with client and their specialist consultants/contractors. Assisted client in developing long-term groundwater remediation.

2005-2016: Hydrogeologist/engineer managing collection and assessment of pumping data, treatment plant flow data, and data from loggers / pressure transducers and provision of hydrogeological advice to assist in optimisation of the pump-and- treat system and system troubleshooting.

2012-ongoing: Ongoing consulting advice and technical review in relation to works associated with development of long- term chlorinated solvent contamination remediation strategies and management for the Orica Botany site.

2010: Conducted a trial of groundwater injection and recovery system. Tasks include well rehabilitation, aquifer tests, monitoring, well fouling mitigation and injection trials.

2005-2008: Hydrogeologist for several large-scale chlorinated solvent DNAPL remediation projects in the conceptual design and field and/or laboratory feasibility trial phases, including: managing site investigations; collection of DNAPL, soil and groundwater samples for trial purposes; preparing DSI reports; providing site information to, and reviewing, third-party



May 2019

Project Experience

reports from remediation vendors. DNAPL remediation technologies assessed included direct recovery, in-situ chemical oxidation and thermal treatment technologies.

2004-2012: Oversight of construction and commissioning of a large (>120 extraction and monitoring wells) hydraulic containment barrier system (subsurface components). Ongoing role conducting well rehabilitation, including chemical, physical and biological assessment, at production bores with biological and physical fouling.

• Orica Kooragang Island, Newcastle NSW (2011-2014):

Seconded with the client to provide advice, strategy and planning input, technical review of deliverables from client’s other consultants, and preparation of reports for issue to regulators in relation to various arsenic (in situ fixation, containment, PRBs, MNA, pump-and-treat) and nutrient contamination remediation projects at an ammonium nitrate manufacturing facility.

Acted as a contaminant hydrogeologist and key report author for a treatability study and feasibility assessment of in situ geochemical fixation remediation for arsenic impacted groundwater.

Concept design of a containment system for arsenic impacts.

Directed site assessment, remediation planning, system design and implementation of a pump and treat system for a nitric acid plume.

• Former ChlorAlkali Plant, Botany NSW (2011-2013): Remediation engineer / hydrogeologist and key author for a feasibility assessment of soil and groundwater mercury remediation options, and preparation of RAP for a containment approach for the former ChlorAlkali Plant. The feasibility assessment and RAP were subject to peer review by an international expert and Site Auditor.

• Ammonium nitrate and cyanide production facility, Gladstone QLD (2011): Managed a remediation project for cyanide, ammonia and nitrate impacted groundwater and stormwater including: remedial options review, advice for the selection of a preferred approach and design of a hydraulic containment system. Also conducted a review of ex situ treatment and reuse options for cyanide impacted soil.

• Trans Bay Cable Project, CA USA (2009): Provided environmental oversight of construction and hazardous waste management for a construction project at a former gasworks site in San Francisco.

• Golden Eagle Refinery, CA USA (2008-2009): Field engineer assisting with management and troubleshooting for the operation and maintenance of a large-scale (>30 pumping wells and 1 km of piping) LNAPL recovery system. Role involved task management, subcontractor management, health and safety oversight, system inspections, remediation system design, LNAPL recovery tests.

• Antarctica, Sub-Antarctic and Arctic (2000-2004): PhD related work with University of Melbourne and Australian Antarctic Division included investigation and pilot trial of remediation strategies such as pump-and-treat, PRBs and in-situ chemical oxidation for management of several petroleum, heavy metal and PCB contaminated sites at Casey and Wilkes Stations in Antarctica, Macquarie Island and Resolution Island, Canada. This involved working with a diverse team of scientists, engineers and managers in all aspects of the project from design, planning, laboratory and field studies to implementation.

ENVIRONMENTAL SITE ASSESSMENTS

Andrei has conducted or been responsible for the delivery and project management of numerous Brownfields environmental site assessments in Australia. These have ranged from small (<$50k) to several large (>$500k) projects typically used to support contamination management, meet regulatory requirements, property transactions and land redevelopment. Andrei has also acted as lead contaminant hydrogeologist on a number of these projects. Key projects in addition to those mentioned above include:

• Multiple Dulux industrial facilities, NSW (2017-ongoing): Technical director for contamination assessment, and surface water and groundwater monitoring programs at Dulux’s NSW sites. Also prepared management plans and monitoring programs.

• PFAS assessment – large industrial facility, NSW (2016-2017): Project manager for a groundwater and soil seepage PFAS investigations at a large heavy industrial facility in NSW to support internal due diligence and legal advice in relation to PFAS liabilities.

• Portfolio of waste processing facilities, Australia (2016): Peer review of deliverables for a project providing due diligence services to a client to support the sale of a portfolio of industrial facilities across Australia. Deliverables included documentation of preliminary and limited detailed (soil, groundwater, surface water, soil vapour) assessments.

• Commercial/industrial site investigation, Marrickville NSW (2016): Project manager of a preliminary desktop and detailed site investigation (soil, soil vapour and groundwater) and reporting at a mixed use commercial and industrial site at Carrington Road, Marrickville. The investigations were conducted to inform remediation planning and master planning for development of the site.



May 2019

Project Experience

• Former Koltex site, Leichhardt NSW (2015-2016): Project manager and hydrogeologist for a project to undertake site investigations (soil, soil vapour and groundwater), development a conceptual site model, preparation of remediation work plans, waste classifications and stakeholder liaison to support remediation and audit of the development site.

• Former Taubmans site, St Peters NSW (2015-2016): Project manager and directed provision of due diligence advice, site investigations (soil, soil vapour and groundwater), development an initial conceptual site model, engagement with EPA to support contamination aspects of the development planning. Issues were related to chlorinated solvents in groundwater, and other contamination issues common to urban industrial sites.

• Multiple former commercial/industrial brownfield sites, NSW (2004-ongoing): Acted variously as project director, project manager or oversight of field programs for environmental investigations (soil, soil vapour and groundwater) at other properties in Sydney, Newcastle and ACT - typically related to due diligence assessments, property transactions or contamination management at former industrial sites and retail petroleum sites. These include BlueScope Erskine Park NSW, RMS Matraville NSW, illegal filling at Kentlyn NSW, various Mobil sites in ACT and NSW.

• Orica Kooragang Island, NSW (2010-2014): Project manager for site investigations in relation to assessment of nutrients and nitric acid impacts. Also was the author for groundwater monitoring programs, an environment management plan and conducted groundwater monitoring in relation to arsenic groundwater impacts.

• Xstrata/Glencore copper refinery, Townsville QLD (2010-2013): Project manager and principal investigator for environmental contamination investigations at the site. This included a program of soil bores, groundwater wells, well repair/redevelopment, groundwater and surface water monitoring and reporting. The investigations supported development of a CSM and data gaps assessment for closure planning.

• Orica Botany, NSW (2004-2009): Acted as the project manager or lead field investigator for a series of DNAPL source area assessments and large-scale chemical and hydraulic monitoring programs (>100 monitoring locations) to characterise geology, hydrology, contaminant fate and transport, and inputs into assessment of risks to environment and human health from chlorinated hydrocarbons in the subsurface associated with a large chemical industrial site. Roles and responsibilities consisted of:

Project management of monitoring programs.

Key author for groundwater monitoring and assessment programs.

Oversight of installation of a large network of bundled piezometers and monitoring wells.

Conducted DNAPL source area field investigations.

Hydraulic well and aquifer tests (slug, DNAPL recovery) and interpretation.

Conducted intrusive and down-hole geophysical testing.

Installation and maintenance of a hydraulic monitoring system of pressure transducers and loggers.

Key author of reports, including hydrogeological and geochemical components and interpretations.

• Resolution Island / Queens University, Canada (2001): Provided scientific advice, field analytical services, remediation oversight and health and safety supervision for a large remediation project at a DEW-line site with sediments and groundwater contaminated with PCBs.

DUE DILIGENCE AND EXPERT OPINION / SUPPORT

In addition to providing technical support and peer review to site audits, Andrei has provided due diligence advice to support property or company acquisitions or purchase of development rights of industrial and brownfield sites. These have typically involved review of third party information (and occasionally supporting site investigations). For advice relating to land development, consideration of development constraints and opportunities has been made. Andrei has also provided independent review of available information to support client’s internal risk management and help with community communications in the upstream oil and gas and mining sectors. Examples include:

• Paramatta Light rail, Transport for NSW (2018-ongoing): Provision of expert support to the site auditor for the remediation of solvents, hexavalent chromium and asbestos at the former Akzo Nobel site. Remediation comprises a containment wall system and integrated capping system.

• Hydro Aluminium Smelter, Kurri Kurri NSW (2018-ongoing): Assessment of long-term liabilities and associated financial assurance associated with a proposed containment cell to support NSW Department of Environment and Planning project approvals.

• Pasminco Cockle Creek, NSW (2018-ongoing): Assessment of long-term liabilities and associated financial assurance associated with the containment cell to support NSW Department of Environment and Planning project approvals.



May 2019

Project Experience

• Expert support, Land and Environment Court (2017): Provided expert evidence to support proceedings involving illegal waste disposal at a site in western Sydney. The waste had principally impacted on Aboriginal heritage and environmental values.

• Various industrial brownfield Sites, NSW (2014-ongoing): Provided due diligence advice in relation to acquisition of industrial, commercial and brownfield properties for redevelopment. Clients have included major land developers, industrial companies and retail companies. The sites typically were potentially impacted with chlorinated solvents, petroleum hydrocarbons, asbestos and metals. Site have included various properties in Redfern, St Peters, Marrickville, Kings Park, Hurstville, Sydney Olympic Park. These have often led to further assessment, involvement in structure planning, remediation planning and remediation works.

• Confidential LNG Site, PNG (2015): Technical review / due diligence assessment of environmental and process information to assist client in assessing risks associated with a condensate release at a gas processing facility.

• Orica Kooragang Island, Newcastle NSW (2014-2015): Management and preparation of reports required for PRPs under an EPL for a public/regulatory audience. Involved working with client engineers and management to distil technical process/engineering information from a broad range of process plant cleaner-production projects into a document suitable for the targeted audience.

WATER TREATMENT & MANAGEMENT

Andrei has been involved in water treatment and management projects in conjunction with contaminated site assessments. These have included at the front end of projects assisting clients in developing strategies to manage wastewater at industrial sites, and being responsible for concept design, and operation and maintenance, of small to mid-sized groundwater treatment plants for organic contaminants, cyanide, chromium, low pH and nutrients. Key projects include:

• PFAS water treatment option feasibility review, VIC (2017): Assisted in review of PFAS water treatment technologies and initial feasibility assessment for a former fire training facility.

• Groundwater pump and treat systems, various sites NSW (2010-ongoing): Project manager or principal engineer for the operation, maintenance and monitoring of groundwater pump and treat systems – including: PCE impacted groundwater at Lawrence Dry Cleaners, NSW; chromium (VI) and chlorinated methanes at for AkzoNobel site, Camellia NSW; acidic groundwater at Orica Kooragang Island, NSW; metals and PCE impacted groundwater former Koltex site, NSW; TCE impacted groundwater at a metals manufacturing facility, Penrith NSW. Have also been responsible for overall concept design, procurement and commissioning for the plant at the former Koltex site.

• Orica Yarwun AN and Cyanide Production Facility, QLD (2010-2013):

2013: Project Manager and engineering consultation to assess stormwater management and treatment options for cyanide and nutrients (see below). This also included working with hydraulic engineers and modellers for stormwater capture and retention system design, assessment of runoff hydrographs and water quality, review and development of nutrient and cyanide treatment options, including trial of cyanide biological treatment.

2010-2012: Project Manager and engineer for an ongoing project to assist the client in managing industrial effluent issues at the facility, and potential integration with groundwater remediation systems. This involved developing management strategies, characterisation of effluent system and waste streams, identification of preferred treatment options, a feasibility assessment, treatability trials, costing and design. Constituents include ammonia, nitrate, cyanide, metals and phosphates. Also involved compliance monitoring and licensing.

• Selenium Water Treatment, Port Kembla Copper, NSW (2011): Review of performance of water runoff capture systems, a water treatment plant and desktop feasibility study of treatment alternatives for selenium at a former copper smelter being decommissioned.

• University of Melbourne, VIC (2000-2003): In PhD related work conducted research into using ion exchange resins and zeolites for treatment of heavy metals in waters.



May 2019

Publications

REFEREED JOURNAL ARTICLES

• Woinarski, A.Z. et al. A natural zeolite permeable reactive barrier to treat heavy-metal contaminated waters in Antarctica: Fixed- bed ion exchange studies. Process Safety and Environmental Protection, 84(2) (2006), 109-116.

• Ferguson, S.H., A.Z. Woinarski et al. A Field Trial of In Situ Chemical Oxidation (ICO) to Remediate long-term Diesel Contaminated Antarctic Sediments. Cold Regions Science and Technology, 40 (2004), 47-60.

• Woinarski, A.Z. The effects of cold temperature on copper ion exchange by natural zeolite for use in a permeable reactive barrier in Antarctica. Cold Regions Science and Technology, 37(2) (2003), 159-168.

OTHER

• Eleventh International Conference on Remediation of Chlorinated and Recalcitrant Compounds (‘Battelle’), April 8-12 2018 - Insights on Risk-Reduction Mechanisms from 12 Years’ Operation of a Pump-and-Treat System at the Botany Chlorinated Hydrocarbon ‘Mega-Site’. G. Dasey, A. Woinarski, and S. Corish

• Eleventh International Conference on Remediation of Chlorinated and Recalcitrant Compounds (‘Battelle’), April 8-12 2018 - Evolution of a Conceptual Site Model for the Botany Chlorinated Hydrocarbon ‘Mega-Site’ Clean-Up Project. A. Woinarski, G. Dasey, and J. Stening

• Stevens, G.W, A.Z Woinarski et al. Penguins, pollution and chemical engineering in Antarctica, The Chemical Engineer. 2004

• Woinarski, A.Z. 2004. Development of a natural zeolite permeable reactive barrier for the treatment of contaminated waters in Antarctica. PhD Thesis, Department of Chemical and Biomolecular Engineering, University of Melbourne

Appendix B: Stakeholder Consultation

1

Michelle Agnew

From: Jason ClaySent: Tuesday, 1 February 2022 10:13 AMTo: [email protected]; [email protected];

[email protected]; [email protected]: Michelle AgnewSubject: 19346 - Heron, Woodlawn, Audit

Dear All Senversa has been commissioned by Heron Resources to undertake the Independent Environmental Audit of the Woodlawn Mine. Woodlawn is a metals (lead and zinc) mine, approximately 50 km north-east of Canberra and 250 km south-west of Sydney. We understand that the site is currently under care and maintenance while Heron resolves its voluntary administration. The audit will be of its various approval (mining lease (SML 20), major project and Environment Protection Licence (EPL)) conditions and is required to happen every three years from the commencement of construction. We are writing to inform you that the audit will be conducted on and around 15 February. We would be very grateful if you could let us know if you have comments or issues that you would like us to focus on, especially any matters arising since the last audit or have any further questions or queries that you would like raised with Heron Resources. Regards

Jason Clay

Senior Principal, Contaminated Sites Auditor (NSW and WA)

M: +61 410 431 674

E:

[email protected]

Jason Clay is on Teams

www.senversa.com.au

Level 24, 1 Market St, Djubuguli, Eora Country

Sydney, NSW , 2000, Australia

+61 2 8252 0000

This email and any attachments may contain information that is confidential and/or privileged. If you receive this email by mistake, please notify the sender and delete all copies. Confidentiality and/or privilege is not waived in relation to emails sent or received in error. Senversa accepts no responsibility for emails sent by employees that are of a personal nature or in breach of any law or regulation. We attempt to minimise cybersecurity risks, however cannot guarantee that emails or attachments are secure. Any personal information in this email must be handled in accordance with the Privacy Act 1988 (Cth) or equivalent.

Senversa acknowledges the traditional custodians of the lands and waters upon which we conduct our work, and pay our respect to the elders, past, present and those to come.

1

Michelle Agnew

From: WaterRegSouth <[email protected]>Sent: Thursday, 3 February 2022 1:25 PMTo: Jason Clay; [email protected];

[email protected]; [email protected]: Michelle AgnewSubject: RE: 19346 - Heron, Woodlawn, Audit

Hi Jason, Thank you for your email. You may like to forward your email to the Natural Resource Access Regulator as they are the responsible agency for granting and managing water licences and approvals for water users that include water utilities, government agencies, mines, irrigation corporations, and Aboriginal communities and businesses. NRAR also advises on state-significant development and infrastructure projects. WaterNSW are responsible for licenses and approvals for rural landholders, rural industries and developments which are not state-significant. NRAR can be contacted on 1800 633 362 or [email protected]. Kind regards, Angela Lepper Team Leader

WaterNSW PO Box 398, Parramatta, NSW 2124 1300 662 077

From: Jason Clay <[email protected]> Sent: Tuesday, 1 February 2022 10:13 AM To: WaterRegSouth <[email protected]>; [email protected]; [email protected]; [email protected] Cc: Michelle Agnew <[email protected]> Subject: 19346 - Heron, Woodlawn, Audit ZjQcmQRYFpfptBa nnerStart

This Message Is From an External Sender This message came from outside your organization. Be careful opening emails, attachments and links from unknown senders.

ZjQcmQRYFpfptBa nnerE nd

Dear All Senversa has been commissioned by Heron Resources to undertake the Independent Environmental Audit of the Woodlawn Mine. Woodlawn is a metals (lead and zinc) mine, approximately 50 km north-east of Canberra and 250 km south-west of Sydney.

2

We understand that the site is currently under care and maintenance while Heron resolves its voluntary administration. The audit will be of its various approval (mining lease (SML 20), major project and Environment Protection Licence (EPL)) conditions and is required to happen every three years from the commencement of construction. We are writing to inform you that the audit will be conducted on and around 15 February. We would be very grateful if you could let us know if you have comments or issues that you would like us to focus on, especially any matters arising since the last audit or have any further questions or queries that you would like raised with Heron Resources. Regards

Jason Clay


M: +61 410 431 674

E:

[email protected]


www.senversa.com.au



+61 2 8252 0000



1

Michelle Agnew

From: Jason ClaySent: Friday, 4 February 2022 7:50 AMTo: [email protected]: Michelle AgnewSubject: FW: 19346 - Heron, Woodlawn, Audit

QcmQRYFpfptBa nnerE nd

Dear NRAR Senversa has been commissioned by Heron Resources to undertake the Independent Environmental Audit of the Woodlawn Mine. Woodlawn is a metals (lead and zinc) mine, approximately 50 km north-east of Canberra and 250 km south-west of Sydney. We understand that the site is currently under care and maintenance while Heron resolves its voluntary administration. The audit will be of its various approval (mining lease (SML 20), major project and Environment Protection Licence (EPL)) conditions and is required to happen every three years from the commencement of construction. We are writing to inform you that the audit will be conducted on and around 15 February. We would be very grateful if you could let us know if you have comments or issues that you would like us to focus on, especially any matters arising since the last audit or have any further questions or queries that you would like raised with Heron Resources. Regards

Jason Clay


M: +61 410 431 674

E:

[email protected]


www.senversa.com.au



+61 2 8252 0000



1

Michelle Agnew

From: Jason ClaySent: Friday, 11 February 2022 10:12 AMTo: Michelle AgnewSubject: FW: AREQ0025017 | Woodlawn Mine Tarago | Enquiry (external) | Other Enquiry | 01

Feb 2022 10:50:24Attachments: Senversa_Woodlawn Mine_2022.pdf

Jason Clay


M: +61 410 431 674


www.senversa.com.au

Level 24, 1 Market St, Djubuguli, Eora Country Sydney , NSW , 2000, Australia

From: Resources Regulator <[email protected]> Sent: Friday, 11 February 2022 9:37 AM To: Jason Clay <[email protected]> Cc: [email protected] Subject: AREQ0025017 | Woodlawn Mine Tarago | Enquiry (external) | Other Enquiry | 01 Feb 2022 10:50:24

Dear Mr Clay ,

Please find attached the Regulator's response to your request for consultation on the independent audit of the Woodlawn Mine.

Regards,

Jenny Ehmsen Principal Compliance Auditor MAI - Enforcement | Resources Regulator T 4063 6443 M 0438 735 010

The Department of Regional New South Wales acknowledges that it stands on Country which always was and always will be Aboriginal land. We acknowledge the Traditional Custodians of the land and waters, and we show our respect for Elders past, present and emerging. We are committed to providing places in which Aboriginal people are included socially, culturally and economically through thoughtful and collaborative approaches to our work.

2

Ref:MSG0611901_WokdF8ptNEGeIXBkwWpN

AREQ0025017

Mr Jason Clay Senversa Pty Ltd Level 24, 1 Market Street Sydney NSW 2000 By email: [email protected]

Dear Mr Clay

Subject: Woodlawn Mine – Independent Environmental Audit

Thank you for your email and letter dated 1 February 2022 requesting consultation on the independent audit to be undertaken of the Woodlawn Mine which is covered by mining lease Special (Crown & Private Lands) Lease No. 20 [S(C&PL)L20].

The Resources Regulator requires that the following issues be addressed in independent environmental audits undertaken in accordance with a planning consent condition.

• Review relevant mining leases and exploration licences as agreed with Resources Regulator

• Undertake an assessment of compliance against the conditions of title related to environmental management

• Verify that there is a current Mining Operations Plan (MOP) in place and it has been approved by the Regulator – review compliance against any conditions of approval of the MOP

• Undertake a critical review of the MOP, including an assessment of its compatibility with the description of operations contained in the planning approval. In particular:

• Review the rehabilitation strategy as outlined in the MOP to determine if it is consistent with the Project Approval in terms of progressive rehabilitation schedule; and proposed final land use(s)

• Review the rehabilitation objectives and completion criteria as outlined in the MOP to determine if they have been developed in accordance with the proposed final land use(s) as outlined in the Project Approval

NSW Resources Regulator 516 High Street Maitland NSW 2320 | PO Box 344 HRMC NSW 2310 | Tel: 1300 814 609 |

resourcesregulator.nsw.gov.au


2

• Review the development and implementation of any rehabilitation monitoring programs to assess performance against the nominated objectives and completion criteria – verified by reviewing monitoring reports and rehabilitation inspection records

• Determine if a rehabilitation care and maintenance program has been developed and implemented based on the outcomes of monitoring program – verified by reviewing Annual Rehabilitation Programs or similar documentation

• Confirm that mining operations are being conducted in accordance with the approved MOP (production, mining sequence etc.), including within the designated MOP approval boundary – to be verified by site plans and site inspection

• Confirm that rehabilitation progress is consistent with the approved MOP as verified by site plans and a site inspection. This should include an evaluation against rehabilitation targets and whether the final landform is being developed in accordance with conceptual final landform in the Project Approval

• Based on a visual inspection, determine if there are any rehabilitation areas that appear to have failed or that have incurred an issue that may result in a delay in achieving the successful rehabilitation outcomes.

In addition to the above, the audit should note observations where rehabilitation procedures, practices and outcomes represent best industry practice.

It would be appreciated if a copy of the final audit report could be sent to the Regulator at [email protected] upon completion of the audit.

Yours sincerely

Jenny Ehmsen Principal Compliance Auditor

11 February 2022


1

Michelle Agnew

From: Jason ClaySent: Wednesday, 9 February 2022 9:52 AMTo: Michelle AgnewSubject: FW: 19346 - Heron, Woodlawn, Audit

Jason Clay


M: +61 410 431 674


www.senversa.com.au

Level 24, 1 Market St, Djubuguli, Eora Country Sydney , NSW , 2000, Australia

From: Georgia Dragicevic <[email protected]> Sent: Tuesday, 8 February 2022 9:49 PM To: Jason Clay <[email protected]> Subject: RE: 19346 - Heron, Woodlawn, Audit Hi Jason, Please consider any water related incidents and associated management, including any dams management. Kind regards, Georgia

From: Jason Clay <[email protected]> Sent: Tuesday, 1 February 2022 10:13 AM To: [email protected]; Georgia Dragicevic <[email protected]>; Janine Goodwin <[email protected]>; Peter McMillan <[email protected]> Cc: Michelle Agnew <[email protected]> Subject: 19346 - Heron, Woodlawn, Audit Dear All Senversa has been commissioned by Heron Resources to undertake the Independent Environmental Audit of the Woodlawn Mine. Woodlawn is a metals (lead and zinc) mine, approximately 50 km north-east of Canberra and 250 km south-west of Sydney. We understand that the site is currently under care and maintenance while Heron resolves its voluntary administration. The audit will be of its various approval (mining lease (SML 20), major project and Environment Protection Licence (EPL)) conditions and is required to happen every three years from the commencement of construction. We are writing to inform you that the audit will be conducted on and around 15 February.

2

We would be very grateful if you could let us know if you have comments or issues that you would like us to focus on, especially any matters arising since the last audit or have any further questions or queries that you would like raised with Heron Resources. Regards

Jason Clay


M: +61 410 431 674

E:

[email protected]


www.senversa.com.au


Sydney , NSW, 2000, Australia

+61 2 8252 0000




App C - Site Photos1

Photo 1. Seepage South of the Box Cut.

Photo 2. Non-Compliance 4: Inappropriate Storage of Wastes.



Photo 3. Non-Compliance 4: Inappropriate Storage of Wastes.

Photo 4. Erosion of the Remediated Waste Rock Dump.



Photo 5. Erosion matting on Remediated Waste Rock Dump.

Photo 6. WOO Rehabilitation Trial on Tailings Dam North.



Photo 7. Pollution Control Dam (site of stormwater breach).

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