williams, melissa melissa williams d i queensland ......the report states the demand for dust for...

Williams, Melissa

From: Williams, Melissa

Sent:

To:

Tuesday, 3 January 2012 9:11AM

Davison, Mike

Subject: FW: Hancock response to RPS request for outstanding informalion

Attachments: Alpha Coal CG Conditions report ver6 23.12.11.doc; Alpha Coal CG Condit ions report ver6 231211.pdf

For your enjoyment

Melissa Williams Significant Projects Coordination Office of the Coordinator-General Department of Employment, Economic Devel opment and Innovation Queensland Government

tel +61 7 3836 0667 (ext 60667) e [email protected] post PO Box 15517, City East Q 4002 visit Level 4, 63 George Street, Brisbane Q 4000 www.deedi.qld.qov.au

Tomorrow's Queensland: strong, green, smart, healthy and fair www.towardQ2.qld.qov.au

Please consider the enwonment before pnnt1ng th~s email

From: David Finney [mailto:[email protected]) Sent: Friday, 23 December 2011 12:34 PM To: Williams, Melissa Cc: Norrie Sanders Subject: RE: Hancock response to RPS request for outstanding information

Hi Melissa

Unfortunately Suzie sent you a previous version of the attached report. Please note that the attached version contains minor adjustments in response to our review of the Hancock submission of December 13.

Our apologies for any inconvenience caused.

Regards

135 Abbon Stieet , Cairns, OLD. Australia, 4870

David Finney Environment Manager- NQ E [email protected] W YIWW.msgroup.com.au

PO Box 1949, Cairns, OLD, 4870 T +61 7 4031 1336 F +61 7 4031 2942

TM men.age (~MY attadvnerO) is int.nded b r 1he use of 1he person or entity named above and may c:ontain In~ lion ~Nit is privllte, ~- 01 privltO'fd. If you are not the intended ,.cipient you ar• not authoriMd 10 <hdoM, ~-copy« UM of M n'ln"*gt. If you have tec:eh.d tnc.onwn.nc.bon in etrOI, pMaw contact thewritM il'tlln4Kb:ely on p: -+61 7 oiOll 1336. Wile RPS takes al raa~ble prwcautiOnl lb ..,....,. tlat b ~ f.Ysttms ~ra lrH ol YitUM$, itwil not bot iable tot <11ny 1oM. dilmage. iabil.ty. or da.rn ariwlg * of or lnc::i6tntal10 any damage 1o the c:omp.rter aystem of a recipient o f conwnu~tions or doo..ments origina~ from RPS and r.apientll rK~~i..,. COI'I'II'I'IUI''iionll t-om RPS It Uwir OWI'I nail

From: Melissa Williams (mailto:[email protected]] Sent: Wednesday, 14 December 201111:24 AM To: David Finney Cc: Mike Davison; Stuart Cameron; Norrie Sanders Subject: Re: Hancock response to RPS request for outstanding information

Gooc moming David

Norrie advised me last week to contact you in his absence for matters relating to RPS's wor1< on the Alpha Coal project.

Please find attached Hancock's response to Norrie's request for further information beyond the Alpha Coal Project SEIS and SEIS Addendum (via email, 14 November- see below).

Can RPS please review Hancock's responses to the request and advise whether any of this information will alter recommendations made by RPS in the repor1 provided to our office last week.

As the Coordinator-Generars Evaluation Report for this project is currently being developed, we would like to be advised of any likely alterations to RPS's recommendations as soon as is practical.

Please don't hesitate to call with any queries.

Kind regards Melissa Williams SignifiCant Projects Coordination

Office of the Coordinator-General Department of Employment, Economic Development and Innovation Queensland Government

tel +61 7 3836 0667 (ext 60667)

e [email protected] .qov.au post PO Box 15517, City East Q 4002 visit Level4, 63 George Street, Brisbane Q 4000 www.deedi.gld.qov.au

Tomorrow's Queensland: strong, green, smart, healthy and fa ir www.towardQ2.qld.qov.au

?tease consider the environment before pnnnng this email

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From:Sent: Tuesday, 13 December 2011 4:06 PM To: Melissa Williams Cc:Subject: Hancock response to RPS request for outstanding information

Dear Melissa,

Please find attached Hancock's response to the RPS request for information on the Alpha Coal Project.

This response is provided in both PDF and word format for ease of use.

Thank you.

Kind Regards,

Hancock Coal Ply Ltd Level 8, 307 Queen Street Brisbane OLD 4000 Phone: (+61) 7 3003 5903

Website: www.hancockcoal.com.au

./;Please consider the environment before printing this email.

From:

Sent: Friday, 2 December2011 10:54 AM

To: Melissa Williams

Cc: Mike Davison;

Subject: RPS Responses- delay

Hi Melissa,

of5

Just to let you know that the responses to RPS arc taking longer than anticipated so they will not be coming your way this week. I am waiting on the response time from PB who arc looking at the surface water questions and will get back to you once this has come through.

Regards

From:Sent: Monday, 14 November 2011 5:11PM To: Me!issa Williams; Cc: Mike Davison;Subject: RE: RPS requests_Aipha SEIS

Thank you for this.

please can you action gathering the information requested by Norrie.

Thanks and best regards,

Hancock Coal Ply ltd level 3, 60 Albert Street Brisbane OLD 4000

Website: www.hancockcoat.com.au

.J1 Please consider the environment before printing this email.

From: Melissa Williams [mailto:[email protected]] Sent: Monday, 14 November 2011 5:07PM

15/0112013

Sch. 4(3)(3)

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To:Cc: Mike Davison Subject: RPS requests_Aipha SEIS

Good afternoon

of5

Following our meeting this afternoon I received an email from Norrie Sanders (RPS) detailing requests for further information to allow completion of relevant sections of their conditioning report.

1 believe these were in line with discussions you had with Norrie during the site visit last week.

Please contact Norrie directly for any clarification on these points, with Mike and myself cc'd.

Thanks and kind regards Melissa Williams Significant Projects Coordination Office of the Coordinator-General

Department of Employment, Economic Development and Innovation Queensland Government

tel +61 7 3836 0667 (ext 60667) e [email protected] post PO Box 15517, City East Q 4002 visit Level4, 63 George Street, Brisbane Q 4000 www.deedi.qld.qov.au

Tomorrow's Queensland: strong, green, smart, healthy and fairwww.towardQ2.gld.gov.au

Plo~s~ comidi!rtho environment before Plinbngthi• em oil

From: Norrie Sanders [mailto:[email protected]] Sent: Monday, 14 November 20111:45 PM To: Melissa Williams Subject: outstanding information

Hi Melissa

Below is a summary of outstanding items which would help us to complete the conditions report. 1 have omitted reference to mine groundwater, tailings dam and rail flooding because both topics are under active assessment by Hancock. The information that I alluded to during the field trip to Alpha were based on our second review report (EIS and SEIS), extracts of which are included below. My conversation with mainly covered the creek analysis, but I have added other mine information for completeness.

Mine Water balance: see table below

Creek diversion: o add pre development curve to stream power graphs (8-8 and B-9) o Provide commentary on physical impacts on creeks where post development hyrdaulic parameters exceed current condition andfor A CARP guidelines- particularly

upstream and downstream of diversions. Stability risks in 050 are acknowledged but not specifically assessed or solutions proposed. o No flood inundation mapping is provided in the SEIS for the 2 year and SO year ARI events. The flood report includes intermediate (5, 10, 20 year) flood flows but does

not include hydraulic stability parameters.

o Comparative statistics on channel morphology pre and post diversion are not presented. Geomorphic features that mimic current morphology, such as terraces, meanders, wetlands, pools etc are not explicitly considered. Impacts on channel networks, floodplain connectivity, pools, takes and palustrine wetlands are absent.

Waste Rock: see table below

Landform and rehabilition: see table below

Mine water balance -Issues and recommendations

Issue Comment Actions Discharges to Lagoon The quantity and quality of discharges to Use daily water balance Creek- aggregated Lagoon creek are not specifled other than modelling to asses discharge outputs from water discharge criteria. The mine water risk under different event modelling do not provide a balance needs to be further analysed to scenarios using daily time sufficient basis for demonstrate that there is sufficient step. assessing risks and storage and treatment capacity to allow evaluating management adherence to the standards under specific Consider design and arrangements even conditions. management arrangements to

prevent discharge (e.g. temporary storage within levee area) when discharge criteria are not achievable.

20% of the "settling zone" volume has Some calculations to justify

been allowed for sediment storage in the the proposed sediment

sediment dams. This may not be storage allowance for the sediment dams needs to be sufficient for the volume of sediment included in the EIS. This will 2.3.1 Sediment Dams was hoff from the overburden which will

contain dispersive soils. If too small, the depend on the catchment

sediment dams will fill with sediment area, erodibility of the material

quickly, and overflows to Lagoon Creek and life of dam. The rate of sediment removal needs to be may be more frequent that anticipated. assessed.

3.1 Climate Data Figure 3--2 is said to be a log Pearson Ill Amend text. probability distribution. It appears to be

~~~~~~~e~~~-plot, not a frequency

It would be useful to see flow duration curves for the estimated and recorded

3.5.1 Sacramento Model flows to provide more information on the Provide more information on goodness of fit of this calibrated model. model cailbration The model's ability to reproduce low flows mav be imPOrtant in this context.

Limited or no explanation of where the Need to provide some more

3.5.2 Catchment yields catchment yields came from for different information (e.g. references)

land use activities. to justify the choice of catchment ield

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4.4 Dirty Water The proposed release points should be Clarification of the locations of Management System. shown on a plan. Table 4-1 gives the co- the sediment dam discharge

ordinates only. The table lists the release points is required. Sediment Dam discharge points as SD1a, SD2b, SD4b, and SD6b. points. However these do not appear on the

accompanying figures 4-1 to 4-5. Sediment dam capacities should be able The 10% AEP 24 hour rainfall to hold the 10%AEP 24 hour storm runoff depths should be tabulated

5.3.2 Sediment dam above the sediment zone. The capacities somewhere, and a description capacities do not seem large enough to hold this of how the sediment dams'

volume, but this may depend on the capacities have been derived runoff losses assumed. from the ifd data. The Report states the demand for dust For noting. May have been suppression is conservatively high, and preferable to relate dust does not account for rainfall. This means suppression requirements to in a high rainfall year, water use for dust daily evaporation- rainfall. In

5.5.2 Haul Road and suppression might be significantly lower this way dust suppression Hardstand watering than the volume listed in the report. As requirements would be less

this demand is a significant component of during wet years. the total demand, a lower demand may lead to more frequent overflow of the final sediment dams.

Figure 4.6 GoldSim This is meant as a schematic diagram of Prepare a schematic diagram network diagram. the water management system. It is a preferably overlaid on

Go!dSim output and is very confusing. background plan to show approximate location of sediment dams, environmental dams and discharge points.

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Waste rock· Issues and recommendations

Issue Comment Actions Proceed with proposed additional

Kinetic testing to dale is The AMD potential of raw coal and tailings column testing to further investigate limited and outcomes only is not yet confirmed and further kinetic Temporal saline and preliminary at this stage testing is required. acidic/metalfferous drainage

characteristics. It is recommended that further work is carried out to confirm dosing rates

Coarse coal rejects and Preliminary trial alkaline treatment efficacy during final design stage and these roof and floor waste rock are confirmed in the live MWMP. appear to have the highest has been undertaken on coarse reject Similar work should be carried out AP.

and coal seam roof and floor material. on representative tailings materials If further leachate testing confirms of concern AMD ootentiat. Seepage fate risk is to be

TSF location Tailings is likely to have acid leachate considered in groundwater

considerations generation potential and low to moderate modelling for initial out of pit TSF saline leachate potential and in pit disposaL This should be

conditioned in the EA Mining scheduling to recognize the

WRD capping strategy must recognize the goal of final placement of low high risk associated with placement of dispersion overburden cap

Presence of dispersive dispersive and highly dispersive (sandstones, luff) where possible. overburden and soils/clays- overburden within the final cover. This should be an EM Plan Final landform Design commitment and EA condition. implications Stripping depths of low or nil dispersive MINMP should also include

topsoils have been adequately identified strategies for selective placement for preferential rehabilitation use. and management of saline waste

materials. Bring forward development of the

EIS commits to preparation of a final void final void water quality model to the Final void water quality water quality model by year 5 of EM Plan OR approval conditions to

operations. provide for adequate worst case management strategies

Landform and rehabilitation· issues and recommendations

Issue Comment Action DERM's mandatory requirements and Consider Landform Design and

How is Mine Closure guidelines (e.g. 18) will apply to the Rehabilitation, EA 1998, Centre Planning addressed? rehabilitation strategy (25.1.213) but for Land Rehabmtation research,

no word on industrY-based initiatives QRC etc. Explain what will be done

EIS proposes fairly standard post differently. mine land classification, final landform plan, topsoil management and revegetation {25.1 ). What {similar) mine has achieved these?

Mine wastes are largely sodic I dispersive (Appx J1 7) and Discuss MINMP experience with encapsulation is proposed (16.6.3.1, test pit with HPPL I Thiess and 25.1.BandAppxJ1 &7.1.5) then provide mine planning A Mine Waste Management Plan details of how selective {MWMP} is in place for the lest pit and encapsulation will occur while commitments have been made (SEIS operating differing mine methods AppxD1.16.2) {IPCC draglines, truck I shovel)

How, in practical terms, will in different parts of the mine. rehabilitation be met?

Erosion and sediment control Provide more erosion guidance, (25.1.9.4) offers more on sediment especially for waste rock control and less on erosion control landform Land suitability classification unclear

Map pre and post mine land suitability classification across the mine and how Class to soils will be tracked.

Riparian vegeta:i~n is ~)oposed along Supply more details

creek diversions 25.1.6 Add such infrastructure as

Rehabilitation Success Criteria (Table diversions, levees, sediment Rehabilitation criteria should dams, roads, water storages, address the entire mine?

P47) should address 'other mine camp, quarry, landfill. Also infrastructure' modify Monitoring (Table P48) if reauired.

Unless stated otherwise, this email, together with any attachments, is intended for the named recipient(s) only and may contain privile·

If not an intended recipient of this email, you must not copy, distribute or take any action(s) that relies on it; any form of disclosu

Unless stated otherwise, this email represents only the views of the sender and not the views of the Queensland Government.

Unless stated otherwise, this email, together with any attachments, is intended for the named recipient{s) only and may contain privile•


Unless stated otherwise, this email represents only the views of the sender and not the vie·Ns of the Queensland Government.


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Alpha Coal Project

Review of Selected Aspects of the EIS Supplementary EIS, SEIS Addendum and other Proponent Responses: proposed conditions

Prepared by:

RPS AUSTRALIA EAST PTY LTD

7 43 Ann Street

PO Box 1559 FORTITUDE VALLEY QLD 4006

T: 617 3237 8899

F: 617 3237 8833 E: [email protected]

W: rpsgroup.com.au

Report Number: PR1 06805

Version I Date: Rev A I 08/0612011

RPS Australia East Ply Ltd (ABN: 44140 292 762)

Prepared for:

DEPARTMENT OF INFRASTRUCTURE AND PLANNING

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-Important Note

23 DECEMBER 2011 Alpha Coal conditions report

Apart from fair dealing for the purposes of private study, research, criticism, or review as permitted under the

Copyright Act, no part of this report, its attachments or appendices may be reproduced by any process without the

written consent of RPS Australia East Pty Ltd. All enquiries should be directed to RPS Australia East Pty Ltd.

We have prepared this report for the sole purposes of Department of lnfrstructure and Planning ("Client") for the

specific purpose only for which it is supplied. This report is strictly limited to the purpose and the facts and matters

stated in it and does not apply directly or indirectly and will not be used for any other application, purpose, use or

matter.

In preparing this report we have made certain assumptions. We have assumed that all information and documents

provided to us by the Client or as a result of a specific request or enquiry were complete, accurate and up-to-date.

Where we have obtained information from a government register or database, we have assumed that the information

is accurate. Where an assumption has been made, we have not made any independent investigations with respect to

the matters the subject of that assumption. We are not aware of any reason why any of the assumptions are

incorrect.

This report is presented without the assumption of a duty of care to any other person (other than the Client) ("Third

Party"). The report rnay not contain sufficient information for the purposes of a Third Party or for other uses. Without

the prior written consent of RPS Australia East Pty Ltd:

This report may not be relied on by a Third Party; and RPS Australia East Pty Ltd will not be liable to a Third Party for

any loss, damage, liability or claim arising out of or incidental to a Third Party publishing, using or relying on the facts,

content, opinions or subject matter contained in this report.

If a Third Party uses or relies on the facts, content, opinions or subject matter contained in this report with or without

the consent of RPS Australia East Pty Ltd, RPS Australia East Pty Ltd disclaims all risk and the Third Party assumes

all risk and releases and indemnifies and agrees to keep indemnified RPS Australia East Pty Ltd from any loss,

damage, claim or liability arising directly or indirectly from the use of or reliance on this report.

In this note, a reference to loss and damage includes past and prospective economic loss, loss of profits, damage to

property, injury to any person (including death) costs and expenses incurred in taking measures to prevent, mitigate

or rectify any harm, loss of opportunity, legal costs, compensation, interest and any other direct, indirect,

consequential or financial or other loss.

Document Status

I I I I RPS I l

Version Purpose of Document Orig Review I Review Date I R ~ II Release I ~s~e I evtew Approval; a e ' 0 I

A Client milestone NS,SC,OF, NS 3 Oct 2011 NS NS 3 Oct 2011 BO,GH,PD

8 Client milestone NS,SC,DF, NS 7 Nov 2011 NS NS 7 Nov 2011 BO,GH,PO

c Client milestone NS,SC,OF,

OF 23 dec2011 OF OF 23.12.11 BO,GH,PO

PR106805; RevAIOS/06/2011 Page ii

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Contents

1.0

2.0

3.0

INTRODUCTION AND PURPOSE ........................................................................................... 4

SUMMARY ............................................................................................................................... 5

MINE ......................................................................................................................................... 7

3.1 WATER MANAGEMENT .......................................................................................................... 7

3.1.1 Water balance and surface water discharges ........................................................... 7

3.1.2 Groundwater Modelling ............................................................................................. 8

3.1.3 Groundwater Monitoring .......................................................................................... 10

3.1.4 Initial Project Water Supply ..................................................................................... 11

3.2 CREEK DIVERSIONS ............................................................................................................ 12

3.2.1 Evaluation ................................................................................................................ 12

3.2.2 Proposed Conditions ............................................................................................... 13

3.3 WASTE ROCK CHARACTERIZATION AND MANAGEMENT .............................................. 16

3.3.1 Evaluation ................................................................................................................ 16

3.3.2 Proposed conditions ................................................................................................ 16

3.4 TAILINGS MANAGEMENT ..................................................................................................... 17

3.4.1 Evaluation ................................................................................................................ 17


3.5 FINAL LANDFORM AND REHABILITATION ......................................................................... 20

3.5.1 Evaluation ................................................................................................................ 20


4.0 RAIL ........................................................................................................................................ 24

4.1 VEGETATION ......................................................................................................................... 24

4.1.1 Evaluation ................................................................................................................ 24


4.2 CREEK AND RIVER CROSSINGS ........................................................................................ 30

4.2.1 Evaluation ................................................................................................................ 30


PR106805; Rev A I 08/06/2011 Page iii

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1.0 Introduction and Purpose


RPS was commissioned by The Department of Infrastructure and Planning (DIP) to advise on several

technical aspects of the Alpha Coal project. The objectives are to assess the adequacy of the

environmental impact assessment and to assist in establishing effective mitigation measures.

The technical scope is:

Mine: water, creek diversions, waste rock, tailings and rehabilitation

Railway: vegetation, waterway crossings and coal dust

By agreement, railway coal dust is no longer part of the scope because the issues are mitigation

measures are well established through environmental management conditions.

The document scope includes progressive reviews of the EIS, SEIS and EMPs, and input to approval

conditions and the Coordinator-General's report.

Our review of the Environmental Impact Statement (Issue 3, November 201 0) was submitted to DIP on 25

March 2011. The review noted that the EIS had a number of substantial gaps in basic data and analysis.

The second review included the Supplementary EIS (Issue 2 April 2011) and was submitted as a draft to

DIP on 24 June 2011. The review did not include groundwater because the proponent was still

assembling groundwater information.

The third and final review (this document) included the Supplementary EIS (Issue 4a, August 2011) and

the SEIS addendum report (Issue 1, November 2011). At DIP's request, this review focuses on

recommended conditions, rather than a detailed analysis of the project documents. The analysis has

been undertaken, but is presented only as a summary. The review is also the accumulation of our earlier

reports and therefore is a response to all of the relevant project documentation.

In addition it includes analysis and recommendations arising from a response received from Hancock

Coal (13 December 2011) to our various requests for additional information beyond the SEIS and SEIS

Addendum of 141h November.

Members of the review team also participated in meetings with the proponent's representatives and

government officers. A site inspection, including the test pit, lagoon creek and tailings dam site, was also

undertaken by two of the review team, in company with representatives of Hancock Coal and several

Queensland government officers.

PR106805; Rev B Page4

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- 23 DECEMBER 2011 Alpha Coal conditions report

2.0 Summary

Version 4 of the SEIS has added new information on some of the critical areas, notably stream diversions

and waste rock. The information has clarified several areas that can now be conditioned with more

confidence. Further information was recently provided through the SEIS Addendum dated November

2011, especially in relation to the TSF geotechnical and hydrogeological studies, and the railway flooding

studies.

Although the documentation is complete, consistent with our earlier advice, there is no issue within the

scope of our work that cannot be adequately conditioned and dealt with in more detailed design and

management planning. However, all areas continue to have gaps and errors in the information that is of

relevance to condition setting.

We note that some conditions have been drafted more conservatively (to reduce environmental risk) than

they may have been if all information had been supplied. The assessment of groundwater impacts both

during and post mining has not been completed to an adequate level of reliability, and should be resolved

before project operational approval.

The following is a brief summary of the status of each critical area for which we were commissioned:

• Water Management: water balance modeling has not been amended to include sensitivity

analysis and risk assessment, as previously requested by RPS. Consequently, conditions are

based on performance criteria and storage capacity. The bulk of conditions are expected to come

from DERM. Groundwater data are still being accumulated and analysed by the proponent. In

particular, potential impacts from the project have not been adequately assessed by groundwater

modeling, leading to significant uncertainty in the magnitude of regional impacts. Conditions

relating to groundwater are expected to be specified by DERM, but would need to also include

monitoring conditions to confirm conformance of the groundwater impacts to the predicted

impacts. Hancock Coal have advised in their response of 131" December that DERM is satisfied

with the groundwater model calibration however we would like to sight evidence of this

notification.

• Creek Diversions: data on the base case for stream power is not included, so erosion impacts

on the natural stream can only be inferred from other criteria. Conditions have been drafted

conservatively, based on established guidelines and information from the SEIS.

• Waste Rock: most issues are substantially clarified by the SEIS. Drafted Conditions focus on

content of the Waste Management Plan.

• Tailings: most attention in the review has been on the adequacy of the EMP as a reflection of the

proponent's commitments. There are shortcomings in the EMP, but all are able to be dealt with

through conditions. Lateral movement across the perching layer could lead to leachate migrating

outside the footprint of the TSF, where deeper hydraulic connection may exist. Although the

potential for leachate migration may be low, modelling is considered necessary, especially as the

out-of-pit TSF will remain in place in perpetuity.

PR1 06805; Rev B Page5

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• Final Landform: Similar comments apply as per tailings. Conditions are provided that build on

established DERM approaches and previous comments by RPS.

• Railway vegetation: information is substantially complete in the SEIS. Established conditions

are proposed for vegetation clearing and rehabilitation. Proposed offsets are quantified in the

conditions.

• Railway Crossings: flood afflux and velocity targets have been subject to discussion and are

acknowledged within the wording of the SEIS. Conditions have been drafted to clarify the targets

and provide for a more certain outcome for landholders in the event of no agreement with the

proponent to relax the targets.

PR 1 06805; Rev B Page6

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3.0 Mine

3.1 Water management

3.1.1 Water balance and surface water discharges

llJ.j_ Evaluation


The mine water balance analysis concludes that in a 90 percentile wet year, no discharge of

contaminated water to lagoon creek will occur. The water modelling used a number of assumptions that

were questioned in our previous report, notably:

• The 20% settling zone may not be sufficient

• Sediment dam capacities should exceed 10% AEP 24 hour storm volume

• Demand for dust suppression is assumed to continue in all weathers - in wet conditions, actual

demand is likely to be lower and will increase pond volumes

Sensitivity of the model outputs to these factors is unknown on the basis of the results presented, but all

could increase the risk of overflow to the creek. A more important omission is the lack of analysis of

discharge risks under different event scenarios. The 90%ile wet year modeled as worst case corresponds

to an annual rainfall of less than 800mm. Annual rainfall of up to 1400mm have been recorded. Similarly,

short term rainfall intensities may result in discharge in some circumstances.

3.1.1.2 Proposed Conditions

(Note: we have assumed that DERM will provide conditions for Pit dewatering, emergency releases from

ponds and detailed content of Water Management Plan. The following conditions are limited to containing

contaminant discharge):

No discharge of contaminated water is to occur under normal operating conditions.

Size Environmental dams to contain a 10% AEP 24 hour storm volume or 20 year ARI 3 month critical

wet period, whichever is the greater.

Increase sediment pond capacities by1 0%.

Maintain sediment level in ponds to less than 20% of operating volume.

PR106805; Rev B Page 7

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-3.1.2 Groundwater Modelling

3.1.2.1 Evaluation

Groundwater Modelling


Only preliminary groundwater modeling has been undertaken to date. A numerical regional groundwater

model is under development, using the finite element software FEFLOW, but modeling to date has not

adequately assessed the potential regional impacts from the project.

The regional model has been used for preliminary assessment of mining impacts and post-mining

recovery of groundwater levels, but the modeling has been compromised by a number of simplifying

assumptions. This significantly reduces the reliability of the predicted impacts and recovery.

Modeling of the mining phase was reported in Appendix N (SEIS Version 4, August 2011 ), but it involved

a number of simplifying assumptions that limit the reliability of the predictions (e.g. including no recharge,

uniform pre-mining groundwater levels across the model area, constant heads at the model boundaries,

unchanged hydraulic properties throughout the mining phase). Post-mining simulation of the

development of pit void lakes was also undertaken (SEIS Version 2, April 2011 ), but this was before the

mining impacts had been predicted, so it was based on unreliable assumed starting, and involved the

same other limitations as for the mining phase modeling.

Because of the above limitations with the groundwater modeling, it is difficult to have confidence in the

model-generated impact predictions obtained to date. More advanced modeling is required.

Recharge

Recharge to the Colinlea Sandstone and the coal measures sequence has been assessed as most likely

derived from diffuse recharge in the elevated areas along the Great Dividing Range to the south-west of

the project. This may be incompatible with the proponent's conclusion of minimal impact by the project

on the GAB aquifers. Recharge from the south-west of the mine would imply that it is derived either from

discharge from the GAB strata, or vertical infiltration from the surface through the GAB beds and the

basal Rewan Formation into the underlying Colinlea Sandstone. In either case, the potential for impact

on the GAB exists. The source and mechanism of recharge needs to be resolved in order to eliminate

this potential inconsistency.

Some attempt has been made to assess the potential impact of the project on the GAB, through

sensitivity modeling. However, without proper representation of recharge, this is of limited reliability.

Out of Pit Tailings Storage Facility

The hydrogeological and geotechnical investigations of the TSF site have indicated that the TSF location

is unlikely to be the primary recharge area for the Colinlea Sandstone. Nevertheless, any TSF located in

that area would need to incorporate careful investigation of the TSF floor area to eliminate potential

secondary recharge pathways (e.g. structural features), and to ensure low permeability of the TSF floor.

The Hancock response of 13th December 2011 states "Groundwater data and modelling indicates that

there is no hydraulic connection between the perched groundwater table and the piezometric levels

associated with the underlying confined layers. Thus modelling to include out-of-pit TSF is not

required." It cannot be concluded from the present status of groundwater beneath the TSF area that

lack of hydraulic connection will prevail once there is a continuous source of leachate available, as a


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mound may develop that allows deeper hydraulic connection (ie through the perching layer) to the deeper

groundwater. After all the perched nature of the shallow groundwater is a function of the availability of

water (from rainfall infiltration) and the vertical permeability of the perching layer. Lateral movement

across the perching layer could lead to leachate migrating outside the footprint of the TSF, where deeper

hydraulic connection may exist. Although the potential for leachate migration may be low, modelling is

considered necessary, especially as the out-of-pit TSF will remain in place in perpetuity.

Mine Dewatering Requirements

Monitoring of dewatering of the Alpha Test Pit (ATP) indicted that only limited water inflow rates are likely

from the overburden and the coal measures above the D seam, and that the major water inflows are likely

to be derived from the D-E sandstone underlying the D seam, and deeper units. With mining proposed

down to and including the D seam, it will be necessary to depressurize the underlying strata (at least the

D-E sandstone) and to dewater the strata above. A combination of pumping from external dewatering

bores and in-pit sumps is likely to be required.

The report on the monitoring of dewatering of the ATP suggested that post-mining recharge will be

limited, but this has not yet been evaluated by the regional groundwater model.


It is assumed that conditions will generally be set by DERM, as detailed in their Submission 11 (DERM,

October 2011 ), but the following additional conditions are recommended.

Modelling

A condition should be imposed requiring the groundwater model to be modified to allow more advanced

modeling to be undertaken prior to project approval. The modifications should at least include proper

representation of both recharge and natural discharge, appropriate model boundary conditions, variable

hydraulic properties through the simulations to allow the change in material properties from coal and

overburden to void space and then to waste rock backfill as open cut mining proceeds to be represented,

proper assignment of starting heads, and sequential modeling from pre-mining to mining to post-mining.

As the model needs to incorporate the combined effects of both the Alpha open cut project and the

adjacent Kevin's Corner open cut and underground mining project, it will be necessary to ensure that the

model is able to represent underground mining, including both saturated and unsaturated or pseudo

unsaturated flow, and parameter changes during simulations to represent the progressive effects of

subsidence on overburden layers.

A further condition should be imposed requiring periodic post-audits of the groundwater model, and re

calibration and re-prediction of future impacts during the mining phase of the project. These should be

undertaken initially at a minimum of 3-yearly intervals, and eventually at 5-yearly intervals throughout the

mining phase of the project.

Recharge


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A condition should be imposed that further investigations be undertaken to verify the source(s) and

mechanism(s) of recharge prior to project approval, as this may have a bearing on the potential for the

project to impact on the GAB.

Out-of-Pit Tailings Storage Facility

It may be necessary to require lining or sealing of at least parts of the floor of the TSF, as requested by

DERM. It should be a condition that prior to construction, a thorough investigation of the floor of each

proposed TSF cell be undertaken to identify and eliminate any potential zones of enhanced vertical

permeability that may provide preferred pathways (such as geological structures, soil features, etc) for

seepage to the underlying Colinlea Sandstone and/or down-gradient areas.

Although the potential for leachate migration may be low, modelling is considered necessary, especially

as the out-of-pit TSF will remain in place in perpetuity.


The effectiveness of external bores should be further evaluated as a means of depressurizing the less

permeable overburden and coal measures above the D seam, prior to commencement of mining.

Post-mining recharge should be appropriately evaluated with the regional groundwater model prior to

project approval.

3.1.3 Groundwater Monitoring

.1ldJ. Evaluation

A network of monitoring bores has been installed within and around both the open cut and the out-of-pit

TSF areas. A baseline monitoring program involving both water quality and groundwater levels has been

commenced, and is described in the EIS and SEIS documents.


It is expected that conditions would be primarily determined by DERM.

The DERM document (Submission 11, dated October 2011) specifies groundwater conditions that focus

mainly on water quality monitoring. The DERM conditions include the requirement to undertake a

minimum 12-month baseline monitoring program to determine per-mining groundwater conditions. A

further DERM condition requires that the proponent develop appropriate trigger values for a range of

water quality parameters.

However, other conditions should include, subject to development (prior to commencement of mining) of

a satisfactory numerical model, calibration and reliable prediction of impacts both during and after mining:


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• Groundwater level monitoring at representative monitoring bores, at frequencies determined on

the basis of the results of baseline monitoring and trigger values (monthly/quarterly/continuous);

• Monitoring of groundwater inflows and dewatering volumes pumped (monthly/continuous);

• Periodic comparison of water level changes with model-predicted water level changes, to verify

the reliability of model predictions;

• Annual reporting of the results of monitoring and comparison of observed impacts with predicted

impacts, to be made available to the government agencies and the public.

3.1.4 Initial Project Water Supply

3.1.4.1 Evaluation

The proponent has proposed using groundwater from either dewatering or from other water supply bores

in the early stages of mining prior to the completion of the external water supply pipeline. No assessment

of groundwater availability for the project water supply has been undertaken to date.

3.1.4.2 Conditions

It should be a condition of approval that a thorough investigation to demonstrate availability of sufficient

groundwater to meet the project's initial water supply needs be undertaken prior to commencement of

mining.

PR 1 06805; Rev B Page 11

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3.2 Creel< diversions

3.2.1 Evaluation


[Note: a revised version of Appendix J (Stream morphology technical report) was received on 29

September 2011, in response to a number of identified errors and omissions. The evaluation below is

largely based on the SEIS version 4 of Appendix J, but where issues have been clarified by the revision,

this has been taken into account. Remaining errors and omissions have been identified below and

conditions have been derived conservatively, wherever the data are inadequate or conflicting, to address

the higher environmental risk.]

Appendix J (Stream morphology technical report) demonstrates that the creek diversions are generally

within ACARP guidelines for 2 Year ARI. The exception is the 9.6km Lagoon Creek diversion, in which

maximum Shear Stress exceeds the relevant guideline by 50%. However, the remaining 15km of

undiverted reaches of Lagoon Creek, within the MLA boundary appear to be significantly affected by the

diversions, with spot velocities increasing at one site in the upper reach from 0.8mls to 1.4mls and in the

lower reach from 0.25mls to 1.4mls. These figures are at the upper limit of ACARP guidelines for

vegetated streams and above the limit for unvegetated streams. More importantly, they represent a substantial increase in velocities in a natural channel which has mobile bed sediments and sparsely

vegetated, unstable banks in many areas.

At 50 year ARI, spot velocities show substantial increases over current within the diversion and

downstream, with an increase from 2 to 2.5mls at one point downstream. Sheer stress predictions

generally are in line with current conditions, with one spike in the Lagoon Creek diversion. Stream power

data for the base case are not presented, but a number of spikes occur downstream of the Spring Creek

confluence, with one maximum at 400Wim2 and two maxima around 200Wim2. In a review of the

MacArthur river diversions, Wayne Erskine noted that channels erode at high powers (>25-100W/m2) and

that "no alluvial channel or bedrock can withstand a specific stream power of greater than 200W!m2"

(Recommended Improvements in Design of McArthur River Diversion Channels, 2006). The DERM limit

of 220W/m2, is above threshold for this type of stream and should only be applied to the diverted reach,

which can be stabilized as part of design/construction.

There is some doubt about the reliability of the stream power graphs in the report (see below), but these

spikes indicate high to very high risk zones in parts of the undiverted reaches. Whether this can be

satisfactorily mitigated by bank armouring is not possible to judge from the SEIS. This is complicated by

the fact that some of the affected reaches are downstream of the MLA boundary.

It should be noted that the critical limits for these hydraulic parameters are a function of channel

morphology, soils, vegetation and flow duration. In the undiverted reaches, Appendix J describes all of

these except flow duration. The longer the flow duration, the lower the critical value of the parameter and

hence the higher the risk of erosion.

There are a number of obvious errors in the report that have affected the interpretation of the data

presented in the SEIS, some of which have been picked up in the revised version. The most critical are:


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• Many of the values in Table 6.6 do not match the graphs in Appendix B (corrected in revised

version)

• Figures B-9 and B-27 are identical, despite being different creeks and different lengths

(corrected)

• Lagoon creek stream power graphs (B-8 and B-9) show only developed case and are only 9.2km

(less than the diversion length) whereas other graphs (B-4 to B-7) show over 40km (partially

corrected).

• The stream power scale in Figure B-8 appears to be two orders of magnitude low, based on

calculated stream power using velocity and shear stress, and comparison with the previous

SEIS.

• The stream power values shown in Figure B-9 appear truncated downstream of the Lagoon

Creek diversion and should be substantially higher if the corresponding shear stress and velocity

charts are correct.

Recommendations:

• Approve the proposed diversions subject to conditions to reduce the risks of serious erosion

3.2.2 Proposed Conditions

Preconstruction

Submit final designs for approval that:

• Are generally in accordance with the diversion plan forms depicted in Appendix J

• Provide a detailed baseline geomorphic assessment of undiverted creek reaches that are

predicted to be affected by changed hydraulic conditions (Appendix J) - at a minimum, within the

MLA and up to 5km downstream. The assessment is to provide quantitative benchmarks of

current condition (e.g. bank structure, vegetation, instream sediment, channel location and

dimensions) as a comparison to potential future changes.

• Provide a detailed evaluation of soil conditions along the diversion routes and propose designs to

minimize erosion potential for areas with erodible and/or dispersive soils;

• Demonstrate compliance with hydraulic criteria (Table 3.2);

• Propose design solutions to ensure channel stability for any locations where one or more

hydraulic criteria are exceeded;

• Provide for equivalent aquatic habitat diversity based on the range of habitats being removed as

a result of the diversion;


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• Specify riparian and floodplain vegetation planting to re-establish natural densities and species

diversity;

• Specify methods to maximize vegetation establishment rates (e.g. temporary irrigation, soil

amendment) and maintain viable plants;

• Include contingency plans for temporary stabilization during vegetation establishment period e.g.

grassing, anionic polyacrylamide application.

Table 3.2: Criteria for hydraulic design

. . . Criterion Diverted reaches - Natural reaches- Notes

. ) ~ 5 ~ . maxim!lm value1 maximum increase' .

• . . . . ..

2 yr ARI Stream Power (W/m2) 60 7% SEIS does not present

(up to 60W/m2)

graphs of stream power

for natural reaches.

A CARP guideline is

used as default.

50 yr ARI Stream Power (W/m2) 220 3% As above; A CARP

(up to 150W/m2)

criterion is too high for

the natural reaches of

the creek.

2 yr ARI Velocity (m/s) 1.5 50%

(up to 1.5m/s)

50 yr ARI Velocity (m/s) 2.5 10% Maximum velocity in

(up to 2.0m/s) natural reach based on

Appendix J, Figure B-5

2 yr ARI Shear Stress (N/m2) 40 50%

(up to 40N/m2)

50 yr ARI Shear Stress (N/m2) 80 10% Maximum shear stress

(up to 120N/m2)

in natural reach based

on Appendix J, Figure B-

7.

Notes:

1. DERM/ACARP criteria

2. The lower of the two figures is applicable. Percentages are relative to a discrete point or uniform reach; allowable limits

for velocity and sheer stress derived from SEIS Appendix J, Figures B-4 to B-7. Absolute limit is shown in parentheses

and is based on ACARP guidelines and Appendix J, Figures B-4 to B-7.

PR1 06805; Rev B Page 14

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Construction


Include in the erosion and sediment control plan specific measures to minimise erosion risk during

diversion construction. In particular, effective measures to control erosion risk from dispersive soils

exposed during construction must be included.

Identify and implement contingency measures to minimize the risk of major erosion damage in the event

of a high flows occurring during the construction period.

Post construction stabilization and revegetation

Test bed and bank materials from the constructed channels for erodibility (ESP, pH, EC, Emerson

dispersion) and modify the channel stabilization measures accordingly. In particular, treat areas of

dispersive soils to minimize dispersion - e.g. addition of gypsum and topsoiling (minimum 0.5m),

meshing, seeding;

Undertake revegetation and other channel stabilization works as per the approved design. Undertake

progressive stabilization and planting within one week of bulk earthworks.

Provide contingency measures for high risk events such as floods and high intensity rainfall to prevent

high rates of sediment mobilization during plant establishment phase (10 year minimum).

Rehabilitate areas affected by post construction erosion and/or deposition (e.g. following floods, overbank

flow or dispersion).

Monitoring

Monitoring sites are to be established at critical areas within diversions, within natural channels within the

site and in affected reaches downstream of the MLA. Reference (control) sites are to be established

Monitoring is to be undertaken quarterly and after flood events (1 year ARI and above)

Monitoring is to include:

• Plant health and mortality

• Bank erosion, slumping and loss of topsoil;

• Soil dispersion in channel;

• Sediment deposition in channels

• Change in channel location/planform (may require aerial photography at 1 year intervals)


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3.3 Waste Rock Characterization and Management

3.3.1 Evaluation


The additional waste rock characterization work discussed in Volume 2 Appendix S - Coal Mine Interim

Geochemical Report has substantially clarified many issues arising out of the EIS. Notwithstanding that

some geochemical testing remains in progress (e.g. Tailings and C Seam waste kinetic testing) proposed

management of waste rock and tailings materials have been adequately identified in commitments

proposed in Section 3.6.12.

3.3.2 Proposed conditions

E4 Waste Management

E 9 Authorised spoil disposal facility(s) must be constructed and maintained in accordance with certified

design plans submitted to the administering authority which are to be reviewed and revised as necessary

in accordance with findings of the MWMP and ongoing waste characterization. work, including short term

coarse reject PAF neutralization.

E 13 Mining Waste Management

Refer to comments and details under Section 3.4.2.


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3.4 Tailings Management

3.4.1 Evaluation


Evaluation of Tailings Management is connected with Final Landform and Rehabilitation (section 3.5) and

to a lesser extent with Waste Rock Characterization (3.3) and Water (3.1 ).

SEIS EMP (Vol V) is an important planning document as it summarises contextual planning data that

supports proposed conditions. In its current form, it is comprehensive and either partially confuses

connections between sections or does not reference them clearly. Lack of clarity and referencing detracts

from its value in mine development. Improvements to EMP material are proposed below in this section

and to proposed Conditions in 3.4.2.

Proposed EMP changes are:

• A document structure edit that:

o formats and numbers sub-sections that can then be referenced easily later, e.g. V3.6.6.1

has many sub-sections, and

o shows a flow diagram of plans and how they fit together, e.g. MWMP, Spoil Management

Plan, PCMP, RMP

• A technical content edit that:

o connects mine waste elements correctly. For example, E6-12, termed 'Spoil' applies to

Tailings Storage Facility (TSF) whereas MWMP seems to have a broader definition that

is all mining wastes including TSF, rejects and overburden;

o includes all Commitments from Volume 0 (many Commitments are missing from 01.16.2

and 01.25 in V3.6.12 and V3.7.9, respectively;

o avoids repetition, e.g. Conditions E13 and F12 are the same; and,

o has conditions in the correct section, e.g. F14 & F15 should be in E

• greater emphasis on landform stability throughout V3.6.6 - 3.6.13, as requested in RPS report

and in Overburden meeting 18/5/11

• link V3.7.4/5 Environmental Protection Objectives and Performance Criteria to OERM's Financial

Assurance and Rehabilitation requirements and to water quality outcomes

• Table V-62 Rehabilitation Success Criteria offers potentially useful key criteria for indicators that

need to:

o be better referenced, e.g. Landform stability to Slope conditions (Table F1 & F2), to IECA

Erosion & Sediment Control Guidelines 2008 and soil loss factors for different slope

configurations


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o support EMP quantitative data, e.g. topsoil depths to V3.7.6.1; and,

o provide more practical guidance, e.g. 'Use contour banks and diversion drains either to

direct water down slopes into sediment control basins and/or into dump revegetation

schemes as per schematic X'

The implications on Financial Assurance should be explained for success/failure of tailings, rehabilitation,

re-mining rehabilitated areas in support of Table V-63 Rehabilitation Monitoring Program.

New and revised conditions have been proposed.

The new condition (E17) is to accommodate potential transitions between two discrete alternatives of out

and in-pit tailings storage and different sizes that require risk assessment and impact mitigation to suit.

The revised condition (E13) revises an increasingly standard condition that covers all mining wastes,

focuses on PAF and does not link clearly to other standard conditions. It has been revised to:

• link to a broader Rehabilitation Management Plan

• complement spoil management planning, post closure management planning; rehabilitation success criteria, rehabilitation monitoring and standard mine planning;

• characterise reactive and unreactive materials to suit landform, polluting and revegetation

parameters;

• follow a standard mine design, construction and maintenance program; and,

• build on the MWMP for the bulk sample pit.

The revised condition (W34) is added to ensure that monitoring is specifically required to identify the

potential for saline seepage from the TSF to impact on Lagoon Creek .

SEIS Addendum Appendix C TSF Hydrogeology Assessment and Appendix D TSF Geotechnical

Assessment do not change conditions G1-19 in SEIS V3.4.1 0.2. They provide more confidence about the

out-of-pit TSF and guide the design report and construction of the regulated structure required by

Conditions.


This section addresses changes to proposed conditions in V.3.6.13, Schedule E Waste and Mining Waste

Management:

1. Add Condition:

E17 Prior to construction of any mineral waste storage facility, undertake a risk assessment, in

accordance with generally accepted standards to determine if.'

a) the mineral waste is a hazardous waste or has acid producing potential;


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-b) the mined pit is a hazardous dam.


Two discrete alternatives of out and in-pit tailings storage and different sizes to accommodate potential

transitions require risk assessment and impact mitigation to suit.

2. Revise condition E13 to read:

E13 A Mining Waste Management Plan together with certification by an appropriately qualified person

must be developed and implemented during the continuation of the environmental authority. The Mining

Waste Management Plan must be part of a Rehabilitation Management Plan and at a minimum include:

a) Characterisation programs to ensure that all mining waste is progressively characterised during

disposal for net acid producing potential, salinity and the following contaminants: Iron (Fe},

Aluminium (AI}, Copper (Cu}, Magnesium (Mg}, Manganese (Mn}, Calcium (Ca), Sodium (Na)

and Sulphate (S04};

b) Characterisation programs to ensure that physical properties of the mmmg waste are

progressively characterised during disposal and suitable for landform designs that include the

following parameters: soil dispersibility and robustness, rock armour, topsoil suitability;

c) Availability or leachability of metals and other pollutants (e.g. soluble salts) from the mining

waste;

d) Quantities and distribution of acid forming (PAF}, erodible and robust mining waste and topsoil;

e) Assessment of potential risks and opportunities of PAF, erodible and robust mining waste on the

success of proposed rehabilitation methods;

f) Design and management plans for selective placement and capping of materials to suit

rehabilitation success criteria

g) Construction and maintenance methodologies to suit designs;

h) Contingency plans and emergency procedures for non-routine situations;

i) Periodic performance review program for designs, construction and maintenance;

j) Monitoring as per Rehabilitation Monitoring program; and,

k) Continual improvement mechanisms

3. Revise Condition W34 to read:

W34 The holder of this Environmental Authority must ensure proper and effective measures are taken to

avoid or otherwise minimize the generation and or release of saline drainages; this shall include the

installation of a network of bores (with pump back capability) between the TSF and Lagoon Creek to

monitor for the potential migration of saline seepage to Lagoon Creek.


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-3.5 Final landform and rehabilitation

3.5.1 Evaluation


The introductory comments made in 3.4.1 about the EMP structure and changes apply more to this the

Final landform and rehabilitation section. The structure of Volume V and its cross-referencing to SEIS I

EIS was less clear.

In summary, it is proposed that conditions in V3. 7.1 0, Schedule F Land be deleted, relocated, added and

changed as identified below.

Delete conditions: F12, F13, F14, F15, as they are repeated in Schedule E.

Move conditions: F16 & F17 that would suit Schedule E better

Two additional conditions are proposed:

1. New F12 and Table F1 & F2 are standard conditions. Table V-62 Rehabilitation Success criteria

cover more than these data, but not clearly (as stated in the comments on the EMP structure).

For example, in Table F1: defining land suitability Class is necessary, and in Table F2,

distinguishing slope ranges for voids, ramps and different dumps would be useful. Data needs to

be provided by the Proponent and be compatible for land use, suitability and designs proposed in

the EIS.

2. New F13 is required due to a lack of clarity and quantifiable data in Table V-62 Rehabilitation

Success Criteria, Condition F1 and in the section V3. 7 Land Management (refer comments in

3.4.1 ).

Revise five conditions:

1. F2 adds stockpiling and respread of topsoil to the existing condition that requires the Topsoil

Management Plan only to address topsoil stripping.

2. F4 adds reference to conformance to success criteria which is the outcome sought by the title of

the condition.

3. F9 adds to the Rehabilitation Monitoring Program implications for financial assurance of

rehabilitation success or failure as they are linked.

4. F1 0 reverts to a standard condition. It raises the timeframe to 30 years, from 20 years, and offers

a shorter period if rehabilitation competence is proven.

5. F11 adds safety and structural integrity to the monitoring regime to align with the Rehabilitation

guideline and adds a section on decommissioning.


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Additional and changed conditions are defined below.

1. Additional conditions:


New F12 A// areas significantly disturbed by mining activities must be rehabilitated to a stable landform

with a self-sustaining vegetation cover in accordance with Table F1 and Table F2 (complete in

negotiations between Proponent and Regulator).

Table F1: Final/and use and rehabilitation approval schedule

Disturbance type Post-mining land use Post-mining land Post-mining land

suitability class for dry suitability class for beef

land cropping cattle grazing

xxxx xxxx xxxx xxxx

e.g. Infrastructure e.g. Grazing e.g. N/a e.g. Class IV

xxxx xxxx xxxx xxxx

Table F2: landform design criteria for Alpha coal mine

Disturbance type Slope Range (%)

xxxx XXXX,

e.g. Overburden emplacement e/g. 0-9%

xxxx xxxx

New F13: Complete an investigation into the planned rehabilitation of disturbed areas and submit a report

to the administering authority proposing acceptance criteria to meet the outcomes in condition F1 and

Table F1 and Table F2 within 12 months of the issue of the Environmental Authority.

2. Revised conditions

F2 Topsoil: Topsoil must be strategically stripped ahead of mining, stockpiled and spread for rehabilitation

in accordance with a topsoil management plan.


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F4 Rehabilitation landform criteria: Progressive rehabilitation must commence within two (2) years of

when areas become available within the operational/and and conform to success criteria.

F9 The Rehabilitation Monitoring Program must be included in the Plan of Operations and updated with

each subsequent Plan of Operations, describing:

a) How the rehabilitation objectives will be achieved,

b) Verification of rehabilitation success

c) Implications for financial assurance

Implications of monitoring on financial assurance is added.

F10 Post closure management plan: A Post Closure Management Plan for the site must be prepared at

least 18 months prior to the final coal processing on site and implemented for a nominal period of:

1. at least thirty (30) years following final coal processing on site, or

2. a shorter period if the site is proven to be geotechnically and geochemically stable and it can be

demonstrated to the satisfaction of the administering authority that the site has been

decommissioned and rehabilitated such that it will not cause environmental harm for the

foreseeable future.

F11 The Post Closure Management Plan should include the following elements:

a) operation and maintenance of:

1 wastewater and reticulation systems

2 waste water treatment systems

3 the groundwater monitoring network

4 final cover systems, and

5 vegetative cover

b) monitoring of:

1 surface water quality

2 groundwater quality

3 seepage rates

4 erosion rates

5 the integrity and effectiveness of final cover systems


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6 the health and resilience of native vegetation cover

7 safety

8 structural integrity

c) decommissioning of."

1. infrastructure and buildings;

2. site preparation and services;

3. contaminated land assessment

4. hardstand and roads

5. dam and surface water drainage and features.

PR106805; Rev B


Page 23

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4.0 Rail

4.1 Vegetation

4.1.1 Evaluation


Where clearing of remnant vegetation for the railway line affects a portion of an intact area of remnant

vegetation, the uncleared remnant vegetation is to be of sufficient size and configuration to ensure that

the remaining vegetation results in a functioning ecosystem. The clearing should be located so that

connectivity is maintained between the affected patch of remnant vegetation and adjacent patches.

Clearing of remnant vegetation should not take place where the width of remnant vegetation is less than

200 metres.

Clearing of remnant vegetation for the railway line and associated with any watercourse crossings should

be undertaken in accordance with 'Guideline - activities in a watercourse, lake or spring associated with

mining operations' (version 1, 15 April 2008).

4. I .2 Proposed Conditions

Vegetation Management

The holder of this authority must:

1. prevent or minimise disturbance to vegetation; and

2. manage the effects of clearing to prevent the loss of biodiversity, reduction of ecological

processes and land degradation.

The holder of this authority must ensure that any clearing complies with the following:

1. the clearing does exceed the proposed clearing areas identified in Table 4.1. A detailed

assessment of clearing of wetland vegetation, particularly within the Caley Valley Wetlands,

is completed;

2. all reasonable and practical measures are made to minimise the area cleared and to avoid

the clearing of mature trees;

3. access tracks are not located in Endangered Regional Ecosystems;

4. clearing of mature and hollow bearing trees are avoided where practicable; and

5. a qualified ecologist is present during clearing activities to ensure impacts on flora and fauna

are minimised.


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Table 4 1· Disturbance Limits .. Environmental Category

Endangered RE

Of Concern RE

Threshold RE

Essential Habitat

Waterway vegetation

Wetland vegetation

Corridor vegetation

Fish habitat

High value regrowth

Threatened Ecological Community

Disturbance Limit (ha)

111.43

104.16

11.01

14.08

72.34

To be determined

395.91

0.43

62

87.35


The holder of this authority must ensure that camps and lay down areas are located at least 20m from

remnant regional ecosystems or high value regrowth regional ecosystems.

The proponent is required to ensure that all clearing in relation to the services corridor must meet the

Regional Vegetation Management Code for Brigalow Belt and New England Tablelands Bioregions

(Version 2); and as such, the proponent will need to provide a vegetation offset as per the Queensland

Government Policy for Vegetation Management Offsets current at the time the clearing is required. The

offsets identified must be legally secured as outlined under Criteria 4: Policy for Vegetation Management

Offsets (Version 2.4) prior to the area required for the development being cleared.

Where possible, the clearing of native vegetation within road reserves or watercourses must not reduce

the width of the vegetation community to less than 50m.

Fallen timber must be moved as little as possible and replaced once construction has been completed.

Trees that are required to be felled must be retained on site and subsequently moved into adjoining

habitats and left as ground habitat, unless otherwise required by the land holder.

The proponent must submit a threatened flora and fauna species and ecological communities'

management plan for approval by the Department of Environment and Resource Management prior to the

commencement of any works that:

(a) ensures the impacts to these species and communities are minimized;

(b) contributes to the survival of these species and communities in the wild; and


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(c) achieves conservation benefits for these species and communities where practicable.

As a minimum, the threatened flora and fauna species and ecological communities' management plan

should include:

(a) a list of species listed as endangered, vulnerable or rare under the Nature Conservation Act 1994 that

may be impacted;

(b) a map that identifies GPS positions for known locations of significant species as listed under the

Nature Conservation Act 1994 in the clearing footprint and its surrounds;

(c) affected species listed by the Department of Environment and Resource Management on its 'Back on

Track' systems that are identified as in decline and have a good potential for recovery;

(d) the additional and ongoing management activities to mitigate impacts to native vegetation

communities;

(e) how the proponent will satisfy the requirements of Section 322 of the Nature Conservation (Wildlife

Management) Regulation 2006 relating to tampering with animal breeding places;

(f) management of affected fauna during construction and operational phases;

(g) a commitment to provide information on flora and fauna management actions for significant species

for inclusion in the Department of Environment and Resource Management's 'Recovery Actions

Database' when that framework is finalized and becomes operational; and

(h) a commitment to submit a clearing permit for approval by the Department of Environment and

Resource Management should an endangered, vulnerable or near threatened plant listed under the

Nature Conservation Act 1994 be identified in the clearing footprint.

Rehabilitation Requirements

Progressive rehabilitation of temporary disturbances (including camps, lay down areas, stockpiles and

construction access tracks) must commence as soon as practicable following decommissioning.

All land significantly disturbed by construction of the rail must be rehabilitated to:

2. a stable landform with a self-sustaining vegetation cover with similar species and

density of cover to that of the surrounding undisturbed areas, except over the area

that must be maintained free of large flora species for rail operation and access;

3. ensure that all temporarily disturbed land is reinstated to the pre-disturbed land use

and suitability class;

4. ensure that the maintenance requirements for rehabilitated land is no greater than

that required for the land prior to its disturbance.

For areas of native vegetation, revegetation must use seed sourced from local provenance native

species.


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For any planned rehabilitation outcome that cannot fulfill these rehabilitation requirements, approval must

be sought from the administering authority, prior to the rehabilitation being carried out.

Maintenance of rehabilitated areas must take place to ensure and demonstrate:

1. stability of landforms;

2. erosion control measures remain effective;

3. stormwater runoff from rehabilitated areas does not negatively affect the environmental values of

any waters;

4. plants show healthy growth and recruitment is occurring; and

5. declared pest plants are controlled on rehabilitated areas to a level consistent with the

surrounding property and prevented from spreading to unaffected areas.

Rehabilitation can be considered successful when the site can be managed for its designated land-use

(either similar to that of surrounding undisturbed areas or as otherwise agreed in a written document with

the landowner/holder and administering authority) without any greater management input than for other

land in the area being used for a similar purpose and there is evidence that the rehabilitation has been

successful for at least 3 years.

Pest and Weed Management

The holder of this authority must develop and implement a pest and weed control program that includes

but is not limited to the following:

1. identification of areas requiring pest and weed control;

2. control measures to prevent the spread of pest and weed species; and

3. measures to eliminate infestations of noxious pest and weed species that may occur.

Biodiversity Offsets

A Biodiversity Offsets Management Plan must be prepared to comply with the following offsets policies:

1. Policy for Vegetation Management Offsets, Version 2.4 (DERM, 2009); and

2. Biodiversity Offsets Policy (DERM, 2011 ).

3. The area of wetland vegetation to be disturbed has not determined and therefore the Offset

Strategy does not supply a total estimate of offset requirements at the time of this report.

A minimum offset ratio of 1:3 (clearing: offset) is required for the clearing of vegetation associated with

the environmental areas identified in Table 4.2.

Table 4.2: Proposed Clearing Area and Minimum Offset Requirements


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Environmental Area Proposed Clearing Area

(ha)

Endangered REs 111.43

Of Concern REs 104.16

Threshold REs 11.01

Essential Habitat 14.08

Waterway vegetation 72.34

Wetland vegetation To be determined

Corridor vegetation 395.91

Fish habitat 0.43

High value regrowth 62

Threatened Ecological 87.35

Communities


Minimum Offset (ha)

334.29

312.48

33.03

42.24

217.02

To be determined

1,187.73

1.29

186

262.05

Threatened flora species are also to be offset at a minimum 1:3 ratio for each individual cleared for the

project. The determination of the suitability of offsets will need to address the following involve

considerations:

• tenure and land use constraints;

• distance from clearing area;

• landscape connectivity;

• patch size;

• condition;

• remnant status;

• existing level of protection;

• habitat for threatened taxa .

The Biodiversity Offsets management Plan must address the Policy for Vegetation Management Offsets

and include the following:

• Identification of suitable offset sites;

• BioCondition assessments of clearing and offsets areas to determine ecological equivalence;


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• Rehabilitation measures and targets to achieve offset objectives;

• Measures to address threatening processes;

• Pest and weed management;

• Live-stock management and fencing requirements;

• Fire management;

• Contingencies for failed revegetation and regeneration;

• Legal protections measures to secure biodiversity offsets;

• Monitoring and maintenance plan;

• Roles and responsibilities

• Reporting requirements.

PR1 06805; Rev B


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-4.2 Creek and River Crossings

4.2.1 Evaluation


The revised crossing designs in the SEIS and the SEIS addendum have addressed a number of issues in

relation to mitigating the barrier effect of the railway on passage of floodwaters across the landscape.

The proposed maximum afflux of 1.5m and outflow velocity of 5m/s in the original EIS (Appendix Y, table

3.2) were considered to be too high and following negotiations with Hancock, section 3.2.1 has been

amended to provide for a maximum afflux target of 0.5m. In locations where greater than 0.5m can be

"tolerated", the proponent's proposal is for a design report and landholder consultation. It is unclear

whether a condition based on these maxima would be achieved if the landholder disagreed. A maximum

outlet velocity target from culverts of 3m/s was proposed "where possible", with "stakeholder input".

The wording in section 3.2.1 of the SEIS implies that if the design change to achieve these lower targets

is not practical, then the design should still be acceptable. This situation would lead to considerable

uncertainty about the outcomes for the landholders in the event of a disagreement or more importantly, in

the event that the outcomes may cause adverse impact to rural productivity, safety or assets. Velocities

as high as 5m/s would also have a high erosive potential and could threaten creek stability and ecology.

The analysis has indicated that some of the floodplains have complex flow patterns and the low relief can

result in floods in some locations under some circumstances moving in the reverse direction from the

normal flow (i.e. there can be downstream to upstream) movement. This means that at these locations,

flood afflux can occur in the normal "downstream" direction. The crossings are designed with an assumed

flow from upstream to downstream, so once the flood modeling is completed, there is a case for revising

those designs which have exhibit this unusual behaviour.

More detailed flood modelling of the floodplain areas crossed by the proposed rail alignment has been

completed, and the results are described in the addendum report to the SEIS. The drainage design

criteria proposed and used by the consultants in their floodplain modelling are included in the addendum

reports and have been reproduced here as Table 4.1 below.


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Table 4.1 Proposed SEIS modified Drainage Design Criteria (from SEIS addendum reports)

Inundation Extent

Inundation Duration

Max Velocity

Maximum afflux

Acceptable increases In inundation extent (above the existing conditions for a given return period to the 50 year ARI event) will be proposed where such an increase will not alter rural land use and result in significant Impacts

Inundation duration not more than 3 days on valued pasture I and that had previously been Inundated for 3 days or less for similar rainfall events.

Brtdge outi et velocity ~ maximum of 1.2 x existing velocity at a distance equal to the bridge span downstream of bridge

Culverts outlet velocity

~ 1.5 m/s where erodible solls are present

~ 2.5 m/s for normal soils (with no erosion control)

Maximum 0.5 m- normally (unless justifiable)

Maximum 0.2m -around crttlcal infrastructure

Maximum 0.1 m -around dwellings

The addendum report describes the hydrologic and hydraulic modelling carried out in the following

floodplain areas:

• Logan Creek I Brown Creek

• Sutter River I Eaglefield Creek

• Belyando River I Native Companion Creek

• Mistake Creek

• Midere Creek I Piebald Creek

• Diamond Creek I Myra Creek I Nibbereena

Results of this modelling were provided in the addendum report, and information packs containing the

results of the modelling have been supplied to impacted landholders along the route. The addendum

reports indicate that the proposed cross drainage will meet the modified drainage design criteria listed in

Table 4.1.

In general, it appears that proposed cross drainage provisions for the floodplain areas are acceptable,

based on the results of the modelling, although this would need to be confirmed by a more detailed

review of the proposed cross drainage structures and the modelling results closer to the design stage.

In addition to the floodplain areas, which have been the subject of the detailed modelling referred to

above, there are a large number of culverts on small drainage lines and streams. The original BFS study

lists 335 culvert sets, and provides some details of the velocity estimates through these culverts. While

the BFS study is a preliminary sizing exercise, the results (listed in appendices of the BFS drainage

report) indicate that for 6% of these culverts, the maximum outlet velocity will exceed 3.0 mlsec; and for

25% of the culverts the afflux (head) will exceed approximately 0.3 metres. For these culverts the size

should be increased to meet the proposed design drainage criteria.


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-4.2.2 Proposed Conditions


From the above description and from a review of the available information, it is considered that the

railway cross-drainage should be designed so as to achieve the following criteria:

• Maximum afflux of 0.3m for the design flood event, subject to special conditions (below) for lands

other than infrastructure and housing. At dwellings, the maximum afflux should be 0.1 metres or

less, and at infrastructure (for example state roads, and sub-stations etc), the maximum afflux

should be less than 0.2 metres.

• Maximum culvert outlet velocity 2.5 m/s for the design flood event, subject to special conditions

(below).

• Inundation duration compared to present- less than 5% increase in the duration of flooding for

design events.

• Inundation extent compared to present - no significant impacts; no change in land use; no

change in land productivity. Landholders in affected areas to be informed of any changes.

• Maximum afflux and water velocity criteria are applicable both upstream and downstream for

those waterways that may exhibit reverse flow under some circumstances

Submit to the Co-ordinator General for approval a detailed design report for flood passage and drainage

associated with the railway, generally in accordance with the items listed in Appendix Y, section 3.2.1,

with the following additional information:

• Flood levels

• Afflux, duration of inundation and culvert velocities for 20, 50 and 100 year ARI events

comparing current and developed conditions

• Frequency of overtopping of the lowest rail level at the cross drainage location.

• Specific impacts on infrastructure, assets (including housing) and rural operations.

• Sensitivity analysis demonstrating the effects of different design options on afflux

Submit a written statement from each landholder who is potentially impacted by changes to the drainage

regime which contains:

• Confirmation that the landholder has sited design information showing afflux,

• Landholder responses to information provided showing impacts on flooding, including afflux and

changes in inundated areas.

Following a significant flood event, the proponent shall undertake a damages survey and in the event

of adverse impacts to assets or waterways, rectify and/or compensate any damage to assets,

infrastructure and farm production that has resulted from the railway.


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Provide a bond of $200,000 for an independent auditor to assess flood impacts and verify the

requirement for, and the appropriateness of, rectification and/or compensation measures.

Special Conditions

a) In some locations; for example in floodplain areas, highly erodible areas, and areas where there

is significant flood-prone infrastructure within short distances upstream of the alignment, a

smaller afflux may be appropriate. The afflux and culvert outlet velocity criteria may be set at

lower values in these areas in response to landholder and other stakeholder consultation and

requests, and an assessment by the regulator.

b) In other locations; for example in remote undeveloped locations in erosion resistant landscapes,

a larger afflux may be permissible. This will only be considered where:

• A separate design report is prepared, to justify the higher afflux;

• Impacted landholders have sited the design report, acknowledged the variation and

agreed to the higher afflux conditions in writing; and

• Assessment by the regulator confirms no adverse consequences are likely.


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Williams, Melissa

From:

Sent:

To:

Williams, Melissa

Tuesday, 3 January 2012 10:26 AM

'Curley Peter'

Cc: Davison, Mike

Subject: FW: Hancock response to RPS request for outstanding information

Page 1 of2

Attachments: Alpha Coal CG Conditions report ver6 23.12.11.doc; Alpha Coal CG Conditions report ver6 231211.pdf

Good morning Peter, Happy New Year!

Please find attached the revised 'proposed conditions' report from RPS, provided on 23 December 2011. As discussed before Christmas, this revision was prepared in response to the additional information provided to RPS by Hancock on 14 December.

Please provide this document to the relevant DERM officers for their review in consideration of conditions for the CG's report.

Kind regards Melissa Williams Significant Projects Coordination Office of the Coordinator-General Department of Employment, Economic Development and Innovation Queensland Government


Tomorrow's Queensland: strong, green, smart, healthy and fair www.towardQ2.qld.gov.au

Please consider the environment before printing this email

From: David Finney [mailto:[email protected]] Sent: Friday, 23 December 2011 12:34 PM To: Williams, Melissa Cc: Norrie Sanders Subject: RE: Hancock response to RPS request for outstanding information

Hi Melissa



Regards

David Finney Environment Manager - NQ E [email protected]

15/0112013 RTI Document No. 39

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135 Abbott Street, Cairns, QLD, Australia, 4870

Wwww.rosaroup.com.au

PO Box 1949, Cairns, QLD, 4870 T +61 7 40311336 F +61 7 4031 2942

Page 2 of2

This message {including any attachments) is intended for the use of the person or entity named above and may contain information that is private, confidential or privileged. If you are not the intended recipient you are not authorised to disclose, distribute, copy or use of this message. If you have received this communication in error, please contact the writer immediately on p: +61 7 4031 1336. While RPS takes all reasonable precautions to ensure that its computer systems are free of viruses, it will not be liable for any loss, damage, liability, or claim arising out of or incidental to any damage to the computer system of a recipient of communications or documents originating from RPS and recipients receive communications from RPS at their own risk


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Alpha Coal Project

Review of Selected Aspects of the EIS Supplementary EIS, SEIS Addendum and other Proponent Responses: proposed conditions

Prepared by:

RPS AUSTRALIA EAST PTY LTD

7 43 Ann Street

PO Box 1559

FORTITUDE VALLEY QLD 4006

T: 617 3237 8899

F: 617 3237 8833

E: [email protected]

W: rpsgroup.com.au

Report Number: PR106805

Version I Date: Rev A I 0810612011

RPS Australia East Pty Ltd (ABN: 44 140 292 762)

Prepared for:

DEPARTMENT OF INFRASTRUCTURE AND PLANNING

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Important Note


Apart from fair dealing for the purposes of private study, research, criticism, or review as permitted under the

Copyright Act, no part of this report, its attachments or appendices may be reproduced by any process without the

written consent of RPS Australia East Pty Ltd. All enquiries should be directed to RPS Australia East Pty Ltd.

We have prepared this report for the sole purposes of Department of lnfrstructure and Planning ("Client") for the

specific purpose only for which it is supplied. This report is strictly limited to the purpose and the facts and matters

stated in it and does not apply directly or indirectly and will not be used for any other application, purpose, use or

matter.

In preparing this report we have made certain assumptions. We have assumed that all information and documents

provided to us by the Client or as a result of a specific request or enquiry were complete, accurate and up-to-date.

Where we have obtained information from a government register or database, we have assumed that the information

is accurate. Where an assumption has been made, we have not made any independent investigations with respect to

the matters the subject of that assumption. We are not aware of any reason why any of the assumptions are

incorrect.

This report is presented without the assumption of a duty of care to any other person (other than the Client) ("Third

Party"). The report may not contain sufficient information for the purposes of a Third Party or for other uses. Without

the prior written consent of RPS Australia East Pty Ltd:

This report may not be relied on by a Third Party; and RPS Australia East Pty Ltd will not be liable to a Third Party for

any loss, damage, liability or claim arising out of or incidental to a Third Party publishing, using or relying on the facts,

content, opinions or subject matter contained in this report.

If a Third Party uses or relies on the facts, content, opinions or subject matter contained in this report with or without

the consent of RPS Australia East Pty Ltd, RPS Australia East Pty Ltd disclaims all risk and the Third Party assumes

all risk and releases and indemnifies and agrees to keep indemnified RPS Australia East Pty Ltd from any loss,

damage, claim or liability arising directly or indirectly from the use of or reliance on this report.

In this note, a reference to loss and damage includes past and prospective economic loss, loss of profits, damage to

property, injury to any person (including death) costs and expenses incurred in taking measures to prevent, mitigate

or rectify any harm, loss of opportunity, legal costs, compensation, interest and any other direct, indirect,

consequential or financial or other loss.

Document Status

Version I Purpose of Document Review I Review Date QA RPS I

Orig Release I Issue Review Date

I Approval,

A Client milestone NS,SC,OF,

NS 30ct2011 NS NS 30ct2011 BO,GH,PO

8 Client milestone NS,SC,OF, NS 7 Nov 2011 NS NS 7 Nov 2011 BO,GH,PO

c Client milestone NS,SC,OF,

OF 23 dec2011 OF OF 23.12.11 BO,GH,PO

PR106805; Rev A I 08/06/2011 Page ii

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Contents


1.0 INTRODUCTION AND PURPOSE ........................................................................................... 4

2.0 SUMMARY ............................................................................................................................... 5

3.0 MINE ......................................................................................................................................... 7

3.1 WATER MANAGEMENT .......................................................................................................... 7

3.1.1 Water balance and surface water discharges ........................................................... 7

3.1.2 Groundwater Modelling ............................................................................................. 8

3.1.3 Groundwater Monitoring .......................................................................................... 10

3.1.4 Initial Project Water Supply ..................................................................................... 11

3.2 CREEK DIVERSIONS ............................................................................................................ 12

3.2.1 Evaluation ................................................................................................................ 12


3.3 WASTE ROCK CHARACTERIZATION AND MANAGEMENT .............................................. 16

3.3.1 Evaluation ................................................................................................................ 16


3.4 TAILINGS MANAGEMENT .................................................................................................... 17

3.4.1 Evaluation ................................................................................................................ 17


3.5 FINAL LANDFORM AND REHABILITATION ......................................................................... 20

3.5.1 Evaluation ................................................................................................................ 20


4.0 RAIL ....................................................................................................................................... 24

4.1 VEGETATION ........................................................................................................................ 24

4.1.1 Evaluation ................................................................................................................ 24


4.2 CREEK AND RIVER CROSSINGS ........................................................................................ 30

4.2.1 Evaluation ................................................................................................................ 30


PR106805; Rev A I 0810612011 Page iii

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-1.0 Introduction and Purpose


RPS was commissioned by The Department of Infrastructure and Planning (DIP) to advise on several

technical aspects of the Alpha Coal project. The objectives are to assess the adequacy of the

environmental impact assessment and to assist in establishing effective mitigation measures.

The technical scope is:

Mine: water, creek diversions, waste rock, tailings and rehabilitation

Railway: vegetation, waterway crossings and coal dust

By agreement, railway coal dust is no longer part of the scope because the issues are mitigation

measures are well established through environmental management conditions.

The document scope includes progressive reviews of the EIS, SEIS and EMPs, and input to approval

conditions and the Coordinator-General's report.

Our review of the Environmental Impact Statement (Issue 3, November 201 0) was submitted to DIP on 25

March 2011. The review noted that the EIS had a number of substantial gaps in basic data and analysis.

The second review included the Supplementary EIS (Issue 2 April 2011) and was submitted as a draft to

DIP on 24 June 2011. The review did not include groundwater because the proponent was still

assembling groundwater information.

The third and final review (this document) included the Supplementary EIS (Issue 4a, August 2011) and

the SEIS addendum report (Issue 1, November 2011). At DIP's request, this review focuses on

recommended conditions, rather than a detailed analysis of the project documents. The analysis has

been undertaken, but is presented only as a summary. The review is also the accumulation of our earlier

reports and therefore is a response to all of the relevant project documentation.

In addition it includes analysis and recommendations arising from a response received from Hancock

Coal (13 December 2011) to our various requests for additional information beyond the SEIS and SEIS

Addendum of 141h November.

Members of the review team also participated in meetings with the proponent's representatives and

government officers. A site inspection, including the test pit, lagoon creek and tailings dam site, was also

undertaken by two of the review team, in company with representatives of Hancock Coal and several

Queensland government officers.


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-2.0 Summary


Version 4 of the SEIS has added new information on some of the critical areas, notably stream diversions

and waste rock. The information has clarified several areas that can now be conditioned with more

confidence. Further information was recently provided through the SEIS Addendum dated November

2011, especially in relation to the TSF geotechnical and hydrogeological studies, and the railway flooding

studies.

Although the documentation is complete, consistent with our earlier advice, there is no issue within the

scope of our work that cannot be adequately conditioned and dealt with in more detailed design and

management planning. However, all areas continue to have gaps and errors in the information that is of

relevance to condition setting.

We note that some conditions have been drafted more conservatively (to reduce environmental risk) than

they may have been if all information had been supplied. The assessment of groundwater impacts both

during and post mining has not been completed to an adequate level of reliability, and should be resolved

before project operational approval.

The following is a brief summary of the status of each critical area for which we were commissioned:

• Water Management: water balance modeling has not been amended to include sensitivity

analysis and risk assessment, as previously requested by RPS. Consequently, conditions are

based on performance criteria and storage capacity. The bulk of conditions are expected to come

from DERM. Groundwater data are still being accumulated and analysed by the proponent. In

particular, potential impacts from the project have not been adequately assessed by groundwater

modeling, leading to significant uncertainty in the magnitude of regional impacts. Conditions

relating to groundwater are expected to be specified by DERM, but would need to also include

monitoring conditions to confirm conformance of the groundwater impacts to the predicted

impacts. Hancock Coal have advised in their response of 131" December that DERM is satisfied

with the groundwater model calibration however we would like to sight evidence of this

notification.

• Creek Diversions: data on the base case for stream power is not included, so erosion impacts

on the natural stream can only be inferred from other criteria. Conditions have been drafted

conservatively, based on established guidelines and information from the SEIS.

• Waste Rock: most issues are substantially clarified by the SEIS. Drafted Conditions focus on

content of the Waste Management Plan.

• Tailings: most attention in the review has been on the adequacy of the EMP as a reflection of the

proponent's commitments. There are shortcomings in the EMP, but all are able to be dealt with

through conditions. Lateral movement across the perching layer could lead to leachate migrating

outside the footprint of the TSF, where deeper hydraulic connection may exist. Although the

potential for leachate migration may be low, modelling is considered necessary, especially as the

out-of-pit TSF will remain in place in perpetuity.


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• Final Landform: Similar comments apply as per tailings. Conditions are provided that build on

established DERM approaches and previous comments by RPS.

• Railway vegetation: information is substantially complete in the SEIS. Established conditions

are proposed for vegetation clearing and rehabilitation. Proposed offsets are quantified in the

conditions.

• Railway Crossings: flood afflux and velocity targets have been subject to discussion and are

acknowledged within the wording of the SEIS. Conditions have been drafted to clarify the targets

and provide for a more certain outcome for landholders in the event of no agreement with the

proponent to relax the targets.


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3.0 Mine

3.1 Water management

3.1.1 Water balance and surface water discharges

JJ.Jj_ Evaluation


The mine water balance analysis concludes that in a 90 percentile wet year, no discharge of

contaminated water to lagoon creek will occur. The water modelling used a number of assumptions that

were questioned in our previous report, notably:

• The 20% settling zone may not be sufficient

• Sediment dam capacities should exceed 10% AEP 24 hour storm volume

• Demand for dust suppression is assumed to continue in all weathers - in wet conditions, actual

demand is likely to be lower and will increase pond volumes

Sensitivity of the model outputs to these factors is unknown on the basis of the results presented, but all

could increase the risk of overflow to the creek. A more important omission is the lack of analysis of

discharge risks under different event scenarios. The 90%ile wet year modeled as worst case corresponds

to an annual rainfall of less than 800mm. Annual rainfall of up to 1400mm have been recorded. Similarly,

short term rainfall intensities may result in discharge in some circumstances.

3. I. 1.2 Proposed Conditions

(Note: we have assumed that DERM will provide conditions for Pit dewatering, emergency releases from

ponds and detailed content of Water Management Plan. The following conditions are limited to containing

contaminant discharge):

No discharge of contaminated water is to occur under normal operating conditions.

Size Environmental dams to contain a 10% AEP 24 hour storm volume or 20 year ARI 3 month critical

wet period, whichever is the greater.

Increase sediment pond capacities by1 0%.

Maintain sediment level in ponds to less than 20% of operating volume.


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3.1.2 Groundwater Modelling

3.1.2.1 Evaluation

Groundwater Modelling


Only preliminary groundwater modeling has been undertaken to date. A numerical regional groundwater

model is under development, using the finite element software FEFLOW, but modeling to date has not

adequately assessed the potential regional impacts from the project.

The regional model has been used for preliminary assessment of mining impacts and post-mining

recovery of groundwater levels, but the modeling has been compromised by a number of simplifying

assumptions. This significantly reduces the reliability of the predicted impacts and recovery.

Modeling of the mining phase was reported in Appendix N (SEIS Version 4, August 2011 ), but it involved

a number of simplifying assumptions that limit the reliability of the predictions (e.g. including no recharge,

uniform pre-mining groundwater levels across the model area, constant heads at the model boundaries,

unchanged hydraulic properties throughout the mining phase). Post-mining simulation of the

development of pit void lakes was also undertaken (SEIS Version 2, April 2011), but this was before the

mining impacts had been predicted, so it was based on unreliable assumed starting, and involved the

same other limitations as for the mining phase modeling.

Because of the above limitations with the groundwater modeling, it is difficult to have confidence in the

model-generated impact predictions obtained to date. More advanced modeling is required.

Recharge

Recharge to the Colin lea Sandstone and the coal measures sequence has been assessed as most likely

derived from diffuse recharge in the elevated areas along the Great Dividing Range to the south-west of

the project. This may be incompatible with the proponent's conclusion of minimal impact by the project

on the GAB aquifers. Recharge from the south-west of the mine would imply that it is derived either from

discharge from the GAB strata, or vertical infiltration from the surface through the GAB beds and the

basal Rewan Formation into the underlying Colin lea Sandstone. In either case, the potential for impact

on the GAB exists. The source and mechanism of recharge needs to be resolved in order to eliminate

this potential inconsistency.

Some attempt has been made to assess the potential impact of the project on the GAB, through

sensitivity modeling. However, without proper representation of recharge, this is of limited reliability.

Out of Pit Tailings Storage Facility

The hydrogeological and geotechnical investigations of the TSF site have indicated that the TSF location

is unlikely to be the primary recharge area for the Colin lea Sandstone. Nevertheless, any TSF located in

that area would need to incorporate careful investigation of the TSF floor area to eliminate potential

secondary recharge pathways (e.g. structural features), and to ensure low permeability of the TSF floor.

The Hancock response of 13th December 2011 states "Groundwater data and modelling indicates that

there is no hydraulic connection between the perched groundwater table and the piezometric levels

associated with the underlying confined layers. Thus modelling to include out-of-pit TSF is not

required." It cannot be concluded from the present status of groundwater beneath the TSF area that

lack of hydraulic connection will prevail once there is a continuous source of leachate available, as a


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mound may develop that allows deeper hydraulic connection (ie through the perching layer) to the deeper

groundwater. After all the perched nature of the shallow groundwater is a function of the availability of

water (from rainfall infiltration) and the vertical permeability of the perching layer. Lateral movement

across the perching layer could lead to leachate migrating outside the footprint of the TSF, where deeper

hydraulic connection may exist. Although the potential for leachate migration may be low, modelling is

considered necessary, especially as the out-of-pit TSF will remain in place in perpetuity.


Monitoring of dewatering of the Alpha Test Pit (ATP) indicted that only limited water inflow rates are likely

from the overburden and the coal measures above the D seam, and that the major water inflows are likely

to be derived from the D-E sandstone underlying the D seam, and deeper units. With mining proposed

down to and including the D seam, it will be necessary to depressurize the underlying strata (at least the

D-E sandstone) and to dewater the strata above. A combination of pumping from external dewatering

bores and in-pit sumps is likely to be required.

The report on the monitoring of dewatering of the ATP suggested that post-mining recharge will be

limited, but this has not yet been evaluated by the regional groundwater model.


It is assumed that conditions will generally be set by DERM, as detailed in their Submission 11 (DERM,

October 2011 ), but the following additional conditions are recommended.

Modelling

A condition should be imposed requiring the groundwater model to be modified to allow more advanced

modeling to be undertaken prior to project approval. The modifications should at least include proper

representation of both recharge and natural discharge, appropriate model boundary conditions, variable

hydraulic properties through the simulations to allow the change in material properties from coal and

overburden to void space and then to waste rock backfill as open cut mining proceeds to be represented,

proper assignment of starting heads, and sequential modeling from pre-mining to mining to post-mining.

As the model needs to incorporate the combined effects of both the Alpha open cut project and the

adjacent Kevin's Corner open cut and underground mining project, it will be necessary to ensure that the

model is able to represent underground mining, including both saturated and unsaturated or pseudo

unsaturated flow, and parameter changes during simulations to represent the progressive effects of

subsidence on overburden layers.

A further condition should be imposed requiring periodic post-audits of the groundwater model, and re

calibration and re-prediction of future impacts during the mining phase of the project. These should be

undertaken initially at a minimum of 3-yearly intervals, and eventually at 5-yearly intervals throughout the

mining phase of the project.

Recharge


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A condition should be imposed that further investigations be undertaken to verify the source(s) and

mechanism(s) of recharge prior to project approval, as this may have a bearing on the potential for the

project to impact on the GAB.

Out-of-Pit Tailings Storage Facility

It may be necessary to require lining or sealing of at least parts of the floor of the TSF, as requested by

DERM. It should be a condition that prior to construction, a thorough investigation of the floor of each

proposed TSF cell be undertaken to identify and eliminate any potential zones of enhanced vertical

permeability that may provide preferred pathways (such as geological structures, soil features, etc) for

seepage to the underlying Colin lea Sandstone and/or down-gradient areas.

Although the potential for leachate migration may be low, modelling is considered necessary, especially

as the out-of-pit TSF will remain in place in perpetuity.


The effectiveness of external bores should be further evaluated as a means of depressurizing the less

permeable overburden and coal measures above the D seam, prior to commencement of mining.

Post-mining recharge should be appropriately evaluated with the regional groundwater model prior to

project approval.

3.1.3 Groundwater Monitoring

3.1.3.1 Evaluation

A network of monitoring bores has been installed within and around both the open cut and the out-of-pit

TSF areas. A baseline monitoring program involving both water quality and groundwater levels has been

commenced, and is described in the EIS and SEIS documents.


It is expected that conditions would be primarily determined by DERM.

The DERM document (Submission 11, dated October 2011) specifies groundwater conditions that focus

mainly on water quality monitoring. The DERM conditions include the requirement to undertake a

minimum 12-month baseline monitoring program to determine per-mining groundwater conditions. A

further DERM condition requires that the proponent develop appropriate trigger values for a range of

water quality parameters.

However, other conditions should include, subject to development (prior to commencement of mining) of

a satisfactory numerical model, calibration and reliable prediction of impacts both during and after mining:


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• Groundwater level monitoring at representative monitoring bores, at frequencies determined on

the basis of the results of baseline monitoring and trigger values (monthly/quarterly/continuous);


• Periodic comparison of water level changes with model-predicted water level changes, to verify

the reliability of model predictions;

• Annual reporting of the results of monitoring and comparison of observed impacts with predicted

impacts, to be made available to the government agencies and the public.

3.1.4 Initial Project Water Supply

3.1.4.1 Evaluation

The proponent has proposed using groundwater from either dewatering or from other water supply bores

in the early stages of mining prior to the completion of the external water supply pipeline. No assessment

of groundwater availability for the project water supply has been undertaken to date.

3.1.4.2 Conditions

It should be a condition of approval that a thorough investigation to demonstrate availability of sufficient

groundwater to meet the project's initial water supply needs be undertaken prior to commencement of

mining.


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3.2 Creel< diversions

3.2.1 Evaluation


[Note: a revised version of Appendix J (Stream morphology technical report) was received on 29

September 2011, in response to a number of identified errors and omissions. The evaluation below is

largely based on the SEIS version 4 of Appendix J, but where issues have been clarified by the revision,

this has been taken into account. Remaining errors and omissions have been identified below and

conditions have been derived conseNatively, wherever the data are inadequate or conflicting, to address

the higher environmental risk.]

Appendix J (Stream morphology technical report) demonstrates that the creek diversions are generally

within ACARP guidelines for 2 Year ARI. The exception is the 9.6km Lagoon Creek diversion, in which

maximum Shear Stress exceeds the relevant guideline by 50%. However, the remaining 15km of

undiverted reaches of Lagoon Creek, within the MLA boundary appear to be significantly affected by the

diversions, with spot velocities increasing at one site in the upper reach from 0.8mls to 1.4m/s and in the

lower reach from 0.25m/s to 1.4m/s. These figures are at the upper limit of ACARP guidelines for

vegetated streams and above the limit for unvegetated streams. More importantly, they represent a

substantial increase in velocities in a natural channel which has mobile bed sediments and sparsely

vegetated, unstable banks in many areas.

At 50 year ARI, spot velocities show substantial increases over current within the diversion and

downstream, with an increase from 2 to 2.5m/s at one point downstream. Sheer stress predictions

generally are in line with current conditions, with one spike in the Lagoon Creek diversion. Stream power

data for the base case are not presented, but a number of spikes occur downstream of the Spring Creek

confluence, with one maximum at 400W/m2 and two maxima around 200W/m2. In a review of the

MacArthur river diversions, Wayne Erskine noted that channels erode at high powers (>25-1 OOW/m2) and

that "no alluvial channel or bedrock can withstand a specific stream power of greater than 200Wim2"

(Recommended Improvements in Design of McArthur River Diversion Channels, 2006). The DERM limit

of 220W/m2, is above threshold for this type of stream and should only be applied to the diverted reach,

which can be stabilized as part of design/construction.

There is some doubt about the reliability of the stream power graphs in the report (see below), but these

spikes indicate high to very high risk zones in parts of the undiverted reaches. Whether this can be

satisfactorily mitigated by bank armouring is not possible to judge from the SEIS. This is complicated by

the fact that some of the affected reaches are downstream of the MLA boundary.

It should be noted that the critical limits for these hydraulic parameters are a function of channel

morphology, soils, vegetation and flow duration. In the undiverted reaches, Appendix J describes all of

these except flow duration. The longer the flow duration, the lower the critical value of the parameter and

hence the higher the risk of erosion.

There are a number of obvious errors in the report that have affected the interpretation of the data

presented in the SEIS, some of which have been picked up in the revised version. The most critical are:


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• Many of the values in Table 6.6 do not match the graphs in Appendix B (corrected in revised

version)

• Figures B-9 and B-27 are identical, despite being different creeks and different lengths

(corrected)

• Lagoon creek stream power graphs (B-8 and B-9) show only developed case and are only 9.2km

(less than the diversion length) whereas other graphs (B-4 to B-7) show over 40km (partially

corrected).

• The stream power scale in Figure B-8 appears to be two orders of magnitude low, based on

calculated stream power using velocity and shear stress, and comparison with the previous

SEIS.

• The stream power values shown in Figure B-9 appear truncated downstream of the Lagoon

Creek diversion and should be substantially higher if the corresponding shear stress and velocity

charts are correct.

Recommendations:

• Approve the proposed diversions subject to conditions to reduce the risks of serious erosion


Preconstruction

Submit final designs for approval that:

• Are generally in accordance with the diversion plan forms depicted in Appendix J

• Provide a detailed baseline geomorphic assessment of undiverted creek reaches that are

predicted to be affected by changed hydraulic conditions (Appendix J)- at a minimum, within the

MLA and up to 5km downstream. The assessment is to provide quantitative benchmarks of

current condition (e.g. bank structure, vegetation, instream sediment, channel location and

dimensions) as a comparison to potential future changes.

• Provide a detailed evaluation of soil conditions along the diversion routes and propose designs to

minimize erosion potential for areas with erodible and/or dispersive soils;

• Demonstrate compliance with hydraulic criteria (Table 3.2);

• Propose design solutions to ensure channel stability for any locations where one or more

hydraulic criteria are exceeded;

• Provide for equivalent aquatic habitat diversity based on the range of habitats being removed as

a result of the diversion;


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• Specify riparian and floodplain vegetation planting to re-establish natural densities and species

diversity;

• Specify methods to maximize vegetation establishment rates (e.g. temporary irrigation, soil

amendment) and maintain viable plants;

• Include contingency plans for temporary stabilization during vegetation establishment period e.g.

grassing, anionic polyacrylamide application.

Table 3.2: Criteria for hydraulic design

. - . , Criterion-.·-. : .. Diverted reaches - Natural reaches- Notes .. . . - ! · . ' maxi~um value' maximum increase2 . . -.

2 yr ARI Stream Power (W/m2) 60 7% SEIS does not present

(up to 60W/m2)

graphs of stream power

for natural reaches.

A CARP guideline is

used as default.

50 yr ARI Stream Power (W/m2) 220 3% As above; A CARP

(up to 150W/m2)

criterion is too high for

the natural reaches of

the creek.

2 yr ARI Velocity (m/s) 1.5 50%

(up to 1.5m/s)

50 yr ARI Velocity (m/s) 2.5 10% Maximum velocity in

(up to 2.0m/s) natural reach based on

Appendix J, Figure B-5

2 yr ARI Shear Stress (N/m2) 40 50%

(up to 40N/m2)

50 yr ARI Shear Stress (N/m2) 80 10% Maximum shear stress

(up to 120N/m2)

in natural reach based

on Appendix J, Figure B-

7.

Notes:

1. DERM/ACARP criteria

2. The lower of the two figures is applicable. Percentages are relative to a discrete point or uniform reach; allowable limits

for velocity and sheer stress derived from SEIS Appendix J, Figures B-4 to B-7. Absolute limit is shown in parentheses

and is based on ACARP guidelines and Appendix J, Figures 8-4 to B-7.


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Construction


Include in the erosion and sediment control plan specific measures to minimise erosion risk during

diversion construction. In particular, effective measures to control erosion risk from dispersive soils

exposed during construction must be included.

Identify and implement contingency measures to minimize the risk of major erosion damage in the event

of a high flows occurring during the construction period.

Post construction stabilization and revegetation

Test bed and bank materials from the constructed channels for erodibility (ESP, pH, EC, Emerson

dispersion) and modify the channel stabilization measures accordingly. In particular, treat areas of

dispersive soils to minimize dispersion - e.g. addition of gypsum and topsoiling (minimum 0.5m),

meshing, seeding;

Undertake revegetation and other channel stabilization works as per the approved design. Undertake

progressive stabilization and planting within one week of bulk earthworks.

Provide contingency measures for high risk events such as floods and high intensity rainfall to prevent

high rates of sediment mobilization during plant establishment phase (10 year minimum).

Rehabilitate areas affected by post construction erosion and/or deposition (e.g. following floods, overbank

flow or dispersion).

Monitoring

Monitoring sites are to be established at critical areas within diversions, within natural channels within the

site and in affected reaches downstream of the MLA. Reference (control) sites are to be established

Monitoring is to be undertaken quarterly and after flood events (1 year ARI and above)

Monitoring is to include:

• Plant health and mortality

• Bank erosion, slumping and loss of topsoil;

• Soil dispersion in channel;

• Sediment deposition in channels

• Change in channellocation/planform (may require aerial photography at 1 year intervals)


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3.3 Waste Rock Characterization and Management

3.3.1 Evaluation


The additional waste rock characterization work discussed in Volume 2 Appendix S - Coal Mine Interim

Geochemical Report has substantially clarified many issues arising out of the EIS. Notwithstanding that

some geochemical testing remains in progress (e.g. Tailings and C Seam waste kinetic testing) proposed

management of waste rock and tailings materials have been adequately identified in commitments

proposed in Section 3.6.12.


E4 Waste Management

E 9 Authorised spoil disposal facility(s) must be constructed and maintained in accordance with certified

design plans submitted to the administering authority which are to be reviewed and revised as necessary

in accordance with findings of the MWMP and ongoing waste characterization. work, including short term

coarse reject PAF neutralization.

E 13 Mining Waste Management

Refer to comments and details under Section 3.4.2.


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3.4 Tailings Management

3.4.1 Evaluation


Evaluation of Tailings Management is connected with Final Landform and Rehabilitation (section 3.5) and

to a lesser extent with Waste Rock Characterization (3.3) and Water (3.1 ).

SEIS EMP (Vol V) is an important planning document as it summarises contextual planning data that

supports proposed conditions. In its current form, it is comprehensive and either partially confuses

connections between sections or does not reference them clearly. Lack of clarity and referencing detracts

from its value in mine development. Improvements to EMP material are proposed below in this section

and to proposed Conditions in 3.4.2.

Proposed EMP changes are:

• A document structure edit that:

o formats and numbers sub-sections that can then be referenced easily later, e.g. V3.6.6.1

has many sub-sections, and

o shows a flow diagram of plans and how they fit together, e.g. MWMP, Spoil Management

Plan, PCMP, RMP

• A technical content edit that:

o connects mine waste elements correctly. For example, E6-12, termed 'Spoil' applies to

Tailings Storage Facility (TSF) whereas MWMP seems to have a broader definition that

is all mining wastes including TSF, rejects and overburden;

o includes all Commitments from Volume 0 (many Commitments are missing from 01.16.2

and 01.25 in V3.6.12 and V3.7.9, respectively;

o avoids repetition, e.g. Conditions E13 and F12 are the same; and,

o has conditions in the correct section, e.g. F14 & F15 should be in E

• greater emphasis on landform stability throughout V3.6.6- 3.6.13, as requested in RPS report

and in Overburden meeting 18/5/11

• link V3.7.4/5 Environmental Protection Objectives and Performance Criteria to OERM's Financial

Assurance and Rehabilitation requirements and to water quality outcomes

• Table V-62 Rehabilitation Success Criteria offers potentially useful key criteria for indicators that

need to:

o be better referenced, e.g. Landform stability to Slope conditions (Table F1 & F2), to IECA

Erosion & Sediment Control Guidelines 2008 and soil loss factors for different slope

configurations

PR106805; Rev 8 Page 17

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o support EMP quantitative data, e.g. topsoil depths to V3.7.6.1; and,

o provide more practical guidance, e.g. 'Use contour banks and diversion drains either to

direct water down slopes into sediment control basins and/or into dump revegetation

schemes as per schematic X'

The implications on Financial Assurance should be explained for success/failure of tailings, rehabilitation,

re-mining rehabilitated areas in support of Table V-63 Rehabilitation Monitoring Program.

New and revised conditions have been proposed.

The new condition (E17) is to accommodate potential transitions between two discrete alternatives of out

and in-pit tailings storage and different sizes that require risk assessment and impact mitigation to suit.

The revised condition (E13) revises an increasingly standard condition that covers all mining wastes,

focuses on PAF and does not link clearly to other standard conditions. It has been revised to:

• link to a broader Rehabilitation Management Plan

• complement spoil management planning, post closure management planning; rehabilitation success criteria, rehabilitation monitoring and standard mine planning;

• characterise reactive and unreactive materials to suit landform, polluting and revegetation

parameters;

• follow a standard mine design, construction and maintenance program; and,

• build on the MWMP for the bulk sample pit.

The revised condition (W34) is added to ensure that monitoring is specifically required to identify the

potential for saline seepage from the TSF to impact on Lagoon Creek .

SEIS Addendum Appendix C TSF Hydrogeology Assessment and Appendix D TSF Geotechnical

Assessment do not change conditions G1-19 in SEIS V3.4.1 0.2. They provide more confidence about the

out-of-pit TSF and guide the design report and construction of the regulated structure required by

Conditions.


This section addresses changes to proposed conditions in V.3.6.13, Schedule E Waste and Mining Waste

Management:

1. Add Condition:

E17 Prior to construction of any mineral waste storage facility, undertake a risk assessment, in

accordance with generally accepted standards to determine if."

a) the mineral waste is a hazardous waste or has acid producing potential;


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b) the mined pit is a hazardous dam.


Two discrete alternatives of out and in-pit tailings storage and different sizes to accommodate potential

transitions require risk assessment and impact mitigation to suit.

2. Revise condition E13 to read:

E13 A Mining Waste Management Plan together with certification by an appropriately qualified person

must be developed and implemented during the continuation of the environmental authority. The Mining

Waste Management Plan must be part of a Rehabilitation Management Plan and at a minimum include:

a) Characterisation programs to ensure that all mining waste is progressively characterised during

disposal for net acid producing potential, salinity and the following contaminants: Iron (Fe),

Aluminium (AI}, Copper (Cu), Magnesium (Mg), Manganese (Mn}, Calcium (Ca), Sodium (Na)

and Sulphate (S04);

b) Characterisation programs to ensure that physical properties of the mmmg waste are

progressively characterised during disposal and suitable for landform designs that include the

following parameters: soil dispersibility and robustness, rock armour, topsoil suitability;

c) Availability or leachability of metals and other pollutants (e.g. soluble salts) from the mining

waste;

d) Quantities and distribution of acid forming (PAF}, erodible and robust mining waste and topsoil;

e) Assessment of potential risks and opportunities of PAF, erodible and robust mining waste on the

success of proposed rehabilitation methods;

f) Design and management plans for selective placement and capping of materials to suit

rehabilitation success criteria

g) Construction and maintenance methodologies to suit designs;

h) Contingency plans and emergency procedures for non-routine situations;

i) Periodic performance review program for designs, construction and maintenance;

j) Monitoring as per Rehabilitation Monitoring program; and,

k) Continual improvement mechanisms

3. Revise Condition W34 to read:

W34 The holder of this Environmental Authority must ensure proper and effective measures are taken to

avoid or otherwise minimize the generation and or release of saline drainages; this shall include the

installation of a network of bores (with pump back capability) between the TSF and Lagoon Creek to

monitor for the potential migration of saline seepage to Lagoon Creek.


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3.5 Final landform and rehabilitation

3.5.1 Evaluation


The introductory comments made in 3.4.1 about the EMP structure and changes apply more to this the

Final landform and rehabilitation section. The structure of Volume V and its cross-referencing to SEIS I

EIS was less clear.

In summary, it is proposed that conditions in V3.7.10, Schedule F Land be deleted, relocated, added and

changed as identified below.

Delete conditions: F12, F13, F14, F15, as they are repeated in Schedule E.

Move conditions: F16 & F17 that would suit Schedule E better

Two additional conditions are proposed:

1. New F12 and Table F1 & F2 are standard conditions. Table V-62 Rehabilitation Success criteria

cover more than these data, but not clearly (as stated in the comments on the EMP structure).

For example, in Table F1: defining land suitability Class is necessary, and in Table F2,

distinguishing slope ranges for voids, ramps and different dumps would be useful. Data needs to

be provided by the Proponent and be compatible for land use, suitability and designs proposed in

the EIS.

2. New F13 is required due to a lack of clarity and quantifiable data in Table V-62 Rehabilitation

Success Criteria, Condition F1 and in the section V3.7 Land Management (refer comments in

3.4.1).

Revise five conditions:

1. F2 adds stockpiling and respread of topsoil to the existing condition that requires the Topsoil

Management Plan only to address topsoil stripping.

2. F4 adds reference to conformance to success criteria which is the outcome sought by the title of

the condition.

3. F9 adds to the Rehabilitation Monitoring Program implications for financial assurance of

rehabilitation success or failure as they are linked.

4. F1 0 reverts to a standard condition. It raises the timeframe to 30 years, from 20 years, and offers

a shorter period if rehabilitation competence is proven.

5. F11 adds safety and structural integrity to the monitoring regime to align with the Rehabilitation

guideline and adds a section on decommissioning.


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Additional and changed conditions are defined below.

1. Additional conditions:


New F12 All areas significantly disturbed by mining activities must be rehabilitated to a stable landform

with a self-sustaining vegetation cover in accordance with Table F1 and Table F2 (complete in

negotiations between Proponent and Regulator).

Table F1: Final/and use and rehabilitation approval schedule

Disturbance type Post-mining land use Post-mining land Post-mining land

suitability class for dry suitability class for beef

land cropping cattle grazing

xxxx )()()()( )()()()( )()()()(

e.g. Infrastructure e.g. Grazing e.g. Nla e.g. Class IV

)()()()( )()()()( xxxx xxxx

Table F2: landform design criteria for Alpha coal mine

Disturbance type Slope Range (%)

)()()()( )()()()(,

e.g. Overburden emplacement elg. 0-9%

)()()()( xxxx

New F13: Complete an investigation into the planned rehabilitation of disturbed areas and submit a report

to the administering authority proposing acceptance criteria to meet the outcomes in condition F1 and

Table F1 and Table F2 within 12 months ofthe issue of the Environmental Authority.

2. Revised conditions

F2 Topsoil: Topsoil must be strategically stripped ahead of mining, stockpiled and spread for rehabilitation

in accordance with a topsoil management plan.


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F4 Rehabilitation landform criteria: Progressive rehabilitation must commence within two (2) years of

when areas become available within the operational/and and conform to success criteria.

F9 The Rehabilitation Monitoring Program must be included in the Plan of Operations and updated with

each subsequent Plan of Operations, describing:

a) How the rehabilitation objectives will be achieved,

b) Verification of rehabilitation success

c) Implications for financial assurance

Implications of monitoring on financial assurance is added.

F10 Post closure management plan: A Post Closure Management Plan for the site must be prepared at

least 18 months prior to the final coal processing on site and implemented for a nominal period of:

1. at least thirty (30) years following final coal processing on site, or

2. a shorter period if the site is proven to be geotechnically and geochemically stable and it can be

demonstrated to the satisfaction of the administering authority that the site has been

decommissioned and rehabilitated such that it will not cause environmental harm for the

foreseeable future.

F11 The Post Closure Management Plan should include the following elements:

a) operation and maintenance of.·

1 wastewater and reticulation systems

2 waste water treatment systems

3 the groundwater monitoring network

4 final cover systems, and

5 vegetative cover

b) monitoring of.·

1 surface water quality

2 groundwater quality

3 seepage rates

4 erosion rates

5 the integrity and effectiveness of final cover systems


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6 the health and resilience of native vegetation cover

7 safety

8 structural integrity

c) decommissioning of:

1. infrastructure and buildings;

2. site preparation and services;

3. contaminated land assessment

4. hardstand and roads

5. dam and surface water drainage and features.

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4.0 Rail

4.1 Vegetation

4.1.1 Evaluation


Where clearing of remnant vegetation for the railway line affects a portion of an intact area of remnant

vegetation, the uncleared remnant vegetation is to be of sufficient size and configuration to ensure that

the remaining vegetation results in a functioning ecosystem. The clearing should be located so that

connectivity is maintained between the affected patch of remnant vegetation and adjacent patches.

Clearing of remnant vegetation should not take place where the width of remnant vegetation is less than

200 metres.

Clearing of remnant vegetation for the railway line and associated with any watercourse crossings should

be undertaken in accordance with 'Guideline - activities in a watercourse, lake or spring associated with

mining operations' (version 1, 15 April 2008).


Vegetation Management

The holder of this authority must:

1. prevent or minimise disturbance to vegetation; and

2. manage the effects of clearing to prevent the loss of biodiversity, reduction of ecological

processes and land degradation.

The holder of this authority must ensure that any clearing complies with the following:

1. the clearing does exceed the proposed clearing areas identified in Table 4.1. A detailed

assessment of clearing of wetland vegetation, particularly within the Caley Valley Wetlands,

is completed;

2. all reasonable and practical measures are made to minimise the area cleared and to avoid

the clearing of mature trees;

3. access tracks are not located in Endangered Regional Ecosystems;

4. clearing of mature and hollow bearing trees are avoided where practicable; and

5. a qualified ecologist is present during clearing activities to ensure impacts on flora and fauna

are minimised.


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Table 4 1· Disturbance Limits .. Environmental Category

Endangered RE

Of Concern RE

Threshold RE

Essential Habitat

Waterway vegetation

Wetland vegetation

Corridor vegetation

Fish habitat

High value regrowth

Threatened Ecological Community

Disturbance Limit (ha)

111.43

104.16

11.01

14.08

72.34

To be determined

395.91

0.43

62

87.35


The holder of this authority must ensure that camps and lay down areas are located at least 20m from

remnant regional ecosystems or high value regrowth regional ecosystems.

The proponent is required to ensure that all clearing in relation to the services corridor must meet the

Regional Vegetation Management Code for Brigalow Belt and New England Tablelands Bioregions

(Version 2); and as such, the proponent will need to provide a vegetation offset as per the Queensland

Government Policy for Vegetation Management Offsets current at the time the clearing is required. The

offsets identified must be legally secured as outlined under Criteria 4: Policy for Vegetation Management

Offsets (Version 2.4) prior to the area required for the development being cleared.

Where possible, the clearing of native vegetation within road reserves or watercourses must not reduce

the width of the vegetation community to less than 50m.

Fallen timber must be moved as little as possible and replaced once construction has been completed.

Trees that are required to be felled must be retained on site and subsequently moved into adjoining

habitats and left as ground habitat, unless otherwise required by the land holder.

The proponent must submit a threatened flora and fauna species and ecological communities'

management plan for approval by the Department of Environment and Resource Management prior to the

commencement of any works that:

(a) ensures the impacts to these species and communities are minimized;

(b) contributes to the survival of these species and communities in the wild; and

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(c) achieves conservation benefits for these species and communities where practicable.

As a minimum, the threatened flora and fauna species and ecological communities' management plan

should include:

(a) a list of species listed as endangered, vulnerable or rare under the Nature Conservation Act 1994 that

may be impacted;

(b) a map that identifies GPS positions for known locations of significant species as listed under the

Nature Conservation Act 1994 in the clearing footprint and its surrounds;

(c) affected species listed by the Department of Environment and Resource Management on its 'Back on

Track' systems that are identified as in decline and have a good potential for recovery;

(d) the additional and ongoing management activities to mitigate impacts to native vegetation

communities;

(e) how the proponent will satisfy the requirements of Section 322 of the Nature Conservation (Wildlife

Management) Regulation 2006 relating to tampering with animal breeding places;

(f) management of affected fauna during construction and operational phases;

(g) a commitment to provide information on flora and fauna management actions for significant species

for inclusion in the Department of Environment and Resource Management's 'Recovery Actions

Database' when that framework is finalized and becomes operational; and

(h) a commitment to submit a clearing permit for approval by the Department of Environment and

Resource Management should an endangered, vulnerable or near threatened plant listed under the

Nature Conservation Act 1994 be identified in the clearing footprint.

Rehabilitation Requirements

Progressive rehabilitation of temporary disturbances (including camps, lay down areas, stockpiles and

construction access tracks) must commence as soon as practicable following decommissioning.

All land significantly disturbed by construction of the rail must be rehabilitated to:

2. a stable landform with a self-sustaining vegetation cover with similar species and

density of cover to that of the surrounding undisturbed areas, except over the area

that must be maintained free of large flora species for rail operation and access;

3. ensure that all temporarily disturbed land is reinstated to the pre-disturbed land use

and suitability class;

4. ensure that the maintenance requirements for rehabilitated land is no greater than

that required for the land prior to its disturbance.

For areas of native vegetation, revegetation must use seed sourced from local provenance native

species.


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For any planned rehabilitation outcome that cannot fulfill these rehabilitation requirements, approval must

be sought from the administering authority, prior to the rehabilitation being carried out.

Maintenance of rehabilitated areas must take place to ensure and demonstrate:

1. stability of landforms;

2. erosion control measures remain effective;

3. stormwater runoff from rehabilitated areas does not negatively affect the environmental values of

any waters;

4. plants show healthy growth and recruitment is occurring; and

5. declared pest plants are controlled on rehabilitated areas to a level consistent with the

surrounding property and prevented from spreading to unaffected areas.

Rehabilitation can be considered successful when the site can be managed for its designated land-use

(either similar to that of surrounding undisturbed areas or as otherwise agreed in a written document with

the landowner/holder and administering authority) without any greater management input than for other

land in the area being used for a similar purpose and there is evidence that the rehabilitation has been

successful for at least 3 years.

Pest and Weed Management

The holder of this authority must develop and implement a pest and weed control program that includes

but is not limited to the following:

1. identification of areas requiring pest and weed control;

2. control measures to prevent the spread of pest and weed species; and

3. measures to eliminate infestations of noxious pest and weed species that may occur.

Biodiversity Offsets

A Biodiversity Offsets Management Plan must be prepared to comply with the following offsets policies:

1. Policy for Vegetation Management Offsets, Version 2.4 (DERM, 2009); and

2. Biodiversity Offsets Policy (DERM, 2011 ).

3. The area of wetland vegetation to be disturbed has not determined and therefore the Offset

Strategy does not supply a total estimate of offset requirements at the time of this report.

A minimum offset ratio of 1:3 (clearing: offset) is required for the clearing of vegetation associated with

the environmental areas identified in Table 4.2.

Table 4.2: Proposed Clearing Area and Minimum Offset Requirements


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Environmental Area Proposed Clearing Area (ha)

Endangered REs 111.43

Of Concern REs 104.16

Threshold REs 11.01

Essential Habitat 14.08

Waterway vegetation 72.34

Wetland vegetation To be determined

Corridor vegetation 395.91

Fish habitat 0.43

High value regrowth 62

Threatened Ecological 87.35 Communities


Minimum Offset (ha)

334.29

312.48

33.03

42.24

217.02

To be determined

1 '187.73

1.29

186

262.05

Threatened flora species are also to be offset at a minimum 1:3 ratio for each individual cleared for the

project. The determination of the suitability of offsets will need to address the following involve

considerations:

• tenure and land use constraints;

• distance from clearing area;

• landscape connectivity;

• patch size;

• condition;

• remnant status;

• existing level of protection;

• habitat for threatened taxa .

The Biodiversity Offsets management Plan must address the Policy for Vegetation Management Offsets

and include the following:

• Identification of suitable offset sites;

• BioCondition assessments of clearing and offsets areas to determine ecological equivalence;


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• Rehabilitation measures and targets to achieve offset objectives;

• Measures to address threatening processes;

• Pest and weed management;

• Live-stock management and fencing requirements;

• Fire management;

• Contingencies for failed revegetation and regeneration;

• Legal protections measures to secure biodiversity offsets;

• Monitoring and maintenance plan;

• Roles and responsibilities

• Reporting requirements.

PR106805; Rev B


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4.2 Creel< and River Crossings

4.2.1 Evaluation


The revised crossing designs in the SEIS and the SEIS addendum have addressed a number of issues in

relation to mitigating the barrier effect of the railway on passage of floodwaters across the landscape.

The proposed maximum afflux of 1.5m and outflow velocity of 5m/s in the original EIS (Appendix Y, table

3.2) were considered to be too high and following negotiations with Hancock, section 3.2.1 has been

amended to provide for a maximum afflux target of 0.5m. In locations where greater than 0.5m can be

"tolerated", the proponent's proposal is for a design report and landholder consultation. It is unclear

whether a condition based on these maxima would be achieved if the landholder disagreed. A maximum

outlet velocity target from culverts of 3m/s was proposed "where possible", with "stakeholder input".

The wording in section 3.2.1 of the SEIS implies that if the design change to achieve these lower targets

is not practical, then the design should still be acceptable. This situation would lead to considerable

uncertainty about the outcomes for the landholders in the event of a disagreement or more importantly, in

the event that the outcomes may cause adverse impact to rural productivity, safety or assets. Velocities

as high as 5m/s would also have a high erosive potential and could threaten creek stability and ecology.

The analysis has indicated that some of the floodplains have complex flow patterns and the low relief can

result in floods in some locations under some circumstances moving in the reverse direction from the

normal flow (i.e. there can be downstream to upstream) movement. This means that at these locations,

flood afflux can occur in the normal "downstream" direction. The crossings are designed with an assumed

flow from upstream to downstream, so once the flood modeling is completed, there is a case for revising

those designs which have exhibit this unusual behaviour.

More detailed flood modelling of the floodplain areas crossed by the proposed rail alignment has been

completed, and the results are described in the addendum report to the SEIS. The drainage design

criteria proposed and used by the consultants in their floodplain modelling are included in the addendum

reports and have been reproduced here as Table 4.1 below.


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Table 4.1 Proposed SEIS modified Drainage Design Criteria (from SEIS addendum reports)

j?,~f9~::~~p:~:~[{:~1:1-:~;:: :~.~~.i£l~~~~f.iJ~i~~:,~2{§J::;%:t~l%~~~~fa:;~:~;~2:~~~~;,fJ?~H¥-~~J~~}?f:?Qi~~lB;~~-)}t~l;~~-~}~;~@;;·;~~Jfi, Inundation Extent Acceptable increases In inundation extent {above the e>lsting

conditions for a given return period to the 50 year ARI event) will be proposed where such an increase will not alter rural land use and result in significant Impacts

Inundation Duration Inundation duration not more than 3 days on valued pasture land that had previously been Inundated for 3 days or less for similar rainfall events.

Max Velocity Bridge outlet velocity - maximum of 1.2 X existing velocity at a distance equal to the bridge span downstream of bridge

Culverts outlet velocity

~ 1.5 m/s where erodible soils are present

~ 2.5 mfs for nonnal soils (with. no erosion control)

Ma>imum afflux Maximum 0.5 m - normally (unless justifiable)

Maximum 0.2m - around critical infrastructure

Maximum 0.1 m- around dwellings

The addendum report describes the hydrologic and hydraulic modelling carried out in the following

floodplain areas:

• Logan Creek I Brown Creek

• Sutter River I Eaglefield Creek

• Belyando River I Native Companion Creek

• Mistake Creek

• Midere Creek I Piebald Creek

• Diamond Creek I Myra Creek I Nibbereena

Results of this modelling were provided in the addendum report, and information packs containing the

results of the modelling have been supplied to impacted landholders along the route. The addendum

reports indicate that the proposed cross drainage will meet the modified drainage design criteria listed in

Table 4.1.

In general, it appears that proposed cross drainage provisions for the floodplain areas are acceptable,

based on the results of the modelling, although this would need to be confirmed by a more detailed

review of the proposed cross drainage structures and the modelling results closer to the design stage.

In addition to the floodplain areas, which have been the subject of the detailed modelling referred to

above, there are a large number of culverts on small drainage lines and streams. The original BFS study

lists 335 culvert sets, and provides some details of the velocity estimates through these culverts. While

the BFS study is a preliminary sizing exercise, the results (listed in appendices of the BFS drainage

report) indicate that for 6% of these culverts, the maximum outlet velocity will exceed 3.0 mlsec; and for

25% of the culverts the afflux (head) will exceed approximately 0.3 metres. For these culverts the size

should be increased to meet the proposed design drainage criteria.


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From the above description and from a review of the available information, it is considered that the

railway cross-drainage should be designed so as to achieve the following criteria:

• Maximum afflux of 0.3m for the design flood event, subject to special conditions (below) for lands

other than infrastructure and housing. At dwellings, the maximum afflux should be 0.1 metres or

less, and at infrastructure (for example state roads, and sub-stations etc), the maximum afflux

should be less than 0.2 metres.

• Maximum culvert outlet velocity 2.5 m/s for the design flood event, subject to special conditions

(below).

• Inundation duration compared to present - less than 5% increase in the duration of flooding for

design events.

• Inundation extent compared to present - no significant impacts; no change in land use; no

change in land productivity. Landholders in affected areas to be informed of any changes.

• Maximum afflux and water velocity criteria are applicable both upstream and downstream for

those waterways that may exhibit reverse flow under some circumstances

Submit to the Co-ordinator General for approval a detailed design report for flood passage and drainage

associated with the railway, generally in accordance with the items listed in Appendix Y, section 3.2.1,

with the following additional information:

• Flood levels

• Afflux, duration of inundation and culvert velocities for 20, 50 and 100 year ARI events

comparing current and developed conditions

• Frequency of overtopping of the lowest rail level at the cross drainage location.

• Specific impacts on infrastructure, assets (including housing) and rural operations.

• Sensitivity analysis demonstrating the effects of different design options on afflux

Submit a written statement from each landholder who is potentially impacted by changes to the drainage

regime which contains:

• Confirmation that the landholder has sited design information showing afflux,

• Landholder responses to information provided showing impacts on flooding, including afflux and

changes in inundated areas.

Following a significant fiood event, the proponent shall undertake a damages survey and in the event

of adverse impacts to assets or waterways, rectify and/or compensate any damage to assets,

infrastructure and farm production that has resulted from the railway.


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Provide a bond of $200,000 for an independent auditor to assess flood impacts and verify the

requirement for, and the appropriateness of, rectification and/or compensation measures.

Special Conditions

a) In some locations; for example in floodplain areas, highly erodible areas, and areas where there

is significant flood-prone infrastructure within short distances upstream of the alignment, a

smaller afflux may be appropriate. The afflux and culvert outlet velocity criteria may be set at

lower values in these areas in response to landholder and other stakeholder consultation and

requests, and an assessment by the regulator.

b) In other locations; for example in remote undeveloped locations in erosion resistant landscapes,

a larger afflux may be permissible. This will only be considered where:

• A separate design report is prepared, to justify the higher afflux;

• Impacted landholders have sited the design report, acknowledged the variation and

agreed to the higher afflux conditions in writing; and

• Assessment by the regulator confirms no adverse consequences are likely.


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Williams, Melissa

From:

Sent:

To:

Williams, Melissa


Cc: Davison, Mike; '

Subject: RPS review and proposed conditions

Page 1 of 1

Attachments: Alpha Coal CG Conditions report ver6 23.12.11 .doc; Alpha Coal CG Conditions report ver6 23 12 11.pdf

Good morning

Please find attached for your information the 'proposed cond itior project. This was provided to our office on 23 December 2011 . P provided to DERM.

The recommendations contained in this report are based on: - RPS's prior review of EIS material -the SEIS -the SEIS addendum - additional information requested by RPS provided via email by

Please contact me with any queries.


tel +61 7 3836 0667 (ext 60667) e [email protected] post PO Box 15517, City East Q 4002 visit Level 4, 63 George Street, Brisbane Q 4000 www.deedi.qld.gov.au



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Williams, Melissa

From:

Sent:

To:

Williams, Melissa


'Curley Peter'

Cc: Davison, Mike

Subject: FW: Hancock response to RPS request for outstanding information

Page 1 of2

Attachments: Alpha Coal CG Conditions report ver6 23.12.11.doc; Alpha Coal CG Conditions report ver6 23 12 11.pdf

Good morning Peter, Happy New Year!

Please find attached the revised 'proposed conditions' report fro As discussed before Christmas, this revision was prepared in re provided to RPS by Hancock on 14 December.

Please provide this document to the relevant DERM officers for for the CG's report.

Kind regards Melissa Williams Significant Projects Coordination Office of the Coordinator-General Department of Employment, Economic Development and ln1 Queensland Government

tel +61 7 3836 0667 (ext 60667) e [email protected] post PO Box 15517, City East Q 4002 visit Level 4, 63 George Street, Brisbane Q 4000 www. deed i. q ld. gov. au



From: David Finney [mailto:[email protected]] Sent: Friday, 23 December 2011 12:34 PM To: Williams, Melissa Cc: Norrie Sanders Subject: RE: Hancock response to RPS request for outstanding information

Hi Melissa



Regards

David Finney Environment Manager- NQ E [email protected]

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135 Abbott Street, Cairns, OLD, Australia, 4870

Wwww.rpsgroup.com.au

PO Box 1949, Cairns, OLD, 4870 T +61 7 40311336 F +61 7 4031 2942

Page 2 of2

This message (including any attachments) is intended for the use of the person or entity named above and may contain information that is private, confidential or privileged. If you are not the intended recipient you are not authorised to disclose, distribute, copy or use of this message. If you have received this communication in error, please contact the writer immediately on p: +61 7 40311336. While RPS takes all reasonable precautions to ensure that its computer systems are free of viruses, it will not be liable for any loss, damage, liability, or claim arising out of or incidental to any damage to the computer system of a recipient of communications or documents originating from RPS and recipients receive communications from RPS at their own risk


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Williams, Melissa


Sent: Tuesday, 3 January2012 9:16AM

To: 'David Finney'

Cc: 'Norrie Sanders'; Davison, Mike

Subject: RE: Hancock response to RPS request for outstanding infonnation

Good moming David, Happy New Year!

Thank you for providing the correct version, we will review this and contact you if we have any questions.

Kind regards Melissa Williams Significant Projects Coordination Office of the Coordinator~General Department of Employment, Economic Development and Innovation Queensland Government

tel +61 7 3836 0667 (ext 60667) e [email protected] post PO Box 15517, Clty East Q 4002 visit Level4, 63 George Street, Brisbane Q 4000 www.deedi.gld.gov.au

Tomorrow's Queensland: strong, green, smart, healthy and fairW\W/.\oward02.qld.qov.au

Please ocnsfderthc environment bcroro pontin~ this armil

From: David Finney [mailto:[email protected]] Sent: Friday, 23 December 2011 12:34 PM To: Williams, Melissa Cc: Norrie Sanders Subject: RE: Hancock response to RPS request for outstanding Information

Hi Melissa



Regards

-135 Abbott Street, Cairns, OLD, Australia. 4870

David Finney Environment Manager· NQ E [email protected] Wwww.ro~group.com.au

PO Box 1949, Cairns, OLD, 4870 T +51 7 4031 1335 F +51 7 4031 2942

Thfo meo .. go (lnduding ony oltllclunonb;) is intondod fcrlha u .. oltM ~"'""'"or ontity nomod obovo ond nuy cont>in infctmo.tJon that is priwto, <:<>nfldential or p<Nilo!)Od. II you aro not tho intondod "'ciplont you oro not outhorisod to disoloso. dislrib<Jll>. <:<>py or UM of tru. "'"'""!I<'· If you Mvo rnwivcd this communieotion in onor, ploooo contact \1\o writorlm.,.diamly on p: +!It 7 4031 1336 Vo.hilo RPS IDkos oil roooonoblo proeoUliono to on<urn !hot itn <:<>mputor 5yolomo ora froo olvirtJOO$, it will not bo lio!:1o lor any !oso. damt>~<>. liobility, or claim arhing out of or fncidonlol to any dama~o to tho e<>mpu'.or oyolom of a roc:ipiont o! <:<>mmurOc:>\iono or doournonts ofi9inating from RPS and mdpionl!< rocoiV<! <:<>mmunica\ion$ from RPS otlhoirownriol<

From: Melissa Williams [mailto:[email protected]] Sent: Wednesday, 14 December 201111;24 AM To: David Finney Cc: Mike Davisoni Stuart cameron; Norrie sanders Subject: Re: Hancock response to RPS request for outstanding information

Good morning David

Norrie advised me last week to contact you in his absence for matters relating to RPS's work on the Alpha Coal project.

Please find attached Hancock's response to Norrie's request for further information beyond the Alpha Coal Project SE!S and SElS Addendum (via email, 14 November- see below).

Can RPS please review Hancock's responses to the request and advise whether any of this information will alter recommendations made by RPS in the report provided to our office last week.

As the Coordinator-General's Evaluation Report for this project is currently being developed, we would like to be advised of any likely alterations to RPS's recommendations as soon as is practical.


Kind regards Melissa Williams Significant Projects Coordination Office of the Coordinator·General Department of Employment, Economic Development and Innovation Queensland Government


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Tomorrow's Queensland: strong, green, smart, healthy and fair www.toward02.ald.qov_au

Please consider the environment ooro:c poin~ng lh'" email

From:Sent: Tuesday, 13 December 2011 4:06PM To: Melissa Williams Cc:Subject: Hancock response to RPS request for outstanding information

Dear Melissa,



Thank you.

Kind Regards,

Hancock Coal Ply ltd Level 8, 307 Queen Street Brisbane OLD 4000


.J1 Please consider the environment before prlnling this email.

From:

Sent: Friday, 2 December 2011 10:54 Mt


Cc: Mike Davison;

Subject: RPS Responses· delay

Hi Melissa,

Page 2 of5

Just to let you know that the responses to RPS are taking longer than anticipated so they will not be coming your way this week. I am waiting on the response time from PB who are looking at the surface water questions and will get back to you once this has come through.

Regards

From:Sent: Monday, 14 November 2011 5:11PM To: Melissa Williams; Cc: Mike Davison; Subject: RE: RPS requests_A!pha SEIS

Thank you for this.



Hancock Coal Ply Ltd Level 3, 60 Albert Street Brisbane OLD 4000


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J1 Please consider the environment before printing this emaiL

From: Melissa Williams [mailto:[email protected]] Sent: Monday, 14 November 2011 5:07 PM To:Cc: 1>1ike Davison Subject: RPS requests_Aipha SEIS

Good afternoon

Page 3 of5

Following our meeting this afternoon I received an email from Norrie Sanders (RPS) detailing requests for further infonnation to allow complellon of relevant sections of their conditioning report.

I believe these were in line with discussions you had with Norrie during the site visit last week.


Thanks and kind regards Melissa Williams Significant Projects Coordination Office of the Coordinator-Genera\ Department of Employment, Economic Development and Innovation Queensland Government

tel +61 7 3836 0667 (ext 60667) e [email protected] post PO Box 15517, City East a 4002 visit Level4, 63 George Street, Brisbane a 4000 www.deedi.gld.gov.au

Tomorrow's Queensland: strong, green, smart, healthy and fairwww.towarda2.gld.gov.au

Ple~sa conO<dor the crrmonment before pnn~no !Ius email

From: Nonie Sanders [mailto:[email protected]] Sent: Monday, 14 November 20111:45 PM To: Melissa Williams Subject: outstanding information

Hi Melissa

Below is a summary of outstanding items which would help us to complete the conditions report. I have omitted reference to mine groundwater, tailings dam and rail flooding because both topics are under active assessment by Hancock. The information that I alluded to during the field trip to Alpha were based on our second review report (EIS and SEIS), extracts of which are included below. My conversation with mainly covered the creek analysis, but I have added other mine infonnation for completeness.


Creek diversion: o add pre development curve to stream power graphs (8-8 and B-9) o Provide commentary on physical impacts on creeks where post development hyrdau!ic parameters exceed current condition andfor ACARP guidelines- particularly

upstream and downstream of diversions. Stability risks in a50 are acknowledged but not specifically assessed or solutions proposed. o No flood inundation mapping is provided in the SEIS for the 2 year and 50 year ARt events. The flood report includes intennediate {5, 10,20 year) flood flows but does


o Comparative statistics on channel morphology pre and post diversion are not presented. Geomorphic features that mimic current morphology, such as terraces, meanders, wetlands, pools etc are not explicitly considered. Impacts on channel networks, floodplain connectivity, pools, lakes and palustrine wetlands are absent.


Landform and rehabilltion: see table below

Mine water balance Issues and recommendations

Issue Comment Actions Discharges to Lagoon The quantity and quality of discharges to Use daily water balance Creek- aggregated Lagoon creek are not specified other than modelling to asses discharge outputs from water discharge criteria. The mine water risk under different event modelling do not provide a balance needs to be further analysed to scenarios using daily time sufficient basis for demonstrate that there is sufficient step. assessing risks and storage and treatment capacity to allow evaluating management adherence to the standards under specific Consider design and arrangements even conditions. management arrangements to

prevent discharge (e.g. temporary storage within levee area} when discharge criteria are not achievable.


been allowed for sediment storage in the the proposed sediment

sediment dams. This may not be storage allowance for the sediment dams needs to be sufficient for the volume of sediment included in the EIS. This will 2.3.1 Sediment Dams wash off from the overburden which will

contain dispersive soils. lftoo small, the depend on the catchment

sediment dams witt fill with sediment area, erodibility of the material

quickly, and overflows to Lagoon Creek and life of dam. The rate of sediment removal needs to be may be more frequent that anticipated. assessed.

3.1 Climate Data Figure 3-2 is said to be a log Pearson 111 Amend text. probability distribution. It appears to be an exceedence plot, not a frequency distribution lot.

It would be useful to see flow duration curves for the estimated and recorded Provide more information on 3.5.1 Sacramento Model flows to provide more information on the model caitbration goodness of fit of this calibrated model. The model's ability to reproduce tow flows

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mav be imoortant in this context.


3.5.2 Catchment yields catchment yields came from for different information (e.g. references) to justify the choice of land use activities. catchment vield

4.4 Dirty Water The proposed release points should be Clarification of the locations of Management System. shown on a plan. Table 4-1 gives the co- the sediment dam discharge

ordinates only. The table lists the release points is required. Sediment Dam discharge points as SD1a, SD2b, SD4b, and S06b.

points. However these do not appear on the accompanying fi ures 4-1 to 4-5. Sediment dam capacities should be able The 10%AEP 24 hour rainfall to hold the 10%AEP 24 hour storm runoff depths should be tabulated




this demand is a signlficant component of during wet years. the total demand, a lower demand may lead to more frequent overflow of the final sediment dams.

Figure 4.6 GoldSim This is meant as a schematic diagram of Prepare a schematic diagram network diagram. the water management system. It is a preferably overlaid on

GoldSim output and is very confusing. background plan to show approximate location of sediment dams, environmental dams and discharge points.


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Kinetic testing to date is The AMD potential of raw coal and tailings column testing to further investigate limited and outcomes only is not yet confirmed and further kinetic Temporal saline and preliminary at this stage testing is required. acidic/metatiferous drainage

characteristics. It is recommended that further work is carried out to confirm dosing rates

Coarse coal rejects and Preliminary trial alkaline treatment efficacy during final design stage and these

roof and floor waste rock are confirmed in the live MVvMP. appear to have the highest has been undertaken on coarse reject Similar work should be carried out AP. and coal seam roof and floor material. on representative tailings materials if

further leachate testing confirms of concern AMD ootenlia!. Seepage fate risk is to be


considerations generation potential and low to moderate modelling for initial out of pit TSF saline leachate potentlal and in pit disposal. This should be

conditioned in the EA Mining scheduling to recognize the

WRD capping strategy must recognize the goal of final placement of low high risk associated with placement of dispersion overburden cap

Presence of dispersive dispersive and highly dispersive {sandstones, tuff} where possible. overburden and soilsfclays- overburden within the final cover. This should be an EM Plan Final landform Design commitment and EA condition. implications Stripping depths of low or nil dispersive MINMP should also include


materials. Bring forward development of the

EIS commits to preparation of a final void final void water quality model to the Final void water quality water quality model by year 5 of EM Plan OR approval conditions to

operations. provide for adequate worst case manaaement strateqies

Landform and rehabilitation· issues and recommendations Issue Comment Action

DERM's mandatory requirements and Consider Landform Design and How is Mine Closure guidelines {e.g. 18) will apply to the Rehabilitation, EA 1998, Centre Planning addressed? rehabilitation strategy {25.1.2/3) but for Land Rehabilitation research,

no word on industrY-based initiatives QRC etc. Explain what will be done

EIS proposes fairly standard post differently. mine land classification, final landform plan, topsoil management and revegetation {25.1 ). Vvhat {similar) mine has achieved these?

Mine wastes are largely sadie I dispersive {Appx J1 7) and Discuss M\I\IMP experience with encapsulation is proposed (16.6.3.1, test pit with HPPL I Thiess and 25.1.8andAppxJ1 &7.1.5) then provide mine planning A Mine Waste Management Plan details of how selective {MWMP) is in place for the test pit and encapsulation will occur while commitments have been made {SEIS operating differing mine methods Appx01.16.2) {IPCC dragllnes, truck I shovel)

How, in practical terms, will in different parts of the mine. rehabilitation be met?



Riparian vegeta:i~n is ~1oposed along Supply more details


Rehabilitation Success Criteria {Table diversions, levees, sediment Rehabilitation criteria should dams, roads, water storages, address the entire mine? P47) should address 'other mine camp, quarry, landfill. Also infrastructure' modify Monitoring {Table P48) if

reauired.

Unless stated otherwise, this email, together with any attachments, is intended for the named recipient(s) only and may contain privile•

If not an intended recipient of this email, you must not copy, distribute or take any action{s) that relies on it; any form of disclosu



If not an intended recipient of this email, you must not copy, distribute or take any action(s} that relies on it; any form of disclosu



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Williams, Melissa

From:

Sent: Tuesday, 3 January 2012 11:00 AM

To: Williams, Melissa

Subject: Re: RPS review and proposed conditions

Hello Melissa

Page 1 of2

Greetings for 2012. I will be at work Thursday and Friday this week. Will talk to you then if needed.

Thanks,

From: Williams, Melissa [mailto:[email protected]] Sent: Tuesday, January 03, 2012 11:52 AM To:Cc: Davison, Mike <[email protected]>; Subject: RPS review and proposed conditions

Good morning

Please find attached for your information the 'proposed conditions' report from RPS for the Alpha Coal project. This was provided to our office on 23 December 2011. A copy of this report has also been provided to DERM.

The recommendations contained in this report are based on: - RPS's prior review of EIS material -the SEIS -the SEIS addendum -additional information requested by RPS provided via email by Hancock on 13 December 2011




Tomorrow's Queensland: strong, green, smart, healthy and fair www.toward02.qld.gov.au


********************************DISCLAI~ER****************************

The information contained in the above e-mail message or messages

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(which includes any attachments) is confidential and may be legally privileged. It is intended only for the use of the person or entity to which it is addressed. If you are not the addressee any form of disclosure, copying, modification, distribution or any action taken or omitted in reliance on the information is unauthorised. Opinions contained in the message( s) do not necessarily reflect the opinions of the Queensland Government and its authorities. If you received this communication in error, please notifY the sender immediately and delete it from your computer system network.

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Williams, Melissa

From:

Sent: Tuesday, 3 January 2012 11:30 AM


Cc: Davison, Mike;

Subject: RE: RPS review and proposed conditions

Hi Melissa,

Many thanks for the below correspondence and the attached.

Cheers,

'<fP~I HANCOCK COAL PTY LTD

HANCOCK COAL PTY L TO Level 8, 307 Queen Street, Brisbane, Qld, 4000 (GPO Box 963, Brisbane, Qld, 4001)

From: Williams, Melissa [mailto:[email protected]] Sent: Tuesday, 3 January 2012 10:53 AM To:Cc: Davison, Mike; Subject: RPS review and proposed conditions

Good morning

Page 1 of2

Please find attached for your information the 'proposed conditions' report from RPS for the Alpha Coal project. This was provided to our office on 23 December 2011. A copy of this report has also been provided to DERM.

The recommendations contained in this report are based on: - RPS's prior review of EIS material -the SEIS -the SEIS addendum -additional information requested by RPS provided via email by Hancock on 13 December 2011



tel +61 7 3836 0667 (ext 60667) e [email protected]

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post PO Box 15517, City East Q 4002 visit Level 4, 63 George Street, Brisbane Q 4000 www.deedi.qld.gov.au



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Williams, Melissa

From: Williams, Melissa Sent: To:

Tuesday, 24 January 2012 12:16 PM

Cc: Subject:

Davison, Mike;Points for discussion with RPS

Good afternoon

Following our meeting yesterday, can you please provide a list of points for discussion/clarification from the RPS 'proposed conditions' report dated 23 December 2011.

Thanks and kind regards Melissa Williams Significant Projects Coordination Office of the Coordinator-General Department of Employment, Economic Development and Innovation Queensland Government




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Williams, Melissa

From: Davison, Mike Sent: To:

Tuesday, 31 January 2012 2:57PM Williams, Melissa

Subject: RPS

Hey Mel

In the RPS paper under Section 3.3.1 Waste Rock Classification they refer to Vol 2 Appendix S of the SEIS. They then refer to commitments proposed in Section 3.6.12

I cannot find this Section 3.6.12. Can they advise us where Section 3.6.12 is located

Cheers

Mike

Mike Davison Project Manager Significant Projects Coordination Office of The Coordinator-General Level4 63 George Street Brisbane 4000 Phone: 07 3405 6205 email: [email protected]

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Williams, Melissa

From: Norrie Sanders [[email protected]]

Sent: Wednesday, 1 February 2012 2:12PM


Subject: FW: URGENT: A few clarifications

Hi Melissa

Greg H advises that:

Page I of2

Section 4.2.2. the conditions should be 0.3 m maximum afflux, and 2.5 m/sec maximum outlet velocity for the cross drainage structures.

David Finney is looking up waste rock section when he returns to office tomorrow.

Cheers

Norrie

743 Ann Street, Fortitude Valley, QLD, Australia, 4006

Norrie Sanders Principal - Env, Climate Change E [email protected] W www.rpsqroup.com.au

PO Box 1559, Fortitude Valley, QLD, 4006 T +61 7 3606 6071 F +61 7 3237 8833 M 0417 762 066

This message (including any attachments) is intended for the use of the person or entity named above and may contain information that is private, confidential or privileged. If you are not the intended recipient you are not authorised to disclose, distribute, copy or use of this message. If you have received this communication in error, please contact the writer immediately on p: +61 7 3237 8899. While RPS takes all reasonable precautions to ensure that its computer systems are free of viruses, it will not be liable for any loss, damage, liability, or claim arising out of or incidental to any damage to the computer system of a recipient of communications or documents originating from RPS and recipients receive communications from RPS at their own risk

From: Williams, Melissa [mailto:[email protected]] Sent: Tuesday, January 31, 2012 5:40 PM To: Norrie Sanders Cc: Davison, Mike Subject: A few clarifications

Good afternoon Norrie

As per our phone conversation, could you please give clarification on the below points from the 'proposed conditions' report provided 23 December.

-In section 4.2.2 it appears afflux should be conditioned to 0.3 regarding railway cross drainage, in 4.2.1, reference is made to afflux of 0.5. Can you please confirm the proposed condition is correct in reading 0.3rn afflux and outlet velocity of 2.5m/s for railway cross drainage.

- In Section 3.3.1 of the report, reference is made to Vol 2 Appendix S of the SEIS, there is then also reference to commitments proposed in Section 3.6.12. We cannot find 'Section 3.6.12' in the above appendix. Can you please confirm if this is a correct reference, and if so in which document (EIS, SEIS, Addendum) this reference can be found.

Thanks and kind regards Melissa Williams Significant Projects Coordination


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Office of the Coordinator-General Department of Employment, Economic Development and Innovation Queensland Government

tel +61 7 3836 0667 (ext 60667) e [email protected] post PO Box 15517, City East Q 4002 visit Level 4, 63 George Street, Brisbane Q 4000 www.deedi.gld.gov.au



Page 2 of2

********************************DISCLAIMER**************************** The infonnation contained in the above e-mail message or messages (which includes any attachments) is confidential and may be legally privileged. It is intended only for the use of the person or entity to which it is addressed. If you are not the addressee any form of disclosure, copying, modification, distribution or any action taken or omitted in reliance on the information is unauthorised. Opinions contained in the message(s) do not necessarily reflect the opinions of the Queensland Govermnent and its authorities. If you received this conununication in error, please notifY the sender inunediately and delete it from your computer system network.


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Williams, Melissa


Sent: Thursday, 2 February 2012 8:56AM

To: Davison, Mike

Subject: FW: URGENT: A few clarifications

a partial reply ....

Melissa Williams Significant Projects Coordination Office of the Coordinator-General Department of Employment, Economic Development and Innovation Queensland Government




From: Norrie Sanders [mailto:[email protected]] Sent: Wednesday, 1 February 2012 2:12 PM To: Williams, Melissa Subject: FW: URGENT: A few clarifications

Hi Melissa


Page 1 of2

Section 4.2.2. the conditions should be 0.3 m maximum afflux, and 2.5 m/sec rnaximum outlet velocity for the cross drainage structures.


Cheers

Norrie

743 Ann Street, Fortitude Valley, OLD, Australia, 4006

15/01/2013

Norrie Sanders Principal- Env, Climate Change E [email protected] Wwww.rosgroup.com.au

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This message (including any attachments) is intended for the use of the person or entity named above and may contain information that is private, confidential or privileged. If you are not the intended recipient you are not authorised to disclose, distribute, copy or use of this message. If you have received this communication in error, please contact the writer immediately on p; +61 7 3237 8899. While RPS takes all reasonable precautions to ensure that its computer systems are free of viruses, it will not be liable for any loss, damage, liability, or claim arising out of or incidental to any damage to the computer system of a recipient of communications or documents originating from RPS and recipients receive communications from RPS at their own risk




- In section 4.2.2 it appears afflux should be conditioned to 0.3 regarding railway cross drainage, in 4.2.1, reference is made to afflux of 0.5. Can you please confirm the proposed condition is correct in reading 0.3m afflux and outlet velocity of 2.5mls for railway cross drainage.






********************************DISCLAI11ER**************************** The info1mation contained in the above e-mail message or messages (which includes any attachments) is confidential and may be legally privileged. It is intended only for the use of the person or entity to which it is addressed. If you are not the addressee any form of disclosure, copying, modification, distribution or any action taken or omitted in reliance on the information is unauthorised. Opinions contained in the message( s) do not necessarily reflect the opinions of the Queensland Government and its authorities. If you received this communication in error, please notifY the sender immediately and delete it from your computer system network.


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Williams, Melissa


Sent: Thursday, 2 February 2012 9:06AM

To: 'Norrie Sanders'

Subject: RE: URGENT: A few clarifications

Thanks for that confirmation from Greg, was sure that it would be correct but Mike wanted to double check:)

Look forward to hearing back re waste rock.

Kind regard Melissa Williams Significant Projects Coordination Office of the Coordinator-General Department of Employment, Economic Development and Innovation Queensland Government

tel +61 7 3836 0667 (ext 60667) e [email protected] post PO Box 15517, City East Q 4002 visit Level 4, 63 George Street, Brisbane Q 4000 www.deedi.gld.qov.au

Tomorrow's Queensland: strong, green, smart, healthy and fair www.toward02.gld.gov.au



H.1 Melissa




Cheers

Norrie

15/01/2013

Norrie Sanders Principal - Env, Climate Change E [email protected] Wwww.rosgroup.com.au

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743 Ann Street, Fortitude Valley, OLD, Australia, 4006


Page2 of3

This message (including any attachments) is intended for the use of the person or entity named above and may contain information that is private, confidential or privileged. If you are not the intended recipient you are not authorised to disclose, distribute, copy or use of this message. If you have received this communication in error, please contact the writer immediately on p: +61 7 3237 8899. \IVhi!e RPS takes all reasonable precautions to ensure that its computer systems are free of viruses, it will not be liable for any loss, damage, liability, or claim arising out of or incidental to any damage to the computer system of a recipient of communications or documents originating from RPS and recipients receive communications from RPS at their own risk




- In section 4.2.2 it appears afflux should be conditioned to 0.3 regarding railway cross drainage, in 4.2.1, reference is made to afflux of 0.5. Can you please confirm the proposed condition is correct in reading 0.3m afflux and outlet velocity of 2.5m/s for railway cross drainage.






********************************DISCLAI~ER****************************

The information contained in the above e-mail message or messages (which includes any attachments) is confidential and may be legally privileged. It is intended only for the use of the person or entity to which it is addressed. If you are not the addressee any form of disclosure, copying, modification, distribution or any action taken or omitted in reliance on the information is unauthorised. Opinions contained in the message( s) do not necessarily reflect the opinions of the Queensland Government and its authorities. If you received


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this communication in en·or, please notifY the sender immediately and delete it from your computer system network

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Williams, Melissa


Sent: Tuesday, 7 February 2012 12:37 PM


Cc: Davison, Mike

Subject: RE: URGENT: A few clarifications

Hi Norrie

Any response from David regarding the clarification on waste rock?

Page 1 of3

Also, Hancock have asked for a meeting with us, yourself and Greg. They would like to ask some clarification questions regarding the rail flooding in the 'recommended conditions' report. Can you please advise whether you and Greg may be available. Next week is crazy for us, how about the week after (between 20th-24th Feb)?






Hi Melissa




Cheers

Norrie


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Norrie Sanders Principal - Env, Climate Change E [email protected] W www.rosqroup.com.au


Page2 of3

This message (including any attachments) is intended for the use of the person or entity named above and may contain information that is private, confidential or privileged. If you are not the intended recipient you are not authorised to disclose, distribute, copy or use of this message. If you have received this communication in error, please contact the writer immediately on p: +61 7 3237 8899. VIJhi!e RPS takes all reasonable precautions to ensure that its computer systems are free of viruses, it will not be liable for any loss, damage, liability, or claim arising out of or incidental to any damage to the computer system of a recipient of communications or documents originating from RPS and recipients receive communications from RPS at their own risk

From: Williams, Melissa [mailto:[email protected]] Sent: Tuesday, January 31, 2.012. 5:40 PM To: Norrie Sanders Cc: Davison, Mike Subject: A few clarifications



-In section 4.2.2 it appears afflux should be conditioned to 0.3 regarding railway cross drainage, in 4.2.1, reference is made to afflux of 0.5. Can you please confirm the proposed condition is correct in reading 0.3m afflux and outlet velocity of 2.5m/s for railway cross drainage.




Tomorrow's Queensland: strong, green, smart, healthy and fair www.towardQ2.gld.gov.au


********************************DISCLAI~ER**************************** The information contained in the above e-mail message or messages (which includes any attachments) is confidential and may be legally privileged. It is intended only for the use of the person or entity


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to which it is addressed. If you are not the addressee any form of disclosure, copying, modification, distribution or any action taken or omitted in reliance on the information is unauthorised. Opinions contained in the message(s) do not necessarily reflect the opinions of the Queensland Govermnent and its authorities. If you received this communication in enor, please notifY the sender immediately and delete it from your computer system network.

15/01/2013

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Williams, Melissa


Tuesday, 7 February 2012 2:36PM

Subject: Another meeting request - RPS

Good afternoon

RPS have advised that they are available to meet and discuss their report (especially rail flooding) on Monday 20 Feb before 2pm (maybe 12-1, before the fortnightly meeting), or on Wednesday 22 Feb after 2pm. Neither of our offices have availability next week.

We would probably prefer the Wednesday afternoon, but can arrange the Monday as well. Can you please confirm what time would work for you.



Tomorrow's Queensland: strong, green, smart, healthy and fair www.towardQ2.qld.qov.au


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Williams, Melissa

From:

Sent: Tuesday, 7 February 2012 4:10PM


Subject: RE: Another meeting request- RPS

Dear Melissa,

Monday would work best for us.

will attend for rail matters.


Hancock Coal Ply Ltd Level 8, 307 Queen Street, Brisbane, Qld, 4000 (GPO Box 963, Brisbane, Qld, 4001)


~ Please consider the environment before printing this email.

From: Williams, Melissa [mailto:[email protected]] Sent: Tuesday, 7 February 2012 2:36 PM To: Subject: Another meeting request- RPS

Good afternoon

Page I of2

RPS have advised that they are available to meet and discuss their report (especially rail flooding) on Monday 20 Feb before 2pm (maybe 12-1, before the fortnightly meeting), or on Wednesday 22 Feb after 2pm. Neither of our offices have availability next week.

We would probably prefer the Wednesday afternoon, but can arrange the Monday as well. Can you please confirm what time would work for you.


tel +61 7 3836 0667 (ext 60667) e [email protected] post PO Box 15517, City East Q 4002 visit Level 4, 63 George Street, Brisbane Q 4000 www.deedi.gld.gov.au

Tomorrow's Queensland: strong, green, smart, healthy and fair www.towardQ2.gld.gov.au


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Williams, Melissa

From:

Sent:

To:

Cc:

David Finney [[email protected]]

Wednesday, 8 February 2012 4:44PM

Williams, Melissa

Norrie Sanders

Subject: Hancock Coal Waste Rock Queries

Hi Melissa

Page 1 of 1

Sorry for the delay but have been tied up in off site training this week. Section 3.6.12 refers to the Environmental Management Plan. My apologies for the lack of clarification.

Regards


David Finney Environment Manager- NQ E [email protected] WWWN.rosqroup.com.au

PO Box 1949, Cairns, QLD, 4870 T +61 7 40311336 F +61 7 4031 2942

This message (including any attachments) is intended for the use of the person or entity named above and may contain information that is private, confidential or privileged. If you are not the intended recipient you are not authorised to disclose, distribute, copy or use of this message. If you have received this communication in error, please contact the writer immediately on p: +61 7 4031 1336. While RPS takes all reasonable precautions to ensure that its computer systems are free of viruses, it will not be liable for any loss, damage, liability, or claim arising out of or incidental to any damage to the computer system of a recipient of communications or documents originating from RPS and recipients receive communications from RPS at their own risk


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Williams, Melissa


Sent: Wednesday, 8 February 2012 4:53PM

To: Davison, Mike

Subject: FW: Hancock Coal Waste Rock Queries

RPS request re waste rock

Melissa Williams Significant Projects Coordination Office of the Coordinator-General Department of Employment, Economic Development and Innovation Queensland Government




From: David Finney [mailto:[email protected]] Sent: Wednesday, 8 February 2012 4:44 PM To: Williams, Melissa Cc: Norrie Sanders Subject: Hancock Coal Waste Rock Queries

Hi Melissa

Page 1 of 1

Sorry for the delay but have been tied up in off site training this week. Section 3.6.12 refers to the Environmental Management Plan. My apologies for the lack of clarification.

Regards


David Finney Environment Manager - NQ E [email protected] W www .rosgroup.com.au

PO Box 1949, Cairns, QLD, 4870 T +61 7 4031 1336 F +61 7 4031 2942

This message (including any attachments) is intended for the use of the person or entity named above and may contain information that is private, confidential or privileged. If you are not the intended recipient you are not authorised to disclose, distribute, copy or use of this message. lf you have received this communication in error, please contact the writer immediately on p: +61 7 4031 1336. While RPS takes all reasonable precautions to ensure that its computer systems are free of viruses, it will not be liable for any loss, damage, liability, or claim arising out of or incidental to any damage to the computer system of a recipient of communications or documents originating from RPS and recipients receive communications from RPS at their own risk.


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Williams, Melissa

From: Sent: To:

Curley Peter [[email protected]] Thursday, 9 February 2012 3:02PM Davison, Mike

Cc: Subject:

Cameron, Stuart; Williams, Melissa RPS Report review by DERM

Attachments: DERM advice on RPS report to CoG 9feb12.doc

DERM advice on RPS report to c. ..

Mike

Please find attached the DERM officer response to CoG's RPS report for the Alpha EIS/SEIS/Addendum.

The groundwater section is included.

Happy to discuss and bring in relevant DERM officers as required.

cheers

Peter Curley Statewide Environmental Assessments Telephone 07 3330 5713 Facsimilie 07 3330 5754 Email: [email protected] <mailto:[email protected]> Environment & Natural Resource Regulation Department of Environment and Resource Management 8/400 George Street, Brisbane 4000 GPO 2454, Brisbane 4001

From: Davison, Mike [mailto:[email protected]] Sent: Wed 8/02/2012 2:04 PM To: Curley Peter Cc: Cameron, Stuart; Williams, Melissa Subject: Hi

Will you send me details of DERM Groundwater comments prior to us having a meeting on this topic

Cheers

Mike Mike Davison Project Manager Significant Projects Coordination Office of The Coordinator-General Level 4 63 George Street Brisbane 4000 Phone: 07 3405 6205 email: [email protected]

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addressee any form of disclosure, copying, modification, distribution or any action taken or omitted in reliance on the information is unauthorised. Opinions contained in the message(s) do not necessarily reflect the opinions of the Queensland Government and its authorities. If you received this communication in error, please notify the sender immediately and delete it from your computer system network.

The information in this email together with any attachments is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. There is no waiver of any confidentiality/privilege by your inadvertent receipt of this material. Any form of review, disclosure, modification, distribution and/or publication of this email message is prohibited, unless as a necessary part of Departmental business. If you have received this message in error, you are asked to inform the sender as quickly as possible and delete this message and any copies of this message from your computer and/or your computer system network.

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Department of Environment and Resource Management Advice on RPS Report to Coordinator General -Alpha Coal Project

Advice on the RPS Report to Coordinator General November 2011 for the Alpha Coal Project

Office of the Coordinator General provided a copy of the RPS Report in late December 2011 for advice.

The advice following is provided for consideration in developing any CoordinatorGeneral's Report (CoG Report) for this project. This advice may also be used to inform the proponent of information requirements and corrections that should be addressed before the EIS process is completed.

The advice addresses the • Addendum to the Supplementary EIS (SEIS) • RPS Australia East Ply Ltd "Review of Selected Aspects of the (Alpha) EIS and

Supplementary EIS: proposed conditions

The RPS Report addresses the following issues. The relevant DERM jurisdiction is also specified. • water management (DERM advice on groundwater follows) • creek diversions (DERM advice follows), • waste rock characterisation, tailings management, final landform and

rehabilitation (DERM conditions are under development as part of the draft Environmental Authority for the mining lease. The draft EA will be available to CoG before finalisation of the CG Report- possibly end February or early March)

• rail corridor vegetation (DERM advice follows) • rail creek and river crossings (flooding is not DERM jurisdiction)

Groundwater

General comments

RPS have proposed a number of conditions to be imposed on any approval for the project to ensure that the groundwater model is revised, that the source of recharge to groundwater is identified and that impacts on the GAB are investigated further.

DERM has expressed similar concerns about these aspects of the groundwater report, including the source of recharge and the direction of groundwater flows, and is concerned that the impacts of a project such as this on the groundwater resource are fully investigated.

However DERM also recognizes that the initial groundwater investigations especially in an area where there has been no previous long term monitoring of its behavior and there is little base data, will only be a starting point and ongoing investigations will be required for the life of the project to refine the original groundwater model and impacts of the project on groundwater.

DERM considers that as long as there are built in mechanisms that require protection of the resource and mitigation of ongoing impacts then approval for projects that take groundwater (i.e mine dewatering) can be adequately conditioned

Currently the conditions that deal with these issues and other issues such as make good requirements, and regular monitoring, assessment and preparation of annual reports are included on a water licence issued under the Water Act 2000 and not on the Environmental Approval for the project. This is because the take of water is not

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regulated under either the EPA act or the Mining Act and the need to ensure that there is no confusion over water terms in any environmental approval and terms on a water licence.

DERM has advised the proponents that a water licence will be required to authorise the taking of water by dewatering and that it will be conditioned with appropriate terms. These terms are part of a standard suite of terms that DERM imposes on all water licenses issued for dewatering and these terms are summarised in the further comments below. The terms will be the same as those issued for the water licence for the bulk test pit dewatering licence for this project (see attachment A)

Section Condition 3.1.2.2 - proposed conditions modelling .··

Comments

RPS have stated that a condition should be imposed requiring the groundwater model to be modified to allow more advanced modelling to be undertaken prior to project approval (construction).

They have also recommended that a further condition should be imposed requiring periodic post-audits of the groundwater model, and re-calibration and re-prediction of future impacts during the mining phase of the project. These should be undertaken initially at a minimum of 3-yearly intervals, and eventually at 5-yearly intervals throughout the mining phase of the project.

Response

DERM supports this recommendation and has advised the proponent that these terms will be imposed on the water licence for dewatering. See special condition 7 and 8 in attachment A

Section Condition 3.1.2.2 - proposed conditions recharge

Comments

RPS have stated that a condition should be imposed that further investigations be undertaken to verify the source(s) and mechanism(s) of recharge prior to project approval, as this may have a bearing on the potential for the project to impact on the GAB.

Response

DERM supports the RPS recommendation that the source of groundwater recharge is more clearly identified; however it does not share the concerns of RPS that the project has the potential to impact on the GAB aquifers.

The mine footprint does not extend far enough west to intercept any GAB aquifers; therefore any impacts can only be from water draining from GAB aquifers (the clematis sandstone) into the aquifers of the Colinlea sandstones and bandanna formation. This would require a reduction in head in the Colin/ea sandstone significant enough to induce the transfer of water from the clematis through the Rewan formation and into the Colin/ea sandstone. However the Rewan formation is recognised as a significant aquitard and does not contain any useable aquifers. Section N.3.3 of appe4ndix N in the SEtS v4 confirms that the Rewan has a very low permeability. Therefore it is not considered that there will be any threat to the Gab

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aquifers from this project.

However DERM recognises that it will be necessary to monitor and gather further data to identify groundwater behaviour. It is considered that special condition 7 and 8 in attachment will be sufficient to address the concerns raised by RPS and DERM on this issue.

Section Condition 3.1.3.2 - proposed conditions groundwater monitoring

Comments

RPS have stated that a condition should include, subject to development (prior to commencement of mining) of a satisfactory numerical model, calibration and reliable prediction of impacts both during and after mining:

• Groundwater level monitoring at representative monitoring bores, at frequencies determined on the basis of the results of baseline monitoring and trigger values (monthly/quarterly/continuous);


• Periodic comparison of water level changes with model-predicted water level changes, to verify the reliability of model predictions;

• Annual reporting of the results of monitoring and comparison of observed impacts with predicted impacts, to be made available to the government agencies and the public.

Response

DERM supports this RPS recommendation. The requirement to monitor asses and report is part of the standard suite of terms that DERM will include on the water licence for mine dewatering. It is considered that special condition 8 and 9 in attachment A will be sufficient to address the concerns raised by RPS and DERM on this issue.

Section Condition 3.1.4.2 - proposed conditions project water supply

Comments

RPS have stated that a condition should be imposed that a thorough investigation to demonstrate availability of sufficient groundwater to meet the project's initial water supply needs be undertaken prior to commencement of mining (construction).

Response

Should the project be approved and DERM grant a water licence for dewatering, then DERM officers would want to see any dewatering water beneficially used, i.e for a mine water supply. As the impacts of the take of this water would be regulated by the mine dewatering licence then no further investigation would be required.

However if the mine wanted to drill additional bores for the purpose of providing a water supply for the mine, then an additional water licence would be required. DERM would require an additional groundwater investigation to be undertaken to assess the impacts of this additional take and any water licence granted would be conditioned

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with the same terms as the dewatering license (i.e attachment A). Therefore DERM considers that this term would not be required on any mine approval issued by the COG.3

Creek Diversions

Overview on conditions for the Water Act

The Alpha Coal Conditions Report by RPS has made the recommendation to "approve the proposed diversions subject to conditions to reduce the risks of serious erosion" (page 13). The decision on whether a water licence application is approved is made under the provisions of the Water Act 2000. Any application that is submitted is assessed on its merits and in accordance with the criteria under that Act.

The proposed conditions within the RPS report do not state whether these are to be conditions on the water licences for the diversion channels. In their current form they cannot be conditions of the water licence as the information requested within the conditions is required to be submitted and assessed during the investigation of the water licence applications.

Should the Coordinator General accept the proposed conditions within the report, the conditions should be written that the proponent submit information and reports that meet these conditions as part of an application for a water licence under the provisions of the Water Act 2000. The water licence can then be conditioned according to the outcome of that investigation.

The information requirements of the proposed conditions should be considered as a minimum and in addition to any other information that may be required to assess the water licence application for the watercourse diversions under the provisions of the Water Act 2000.

Below outlines DERM officer views in relation to the proposed RPS conditions.

Preconstruction RPS and DERM have expressed the same concerns over the conflicting and at times, contradictory nature of the potential hydraulic conditions of the proposed diversions and indeed, their potential impact on the existing downstream hydraulic conditions of all watercourses. In light of these results, DERM cannot fully support the pre-construction condition relating to the approval of current diversion plans. Any impact from diversions upstream and downstream on the diverted watercourse should be minimal if at all. DERM does not specify the length of watercourse to review upstream or downstream from the confluence point with a diversion.

The extent of potential impact from diversions may also include upstream reaches of the diverted watercourse. RPS have stated that reaches within the ML and downstream by up to 5km should be assessed for baseline geomorphic conditions. DERM would encourage that this assessment be extended to upstream of the diversion confluence by a similar length.

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Section Condition 3.2.2 - proposed conditions pre construction

Comments

RPS have stated that final designs for approval should be 'generally in accordance with the diversion plan forms depicted in Appendix J'.

RPS have also recommended that the baseline geomorphic conditions of impacted watercourses be undertaken within the ML and downstream by a minimum of 5km.

Response

DERM does not support this recommendation in light of potential impact to the stability and performance of the existing downstream watercourses due to proposed diversions. Further review of the proposed diversions including modifications to planned routes should be fully investigated. Baseline geomorphic assessments should extend upstream by up to 5km from the confluence with the proposed diversions.

DERM WM&U support the other recommendations relating to compliance with hydraulic criteria, soil/geotechnical assessment and vegetation proposed for the diversion. In respect to Table 3.2: Criteria for hydraulic design (page 14), RPS have noted that the acceptable increases in hydraulic parameters for natural reaches 'are relative to a discrete point or uniform reach. DERM supports these remarks and reiterates that the proposed diversions should not impact on the stability and performance of existing watercourses upstream or downstream.

Construction DERM WM&U support all recommendations.

Post construction stabilization and revegetation DERM WM&U support all recommendations.

Monitoring DERM WM&U support all recommendations.

The monitoring program should include the Index of Diversion Condition, as outlined in the A CARP Project C9068, which has been widely adopted within the Bowen Basin for the monitoring of watercourses and stream diversions.

Section Condition 3.2.2 -monitoring .

Comments

RPS have not identified that the current industry adopted Index of Diversion Condition, as outlined in the A CARP Project C9068 will be implemented as the part of the monitoring program for watercourses and stream diversions impacted by mining activities.

Response

The monitoring program include the Index of Diversion Condition, as outlined in the A CARP Project C9068 for all watercourses and stream diversions impacted by mining.

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Department of Environment and Resource Management Advice on RPS Report to Coordinator General - Alpha Coal Project

Additional Comments

The current extent of mining activities surrounding the Alpha Mine includes the Kevin's Corner and Galilee Coal Projects. The cumulative impact of these three projects on the existing natural resources including watercourses and diversions should be examined. The proponent should investigate how the cumulative impact of their proposed diversions and mining activities impacts on adjacent mining projects. This impact has not been identified in the RPS document.

General Comment- cumulative impact on watercourses and diversions

Comments

RPS have not identified the cumulative impact of mining related activities including proposed diversions that the Alpha Coal Project may have on the adjacent Kevin's Corner and Galilee Coal Projects.

Response

The detailed design of proposed stream diversions and associated structures will need to consider the cumulative impact on adjacent mining projects.

Vegetation (rail)

Prior to the lodgement of the application to DERM Vegetation Management to clear native vegetation, the applicant should apply for a Property Map of Assessable Vegetation (PMAV) to change the Regional Ecosystem mapping if any inaccurate mapping data is identified

Section 4.1.2 Vegetation Management contains recommendations/conditions that may not be compatible with DERM decision making including the following specific passages (as highlighted): 'The offsets identified must be legally 4: Policy for

Vegetation Management Offsets (Version required for the development being cleared.

Where possible, the clearing of native vegetation within road watercourses must not reduce the width of the ve~Jet<3tic>n 50m

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ATTACHMENT A- PROPOSED WATER LICENCE TERMS

Conditions (Schedule B)

1. The Schedule B conditions associated with this licence are attached in Annexure A and are conditions, which the licensee must comply with under authority of this licence.

Annexure A

Recital A

Hancock Coal Pty Limited

Hancock Coal Pty Limited (hereinafter "the licensee") is the owner of property described on the Licence, upon which it operates the Alpha Coal Project. The licensee will construct works (comprising works that take groundwater from a bore, shaft or sump pump within MDL 285) accessing the Sedimentary Undifferentiated Formation. These works are referred to as the Dewatering Works.

The operation of the Dewatering Works will impact on the piezometric levels in the region of the Alpha Coal Project during the life of the mine and for a period after the mines closure.

The licensee subsequent to the time of making application for a Licence, submitted to the Department of Environment and Resource Management predictions of the impact of the Dewatering Works on the piezometric levels in the region. These predictions, which were derived from a model developed to enable such predictions to be made, were referenced in the reports titled:

Groundwater Seepage Modelling- Bulk Sample Pit, December 2009, JBT Consulting Pty Ltd.

Bulk Sample Pit Groundwater Monitoring Program, June 2010, JBT Consulting Pty Ltd.

The conditions set out in Schedule A and Schedule B of this Licence are herewith after referred to as "the Conditions".

DEFINITIONS

In this Licence, unless the context otherwise requires:

"bore owner" means the registered owner of the land on which a bore exists as approved development under the Sustainable Planning Act 2009 and/or from which water is taken under the authority of the Water Act 2000;

"business day" means a day on which trading banks are open for normal banking business in Brisbane;

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"Chief Executive" means the Chief Executive, Department of Environment & Resource Management;

"cost of restoration measures" means the cost incurred in carrying out the restoration measures as are reasonably necessary to restore supply of water to the bore owner pursuant to SPEC 05 (1);

"licensee" has the meaning ascribed to it in Recital A;

"Sedimentary Undifferentiated Bore" means a bore accessing the Sedimentary Undifferentiated Formation

"Tertiary bore" means a bore accessing the Tertiary sedimentary unit

"Permian bore" means a bore accessing the Permian sedimentary unit

"Colinlea bore" means a bore accessing the Colinlea Sandstone Formation

"Dewatering Works" has the meaning ascribed to it in Recital A;

"Monitoring Bores" means the monitoring bores as identified in Bulk Sample Pit Groundwater Monitoring Program, June 2010, JBT Consulting Pty Ltd. and any subsequently drilled bores for monitoring purposes;

"pre-existing bore" has the meaning ascribed to it in SPEC 01 (1) and SPEC 01 (2)(a) but does not include a bore referred to in SPEC 01 (2)(b);

"restoration measures" has the meaning ascribed to it in SPEC 04 (1 );

"Condition" has the meaning ascribed to it in Recital A; and

"unduly affected" has the meaning ascribed to it in SPEC 02.

INTERPRETATION

In this Licence:

(a)

(b)

(c) NOTICES

headings to Conditions are for ease of reference only and shall not in any way affect the meaning of the Conditions; a reference to days or months is a reference to business days and calendar months; and

words in the singular shall include the plural and vice versa.

(a) Form of Notice

Any notices, consents, document, invoice or other communication ("notice") required or permitted to be given by this Licence:

(i) (ii)

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must be in writing; and may be given by being delivered or sent by prepaid registered post (or by facsimile transmission where facsimile transmission facilities are available for receipt of such a communication) to

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(iii)

the address of the parties set out below or such other address as may be notified as the appropriate address from time to time for the purposes of this Licence.

The Chief Executive Department of Environment & Resource Management PO Box 1762 ROCKHAMPTON QLD 4700

Att; Senior Advisor Mining Regulation (Water Management and Use) Telephone: (07) 49384600 Facsimile: (07) 49273079

Licensee: Hancock Coal Ply Limited GPO Box 963 BRISBANE QLD 4001

(b) Time Service Occurs

A notice is deemed to be served on a party, in the case of post, on the third business day after posting and, in the case of facsimile, on the day of transmission if the transmission is before 5.00pm on a business day and in all other circumstances on the business day following transmission of the facsimile provided that the sending party has received a report that there has been a correct and complete transmission.

EXISTING WATER SUPPLIES TO BE PROTECTED

SPEC 01

( 1) Existing bores

At the date of issue of this Licence, any Sedimentary Undifferentiated, Tertiary, Permian, or Colinlea bore, or those in surrounding geological formations that are in existence and:

(a) are approved developments under the Sustainable Planning Act 2009 and/or,

(b) take water under the authority of the Water Act 2000

shall be regarded as a "pre-existing bores."

(2) Future bores

(a) If after the date of issue of this Licence,

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(i) (ii)

a new bore is required; and such new bore is approved development under the Sustainable Planning Act 2009 and/or takes water under the authority of the Water Act 2000; and

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SPEC 02

(iii) such new bore is brought into existence, as either:

A) a new bore to supply a water licence from the Sedimentary Undifferentiated, Tertiary, Permian, or Colinlea formations, or surrounding geological formations, issued prior to this water licence; or

B) a remedial measure required under this Licence to restore unduly affected water supplies; or

C) replacement works,

then such a new bore will be regarded as a "pre-existing bore" for the purposes of this licence.

(b) Any bore constructed after the date of issue of this Licence that does not meet the criteria listed in Spec 01 (2)(a) above will not be regarded as a "pre-existing bore" for the purposes of this Licence.

If, in the opinion of the Chief Executive, at the site of a pre-existing bore:

(a) the actual piezometric drawdown caused by the operation of the Dewatering Works causes the pre-existing bore to have an "impaired capacity", which shall mean after consultation between the Chief Executive, the licensee and the bore owner or a person authorised by the bore owner to represent him as the case may be, the bore is assessed by the Chief Executive as being no longer able to provide an adequate supply of water solely for the authorised purpose/s required at that location; and;

(b) (i)

(ii)

(iii)

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in the case of a bore used to supply domestic water, shall mean, a reduction in the ability of the bore to supply water for domestic requirements as authorised under the Water Act 2000 in the case of a bore used to supply stock water as authorised under the Water Act 2000, shall mean, any material reduction in the number of stock able to be watered, having regard to the stock carrying capacity of the land serviced by the pre-existing bore, including seasonal variations in the stock carrying capacity of that land; in the case of a bore used to supply water for another purpose under the authority of the Water Act 2000, a material reduction in the pumping supply required for the purpose, as reasonably assessed by the Chief Executive after consultation between the Chief

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Executive, the licensee and the bore owner or a person authorised by the bore owner to represent him;

(iv) then the pre-existing bore will be regarded as being "unduly affected" by the operation of the Dewatering Works.

SPEC 03

If in the reasonable opinion of the Chief Executive, a pre-existing bore may be unduly affected by the operation of the Dewatering Works, then the Chief Executive may direct the licensee to carry out necessary investigations and provide to the Chief Executive any data the Chief Executive reasonably requires in order to establish if the pre-existing bore is unduly affected.

SPEC 04 UNDULY AFFECTED SUPPLIES TO BE RESTORED

(1)

Where, after Spec 02 and Spec 03 have been complied with, a pre-existing bore is determined to be unduly affected by the operation of the Dewatering works, the licensee shall, at its cost, carry out such measures, or cause such measures to be carried out, as are reasonably necessary to make good the supply of water to the unduly affected bore pursuant to the conditions of this licence (the "restoration measures").

(2)

A water supply from a pre-existing bore unduly affected by the operation of the Dewatering Works will be considered to be restored if:

(a) there is an adequacy of supply for the authorised use, having regard, after consultation between the Chief Executive, the bore owner and the licensee, to the following factors:

(i) allocation issued to water licence holder that the pre-existing bore supplies; or

(ii) the supply capacity to service the authorised use described in SPEC02 (b)(i)(ii) and (iii) is not materially less than that which would have existed but for the operation of the Dewatering Works; and

(b) the bore owner does not suffer increased cost in the operation of the water supply following the implementation of restoration measures determined in SPEC 05.

SPEC 05 AGREEMENTS ON RESTORATION MEASURES

(1)

(a) If a pre-existing bore is unduly affected by the operation of the Dewatering Works then the licensee will agree with the bore owner appropriate restoration measures and carry out same. The licensee shall bear the cost of restoration measures.

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(2)


(b) Failure to reach agreement pursuant to SPEC 05(1)(a) will constitute a dispute between the licensee and the bore owner arising out of SPEC 04(1) and SPEC 04(2). The dispute may be referred by the parties, or either of them, to the Chief Executive.

If a dispute is referred to the Chief Executive, pursuant to SPEC 05(1 )(b) then the Chief Executive:

(a) may direct the licensee to provide to the reasonable satisfaction of the Chief Executive any data required in order to determine what restoration measures

are required;

(b) will reasonably determine what restoration measures are to be taken. Restoration

measures may include one or more of the following:

(3)

(i) Providing water by carting;

(ii) Deepening a pre-existing bore in the Sedimentary Undifferentiated, Tertiary, Permian, or Colinlea formations or surrounding geological formations;

(iii) Replacing a pre-existing bore;

(iv)Replacing or modifying existing water supply equipment;

(v) Providing a supply of an equivalent quantity of suitable quality water by piping from an alternative water source;

(vi) Providing a cash settlement to the bore owner; or

(vii) Other reasonable measures as may be agreed by the licensee and the bore owner.

Before making any determination or direction pursuant to SPEC 05(2), the Chief Executive will first reasonably consult with the licensee and the bore owner.

(4)

If the Chief Executive makes a determination pursuant to SPEC 05(2), the Chief Executive may proceed to amend the licence to give effect to the decision of the Chief Executive pursuant to SPEC 05(2).

SPEC 06 URGENT RESTORATION

(1)

If, in the reasonable opinion of the Chief Executive,

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(a) restoration measures agreed pursuant to SPEC 05(1)(a) or as determined pursuant to SPEC 05(2)(b), need to be carried out urgently to maintain an adequate supply of water, and

(b) the licensee is not responding with appropriate haste to carry out the restoration measures;

then the Chief Executive will issue a notice to the licensee directing the licensee to commence an appropriate program for implementation of restorations measures within forty-eight hours of receipt of the notice.

(2)

If, in the opinion of the Chief Executive, the licensee fails to adequately comply with a notice issued pursuant to SPEC 06(1), the Chief Executive will:

SPEC 07

(1)

(a) carry out the necessary restoration measures; and (b) notify the licensee of the cost of the restoration measures and

direct the licensee to reimburse the Chief Executive for the cost of the restoration measures

(c) The licensee shall pay to the Chief Executive the costs so notified.

MONITORING AND ASSESSMENT

The licensee shall provide to the Chief Executive a Performance Review Report in respect of the performance of the Alpha Coal Project Bulk Sample Pit Dewatering works and those monitoring bores as identified in the "Definitions" at the times stated in SPEC 08. Topics addressed in any Performance Review Report shall include:

(a)

(b)

(c)

(d)

(e)

(f)

(g)

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the monthly volume of water extracted from Dewatering Works;

any changes in water quality in the Dewatering Works and monitoring bores;

the piezometric levels on a quarterly basis in the Monitoring Bores;

an assessment of the need for adjustment of the model used to assess piezometric impact; details of any adjustment since the previous Performance Review Report to the model used to predict piezometric impact, and if adjustments have been made to the model, plans are to be provided showing:

the revised prediction, made using the adjusted model, of the total piezometric impact from the commencement of pumping to 20 years after the commencement of pumping or such other period as the Chief Executive may determine; and

the difference between these predicted piezometric impacts and the piezometric impacts as predicted at the time of application for licences for the Alpha Coal Project Bulk Sample Pit Dewatering Works as described in SPEC OB(f) below.

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(2)


(h) an assessment of any material departure of the performance of the Dewatering works (including piezometric impact) from the performance predicted for a withdrawal amount of 400 Megalitres per annum

(i) plans showing the piezometric impact caused by the operation of the Dewatering Works, using the then current model, are to be included in the next scheduled Performance Review Report pursuant to SPEC 08(1);

G) details of any pre-existing bores which are predicted by the then current model to become unduly affected by the Dewatering Works to be included in the next scheduled Performance Review Report; and

(k) details of any restoration measures carried out since the commencement of pumping if it is the first Performance Review Report or since the previous Performance Review Report, in respect of pre-existing bores unduly affected by the Dewatering works including details of piezometric drawdown, bore description and licence number

(a) In conjunction with the second Performance Review Report, the licensee will provide the Chief Executive with a Peer Review Report (PRR) of the model used by Hancock Coal Pty Limited to predict piezometric drawdown and associated impacts of the Dewatering Works. The peer review must be undertaken external to Hancock Coal Pty Limited and the models developing consultants. The PRR must at least review the following:

(i) the assumptions about the hydrogeology of the aquifers; (ii) impacts on the physical integrity of the aquifers; (iii) the ability of the geological formation to contain the

piezometric drawdown and impacts due to the extraction of the water;

(iv) any other matter the Chief Executive considers reasonable;

(b) The name and contact details of the reviewers who undertake the PRR in SPEC 07 (2)(a) must also be provided to the Chief Executive.

SPEC 08 FREQUENCY OF REPORTING

(1)

The first water year shall be defined as the period covering the period from the commencement of extraction (under the authority of this licence) of water from the Dewatering Works to the end of the next following June. Thereafter the water year shall commence on 1 July of any year and end on 31 June the year following. The first Performance Review Report shall cover the period as defined by the first water year. Thereafter scheduled Performance Review Reports shall then be provided in

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respect of the relative intervening periods, at the end of the 2"d, 3'd, 41h, 5th, yth and 1 01

h water years. The Chief Executive may call for a Performance Review Report at any other time during the currency of the Licence (unscheduled Performance Review Report) if he is of the reasonable opinion that the piezometric impact of the Dewatering Works is greater than the most recent prediction of piezometric impact reported by the licensee.

(2)

An unscheduled Performance Review Report will cover the period from the date of the immediately preceding Performance Review Report, be it an unscheduled or a scheduled Performance Review Report, and the date notified by the Chief Executive as the date of the unscheduled Performance Review Report, or such other period as the Chief Executive may determine. The scheduled Performance Review Report next following an unscheduled Performance Review Report will cover the period from the date of that unscheduled Performance Review Report and the date of the scheduled Performance Review Report.

(3)

A Performance Review Report will be due three months after the end of the relevant water year, or three months after notification of requirement of an unscheduled report.

(4)

The Chief Executive will advise the licensee of the acceptability of a Performance Review Report or Monitoring Report within 60 days of the date of receipt of same. If the Chief Executive reasonably considers a report unacceptable, he will notify the licensee in writing of the deficiencies. The licensee will then submit a further report within 60 days of such notification, or such longer period as determined by the Chief Executive and the same procedure shall be followed as with the original report.

SPEC 09

(1)

CLOSURE OF ALPHA COAL PROJECT BULK SAMPLE PIT OPERATIONS

One year prior to the closure of the operations, the licensee will:

(2)

(a) In the case of a pre-existing bore that has become unduly affected since the commencement of pumping from the Dewatering Works and where the restoration measures carried out by the licensee depend on matters beyond the control of the bore owner, enter into arrangements with the bore owner, to the reasonable satisfaction of the bore owner, to maintain a supply at the affected bore in accordance with SPEC 04(2);

(b) Provide to the Chief Executive a Alpha Coal Project Bulk Sample Pit Operation Pre-Closure Report

It shall be acceptable for the bore owner entering into an arrangement with the licensee pursuant to SPEC 09(1) to require that the arrangement reasonably provides the bore owner with independent control over restored water supply.

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(3)


The Alpha Coal Project Bulk Sample Pit Operation Pre-Closure Report pursuant to SPEC 09(1) shall contain:

(4)

(a) the piezometric levels in the Monitoring Bores and the Dewatering Works;

(b) an assessment of the need for adjustment of the model used to assess piezometric impact;

(c) details of any adjustment since the previous Performance Review Report to the model used to predict piezometric impact;

(d) details of any restoration measures carried out since the last Performance Review Report;

(e) plans showing the prediction, using the then current model, of the total piezometric impact from the commencement of pumping to 48 months after commencement of pumping;

(f) details of any unduly affected bores for which arrangements could not be successfully made pursuant to SPEC 12(1);

The Chief Executive will advise the licensee of the acceptability of the Alpha Coal Project Bulk Sample Pit Operation Pre-Closure Report within 60 days of the date of receipt of the same. If the Chief Executive considers the report unacceptable, he will notify the licensee in writing of the deficiencies. The licensee will then submit a further report within 30 days of such notification or such longer period as determined by the Chief Executive and the same procedure shall be followed as with the original report until the final report is reasonably accepted by the Chief Executive.

(5)

The licensee will fully implement arrangements pursuant to SPEC 09(1) at least 90 days before Alpha Coal Project Bulk Sample Pit Operation closure.

(6)

SPEC 09 will operate even if this licence has expired at the relevant time unless a licence is then in place and otherwise regulates closure.

SPEC 10 GENERAL PROVISIONS

(1)

The taking of water under the authority of this water licence is only permitted for the express purposes listed on this licence and only during the Alpha Coal Project Bulk Sample Pit mining operation authorised on MDL 285.

(2)

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This licence expires on the day stated in the licence, or the day stated in any subsequent renewal of the licence, or upon the closure of the mine referred to in SPEC 09.

End of Schedule B

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Williams, Melissa

From: Curley Peter [[email protected]]

Sent: Tuesday, 14 February 2012 9:39AM


Cc: Davison, Mike

Subject: RE: further comments on the Alpha RPS Report

Melissa

This following paragraphs should be added to DERM views on the RPS Report

cheers

Water Management:

Page 1 of2

In regard to proposals regarding site water management at page 7, true sediment dams (as opposed to environmental dams in disguise) need to be designed to effectively settle out the target suspended material -detention times and path being important. Environmental dams (including those in disguise) will need to have more overall volume than that suggested in the proposed conditions in this report, as well as commitments to monitoring and pumping with contingencies for wet weather. Volumes for environmental dams (and feasible locations) have yet to be specified -a critical matter for overall feasibiliity of the project.

Groundwater and TSF arrangements:

The report suggests at pages 8 & 9 that more advanced modelling is required 'prior to project approval'. Groundwater modelling is not my area of expertise and I had not previously looked at the details - except to note that an effective water balance for final void was not present. The latter will affect operational placement of tailings in pit. At present, there are no concepts and commitments regarding the design and operation of in-pit TSFs. Also, the final void should conservatively be confirmed as a long-term sink.

Irrespective of issues of recharge to recognised aquifers, the out-of-pit TSF is located in a position where shallow seepage could contribute to the nearby watercourse. For this reason, I do not agree with the proposition in this report that lining of that facility should be selective and or optional. Hancock Alpha need to commit to fully lining any out-of-pit facility with at least a competent engineered clay liner.

Diversions and Levees:

For purposes of potential hydraulic impacts of diversions only fiow events out to AEP 1 in 50 are assessed. As indicated previously in regard to this project (and in regard to the nearby Kevin's Corner), where diversions operate in conjunction with levees, those levees needs to be demonstrated to be robust in operation - in particular able to survive erosion to their design AEP which is typically rarer that AEP 1 in 1,000.

At pages 12 of the report it is indicated that unacceptably high average energy dissipations are predicted -particularly in the un-diverted channels downstream during flow events at and more frequent than AEP 1 in 50. Notably these relate to average velocities around 2 metres per second. At page 14 Table 3.2 the notes suggest that the ACARP stream power criterion is too high for natural channels.

Concepts for construction and monitoring to stabilise channels are nevertheless provided at page 15. However, in regard to comment later in the report on acceptable velocities at a culvert outletreproducing Table 4.1 (page 31), it is notable that 1.5 metres per second is acceptable over erodible soils and 2.5 rnetre per second over normal soils.

Figures of average velocity of 2 to 2.5 metres per second are cited in some publications as acceptable over well-grassed surfaces. However, it is the standard position of engineers from containment systems that well-grassed surfaces are wishful thinking on mine sites especially where erodible soils are involved. Sustainability will not be delivered beyond 1.5 metres per second without engineered protection.

The diversions for this project should be reviewed in the light of comments and discussion between


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DERM and the proponent to ensure that modified and affected watercourses and associated levees have adequate erosion protection to be sustainable for relevant design life.

Peter Curley Statewide Environmental Assessments Telephone 07 3330 5713 Facsimilie 07 3330 5754 Email: [email protected] Environment & Natural Resource Regulation Department of Environment and Resource Management 8/400 George Street, Brisbane 4000

GPO 2454, Brisbane 400 I

From: Curley Peter Sent: Monday, 13 February 2012 7:12 PM To: [email protected] Cc: [email protected] Subject: further comments on the Alpha RPS Report

Melissa Attached are some further comments from Gary Hargraves our engineer from Containment Systems. They include detailed comments on diversion design which may be useful.

Please add these to the previous document.

cheers

The information in this email together with any attachments is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. There is no waiver of any confidentiality/privilege by your inadvertent receipt of this material.

Any form of review, disclosure 1 modification, distribution and/or publication of this email message is prohibited, unless as a necessary part of Departmental business.

If you have received this message in error, you are asked to inform the sender as quickly as possible and delete this message and any copies of this message from your computer and/or your computer system network.


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Williams, Melissa

From:

Sent:

To:

Norrie Sanders [[email protected]]

Monday, 20 February 2012 7:35AM

Melissa Williams

Subject: todays meeting

Good morning Melissa

Page 1 of 1

is there an agenda for Todays meeting? If not, can you please confirm that the discussion will be about railway flooding? If there are other matters for discussion, it would be good to know in advance.

Cheers

Norrie


Norrie Sanders Principal- Env, Climate Change E [email protected] Wwww.rosgroup.com.au


This message (including any attachments) is intended for the use of the person or entity named above and may contain information that is private, confidential or privileged. If you are not the intended recipient you are not authorised to disclose, distribute, copy or use of this message. If you have received this communication in error, please contact the writer immediately on p: +61 7 3237 8899. Vv'hile RPS takes all reasonable precautions to ensure that its computer systems are free of viruses, it will not be liable for any loss, damage, liabirlty, or claim arising out of or 'Incidental to any damage to the computer system of a recipient of communications or documents originating from RPS and recipients receive communications from RPS at their own risk


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Williams, Melissa


Sent: Monday, 20 February 2012 8:59AM


Cc: Davison, Mike; Cameron, Stuart

Subject: RE: todays meeting

Good morning Norrie

A formal agenda for today hasn't been formulated. We have confirmed with Hancock a number of times that rail flooding is the only issue to be discussed. We made it very clear that if they wanted to discuss any other issues we would need plenty of notice to invite other RPS representatives.

Also, I can confirm that the meeting will finish at 1 pm, we have another meeting starting then. If you are able to arrive a few minutes before twelve, would be good to have a quick discussion before Hancock arrive, I understand that this may not be possible.

See you in a few hours.

Kind regards Melissa Williams Significant Projects Coordination Office of the Coordinator-General Department of Employment, Economic Development and In Queensland Government




From: Norrie Sanders [mailto:[email protected]] Sent: Monday, 20 February 2012 7:35AM To: Melissa Williams Subject: todays meeting

Good morning Melissa

is there an agenda for Todays meeting? If not, can you please confirm that the discussion will be about railway flooding? If there are other matters for discussion, it would be good to know in advance.

Cheers

Norrie

15/01/2013

Norrie Sanders Principal - Env, Climate Change E [email protected]


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W www.rosgroup.com.au


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This message (including any attachments) is intended for the use of the person or entity named above and may contain information that is private, confidential or privileged. If you are not the intended recipient you are not authorised to disclose, distribute, copy or use of this message. If you have received this communication in error, please contact the writer immediately on p: +61 7 3237 8899. Vv'hile RPS takes all reasonable precautions to ensure that its computer systems are free of viruses, it will not be liable for any loss, damage, liability, or claim arising out of or incidental to any damage to the computer system of a recipient of communications or documents originating from RPS and recipients receive communications from RPS at their own risk


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Williams, Melissa


Tuesday, 21 February 2012 2:40PM

Cc: Subject:

Davison, Mike; Cameron, Stuart DERM advice on RPS report

Attachments: DERM advice on RPS report to CoG 9feb12.pdf; Additon to DERM advice. pdf

Good afternoon and others Cc'd)

Please find attached for your information advice provided to our office by DERM on the RPS report (including recommended conditions) dated 23 December 2012.

The advice is provided as an initial document (dated 9 February) and additional comments (dated 14 February).

DERM advice on RPS report to C. ••

Additon to DERM advice. pdf





1

Sch. 4(3)(3)Sch. 4(3)(3)

Sch.4(3)(3)


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Department of Environment and Resource Management Advice on RPS Report to Coordinator General- Alpha Coal Project




The advice addresses the • Addendum to the Supplementary EIS (SEIS) • RPS Australia East Pty Ltd "Review of Selected Aspects of the (Alpha) EIS and





Groundwater

General comments






9 February 2012 1


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S(!ction Condition 3 .. 1 ,2.2 -proposed c~f1ditions modelling 2 ; • ·• • > •t .·.

Comments



Response


Sei:'l:i9n ¢qnditiol13.1.2.2.- proposed conditions recharge

Comments


Response


The mine footprint does not extend far enough west to intercept any GAB aquifers; therefore any impacts can only be from water draining from GAB aquifers (the clematis sandstone) into the aquifers of the Colin lea sandstones and bandanna formation. This would require a reduction in head in the Colinlea sandstone significant enough to induce· the transfer of water from the clematis through the Rewan formation and into the Colin lea sandstone. However the Rewan formation is recognised as a significant aquitard and does not contain any useable aquifers. Section N.3.3 of appe4ndix N in the SE/S v4 confirms that the Rewan has a very/ow permeability. Therefore it is not considered that there will be any threat to the Gab

9 February 2012 2

.


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~E!cti.ol"l S'!P~)tiql13..1,3,2_ -.P~OpOll,ed cql}~)tiprl~ grpy~d.:W~t.'%r.~c@!£rin!t .......•........ ·.·· Comments






Response


Sectiql} s()ri~ition 3.1,4;2 - propose~ corlditions .project water Sl!PPIY <) '

Comments


Response



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Creek Diversions







Preconstruction RPS and DERM have expressed the same concerns over the conflicting and at times, contradictory nature of the potential hydraulic conditions of the proposed diversions and indeed, their potential impact on the existing downstream hydraulic conditions of all watercourses. In light of these results, DERM cannot fully support the pre-construction condition relating to the approval of current diversion plans. Any impact from diversions upstream and downstream on the diverted watercourse should be minimal if at all. DERM does not specify the length of watercourse to review upstream or downstream from the confluence point with a diversion.


9 February 2012 4


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s~cti()n c;:qnflition 3}2" prppqsedcollditions pr~ cC!nstrUI5tioi'J'

Comments

'<-',' '''<<•¥<'<



Response






The monitoring program should include the Index of Diversion Condition, as outlined in the ACARP Project C9068, which has been widely adopted within the Bowen Basin for the monitoring of watercourses and stream diversions .

Section C:6ndition 3o2:2 " monitoring /\<<,-,,;;f'">i> /J,<''<',::,>--<'-<,>i'--i/,,','/,'/,''<''/Je>, h ',"' <, ,,,,,, ,,, ,, ,',',<-'-.-','' ', ••••• .•.•. •.. ·.·•••• 'J •··••··· ...•. / .. 2 • ;·;· '· . Comments


Response


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Additional Comments


General Comment- cumul.ative impact on watercourses and diversions ···•··•.••.•· < · Comments


Response


Vegetation (rail)


Section 4.1.2 Vegetation Management contains recommendations/conditions that may not be compatible with DERM decision making including the following specific passages (as highlighted): "The offsets identified must be legally secured as outlined under Criteria 4: Policy for Vegetation Management Offsets (Version :::; t;l illi llil11 prior to the area required for the development being cleared.

Where possible, the clearing of native vegetation within road IHUllCH the Width Of the ~~~

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Annexure A

Recital A

Hancock Coal Ply Limited

Hancock Coal Pty Limited (hereinafter "the licensee") is the owner of property described on the Licence, upon which it operates the Alpha Coal Project. The licensee will construct works (comprising works that take groundwater from a bore, shaft or sump pump within MDL 285) accessing the Sedimentary Undifferentiated Formation. These works are referred to as the Dewatering Works.






DEFINITIONS




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"Monitoring Bores" means the monitoring bores as identified in Bulk Sample Pit Groundwater Monitoring Program, June 2010, JBT Consulting Ply Ltd. and any subsequently drilled bores for monitoring purposes;





INTERPRETATION

In this Licence:

(a)

{b)

(c) NOTICES



(a) Form of Notice


(i) (ii)

9 February 2012


8


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(iii)




Licensee: Hancock Coal Pty Limited GPO Box963 BRISBANE QLD 4001




SPEC 01

(1) Existing bores





(2) Future bores


9 February 2012

(i) (ii)


9


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SPEC 02









(b) (i) in the case of a bore used to supply domestic water,

shall mean, a reduction in the ability of the bore to supply water for domestic requirements as authorised under the Water Act 2000

(ii) in the case of a bore used to supply stock water as authorised under the Water Act 2000, shall mean, any material reduction in the number of stock able to be watered, having regard to the stock carrying capacity of the land serviced by the pre-existing bore, including seasonal variations in the stock carrying capacity of that land;

(iii) in the case of a bore used to supply water for another purpose under the authority of the Water Act 2000, a material reduction in the pumping supply required for the purpose, as reasonably assessed by the Chief Executive after consultation between the Chief

9 February 2012 10


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SPEC 03



(1)


(2)







(1)


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(2)



If a dispute is referred to the Chief Executive, pursuant to SPEC 05(1)(b) then the Chief Executive:


are required;



(3)


(ii) Deepening a pre-existing bore in the Undifferentiated, Tertiary, Permian, or Colinlea surrounding geological formations;


Sedimentary formations or






(4)



(1)


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(a) restoration measures agreed pursuant to SPEC 05(1 )(a) or as determined pursuant to SPEC 05(2)(b), need to be carried out urgently to maintain an adequate supply of water, and



(2)

If, in the opinion of the Chief Executive, the licensee fails to adequately comply with a notice issued pursuant to SPEC 06(1 ), the Chief Executive will:

SPEC 07

(1)






(a)

(b)

(c)

(d)

(e)

(f)

(g)

9 February 2012



the piezometric levels on a quarterly basis in the· Monitoring Bores;



the difference between these predicted piezometric impacts and the piezometric impacts as predicted at the time of application for licences for the Alpha Coal Project Bulk Sample Pit Dewatering Works as described in SPEC 08(f) below.

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(2)



(i) plans showing the piezometric impact caused by the operation of the Dewatering Works, using the then current model, are to be included in the next scheduled Performance Review Report pursuant to SPEC 08(1 );

0) details of any pre-existing bores which are predicted by the then current model to become unduly affected by the Dewatering Works to be included in the next scheduled Performance Review Report; and








(1)


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respect of the relative intervening periods, at the end of the 2"ct, 3'ct, 4th, 51h, 7'h and

1Oth water years. The Chief Executive may call for a Performance Review Report at any other time during the currency of the Licence (unscheduled Performance Review Report) if he is of the reasonable opinion that the piezometric impact of the Dewatering Works is greater than the most recent prediction of piezometric impact reported by the licensee.

(2)


(3)


(4)

The Chief Executive will advise the licensee of the acceptability of a Performance Review Report or Monitoring Report within 60 days of the date of receipt of same. If the Chief Executive reasonably considers a report unacceptable, he will notify the licensee in writing of the deficiencies. The licensee will then submit a further report within 60 days of such notification, or such longer period as determined by the Chief Executive arid the same procedure shall be followed as with the original report.

SPEC 09

(1)



(2)


· (b) Provide to the Chief Executive a Alpha Coal Project Bulk Sample Pit Operation Pre-Closure Report


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(3)



(4)







· The Chief Executive will advise the licensee of the acceptability of the Alpha Coal Project Bulk Sample Pit Operation Pre-Closure Report within 60 days of the date of receipt of the same. If the Chief Executive considers the report unacceptable, he will notify the licensee in writing of the deficiencies. The licensee will then submit a further report within 30 days of such notification or such longer period as determined by the Chief Executive and the same procedure shall be followed as with the original report until the final report is reasonably accepted by the Chief Executive.

(5)


(6)


SPEC 10 GENERAL PROVISIONS

(1)


(2)

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End of Schedule B

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Williams, Melissa

Subject: FW: further comments on the Alpha RPS Report

From: Curley Peter [mailto:[email protected]] Sent: Tuesday, 14 February 2012 9:39AM To: Williams, Melissa Cc: Davison, Mike Subject: RE: further comments on the Alpha RPS Report

Melissa


cheers

Water Management:

Page 1 of2

In regard to proposals regarding site water management at page 7, true sediment dams (as opposed to environmental dams in disguise) need to be designed to effectively settle out the target suspended material- detention times and path being important. Environmental dams (including those in disguise) will need to have more overall volume than that suggested in the proposed conditions in this report, as well as commitments to monitoring and pumping with contingencies for wet weather. Volumes for environmental dams (and feasible locations) have yet to be specified- a critical matter for overall feasibiliity of the project.


The report suggests at pages 8 & 9 that more advanced modelling is required 'prior to project approval'. Groundwater modelling is not my area of expertise and I had not previously looked at the details - except to note that an effective water balance for final void was not present. The latter will affect operational placement of tailings in pit. At present, there are no concepts and commitments regarding the design and operation of in-pit TSFs. Also, the final void should conservatively be confirmed as a long-term sink.

Irrespective of issues of recharge to recognised aquifers, the out-of-pit TSF is located in a position where shallow seepage could contribute to the nearby watercourse. For this reason, I do not agree with the. proposition in this report that lining of that facility should be selective and or optional. Hancock Alpha need to commit to fully lining any out-of-pit facility with at least a competent engineered clay liner.


For purposes of potential hydraulic impacts of diversions only flow events out to AEP 1 in 50 are assessed. As indicated previously in regard to this project (and in regard to the nearby Kevin's Corner), where diversions operate in conjunction with levees, those levees needs to be demonstrated to be robust in operation -in particular able to survive erosion to their design AEP which is typically rarer that AEP 1 in 1,000.

At pages 12 of the report it is indicated that unacceptably high average energy dissipations are predictedparticularly in the un-diverted channels downstream during flow events at and more frequent than AEP 1 in 50. Notably these relate to average velocities around 2 metres per second. At page 14 Table 3.2 the notes suggest that the ACARP stream power criterion is too high for natural channels.

Concepts for construction and monitoring to stabilise channels are nevertheless provided at page 15. However, in regard to comment later in the report on acceptable velocities at a culvert outlet -reproducing Table 4.1 (page 31), it is notable that 1.5 metres per second is acceptable over erodible soils and 2.5 metre per second over normal soils.



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The diversions for this project should be reviewed in the light of comments and discussion between DERM and the proponent to ensure that modified and affected watercourses and associated levees have adequate erosion protection to be sustainable for relevant design life.

Peter Curley Statewide Environmental Assessments Telephone 07 3330 5713 Facsimilie 07 3330 5754 Email: [email protected] Environment & Natural Resource Regulation Department of Environment and Resource Management 8/400 George Street, Brisbane 4000 GPO 2454, Brisbane 4001


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Williams, Melissa


Tuesday, 21 February 2012 2:41 PM 'Norrie Sanders'

Cc: Subject:

Cameron, Stuart; Davison, Mike DERM advice on RPS report

Attachments: DERM advice on RPS report to CoG 9feb12.pdf; Additon to DERM advice. pdf


Please find attached for your information advice provided to our office by DERM on RPS's 'recommended conditions report' dated 23 December 2012.

The advice is provided as an initial document (dated 9 February) and additional comments (dated 14 February).

DERM advice on RPS report to C. ..

Additon to DERM advice. pdf





1


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The advice addresses the • Addendum to the Supplementary EIS (SEIS) • RPS Australia East Pty Ltd "Review of Selected Aspects of the (Alpha) EIS and





Groundwater

General comments






9 February 2012 I


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Section Condition3.1.2.2- proposed conditions modelling

Comments



Response


Section Condition 3.1.2.2 - proposed conditions recharge

Comments


Response


The mine footprint does not extend far enough west to intercept any GAB aquifers; therefore any impacts can only be from water draining from GAB aquifers (the clematis sandstone) into the aquifers of the Colin lea sandstones and bandanna formation. This would require a reduction in head in the Colinlea sandstone significant enough to induce the transfer of water from the clematis through the Rewan formation and into the Colinlea sandstone. However the Rewan formation is recognised as a significant aquitard and does not contain any useable aquifers. Section N.3.3 of appe4ndix N in the SEIS v4 confirms that the Rewan has a very low permeability. Therefore it is not considered that there will be any threat to the Gab

9 February 2012 2


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Section Condition 3.1.3.2 - proposed conditions groundwater monitoring

Comments






Response


Section Condition 3.1.4.2 - proposed conditions project water supply

Comments


Response



9 February 2012 3


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Creek Diversions







Preconstruction RPS and DERM have expressed the same concerns over the confiicting and at times, contradictory nature of the potential hydraulic conditions of the proposed diversions and indeed, their potential impact on the existing downstream hydraulic conditions of all watercourses. In light of these results, DERM cannot fully support the pre-construction condition relating to the approval of current diversion plans. Any impact from diversions upstream and downstream on the diverted watercourse should be minimal if at all. DERM does not specify the length of watercourse to review upstream or downstream from the confluence point with a diversion.


9 February 2012 4


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Section Condition 3.2.2 -proposed conditions pre construction

Comments

.



Response






The monitoring program should include the Index of Diversion Condition, as outlined in the ACARP Project C9068, which has been widely adopted within the Bowen Basin for the monitoring of watercourses and stream diversions.

Section Condition 3.2.2 -monitoring .

Comments


Response


9 February 2012 5


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Additional Comments


General Comment- cumulative impact on watercourses and diversions

Comments


Response


Vegetation (rail)


Section 4.1.2 Vegetation Management contains recommendations/conditions that may not be compatible with DERM decision making including the following specific passages (as highlighted): 'The offsets identified must be legally secured as outlined under Criteria 4: Policy for

Vegetation Management Offsets (Version ~ '(i)llii t tn lni prior to the area required for the development being cleared.

Where possible, the clearing of native vegetation within road or not reduce the width of the ve!Jetaticm

9 February 2012 6


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Annexure A

Recital A

Hancock Coal Pty Limited

Hancock Coal Ply Limited (hereinafter "the licensee") is the owner of property described on the Licence, upon which it operates the Alpha Coal Project. The licensee will construct works (comprising works that take groundwater from a bore, shaft or sump pump within MDL 285) accessing the Sedimentary Undifferentiated Formation. These works are referred to as the Dewatering Works.






DEFINITIONS




9 February 2012 7


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"Monitoring Bores" means the monitoring bores as identified in Bulk Sample Pit Groundwater Monitoring Program, June 2010, JBT Consulting Ply Ltd. and any subsequently drilled bores for monitoring purposes;





INTERPRETATION

In this Licence:

(a)

(b)


(c) NOTICES


(a) Form of Notice


(i) (ii)

9 February 2012


8


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(iii)




Licensee: Hancock Coal Pty Limited GPO Box 963 BRISBANE QLD 4001




SPEC 01

(1) Existing bores





(2) Future bores


9 February 2012

(i) (ii)


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SPEC 02









(b) (i) in the case of a bore used to supply domestic water,

shall mean, a reduction in the ability of the bore to supply water for domestic requirements as authorised under the Water Act 2000

(ii) in the case of a bore used to supply stock water as authorised under the Water Act 2000, shall mean, any material reduction in the number of stock able to be watered, having regard to the stock carrying capacity of the land serviced by the pre-existing bore, including seasonal variations in the stock carrying capacity of that land;

(iii) in the case of a bore used to supply water for another purpose under the authority of the Water Act 2000, a material reduction in the pumping supply required for the purpose, as reasonably assessed by the Chief Executive after consultation between the Chief

9 February 2012 10


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SPEC 03



(1)


(2)







(1)


9 February 2012 11


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(2)



If a dispute is referred to the Chief Executive, pursuant to SPEC 05(1)(b) then the Chief Executive:


are required;



(3)


(ii) Deepening a pre-existing bore in the Sedimentary Undifferentiated, Tertiary, Permian, or Colinlea formations or surrounding geological formations;







(4)



(1)


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(a) restoration measures agreed pursuant to SPEC 05(1)(a) or as determined pursuant to SPEC 05(2)(b), need to be carried out urgently to maintain an adequate supply of water, and



(2)

If, in the opinion of the Chief Executive, the licensee fails to adequately comply with a notice issued pursuant to SPEC 06(1), the Chief Executive will:

SPEC 07

(1)






(a)

(b)

(c)

(d)

(e)

(f)

(g)

9 February 2012



the piezometric levels on a quarterly basis in the Monitoring Bores;



the difference between these predicted piezometric impacts and the piezometric impacts as predicted at the time of application for licences for the Alpha Coal Project Bulk Sample Pit Dewatering Works as described in SPEC 08(f) below.

13


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(2)



(i) plans showing the piezometric impact caused by the operation of the Dewatering Works, using the then current model, are to be included in the next scheduled Performance Review Report pursuant to SPEC 08(1 );

0) details of any pre-existing bores which are predicted by the then current model to become unduly affected by the Dewatering Works to be included in the next scheduled Performance Review Report; and








(1)


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respect of the relative intervening periods, at the end of the 2"d, 3'd, 41", 51", 7'" and 1 o'" water years. The Chief Executive may call for a Performance Review Report at any other time during the currency of the Licence (unscheduled Performance Review Report) if he is of the reasonable opinion that the piezometric impact of the Dewatering Works is greater than the most recent prediction of piezometric impact reported by the licensee.

(2)


(3)


(4)

The Chief Executive will advise the licensee of the acceptability of a Performance Review Report or Monitoring Report within 60 days of the date of receipt of same. If the Chief Executive reasonably considers a report unacceptable, he will notify the licensee in writing of the deficiencies. The licensee will then submit a further report within 60 days of such notification, or such longer period as determined by the Chief Executive and the same procedure shall be followed as with the original report.

SPEC 09

(1)



(2)


(b) Provide to the Chief Executive a Alpha Coal Project Bulk Sample Pit Operation Pre-Closure Report


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(3)



(4)







The Chief Executive will advise the licensee of the acceptability of the Alpha Coal Project Bulk Sample Pit Operation Pre-Closure Report within 60 days of the date of receipt of the same. If the Chief Executive considers the report unacceptable, he will notify the licensee in writing of the deficiencies. The licensee will then submit a further report within 30 days of such notification or such longer period as determined by the Chief Executive and the same procedure shall be followed as with the original report until the final report is reasonably accepted by the Chief Executive.

(5)


(6)


SPEC10 GENERAL PROVISIONS

(1)


(2)

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End of Schedule B

9 February 2012 17


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Williams, Melissa

Subject: FW: further comments on the Alpha RPS Report

From: Curley Peter [mailto:[email protected]] Sent: Tuesday, 14 February 2012 9:39AM To: Williams, Melissa Cc: Davison, Mike Subject: RE: further comments on the Alpha RPS Report

Melissa


cheers

Water Management:

Page 1 of2

In regard to proposals regarding site water management at page 7, true sediment dams (as opposed to environmental dams in disguise) need to be designed to effectively settle out the target suspended material -detention times and path being important. Environmental dams (including those in disguise) will need to have more overall volume than that suggested in the proposed conditions in this report, as well as commitments to monitoring and pumping with contingencies for wet weather. Volumes for environmental dams (and feasible locations) have yet to be specified -a critical matter for overall feasibiliity of the project.


The report suggests at pages 8 & 9 that more advanced modelling is required 'prior to project approval'. Groundwater modelling is not my area of expertise and I had not previously looked at the details- except to note that an effective water balance for final void was not present. The latter will affect operational placement of tailings in pit. At present, there are no concepts and commitments regarding the design and operation of in-pit TSFs. Also, the final void should conservatively be confirmed as a long-term sink.

Irrespective of issues of recharge to recognised aquifers, the out-of-pit TSF is located in a position where shallow seepage could contribute to the nearby watercourse. For this reason, I do not agree with the proposition in this report that lining of that facility should be selective and or optional. Hancock Alpha need to commit to fully lining any out-of-pit facility with at least a competent engineered clay liner.


For purposes of potential hydraulic impacts of diversions only flow events out to AEP 1 in 50 are assessed. As indicated previously in regard to this project (and in regard to the nearby Kevin's Corner), where diversions operate in conjunction with levees, those levees needs to be demonstrated to be robust in operation- in particular able to survive erosion to their design AEP which is typically rarer that AEP 1 in 1,000.

At pages 12 of the report it is indicated that unacceptably high average energy dissipations are predictedparticularly in the un-diverted channels downstream during flow events at and more frequent than AEP 1 in 50. Notably these relate to average velocities around 2 metres per second. At page 14 Table 3.2 the notes suggest that the ACARP stream power criterion is too high for natural channels.

Concepts for construction and monitoring to stabilise channels are nevertheless provided at page 15. However, in regard to comment later in the report on acceptable velocities at a culvert outlet -reproducing Table 4.1 (page 31), it is notable that 1.5 metres per second is acceptable over erodible soils and 2.5 metre per second over normal soils.



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The diversions for this project should be reviewed in the light of comments and discussion between DERM and the proponent to ensure that modified and affected watercourses and associated levees have adequate erosion protection to be sustainable for relevant design life.

Peter Curley Statewide Environmental Assessments Telephone 07 3330 5713 Facsimilie 07 3330 5754 Email: [email protected] Environment & Natural Resource Regulation Department of Environment and Resource Management 8/400 George Street, Brisbane 4000 GPO 2454, Brisbane 4001


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Williams, Melissa

From: Sent: To: Cc: Subject:

Mike

Issue 1

Curley Peter [[email protected]] Tuesday, 28 February 2012 4:21 PM Davison, Mike Williams, Melissa; Cameron, Stuart Alpha EIS/SEIS- 2 issues

DERM officers are seeking Alpha's response to the RPS Report particularly on groundwater and diversions, and TSF. Is there a response in writing and can we have a copy now? We are preparing a list of further information required for DERM to support any progression to a CG Report (ie end of EIS process). The spreadsheets supplied by Alpha are not likely to be adequate. Happy to discuss before next Monday's regular Alpha meeting. In Brisbane Thursday and free AM.

Issue 2 Rail ERA's can't be further negotiated until we know the exact location in relation to noise and water discharges. We need to know how the CG Report will refer to the interim (draft?) ERA's so that some words can be concocted on these issues (std conditions are for no noise and no water discharges which can be ammended once ERA's are applied for - not acceptable to Alpha) . Suggest a brief discussion and follow up email is required on this before next Mondays Alpha meeting. They intend raising this issue.

cheers


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Williams, Melissa


Tuesday, 28 February 2012 4:29PM 'Curley Peter'

Cc: Subject:

Cameron, Stuart; Davison, Mike; McDonnell, Damian RE: Alpha EIS/SEIS- 2 issues

Hi Peter (and others)

Mike's gone for the afternoon. I'd suggest it would be best for us to get together Thursday morning to discuss, before next Monday's meeting.

We don't have anything in writing from Hancock re response to the RPS report yet, but have been told to expect it 'very soon•.

I've tentatively booked a meeting room 10.30-11.30, will send a meeting request (assuming this time works for everyone) tomorrow.

Cheers

Melissa Williams Significant Projects Coordination Office of the Coordinator-General Department of Employment 1 Economic Development and Innovation Queensland Government




-----Original Message-----From: Curley Peter [mailto:[email protected]] Sent: Tuesday, 28 February 2012 4:21 PM To: Davison, Mike Cc: Williams, Melissai Cameron, Stuart Subject: Alpha EIS/SEIS - 2 issues

Mike

Issue 1 DERM officers are seeking Alpha's response to the RPS Report particularly on groundwater and diversions, and TSF. Is there a response in writing and can we have a copy now? We are preparing a list of further information required for DERM to support any progression to a CG Report (ie end of EIS process). The spreadsheets supplied by Alpha are not likely to be adequate. Happy to discuss before next Monday's regular Alpha meeting. In Brisbane Thursday and free AM.

Issue 2 Rail ERA's can't be further negotiated until we know the exact location in relation to noise and water discharges. We need to know how the CG Report will refer to the interim (draft?) ERA's so that some words can be concocted on these issues (std conditions are for no noise and no water discharges which can be ammended once ERA's are applied for - not acceptable to Alpha). Suggest a brief discussion and follow up email is required on this before next Mondays Alpha meeting. They intend raising this issue.

cheers

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The information in this email together with any attachments is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. There is no waiver of any confidentiality/privilege by your inadvertent receipt of this material. Any form of review 1 disclosure 1 modification 1 distribution and/or publication of this email message is prohibitedr unless as a necessary part of Departmental business. If you have received this message in error 1 you are asked to inform the sender as quickly as possible and delete this message and any copies of this message from your computer and/or your computer system network.

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Williams, Melissa

From: Sent:

Curley Peter [[email protected]] Thursday, 15 March 2012 9:34AM

To: Davison, Mike Cc: Subject:

Cameron, Stuart; Williams, Melissa RE: HCPL Feedback on RPS Report

Mike Will do. Happy to discuss in a week or so.

cheers

From: Davison, Mike [mailto:[email protected]] Sent: Wed 14/03/2012 1:24 PM To: Curley Peter Cc: Cameron 1 Stuart; Williams, Melissa Subject: FW: HCPL Feedback on RPS Report

Hi Peter, We will need to get DERM's comments on this. They are in response to RPS submission. Comments from lOAP to 10 BD relate to vegetation clearing along the rail corridor, Section 4 of the RPS report.

lOBI to lOBS relate to Section 4.2 of the RPS report, Creek and River crossings.

Can you pass this onto the relevant DERM people to get their comments.

We may need to discuss between us prior to talking to Hancock.

Cheers

Mike

From: Cameron, Stuart Sent: Wednesday, 14 March 2012 8:48 AM To: Davison 1 Mike Cc: McDonnell, Damian Subject: FW: HCPL Feedback on RPS Report

for your reference

Stuart Cameron Project Manager Significant Projects Coordination Office of the Coordinator-General Department of Employment, Economic Development and Innovation Queensland Government tel +61 7 3227 7459 mob post PO Box 15517 City East Qld 4002 visit Level 4, 63 George Street, Brisbane

From: Sent: Tuesday, 13 March 2012 6:02 PM To: Cameron, Stuart

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Cc: Subject: HCPL Feedback on RPS Report

Good afternoon Stuart,

Attached letter and comments on the Rail vegetation and flooding recommendations which are contained in the RPS Report. We note that the flooding proposals were discussed in detail in the meeting of 20 February between CG, RPS and Hancock.

I understand that you are still involved in the Hancock report, however I may need to re-direct this to other in the Coordinator Generals Team. Please let me know by return email who should receive the letter.

Regards

Hancock Coal Pty Ltd

This email (including all attachments) may contain personal information that is intended solely for the named addressee. It is confidential and may be subject to legal or other professional privilege. Any confidentiality or privilege is not waived or lost because this email has been sent to you by mistake. Any personal information in this email must be handled in accordance with the Privacy Act 1988 (Cth). Any unauthorised use of the contents is expressly prohibited. If you have received this email in error, please let us know by reply email, delete it from your system and destroy any copies. Before opening or using attachments, check them for viruses and defects. It is the responsibility of the recipient to ensure that it is virus free and no responsibility is accepted by us for any loss or damage arising in any way from its use. Our liability is limited to re-supplying the email . This email and any attachments are also subject to copyright. No part of them may be reproduced, adapted or transmitted without the written permission of the copyright owner.

********************************DISCLAIMER**************************** The information contained in the above e-mail message or messages (which includes any attachments) is confidential and may be legally privileged. It is intended only for the use of the person or entity to which it is addressed. If you are not the addressee any form of disclosure, copying, modification, distribution or any action taken or omitted in reliance on the information is unauthorised. Opinions contained in the message(s) do not necessarily reflect the opinions of the Queensland Government and its authorities. If you received

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From: Melissa Williams [mailto:[email protected]] Sent: Wednesday, December 14, 201111:24 AM To: David Finney Cc: Mike Davison; Stuart cameron; Norrie Sanders Subject: Re: Hancock response to RPS request for outstanding Information

Good morning David


Please find attached Hancock's response to Norrie's request for further information beyond the Alpha Coal Project SEIS and SEIS Addendum (via email, 14 November- see below)





tel +61 7 3836 0667 (ext 60667) e [email protected] post PO Box 15517, City East Q 4002 visit level 4, 63 George Street, Brisbane Q 4000 www.deedi.gld.oov.au

Tomorrow's Queensland: strong, green, smart, healthy and fairwww-.toward02.qld.gov.au

Plea•e consider the cnvironmo~t before pnnt1ng this email

FromSent: Tuesday, 13 December 2011 4:06 PM To: Melissa Williams Cc: Subject: Hancock response to RPS request for outstanding information

Dear Melissa,



Thank you.

Kind Regards,

Hancock Coal Ply ltd levelS, 307 Queen Street

15/01/2013

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Brisbane OLD 4000

Website: www.hancockcoal.com_au

.J:J Please consider the environment before printing this email.

From

Sent: Friday, 2December201 I 10:54 AM


Cc: Mike Davison;

Subject: RPS Responses· delay

Hi Melissa,

Page 2 of5

Just to let you know that the responses to RPS are taking longer than anticipated so they will not be coming your way this week. I am waiting on the response time from PB who are looking at the surface water questions and \~ill get back to you once this has come through.

Regards

From:Sent: Monday, 14 November 2011 5:11PM To: Melissa Williams; Cc: Mike Davison; Subject: RE: RPS requests_Aipha SEIS

Thank you for \his.

please can you action galhering the information requested by Norrie.


Hancock Coal Ply Ltd Leve13, 60 Albert Street Brisbane OLD 4000

Website: www.llancockcoal.com.au

.Ji Please consider the environmenl before printing this email.

From: Mellssa Williams [mailto:[email protected]] Sent: Monday, 14 November 2011 5:07PM To: Cc:Subject: RPS requests_Aipha SEIS

Good afternoon

Following our meeting this afternoon I received an email from Norrie Sanders (RPS) detailing requests for further information to allow completion of relevant sections of their conditioning report.

I believe these were in line wilh discussions you had with Norrie during the site visit last week.



tel +61 7 3836 0567 {ext 60567} e [email protected] post PO Box 15517, City East Q 4002 visit Level 4, 63 George Street, Brisbane Q 4000 www.deedi.gtd.gov.au

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P!oo$C ronsidor the environment l>c!crc ptinbn~ this em oil

From: Norrie Sanders [mailto:[email protected]] Sent: Monday, 14 November 20111:45 PM To: Melissa Williams Subject: outstanding information

Hi Melissa

Page 3 of5

Below is a summary of outstanding items which would help us to complete the conditions report. I have omitted reference to mine groundwater, tailings dam and rail flooding because both topics are under active assessment by Hancock. The information that I alluded to during the field trip to Alpha were based on our second review report {EIS and SEIS), extracts of which are included below. My conversation with mainly covered the creek analysis, but I have added other mine information for completeness.


Creek diversion: o add pre development curve to stream power graphs (B-8 and B-9) o Provide commentary on physical impacts on creeks where post development hyrdaulic parameters exceed current condition and/or A CARP guidelines- particularly

upstream and downstream of diversions. Stability risks in 050 are acknowledged but not specifically assessed or solutions proposed. o No flood inundation mapping is provided in the SEIS for the 2 year and 50 year ARI events. The flood report includes intermediate (5, 10, 20 year) flood flows but does


a Comparative statistics on channel morphology pre and post diversion are not presented. Geomorphic features that mimic current morphology, such as terraces, meanders, wetlands, pools etc are not explicitly considered. Impacts on channel networks, floodplain conneclivlty, pools, Jakes and palustrine wetlands are absent.


Landfonn and rehabilition: see table below

Mine water balance -Issues and recommendations

Jssue Comment Actions Discharges to Lagoon The quantity and quality of discharges to Use daily water balance Creek- aggregated lagoon creek are not specified other than modelling to asses discharge outputs from water discharge criteria. The mine water risk under different event modelling do not provide a balance needs to be further analysed to scenarios using daily time sufficient basis for demonstrate that there is sufficient step. assessing risks and storage and treatment capacity to allow evaluating management adherence to the standards under specific Consider design and arrangements even conditions. management arrangements to



been allowed for sediment storage in the the proposed sediment storage allowance for the

sediment dams. This may not be sediment dams needs to be sufficient for the volume of sediment included in the EIS. This will 2.3.1 Sediment Dams was hoff from the overburden which will depend on the catchment

contain dispersive soils. If too small, the sediment dams will fil! with sediment area, erodibility of the material

quickly, and overflows to lagoon Creek and life of dam. The rate of sediment removal needs to be

may be more frequent that anticipated. assessed. 3.1 Climate Data Figure 3-2 is said to be a log Pearson Ill Amend text.

probability distribution. 1t appears to be an exceedence plot, not a frequency distribution plot. It would be useful to see flow duration curves for the estimated and recorded

3.5.1 Sacramento Model flows to provide more information on the Provide more infonnation on goodness of fit of this calibrated modeL model calibration The model's ability to reproduce !ow flows mav be imoortant in this context.


3.5.2 Catchment yields catchment yields came from for different information (e.g. references) to justify the choice of

land use activities. catchment vield 4.4 Dirty Water The proposed release points should be Clarification of the locations of Management System. shown on a plan. Table 4-1 gives the co- the sediment dam discharge

ordinates only. The table lists the release points is required. Sediment Dam discharge points as SD1a, SD2b, SD4b, and SD6b. points. However these do not appear on the

accompanying figures 4-1 to 4-5. Sediment dam capacities should be able The 10% AEP 24 hour rainfall to hold the 10%AEP 24 hour storm runoff depths should be tabulated



5.5.2 Haul Road and suppression might be significantly !ower this way dust suppression Hardstand watering than the volume listed in the report. As requirements would be less

this demand is a significant component of during wet years. the Iota! demand, a !ower demand may lead to more frequent overflow of the final sediment dams.

Figure 4.6 GoldSim This is meant as a schematlc diagram of Prepare a schematic diagram network diagram. the water management system. It is a preferably overlaid on

Go!dSim output and is very confusing. background plan to show approximate location of sediment dams, environmental dams and discharge points.

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Wt as e roc kl ssues an d recommen • r a tons


Kinetic testing to date is The AMD potential of raw coal and tamngs column testing to further investigate limited and outcomes only is not yet confirmed and further kinetic Temporal saline and preliminary at this stage testing is required. acidic/metaliferous drainage

characteristics. 1t is recommended that further work is carried out to confirm dosing rates

Coarse coal rejects and Preliminary trial alkaline treatment efficacy

during final design stage and these roof and floor waste rock are confirmed in the live MlfvM.P. appear to have the highest has been undertaken on coarse reject

Similar work should be carried out AP. and coal seam roof and floor material. on representative tailings materials If

further leach~t!!;sting confirms of concern AMO tential. Seepage fate risk is to be


considerations generation potential and low to moderate modelling for initial out of pit TSF saline leachate potential and in pit disposal. This should be

conditioned in the EA

WRO capping strategy must recognize the Mining scheduling to recognize the goal of final placement of low

high risk associated with placement of dispersion overburden cap Presence of dispersive dispersive and highly dispersive (sandstones, tuff} where possible. overburden and soilsfclays- overburden within the final cover. This should be an EM Plan Final landform Design commitment and EA condition. implications Stripping depths of low or nil dispersive MVVMP should also include


materials. Bring fotward development of the

EIS commits to preparation of a final void final void water quality model to the Final void water quality water quality mode! by year 5 of EM Plan OR approval conditions to

operatlons. provide for adequate worst case manaaement strateaies

L df '" orman d h bTt r " ' I I a 10n: ISSUeS an d d f recommen a 10ns Issue Comment Action

OERM's mandatory requirements and Consider Landform Design and How is Mine Closure guidelines (e.g. 18) will apply to the Rehabilitation, t:A 1998, Centre Planning addressed? rehabilitation strategy {25.1.213) but for Land Rehabilitation research,

no word on industrv-:based initiatives ORCetc. Explain what will be done

EIS proposes fairly standard post differently. mine land classification, final landform plan, topsoll management and revegetation (25.1 ). \ftlhat (similar) mine has achieved these?

Mine wastes are largely sadie I dispersive {Appx J1 7) and Discuss M\1\rMP experience with encapsulation is proposed (16.6.3.1, test pit with HPPLI Thiess and 25.1.8andAppxJ1 &7.1.5) then provide mine planning A Mine Waste Management Plan details of how selective (MWMP} is in place for the test pit and encapsulation wit! occur white commitments have been made (SEtS operating differing mine methods AppxD1.16.2} (IPCC draglines, truck f shovel)

How, in practical terms, wl!l in different parts of the mine. rehabilita\lon be met?



Riparian vegeta;i~n is .~loposed along Supply more details


Rehabilitation Success Criteria {Table diversions, levees, sediment Rehabilitation criteria should dams, roads, water storages, address the entire mine? P47) should address 'other mine camp, quarry, landfilL Also infrastructure' modify Monitoring (Table P48) if

re~Uired.








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Williams, Melissa

From: Sent:

Curley Peter [[email protected]] Thursday, 15 March 2012 9:34AM



Mike Will do. Happy to discuss in a week or so.

cheers

From: Davison, Mike [mailto:[email protected]] Sent: Wed 14/03/2012 1:24 PM To: Curley Peter Cc: Cameron, Stuart; Williams, Melissa Subject: FW: HCPL Feedback on RPS Report

Hi Peter, We will need to get DERM's comments on this. They are in response to RPS submission. Comments from lOAP to 10 BD relate to vegetation clearing along the rail corridor, Section 4 of the RPS report.




Cheers

Mike

From: Cameron, Stuart Sent: Wednesday, 14 March 2012 8:48AM To: Davison, Mike Cc: McDonnell, Damian Subject: FW: HCPL Feedback on RPS Report

for your reference

Stuart Cameron Project Manager Significant Projects Coordination Office of the Coordinator-General Department of Employment, Economic Development and Innovation Queensland Government tel +61 7 3227 7459 mob post PO Box 15517 City East Qld 4002 visit Level 4, 63 George Street, Brisbane

From: Sent: Tuesday, 13 March 2012 6:02 PM To: Cameron, Stuart

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Regards


********************************DISCLAIMER**************************** The information contained in the above e-mail message or messages (which includes any attachments) is confidential and may be legally privileged. It is intended only for the use of the person or entity to which it is addressed. If you are not the addressee any form of disclosure, copying, modification, distribution or any action taken or omitted in reliance on the information is unauthorised. Opinions contained in the message{s) do not necessarily reflect the opinions of the Queensland Government and its authorities. If you received

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From: Melissa Wllliams [mailto:[email protected]] Sent: Wednesday, December 14, 201111:24 AM To: David Finney Cc: Mike Davison; Stuart cameron; Norrie Sanders Subject: Re: Hancock response to RPS request for outstanding information

Good rooming David


Please find attached Hancock's response to Norrie's request for further information beyond the Alpha Coal Project SEtS and SEIS Addendum (via email, 14 November~ see below).




Kind regards Melissa Williams Significant Projects Coordination Office of the Coordinator-General

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tel +61 7 3836 0667 {ext 60667) e [email protected]

post PO Box 15517, City East Q 4002 visit level 4, 63 George Street, Brisbane Q 4000 www.deedLgld.gov.au


Pl~ase consider the cnwonmcnt befor~ pnnt<n9 thi> cmoil

FromSent: Tuesday, 13 December 2011 4:05 PM To: Melissa Williams Cc:Subject: Hancock response to RPS request for outstanding information

Dear Melissa,



Thank you.

Kind Regards,

'"'c"•'~~~~~~-, i }<1 ~.!~~~ption: Description: Copy of HC PTY

Hancock Coal Pty Ltd Level 8, 307 Queen Street Brisbane OLD 4000


0 Please consider the environment before printing this email.

From

Sent: Friday, 2 December2011 10:54 AM


Cc: Mike Davison;

Subject" RPS Responses- delay

Hi Melissa,

Page 2 of5

Just to let you know that the responses to RPS are taking longer than anticipated so they will not be coming your way this week. I am waiting on the response time from PB who are looking at the surface water questions and will get back to you once this has come through.

Regards

FromSent: Monday, 14 November 2011 5:11PM To: Melissa Williams;Cc: Mike Davison; Subject: RE: RPS requests_Aipha SEIS

Thank you for this



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Hancock Coal Pty ltd Leve13, 60 Albert Street Brisbane OLD 4000


0 Please consider the environment before printing this email.

From: Melissa Williams [mailto:[email protected]] Sent: Monday, 14 November 2011 5:07PM To:Cc: Mike Davison Subject: RPS requests_Aipha SEIS

Good afternoon

Page 3 of5

Following our meeting this afternoon 1 received an email from Norrie Sanders (RPS} detailing requests for further information to allow completion of relevant sections of their conditioning report.

I believe these were in llne with discussions you had with Norrie during the site vislt last week.

Please contact Norrie directly for any clarification on these points, with Mike and myself cc'd,

Thanks and kind regards Melissa Williams Significant Projects Coordination Office of the Coordinator-General


tel +61 7 3836 0667 (ext 60667) e [email protected]

post PO Box 15517, City East Q 4002 visit level4, 63 George Street, Brisbane Q 4000 www.deedi.gld.gov_au

Tomorrow's Queensland: strong, green, smart, healthy and fairwww.toward02.qld.gov.au

Plea~e consr<l<>r the erwironmnnl bo!ora pnntmg thrs emarl

From: Norrie Sanders [mailto:[email protected]] Sent: Monday, 14 November 20111:45 PM To: Melissa Williams Subject: outstanding Information

Hi Melissa

Below is a summary of outstanding items which would help us to complete the conditions report. I have omitted reference to mine groundwater, tailings dam and rail flooding because both topics are under active assessment by Hancock. The information !hall alluded to during the field trip to Alpha were based on our second review report (EIS and SEIS), extracts of which are included below. My conversation with mainly covered the creek analysis, but I have added other mine information for completeness.


Creek diversion: o add pre development curve to stream power graphs (B-8 and B-9)

o Provide commentary on physical impacts on creeks where post development hyrdaulic parameters exceed current condition and/or ACARP guidelines- particularly

upstream and downstream of diversions. Stability risks in 050 are acknowledged but not specifically assessed or solutions proposed. o No flood inundation mapping is provided in the SEIS for the 2 year and 50 year ARI events. The flood report includes intermediate (5, 10, 20 year) flood flows but does


o Comparative statistics on channel morphology pre and post diversion are not presented. Geomorphic features that mimic current morphology, such as terraces, meanders, wetlands, pools etc are not explicitly considered. Impacts on channel networks, floodplain connectivity, pools, lakes and palustrine wetlands are absent.


landfonn and rehabilition: see table below

Mine water balance- Issues and recommendations

Issue Comment Actions Discharges to lagoon The quantity and quality of discharges to Use daily water balance Creek- aggregated lagoon creek are not specified other than modelling to asses discharge outputs from water discharge criteria. The mine water risk under different event modelling do not provide a balance needs to be further analysed to scenarios using daily time sufficient basis for demonstrate that there is sufficient step. assessing risks and storage and treatment capacity to allow evaluating management adherence to the standards under specific Consider design and arrangements even conditions. management arrangements to


Some calculations to justify 20% of the "settling zone" volume has the proposed sediment been allowed for sediment storage in the storage allowance for the sediment dams. This may not be sediment dams needs to be

2.3.1 Sediment Dams sufficient for the volume of sediment included in the EIS. This will washoff from the overburden which will depend on the catchment contain dispersive soils. If too small, the area, erodibility of the material sediment dams will fill with sediment and life of dam. The rate of quickly, and overflows to lagoon Creek sediment removal needs to be

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mav be more freQuent that anticipated. assessed. 3.1 Climate Data Figure 3-2 is said to be a Log Pearson Ill Amend text.

probability distribution. It appears to be an exceedence plot, not a frequency distribution olot. 11 would be useful to see flow duration curves for the estimated and recorded

3.5.1 Sacramento Model flows to provide more information on the Provide more information on goodness of fit of this calibrated model. model cailbration The model's ability to reproduce low flows may be important in this context.


3.5.2 Catchment yields catchment yields came from for different information (e.g. references) to justify the choice of land use activities. catchment yield

4.4 Dirty Water The proposed release points should be Clarification of the locations of Management System. shown on a plan. Table 4·1 gives the CO· the sediment dam discharge

ordinates only. The table lists the release points is required.

Sediment Dam discharge points as SD1a, SD2b, SD4b, and SD6b.

points. However these do not appear on the accompan ing figures 4-1 to 4-5. Sediment dam capacities should be able The 10% AEP 24 hour rainfall to hold the 10%AEP 24 hour storm runoff depths should be tabulated


volume, but this may depend on the capacities have been derived runoff losses assumed. from the ifd data. The Report slates the demand for dust For noting. May have been suppression is conservatively high, and preferable to relate dust does not account for rainfall. This means suppression requirements to in a high rainfall year, water use for dust dally evaporation- rainfall. In


this demand is a significant component of during wet years. the total demand, a lower demand may lead to more frequent overflow of the final sediment dams.

Figure 4.6 GotdSim This is meant as a schematic diagram of Prepare a schematic diagram network diagram. the water management system. It is a preferably overlaid on

GoldSim output and is very confusing. background plan to show approximate location of sediment dams, environmental dams and discharge points.


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Issue Comment

Kinetic testing to date is The AMD potential of raw coal and taillngs limited and outcomes only is not yet confirmed and further kinetic preliminary at this stage testing is required.

Coarse coal rejects and Preliminary trial alkaline treatment efficacy roof and floor waste rock

appear to have the highest has been undertaken on coarse reject

AP. and coal seam roof and floor material.

TSF location Tailings is likely to have acid leachate

considerations generation potential and low to moderate saline leachate potential

WRD capping strategy must recognize the high risk associated with placement of

Presence of dispersive dispersive and highly dispersive overburden and soils/clays- overburden within the final cover. Final landform Design implications Stripping depths of low or nil dispersive

topsoils have been adequately identified for preferential rehabilitation use.

EIS commits to preparation of a final void Final void water quality water quality model by year 5 of

operations.

Landform and rehabilitation: issues and recommendations

How is Mine Closure Planning addressed?

How, in practical terms, wlll rehabilitation be met?

Rehabilitation criteria should address the entire mine?

A Mine Waste Management Plan (MWMP) is in place for the test pit and commitments have been made (SEtS AppxD1.16.2)

Rehabilitation Success Criteria (Table P47) should address 'other mine infrastructure'

Actions Proceed with proposed additional column testing to further investigate Temporal saline and acidic/metaliferous drainage characteristics. It is recommended that further work is carried out to confirm dosing rates during final design stage and these are confirmed in the live MVVMP. Similar work should be carried out on representative tailings materials if further leachate testing confirms of concem AMD ootential. Seepage fate risk is to be considered in groundwater modelling for initial out of pit TSF and in pit disposal. This should be conditioned in the EA Mining scheduling to recognize the goal of final placement of low dispersion overburden cap (sandstones, tuff) where possible. This should be an EM Plan commitment and EA condition. MWMP should also include strategies for selective placement and management of saline waste materials. Bring forward development of the final void water quality model to the EM Plan OR approval conditions to pro~~;} or adequ=~~' worst case mana ement strate ies

Discuss MWMP experience with test pit wilh HPPL/Thiess and then provide mine planning details of how selective encapsulation will occur white operating differing mine methods (IPCC draglines, truck I shovel) in different parts of the mine.


Supply more details

(Table P48) if

Page 5 of5


If not an intended recipient of this email, you must not copy, distribute or take any action{s) that relies on it; any form of disclosu


Unless stated otherwise, this email, together with any attachments, is intended for the named recipient{s) only and may contain privile,

If not an intended recipient of this email, you must not copy, distribute or tal:e any action(s) that relies on it; any form of disclosu



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Williams, Melissa

From:

Sent:

To:

Subject:

Davison, Mike

Wednesday, 14 March 2012 1:13PM

Williams, Melissa

FW: HCPL Feedback on RPS Report

Page 1 of

Attachments: Stuart Cameron DEEDI - HCPL Feedback on RPS SEIS report- 13 Mar 2012SIGNED. PDF; Stuart Cameron DEEDI- Addendum comments and recommended conditions_Raii_RevE RPS updates.pdf

From: Cameron, Stuart Sent: Wednesday, 14 March 2012 8:48 AM To: Davison, Mike Cc: McDonnell, Damian Subject: FW: HCPL Feedback on RPS Report

for your reference

Stuart Cameron Project Manager Significant Projects Coordination Office of the Coordinator-General Department of Employment, Economic Development and Innovation Queensland Government tel +61 7 3227 7459 mopost PO Box 15517 City East Qld 4002 visit Level4, 63 George Street, Brisbane

From:Sent: Tuesday, 13 March 2012 6:02 PM To: Cameron, Stuart Cc:Subject: HCPL Feedback on RPS Report




Regards

15/01 /2013

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Williams, Melissa

From:

Sent:

To:

Cc:

Subject:

Davison, Mike

Wednesday, 14 March 2012 1:25PM

'Curley Peter'

Cameron, Stuart; Williams, Melissa

FW: HCPL Feedback on RPS Report

Page 1 of2

Attachments: Stuart Cameron DEED I- HCPL Feedback on RPS SEIS report- 13 Mar 2012SIGNED. PDF; Stuart Cameron DEED I- Addendum comments and recommended conditions_Rail_RevE RPS updates. pdf

Hi Peter, We will need to get DERM's comments on this. They are in response to RPS submission. Comments from 1 OAP to 10 BD relate to vegetation clearing along the rail corridor, Section 4 of the RPS report.

1 OBI to 1 OBS relate to Section 4.2 of the RPS report, Creek and River crossings.



Cheers

Mike

From: Cameron, Stuart Sent: Wednesday, 14 March 2012 8:48 AM To: Davison, Mike Cc: McDonnell, Damian Subject: FW: HCPL Feedback on RPS Report

for your reference

Stuart Cameron Project Manager Significant Projects Coordination Office of the Coordinator-General Department of Employment, Economic Development and Innovation Queensland Government tel +61 7 3227 7459 mobpost PO Box 15517 City East Qld 4002 visit Level 4, 63 George Street, Brisbane

From:Sent: Tuesday, 13 March 2012 6:02 PM To: Cameron, Stuart Cc:Subject: HCPL Feedback on RPS Report


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From: Sent:

Curley Peter [[email protected]] Friday, 23 March 2012 5:29PM



Attachments: DERM views on Hancock comments on RPS advice rail loop rail line 23 march12 .doc

DERM views on iancock comments ..

Mike

Comments atttached.

DERM officers have not commented on lOBI to lOBS as it relates to the flooding issue and not specifically creek crossing as stated in the RPS Report Section 4.2.2

Happy to discuss.

cheers

From: Davison, Mike [mailto:[email protected]] Sent: Wed 14/03/2012 1:24 PM To: Curley Peter Cc: Cameron 1 Stuart; Williams, Melissa Subject: FW: HCPL Feedback on RPS Report

Hi Peter 1

We will need to get DERM's comments on this. They are in response to RPS submission. Comments from lOAP to 10 BD relate to vegetation clearing along the rail corridor, Section 4 of the RPS report.




Cheers

Mike

From: Cameron, Stuart Sent: Wednesday, 14 March 2012 8:48AM To: Davison, Mike Cc: McDonnell, Damian Subject: FW: HCPL Feedback on RPS Report

for your reference

Stuart Cameron Project Manager Significant Projects Coordination Office of the Coordinator-General Department of Employment, Economic Development and Innovation Queensland Government tel +61 7 3227 7459

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Department of Environment and Resource Management DERM advice on Hancock views on RPS advice- Alpha Coal Project

Alpha Coal Project- rail line

This advice is provided for consideration in developing any Coordinator-General's Report (CoG Report) for this project. This advice is in response to a request from Mike Davison (dated 14 March 2012) for views on the proponent's response to the RPS recommendations provided to CoG 4 January 2012.

The advice addresses the • Hancock response dated 13 March 2012 • RPS report Review of Selected Aspects of the EIS, Supplementary EIS, SEIS

Addendum and other Proponent Responses: proposed conditions dated 4 January 2012

• DERM advice to CoG dated 9 February 2012 on the above RPS report • environmental management conditions for the construction of the proposed rail

line from the mining lease application area to Abbot Point

The following reference numbers refer to the Hancock response dated 13 March 2012. It is recommended that RPS is consulted on the proponent's response and this DERM officer advice.

10AP and 10AQ The proponent accepts the conditions but only for vegetation clearing outside the rail line itself. RPS seem to intend that it apply to all vegetation clearing associated with the rail line planning and construction.

DERM officers will require specific rail route and clearing information before setting conditions. It is appropriate to plan to avoid clearing vegetation. and the 50m and 20m RPS suggestions are reasonable however DERM officers have previously advised that the 50m distance may not be appropriate in all cases along the rail line (see page 6 of 9 February 2012 DERM advice).

10AR and 10AT It is not clear what "noted" means. The proponent appears to have accepted these recommendations. The 50m and 20m RPS suggestions may be reasonable however DERM officers have previously advised that the 50m distance may not be appropriate in all cases along the rail line (see page 6 of 9 February 2012 DERM advice).

10AU The use of fallen timber should take account of DERM requirements including the DERM authority to sell native forest products on crown lands and certain freehold lands under the Forestry Act 1959. DERM Forest Products will assess and salvage suitable timber products from relevant lands.

The habitat considerations recommended by RPS and discussed by the proponent are supported as is landholder involvement.

10AV and 10AW It is not clear what "noted" means. The proponent appears to have accepted these recommendations. NC Act and VM Act requirements will also address these issues. The CG Report may address this issue on a whole of rail line basis.

10AX and 10AY DERM conditions on rehabilitation issues will be addressed in the relevant ERA requirements. The CG Report may address this issue on a whole of rail line basis eg.

23 March 2012 I

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Williams, Melissa

From:

Sent:

To:

Cc:

Subject:

Wednesday, 9 May 2012 1:05PM

McDonnell, Damian; Mike Davison; Cameron, Stuart; Melissa Williams

Alpha Coal Project- HCPL Response to RPS Comments (Mine)

Attachments: RPS Addendum Comments_HCPL Response_9May12.pdf; RPS Addendum Comments_HCPL Response_9May12.docx

Damian,

Page I of I

Please find attached the HCPL response to the RPS document reviewing selected aspects of the EIS, SEIS and SEIS Addendum (RPS document Rev C dated 23/12/2011). A copy is provided in both Word format and PDF format. We have by earlier correspondence provided our response to the RPS comments on the railway.

Please contact me if you have any questions.

Regards


16/01/2013

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williams, melissa melissa williams d i queensland ......the report states the demand for dust for...

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