Bulga Complex Pollution Incident Response Management Plan

for Bulga Complex Pollution Incident Response Management Document

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1. Introduction The Protection of the Environment Legislation Amendment Act 2011 (PELA) received assent on 16 November 2011 resulting changes to the Protection of the Environment Operations Act 1997 (POEO Act). The intent of the PELA is to improve the way pollution incidents are reported and managed. Provisions include a requirement for holders of Environmental Protection Licences (EPLs) to prepare, keep, test and implement a Pollution Incident Response Management (PIRMP). The specific requirements for PIRMPs are set out in Part 5.7A of the POEO Act and the Protection of the Environment Operations (General) Regulation 2009 (POEO(G) Regulation). In summary, this legislation requires the following: holders of EPLs must prepare a pollution incident response management plan (section 153A, POEO Act); the plan must include the information detailed in the POEO Act (section 153C) and the POEO(G) Regulation (clause 98C) and be in the form required by the POEO(G) Regulation (clause 98B); licensees must keep the plan at the premises to which the EPL relates (section 153D, POEO Act); licensees must test the plan at least every 12 months and after a pollution incident in accordance with the POEO(G) Regulation (clause 98E); and if a pollution incident occurs in the course of an activity so that material harm to the environment is caused or threatened within the meaning of Part 5.7 of the POEO Act, licensees must immediately implement the plan (section 153F, POEO Act). As the holder of EPL 563, the Bulga Coal Complex, incorporating Bulga Open Cut and Bulga Underground, is required to comply with the POEO Act; as such, this document has been developed to satisfy the PIRMP requirements documented above. This document also details the procedures for notification of pollution incidents resulting in or having the potential to cause material harm to the environment. The notification of environmental incidents under this PIRMP is only required for those incidents causing or threatening to result in material environmental harm (a material harm incident) as defined in the POEO Act (see Section 5.1). 1.1 Regulatory Requirements Specific detail is required for inclusion in the PIRMP. Table 1.1 lists information mandated under Section 153C of the POEO Act and clause 98C of the POEO (G) Regulation and details where this information is located in this document. Page 3 of 22

Table 1.1 Document Directory Section 153C Detail required Location in document (a) (b) (c) (d) The procedures to be followed by the holder of the relevant EPL in notifying a pollution incident to: (i) The owners or occupiers of premises in the vicinity of the premises to which the EPL relates; (ii) The local authority for the area in which the premises to which the EPL relates are located and any area affected, or potentially affected, by the pollution; and (iii) Any persons or authorities required to be notified by Part 5.7 (of the POEO Act). A detailed description of the action to be taken, immediately after a pollution incident, by the holder of the relevant EPL to reduce or control any pollution. The procedures to be followed for co-ordinating, with the authorities or persons that have been notified, any action taken in combating the pollution caused by the incident and, in particular, the persons through whom all communications are to be made. Any other matter required by the Protection of the Environment Operations (General) Regulation 2009 (as set out below): 98C (1)(a) A description of the hazards to human health or the environment associated with the activity to which the licence relates (the relevant activity ). 98C (1)(b) The likelihood of any such hazards occurring, including details of any conditions or events that could, or would, increase that likelihood. 98C (1)(c) Details of the pre-emptive action to be taken to minimise or prevent any risk of harm to human health or the environment arising out of the relevant activity. 98C (1)(d) Section 5.3 Section 5.2 Section 5.2 Section 4.0 Section 5.2 Section 2.2 Section 2.2 Section 2.2 An inventory of potential pollutants on the premises or used in carrying out the relevant activity. Section 2.3 98C (1)(e) The maximum quantity of any pollutant that is likely to be stored or held at particular locations (including underground tanks) at or on the premises to which the licence relates. Section 2.3 98C (1)(f) A description of the safety equipment or other devices that are used to minimise the risks to human health or the environment and to contain or control a pollution incident. Sections 2.3, 4.0 Page 4 of 22

Section 153C Detail required Location in document 98C (1)(g) The names, positions and 24-hour contact details of those key individuals who: (i) are responsible for activating the plan; Section 3.2 (ii) are authorised to notify relevant authorities under section 148 of the POEO Act, and (iii) are responsible for managing the response to a pollution incident. 98C (1)(h) The contact details of each relevant authority referred to in section 148 of the POEO Act. Section 5.2 98C (1)(i) Details of the mechanisms for providing early warnings and regular updates to the owners and occupiers of premises in the vicinity of the premises to which the licence relates or where the scheduled activity is carried on. Section 5.3 98C (1)(j) The arrangements for minimising the risk of harm to any persons who are on the premises or who are present where the scheduled activity is being carried on. Section 4.0 98C (1)(k) A detailed map (or set of maps) showing the location of the premises to which the licence relates, the surrounding area that is likely to be affected by a pollution incident, the location of potential pollutants on the premises and the location of any stormwater drains on the premises. Sections 2.1, 2.2 and 2.3 and Appendix 2 Note: no stormwater drains are located on the premises 98C (1)(l) A detailed description of how any identified risk of harm to human health will be reduced, including (as a minimum) by means of early warnings, updates and the action to be taken during or immediately after a pollution incident to reduce that risk. Section 4.0 98C (1)(m) The nature and objectives of any staff training program in relation to the plan. Section 6.1 98C (1)(n) The dates on which the plan has been tested and the name of the person who carried out the test. Section 6.2 98C (1)(o) The dates on which the plan is updated. Section 6.2 98C (1)(p) Page 5 of 22

The manner in which the plan is to be tested and maintained. Section 6.2 2. Premise Details The purpose of this Explosives Management is to provide the practical guidance and set the safety standards for storage, handling and use of explosives at Bulga Underground Operations so as to provide a safe and healthy environment for the Mine and its workforce. The Management identifies the hazards associated with Explosives that affect the Mine and details the controls that have been put into place to manage these hazards and reduce the risks to an acceptable level. 2.1 Site Details Bulga Coal Management is the holder of EPL 563 for the Bulga Coal Complex, which comprises two coal mining operations, being the Bulga Open Cut, which incorporates the Bulga Coal Complex Coal Handling and Preparation t (CHPP), and the Bulga Underground. The CHPP and the rail loading facility, located in the north-east corner of the Bulga Coal Complex services both operations. The Bulga Coal Complex is managed by Bulga Coal Management Pty Limited (BCM) on behalf of the Bulga Joint Venture. Each mining operation is managed as a separate business unit of the Bulga Joint Venture. The surrounding area which may be impacted by a pollution incident occurring at the Bulga Coal Complex, in addition to the premises itself includes the following: landholders adjacent to the mine complex (refer to Appendix 1); downstream water courses (including inundation areas and adjacent landholders): Nine Mile Creek, Loders Creek, Monkey Place Creek and Wollombi Brook which subsequently flow into the Hunter River (refer to Appendix 1).; and nearby localities (refer to Appendix 1). 2.2 Major Hazards The potential major hazards relevant to this PIRMP which have been identified for the Bulga Coal Complex include: spills (e.g. hydrocarbon, hazardous chemicals, etc) resulting in land contamination; spills (e.g. hydrocarbon, hazardous chemicals, saline or sediment laden water, etc) resulting in water contamination; major water discharge (for example dam or pipeline failure); fire (for example spontaneous combustion fires associated with coal stockpiles); and explosions (only associated with Bulga Coal Open Cut, e.g. blasting activities). The likelihood of environmental hazards occurring at the Bulga Coal Complex has been captured through the Bulga Coal Complex Environment and Community Broad Brush Risk Assessment (E&C BBRA), with the management of impacts prioritised according to the level of risk each aspect is assigned. The BBRA is conducted annually in accordance with CAA FIN STD 0001 Risk Management. The Bulga Coal Complex implements site specific risk management plans developed to comply with CAA HSEC STD 0012 Change Standard, including: BUL SD PRO 0023 Risk Management (Bulga Open Cut); and BSM SD PLN 0108 Risk Management (Bulga Underground). The systematic identification, assessment and management of foreseeable catastrophic (core) hazards is undertaken utilising the adopted Glencore Sustainable Development Guideline for catastrophic (core) hazard management XCN SD PRO 0004 Core Hazard Assurance Monitoring. This process includes: Page 6 of 22

identifying foreseeable hazards associated with operations at the Bulga Coal Complex; assessing Sustainable Development risks using recognised analysis and evaluation methodologies; and implementing controls necessary to eliminate or reduce identified catastrophic (core) risks in accordance with the established hierarchy of controls for environmental management. The Bulga Coal Complex also maintains a Core Hazard Register. This register includes nominated control measures to manage foreseeable catastrophic (core) hazards. The site s Core Hazard Register is reviewed annual and lodged with Glencore. The Core Hazard Register includes hazards that could result in either: multiple fatalities; irreversible, sever environmental damage; or a health or community issue that causes significant long term harm. 2.3 Chemicals and Potential Pollutants All chemicals at the Bulga Coal Complex are included in a central register ChemAlert available on the site intranet. All chemicals are accompanied by the relevant Safety Data Sheets as required by work health and safety regulations. Safety Data Sheets are also stored on ChemAlert and include Personal Protective Equipment (PPE) required for handling the chemical. The facilities that store fuel, oil and hazardous chemicals have been designed in accordance with Australian Standard 1940 1993. The system has been designed to include computerised controls for the purpose of monitoring and identification of faults, and includes: impervious walls and floors; sufficient capacity to maintain 110 per cent of the volume of the tank (or 110 per cent volume of the largest tank where more than one tank is stored in the bund); walls not less than 250 millimetres (mm) high; and have floors graded to a collection sump. Explosives for Underground and Open Cut are stored in licensed explosive magazines in accordance with Workcover requirements. The Dangerous Goods Licences (No.07-100095-003 for underground and XSTR100095 for Open Cut) covers the storage of these materials. Potential pollutants created as part of mining operations, and thus excluded from stores registers, include: mine tailings; mine water (extracted from both underground and open cut mine workings); sediment laden surface water runoff from disturbed areas; and effluent waste. These materials are in a constant state of flux as a result of mining operations. Risks associated with these potential pollutants are incorporated into the risk register detailed discussed above. Appendix 2 displays the location of potential pollutants including tailings dams, sediment dams pipelines and fuel storage locations. 3. Management and responsibilities 3.1 Legal Duty to Notify Bulga Coal Complex employees and contractors are responsible for alerting management personnel to all environmental incidents or hazards which may result in an environmental impact, regardless of the nature or scale. Page 7 of 22

Notification responsibilities are detailed in the POEO Act 1997 (Section 148), which encompasses all site personnel, including contractors and sub-contractors. These can be categorised broadly as: the duty of employee or any person undertaking an activity: Any person engaged as an employee or undertaking an activity (at the Bulga Coal Complex) must, immediately after becoming aware of any incident that is believed to cause or threaten to cause material harm to the environment, notify their relevant manager of the incident and all relevant information about it. This is to be undertaken as per Section 5.2; and the duty of the employer or occupier of a premises to notify: An employer or occupier of the premises on which the incident occurs, who is notified (or otherwise becomes aware of) a pollution incident, must undertake notification to the appropriate regulatory authority of any material harm incidents, including relevant information. Notification shall be undertaken by the Environment and Community Manager or Environment and Community Officer as per Section 5.2. 3.2 PIRMP Management The specific responsibilities associated with the management and implementation of the PIRMP are outlined in Table 3.1. Table 3.1 PIRMP Management Responsibilities Name Contact details Position Responsibility Peter Ostermann 0411 204 903 Operations Manager Bulga Underground Responsible for authorising the PIRMP and all subsequent updates. Responsible for providing adequate resourcing for implementation of the PIRMP. Geoff Kelly 0409 352 225 Operations Manager Bulga Open Cut Authorised to liaise with the relevant authority. Responsible for undertaking notification as defined in this PIRMP. Responsible for managing the response to a pollution incident. Ralph Northey 0418 439 874 Environment and Community Manager Bulga Complex Responsible for arranging testing and updating of the PIRMP. Responsible for notification and training of PIRMP. Responsible for coordinating communications with affected community members. Dispatch To provide assistance and alert other people who may be in the vicinity of any incident. Control Room 555 (internally) 6570 4350 Control Room Operator To provide assistance and alert other people who may be in the vicinity of any incident. Page 8 of 22

Other relevant Site Contacts See Appendix 3 See Appendix 3 Responsible for reporting environmental incidents to Shift Supervisor/Environment Department and controlling incidents that occur. 4. Incident Management A pollution incident is defined in the POEO Act as an incident or set of circumstances during or as a consequence of which there is or is likely to be a leak, spill or other escape or deposit of a substance, as a result of which pollution has occurred, is occurring or is likely to occur. It includes an incident or set of circumstances in which a substance has been placed or disposed of on premises, but it does not include an incident or set of circumstances involving only the emission of any noise. In the case of an environmental incident, prior to any other action, the site must contact Fire and Rescue (000) if the incident presents an immediate threat to human health or property. Fire and Rescue NSW are the first responders, as they are responsible for controlling and containing incidents. Where there is no threat to human health or services, Fire and Rescue NSW must still be contacted for information purposes, but as the last point of contact as detailed in Section 5.2. All possible actions should be taken to control the pollution incident in order to minimise health, safety and environmental consequences. These actions, to the maximum extent possible, aim to: provide for the safety of people at and within the vicinity of the site, and contain the pollution. In compliance with CAA HSEC STD 0006 Incident Standard, the actions to be implemented at the Bulga Coal Complex on the occasion of an incident include the following: 1. Secure the scene and contain the incident 2. Determine if Notification is required Refer to Figure 5.1. 3. Gather information (i.e. environmental monitoring). 4. Determine the investigation level. 5. Commence an ICAM (if required). 6. Review and classify information and determine actions. 7. Complete actions. 8. Trend analysis reports. Arrangements for minimising risk of harm to people and the environment as a result of a pollution incident, and for containing or controlling a pollution incident, are included in the following documentation: BUL SD PRO 0071 Emergency Procedure Environmental Spill Response (Bulga Open Cut) BSM SD PRO 0015 Spill Management Response Procedure (Bulga Underground Operation) As a minimum, static spill kits are stored adjacent to major fuel storage locations. The location of static spill kits are shown on Appendix 2. Emergency and incident response procedures to be followed in the event of an incident/emergency are also included in the following plans, including the specific instructions for particular emergencies in the form of Triggered Action Response s (TARPs). BUL SD PRO 0036 Hazard and Incident Management Procedure (Bulga Open Cut); BSM SD PRO 0091 Hazard and Incident Management (Bulga Underground); BUL SD PLN 0002 Emergency Management (Bulga Open Cut); BSM SD PLN 0058 Emergency Management (Bulga Underground); and Page 9 of 22

Site Emergency Procedures and Duty Cards as relevant to specific emergency situations. Each management plan documents the roles and accountabilities of key personnel at each operation in the event of an emergency and the contact details for appropriate emergency services. The plans also provide designated evacuation points and procedures in the event of an emergency. Any changes to emergency procedures are documented and communicated to all personnel. These procedures have been developed to align with the requirements of CAA HSEC STD 0007 Emergency Standard. Incident management at the Bulga Coal Complex focuses on actions to: secure and assign necessary tactical response resources, including equipment and/or personnel, to minimise the environmental impacts associated with the incident; establish that tactical response operations are carried out in a safe, well-organised, legal and effective fashion; provide for the safety and welfare of all responders, employees, contractors and visitors; continuously assess the incident to determine the adequacy of tactical response operations and the need for assistance from the XCN Crisis Management Team; manage stakeholders arriving at site; minimise effects on people, the environment, property, production, and company reputation; implement an environmental monitoring program to quantify impacts as a result of the incident as well as to be used as the basis to notify adjacent landholders and downstream water users as to whether avoidance or remediation measures are required; and interact, as appropriate, with XCN personnel. With regards to the specific major hazards identified in Section 2.2, the following emergency procedures have been developed: Spills (e.g. hydrocarbon, hazardous chemicals, etc) resulting in land and or water contamination; BUL SD PRO 0071 Emergency Procedure Environmental Spill Response (Bulga Open Cut); BSM SD PRO 0015 Spill Management Response Procedure (Bulga Underground Operation); and BSM SD PLN 00 Water Management (Complex). Major water discharge (for example dam failure); Dam Safety Emergency ; CHPP Surge Dam; BSM SD PRO 0015 Spill Management Response Procedure (Bulga Underground Operation); and BSM SD PLN 0006 Erosion and Sediment Control (Bulga Underground Operation). Fire (for example, spontaneous combustion fires associated with coal stockpiles); Explosions; BUL SD PRO 0027 Emergency Procedure - Fire (Mobile Machinery); BUL SD FRM 0018 Duty Card - Fire (Buildings); BUL SD FRM 0019 Duty Card - Fire (Mobile Machinery); BUL SD FRM 0020 Duty Card - Fire (Explosives); and BSM SD FRM 0032 Fire and Explosion Response Procedure. BUL SD FRM 0020 Duty Card - Fire (Explosives); BUL SD PRO 0081 Emergency Procedure Fire and Explosives; and BSM SD FRM 0032 Fire and Explosion Response Procedure. All Bulga Coal Complex employees and contractors receive emergency preparedness and response training during their site familiarisation induction. The Bulga Coal Complex maintains a dedicated emergency response team who undergo regular training and operational drills as detailed in BSM SD MEM 0002 Emergency Phone List (Bulga Underground) and BUL HR FRM 0069 Bulga Incident Management Team Contact List (Bulga Open Cut) (relevant contacts are provided in Appendix 3). Controls of personal protective equipment and incident containment and control Page 10 of 22

equipment are detailed in safety data sheets for chemical of concern, the relevant management plan detailed above and in the risk assessment documents listed in Section 2.2. These include but are not necessarily limited to: emergency spill kits; portable pumping infrastructure; earth moving plant; floating booms and silt curtains; and erosion and sediment control materials. The Bulga Coal Complex has limited authority to undertake pollution management activities on private property, or outside the site boundary and in such cases will liaise directly and provide appropriate assistance to the relevant authority and emergency services. 5. Notification Procedures 5.1 Determination of Material Harm Following containment of the incident, immediate action must be taken to determine if the incident can be classified as a material harm incident, i.e. considered to be causing or threatening material harm. As defined by Section 147 of the POEO Act, a material harm incident has occurred if the incident: involves actual or potential harm to the health or safety of human beings or to ecosystems that is not trivial; or results in actual or potential loss (including all reasonable costs and expenses that would be incurred in taking all reasonable and practicable measures to prevent, mitigate or make good harm to the environment) or property damage of an amount, or amounts in aggregate, exceeding $10,000.00 (or such other amount as is prescribed by the regulations). It is possible for a material harm incident to occur on land that is within the boundary of the EPL. The determination of a material harm incident will be made by the Operations Manager in consultation with the Environment and Community Manager. If the Operations Manager is not available immediately, the determination will be made by the Environment and Community Manager. 5.2 Internal and External Notification As discussed in Section 3.1, notification of an environmental incident is the responsibility of all site and contractor personnel. In the instance of identification of an environmental incident or hazard, personnel will report the issue immediately to their manager or Task Coordinator, who in turn shall report it immediately to the Environment and Community Manager, or any member of the environmental team. Immediately is taken to mean promptly and without delay 1. In the event of an incident, response and notification must be undertaken as per Figure 5.1, which contains the following important information: the local authority for the area in which the premises to which the EPL relates are located and any area affected, or potentially affected, by the pollution; the persons and authorities to be notified by Part 5.7 of the POEO Act; and the contact details of each relevant authority referred to in section 148 of the POEO Act, refer to Table 5.1. Note, the agencies listed in Table 5.1 must be contacted in the order outlined below: Page 11 of 22

Table 5.1 PIRMP Notification Contacts Fire and Rescue Agency Contact details 000 (To be contacted first in this order if the incident presents an immediate threat to human health or property and emergency services are required, or last in this order if emergency response is not required.) EPA 1 555 Ministry of Health Work Hours: (02) 4924 6477 After Hours: (02) 4924 6477 (Diverts to John Hunter Hospital ask for Public Health Officer on call) Work Cover 10 50 Singleton Shire Council Department of ning and Environment (DP&E) NSW Trade & Investment, Mineral Resources Work Hours: (02) 6578 7290 After Hours: (02) 6572 1400 Scott Brooks Ph: 6575 3401 or Mob: 0419 970 924 Monique Meyer Mob: 0429 168 008 EPA, Frequently Asked Questions Regarding the Duty to Notify of a Pollution Incident (last updated 18 June 20) < http://www.epa.nsw.gov.au/legislation/poefaqsnotify.htm> Page 12 of 22

Figure 5.1: ENVIRONMENTAL INCIDENT RESPONSE NOTIFICATION FLOW CHART Key Do STEP 1 STEP 2 Person identifies environmental incident. Notify Shift Supervisor immediately. Check STEP 3 Shift Supervisor reviews incident detail and inspects site Act Immediately contact Environmental Department relevant to the site where the incident has occurred. E&C Manager first off, if not contactable try one of the E&C Officers Open Cut Operations Environment & Community Manager Ph: 0418 439 874 Environment & Community Officer Ph: 0427 2 847 or 0417 245 807 STEP 4 Underground Operations Environment & Community Coordinator Ph: 0400 266 877 Environment & Community Officer Ph: 0418 737 760 or 04 614 458 and relevant Department Manager immediately. Shift supervisor is to provide the following information to the E&C Manager/Officer, if known, and as it becomes available: a) The time, date, nature, duration and location of the incident; b) The location of the place where pollution is occurring or is likely to occur; c) The nature, the estimated quantity or volume and the concentration of any pollutants if known; d) The circumstances in which the incident occurred (including the cause of the incident, if known); e) The action taken or proposed to be taken to deal with the incident and any resulting pollution or threatened pollution if known; f) Other information prescribed by the regulations. E&C Manager/Officer reviews incident detail and determines if incident is reportable under Section 148 of POEO Act. No Follow site incident reporting procedure by completing incident report form in Xstrasafe Yes E&C Manager/Officer to notify the following internal personnel to make determination of material harm: STEP 5 Relevant Operations Manager - Open Cut Ph: 0409 352 225 - Underground Ph: 0411 204 903 XCN General Manager Environment & Community Ph: 0419 281121 Xstrata Coal Legal Counsel Ph: 0414 389047 or 0404 9857 XCN Media and Communications Manager Ph: 0418 228075 E&C Manager/ Officer then immediately calls the following: STEP 6 1. EPA Environment Line on 1555 2. Ministry of Health 02 4924 6477 3. WorkCover on 1050 4. Singleton Council on 6578 7290 5. Fire and Rescue on 00 729 579 And report the details as listed in STEP 4 STEP 7 E&C Manager/Officer to continue to monitor incident. If any information required to be reported in STEP 4 becomes available afterwards, this information if to be reported to the Agencies listed in STEP 6 after it becomes known STEP 8 E&C Manager/Officer to notify the following external Agencies in accordance with relevant site approvals and standards: Department of ning Ph: 0419 970 924 Dept. Primary Industries Ph: 0429 168 008 Affected neighbours as per contact details in Bulga Complex Stakeholder database Page of 22

In the instance of identification of an environmental incident or hazard, the personnel will report the issue immediately to their Shift Supervisor/Task Coordinators, who in turn shall report it to the Environment and Community Manager, or any member of the environmental team. Immediately is taken to mean promptly and without delay. The decision on whether to notify of the incident in accordance with Part 5.7 of the POEO Act should not delay immediate actions to provide the safety of people or contain a pollution incident. However, incident notification will be made as soon as it is safe to do so 2. In addition to being detailed in this document, procedures for undertaking internal and external notification are included in: BSM SD PLN 0067 Environmental Management Strategy (Bulga Coal Complex) (in Section 8.4); BUL SD PRO 0036 Hazard and Incident Management Procedure (Bulga Open Cut); BSM SD PRO 0091 Hazard and Incident Management (Bulga Underground); BUL SD PLN 0002 Emergency Management (Bulga Open Cut); and BSM SD PLN 0058 Emergency Management (Bulga Underground). Record keeping of incident details, including investigations and outcomes, will be undertaken in accordance with CAA HSEC PRO 0007 11.1 Environmental Data Collection and Reporting. After initial notification of any material harm incident, it will be the responsibility of the Environment and Community Manager to liaise with any authority listed in Table 5.1 that requests additional information, or is providing directions for management of the material harm incident. This may include incident investigation reports and ongoing environmental monitoring results. 5.3 Notification to Local Landholders and Community Community notification shall be undertaken at the determination of the Environment and Community Manager and may be based on environmental monitoring results. Names and contact details of stakeholders, including local and downstream residents are included in the the GCAA Consultation Manager database. The following notification methodology is proposed to be utilised as required: early warnings: same day telephone notification to landholders whom may be affected by the incident over the subsequent 24 hour period; and updates: follow up phone calls to all landholders who may have been notified by the initial early warning. Updates are to be provided to the broader local community in affected areas via information sheets or newsletters, Community Consultative Committee meetings, Bulga Coal Complex website, media statements or any other strategy as defined in the BSM SD PLN 0040 Bulga Coal Stakeholder Engagement Strategy. Information provided to the community will be relevant to the incident and may include the following details: type of incident that has occurred; potential impacts local landholders and the community; 2 EPA, Frequently Asked Questions Regarding the Duty to Notify of a Pollution Incident (June 20) <http://www.epa.nsw.gov.au/legislation/poefaqsnotify.htm> Effective : Page 14 of 22

site contact details; and Page 15 of 22

Advice or recommendations based on the incident type and scale. 6. Training, Testing and Communication 6.1 Training All personnel affected by the content of this document will receive instruction or explanation on the relevant parts of the document as per: BUL SD PLN 0016 Training and Competency Management (Bulga Open Cut); and BSM SD PLN 0057 Training and Competency Management (Bulga Underground). Incident management and emergency response shall be included in all XCN Generic and Bulga Coal Complex site inductions. Additionally, routine training exercises may involve the emergency response team responding to a simulated emergency, but may also include expanded simulations that involve other (or all) site personnel, the Bulga Incident Management Team and external response agencies (Ambulance, Fire, Mines Rescue etc). All training records, including the name of the person undertaking training and date of training, shall be maintained in compliance with: BUL SD PRO 0043 Document and Data Control Procedure (Bulga Open Cut); and BSM SD PRO 0032 Document, Data and Records Control Procedure (Bulga Underground). 6.2 Testing, Review and Maintenance The testing of the PIRMP will be undertaken to check that the information is accurate and current and that the plan is capable of being implemented in a workable and effective manner. Testing shall be undertaken in the following ways: 1. The PIRMP will be tested by assessing and reviewing it and making any necessary changes as identified. Testing is taken to be either a desktop review or an environmental emergency drill procedure. Testing will include all components of the plan, including training requirements. 2. A review of the PIRMP will occur every 12 months commencing from the date of authorisation by the BCC Environment and Community Manager. Contact details in this document must be kept current at all times. 3. The PIRMP will be reviewed within one month from the date of any pollution incident that occurs in the course of an activity to which the EPL relates. This review will be undertaken in light of the incident, to provide the information included in the plan is accurate and up to date and the plan is still capable of being implemented in a workable and effective manner. Records will be kept in accordance with: BUL SD PRO 0043 Document and Data Control Procedure (Bulga Open Cut); and BSM SD PRO 0032 Document, Data and Records Control Procedure (Bulga Underground); and will be included in Appendix 5 of this plan. Information regarding testing includes: the manner in which the test was undertaken; dates when the plan has been tested; the person who carried out the testing; and the date and description of any update of or amendment to the plan. 6.3 Availability of the PIRMP The PIRMP shall be kept in written form at the EPL premises and shall be made available to all personnel responsible for implementing the plan, and to an authorised officer (as defined in the POEO Act) on request. Page 16 of 22

The PIRMP will be made publicly available within 14 days of finalisation (taken to be authorisation of the PRIMP by the Bulga Coal Environment and Community Manager) via the Bulga Coal Complex website, in a prominent position and on a publicly available page. No personal information (within the meaning of the Privacy and Personal Information Protection Act 1998) will be made publicly available as part of the PIRMP. 7. Accountabilities Role Operations Manager Accountabilities for this document Responsible for authorising the PIRMP and all subsequent updates. Responsible for ensuring adequate resourcing for implementation of the PIRMP. Authorised to liaise with relevant authorities. Environment & Community Manager Responsible for undertaking notification as defined in this PIRMP. Responsible for managing the response to a pollution incident. Responsible for arranging testing and updating of the PIRMP. Responsible for ensuring notification and training of PIRMP. Responsible for coordinating communications with affected community members. Environment & Community Officer Responsible for undertaking notification as defined in this PIRMP. Responsible for coordinating the resposne to a pollution incident. Responsible for the facilitation of training provided to site personnel in the implementation of this PIRMP. Responsible for communication of the requirements of this PIRMP to site personnel. Page 17 of 22

Blakefield South Mine A.1 Appendix 1 Site Location and Surrounding Areas Page 18 of 22

Blakefield South Mine A.2 Appendix 2 Potential Pollutant Sources Pipelines and Dams Page 19 of 22

Blakefield South Mine A.3 Appendix 3 Potential Pollutant Sources Fuel and Chemical Storage Page 20 of 22

Appendix 4 Bulga Underground Emergency Contact List Name Position Work Mobile Peter Ostermann Operations Manager 6570 4300 0411 204 903 Pat Sharpe Production Manager 6570 4329 0417 064 866 Stewart Besley Engineering Manager 6570 4355 0407 615 732 Clint Todhunter Technical Services Manager 6570 4215 0417 681 596 Gas Drainage Superintendent Hamish Kerr 6570 4217 0409 442 111 Brendan Rolls Ventilation Officer 6570 4338 0411 321 752 Ned Stephenson Environment and Community Coordinator 6570 2541 0400 266 877 Craig Powell Health, Safety & Training Manager 6570 4326 0438 256 447 Troy Straker Development Superintendent 6570 4208 Brad Morgan Longwall Superintendent 6570 4301 0419 224 2 Mark Owen Services Superintendent 6570 4345 0408 162 271 Steve Trow Services Coordinator 6570 4369 0439 171 003 Control Room - 555 6570 4200 Appendix 5 Bulga Open Cut Emergency Contact List Name Position Work Mobile Geoff Kelly Operations Manager 6570 2956 0409 352 225 Peter Shumack CHPP Manager 6570 2489 0417 227 932 Nick Slater Mine Manager 6570 2417 0438 700 794 Control Centre Control Centre (Dispatch) 6570 2484 0429 508 374 Wayne Bower Maintenance Manager 6570 2510 0408 430 349 Maintenance Team Leaders - 6570 2447 0418 478 474 Washery Control Room - 6570 2562 - Washery Team Leader - 6570 2873 0417 250 622 Senior OCE Contact Via Control / on Two Way - - Effective : Page 21 of 22

8. Document Information Property Value by Document Owner Ned Stephenson Lucy Stuart Effective Date 28/09/2012 Keywords PIRMP, Pollution, Incident Response, Environmental Incident, Spill Table 8-1 Reference information 8.1 Change Information Version Date reviewed Review team (consultation) Nature of the amendment 1 10/10/2012 Lucy Stuart Updating document references, including procedures, contacts and Figures. 2 05/02/20 Lucy Stuart Updating contact lists and minor Figure amendments. 3 09/08/20 4 27/08/2014 5 17/09/2015 Joel Jelbart Lucy Stuart Martin Salm Paul Amidy Ned Stephenson Ralph Northey Updated Figure 5.1 Environmental Incident Response Notification Flow Chart Review and update Contacts, Appendices, links and document references. Update of document refences, contact details and location maps Page 22 of 22