P-PRCP-100728034 · CHUM STREET PTY LTD

Department foundSection 8.4.3 of the PRC plan states that geotechnical investigations completed in 2022 (Appendix 3a and 3b) indicated the composition of stockpiled and fill material is variable, including composites of cohesive and non-cohesive soil across the site. Section 8.12 indicates that the entire former mining area will be rehabilitated via cut to fill operations, where previous extraction areas will be removed, levelled and relayed in compacted layers to achieve a stable, free draining landform suitable for residential and industrial post-mining land uses (PMLUs). A rehabilitation criterion to capture the excavation of variable material, as outlined above, is not included in the proposed PRCP schedule. Furthermore, soil samples (test pit and bores) undertaken as part of this investigation indicate highly erodible and moderately to highly reactive clayey soils present across ML4559. Further information is required to demonstrate that relayed fill material is suitable for the proposed PMLU, and the final landform will be structurally stable.

Asked forProvide a revised PRC plan and PRCP schedule that includes milestone criteria for removal and assessment of fill suitability by an AQP to demonstrate that the final landform will achieve a stable condition as defined in section 111A of the EP Act (a stable condition). When nominating the above-mentioned milestone criteria, consideration must be given to inclusion of such criteria in the most appropriate RM. Further, provide a revised PRCP schedule that includes a specific quality criterion for relayed fill material to be suitable for the proposed PMLU(s).

Notice, page 3

Department foundThe geotechnical report prepared by Butler Partners, Appendix 3A, raises concern regarding historical mining activities across ML4559 and stability risks associated with achieving a residential PMLU. Section 6.4 of the report indicates that potentially significant and unquantifiable risk of sinkhole development exists in areas where there are undocumented workings and/or tunnel entries and shafts. Consequently, section 6.5 of the report recommends additional geotechnical investigation (geophysics and drilling) to provide data and analysis of potential subsidence in the proposed residential areas where underground workings exist. The PRC plan does not include the recommended geotechnical investigation. Additional investigation is required to understand the site's subsurface conditions, which is essential for ensuring the long-term stability of the landform and its suitability for the proposed residential PMLU.

Asked forProvide geophysical surveys and additional drilling studies as recommended by the geotechnical report, Appendix 3A, assessing stability of deep reactive clay soils, identifying undocumented underground workings, and providing detailed input data for evaluating potential ground movement and stability risks. Alternatively, provide milestone criteria to conduct geophysical surveys and drilling across the site, focusing on areas with known reactive clay soils and potential underground workings as specified Appendix 3A. Analysis of data from these studies must demonstrate that the final landform will achieve a stable condition, specifically for a residential PMLU.

Notice, page 4

Department foundScientific purposes PMLU Section 2.4.4 of the PRC plan states that the disturbance associated with a quarry located on ML50077 will remain unrehabilitated in accordance with the PMLU scientific purposes. The disturbance includes a quarry with exposed rock units consisting of fossils and a sediment trap. Section 2.3 indicates that the underlying landholder for Lot 89 on RP90564 (outlining ML50077) is Ipswich City Council. An agreement between the holder of environmental authority (EA) EPML00634213 and the landholder that documents responsibility for the ongoing maintenance of the non- rehabilitated fossil quarry is required to ensure that the site will achieve a stable condition.

Asked forProvide evidence to demonstrate that the fossil quarry will achieve a stable condition.

Notice, page 4

Department foundSchedule F Table 2 of EA EPML00634213 includes 12 hectares (ha) of permanent infrastructure (paver manufacturing and ancillary facilities) located on ML4553 with a specified PMLU of industrial. The proposed PRC plan and PRCP schedule do not include a rehabilitation area (RA) for this disturbance area. While it is noted that this area relates to a development approval and EA EPPR00422413 for the underlying land parcel (Lot 271 on Plan SP207443), the area is overlain by ML4553 on EA EPML00634213 which must be rehabilitated to industrial PMLU. An RA that includes milestones for decommissioning and rehabilitation of the paver manufacturing facility is required. Alternatively, it may be appropriate to retain the facility by the landholder for future use. If the landholder is the same as the EA holder, the PRC plan must justify how the infrastructure will provide a benefit or improvement to the use of the land and/or community once mining has ceased.

Asked forProvide an updated PRC plan, PRCP schedule and reference map (figure 21) that includes an RA for the permanent infrastructure and appropriate rehabilitation milestones to ensure that the disturbance area is rehabilitated to a stable condition. If retained, provide an RA with milestone criteria to demonstrate a stable condition and a contemporary landholder statement demonstrating the landholder’s acceptance of the retained facility. Justification for retention of the facility must be clearly stated in the PRC plan.

Notice, page 5

Department foundIndustrial and residual dump PMLU The PRC plan and RA3 of the proposed PRCP schedule proposes two different PMLUs of industrial and residual spoil dump for the same land (ML4714). It is noted that both PMLUs are pre-approved in the land outcome document, which is EA EPML00634213, however, in accordance with Step 2 of section 4.1 of the PRCP Guideline, RAs may only contain one PMLU.

Asked forProvide a revised PRC plan, PRCP schedule and reference maps (figure 21 and 22) that propose a single PMLU, and appropriate milestone criteria associated with ML4714, demonstrating that the final landform will achieve a stable condition.

Notice, page 5

Department foundExisting rehabilitation Section 3.3.3 of the PRC plan states that rehabilitation works are underway within the areas nominated for industrial and residential land uses, with substantial earthworks having been undertaken during 2023. Significant progress has been made, however heavy rainfall events in the latter part of 2023 and early 2024 has prolonged the expected duration of the program. The proposed PRCP schedule indicates that RA1 and RA3 have been available for rehabilitation since 1 January 2023 and milestones RM1, RM3, RM4 and RM5 are scheduled to be completed by 1 December 2024. Similarly, RA2 has been available for rehabilitation since 1 June 2024 and RM1, RM2, RM3, and RM4 are scheduled to be completed by 1 December 2024. The PRC plan does not clearly state the condition of the existing rehabilitation, or the milestones completed at the time of lodgement. Therefore, it is unclear whether milestones (up to RM5) have commenced and will be completed by 1 December 2024. Due to prolonged duration of the program, rehabilitation timeframes for milestones that have not been completed may require adjustment to reflect on-ground works. Alternatively, evidence to demonstrate completion of rehabilitation milestones associated with RA1, RA2 and RA3 is required.

Asked forProvide evidence for completion of rehabilitation milestones associated with RA1, RA2 and RA3 of the proposed PRCP schedule. Alternatively, provide an updated PRCP schedule with revised rehabilitation timeframes for proposed milestones.

Notice, page 6

Department foundWater management Section 8.6.2 of the PRC plan refers to a range of drainage controls that will be used to manage water on site. This includes, but is not limited to, diversions, lateral catch drains, rock check dams, lining of channels and use of energy dissipation structures at the outlets of banks, drains and chutes. The PRC plan does not include information on the design of the structures, or appropriateness and maintenance of the structures long term. Section 8.9.7 further states that water management infrastructure has been incorporated into the design plans for both the residential and industrial PMLU’s, as prepared by an appropriately qualified person. It is intended that these structures will be constructed early in the rehabilitation works to provide suitable water storage capacity for stormwater management requirements during earthworks, to accommodate runoff from disturbed areas in the case of a storm event. It is noted that design plans, prepared by an AQP, for water management structures have not been provided in support of the proposed PRCP schedule. Further, it is noted from section 8.4 that all final surfaces are to be free draining with suitable retention basins in place for ongoing drainage control. However, the PRC plan does not describe the receiving environment and how surface water flow from the site will discharge to the receiving environment.

Asked forProvide an updated PRC plan that includes: • Design plans for water management structures, prepared by an AQP, • design parameters for drainage channels, • an explanation as to how the lining of channels, drains or chutes will be designed or constructed and the design’s appropriateness, • an explanation as to how the drainage control will be maintained long term and its performance criteria, • an explanation as to how stability, in terms of erosion, will be maintained with respect to high volume flows, and • discharge locations at each site and how surface water flow from the site will be non- polluting and not cause erosion in the receiving environment.

Notice, page 7

Department foundIn accordance with section 3.6.1 of the PRCP Guideline, the PRC plan must include a description of the following: • a description of the contaminants that pose a risk to environmental values of the receiving environment • source, pathway and fate of contaminants that have the potential to impact environmental values. The PRC plan does not identify contaminants of concern (CoC), details of CoC, or potential pathways of contaminants post closure of the mine. The information is required to determine the water quality limits, and suitability of monitoring locations to demonstrate the rehabilitation achieves a stable condition.

Asked forProvide an updated PRC plan that includes: • background/baseline receiving environment water quality monitoring data, • a description of potential CoC from the activity and the methodology used to determine the CoC, and • a description of the pathway and fate of contaminants that have the potential to impact environmental values.

Notice, page 7

Department foundSection 3.1.4 of the PRC plan states that the sediment basin located on the former brickworks site remains and is monitored following significant rainfall. Whilst table 4 within section 3.1.4 provides water quality monitoring results for the sediment basin, the location of the sediment basin is not identified in the PRC plan. Further information, including the location and size of this basin, justification for retention and criteria to monitor the water quality, is required. Water quality results presented in table 4 indicate that turbidity levels were elevated at 34.3 NTU compared to 5 NTU (Bremer River Water Quality Objectives – lowland fresh waters) and ANZECC guideline ranges. It is noted that the monitoring results are provided based on the monitoring round that occurred on 19 February 2024. Further monitoring data is required to assess the water quality of the sediment basin and determine a surface water and groundwater quality criteria based on the relevant Water Quality Objectives.

Asked forProvide a revised PRC plan that includes: • a map depicting the location of the sediment trap, and • location of the sediment trap, and • justification for retention of the structure (if landholder is same as EA holder), or a contemporary landholder statement demonstrating the landholder’s acceptance of the retained structure. Provide a revised PRCP schedule that includes: • rehabilitation of the sediment trap in the relevant RA, and • receiving environment surface water and groundwater quality criteria referencing the water quality objectives of the relevant catchment(s).

Notice, page 8

Department foundGroundwater quality Section 3.1.6 of the PRC plan indicates that groundwater observed at the southern section of the site was reported to be alkaline to neutral (pH 7.1 – 12.1) and saline (EC 8,688 – 12,248 μS/cm). The PRC plan does not discuss the fluctuation in these parameters and implications for long-term groundwater quality. While the concentrations of metals and organic contaminants were mostly within acceptable limits of NEPM (2013), occasional exceedances were noted (CLID 2023). The PRC plan does not adequately address the potential cumulative effects of these exceedances. A detailed analysis of groundwater quality trends over time, particularly concerning metals and organic contaminants, is required to ensure long-term safety for residential use.

Asked forProvide a revised PRC plan that includes: • details on any further monitoring required and the cause for exceedances, and • incorporates the findings and recommendations of the CLID into the PRC plan. Provide an updated PRCP schedule that includes a criterion to demonstrate that the land will achieve a stable condition and consistent with the nominated PMLU(s).

Notice, page 9

Department foundSection 8.8 of the PRC plan states the rehabilitated areas will be covered by a topsoil cover of thickness appropriate to the revegetation required. Rehabilitation criteria in RM4 specifies that topsoil is proposed to be applied across all vegetated areas to a minimum 75mm depth, however justification for the selected topsoil depth is not provided in the PRC plan. In addition, despite a surplus of approximately 28,388m3 of topsoil, section 8.8 indicates that topsoil will be purchased from external suppliers in the event of a shortfall. The PRC plan and proposed PRCP schedule do not include a rehabilitation criterion that recognises material deficit or external supply.

Asked forProvided a revised PRC plan that includes justification for the selected topsoil application depth. Provide an updated PRCP schedule that includes a criterion that identifies material imported from external supply.

Notice, page 9

Department foundSection 8.10 of the PRC plan nominates grass species mixture that are potential environmental weeds. For example, paspalum is regarded as an environmental weed in Queensland. An alternative species mix that consists of native pasture species is required to avoid spreading of exotic or invasive environmental weeds.

Asked forProvide an updated revegetation plan that includes a species mix which consists of native species suitable to sustain the nominated PMLU.

Notice, page 10

Department foundFigure 3 within section 2.5 of the PRC plan identifies an area of coal fine stockpile located on ML4559. The PRC plan does not include information on whether the coal fine stockpile will be removed and disposed off-site or remain in the final landform. Consequently, provide a revised rehabilitation criterion in RM1 of the PRCP schedule that identifies removal of the coal fine stockpile.

Asked forProvide a revised PRC plan and PRCP schedule that includes a criterion to remove the coal fine stockpile.

Notice, page 10

Department foundCommunity consultation The PRC plan and supporting technical reports identify risks associated with historical mining that have previously not been consulted with the community. Given that the rehabilitation methodology proposes remediation of variable fill from historical mine work to stabilise the landform for residential and industrial PMLU, the community consultation plan should include details of how the community will be engaged and what information will be released to the community. This is to ensure that anyone impacted by the proposed rehabilitation activities have an opportunity to provide input into the planning process.

Asked forProvide a revised community consultation plan that includes information on engagement stakeholders impacted by the proposed rehabilitation methodology and potential risks associated with achieving the PMLU, in accordance with section 3.5 of the PRCP Guideline.

Notice, page 10

Department foundRegional topography provided as figure 5 within section 3.1.2 of the PRC plan does not provide topographic information due to opacity coverage. Information on local and regional topography forms part of the baseline information that informs the PRC plan, therefore a revised figure that includes contour lines depicting topography of the site is required.

Asked forProvide a revised figure that includes the contour lines across the site and a figure that allows for easy interpretation.

Notice, page 10

Department foundIn addition to item 4 of this information request, the rehabilitation methodology and timeframes applied to RA3 are the same as those applied to RA1. If the PMLU for RA3 is revised to industrial as a result of the response to item 4, it is recommended to combine RA3 and RA1 due to the same rehabilitation methodology being proposed for both disturbance areas. Alternatively, provide appropriate rehabilitation milestone and criterion for residual spoil dump PMLU that demonstrates that the land will achieve stable condition. It is noted that the EA specifies rehabilitation criterion such as geotechnical stability, erosion assessment and vegetation cover for residual spoil dump PMLU that should be integrated in the proposed PRCP schedule.

Asked forProvide a revised PRC plan and PRCP schedule that propose a single PMLU associated with ML4714 and if determined appropriate, a combined RA (industrial PMLU) for areas including the same rehabilitation methodology, if applicable. Provide appropriate rehabilitation milestone(s) and criterion that demonstrates that areas nominated as residual soil dump PMLU will achieve stable condition (if applicable).

Notice, page 11

Department foundRehabilitation areas RA1 and RA3 of the proposed PRCP schedule do not apply RM2 (Contaminated land identification, remediation and removal) to the proposed areas. It is vital to undertake contaminated land assessment at an earlier stage of rehabilitation.

Asked forProvide a revised PRCP schedule that includes RM2 in RA1 and RA3 to ensure that areas of potential contamination are investigated to achieve a final landform that achieves a stable condition.

Notice, page 11

Department foundRA2 (residential PMLU) of the proposed PRCP schedule does not include a milestone for revegetation (RM5). It is noted that the PRC plan indicates that rehabilitation areas nominated for residential and industrial PMLUs will be seeded with a crop cover as groundcover.

Asked forProvide a revised PRCP schedule that includes a revegetation milestone (RM5) in RA2 to achieve the nominated PMLU.

Notice, page 11

Department foundThe naming convention of the proposed rehabilitation area SCI1 is not consistent with the rehabilitation areas (RA) described in the PRCP Guideline. An update throughout the PRC plan, reference maps, spatial information and PRCP schedule is required.

Asked forProvide a revised PRC plan, PRCP schedule, reference maps and spatial information, which update reference from ‘SCI1’ to ‘RA4’.

Notice, page 12

Department foundThe PRCP schedule proposes to achieve RM5 (revegetation) in 3 months (from 1 December 2024 to 1 March 2025). Similarly, it is noted that RM8 (achieved PMLU to stable condition) is proposed to be achieved in 3 months (from 1 March 2025 to 1 June 2025). It is unclear how milestone criteria such as “greater than 70% groundcover”, “weed presence less than 10% of total vegetation cover” and “no active areas of rill or gully erosion” can be achieved within the proposed 3 months. Justification for achievement of milestones in these timeframes is required.

Asked forProvide a revised PRC plan that includes justification for the selected timeframes associated with achieving groundcover in RA1 and RA3.

Notice, page 12

Department foundMonitoring and maintenance The monitoring program and rehabilitation milestones outlined in Section 10 of the PRC plan do not account for monitoring of soil and receiving environment water quality and groundwater quality and level. For water and soil quality, the quality characteristics, or CoC must be listed, as well as the limits that are to be applied in the PRCP schedule. This is required to demonstrate that the final landform achieves a stable condition. A topsoil criterion for electrical conductivity, pH and exchangeable sodium percentage must be included to ensure that topsoil is safe, stable, non- polluting and suitable for the PMLU.

Asked forProvide a revised PRC plan and PRCP schedule that include details of soil and water quality monitoring to demonstrate that the sites will achieve a stable condition.

Notice, page 12

Department foundGas emissions The CLID indicates that Huberg Lazer walkover and GA5000 gas monitors were used to monitor gases, including methane (CH ), present in 4 underground workings. The PRC plan does not adequately address the potential for gas migration from deeper coal seams, nor does it assess the effectiveness of these methods in detecting such risks. The sampling strategy focused on specific test pits and surface walkovers, but the report lacks clarity on whether these locations represent the highest-risk areas for gas emissions. A more strategic approach to selecting sampling sites, especially in areas with a history of underground mining, is needed to ensure comprehensive coverage of potential emission sources. Although none of the recorded methane concentrations exceeded the NSW EPA threshold for further investigation, with the highest being 51 ppm, the report does not sufficiently discuss the potential for gas concentration fluctuations, particularly in tunnels and other subsurface areas. This oversight could lead to undetected gas accumulation, posing a significant safety risk for future land use.

Asked forProvide a revised PRC plan that includes detailed subsurface gas migration assessments, particularly focusing on historical coal seams and less accessible areas. This would align with best practice and ensure the long-term safety of the site, particularly considering its proposed residential PMLU. Provide a revised PRCP schedule that includes monitoring of gases to ensure methane safety is within the acceptable range and suitable for the nominated residential PMLU.

Notice, page 13

Department foundRehabilitation area (SCI1 – scientific purpose PMLU) It is noted that the proposed schedule only applies RM1, RM7, RM9 and RM11 to SCI1. It is understood that the fossil quarry is proposed to remain for scientific research purposes, however further justification for not applying land contamination assessment is required. In addition, RM7 and RM9 include a criterion for weed presence in total vegetation cover, however a revegetation milestone has been not applied. RM7, RM9 and RM11 include a criterion to monitor suspended solids in water discharged from the lease area for a period of 10 months (from 1 March 2025 to 1 January 2026). Justification for the proposed timeframe is required.

Asked forProvide a revised PRC plan that justifies the milestones and timeframes applied to SCI1.

Notice, page 13

Department foundRM1 of the proposed PRCP schedule contains a criterion to remove all waste other than previously disposed historical waste area. Section 2.4.3 of the PRC plan indicates that the historic waste area is situated within the powerline easement that transects ML4559 and contains inert waste (broken bricks and similar waste). Given the waste disposal area is proposed to remain in the final landform, further information to demonstrate that the waste disposal area will achieve a stable condition and residential PMLU is required.

Asked forProvide a revised PRC plan and PRCP schedule that demonstrates that the historical waste disposal area will achieve a stable condition.

Notice, page 14

Department foundDiscrepancy in relation to the total disturbance footprint authorised on the EA has been identified in the PRCP schedule, whereby 5.925ha of disturbance has been omitted from the schedule. In addition, the paver manufacturing facility located on ML4553, which is subject to a development approval, is not included in the PRCP schedule. Disturbance Type Authorised Proposed PRCP area (ha) EA schedule (ha) ML4553: Permanent infrastructure 12 Not included (pave manufacturing and ancillary facilities): Industrial PMLU ML4553: Old coal mining void and 6 8.91 adjacent disturbed land ML4553: Old coal mining spoil 4 35.074 dumps: Industrial or residential PMLU ML4559: Backfilled/rehabilitated old 13 coal mining void (eastern sector of lease): Residential PMLU ML4559: Old coal mining spoil 1.5 dumps: Residential PMLU ML4559: Mine excavations: 15 Residential PMLU Total residential PMLU 33.5 ML4714: Old coal mining spoil 1.5 1.98 dumps and adjacent disturbed areas: Industrial or residual spoil dump PMLU ML50077: Mine excavation and 1 2.014 adjacent disturbed areas: Scientific purposes PMLU Total footprint 54ha 48.075 It is further noted that additional areas that are not authorised for disturbance are included in the PRCP schedule. Areas that are not part of mining disturbance should not be included in the schedule or reference maps and should only be reflected in the final site design.

Asked forProvide a revised PRCP schedule that includes rehabilitation areas for all disturbance authorised in the EA.

Notice, page 14