coal mine particulate matter control best management practice … · 2017-04-04 · an...

Coal Mine Particulate Matter Control Best Management Practice Determination

Placeholder for images

LCO SD FWK 0006 Coal Mine Particulate Matter Control Best Management Practice Determination

Status: Approved Version: 2.0

Effective: 23/02/2012 Review: 23/02/2015

of 98

THIS DOCUMENT IS UNCONTROLLED UNLESS VIEWED ON THE INTRANET

Contents

EXECUTIVE SUMMARY ................................................................................................ 5

1. INTRODUCTION ............................................................................................... 8

1.1 Background................................................................................................................ 8

1.2 PRP Requirements ...................................................................................................... 8

2. Overview of Operations ................................................................................... 13

2.1 Operations ............................................................................................................... 13

2.2 Mine Activities with Potential Air Emissions .................................................................. 15

2.3 Overview of Air Quality Management and Monitoring ..................................................... 16

3. Existing Emissions and Control Measures ........................................................... 19

3.1 Introduction ............................................................................................................. 19

3.2 Study Limitations ...................................................................................................... 19

3.3 Current Measures and Control Efficiencies .................................................................... 19

3.4 Particulate Matter Emissions ...................................................................................... 34

3.5 Ranking of Mine Activities .......................................................................................... 34

3.6 Top Four Mining Sources ............................................................................................ 34

4. Potential Additional Particulate Matter Controls .................................................. 40

4.1 Introduction ............................................................................................................. 40

4.2 Potential Additional PM Controls for Top Four Activities .................................................. 40

4.3 Emission Reductions Achievable due to Additional Controls ............................................ 51

5. Practicability of Best Practice Measures ............................................................. 52

6. Implementation timeframe .............................................................................. 52

7. Appendices .................................................................................................... 55

7.1 Appendix A: Presentation of Information on Cost of Implementation ............................... 55

7.2 Appendix B: Emission Estimation ................................................................................ 57

7.3 Appendix C: Control Efficiencies ................................................................................. 88

8. References .................................................................................................... 91

9. Control and revision history ............................................................................. 97

9.1 Document information ............................................................................................... 97

9.2 Revisions ................................................................................................................. 98




of 98


List of Figures

Figure 1. LCO Locality Map ...................................................................................... 12

Figure 2. LCO CHPP operations ................................................................................. 14

Figure 3. Location of LCO Air Quality Monitoring Stations ............................................. 17

Figure 4. Gravel surfacing of unsealed roads at LCO ................................................... 20

Figure 5. Water application rates on unsealed roads at LCO for the period December 2010

to October 2011, with chemical surfactant (RT9) in use (Source: Reynolds Soil

Technologies, October 2011) .................................................................................... 21

Figure 6. Visual monitoring of road dust levels at LCO ................................................. 22

Figure 7. Dust control efficiency due to RT9 application on unsealed haul roads at LCO for

the period December 2010 to October 2011 (Source: Reynolds Soil Technologies, October

2011) .................................................................................................................... 22

Figure 8. Overburden dumping at LCO ...................................................................... 24

Figure 9. LCO’s 2012 Rehabilitation Plan ................................................................... 27

Figure 10. Proximity of rehabilitation to dump face (November 2011). Photograph shows

rehabilitation on either side of the access road, with rehabilitation area on the left in the

immediate vicinity of the dump face (mounds evident). ................................................ 29

Figure 11. Vegetation on surface of overburden emplacement area. Seeded March 2011.

Photograph taken in November 2011. ........................................................................ 29

Figure 12. Vegetation on surface of overburden emplacement area. Seeded March 2011.

Photograph taken in November 2011. ........................................................................ 29

Figure 13. Temporary rehabilitation in the vicinity of the LCO ROM pad undertaken in Q4 of

2009 and Q1 of 2010. Photograph taken in November 2011. Enclosed ROM coal conveyor

shown in the foreground. .......................................................................................... 30

Figure 14. Temporary rehabilitation in the vicinity of the LCO ROM pad undertaken in Q4 of

2009 and Q1 of 2010. Photograph taken in November 2011. ....................................... 30

Figure 15. LCO ROM stockpile water sprays ............................................................... 31

Figure 16. Enclosed product coal conveyor ................................................................. 31

Figure 17. Partially enclosed coarse reject conveyor .................................................... 31

Figure 18. LCO ROM coal hopper .............................................................................. 32

Figure 19. ROM coal conveyor entering enclosed crusher station. ................................. 32

Figure 20. ROM coal conveyor entering enclosed crusher station. ................................. 32

Figure 21. Contours of normalised surface wind speed (us/ur) for conical and oval, flat

topped stockpiles (after USEPA AP42 Chapter 13.2.5 Industrial Wind Erosion, November

2006). ................................................................................................................... 67




of 98


List of Tables

Table 1. Current Control Measures and Allocated Control Efficiencies (where available) ... 33

Table 2. Annual Particulate Matter Emissions given Partially Uncontrolled and Controlled

2011 Operations ...................................................................................................... 36

Table 3. Annual Particulate Matter Emissions given Controlled Operations (2011 – 2015) 37

Table 4. Ranking of Mine Activities based on Particulate Matter Emissions given Partially

Uncontrolled and Controlled 2011 Operations(a) ......................................................... 38

Table 5. Ranking of Mine Activities based on Particulate Matter Emissions for Controlled

Operations (2011-2015)(a) ....................................................................................... 39

Table 6. Wheel Generated Dust from Unsealed Roads - Comparison of Current and Best

Practice Controls for LCO’s Top Four Sources, and Identification of Additional Measures ... 43

Table 7. Bulldozing Overburden - Comparison of Current and Best Practice Controls for

LCO’s Top Four Sources, and Identification of Additional Measures................................. 47

Table 8. Loading/Dumping Overburden - Comparison of Current and Best Practice Controls

for LCO’s Top Four Sources, and Identification of Additional Measures ............................ 48

Table 9. Wind Erosion of Overburden Emplacement Areas - Comparison of Current and Best

Practice Controls for LCO’s Top Four Sources, and Identification of Additional Measures ... 49

Table 10. Summary of Additional Measures Identified for LCO and Increase in Control

Efficiency Achievable ................................................................................................ 50

Table 11. Annual emission reductions due to implementation of additional measures at LCO

............................................................................................................................. 51

Table 12. Implementation Timeline for Additional Control Measures at LCO .................... 53

Liddell Coal Operations

Sustainable Development Framework




of 98


EXECUTIVE SUMMARY

Liddell Coal, located in the Upper Hunter Valley, is operated by Liddell Coal Operations

(LCO) Pty Limited under the conditions of development consent DA 305-11-01. LCO holds

an Environmental Protection Licence (EPL number 2094) under the Protection of the

Environment Operations Act 1997.

On 8 August 2011 the Office of Environment and Heritage (OEH) issued LCO with a notice of

licence variation to EPL 2094, in respect of the Coal Mine Particulate Matter – Best

Management Practice Pollution Reduction Program having been included in this EPL under

Section 58 of the aforementioned act. LCO is required, in terms of the Pollution Reduction

Program, to undertake a Best Management Practice (BMP) Determination comprising the

following main components:

Estimate baseline emissions and determine the four mining activities that currently

generate the most particulate matter;

Estimate the reduction in emissions that could be achieved by applying best practice

measures;

Assess the practicability of each of these measures; and

Propose a timetable for the implementation of any practical measures.

The required particulate matter BMP Determination has been completed and is documented

within this report.

Emission Estimation

A comprehensive emissions inventory was compiled for current LCO operations to provide

an estimate of the extent of such emissions and identify the four mining activities that

currently generate the most particulate matter. Emission estimates were undertaken for

base case year 2011, with emissions projected for the period 2011 to 2015 to assess any

substantial changes in source ranking over coming years.

TSP, PM10 and PM2.5 emission estimates (tonne per year) were quantified for each mining

activity using USEPA AP42 emission estimation techniques, as specified by the OEH’s Coal

Mine Particulate Matter Control Best Practice – Site Specific Determination Guideline –

November 2011.

Top Four Mining Activities

The top four mining activities that contribute the highest emissions of TSP, PM10 and PM2.5

for the 2011 base case year were identified as follows:

1. Wheel Generated Dust (unsealed roads)

2. Loading/Dumping Overburden

3. Bulldozing Overburden

4. Wind Erosion of Overburden Emplacement Areas

When rankings based on TSP emissions are taken into account for the 2011-2015 period,

bulldozing of coal and bulldozing of coarse reject material also fall within the top four

sources in some instances. Control measures applicable for dozing operations on

overburden are expected to be the same for dozing operations on other materials.






of 98


The top four mining activities identified are estimated to have accounted for approximately

85% of the total TSP, PM10 and PM2.5 emissions from Liddell Coal’s 2011 operations taking

into account current control measures.

Additional Control Measures

Best practice measures applicable for managing particulate matter emissions were reviewed

based on a detailed review of the literature and taking into account measures being

implemented by mining operations locally and internationally. In identifying measures

implementable at coal mining operations, attention was paid to technically and economically

viable (or potentially viable) measures.

Based on the inventoried best practice control measures, a gap analysis was undertaken of

LCO’s current control measures, and potential additional controls identified for

consideration. Additional control measures identified are outlined in table below.

Mining Activity Additional Control Measures Identified

Wheel Generated Dust (Unsealed Roads)

1. Truck operators currently reduce speed as a contingency action given adverse conditions or excessive dust. This measure could be enhanced through linking contingency actions to specific visual triggers.

2. Periodic objective monitoring to demonstrate control efficiency (e.g. in situ

road surface entrainment testing / mobile monitoring).

3. Extend the functionality of LCO’s real-time PM10 and meteorological

monitoring system to integrate triggers and alarms (i.e. reactive/predictive air quality control system establishment)

4. Specify adverse conditions (in terms of meteorological conditions and/or PM10 concentrations) when haul activities will be modified to reduce the potential

for dust impacts, as informed by LCO’s reactive/predictive air quality control system.

5. Target an overall haul road dust control efficiency of 80%.

Bulldozing Overburden

6. Specify visual triggers for dozer operations.

7. Specify adverse conditions (in terms of meteorological conditions and/or PM10

concentrations) when dozer operations will be modified to reduce the

potential for dust impacts, as informed by LCO’s reactive/predictive air quality control system.

Loading/Dumping

Overburden 8. Specify adverse conditions (in terms of meteorological conditions and/or PM10

concentrations) when loading and dumping operations will be modified to reduce the potential for dust impacts, as informed by LCO’s reactive/predictive air quality control system.

9. Formalise a procedure for identifying material with high dust potential for

risk-based additional management (e.g. sheltered dumping; emplacement at less wind-exposed areas; wet suppression).

Wind Erosion of Overburden Emplacement

Areas

10. Establish and implement a procedure for regular identification of areas for risk-based management.






of 98


Emission Reductions Achievable

Emission reductions achievable through the implementation of the additional control

measures identified were quantified, to the extent that control efficiencies are available for

the quantification of such reductions. The extent of the emission reductions estimated are

as follows:

Rank Mine Activity Category

Annual Emissions Reductions due to Additional

Controls (tonnes/year)

TSP PM10 PM2.5

1 Wheel Generated Dust 1,269(a) 389(a) 39(a)

2 Loading and Dumping of Overburden 11 – 66(b) 5 - 32(b) 1 - 5(b)

3 Bulldozing of Overburden NQ NQ NQ

4 Wind Erosion of Overburden 19 9 1

Total 1,299 – 1,354 403 - 430 41 - 45

NQ – not quantifiable.

(a) The dust control efficiency of the haul road management system (incorporating chemical

suppression) has been empirically calculated to be above 90% by external contractor

Reynolds Soil Technologies (RST, 2011) (refer to Section 3.31). LCO however currently

applies a control efficiency of 75% to provide a conservative (lower bound) estimate for

emission reporting purposes. It is feasible that the actual control efficiency achieved at

LCO is equivalent to or greater than 80%, and therefore that this emission reduction has

already been achieved during 2011. This will however only be established following the

implementation of objective monitoring during 2012.

(b) Control efficiency estimated to be in the range of 5% to 30%, achievable by avoiding

overburden dumping at wind-exposed areas when hourly average wind speeds exceeded

a threshold in the range of 6 m/s to 10 m/s.

Practicability of Additional Controls for LCO

All additional control measures identified were evaluated and concluded to be practicable for

implementation by LCO taking into implementation costs, regulatory requirements,

environmental impacts, safety implications and compatibility with current and future

operational practices.

All additional control measures identified will therefore be implemented at LCO to reduce

particulate matter emissions, as per the implementation timeline provided in the report.






of 98


1. INTRODUCTION

1.1 Background

Liddell Coal, located in the Upper Hunter Valley, is operated by Liddell Coal Operations

(LCO) Pty Limited under the conditions of development consent DA 305-11-01.

Liddell Coal is an open cut coal mine located approximately 25 kilometres north-west of

Singleton, NSW (Figure 1). LCO is operated by Liddell Coal Operations Pty Ltd, on behalf of

the Liddell Joint Venture between Xstrata Coal Australia Pty Ltd (67.5%) (Xstrata) and

Mitsui Matsushima Australia Pty Ltd (32.5%) (MMA).

LCO’s Environmental Protection Licence (EPL) is administered under the Protection of the

Environment Operations Act 1997. The EPL outlines specific conditions in regard to

environmental reporting and monitoring. LCO currently holds the following EPL:

Licence Number: 2094

File Number: 27051

Licence Anniversary: 30 June

Review Due Date: 07 September 2014

The NSW Office of Environment and Heritage (OEH) has included Pollution Reduction

Programs (PRPs) in coal mine licences during 2011, requiring site-specific Best Management

Practice (BMP) Reviews to be conducted to identify the most practicable means to reduce

particle emissions.

1.2 PRP Requirements

On 8 August 2011 OEH issued LCO with a notice of licence variation to EPL 2094, in respect

of the Coal Mine Particulate Matter – Best Management Practice Pollution Reduction Program

having been included in this EPL under Section 58 of the Protection of the Environment

Operations Act 1997. The requirements of the aforementioned PRP are outlined below.

U1 Coal Mine Particulate Matter Control Best Practice

U1.1 The Licensee must conduct a site specific Best Management Practice (BMP)

determination to identify the most practicable means to reduce particle emissions.

U1.2 The Licensee must prepare a report which includes, but is not necessarily limited to,

the following:

Identification, quantification and justification of existing measures that are being

used to minimise particle emissions;

Identification, quantification and justification of best practice measures that could

be used to minimise particle emissions;

Evaluation of the practicability of implementing these best practice measures; and

A proposed timeframe for implementing all practicable best practice measures.

In preparing the report, the Licensee must utilise the document entitled Coal Mine

Particulate Matter Control Best Practice – Site Specific Determination Guideline –

August 2011.

U1.3 All cost related information is to be included as Appendix A of the Report required by

condition U1.2 above.






of 98


U1.4 The report required by condition U1.2 must be submitted by the Licensee to the Office

of Environment and Heritage’s Regional Manager Hunter, at PO Box 488G,

NEWCASTLE by 6 February 2012.

U1.5 The report required by condition U1.2 above, except for cost related information

contained in Appendix A of the Report, must be made publicly available by the

Licensee on the Licensee’s website by 13 February 2012.

1.21 Scope of Assessment

The BMP review for LCO followed the process outlined in the OEH’s Coal Mine Particulate

Matter Control Best Practice – Site Specific Determination Guideline (hereafter referred to as

the “OEH Guideline”). This process requires that the following steps be followed, as a

minimum:

1. Identify, quantify and justify existing measures that are being used to minimise particle emissions

1.1. Estimate baseline emissions of TSP. PM10 and PM2.5 (tonne per year) from each mining

activity. This estimate must:

1.1.1. Utilise USEPA AP42 emission estimation techniques (or other method as approved in

writing by the EPA)

1.1.2. Calculate uncontrolled emissions (with no particulate matter controls in place); and

1.1.3. Calculate controlled emissions (with current particulate matter controls in place).

Note: These particulate matter controls must be clearly identified, quantified and justified with supporting information. 1.2. Using the results of the controlled emissions estimates generated from Step 1.1, rank the

mining activities according to the mass of TSP. PM10, and PM2.5 emitted by each mining

activity per year from highest to lowest.

1.3. Identify the top four mining activities from Step 1.2 that contribute the highest emissions of

TSP, PM10 and PM2.5.

2. Identify, quantify and justify the measures that could be used to minimise particle emissions

2.1. For each of the top four activities identified in Step 1.3, identify the measures that could be

implemented to reduce emissions taking into consideration:

2.1.1. The findings of Katestone (June 2011). NSW Coal Mining Benchmarking Study –

International Best Practice Measures to Prevent and/or Minimise Emissions of Particulate

Matter from Coal Mining, Katestone Environmental Pty Ltd, Terrace 5 , 249 Coronation

Drive, PO Box 2217, Milton 4064, Queensland, Australia.

2.1.2. Any other relevant published information; and

2.1.3. Any relevant industry experience from either Australia or overseas.

2.2. For each of the top four activities identified in Step 1.3, estimate emissions of TSP, PM10 and

PM2.5 from each mining activity following the application of the measures identified in Step

2.1.

3. Evaluate the practicability of implementing these best practice measures

3.1. For each of the best practice measures identified in Step 2.1, assess the practicability

associated with their implementation, by taking into consideration:

3.1.1. Implementation costs;

3.1.2. Regulatory requirements;

3.1.3. Environmental impacts;

3.1.4. Safety implications; and

3.1.5. Compatibility with current processes and proposed future developments.

3.2. Identify those best practice measures that will be implemented at the premises to reduce

particle emissions.






of 98


4. Propose a timeframe for implementing all practicable best practice measures

4.1. For each of the best practice measures identified as being practicable in Step 3.2, provide a

timeframe for their implementation.

In evaluating practicability in Step 3, the licensee must document the following specific information: Estimated capital, labour, materials and other costs for each best practice measure on an

annual basis for a ten year period. This information must be set out in the format provided in

Appendix A and included as an attachment to the report;

The details of any restrictions on the implementation of each best practice measure due to an

existing approval or licence;

Quantification of any new or additional environmental impacts that may arise from the

application of a particular best practice measure, such as increased noise or fresh water use;

The details of safety impacts that may result from the application of a particular best practice

measure;

The details of any incompatibility with current operational practices on the premises; and

The details of any incompatibility with future development proposals on the premises.

1.22 Costing of Measures

The cost information referenced in the OEH Guideline is required to allow the NSW

Environmental Protection Authority (EPA) to verify that a particular best practice measure is

not practicable at a particular site.

In subsequent advice provided, the EPA has indicated that any licensee may choose not to

submit cost information for best practice measures that are either currently being

implemented, or that are considered by the licensee to be practicable (personal

communication, Mitchell Bennett, Head, Regional Operational Unit – Hunter, NSW EPA, 27

January 2012) (refer to Appendix A).

1.23 Additions and Clarifications for OEH Mining Activity Categories

Mining activities are defined in the OEH Guideline as including any of the following activities:

Wheel generated particles on unpaved roads

Loading and dumping overburden

Blasting

Bulldozing coal

Trucks unloading overburden

Bulldozing overburden

Front-end loaders on overburden

Wind erosion of exposed areas

Wind erosion of coal stockpiles

Wind erosion of overburden emplacement areas

Unloading from coal stockpiles

Dragline

Trucks unloading coal

Loading coal stockpiles






of 98


Graders

Drilling

Coal crushing

Material transfer of coal

Scrapers on overburden

Train loading

Screening

Material transfer of overburden

Emission factors applied for crushing operations encompass the entire crushing circuit

including screening operations. The “coal crushing” and “screening” activity categories were

therefore combined for the purpose of this study.

Loading and unloading of coal stockpiles was taken to refer to stacking and reclaiming

operations respectively.

“Trucks unloading coal” was taken to mean trucks unloading to the ROM coal hopper, with

“material transfer of coal” applied for conveyor transfer points.

The list of mining activities defined within the OEH Guidelines was extended to include

“trucks loading coal”, specifically applicable for excavators/shovels/loaders loading coal

trucks.

“Loading and dumping overburden” was taken to mean the loading of trucks with

overburden and trucks dumping overburden respectively. Given that there are no other

transfers of overburden, the “material transfer of overburden” activity category was

omitted.

Emissions from topsoil handling (loading, dumping, dozer operations) was included in the

mining activity categories given for overburden.

The list of mining activities was extended to make provision for reject handling and rock

crushing, with the addition of the following activities: “bulldozing rejects”, “material transfer

of rejects” and “other crushing (waste rock)”.






of 98


Figure 1. LCO Locality Map






of 98


2. OVERVIEW OF OPERATIONS

2.1 Operations

Land preparation at LCO is undertaken generally in accordance with the LCO mine

operations plan (MOP). Land preparation ahead of mining operations involves the

construction of appropriate erosion and sediment control structures, the clearing of

vegetation and stripping and stockpiling of topsoil. Land disturbance is minimised by

clearing the smallest practical area of land for the shortest possible time. This is achieved

by:

limiting the cleared width to that required to accommodate excavation plus areas

required for access, overburden emplacement and topsoil stockpiling;

programming the works so that only the areas which are actively being excavated

are cleared; and

implementation of erosion and sediment controls in disturbed areas to control and

manage dirty water.

Vegetation cleared during land preparation was cleared in accordance with Liddell Coal

Environmental Procedure for Site Clearing and the control measures outlined in the

Environmental Assessment for Modification to Liddell Coal Development Consent (EA).

Approximately 93 hectares equal to approximately 88,600 m³ of topsoil was removed ahead

of open cut mining during 2010/2011 period. The topsoil was stockpiled and a portion was

recovered and used in rehabilitation during the reporting period. To ensure topsoil is

managed effectively at LCO the following measures are taken:

soils are stripped as much as practicable in optimum moisture conditions, not in wet or

dry conditions;

stripped material is placed directly onto reshaped overburden and spread where

possible;

soils are strategically located in stockpiles not exceeding three metres in height; and

stockpiles are sown and fertilised as soon as possible to prevent weed growth.

Open cut mining is undertaken at LCO using hydraulic excavators, shovel and trucks. Once

all vegetation and topsoil is cleared, weathered material is removed. When unweathered

rock is encountered a flat bench is established using earthmoving equipment, allowing

access for drilling equipment to prepare the area for blasting. Three drill rigs are used. The

blast holes are loaded with explosives and are detonated in a controlled sequence to break

up the overburden.

One hydraulic shovel and two hydraulic excavators load overburden to rear dump trucks for

transport to the overburden emplacement areas which are generally located in worked out

pit areas. During 2010/2011 approximately 100 million tonnes of overburden was removed.

Exposed coal is mined using hydraulic excavators which load trucks. Run-of-mine (ROM)

coal is transported from the open cut pits by haul trucks to the coal handling and

preparation plant (CHPP) ROM Coal Hopper for direct feed into the LCO Preparation Plant or

to one of the on-site ROM Coal stockpiles (Figure 2). The coal is stockpiled in a ROM

stockpile prior to processing by the CHPP.






of 98


Figure 2. LCO CHPP operations






of 98


Following processing by the CHPP, the coal is stockpiled in a product stockpile with a

capacity for 400,000 tonnes before being railed to the Port of Newcastle. The CHPP

produces both semi soft coking coal and thermal coal. The CHPP has a capacity of 7 Mtpa

and operates 24hrs a day, 7 days a week with the exception of a fortnightly maintenance

shutdown generally lasting 10 to 12 hours. .

The total ROM coal processed at Liddell’s CHPP during the 2010/2011 period was 6,326,228

tonnes, with 4,311,233 tonnes of product coal being produced. A total of 107,508 coarse

reject and 35,914 tonnes of fine rejects were generated. Coarse reject is dewatered and

backhauled for co-disposal at in pit spoils. Fine rejects (tailings) from the LCO CHPP are

pumped to the Antiene Void and Reservoir Tailings Dam.

The LCO haul fleet comprises 18 Hitachi EH5000 300t capacity rear dump trucks and 12

Caterpillar 789C 170t dump trucks. The haul roads are maintained using graders and water

carts, with a dust surfactant being applied, to minimise dust generation and provide a safe

working roadway. Three 70,000 litre capacity Caterpillar 777F water trucks are used.

Gravel sheeting of haul roads is also applied to reduce dust generation.

2.2 Mine Activities with Potential Air Emissions

Several mining activities at LCO have the potential to result in particulate matter emissions,

including:

Dozers stripping topsoil;

Topsoil stockpiling and handling;

Dozers shaping overburden (rehabilitation);

Topsoil dumping and handling (rehabilitation)

Drilling and blasting of overburden;

Bulldozer operations on coal and overburden (in pit);

Loading and dumping of overburden;

Loading of ROM coal;

Hauling of overburden to emplacement areas;

Hauling of coal to ROM pad / ROM hopper;

Trucks unloading coal to ROM stockpile;

Trucks unloading coal to ROM hopper;

Dozers on ROM stockpile – loading coal to ROM hopper;

Coal crushing and screening;

Conveyors and conveyor transfer points;

Dozers on product coal stockpiles;

Train loading;

Loading coarse reject to trucks;

Hauling and handling of rejects;

Dozer working reject material;






of 98


Handling and crushing of rock for gravel surfacing of roads;

Grader operations;

General vehicle activity on site (light vehicles, fuel trucks, water trucks, delivery

trucks);

Coal stockpiles, topsoil stockpiles, active mining area, overburden emplacement areas,

Antiene North (dry tailings impoundment),and unsealed roads (wind erosion

potential); and

Spontaneous combustion (when mining through old underground workings in Liddell

Seam).

2.3 Overview of Air Quality Management and Monitoring

Ongoing management of air quality is undertaken at LCO in line with the Liddell Coal

Environmental Monitoring Program, Dust Management Procedure, and Spontaneous

Combustion Management Plan. Air quality monitoring is undertaken in accordance with the

Liddell Coal Air Quality Monitoring Program.

The Air Quality Monitoring Program was developed in accordance with schedule 3 condition

19 of the development consent. As such, the Air Quality Monitoring Program includes a

combination of high volume air samplers (HVAS) and dust deposition gauges to monitor the

dust emissions of the development, and an air quality monitoring protocol for evaluation of

compliance with the air quality impact assessment and land acquisition criteria. LCO’s dust

monitoring system is comprised of 10 dust gauges and four high volume air samplers

(HVAS) including two TSP samplers and two PM10 samplers. Air quality monitoring locations

are illustrated in Figure 3.

In addition, LCO installed two Tapered Element Oscillating Microbalance’s (TEOM) for fine

particulates (PM10) in 2010. The TEOM’s were installed for the purpose of providing

continuous real time dust monitoring results to determine possible offsite impacts from dust

emissions. LCO also installed a new meteorological station in 2010 at the office and

workshop complex to provide representative, real time meteorological data for air quality

management purposes.

Real-time meteorological monitoring is conducted with data logged on a 5-minute average

basis. Parameters recorded include wind speed, wind direction, sigma theta (wind

deviation), air temperature at 2m and 10m above ground, relative humidity, barometric

pressure, rainfall, solar radiation, and evapo-transpiration.

All sampling equipment, procedures, data analysis and reporting is carried out in accordance

with the relevant Australian Standards and Liddell’s EMS procedure – Environmental

Monitoring and Evaluation.

LCO personnel have access to off-site particulate monitoring data. Daily real time dust

reports from offsite dust monitors are emailed to senior management daily for inspection.

Visible dust monitoring is ongoing at LCO. Documented dust inspections are undertaken

regularly, and Mining Supervisors are continually monitoring visible dust from the

operations. Documented corrective action and auditing is undertaken in adverse dust

conditions.






of 98


Figure 3. Location of LCO Air Quality Monitoring Stations






of 98


Areas of spontaneous combustion have been found when mining through the old

underground workings in the Liddell Seam. The Spontaneous Combustion Management Plan

outlines the standards to be maintained, the monitoring system and the procedures to be

followed in the case of a spontaneous combustion incident. A procedure has been

developed for managing drill and blast operation of area suspected to be liable to

spontaneous combustion. The mine design incorporates the use of benches for sealing off

the highwall to minimise the ingress of oxygen, and the flooding of heated areas prior to

mining with recycled mine water. Every effort is made in managing heat affected

overburden or coal which is cooled and saturated with water where practicable prior to

mining to minimise dust generation.

Specific air quality management measures applied by LCO include the following:

Regular dust inspections are carried out and excavation and tipping activities may be

ceased or modified if excessive dust is observed;

Real time dust monitoring is undertaken to assist with the management of dust on-

site;

Disturbance of the minimum area necessary for construction and prompt

rehabilitation of construction areas;

Watering of roads and trafficked areas to minimise the generation of dust;

Permanent roads are constructed from hard non-friable material and have defined

marker posts to prevent vehicle deviations;

Chemical suppression is applied on unsealed roads to reduce the dust generation

potential;

Long term topsoil stockpiles are vegetated to reduce dust generation;

Permanent overburden emplacements are shaped to 10 degrees or less and seeded;

Dust suppression sprays situated on the ROM dump hopper and transfer conveyor

points are actuated to reduce potential dust generation; and

All equipment is maintained in good working order to reduce emissions.

Further details of these and other air quality management practices at LCO is provided in

subsequent sections.

Operational procedures for dust control are reviewed when required. Training courses are

presented to all personnel, and monthly toolbox talks are undertaken to report on and

reinforce air quality management as required.






of 98


3. EXISTING EMISSIONS AND CONTROL MEASURES

3.1 Introduction

A comprehensive emissions inventory was compiled for current LCO operations to provide

an estimate of the extent of such emissions and identify the four mining activities that

currently generate the most particulate matter. Results are presented in this section

including:

TSP, PM10 and PM2.5 emission estimates (tonne per year) for each mining activity

using USEPA AP42 emission estimation techniques, including partially uncontrolled

emissions and emissions with current controls in place.

Ranking of mining activities according to the mass of TSP, PM10, and PM2.5 emitted by

each mining activity per year.

Identification of the top four mining activities that contribute the highest emissions

of TSP, PM10 and PM2.5.

3.2 Study Limitations

The OEH Guideline requires that uncontrolled and controlled emissions be quantified. The

accurate quantification of uncontrolled emissions is not feasible given that a significant

number of management measures are integrated within mine design, mine planning and

site operations which are not easily quantifiable. This includes LCO’s use of trucks with

larger capacity, progressive rehabilitation, source avoidance measures (e.g. minimising

areas of disturbance and reducing haul distances), and the site’s modification and ceasing of

operations during adverse meteorological conditions or high particulate matter

concentrations. For the purpose of the current study, partially uncontrolled emissions are

presented, with only additional, quantifiable control measures excluded.

A further limitation is that control efficiencies cannot be established for all types of

management measures applied. By example, emission reductions realised by undertaking

sheltered dumping during strong winds, and haul truck operators actively varying truck

speeds to address visible dust levels, are not quantifiable.

In some cases emission estimates may provide an upper bound (conservative) estimate of

emissions due to upper bound operating hours being assumed for certain activities. For

example, operational hours available for bulldozer operations are known to include periods

during which dozers are not actively engaged in work. In the emission estimation however

equivalent dozer emission rates are allocated for all reported operating hours.

3.3 Current Measures and Control Efficiencies

Existing particulate matter control measures being implemented at LCO are documented in

this section, with control efficiencies associated with such measures (where quantifiable)

provided.

3.31 Unsealed Roads

Control measures applied at LCO to minimise particulate matter emissions from unsealed

roads include the following:

Obsolete roads are ripped and revegetated.

Permanent roads are constructed from hard non-friable material and have defined

marker posts to prevent vehicle deviations.






of 98


Sheeting the main haul roads with crushed rock gravel (Figure 4). Gravel surfacing

is applied across all of the major haul roads on site during construction, with

resurfacing as necessary.

Figure 4. Gravel surfacing of unsealed roads at LCO

Application of a chemical surfactant (Petrotac) on the unsealed road leading to the

workshop.

A Haul Road Management System (HRMS) and a chemical surfactant (water extender)

is applied on on-site unsealed roads. Reynolds Soil Technologies’ RT9 product is used.

RT9 comprises a blend of polymers and surfactants, supplied as a viscous liquid, that is

simply diluted into water carts at very low dosage rates and sprayed onto haul roads

as part of the standard haul road water procedure. Application is intended to:

- Improve water penetration

- Bind fine dust particles

- Consolidate haul road surfaces

RT9 is added to water carts at a dosage rate of 1:3000 using an automated dosing

system. Product is applied on a continual basis to about 32 km of haul road to achieve

water savings, dust suppression, improved road conditions. The HRMS is managed by

a contractor, Reynolds Soil Technologies, with a monthly performance report issued to

Liddell Coal. Key Performance Indicators which are tracked are as follows:

- Watercart hours

- Water usage

- Water applied/m² (Figure 5)






of 98


- Distance covered by the watercart

- Time taken to empty the watercart

- Other variables tracked:

- Time between applications

- Product application

- Rainfall, evaporation and temperature

- Visible dust (Figure 6)

- Grading activities

Change to owner operator has provided a greater control of water cart usage.

Operational procedures for watering of the roads are in place (Road Watering Dust

Suppression mining procedure).

Figure 5. Water application rates on unsealed roads at LCO for the period

December 2010 to October 2011, with chemical surfactant (RT9) in use (Source:

Reynolds Soil Technologies, October 2011)






of 98


Figure 6. Visual monitoring of road dust levels at LCO

According to RST, the empirically-derived control effectiveness of RT9 application on

unsealed haul roads at LCO is estimated to be over 90%, as indicated in Figure 7 for the

period December 2010 to October 2011. This control effectiveness will need to be verified

on the ground for the LCO application.

Figure 7. Dust control efficiency due to RT9 application on unsealed haul roads at

LCO for the period December 2010 to October 2011 (Source: Reynolds Soil

Technologies, October 2011)






of 98


NOTE: The dust control efficiency of the haul road management system (incorporating

chemical suppression) has been empirically calculated to be above 90% by external

contractor Reynolds Soil Technologies (RST, 2011). LCO however currently applies a

control efficiency of 75% to provide a conservative (lower bound) estimate for emission

reporting purposes, pending objective measurement of the control effectiveness of the haul

road management system.

A control efficiency of 75% coincides with the control efficiency specified in NPI EETM Mining

(2011) for Level 2 watering, and with the maximum control efficiency indicated by the US-

EPA (2006) to be achievable through wet suppression.

It is feasible that the actual control efficiency being achieved through haul road

management and chemical suppression at LCO is currently equivalent to or greater than 80%,

however LCO elects at this time to assume a lower control efficiency pending the verification

of the in situ control effectiveness of this measure.

3.32 Loading and Dumping of Overburden

Overburden loading is undertaken by excavator at Liddell Coal, trucked and emplaced within

overburden emplacement areas (Figure 8).

Significant control measures implemented to address particulate matter emissions from

overburden dumping include:

Modifying (e.g. sheltered dumping) or cease excavation and tipping activities if

excessive dust is observed.

Provision of in-pit dumping locations for periods of high wind, where practicable.

Detailed logs are not currently kept by LCO regarding when sheltered dumping is

undertaken. For this reason it is not possible to allocate a control efficiency for the control

measures implemented.

It is estimated that the control efficiency of the above measures is likely to be in the range

of 5-30% in the event that unsheltered dumping is avoided when wind speeds are above an

hourly-average wind speed threshold in the range of 6 m/s to 10 m/s. Detailed logs are

however not readily available to determine when sheltered dumping is implemented. The

allocation of control efficiencies for this important measure is therefore not possible.






of 98


Figure 8. Overburden dumping at LCO

3.33 Rehabilitation of Exposed Areas

Significant particulate matter emissions may occur due to wind erosion of overburden

emplacement areas if successful measures are not implemented. Measures implemented at

LCO include:

Minimising areas disturbed by mining activities.

Prompt, progressive rehabilitation of disturbed areas following completion of mining.

Detailed design of overburden dump shapes to minimise profile exposure to off-site

receptors and to reduce surface wind speeds and turbulence.

Temporary rehabilitation of cleared, unmined areas to assist in dust control.

Rehabilitation of disturbed land is carried out generally in accordance with the Liddell mining

operations plan (MOP). LCO’s permanent rehabilitation plan for 2012 is illustrated in Figure

9. As at September 2011, a total of 564 ha were currently disturbed and 557 ha having

been levelled/recontoured and seeded.

An overview of progressive rehabilitation methods applied is given below. Photographs of

the progressive rehabilitation of the overburden emplacement area, in proximity to the

dump face, are provided in Figure 10, Figure 11 and Figure 12.

Landform Design

Post-mining landform design is generally undertaken in accordance with the DPI’s ‘Synoptic

Plan: Integrated Landscapes for Coal Mine Rehabilitation in the Hunter Valley of NSW’.

Topsoil Management

Where possible, topsoil is stripped at optimum moisture to help maintain soil

structure and to reduce dust generation;

Stockpiles are generally less than three metres high;






of 98


Stockpiles to be kept longer than three months are sown with a suitable cover crop

to minimise erosion;

Stockpiles are appropriately sign-posted to identify the area and minimise the

potential for unauthorised use or disturbance.

Surface Preparation

Surface preparation activities for rehabilitated areas are commenced as soon as possible

following the completion of mining activities.

LCO OEAs are orientated such that unrehabilitated dumps are generally protected from the

strong northwesterly winds. Older rehabilitated dumps are generally northwest facing which

mitigates the impact of wind erosion during these northwesterly winds. Overburden

emplacements are shaped to 10 degrees or less and seeded.

Revegetation

Revegetation activities are generally undertaken in spring and autumn; however,

opportunistic revegetation may be practised if areas become available for sowing in summer

and winter. After surface soil amelioration and tillage is completed for any given area,

revegetation will commence as soon as practicable.

Primarily, revegetation involves sowing of pasture species and direct seeding of native tree

species. A range of other techniques may also be utilised where appropriate over isolated

areas associated with steep slopes.

Revegetation techniques are continually developed and refined over the life of the mine

through a continual process of research, trialling, monitoring and improvement.

Rehabilitation Inspections and Audits

Rehabilitation Inspection and Audits are undertaken by external, third parties. The main

objectives of inspections are to assess LCO’s performance against its rehabilitation

commitments and identify opportunities to:

reduce overall site disturbance footprint through progressive rehabilitation, with a

particular focus on reducing the overall area of site disturbance in the short to medium

term; and

enhance the quality of any older rehabilitation areas or legacy issues on site to ensure

that rehabilitation objectives are met and a sustainable post-mining land use is

achieved.

Rehabilitation Monitoring

Rehabilitation monitoring is conducted at four sites. Each plot is 400 m², a size which is widely used and recommended by OEH.

Further Development of the Final Rehabilitation Plan

The rehabilitation objectives and final landform are being further developed during the MOP

period and through detailed mine closure planning.






of 98


Temporary Rehabilitation

LCO have also been working towards seeding cleared, unmined areas in an attempt to

control dust. Temporary seeding rehabilitation works were carried out near the ROM pad to

assist in dust control and visual enhancement along Pikes Gully Road (Figure 13, Figure 14).

As recommended by Global Soil Systems in their July 2009 Rehabilitation Audit, biosolids

were applied (at the rate of 50-100 t/Ha) to 17 Ha of overburden/subsoil bare areas in the

Reservoir Block during Q4 2009 and Q1 2010, along with gypsum applied at the rate of 10

t/Ha. This area was seeded with the typical Liddell seed mix and fertilizer, with successful

results. Other areas in the Reservoir Block and along the railway line were top-dressed with

topsoil, gypsum and the typical Liddell seed mix and fertilizer. Temporary seeding resulted

in good ground coverage (Figure 13, Figure 14). Seeding took place in Q4 2009 and Q1

2010. Photos were taken in November 2011.






of 98


Figure 9. LCO’s 2012 Rehabilitation Plan






of 98


3.34 Coal Extraction, Handling, Processing and Load out

Air quality management measures applied by LCO are as follows:

Regular dust inspections are carried out and coal excavation and tipping activities

may be ceased or modified if excessive dust is observed.

Water sprays are applied at the ROM stockpile area (Figure 15).

Water sprays at applied at the ROM coal hopper. Hopper is level with the ground.

(Figure 18)

ROM coal conveyors and transfers are enclosed (Figure 13).

Product coal conveyors and transfer points are equipped with water sprays and

enclosed (Figure 16).

Reject conveyors and transfer points are partially enclosed (roof and one side)

(Figure 17).

Coal crushing operations are enclosed with water sprays implemented (Figure 19,

Figure 20).

Train loading is partially enclosed with water sprays in operation.

3.35 Allocation of Control Efficiencies

Control efficiencies are not readily quantifiable for all measures applied. Measures for which

control efficiencies could be established based on published control factors are documented

in Table 1. Emission reductions due to rehabilitation efforts are accounted for by emission

estimates only being quantified for exposed, unrehabilitated areas.






of 98


Figure 10. Proximity of rehabilitation to

dump face (November 2011).

Photograph shows rehabilitation on

either side of the access road, with

rehabilitation area on the left in the

immediate vicinity of the dump face

(mounds evident).

Figure 11. Vegetation on surface of

overburden emplacement area. Seeded

March 2011. Photograph taken in

November 2011.

Figure 12. Vegetation on surface of

overburden emplacement area. Seeded

March 2011. Photograph taken in

November 2011.






of 98


Figure 13. Temporary rehabilitation in the

vicinity of the LCO ROM pad undertaken in

Q4 of 2009 and Q1 of 2010. Photograph

taken in November 2011. Enclosed ROM

coal conveyor shown in the foreground.

Figure 14. Temporary rehabilitation in the

vicinity of the LCO ROM pad undertaken in

Q4 of 2009 and Q1 of 2010. Photograph

taken in November 2011.






of 98


Figure 15. LCO ROM stockpile water

sprays

Figure 16. Enclosed product coal

conveyor

Figure 17. Partially enclosed coarse

reject conveyor






of 98


Figure 18. LCO ROM coal hopper

Figure 19. ROM coal conveyor entering

enclosed crusher station.

Figure 20. ROM coal conveyor entering

enclosed crusher station.






of 98


Table 1. Current Control Measures and Allocated Control Efficiencies (where

available)

Activity/Source Control Measure Description

Current Control Efficiency (%)(a)

TSP PM10 PM2.5

% % %

Drilling of Overburden

Water sprays on drills 70 70 70

Conveying of ROM Coal ROM Coal conveyors and transfer points are enclosed

70 70 70

Conveying of Product Coal Product Coal conveyors are almost fully enclosed with under-pans in place

70 70 70

Product Coal conveyor equipped with water sprays and enclosure(b)

85 85 85

Conveying of Coarse Rejects

Coarse Reject conveyors and transfer points are partially enclosed (roof and one side)

70 70 70

Crushing Operations Coal crushing operations are enclosed with

water sprays implemented(c) 85 85 85

Train Loading Partially enclosed with water spays 70 70 70

Vehicle Activity on Unsealed Roads

Haul road management system, including chemical surfactant application(d)

75 75 75

Dozer working coarse rejects

Wind break 30 30 30

Wind erosion of unsealed roads


50 50 50

Wind erosion of

Overburden Emplacement Areas under Secondary Rehabilitation

Secondary rehabilitation(e)

60 60 60

Wind Erosion of ROM Coal stockpile

Stockpile water sprays 50 50 50

Loading of Overburden Drop height reduction from 3m to 1.5m(f) 30 30 30

(a) Control efficiencies were derived from the NPI EETM Mining (2011), and the US-EPA

AP42 Emission Factor literature. The method for calculating combined control efficiencies

was taken from NPI EETM Mining (2011).

(b) A control efficiency of 70% was applied for enclosure, and an additional 50% control

efficiency for water sprays, giving a combined control efficiency of 85%.

(c) A control efficiency of 70% was applied for enclosure, and an additional 50% control


(d) The dust control efficiency of the haul road management system, which includes

chemical suppression, was estimated to be above 90% by external contractor Reynolds

Soil Technologies (refer to Section 3.31). For emission reporting purposes, LCO

currently claims a control efficiency of 75% to provide a conservative (lower bound)

estimated pending objective measurement of the control effectiveness of the HRMS. A

control efficiency of 75% coincides with the control efficiency specified in NPI EETM

Mining (2011) for Level 2 watering, and with the maximum control efficiency indicated

by the US-EPA (2006) to be achievable through wet suppression. It is feasible that the

actual control efficiency being achieved through chemical suppression is currently

equivalent to or greater than 80%.






of 98


(e) Control efficiencies of 40% to 100% applicable for permanent rehabilitation areas

depending on duration in place, coverage, demonstration of self-sustaining (etc.). For

2010/2011 emission estimates control efficiency of 60% was applied for the 93 ha area

rehabilitated during 2009/2010, with a control efficiency of 100% applied for areas

rehabilitated earlier.

(f) Control efficiency referenced within Katestone (2011) for application to truck loading

operations, as calculated based on the dragline equation (Refer to Appendix B).

3.4 Particulate Matter Emissions

3.41 Current Measures and Control Efficiencies

Annual TSP, PM10 and PM2.5 emissions (tpa) estimated utilising USEPA AP42 emission

estimation techniques and site-specific information was undertaken as documented in

Appendix B.

Annual TSP, PM10 and PM2.5 emissions (tpa) estimated for each OEH-defined mining activity

utilising USEPA AP42 emission estimation techniques are provided for 2011 Operations

within Table 2 for:

Partially uncontrolled emissions (excluding additional, quantifiable particulate matter

controls already in place); and

Controlled emissions (with current particulate matter controls in place, where such

controls are quantifiable and control efficiencies available).

Annual TSP, PM10 and PM2.5 emissions (tpa) estimated for each OEH-defined mining activity

projected for LCO operations during the 2011 to 2015 period, given current controls, are

summarised within Table 3.

3.5 Ranking of Mine Activities

OEH-defined mining activities were ranked based on their contribution to total annual TSP,

PM10 and PM2.5 emissions. Activity rankings for 2011 operations, given uncontrolled and

controlled emissions, are presented in Table 4.

Activity rankings for 2011-2015 operations given current controls are presented in Table 5.

3.6 Top Four Mining Sources

Based on the assigned rankings, the top four mining activities that contribute the highest

emissions of TSP, PM10 and PM2.5 for the 2011 base case year were identified as follows:

1. Wheel Generated Dust (unsealed roads)

2. Loading/Dumping Overburden

3. Bulldozing Overburden

4. Wind Erosion of Overburden Emplacement Areas

In the event that different rankings were derived across particle size classes, emphasis was

based on rankings assigned based on PM10 and PM2.5 emissions due to the greater health

risk potential associated with finer particles.

When rankings based on TSP emissions are taken into account for the 2011-2015 period,

bulldozing of coal and bulldozing of coarse reject material also fall within the top four

sources in some instances. Control measures applicable for dozing operations on

overburden are expected to be the same for dozing operations on other materials.






of 98


The top four mining activities identified are estimated to have accounted for approximately

85% of the total TSP, PM10 and PM2.5 emissions from Liddell Coal’s 2011 operations taking

into account current control measures.






of 98


Table 2. Annual Particulate Matter Emissions given Partially Uncontrolled and Controlled 2011 Operations

Mine Activity Categories

Partially Uncontrolled Current Controls

Annual Emissions (tonnes/year) Annual Emissions (tonnes/year)

TSP PM10 PM2.5 TSP PM10 PM2.5 Wheel Generated Dust 25,389.00 7,781.56 778.16 6,347.25 1,945.39 194.54

Wind Erosion of Overburden 279.65 139.83 20.97 232.22 116.11 17.42

Loading/Dumping Overburden/Topsoil 1,123.82 619.01 72.72 853.34 464.84 55.68

Blasting 152.35 79.22 4.57 152.35 79.22 4.57

Bulldozing Coal 403.24 92.24 8.95 403.24 92.24 8.95

Bulldozing Rejects 60.75 11.65 1.34 42.52 8.16 0.94

Bulldozing Overburden/Topsoil 536.18 256.03 89.92 536.18 256.03 89.92

Wind Erosion of Exposed Areas 198.90 99.45 14.92 180.63 90.31 13.55

Wind Erosion of Coal Stockpiles 17.70 8.85 1.33 12.39 6.20 0.93

Material Transfer Rejects 2.11 0.45 0.04 2.11 0.45 0.04

Trucks unloading Coal (hopper) 302.60 43.52 5.75 302.60 43.52 5.75

Loading Coal Stockpiles 122.13 17.79 2.36 121.37 17.52 2.32

Graders 469.96 128.81 14.57 117.49 32.20 3.64

Drilling 48.44 25.19 1.45 14.53 7.56 0.44

Coal Crushing 254.77 101.91 38.22 38.22 15.29 5.73

Loading Coal to Trucks 151.30 41.34 5.75 151.30 41.34 5.75

Material Transfer of Coal 5.93 2.67 0.40 3.87 1.81 0.27

Train Loading 1.09 0.38 0.06 0.33 0.11 0.02

Other Crushing (waste rock) 1.43 0.57 0.22 1.43 0.57 0.22

TOTAL 29,521.34 9,450.47 1,061.68 9,513.36 3,218.88 410.66



LCO SD FWK 0006 Coal Mine Particulate Matter Control Best Management Practice

Determination



of 98


Table 3. Annual Particulate Matter Emissions given Controlled Operations (2011 – 2015)

Mine Activity

Categories

2011 2012 2013 2014 2015

Annual Emissions

(tonnes/year)

Annual Emissions

(tonnes/year)

Annual Emissions

(tonnes/year)

Annual Emissions

(tonnes/year)

Annual Emissions

(tonnes/year)

TSP PM10 PM2.5 TSP PM10 PM2.5 TSP PM10 PM2.5 TSP PM10 PM2.5 TSP PM10 PM2.5

Wheel Generated

Dust 6,347.25 1,945.39 194.54 4,902.60 1,502.61 150.26 3,404.55 1,043.47 104.35 2,080.62 637.70 63.77 2,037.91 624.61 62.46

Wind Erosion of Overburden 232.22 116.11 17.42 252.45 126.23 18.93 275.40 137.70 20.66 247.35 123.68 18.55 275.40 137.70 20.66

Loading/Dumping Overburden/Topsoil 853.34 464.84 55.68 849.52 462.76 55.43 829.60 451.91 54.13 853.88 465.14 55.71 836.36 455.59 54.57

Blasting 152.35 79.22 4.57 151.67 78.87 4.55 148.11 77.02 4.44 152.45 79.27 4.57 149.32 77.65 4.48

Bulldozing Coal 403.24 92.24 8.95 459.99 105.42 10.21 445.88 101.99 9.90 442.75 101.41 9.83 434.24 99.33 9.64

Bulldozing Rejects 42.52 8.16 0.94 652.18 125.09 14.35 660.08 126.61 14.52 698.90 134.05 15.38 695.23 133.35 15.29

Bulldozing

Overburden/Topsoil 536.18 256.03 89.92 432.60 223.49 78.89 392.60 208.98 73.91 369.19 204.26 72.41 418.37 217.69 76.88

Wind Erosion of

Exposed Areas 180.63 90.31 13.55 185.39 92.70 13.90 187.67 93.84 14.08 229.05 114.53 17.18 221.01 110.51 16.58

Wind Erosion of Coal Stockpiles 12.39 6.20 0.93 13.81 6.91 1.04 13.71 6.86 1.03 13.38 6.69 1.00 13.36 6.68 1.00

Material Transfer Rejects 2.11 0.45 0.04 32.29 6.90 0.61 32.68 6.99 0.62 34.61 7.40 0.66 34.42 7.36 0.65

Trucks unloading

Coal (hopper) 302.60 43.52 5.75 354.79 51.02 6.74 334.35 48.08 6.35 338.96 48.75 6.44 325.42 46.80 6.18

Loading Coal

Stockpiles 121.37 17.52 2.32 142.27 20.53 2.71 134.10 19.36 2.56 135.93 19.62 2.59 130.52 18.84 2.49

Graders 117.49 32.20 3.64 90.75 24.87 2.81 63.02 17.27 1.95 38.51 10.56 1.19 37.72 10.34 1.17

Drilling 14.53 7.56 0.44 14.47 7.52 0.43 14.13 7.35 0.42 14.54 7.56 0.44 14.24 7.41 0.43

Coal Crushing 38.22 15.29 5.73 44.81 17.92 6.72 42.22 16.89 6.33 42.81 17.12 6.42 41.10 16.44 6.16

Loading Coal to Trucks 151.30 41.34 5.75 177.39 48.47 6.74 167.17 45.68 6.35 169.48 46.31 6.44 162.71 44.46 6.18

Material Transfer of Coal 3.87 1.81 0.27 4.53 2.12 0.32 4.28 2.00 0.30 4.33 2.03 0.31 4.17 1.95 0.30

Train Loading 0.33 0.11 0.02 0.35 0.12 0.02 0.36 0.13 0.02 0.34 0.12 0.02 0.35 0.12 0.02

Other Crushing (waste rock) 1.43 0.57 0.22 1.43 0.57 0.21 1.39 0.56 0.21 1.44 0.57 0.22 1.41 0.56 0.21

TOTAL 9,513.36 3,218.88 410.66 8,763.28 2,904.12 374.90 7,151.33 2,412.68 322.13 5,868.53 2,026.77 283.12 5,833.26 2,017.37 285.35




Determination



of 98


Table 4. Ranking of Mine Activities based on Particulate Matter Emissions given Partially Uncontrolled and

Controlled 2011 Operations(a)

Mining Activity Category

Partially Uncontrolled Current Controls (2011)

TSP ranking PM10 ranking PM2.5 ranking TSP

ranking PM10

ranking PM2.5

ranking

Wheel Generated Dust 1 1 1 1 1 1

Wind Erosion of Overburden 7 4 5 6 4 4

Loading/Dumping Overburden/Topsoil 2 2 3 2 2 3

Blasting 10 9 11 8 7 10

Bulldozing Coal 5 8 8 4 5 6

Bulldozing Rejects 13 14 14 12 13 13

Bulldozing Overburden/Topsoil 3 3 2 3 3 2

Wind Erosion of Exposed Areas 9 7 6 7 6 5

Wind Erosion of Coal Stockpiles 15 15 15 15 15 14

Material Transfer Rejects 17 18 19 17 18 18

Trucks unloading Coal (hopper) 6 10 9 5 8 7

Loading Coal Stockpiles 12 13 12 10 11 12

Graders 4 5 7 11 10 11

Drilling 14 12 13 14 14 15

Coal Crushing 8 6 4 13 12 9

Loading Coal to Trucks 11 11 9 9 9 7

Material Transfer of Coal 16 16 16 16 16 16

Train Loading 19 19 18 19 19 19

Other Crushing (waste rock) 18 17 17 18 17 17

(a) Mining activity categories ranked within the top four are highlighted.




Determination



of 98


Table 5. Ranking of Mine Activities based on Particulate Matter Emissions for Controlled Operations (2011-

2015)(a)

Mine Activity

Categories

2011 2012 2013 2014 2015

TSP

rankin

g

PM10

rankin

g

PM2.5

ranking

TSP

rankin

g

PM10

rankin

g

PM2.5

ranking

TSP

rankin

g

PM10

rankin

g

PM2.5

ranking

TSP

rankin

g

PM10

rankin

g

PM2.5

rankin

g

TSP

rankin

g

PM10

ranking

PM2.5

rankin

g

Wheel Generated Dust 1 1 1 1 1 1 1 1 1 1 1 2 1 1 2

Wind Erosion of Overburden 6 4 4 7 4 4 7 4 4 7 5 4 7 4 4

Loading/Dumping Overburden 2 2 3 2 2 3 2 2 3 2 2 3 2 2 3

Blasting 8 7 10 10 8 11 10 8 11 10 8 11 10 8 11

Bulldozing Coal 4 5 6 4 6 7 4 6 7 4 7 7 4 7 7

Bulldozing Rejects 12 13 13 3 5 5 3 5 5 3 4 6 3 5 6

Bulldozing Overburden/Topsoil 3 3 2 5 3 2 5 3 2 5 3 1 5 3 1

Wind Erosion of Exposed Areas 7 6 5 8 7 6 8 7 6 8 6 5 8 6 5

Wind Erosion of Coal Stockpiles 15 15 14 16 15 14 16 16 14 16 16 14 16 16 14

Material Transfer Rejects 17 18 18 14 16 15 14 15 15 14 15 15 14 15 15

Trucks unloading Coal (hopper) 5 8 7 6 9 8 6 9 8 6 9 8 6 9 8

Loading Coal Stockpiles 10 11 12 11 12 13 11 11 12 11 11 12 11 11 12

Graders 11 10 11 12 11 12 12 12 13 13 13 13 13 13 13

Drilling 14 14 15 15 14 16 15 14 16 15 14 16 15 14 16

Coal Crushing 13 12 9 13 13 10 13 13 10 12 12 10 12 12 10

Loading Coal to Trucks 9 9 7 9 10 8 9 10 8 9 10 8 9 10 8

Material Transfer of Coal 16 16 16 17 17 17 17 17 17 17 17 17 17 17 17

Train Loading 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19

Other Crushing (waste rock) 18 17 17 18 18 18 18 18 18 18 18 18 18 18 18

(a) Mining activity categories ranked within the top four are highlighted.






of 98


4. POTENTIAL ADDITIONAL PARTICULATE MATTER CONTROLS

4.1 Introduction

Best practice measures applicable for managing particulate matter emissions were reviewed

based on a detailed review of the literature and taking into account measures being

implemented by mining operations locally and internationally (ENVIRON, 2011). In

identifying measures implementable at coal mining operations, attention was paid to

technically and economically viable (or potentially viable) measures. This approach is

consistent with the EU’s definition of Best Available Techniques (BAT), the US definition of

Best Demonstrated Technologies (BDT), Western Australia’s definition of ‘Best Practicable

Measures’ (BPM) and the approach adopted by the Victorian government (EPA Victoria,

2007; WA DEC, 2003; EC, 2009; US Regulation 40 CFR Part 60).

Based on the inventoried best practice control measures, a gap analysis was undertaken of

LCO’s current control measures, and potential additional controls identified for

consideration. Emission reductions achievable through the implementation of such

measures were quantified, to the extent that control efficiencies are available for the

quantification of such reductions. Control efficiencies in the literature were found to be

most typically expressed in terms of TSP emission reductions achievable. For the purpose

of the current assessment such control efficiencies were taken to be applicable for

estimating emission reductions for PM10 and PM2.5.

The practicability of LCO implementing the additional measures inventoried, taking local

factors into account, is addressed in Section 5.

4.2 Potential Additional PM Controls for Top Four Activities

Best practice measures, current controls and potential additional control measures for each

of the top four activities identified for LCO are documented in Table 6, Table 7, Table 8 and

Table 9. Overall control efficiencies achievable are documented in these tables, drawing on

measure-specific control efficiencies documented in Appendix C.

Whereas current controls implemented by LCO are summarised in the aforementioned

tables for ease of comparison with best practice measures, reference should also be made

to the more detailed discussion of current site-wide and source-specific management

measures provided within Section 2.3 and Section 3.3 respectively.

In undertaking the identification of best practice measures, LCO drew on information

collated during the XCN Air Quality Improvement Project (AQIP) (ENVIRON, 2011).

Reference was also made to the findings of Katestone (June 2011) NSW Coal Mining

Benchmarking Study – International Best Practice Measures to Prevent and/or Minimise

Emissions of Particulate Matter from Coal Mining.

The OEH-commissioned Katestone (2011) study concluded best practice control measures

for unpaved haul roads to be the application of chemical suppression. Additionally, visual

monitoring of dust above the deck, wheels or tray of the haul trucks was noted to be used

as a trigger for the application of additional watering. Haul truck drivers were noted to play

an important role in dust management. The measures concluded by Katestone (2011) to be

best practice for unpaved haul roads are largely already being implemented at LCO.

Several additional measures were however identified aimed at enhancing the

implementation of contingency measures at the site (Table 6).

http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?sid=f07430ab163e3fffac41a40e70b19774&c=ecfr&tpl=/ecfrbrowse/Title40/40cfrv6_02.tpl






of 98


Bulldozing emissions are a function of the hours of operation, and the silt and moisture

content of the material being handled. Prevailing winds and dust generation by dozer

cooling fans and exhaust systems, when airflow vents are angled towards the material being

handled or traverse over, also influence the extent of emissions. Significant reductions to

the operational hours of dozers at existing mining operations would necessitate a

substantial redesign of mining operations, and hence was not considered practicable for

operating mines. It is noted that the Katestone (2011) study reached a similar conclusion.

Most of the measures identified for dozer operations comprise contingency measures

implementable during adverse meteorological conditions and/or periods of high particulate

matter concentrations and/or elevated visible dust levels (Table 7). Opportunities for

enhancing the implementation of such contingency measures were identified for LCO.

Control efficiencies achievable are however not quantifiable (Refer to Appendix C).

Control measures applicable for overburden loading and dumping are addressed in Table 8.

Katestone (2011) specifies best practice measures for minimising emissions from

overburden handling to be:

Use of water sprays or water carts with boom sprays;

Cease of modify activities on dry windy days; and

Minimise dump height.

Whereas the latter two measures are included as best practice measures in Table 8, the first

measure is excluded on the grounds that the technical viability of this measure has not yet

been demonstrated locally, inter-state or overseas.

The watering of overburden extraction areas prior to overburden extraction and loading is

implemented on a limited scale by LCO, specifically targeting overburden areas overlying

spontaneous combustion. Water sprays are however not routinely used to control dust from

overburden loading and dumping operations due to practical constraints on the positioning

of such sprays relative to operations. For overburden dumping operations, ambient wind

effects on the water sprayed, present an additional obstacle. Further development of this

technology may render wet suppression feasible for future applications. Based on the

approach adopted for identifying best practice measures, the application of wet suppression

is not identified as a best practice measure.

Control measures addressing wind erosion of overburden emplacement areas are addressed

in Table 9. Other practices to reduce wind entrainment include wind sheltering measures

and rock cladding. These measures are however considered significantly less practicable

given the size of overburden emplacement areas, the manner in which they are constructed,

and the aim of maximising rehabilitation. Interim stabilisation, pending rehabilitation, and

avoidance of disturbance represent more suitable measures. Best practice measures are

identified by Katestone (2011) as follows:






of 98


Maximise rehabilitation works.

If exposed area is a potential source of particulate matter emissions and is likely to be

exposed for more than 3-months, revegetation should take place.

Strategic use of watering, suppressants and hydraulic mulch seeding depending on

circumstances.

The maximum timeframe for overburden emplacement areas remaining exposed prior to

interim stabilisation being applied is dependent on the time of the year the area becomes

available for interim stabilisation and the method selected for such stabilisation. By

example, a period of 1 to 3 months is likely to be viable for chemical suppression, whereas

a period of 3 to 6 months may be more practicable for establishment of vegetation for

seeding to take place in an appropriate season.

The control effectiveness of interim stabilisation support measures will depend on the extent

of the exposed overburden emplacement areas which are likely to remain inactive for a

sufficiently long period (e.g. 6 months), to warrant stabilisation. This extent is currently not

known. For the purpose of estimating potential emission reductions, it is assumed that 10%

of LCO’s unrehabilitated overburden emplacement areas (236 ha) may be subject to interim

stabilisation, with a control efficiency of 80% assumed for the implementation of this

measure for these areas.

In conclusion, LCO is noted to be applying best practice measures in many instances.

Based on a gap analysis of current controls given best practice controls, several additional

measures were identified for potential implementation as documented in Table 6, Table 7,

Table 8 and Table 9, and summarised in Table 10.

Control efficiencies in the literature were found to be most typically expressed in terms of

TSP emission reductions achievable. For the purpose of the current assessment such

control efficiencies were taken to be applicable for estimating emission reductions for PM10

and PM2.5.






of 98


Table 6. Wheel Generated Dust from Unsealed Roads - Comparison of Current and Best Practice Controls for

LCO’s Top Four Sources, and Identification of Additional Measures

Category Current Controls Best Practice Controls Additional Measures

Source

reduction

LCO routinely reduce haul distances through mine

planning to reduce haulage cost.

Use of trucks with larger payload capacities to reduce vehicle kilometres travelled. Larger trucks were purchased during 2010 (ultra class trucks with ~300 tonne capacity).

Obsolete roads are ripped and revegetated.

Coarse reject is backhauled.

Car parks and main access roads are tar sealed.

Ripping and revegetation of obsolete roads.

Prioritise source reduction measures by:

- Taking the most direct route, as practical - Undertaking back-hauling, where practical - Using conveyors in place of haul roads, where

practical - Using larger trucks to minimize trip numbers

Sealing roads with high traffic volumes

Sealing or chemically stabilising hardstand areas with frequent mobile equipment activity.

None

Haul Road Design

Permanent roads are constructed from hard non-friable material and have defined marker posts to prevent vehicle deviations.

Gravel surfacing is applied across all of the major haul

roads on site during construction, with resurfacing as necessary.

Drainage controls are constructed at roadsides and on hardstand areas.

Optimise surface drainage, particularly at intersections

Optimise base materials to reduce silt content and increase the retention of larger aggregates,

particularly at intersections

None

Haul Road

Maintenance

and Management

Maximum haul road speeds of 60 km/hr. Truck

operators currently reduce speed as a contingency action in the event of excessive dust.

Gravel surfacing is applied across all of the major haul roads on site during construction, with resurfacing as necessary.

Haul Road Management System (HRMS), managed by a contractor (Reynolds Soil Technologies), which includes

the application of a chemical surfactant to 32 km of

Restrict vehicle speeds on all roads(a).

Scheduled grading and gravelling of heavy traffic areas such as intersections.

Watering, application of chemical suppressants or paving of light traffic areas, such as the CHPP, underground mine portals and workshop and administrative areas.

Regular resurfacing of high traffic areas such as

intersections to reduce silt build up.

1. Truck operators currently

reduce speed as a contingency action given

adverse conditions or excessive dust. This measure may be enhanced through linking contingency actions to

specific visual triggers.

2. Periodic objective






of 98



unsealed haul roads (RST’s RT9 water extender). The HRMS comprises:

Three Caterpillar 777F water carts implemented (four water carts to be used during hotter months)

Application of RT9 to water carts using an automated dosing system. Dosage rate varied by month depending on conditions (e.g. ranged between 1:640 to 1:1,050 during Aug to Oct 2011 period).

Key Performance Indicators (KPIs) applied: water cart hours, water usage, water applied/m², distance covered by the water cart, time taken to empty the water cart.

Other variables tracked: time between applications, product application, rainfall, evaporation and

temperature, visible dust.

Grading activities

Monthly progress reports submitted by RST to LCO

tracking performance against KPIs.

Training of personnel, including water cart operators and grading personnel

Grading is carefully managed not to impact the effectiveness of the chemical suppression measure.

Chemical suppression using Petrotac on the unsealed road leading to the workshop. Applied by an external contractor (shown to achieve higher water cart availabilities).

Weekly sweeping of paved areas by an external contractor to reduce road silt loadings.

Regular maintenance and inspection of road drainage

Regular maintenance of drainage design features at intersections.

Diligent monitoring and application of controls as surface dries out to avoid excessive emissions. Real-time triggers used to identify problem areas

for targeted application of controls.

Regular watering of haul roads and at the direction

of haul truck operators or the Open Cut Examiner (OCE).

Avoid overwatering of haul roads.

Regular grading and maintenance of intersections.

Application of preventative measures to prevent material deposition on haul roads, such as:

Avoid overloading which could result in

spillage.

Provide for storm water drainage to prevent water erosion onto stabilised unsealed roads.

Prevent wind erosion from adjacent open areas.

Implementation of a haul road management

system, comprising:

Availability of suitable equipment (e.g. water carts equipped with efficient spray systems; chemical agents);

Application strategies (application frequencies and intensities; surfactant doses);

Water cart filling stations adequate in number

and spacing to implement the strategy effectively;

Personnel trained and experienced in water cart operation;

Meteorological monitoring, as an input into the application strategy;

monitoring to demonstrate control efficiency (e.g. in situ road surface entrainment testing / mobile

monitoring).

3. Extend the functionality of

LCO’s real-time PM10 and meteorological monitoring system to integrate triggers and alarms (i.e.

reactive/predictive air quality control system establishment)

4. Specify adverse

conditions (in terms of

meteorological conditions and/or PM10 concentrations) when haul activities will be modified to reduce the potential for dust impacts, as informed

by LCO’s reactive/predictive air quality control system.

5. Target an overall

minimum haul road dust control efficiency of 80%.






of 98



controls is undertaken to ensure controls are performing adequately.

Application of preventative measures to reduce the potential for material deposition on roads, including:

Implementation of a payload management system

to avoid overloading which could result in spillage.

Provide for storm water drainage to prevent water erosion onto stabilised unsealed roads.

Prevent wind erosion from adjacent open areas through the use of shaped windrows with disturbance of such windrows avoided to support crusting.

Road dust monitoring (routine visual inspection; periodic objective measurement to assess control effectiveness); and

Periodic review of the System.

Overall Control

Efficiency

75% to >90% but 75% claimed (b) 70% - >90% (c)(Refer to Appendix C)

Target an overall, in situ

control efficiency of

80%(d)

Notes:

Katestone (2011) references a speed limit of 40 km/hr, although this restriction is not carried through to the conclusions as a best practice measure. The control efficiency, cost of implementation and practicability of introducing a speed restriction of 40 km/hr across an operation is not addressed by Katestone (2011). The maximum possible speed of loaded haul trucks is in the range of 50 km/hr to 60 km/hr, with significantly lower speeds achieved on ramps, near intersections and in proximity to other equipment. Best practice is considered to be the practice of operators driving to conditions, including reducing speed to address visual dust and as a contingency measured triggered by reactive/predictive AQCS alerts.

Lower bound estimate of 75% applied (equivalent to a control efficiency for Level 2 watering) pending quantification of site-specific control efficiency via

objective measurement.

Based on the control efficiencies in the literature, a combination of gravel surfacing, chemical suppression and speed reduction could result in a control efficiency of over 90% (Refer to Appendix C). In practice, the control efficiency achievable depends on the combination of measures applied and site conditions.

The control efficiency achievable through the application of chemical suppression ranges significantly (20% to 99+%) across studies, sites, applications,

products applied and particle size ranges (Refer to Appendix C). Several of the more reputable studies give the control efficiency as being in the range of






of 98


70% to 90% with a control efficiency of approximately 80% referenced by a number of studies including within the US-EPA AP42 Chapter 13.2.2 Unpaved

Roads (November 2006)..






of 98


Table 7. Bulldozing Overburden - Comparison of Current and Best Practice Controls for LCO’s Top Four Sources,

and Identification of Additional Measures

Current Controls Best Practice Controls Additional Measures

Work procedures require dozers to travel

on designated roads.

Dozer with airblasts orientated upward (away from the material being handled) are used.

Dozer operations are modified or ceased if excessive dust is observed.

Minimising the travel speed and distance travelled by

bulldozers (control efficiency not quantified).

Avoid dozer operations at wind exposed areas during dry, windy conditions.

Designate and maintain dozer routes between work areas (e.g. wet suppression of dozer travel routes).

Visual monitoring of dust levels from dozer operations by

trained personnel, with operations modified or ceased when elevated dust levels are observed to occur.

6. Specify visual triggers for dozer operations.

7. Specify adverse conditions (in terms of

meteorological conditions and/or PM10 concentrations) when dozer operations will be modified to reduce the potential for dust impacts, as informed by LCO’s

reactive/predictive air quality control system.

Control Efficiency: Not quantifiable Control Efficiency: Not quantifiable Control Efficiency: Not quantifiable






of 98


Table 8. Loading/Dumping Overburden - Comparison of Current and Best Practice Controls for LCO’s Top Four

Sources, and Identification of Additional Measures


Provision of in-pit dumping locations for periods

of high wind, where practicable.

Modify (e.g. sheltered dumping) or cease excavation and tipping activities if excessive dust is observed.

Minimising double handling of material.

Minimise the distance of fall of overburden materials during loading and tipping as far as

practical.

Log hours during which operations ceased due to dust avoidance through the LCO’s fleet

management system.

Modification of excavation and tipping activities for hot, dry spontaneous combustion affected material.

Cease or modify activities on dry windy days, e.g. sheltered

dumping during periods of high winds.

Minimise the distance of fall of overburden materials during loading and tipping as far as practical.

Minimise double handling of material.

Identify material types that contain fine and/or friable material, and implement a risk based approach for effective dust mitigation.

8. Specify adverse conditions (in

terms of meteorological conditions and/or PM10 concentrations) when loading and dumping operations will be modified to reduce the

potential for dust impacts, as informed by LCO’s reactive/predictive air quality control system.

9. Formalise a procedure for

identifying material with high dust potential for risk-based additional

management (e.g. sheltered dumping; emplacement at less wind-exposed areas; wet suppression).

Control Efficiency: Not quantifiable. 0% assumed.

Not quantifiable or site-specific (Refer to Appendix C) Loading: Not quantifiable Dumping: 5-30%(a)

(a) Based on wind speed measured at Liddell in 2010 and the site-specific emission factor, it was estimated using the

documented emission factor that emissions from overburden dumping could be reduced in the range of 5% to 30% by

undertaking sheltered dumping when hourly average wind speeds exceeded a threshold in the range of 6 m/s to 10

m/s. Determining appropriate site-specific threshold wind speeds to be incorporated within a potential

reactive/predictive air quality control system for the site is a component of the development of such a system, hence

the need for the use of an indicative threshold wind speed range for the projection of potential emission reductions.






of 98


Table 9. Wind Erosion of Overburden Emplacement Areas - Comparison of Current and Best Practice Controls for

LCO’s Top Four Sources, and Identification of Additional Measures


Overburden emplacement within previously mined voids.

Minimising areas disturbed by mining activities and prompt rehabilitation of disturbed areas following completion of mining (Progressive rehabilitation, including the use of ameliorants to improve soil).

Detailed design of overburden dump shapes to minimise profile exposure to off-site receptors and to reduce surface wind speeds and turbulence. LCO OEAs are orientated such that unrehabilitated

dumps are generally protected from the strong northwesterly winds. Older rehabilitated dumps are generally northwest facing which mitigates the impact of wind erosion during these northwesterly winds. Overburden emplacements are shaped to 10 degrees or less

and seeded.)

Temporary rehabilitation of cleared, unmined areas to assist in dust control. Temporary seeding rehabilitation works carried out near

the ROM pad to assist in dust control and visual enhancement along Pikes Gully Road (Q4 2009, Q1 2010). Resulted in good ground coverage.

Maximise in-pit emplacement (sheltering from the

prevailing wind).

Maximise rehabilitation works. (Rehabilitation comprises use of vegetation and land-contouring to produce the final post mining land-form.)

Integration of air quality considerations into design of overburden dump shapes.

Application of interim stabilisation (vegetation;

chemical suppression) for overburden emplacement areas which are to be in place for extended periods prior to final landform and rehabilitation.

Restricting vehicle access to formed roads.

Locate materials with greater dust generation potentials

in less wind exposed areas.

10. Establish and implement a procedure for regular

identification of areas for risk-based management.

Control Efficiencies: 100% for fully rehabilitated; 60% for recently rehabilitated.

Control Efficiencies: 100% for fully rehabilitated; 60% for recently rehabilitated; and 80-90% for

temporary rehabilitation (vegetation; chemical suppression) (Refer to Appendix C).

Additional Control Efficiency: 8%(a)

(a) For the purpose of estimating a potential emission reduction potential, it was assumed that 10% of LCO’s current

unrehabilitated overburden emplacement areas (236 ha) could be made available for interim stabilisation (e.g.

vegetation, chemical suppression), and that such stabilisation would results in an 80% control efficiency. The resultant

overall reduction in total emissions from wind erosion of overburden emplacement is estimated to be 8%.






of 98


Table 10. Summary of Additional Measures Identified for LCO and Increase in

Control Efficiency Achievable

Source Additional Measures Increase in Control

Efficiency

Wheel Generated

Dust (Unsealed

Roads)

1. Truck operators currently reduce speed as a

contingency action given adverse conditions or

excessive dust. This measure will be enhanced

through linking contingency actions to specific visual triggers.

2. Periodic objective monitoring to demonstrate control

efficiency (e.g. in situ road surface entrainment

testing / mobile monitoring).

3. Extend the functionality of LCO’s real-time PM10 and

meteorological monitoring system to integrate

triggers and alarms (i.e. reactive/predictive air quality

control system establishment)

4. Specify adverse conditions (in terms of meteorological

conditions and/or PM10 concentrations) when haul

activities will be modified to reduce the potential for

dust impacts, as informed by LCO’s

reactive/predictive air quality control system.

5. Target an overall haul road dust control efficiency of

80%.

Increase in overall

control efficiency from

75% to 80%(a).

Bulldozing

Overburden 6. Specify visual triggers for dozer operations.

7. Specify adverse conditions (in terms of meteorological conditions and/or PM10 concentrations) when dozer operations will be modified to reduce the potential for

dust impacts, as informed by LCO’s reactive/predictive air quality control system.

Not quantifiable

Loading/Dumping

Overburden 8. Specify adverse conditions (in terms of meteorological

conditions and/or PM10 concentrations) when loading and dumping operations will be modified to reduce the potential for dust impacts, as informed by LCO’s reactive/predictive air quality control system.

9. Formalise a procedure for identifying material with high dust potential for risk-based additional management (e.g. sheltered dumping; emplacement at less wind-exposed areas; wet suppression).

Overburden Dumping:

Control efficiency in the range of 5% to

30%

Overburden Loading: Not quantifiable

Wind Erosion of Overburden Emplacement Areas


Additional control efficiency of 8%.

(a) It is feasible that the actual control efficiency achieved at LCO is equivalent to or greater than 80% due to the site’s haul road management system which includes chemical suppression (implemented since Q4 2010). This will however only be established following the implementation of objective monitoring during 2012.






of 98


4.3 Emission Reductions Achievable due to Additional Controls

Annual emissions estimated for LCO (base year 2011), given current controls and the

implementation of additional control measures identified, are summarised in Table 11.

Annual emission reductions estimated due to the implementation of the additional control

measures identified are presented in the table.

TSP emission reductions were estimated to be in the range of approximately 1,300 to 1,355

tonnes/year, PM10 emission reductions in the range of 400 to 430 tonnes/year, and PM2.5

emission reductions of the order of 40 to 45 tonnes/year.

Table 11. Annual emission reductions due to implementation of additional

measures at LCO


Annual Emissions with Current Controls

(tonnes/year)

TSP PM10 PM2.5

1 Wheel Generated Dust 6,347 1,945 195

2 Loading and Dumping of Overburden 853 465 56

3 Bulldozing of Overburden 536 256 90


Total 7,968 2,782 358


Annual Emissions including Additional Controls (tonnes/year)

TSP PM10 PM2.5

1 Wheel Generated Dust 5,078 1,556 156

2 Loading and Dumping of Overburden 787 – 842(a) 433 – 460(a) 51 – 55(a)

3 Bulldozing of Overburden 536 256 90


Total 6,615 - 6,670 2,352 - 2,379 313 – 317


Annual Emissions Reductions due to Additional Controls (tonnes/year)

TSP PM10 PM2.5

1 Wheel Generated Dust 1,269(b) 389(b) 39(b)

2 Loading and Dumping of Overburden 11 – 66(a) 5 - 32(a) 1 - 5(a)

3 Bulldozing of Overburden NQ NQ NQ


Total 1,299 – 1,354 403 - 430 41 - 45

NQ – not quantifiable.

(a) Control efficiency estimated to be in the range of 5% to 30%, achievable by avoiding

overburden dumping at wind-exposed areas when hourly average wind speeds exceeded

a threshold in the range of 6 m/s to 10 m/s.

(b) The dust control efficiency of the haul road management system (incorporating chemical

suppression) has been empirically calculated to be above 90% by external contractor

Reynolds Soil Technologies (RST, 2011) (refer to Section 3.31). LCO however currently

applies a control efficiency of 75% to provide a conservative (lower bound) estimate for

emission reporting purposes. It is feasible that the actual control efficiency achieved at

LCO is equivalent to or greater than 80%, and therefore that this emission reduction has

already been achieved during 2011. This will however only be established following the

implementation of objective monitoring during 2012.






of 98


5. PRACTICABILITY OF BEST PRACTICE MEASURES

The practicability associated with the implementation of the additional control measures

identified at LCO was evaluated taking into consideration:

implementation costs;

regulatory requirements;

environmental impacts;

safety implications; and

compatibility with current processes and proposed future developments.

All additional control measures identified were concluded to be practicable taking into

account anticipated costs, application of such measures at other mines, compatibility with

current and future operational practices, and regulatory requirements pertaining to the site.

All additional control measures identified, as summarised in Table 10, will therefore be

implemented at LCO to reduce particulate matter emissions as per the implementation

timeline provided in the subsequent section.

6. IMPLEMENTATION TIMEFRAME

The planned timeline for implementing the additional control measures identified is outlined

in Table 12. In cases where tasks are required for establishment of the measure prior to its

implementation, separate provision is made for the development and implementation of the

measure.






of 98


Table 12. Implementation Timeline for Additional Control Measures at LCO

Mine Activity Tasks for Additional Measure Implementation Timeline

Wheel Generated

Dust (Unsealed

Roads)

1. Truck operators currently reduce speed as a

contingency action given adverse conditions or excessive dust. This measure will be enhanced through linking contingency actions to specific visual triggers.

(a) Specification of visual triggers.

February – June 2012

(b) On-going implementation of visual triggers.

July 2012 onwards

2. (a) Establish an objective monitoring method to

demonstrate the control efficiency being

achieved (e.g. in situ road surface

entrainment testing, mobile monitoring,

road-side monitoring).

February – September 2012

(b) Initiate periodic objective monitoring as

part of the site’s Haul Road Management System to track control efficiency.

October 2012 onwards

3. Extend the functionality of LCO’s real-time PM10

and meteorological monitoring system to integrate triggers and alarms (i.e. reactive/predictive air quality control system establishment).


4. Specify adverse conditions (in terms of meteorological conditions and/or PM10 concentrations) when haul activities will be modified to reduce the potential for dust impacts, as informed by LCO’s reactive/predictive air quality control system.

July – September 2012 (development)

October 2012 onwards (implementation)

5. Review current and additional control measures against the 80% control efficiency target.

December 2012

Bulldozing Overburden

6. Specify and implement visual triggers for dozer operations.


(development)

July 2012 onwards (implementation)

7. Specify adverse conditions (in terms of meteorological conditions and/or PM10

concentrations) when dozer operations will be modified to reduce the potential for dust

impacts, as informed by LCO’s reactive/predictive air quality control system.


October 2012 onwards

(implementation)






of 98


Mine Activity Tasks for Additional Measure Implementation Timeline

Loading/Dumping Overburden

8. Specify adverse conditions (in terms of meteorological conditions and/or PM10 concentrations) when loading and dumping operations will be modified to reduce the potential for dust impacts, as informed by LCO’s reactive/predictive air quality control system.


October 2012 onwards (implementation)

9. Formalise a procedure for identifying material

with high dust potential for risk-based

additional management (e.g. sheltered dumping; emplacement at less wind-exposed areas; wet suppression).


(additional training)

July 2012 (implementation)

Wind Erosion of

Overburden Emplacement Areas


February – September 2012 (additional training)

October 2012 (implementation)






of 98


7. APPENDICES

7.1 Appendix A: Presentation of Information on Cost of

Implementation

According to the OEH Guideline, licensees are required to provide estimated capital, labour,

materials and other costs for each best practice measure on an annual basis for a ten year

period. The cost information is required to allow the NSW Environmental Protection

Authority (EPA) to verify that a particular best practice measure is not practicable at a

particular site.

The EPA considers however that any licensee may choose not to submit cost information for

best practice measures that are either currently being implemented, or that are considered

by the licensee to be practicable (personal communication, Mitchell Bennett, Head, Regional

Operational Unit – Hunter, NSW EPA, 27 January 2012). A copy of this correspondence is

provided overleaf.

Given that LCO is either already implemented best management practice measures, or has

agreed to implement identified additional control measures, no cost information is provided.






of 98







of 98


7.2 Appendix B: Emission Estimation

The emission estimation method for the study was developed by ENVIRON Australia (Pty)

Ltd, in consultation with the Office of Environment and Heritage (OEH). Correspondence

regarding the emission factors selected for application is provided at the end of this

appendix. Enhancements and additions to the emission factors referenced in the

correspondence are documented in the relevant sections of this appendix.

Annual TSP, PM10 and PM2.5 emissions (tpa) were estimated for each mining activity utilising

USEPA AP42 emission estimation techniques, and taking into account site-specific material

properties, meteorology, mine activities and activity rates and current control measures.

The emission estimation method comprised the following main steps:

Selection of suitable emission factor equations, in consultation with OEH (Section 7.21).

Collation of the site-specific material property and meteorological data required as input

to equations (Section 7.22).

Calculation of site-specific emission factors for partially uncontrolled activities –

excluding pit retention factors and control efficiencies due to current measures (Section

7.23).

Designation of pit retention factors for sources taking place within the open cut pit

(Section 7.24).

Identification of controls measures and assignment of control efficiencies (Section 7.25).

Collation of site-specific mine activity data for the base case year 2011 (Section 7.26).

Quantification of partially uncontrolled emissions for the base case year 2011, taking

into account pit retention and natural attenuation due to rainfall (Section 7.27).

Quantification of emissions given current controls for the base case year 2011 (Section

7.27).

Whereas detailed emission estimates are provided within this appendix, a summary of the

emission projections by OEH-defined activity category is given within the main report.

7.21 Emission Factors Applied

7.211 Unpaved Roads

The emissions factor for unpaved roads is taken from USEPA AP42 Chapter 13.2.2 Unpaved

Roads (November 2006) as follows:

E = k (s/12) a (W/3) b

Where,

E = Emissions Factor (lb/VMT, i.e. pounds per vehicle miles travelled)

s = surface material silt content (%)

W = mean vehicle weight (Short Tonnes US)






of 98


The following constants are applicable:

Constant

TSP

(assumed from

PM30)

PM10 PM2.5

K (lb/VMT) 4.9 1.5 0.15

A 0.7 0.9 0.9

B 0.45 0.45 0.45

The metric conversion from lb/VMT to g/VKT (grams per vehicle kilometre travelled) is as

follows:

1 lb/VMT = 0.2819 kg/VKT

The surface material silt content and mean vehicle weight information is site specific as

documented in the following section.

Rainfall Adjustment Factor

All roads are subject to some mitigation due to precipitation. The above unpaved road

emission factor can be extrapolated to annual average uncontrolled conditions (but

including natural mitigation due to precipitation) under the simplifying assumption that

annual average emissions are inversely proportional to the number of days with

measureable (more than 0.254 mm) precipitation as follows:

Eext = E [(365-P)/365]

Where:

Eext = annual size-specific emission factor extrapolated for natural mitigation (lb/VMT)

E = unpaved road emission factor (given above)

P = number of days in a year with at least 0.254 mm of precipitation

7.212 Paved Roads

The emissions factor for paved roads is taken from USEPA AP42 Chapter 13.2.1 Paved

Roads (January 2011) as follows:

E = k (sL) 0.91(W) 1.02

Where,

E = Emissions Factor (g/VKT, i.e. grams per vehicle kilometre travelled)

K = particle size multiplier for particle size range and units of interest (See table

below)

sL = Road surface silt loading (grams per square meter) (g/m2), and

W = mean vehicle weight (tonnes)






of 98


The following constants are applicable:

Constant

TSP

(assumed from

PM30)

PM10 PM2.5

K 3.23 0.62 0.15

Questions have been raised in regard to the accuracy of the January 2011 revision of the

Paved Road equation. OEH has however indicated that emission factors from AP42 Section

13.2.1 January 2011 should be used in the quantification of paved road emissions since this

is official USEPA guidance (personal communication, Mitchell Bennett, Office of Environment

and Heritage, 10 October 2011).

The road surface silt loading and mean vehicle weight information is site specific as

documented in the following section.

7.213 Topsoil Scraper

The emissions factors for topsoil scraping activities are taken from USEPA AP42 Chapter

11.9 Western Surface Coal Mining (October 1998) as documented in the table below. No

PM10 and PM2.5 factors defined for this activity, with reference made to the PM10/TSP and

PM2.5/TSP ratios specified for this activity within the OEH 2008 GMR Emissions Inventory.

The emission factors are expressed in kilograms of emissions per tonne of material (topsoil)

stripped.

TSP TSP PM10 PM2.5 Units

Topsoil stripping 0.029 TSP*0.32 TSP x 0.0468 kg/tonne

Scraper unloading

(batch drop)

0.02 TSP*0.32 TSP x 0.0468 kg/tonne

7.214 Dragline

Note: Although LCO does not have dragline operations, the emission factor for dragline

operations is provided, given that this factor is referenced in the estimations of control

efficiency for overburden loading achievable through drop height reduction.

The emissions factors for dragline activities are taken from USEPA AP42 Chapter 11.9

Western Surface Coal Mining (October 1998) as documented in the table below. The

emission factors are expressed in kilograms of emissions per bulk cubic metre of material

(overburden) moved.

TSP PM10 PM2.5 Units

kg/m3






of 98


Where,

d = drop height (m)

M = material moisture content (%)

The average drop height and material moisture content will be site specific.

7.215 Blasting

Emissions factors for blasting are taken from USEPA AP42 Chapter 11.9 Western Surface

Coal Mining (October 1998) as documented in the table below. The emission factors are

expressed in kilogram of emissions per blast, with a single emissions factor specified for

blasting of coal and overburden.

Material TSP PM10 PM2.5 Units

Coal or

Overburden 0.00022(A)1.5 TSP x 0.52 TSP x 0.03 Kg/blast

7.216 Drilling

The TSP emissions factors for drilling activities are taken from USEPA AP42 Chapter 11.9


emission factors are expressed in kilogram of emissions per hole drilled, with separate

factors specified for drilling of coal and overburden. Given that there are no PM10 and PM2.5

emissions factors for drilling, the PM10 and PM2.5 to TSP ratios for blasting overburden and

coal were applied.


Overburden 0.59 TSP x 0.52 TSP x 0.03 kg/hole

Coal 0.1 TSP x 0.52 TSP x 0.03 kg/hole

The number of holes will be site specific.

7.217 Bulldozing

The emissions factors for bulldozing activities are taken from USEPA AP42 Chapter 11.9


emission factors are expressed in kilogram of emissions per hour of dozer activity, with

separate factors specified for dozers operating on coal and overburden.


Coal

kg/hr

Overburden

kg/hr






of 98


Where,

s = material silt content (%)


The material silt content and material moisture content are site specific and are addressed

in the subsequent section.

7.218 Trucks Loading Coal and Overburden

The emissions factors for truck loading are taken from USEPA AP42 Chapter 11.9 Western

Surface Coal Mining (October 1998) as documented in the table below. These emission

factors, expressed in kilogram of emissions per metric tonne of material loaded, are

applicable for operations involving loading by shovels, excavator or front end loaders. In

the case of truck loading of overburden, this chapter only specifies a TSP emission factor.

To derive PM10 and PM2.5 emissions factors for truck loading of overburden, reference was

made to the PM10/TSP and PM2.5/TSP ratios for bulldozing of overburden.


Coal

TSP x 0.019 kg/Mg

Overburden (a)

TSP x 0.105 kg/Mg

(a) See justification for use of this emission factor provided below

Where,


The material moisture content is site specific and are provided in the subsequent section.

OEH recommended that the material handling emission factor equation from USEPA AP42

Chapter 13.2.4 Aggregate Handling and Storage Piles (November 2006) be applied in the

estimation of truck loading of overburden (as documented below) (personal communication,

Mitchell Bennett, Office of Environment and Heritage, 10 October 2011). Although this

emission factor equation, which takes into account the site-specific wind speed, was initially

applied it was found to substantially under predict the emissions from this activity for the

site when site-specific wind data was applied. This confirmed the conclusion reached by

Pitts (2005) that there is an apparent large underestimation in emissions when using the

materials handling equation compared to measurements at Australian mines.

The AP42 materials handling equation gives lower dust emissions when compared to

measurements undertaken during Australian research (NERDCC, 1988 and SPCC, 1983),

and earlier US research (1981). Holmes (1998) indicated that this is likely to be due to

earlier equations treating the entire loading operation as a single operation. The entire

operation comprises the use of a shovel/excavator or front end loader scooping up a load,

moving into a loading position, dumping material into a truck, reloading and repeating the

process. The materials handling equation by comparison considers the batch or continuous

load-out operation in isolation, and is therefore more applicable for estimating emissions for

conveyor transfers or loading from a conveyor to a stockpile.

To provide a more realistic (potentially upper bound) estimate of emissions from trucks

loading overburden reference was therefore made to the default emission factor from






of 98


USEPA AP42 Chapter 11.9 Western Surface Coal Mining (October 1998) as documented in

the table above.

7.219 Trucks Dumping Coal and Overburden

The emissions factors for trucks dumping of coal are taken from USEPA AP42 Chapter 11.9


emission factors are expressed in kilogram of emissions per metric tonne of material

dumped.

In the case of trucks dumping of overburden, this chapter specifies a TSP emission factor.

To derive PM10 and PM2.5 emissions factors for truck loading of overburden, reference was

made to the PM10 and PM2.5 to TSP ratios for bulldozing of overburden.


Coal

TSP x 0.019 kg/Mg

Overburden (a) Refer to the Materials Handling Equation (b)

(a) AP42 Chapter 11.9 gives a default TSP emission factor for truck dumping of coal (0.033

kg/Mg). OEH however recommended that the emission factors for trucks loading coal be

applied, as drawn from this chapter of the AP42 and documented above (personal

communication, Mitchell Bennett, Office of Environment and Heritage, 10 October 2011).

(b) AP42 Chapter 11. Gives a default TSP emission factor for truck dumping of overburden

(0.001 kg/Mg). OEH however recommended that the materials handling equation from

USEPA AP42 Chapter 13.2.4 Aggregate Handling and Storage Piles (November 2006) be

applied in the estimation of trucks dumping overburden (personal communication, Mitchell

Bennett, Office of Environment and Heritage, 10 October 2011).

The material moisture content (%) specified in the above equation is site specific and is

provided in the subsequent section.

7.2110 Grading

Emissions factors for grading are taken from USEPA AP42 Chapter 11.9 Western Surface

Coal Mining (October 1998) as documented in the table below. The emission factors are

expressed in kilogram of emissions per vehicle kilometre travelled (VKT).


0.0034 (S)2.5 0.0056 (S)2.0 x 0.6 TSP x 0.031 kg/VKT

Where,

VKT= Vehicles Kilometres Travelled

S = mean vehicle speed (km/h)

The mean vehicle speed of the grader when operating is site specific and is documented in

the subsequent section.






of 98


7.2111 Material Handling

Reference was made to the materials handling equation from USEPA AP42 Chapter 13.2.4

“Aggregate Handling and Storage Piles (November 2006) for the quantification of emissions

from the following batch and continuous drop operations:

Trucks dumping overburden;

Conveyor transfer points;

Stacking to stockpiles

The equation is expressed as follows:

Where,

E = Emissions factor (kg/Mg)

k = 0.74 for particles less than 30 µm

k = 0.35 for particles less than 10 µm

k = 0.053 for particles less than 2.5 µm

U = mean wind speed (m/s)

M = material moisture content (%).

The mean wind speed and material moisture content are site specific and are documented in

the subsequent section.

7.2112 Crushing and Screening

No specific emission factors are given for coal crushing and screening operations within

AP42 or within other widely referenced emission estimation methodologies. A conservative

approach (i.e. expected to provide an upper bound emission estimate) is adopted in which

reference is made to emissions factors for crushing and screening contained within USEPA

AP42 Chapter 11.24 Metallic Minerals Processing (January 1995). The emissions factors

from this chapter are documented for high moisture content and low moisture content ores,

with high moisture content defined as being greater than or equal to 4% by weight.

According to USEPA AP42 Chapter 11.24, a single crushing operation is likely to include a

hopper or ore dump, screen(s), crusher, surge bin, apron feeder, and conveyor belt transfer

points, with emissions from these various pieces of equipment frequently being ducted to a

single control device. The emission factors provided for in USEPA AP42 Chapter 11.24 for

primary, secondary, and tertiary crushing operations are for process units that are typical

arrangements of the aforementioned equipment. For this reason the emission factors for

crushing were taken to be applicable for the quantification of coal crushing and screening

operations.

No PM2.5 factors are given within USEPA AP42 Chapter 11.24, reference was therefore made

to the PM2.5 fraction specified for Category 3 emissions within USEPA AP42 Appendix B.2

Generalized Particle Size Distribution (January 1995). Category 3 covers materials handling

and processing of aggregate and unprocessed ore, including emissions from milling,

grinding, crushing, screening, conveying, cooling, and drying of material.






of 98


A summary of the emission factors applied for coal crushing and screening operations is

given in the table below, expressed as kilograms of emissions per metric tonne of coal.

Material Process TSP PM10 PM2.5 Units

High moisture coal

(≥4% wt)

Primary

Crushing

TSP x 0.15 Kg/Mg

Secondary

Crushing

TSP x 0.15 Kg/Mg

Tertiary

Crushing

TSP x 0.15 Kg/Mg

Low moisture coal

(<4% wt)

Primary

Crushing

TSP x 0.15 Kg/Mg

Secondary

Crushing 0. (b) TSP x 0.15 Kg/Mg

Tertiary

Crushing TSP x 0.15 Kg/Mg

7.2113 Wind Erosion of Overburden Emplacement Areas and Other Exposed Areas

The TSP emissions factor taken from the USEPA AP42 Chapter 11.9 Western Surface Coal

Mining (October 1998) was applied in the quantification of wind blown dust from overburden

emplacement areas and other exposed areas (but excluding coal stockpiles). In designating

PM10 and PM2.5 emission factors, reference was made to the PM10/TSP and PM2.5/TSP ratios

specified within USEPA AP42 Chapter 13.2.5 Industrial Wind Erosion (November 2006).

Emission factors, expressed in metric tonnes per hectare of exposed area per year

(Mg/ha/yr), are given in the table below.


0.85 TSP x 0.5 TSP x 0.075 Mg/ha/yr

The TSP emission factor is specified for seeded land, stripped overburden and graded

overburden. This factor was derived based on upwind downwind sampling of exposed areas

at coal mines in the US. Pitts (2005) noted that these coal mines, documented within the

background document to USEPA AP42 Chapter 11.9 Western Surface Coal Mining (October

1998), are located within reasonably dry areas (rainfall in the range of 280 to 430

mm/year) characterised by relatively high wind speeds (four sites with average wind speeds

of 4.8 to 6 m/s, and one with 2.3 m/s). Pitts (2005) therefore concluded that the equation

appears to be based on reasonably dry and windy sites.

The above emission factors are applied in the assessment of wind erosion from shaped and

unshaped overburden emplacement areas, including freshly placed areas, graded areas and

seeded areas. The factors are also applied to vegetated overburden emplacement areas,

with control factors being taken into account contingent upon the level of vegetation

coverage achieved.






of 98


These emission factors are also applied in the quantification of wind blown dust from other

general exposed areas, such as unsealed roads, active mining areas and topsoil stockpiles.

Wind erosion of coal stockpiles is however not quantified using these factors.

7.2114 Wind Erosion of Active Coal Stockpile

A TSP emission factor for active coal storage piles is given in USEPA AP42 Chapter 11.9

Western Surface Coal Mining (October 1998) as follows:

ETSP = 1.8 x u

Where,

ETSP = TSP emissions in kg/ha/hr (kilograms per hectare per hour)

U = mean wind speed (m/s)

The above emission factor is however given for wind erosion and stockpile maintenance.

The Mining Activities defined by OEH for BMP determination purposes lists specifically wind

erosion of coal stockpiles, with dozers on coal being defined as a further activity. This

distinction is understandable given that separate measures may be applied to address

particular emissions arising from wind erosion of stockpiles and maintenance of such

stockpiles by mobile equipment. Given that the above emission factor does not distinguish

between wind erosion and maintenance emissions, an alternative approach was adopted.

Bulldozer operations were addressed using the bulldozer on coal emission factors

documented previously.

Wind blown dust from coal stockpiles was estimated by applying the complex, predictive

emission estimation procedure documented within USEPA AP42 Chapter 13.2.5 Industrial

Wind Erosion (November 2006) as described below.

The predictive emission factor equation for industrial wind erosion is given as follows:

Where,

k = particle size multiplier (k = 1 for TSP, 0.5 for PM10 and 0.075 for PM2.5)

N = number of disturbances per year

Pi = erosion potential corresponding to the observed (or probable) fastest mile of

wind for the ith period between disturbances (g/m²), calculated by:

P = 58(u* - ut*)2 + 25(u* - ut*)

P = 0 for u* ≤ ut*

Where,

u* = friction velocity (m/s)

ut* = threshold friction velocity (m/s)






of 98


The following steps were followed in applying this equation:

Step 1 – The fastest mile of wind was determined between disturbances.

The coal stockpiles were conservatively assumed to be subject to disturbance on a

continuous (hourly) basis to provide an upper bound estimate of emissions (i.e. N=8760).

Emissions were calculated on an hourly basis for the base case emission inventory year

based on measured site-specific wind speed data for this year.

The fastest mile of wind was calculated from the hourly average wind speed based on the

gust factor range documented by Pitts (2005) drawing on the work of Krayer and Marshall

(1992). Fastest mile wind speeds are given by Pitts (2005) as being in the range of

approximately 1.18 to 1.27 times the hourly wind speed. A factor of 1.27 was used to

provide an upper bound estimate of emissions.

Step 2 – The friction velocity was derived for several stockpile sub-areas to account for

different wind exposures.

Given that coal stockpiles typically penetrate the surface wind layer (i.e. piles with height-

to-base ratios exceeding 0.2), it is necessary to consider that different areas of a stockpile

have different exposures to the wind. The friction velocity (u*) must therefore be

calculated taking into account the surface wind speed distribution (us+) which is estimated

as follows:

10u

u

uu

r

s

s

(12)

where,

us+ = surface wind speed distribution

us = surface wind speed (m/s), measured at 25 cm from the pile’s surface

ur = approach wind speed (m/s), or reference wind speed measured at a height of

10 m.

= gust wind speed at reference height of 10 m for periods between disturbances

(m/s)

The shape of the pile and its orientation to the prevailing wind determine wind exposure

patterns (us/ur ratios) at the pile surface. USEPA AP42 Chapter 13.2.5 Industrial Wind

Erosion (November 2006) documents wind exposure patterns for two coal stockpile

configurations based on wind tunnel studies undertaken. The two pile shapes are a conical

pile and an oval pile with a flat top, both with 37 degree side slopes. Contours of

normalised surface wind speeds (us/ur) for both pile shapes are illustrated in Figure 21, with

provision made for differences in the contours for the oval, flat topped stockpile given

different approach wind bearings. The percentage of the pile surface areas represented by

us/ur ratio is given in the table below.






of 98


Figure 21. Contours of normalised surface wind speed (us/ur) for conical and oval,

flat topped stockpiles (after USEPA AP42 Chapter 13.2.5 Industrial Wind Erosion,

November 2006).






of 98


Pile Sub-area

(us/ur)

Percent of Pile Surface Area

Pile A Pile B1 Pile B2 Pile B3 Generic

0.2 40% 36% 31% 28% 27%

0.6 48% 50% 51% 54% 54%

0.9 12% 14% 15% 14% 15%

1.1 0% 0% 3% 4% 4%

Allowing for variations in actual stockpile shapes, a generic set of pile surface areas was

established for application in the emission estimates (as shown in above table). In deriving

this generic set reference was made to the maximum areas across stockpile types covered

by sub-areas with higher us/ur ratios.

Based on the surface wind speed distribution (us+), the friction velocity (u*) was calculated

for each pile sub-area, taking into account the non-uniform wind exposure of stockpiles, by

applying the following equation:

ss u

uu 10.0

)5.0ln

25(

4.0*

Step 3 – A threshold friction velocity was determined.

Reference was made to the literature to identify threshold friction velocities for use in the

erosion potential calculations. Threshold friction velocities for coal piles are given as being

in the range of 0.7 m/s to 1.12 m/s (USEPA, 1988; USEPA AP42 Chapter 13.2.5 Industrial

Wind Erosion, November 2006; Sullivan and Ajwa, 2011). For the purpose of this

assessment the threshold friction velocity of 1.12 m/s applicable to uncrusted coal

stockpiles was applied, as drawn from USEPA AP42 Chapter 13.2.5 Industrial Wind Erosion,

November 2006.

Step 4 – Calculation of annual erosion potential for the entire pile

The erosion potential (P) was calculated for each stockpile sub-area, for each hour, based

on the calculated friction velocity (u*) and the selected threshold friction velocity (ut*) as

follows:

P = 58(u* - ut*)2 + 25(u* - ut*)

P = 0 for u* ≤ ut*

The erosion potentials were then summed across stockpile sub-areas and across hours to

give the total annual erosion potential for the entire pile.






of 98


7.22 Site-specific inputs

A summary of the site-specific information input into the emission estimation calculations is

provided in the table below.

Description Units PRP 2010/2011

Value Source of Information

Material Properties

Moisture Content of ROM Coal % 8 Liddell inputs to OEH Industrial Emissions Inventory Survey 2009

Moisture Content of Product Coal % 10 Liddell inputs to OEH Industrial Emissions Inventory Survey 2009

Moisture Content of Topsoil % 26 Liddell inputs to OEH Industrial Emissions Inventory Survey 2009

Moisture Content of Road Material % 1.7 Site-specific sampling (AP-42 Default Factors is 2.4%)

Moisture Content of Overburden % 1.7 Site-specific sampling (AP-42 Default Factors is 7.9%)

Moisture Content of Tailings % 1.5 Site-specific sampling of dry tailings

Silt Content of ROM Coal % 5 Liddell inputs to OEH Industrial Emissions Inventory Survey 2009

Silt Content of Product Coal % 4 Liddell inputs to OEH Industrial

Emissions Inventory Survey 2009

Silt Content of Topsoil % 32.2 Site-specific sampling

Silt Content of Road Material % 12.1 Site-specific sampling

Silt Content of Overburden % 21.9 Site-specific sampling

Silt Content of Tailings % 46.8 Site-specific sampling

Moisture content reject % 30 Liddell NPI 2010/2011 spreadsheet

Silt content reject % 4 Assume same as coal

Meteorological Data

Mean Wind Speed m/s 2.99 Liddell Meteorological Data (2009-

2011)

No of Rain Days (>0.25mm) days 86.3 Jerrys Plains PO Meteorological Station

Vehicle Information

4WD Speed km/h 55

Grader Speed km/h 13

Weight of Light Vehicle tonnes 1.5

Weight of Haul Trucks 1 tonnes 299

Weight of Water Trucks tonnes 119

Weight of Service Trucks tonnes 7

Weight of User Defined tonnes 250

Drill and Blast

Average Area of Overburden Blast m² 23,767

Rainfall Adjustment

Rainfall adjustment for Road Dust (natural control due to rainfall)

0.764 Calculated based on rainfall






of 98


Moisture and silt contents of unsealed road surface material, topsoil, overburden and dry

tailings were determined based on grab sampling of in situ material and subsequent

laboratory analysis by Simtars (the Safety in Mines Testing and Research Station, Department of

Employment, Economic Development and Innovation). Reference was made to the procedures

outlined in USEPA AP42 Appendix C.1 Procedures for Sampling Surface / Bulk Dust Loading

(July 1993) and USEPA AP42 Appendix C.2 Procedures for Laboratory Analysis of Surface /

Bulk Dust Loading Samples (July 1993). Details regarding the samples taken and results

obtained are provided in the tables below.

Results by Sample:

Average Properties by Material Type:

Material Type Moisture Content (%) Silt Content (%)

Unsealed road surface 1.7 12.1

Topsoil 2.2 32.2

Overburden 1.7 21.9

Dry Tailings 1.5 46.8

No. Sample Name Material Type Moisture Content

(%) Silt Content

(%)

1 Durham Rd 1 Unsealed road surface 2.2 16.2

2 Durham Rd 2 Unsealed road surface 1.8 17.4

3 Waterfill Ramp Unsealed road surface 1.3 6.0

4 RL195 Road Unsealed road surface 1.4 8.8

5 Topsoil Topsoil 2.2 32.2

6 Overburden 1 Overburden 1.8 25.3

7 Overburden 2 Overburden 1.6 18.5

8 Res West Tailings Dry Tailings 1.5 46.8

9 Res west tailings wet Tailings ND 82.7






of 98


7.23 Site-specific Emission Factors (Partially Uncontrolled)

Based on the emission factor equations documented in Section 7.21, and the site-specific

equation inputs documented in Section 7.22, site-specific emission factors were calculated.

These emission factors, provided below, exclude pit retention factors and control measure

efficiencies.

Source

Unit

Calculated Emission Factor

(Integrating Site-specific

Data)

TSP PM10 PM2.5

Light Vehicle Wheel Generated Dust kg/VKT 0.78 0.24 0.02

Scraper Topsoil kg/tonne 0.029 0.009 0.001

Haul Truck Wheel Generated Dust kg/VKT 8.40 2.57 0.26

Water Cart Wheel Generated Dust kg/VKT 5.54 1.70 0.17

Service Truck Wheel Generated Dust kg/VKT 1.55 0.48 0.05

Spare 1 Wheel Generated Dust kg/VKT 7.75 2.38 0.24

Drilling Overburden kg/hole 0.59 0.31 0.02

Drilling Coal kg/hole 0.10 0.05 0.003

Blasting kg/blast 806 419 24

Explosives kg/tonne 51 51 5

Dozers Overburden kg/hour 52.91 16.44 5.56

Dozers Topsoil kg/hour 2.43 0.64 0.25

Dozers Coal ROM kg/hour 16.45 3.85 0.36

Dozers Coal Processed kg/hour 9.42 2.02 0.21

Dozers Reject kg/hour 2.26 0.43 0.05

Truck Loading/Dumping ROM Coal kg/tonne 0.048 0.007 0.0009

Truck Loading/Dumping Reject kg/tonne 0.010 0.002 0.0002

Truck Loading/Dumping Topsoil kg/tonne 0.00005 0.00002 0.00000

3

Truck Dumping Overburden kg/tonne 0.0022 0.0010 0.0002

Truck Loading Overburden kg/tonne 0.0180 0.0054 0.0006

Material Handling ROM Coal (conveyor transfers) kg/tonne 0.00025 0.00012 0.00002

Material Handling Processed Coal (conveyor transfers)

kg/tonne 0.00025 0.00009 0.00001

Material Handling Dry Tailings kg/tonne 0.00264 0.00125 0.00019

Graders Working kg/VKT 2.07 0.568 0.06

Primary Crushing kg/tonne 0.010 0.004 0.0015

Secondary Crushing kg/tonne 0.030 0.012 0.0045

Tertiary Crushing kg/tonne 0.030 0.01 0.0045

Wind Erosion Exposed Areas kg/ha/yr 850 425 64

Wind Erosion Coal Stockpiles kg/ha/yr 1770 885 133






of 98


7.24 Pit Retention Factors

Particulate matter emissions from mining activities located in-pit may be reduced by ‘pit

retention’. This potential reduction is more significant for larger particles, whereas fine

particles have longer atmospheric residence times and are less likely to be removed from

the air by deposition or impaction in the near field even given their release within the

confines of an open cut pit. The National Pollutant Inventory (NPI) Emission Estimation

Technique Manual (EETM) Version 3.0 dated 2011 gives the pit retention factor as being

50% for TSP and 5% for PM10. These factors were applied to account for reductions in

emission for activities occurring within the pit. No pit retention factor was applied for PM2.5.

The percentage emission reduction estimated for each activity based on the

abovementioned pit retention factors and the extent to which activities occur within the pit

are as follows:

Activity Pit Retention (%)

TSP PM10 PM2.5

Loading Overburden to Trucks 50 5 0

Dozers on Overburden and Coal 50 5 0

Loading Coal to Trucks 50 5 0

No pit retention factor was applied for other activities not listed in the above table.

Overall the application of the pit retention factor was estimated to reduce uncontrolled

annual TSP emission estimates by 4.4% and PM10 estimates by 0.4%.






of 98


7.25 Control Efficiencies Applied

A summary is provided below of the control measures currently being implemented for

which control efficiencies are available for application. These control efficiencies were taken

into account in estimating emissions for controlled operations.

Activity/Source Control Measure Description

Current Control Efficiency (%)(a)

TSP PM10 PM2.5

% % %

Drilling of Overburden

Water sprays on drills 70 70 70

Conveying of ROM Coal ROM Coal conveyors and transfer points are enclosed

70 70 70

Conveying of Product Coal Product Coal conveyors are almost fully enclosed with under-pans in place

70 70 70

Product Coal conveyor equipped with water sprays and enclosure(b)

85 85 85

Conveying of Coarse Rejects

Coarse Reject conveyors and transfer points are partially enclosed (roof and one side)

70 70 70

Crushing Operations Coal crushing operations are enclosed with

water sprays implemented(c) 85 85 85

Train Loading Partially enclosed with water spays 70 70 70

Vehicle Activity on Unsealed Roads


75 75 75

Dozer working coarse rejects

Wind break 30 30 30

Wind erosion of unsealed roads


50 50 50

Wind erosion of Overburden Emplacement Areas under Secondary

Rehabilitation

Secondary rehabilitation(e)

60 60 60

Wind Erosion of ROM Coal stockpile

Stockpile water sprays 50 50 50

Loading of Overburden Drop height reduction from 3m to 1.5m(f) 30 30 30

(a) Control efficiencies were derived from the NPI EETM Mining (2011), and the US-EPA

AP42 Emission Factor literature. The method for calculating combined control

efficiencies was taken from NPI EETM Mining (2011).

(b) A control efficiency of 70% was applied for enclosure, and an additional 50% control


(c) A control efficiency of 70% was applied for enclosure, and an additional 50% control


(d) The dust control efficiency of the haul road management system, which includes

chemical suppression, was estimated to be above 90% by external contractor

Reynolds Soil Technologies (refer to Section 3.31). For emission reporting purposes,

LCO currently claims a control efficiency of 75% to provide a conservative (lower

bound) estimated pending objective measurement of the control effectiveness of the

HRMS. A control efficiency of 75% coincides with the control efficiency specified in

NPI EETM Mining (2011) for Level 2 watering, and with the maximum control

efficiency indicated by the US-EPA (2006) to be achievable through wet suppression.






of 98


It is feasible that the actual control efficiency being achieved through chemical

suppression is currently equivalent to or greater than 80%.

(e) Control efficiencies of 40% to 100% applicable for permanent rehabilitation areas

depending on duration in place, coverage, demonstration of self-sustaining (etc.).

For 2010/2011 emission estimates control efficiency of 60% was applied for the 93

ha area rehabilitated during 2009/2010, with a control efficiency of 100% applied for

areas rehabilitated earlier.

(f) Control efficiency referenced within Katestone (2011) for application to truck loading

operations, as calculated based on the dragline equation (Refer to Appendix B).






of 98


7.26 Mine Activity Data for Base Case Year 2011

Activity Material Description of Activity

Extent of

Activity (2011)

Activity Rate Units

Removing Topsoil and Rehabilitation

Topsoil Dozers stripping topsoil 650 Hrs

Topsoil Scrapers removing topsoil - tpa

Topsoil Loading topsoil 110,760 tpa

Topsoil Trucks dumping to stockpile 110,760 tpa

Topsoil Stockpile to trucks (Excavators/Shovels/FELs)

110,760 tpa

Topsoil Trucks dumping to rehab area 110,760 tpa

Overburden Dozer shaping overburden ready for topsoiling

4,052 Hrs

Topsoil Dozer spreading topsoil - Hrs

Drilling Operations

Overburden Drilling 82,102 No. of holes

Coal Drilling - No. of holes

Blasting Operations

Overburden Blasting 189 No. Blasts

Coal Blasting - No. Blasts

Overburden

Extraction and Dumping

Overburden Truck Loading Overburden

(Excavators/Shovels/FELs) 100,175,700 tpa

Overburden Dozers on Overburden 12,102 Hrs

Overburden Trucks Dumping Overburden 100,175,700 tpa

Coal Extraction and Transfer to ROM Coal Hopper

ROM Coal Truck Loading Coal (Excavators/Shovels/FELs)

6,326,228 tpa

ROM Coal Dozers on Coal - Hrs

ROM Coal Trucks Dumping Coal to Hopper 6,326,228 tpa

ROM Coal Trucks Dumping to ROM Stockpile

2,530,491 tpa

ROM Coal Dozers on stockpile 16,733 Hrs

ROM Coal Unloading from Coal Stockpile - tpa

CHPP – ROM Coal

Operations

ROM Coal Loading Conveyor 6,369,210 tpa

ROM Coal Conveying to primary crusher 6,369,210 tpa

ROM Coal Primary crusher 6,369,210 tpa

ROM Coal Conveying to Secondary Crusher

6,369,210 tpa

ROM Coal Secondary crusher 6,369,210 tpa

ROM Coal Conveying to CHPP 6,369,210 tpa

CHPP – Product Coal

Operations

Product Coal Loading Conveyor 4,311,233 tpa

Product Coal Conveying to stockpile 4,311,233 tpa

Product Coal Dozer working stockpile 13,417 Hrs

Product Coal Conveying to bins

tpa

Product Coal Loading Trains 4,311,233 tpa

Vehicle Activity on Mine Roads

Overburden Grader working on surface 226,842 VKT

Overburden Trucks hauling coal material 1,731,523 VKT

Overburden Trucks hauling - gravel roads

VKT

Overburden Water Truck 152,043 VKT

Overburden Service Truck 129,195 VKT

Overburden Spare 1 1,079,649 VKT

Overburden Light Vehicles (4 wheel) 1,856,457 VKT






of 98


Activity Material Description of Activity

Extent of Activity (2011)

Activity Rate Units

Coarse Reject Material Handling

Coarse Reject

Rejects conveyed from CPP to bin

tpa

Coarse

Reject

Loading Reject to Trucks 107,508 tpa

Coarse

Reject

Dumping Coarse Reject 107,508 tpa

Coarse Reject

Dozer working rejects 26,906 Hrs

Rock Crushing for Road Surface

Overburden Excavators/Shovels/FEL's 143,478 tpa

Overburden Primary Crushing 143,478 tpa

Exposed Areas and

Stockpiles

Overburden Exposed Overburden

Emplacement Areas 236 ha

Tailings Antiene North (dry tailings) 32 ha

Road material

Unsealed roads 43 ha

"Overburden" Other Exposed Areas (e.g. Pit) 157 ha

"Overburden" Area under Secondary

Rehabilitation 93 ha

Topsoil Topsoil stockpiles 2 ha

ROM Coal ROMCoal stockpile 6 ha

Product Coal Product Coal stockpile 4 ha

VKT – vehicle kilometres travelled

tpa – tonnes per annum

ROM – run-of-mine

FEL – front end loader

CHPP – coal handling and preparation plant






of 98


7.27 Emission Estimates for 2011 Operations – Partially Uncontrolled and Controlled

Mine Activity Category Mine Activity Partially Uncontrolled - Annual

Emissions (kg/year) Current Controls - Annual

Emissions (kg/year)

TSP PM10 PM2.5 TSP PM10 PM2.5

Bulldozing Overburden/Topsoil Dozers stripping topsoil 1,577 419 166 1,577 419 166

Loading/Dumping Overburden/Topsoil

Loading topsoil 5 3 0 5 3 0


Trucks dumping to stockpile 5 3 0 5 3 0


Stockpile to trucks (Excavators/Shovels/FELs)

5 3 0 5 3 0


Trucks dumping to rehab area 5 3 0 5 3 0

Bulldozing Overburden/Topsoil Dozer shaping overburden ready for topsoiling

214,411 66,612 22,513 214,411 66,612 22,513

Drilling Drilling Overburden 48,440 25,189 1,453 14,532 7,557 436

Drilling Drilling Coal - - - - - -

Blasting Blasting Overburden 152,350 79,222 4,570 152,350 79,222 4,570

Blasting Blasting Coal - - - - - -


Truck Loading Overburden (Excavators/Shovels/FELs)

901,581 513,901 56,800 631,107 359,731 39,760

Bulldozing Overburden/Topsoil Dozers on Overburden 320,191 189,001 67,240 320,191 189,001 67,240


Trucks Dumping Overburden 221,897 104,951 15,893 221,897 104,951 15,893

Loading Coal to Trucks Truck Loading Coal (Excavators/Shovels/FELs)

151,299 41,342 5,749 151,299 41,342 5,749

Bulldozing Coal Dozers on Coal - - - - - -

Trucks unloading Coal (hopper) Trucks Dumping Coal to Hopper 302,597 43,518 5,749 302,597 43,518 5,749

Loading Coal Stockpiles Trucks Dumping to ROM Stockpile 121,039 17,407 2,300 121,039 17,407 2,300

Bulldozing Coal Dozers on stockpile 275,278 64,433 6,056 275,278 64,433 6,056

Unloading from Coal Stockpiles Unloading from Coal Stockpile - - - - - -

Material Transfer of Coal Loading Conveyor 1,614 763 116 1,614 763 116

Material Transfer of Coal Conveying to primary crusher 1,614 763 116 484 229 35

Coal Crushing Primary crusher 63,692 25,477 9,554 9,554 3,822 1,433

Material Transfer of Coal Conveying to Secondary Crusher 1,614 763 116 1,614 763 116






of 98


Mine Activity Category Mine Activity Partially Uncontrolled - Annual Emissions (kg/year)

Current Controls - Annual Emissions (kg/year)

TSP PM10 PM2.5 TSP PM10 PM2.5

Coal Crushing Secondary crusher 191,076 76,431 28,661 28,661 11,465 4,299

Material Transfer of Coal Conveying to CHPP 1,614 763 116 1,614 763 116

Material Transfer of Coal Loading Conveyor 1,092 378 57 164 57 9

Material Transfer of Coal Conveying to stockpile 1,092 378 57 328 113 17

Bulldozing Coal Dozer working stockpile 126,351 27,049 2,780 126,351 27,049 2,780

Material Transfer of Coal Conveying to bins - - - - - -

Train Loading Loading Trains 1,092 378 57 328 113 17

Graders Grader working on surface 469,960 128,810 14,569 117,490 32,202 3,642

Wheel Generated Dust Trucks hauling coal material 14,538,585 4,455,978 445,598 3,634,646 1,113,995 111,399

Wheel Generated Dust Trucks hauling - gravel roads - - - - - -

Wheel Generated Dust Water Truck 842,510 258,224 25,822 210,628 64,556 6,456

Wheel Generated Dust Service Truck 200,360 61,409 6,141 50,090 15,352 1,535

Wheel Generated Dust Spare 1 8,368,090 2,564,763 256,476 2,092,022 641,191 64,119

Wheel Generated Dust Light Vehicles (4 wheel) 1,439,451 441,182 44,118 359,863 110,295 11,030

Material Transfer Rejects Loading Reject to Trucks 1,053 225 20 1,053 225 20

Material Transfer Rejects Dumping Coarse Reject 1,053 225 20 1,053 225 20

Bulldozing Rejects Dozer working rejects 60,745 11,651 1,336 42,522 8,156 935


Excavators/Shovels/FEL's 318 150 23 318 150 23

Other Crushing (waste rock) Primary Crushing 1,435 574 215 1,435 574 215

Wind Erosion of Overburden Exposed Overburden Emplacement Areas

200,600 100,300 15,045 200,600 100,300 15,045

Wind Erosion of Exposed Areas Antiene North (dry tailings) 27,200 13,600 2,040 27,200 13,600 2,040

Wind Erosion of Exposed Areas Unsealed roads 36,550 18,275 2,741 18,275 9,138 1,371

Wind Erosion of Exposed Areas Other Exposed Areas (e.g. Pit) 133,450 66,725 10,009 133,450 66,725 10,009

Wind Erosion of Exposed Areas Area under Secondary Rehabilitation

79,050 39,525 5,929 31,620 15,810 2,372

Wind Erosion of Exposed Areas Topsoil stockpiles 1,700 850 128 1,700 850 128

Wind Erosion of Coal Stockpiles ROM Coal stockpile 10,622 5,311 797 5,311 2,656 398

Wind Erosion of Coal Stockpiles Product Coal stockpile 7,081 3,541 531 7,081 3,541 531

TOTAL 29,521,343 9,450,467 1,061,677 9,513,363 3,218,880 410,657






of 98







of 98


7.3 Appendix C: Control Efficiencies

A summary of control measures and associated control efficiencies from the literature is

provided for significant mining activities.

7.31 Wheel Generated Dust Controls and Control Efficiencies

Type of Measure Control Measure PM Control

Efficiency Reference

Source reduction Usage of conveyors in

place of haul roads 95% Katestone (2011)

Paving of the travel surface >90% MRI (2006) ; Bohn et al. (1978)

Surface improvement Low silt aggregate 30% Bohn et al. (1978)

Application of geotextiles to gravel-surfaced haul roads

56-75% Freeman (2006)

Speed restrictions Reducing truck speed from 75km/hr to 50km/hr

40-75% Foley et al. (1996)

Reducing truck speed from

65km/hr to 30km/hr 50-85% Foley et al. (1996)

Wet suppression Watering (standard procedure)

10% - 75% MRI (2006)

Level 1 watering : 2L/m²/hr

50% NPI EETM Mining (2011)

Level 2 watering : > 2L/m²/hr

75% NPI EETM Mining (2011)

Watering twice a day for

industrial unpaved road 55% MRI (2006)

Surface treatment Petroleum resin (after 5

months of application) 80%

US-EPA AP42 Chapter 13.2.2 Unpaved Roads

(2006)

Oil and double chip surface 80% Bohn et al. (1978)

Chemical suppression 84% MRI (2006)

Chemical suppression 40-98% Foley et al. (1996)

Hygroscopic salt application (control efficiency effectiveness over 14 days)

45% Thompson et al. (2007)

Hygroscopic salt application: (control efficiency effectiveness

within 2 weeks)


Lignosulphonate application: (control efficiency effectiveness over 23 days)


Lignosulphonate 70% Thompson et al. (2007)






of 98


Type of Measure Control Measure PM Control Efficiency

Reference

application: (control efficiency effectiveness over 23 days - upper bound)

Polymer emulsions (control efficiency effectiveness

over 58 days)


Tar and bitumen emulsions (control efficiency

effectiveness over 20 days)


Chemical suppression using EK35

63-94%+(a) US-EPA (2006a)

Chemical suppression using

EnviroKleen 20-99%+(a) US-EPA (2006b)

Chemical suppression using DustGard

58-90%+(a) US-EPA (2006c)

Chemical suppression using

PetroTac 73-94%(a) US-EPA (2006d)

Chemical suppression using Techsuppress

43->90%(a) US-EPA (2006e)

Use of trucks with larger payloads

Usage of larger vehicles rather than smaller

vehicles, 90t to 220t

40% Katestone (2011)

Usage of larger vehicles rather than smaller vehicles, 140t to 220t


Usage of larger vehicles rather than smaller vehicles, 140t to 360t


(a) The dust control efficiency is published by particle size fraction as follows:

Product

Dust Control Efficiency (%)

Total Particulate Matter (TPM) PM10 PM2.5

EK35 63 - 87 84 - 90 56 - 94+

EnviroKleen 78 - 99+ 87 - 91+ 20 - 87+

DustGard 75 - 86 88 - 90+ 58 - 59

PetroTac 74 - 94 73 - 98 >90

Techsuppress 62 - 84 43 - 76 >90






of 98


7.32 Loading and Dumping of Overburden Control Efficiencies

Applicability of Measure Control Measure PM Control Efficiency

References

Truck loading/dumping (and hauling)

Replacement of ‘truck and shovel’ operations with dragline

Site-specific(a)

Avoid double handling of material

100% for avoided handling

Overburden loading by excavator

Minimise drop height from 3m to 1.5 m

30% Katestone (2011)(b)

Modify operations during dry, windy conditions

Not applicable(c)

Truck dumping Minimise drop height from 3m to 1.5 m

30% Katestone (2011)(b)

Modify operations during dry, windy conditions

Not quantifiable(d)

Reduce roll distance of

overburden when dumping Not quantifiable

(a) The control efficiency achieved depends on the site-specific emission intensity (kg

emissions / tonne handled) of dragline operations relative to ‘truck and shovel’ handling.

(b) Reductions are inferred from emission factor for dragline operations which accounts for

drop height (Refer to Appendix B), and rounded down to the nearest 10%.

(c) This measure addresses the potential for off-site impacts by reducing emissions on days

when airborne particles are more likely to be dispersed off-site, rather than reducing

overall annual emissions.

(d) Depends on the prevailing wind speed, sheltered dump space availability and the wind

speed at which modified operations are implemented. The control efficiency is therefore

site-specific, likely to vary substantially over time, and cannot be quantified with

sufficient certainty.

7.33 Bulldozing Overburden Control Efficiencies

Control efficiencies for measures addressing emissions from bulldozing operations are

largely unavailable in the literature.

Katestone (2011) documents a control efficiency of 50% achievable through the application

of watering of overburden ahead of such material being subject to dozer operations. The

control efficiency was also based on a control factor derived from the literature for scrapers

operating on topsoil.

The above measure was however estimated by Katestone (2011) to cost $141,103 per

tonne of PM10 reduced (a factor of 30 times higher compared to measures such as chemical

suppression of haul roads; $4,710/tonne), and therefore not concluded to be a best practice

measure.

The addition of moisture to a sufficient depth, to substantially influence dust emissions from

dozers handling overburden, is impractical and unlikely to achieve the control efficiency

allocated by Katestone (2011).






of 98


7.34 Wind Erosion of Overburden Emplacement Areas – Control

Efficiencies

Type of

Measure Control Measure

PM Control Efficiency

References

Rehabilitation Fully rehabilitated (release)

vegetation 100% NPI EETM Mining (2011)

Rehabilitation 99% Katestone (2011) citing NPI EETM Mining (2001)

‘Secondary rehabilitation’ 60% NPI EETM Mining (2011)

‘Primary rehabilitation’ 30% NPI EETM Mining (2011)

Interim stabilisation Chemical suppression 84% CARB (2002)

Revegetation 90% NPI EETM Mining (2011)

Chemical suppression 70% Bohn et al. (1978)

Wet suppression (watering) 50% Bohn et al. (1978)

Avoid disturbance Restrict vehicle access

Not quantifiable

Emplacement of dustier

material in more sheltered areas

Not quantifiable

8. REFERENCES

ACARP Project C20016, Minimise Fume Generation from Blasting. (On-going project,

reference made to project abstract.)

ACARP Project C20023, Improvement of Haul Road Dust Emission Estimation and Controls

at Coal Mines. (On-going project, reference made to project abstract.)

ACARP Project C19034 Extension, Use of Meteorological Models to Improve Management of

Dust from Open Cut Mines. (On-going project, reference made to project abstract.)

ACARP Project C14055, High Resolution Infra-Red Imagery for the Monitoring of

Revegetation. (On-going project, reference made to project abstract.)

Asia-Pacific Partnership on Clean Development and Climate - Coal Mining Task Force (2009).

Leading Practice Sustainable Development Program for the Mining Industry - Airborne

Contaminants, Noise and Vibration Handbook, October 2009.

Australian Department of Industry Tourism and Resources (2006). Mine Rehabilitation,

Leading Practice Sustainable Development Program for the Mining Industry.

Australian Standard - AS 4156.6-2000 Coal Preparation, Part 6: Determination of

dust/moisture relationship for coal.






of 98


Bohn, R., Cuscinio, T., Cowherd, C., (1978). Fugitive Emissions from Integrated Iron and

Steel Plants, Prepared by Midwest Research Institute for USEPA. EPA Report No. EPA-

600/2-78-050, NTIS Report No. PB-281322

Buonicore, A.J., Davis, W.T. (ed) (1992). Air Pollution Engineering Manual, US Air and

Water Management Association, Van Nostrand Reinhold Company

Brodkom F. (2001). Good Environmental Practice in the European Extractive Industry: A

Reference Guide.

CARB, (2002). Evaluation of Air Quality Performance Claims for Soils-Cement Dust

Suppressant

Carnes, D., Drehmel, D.C. (1981). The Control of Fugitive Emissions using Windscreens.

Third Symposium on the Transfer and Utilization of Particulate Control Technology,

Orlando, Florida

Countess Environmental (2006). WRAP Fugitive Dust Handbook, Western Governor's

Association

Currier, E.L., Neal, B.D., (1979). Fugitive Emission from Coal-Fired Power Plants, 72nd

Annual Meeting of the Air Pollution Control Association, OH. Paper 79-11.4

Cooke JA and Limpitlaw D (2003). Post-mining Site Regeneration: Review of Good Practice

in South Africa, unpublished report to the Global Mining Consortium, Global Centre for

Post-Mining Regeneration, Cornwall, UK.

Countess Environmental (2006). WRAP Fugitive Dust Handbook, Prepared for Western

Governors’ Association, September 2006.

Cowherd C. (2009) Technical Support Document for Mobile Monitoring Technologies,

Midwest Research Institute, 9 January 2009.

Cowherd C. (2009). Mobile Monitoring Method Specifications, Midwest Research Institute, 6

February 2009.

Cowherd C. and Muleski G.E. (2008). Road Dust Control Performance Monitoring, Paper

presented at the 2008 Road Dust Management Practices and Future Needs Conference,

November 13-14 2008, San Antonio, Texas.

Cowherd C. and Englehart J. (1984). Paved Road Particulate Emissions, EPA-600/7-84-077,

US Environmental Protection Agency, Cincinnati, OH.

Cowherd C. and Englehart J. (1985). Size Specific Particulate Emission Factors for Industrial

and Rural Roads, EPA-600/7-85-038, US Environmental Protection Agency, Cincinnati,

OH.

Cowherd C., Muleski G. E. and Kinsey J. S. (1998). Control of Open Fugitive Dust Sources,

EPA-450/3-88-008, United States Environmental Protection Agency, Research Triangle

Park, North Carolina.

Davis, E.A., (1981). Fugitive Dust Emissions from the Proposed Vienna Unit No.9. Prepared

by the John Hopkins University Applied Physics Laboratory for the Maryland Power Plant

Siting Program. NTIS Report No. PB81-190175

DUST-QUANT LLC (2009). User’s Guide for the Miniature Portable In-situ Wind Erosion lab

(PI-SWERL), Version 1.2, Nevada.






of 98


EC (2009). Reference Document on Best Available Techniques for Management of Tailings

and Waste-Rock in Mining Activities, January 2009. (Various other BREF documents also

hold relevance, e.g. fugitive dust control for iron and steel industries, lime

manufacturing plant, ferrous metals processing, etc.)

ENVIRON (2011). Air Quality Improvement Project – Review of Best Practice and XCN Dust

Management Guideline Development, Report compiled by ENVIRON Australia Pty Ltd

on behalf of Xstrata Coal New South Wales, Project No. AS121214, March 2011.

Environment Australia (2001). Emission Estimation Technique Manual for Mining Version

2.3, Environment Australia, GPO Box 787, Canberra, ACT, Australia

Environment Australia (2011). Emission Estimation Technique Manual for Mining Version

3.0, Environment Australia, GPO Box 787, Canberra, ACT, Australia

Environment Australia, (1998). Best Practice Environmental Management in Mining: Dust

Control, Environment Australia, Department of the Environment, 1998.

EPA Victoria (2007). Protocol for Environmental Management – Mining and Extractive

Industries, Publication 1191, December 2007

Etyemezian, V., Kuhns, H., Gillies, J., Green, M., Pitchford, M., Watson, J. (2003). Vehicle-

Based Road Dust Emissions Measurements: I. Methods and Calibration; Atmos. Environ.

2003, 37, 4559-4571.

Fitz D. and Bumiller K. (2008). Evaluation of Dust Control Suppressants on Unpaved Roads

Using Mobile Sampling, Paper presented at the 2008 Road Dust Management Practices

and Future Needs Conference, November 13-14 2008, San Antonio, Texas.

Foley, G., Cropley, S., Giummarra, G. (1996). Road Dust Control Techniques - Evaluation of

Chemical Dust Suppressants. Performance. Special Report 54 to ARRB Transport

Research Limited, Australia

Freeman E. (2006). Geotextile Separators for Dust Suppression on Gravel Roads, MSc

Thesis, University of Missouri-Columbia, 2006.

Georgeff J, Andrew Grigg, David Mulligan, (2004). Bibliography of Rehabilitation on Coal

Mines in Central Queensland, ACARP Project No. C1204401/06/2005.

Gillies J.A., Watson J.G., Rogers C.F. DuBois D.W., Chow J.C, Langston R. and Sweet J.

(1999). Long Term Efficiencies of Dust Suppression to Reduce PM 10 Emissions From

Unpaved Roads, JAWMA, 49, 3-16.

Hashmonay RA, Kagann RH, Rood MJ, Kim BJ, Kemme MR and Gillies J (2009). An

Advanced Test Method for Measuring Fugitive Dust Emissions Using a Hybrid System of

Optical Remote Sensing and Point Monitor Techniques, in Y.J. Kim et al. (eds.),

Atmospheric and Biological Environmental Monitoring, Springer Science+Business Media

B.V. 2009.

Henderson S. (2008). Specification of Overburden for Use as Spoil Cover, ACARP Project

No. C1404201/07/2008.

Holmes Air Sciences (1998). Review of Load Based Licensing Requirements and Exploration

of Alternative Approaches, Report to the Minerals’ Council of NSW, April 1998, as cited

within Pitts (2005).

Jones D. (2000). Dust and Dust Control on Unsealed Roads. PhD Thesis, University of the

Witwatersrand, South Africa.






of 98


Jones, D. and Ventura, D.F.C. (2004). A Procedure for Fit-For-Purpose Certification of Non-

Traditional Road Additives. Pretoria, South Africa: Agrément, South Arica.

Jones D., James D. and Vitale R. (2008). Road Dust Management: State of the Practice,

Paper presented at the 2008 Road Dust Management Practices and Future Needs

Conference, November 13-14 2008, San Antonio, Texas.

Jutze, G.A., Zoller, J.M., Janszen, T.A., Amick, R.S., Zimmer, C.E., (1977). Technical

Guidance for Control of Industrial Process Fugitive Particulate Emissions, prepared by

PEDCo-Environmental, Inc. for USEPA. EPA Report No. EPA-450/3-77-010

Katestone Environmental (2011). NSW Coal Mining Study: International Best Practice

Measures to Prevent and/or Minimise Emissions of Particulate Matter from Coal Mining,

Report compiled on behalf of NSW Office of Environment and Heritage.

Kavouras I.G, Etymezian V., Nikolich G. and Gillies J. (2009). A New Technique for

Characterizing the Efficacy of Fugitive Dust Suppressants, Journal of Air and Waste

Management Association, 59, 603-612, 2009.

Keipert N, Carl Grant, John Duggin, Peter Lockwood, (2004). Effect of Different Stockpiling

Operations on Topsoil Characteristics for Rehabilitation in the Hunter Valley, ACARP

Project No. C902901/08/2004.

Krayer, W.R. and Marshall, R.D. (1992). Gust factors applied to Hurricane Winds. Bulletin

American Meteorological Society, 73, 613-617.

Kuhns H, Etyemezian V, Green M, Hendrickson K, McGrown M, Barton K, Pitchford M.

(2003). Vehicle based road dust emissions measurements — Part II: effect of

precipitation, wintertime road sanding, and street sweepers on inferred PM10 emission

potentials from paved and unpaved roads. Atmos Environ 2003; 37:4573–82.

Liddell Coal Operations - Liddell Coal Environmental Monitoring Program.

Liddell Coal Operations - Dust Management Procedure.

Liddell Coal Operations - Spontaneous Combustion Management Plan

Liddell Coal Operations - Liddell Coal Air Quality Monitoring Program.

Liddell Coal Operations (2010). Annual Environmental Management Report, Year Ending

June 2010, Liddell Coal Operations Pty Ltd.

Martin, D., Drehmel, D.C., (1981). The Influence of Aggregate Pile Shape and Orientation

on Particulate Fugitive Emissions. Third Symposium on the Transfer and Utilization of

Particulate Control Technology, Orlando, Florida

Midwest Research Institute (2006). Background Document for Revisions to Fine Fraction

Ratios used for AP-42 Fugitive Dust Emission Factors, MRI Project No. 110397, Western

Governors' Association, Western Regional Air Partnership (WRAP)

Nichols W., (2004). Development of Rehabilitation Completion Criteria for Native Ecosystem

Establishment on Coal Mines in the Bowen Basin, ACARP Project No.

C1204501/05/2004.

NIOSH (2005). Technology news 512: Improve drill dust collector capture through better

shroud and inlet configurations. Pittsburgh, PA: U.S. Department of Health and Human

Services, Centers for Disease Control and Prevention, National Institute for Occupational

Safety and Health, DHHS (NIOSH) Publication No. 2006–108.






of 98


NIOSH (2010). Best Practices for Dust Control in Coal Mining, Pittsburgh, PA: U.S.

Department of Health and Human Services, Public Health Service, Centers for Disease

Control and Prevention, National Institute for Occupational Safety and Health, DHHS

(NIOSH) Publication No. 2010-110, Information Circular 9517, 2010 Jan; :1-76.

NIOSH (2011). Coal Mine Dust Exposure and Associated Health Outcomes, A Review of

Information Published Since 1995, Current Intelligence Bulletin 64, Department of

Health and Human, Centers for Disease Control and Prevention, National Institute for

Occupational Safety and Health, April 2011.

NPI EETM (1999). National Pollutant Inventory, Emission Estimation Technique Manual for

Fugitive Emissions, December 1999, Environment Australia.


Mining and Processing of Non-Metallic Minerals, Version 2.0, August 2000, Environment

Australia.


Mining, Version 2.3, December 2001, Environment Australia.


Explosives Detonation and Firing Ranges, Version 2.0, January 2008, Environment

Australia.


Mining, Version 3.0, Environment Australia.

NSW Minerals Council, (2000). Technical Paper - Particulate Matter and Mining Interim

Report

Ohio EPA (1980). Reasonably Available Control Measures for Fugitive Dust Sources. Office of

Air Pollution Control, Division of Engineering, Columbus OH, 43216. NTIS Report No.

PB82-103805

Organiscack, J.A., Page, S.J., Cecala, A.B., Kissell, F.N., (2003). Chapter 5 - Surface Mine

Dust Control, Handbook for Dust Control in Mining. IC9465 Information Circular 2003

Park, C.W., Lee, S.J., (2002). Verification of the Shelter Effect of a Windbreak on Coal Piles

in the POSCO Open Storage Yards at the Kwang-Yang works, Atmospheric Environment,

Vol.36, 13, 2171-2185

Planner J. (2010). Coal Dust Control Techniques – Review of Current Practice, ACARP

Project C19007, Published 1 May 2010.

Queensland EPA (1995). Technical Guidelines for the Environmental Management of

Exploration and Mining in Queensland.

Personal communication, Mitchell Bennett, Office of Environment and Heritage, 10 October

2011.

Personal communication, Mitchell Bennett, Office of Environment and Heritage, 27 January

2011.

Pitts O. (2005). Improvement of NPI Fugitive Particulate Matter Emission Estimation

Techniques, Final Report, Sinclair Knight Merz, RFQ No. 0027/2004.

Reed WR, Organiscak JA, Page SJ (2004). New approach controls dust at the collector dump

point. Eng Min J 205(7):29–31.






of 98


RST (2011). Monthly Project Reports for the Haul Road Management System and RT9

Product Application, Reports compiled by Reynold Soil Technologies on behalf of Liddell

Coal Operations Pty Ltd.

Scorgie Y., Fishwick S. and Roddis D. (2011). Methods to Assess In Situ Dust Control

Efficiencies, Paper presented at the Clean Air Society of Australia and New Zealand

Conference, 31 July - 2 August 2011, Auckland.

South Coast Air Quality Management District (2005, 2007). Rules on Fugitive Dust Control

(403) and Fugitive Dust Mitigation Measure Tables (documents control efficiencies for

different controls on unpaved roads, storage piles, materials handling etc.)

SPCC (1986). Particle Size Distributions in Dust from Open Cut Coal Mines in the Hunter

Valley, Report Number 10636-002-71, State Pollution Control Commission of NSW, 1986

SPCC (1983). Air Pollution from Coal Mining and Related Developments, State Pollution

Control Commission, ISBN 0 7240 5936 9, as cited within Pitts (2005).

Stevenson T. (2004). Dust Suppression on Wyoming’s Coal Mine haul Roads,

Recommended Practices and Best Available Control Measures (BACT), A Manual,

Prepared for Industries of the Future Converse Area new Development, October 2004.

Stewart L. A Pocket Field Guide for the Control of Dust at Opencut Coalmines, Newcastle

Office, Department of Environment, Climate Change and Water, Version 4.

Sullivan, D.A. and Ajwa H.A. (2011). Evaluation of Wind Erosion Emissions Factors for Air

Quality Modeling, Soil Science Society of America Journal, 75, 1285-1294.

Sweeney, M., Etyemezian, V., Macpherson, T., Nickling, W., Gillies, J., Nikolich, G.,

McDonald, E. (2008). Comparison of PI-SWERL with Dust Emission Measurements from

a Straight-Line Field Wind Tunnel; J. Geophys. Res. 2008, 113, F01012.

Thompson P., Misso N., Woods J., Seaton, A., Cherrie J. Miller B. and Searl A. (2007).

Literature Review and Report on Potential Health Impacts of Exposure to Crustal Material

in Port Hedland, Review was undertaken by the Lung Institute of Western Australia and

the Institute of Occupational Medicine, UK, on behalf of the Department of Health,

Western Australia, Final Report, April 2007.

Thompson, R.J., Visser, A.T., (2007). Selection, Performance and Economic Evaluation of

Dust Palliatives on Surface Haul Mine Roads, The Journal of The South African Institute

of Mining and Metallurgy, Volume. 107

TRW (1982). BACT and Fugitive Emissions Evaluation of Kentucky Utilities - Hancock

Station PSD Application, Prepared for USEPA Region IV

USEPA (1988). Control of Open Fugitive Dust Sources, EPA-450/3-88-008. Office of Air

Quality Planning and Standards, Research Triangle Park, NC.

USEPA (1992). Fugitive Dust Background Document and Technical Information Document

for Best Available Control Measures, EPA-450/2-92-004, U.S. Department of Commerce,

Springfield, VA, September 1992.

USEPA (1993). AP42 Emission Factor Database, Appendix C.1 Procedures for Sampling

Surface / Bulk Dust Loading (July 1993).

USEPA (1993). AP42 Emission Factor Database, Appendix C.2 Procedures for Laboratory

Analysis of Surface / Bulk Dust Loading Samples (July 1993)






of 98


USEPA (1995). AP42 Emission Factor Database, Chapter 11.24 Metallic Minerals Processing

(January 1995).

USEPA (1995). AP42 Emission Factor Database, Appendix B.2 Generalized Particle Size

Distribution (January 1995).

USEPA (2006). AP42 Emission Factor Database, Chapter 13.2.5 Industrial Wind Erosion,

United States Environmental Protection Agency, November 2006.

USEPA (2006). AP42 Emission Factor Database, Chapter 13.2.2 Unpaved Roads, United

States Environmental Protection Agency, November 2006.

USEPA (2006). AP42 Emission Factor Database, Chapter 13.2.4 Aggregate Handling, United

States Environmental Protection Agency, November 2006.

US-EPA (2006). AP42 Emission Factor Database, Chapter 11.9 Western Surface Coal

Mining, United States Environmental Protection Agency, November 2006.

US-EPA, (2006). 40 CFR Part 50, National Ambient Air Quality Standards for Particulate

Matter: Final Rule, October 2006.

USEPA (2007). Other Test Method 10 (OTM-10), Optical Remote Sensing for Emission

Characterization from Non-Point Sources.

USEPA (2010). AP42 Emission Factor Database, Chapter 13.2.1 Paved Roads, Proposed

Revision, United States Environmental Protection Agency, June 2010.

USEPA (2011). AP42 Emission Factor Database, Chapter 13.2.1 Paved Roads, United States

Environmental Protection Agency, January 2011.

WA DEC (2003). Guidance Statement No 55 – Implementing Best Practice in proposals

submitted to the Environmental Impact Assessment process, Western Australia

Department of Environment and Conservation.

WA DEC (2008). Draft – A Guideline for the Development and Implementation of a Dust

Management Program, Western Australia Department of Conservation, May 2008.

9. CONTROL AND REVISION HISTORY

9.1 Document information

Property Value

Approved by Operations Manager

Document Owner Environment & Community Coordinator

Effective Date 23/02/2012

Keywords Dust, Pollution, Reduction, Programme

For a complete list of document properties, select View Properties from the document’s

context menu on the intranet.






of 98


9.2 Revisions

Version Date reviewed

Review team

(consultation) Nature of the amendment

1 01/02/2012 Environ;

M. Hawthorne;

T. Wells;

D. Foster;

D. O’Brien

B. Desomer

Review draft document and finalise

2 02/02/2012 Environ;

M. Hawthorne

D. Foster

B. Desomer

Finalised for doc control and distribution

3 23/02/2012 Environ

B de Somer

Updated links in Section 4.2, updated formulas

in Appendix B

coal mine particulate matter control best management practice … · 2017-04-04 · an...

Documents