STRATFORD MINING COMPLEX Air Quality and Greenhouse Gas Management Plan

Transcription

1 STRATFORD MINING COMPLEX Air Quality and Greenhouse Gas Management Plan

2 STRATFORD MINING COMPLEX AIR QUALITY AND GREENHOUSE GAS MANAGEMENT PLAN Revision Status Register Section/Page/ Annexure Revision Number Amendment/Addition Distribution DP&E Approval Date All 1 Dust Management Plan EPA, DoPI October 2002 All 2 Stratford Mining Complex Air Quality and Greenhouse Gas Management Plan (May 2011) All Version C (April 2017) Stratford Mining Complex Air Quality and Greenhouse Gas Management Plan (April 2017) EPA, DoPI - EPA, DP&E 22 September 2017 APRIL 2017 Project No. GCL Document No

3 TABLE OF CONTENTS Section Page 1 INTRODUCTION STRATFORD MINING COMPLEX PURPOSE AND SCOPE STRUCTURE OF THE AQMP 4 2 STATUTORY REQUIREMENTS EP&A ACT DEVELOPMENT CONSENT Air Quality and Greenhouse Gas Management Plan Management Plan Requirements LICENCES, PERMITS AND LEASES OTHER LEGISLATION GREENHOUSE GAS AND ENERGY LEGISLATION National Greenhouse and Energy Reporting Act, Energy Efficiency Opportunities Act, SOURCE OF EMISSIONS AIR QUALITY Substances Considered Sources of Particulate Matter GREENHOUSE GASES Substances Considered Sources of Greenhouse Gas Emissions 10 4 AIR QUALITY CRITERIA AND PERFORMANCE INDICATORS DEVELOPMENT CONSENT CONDITIONS Air Quality Assessment Criteria and Air Quality Acquisition Criteria Greenhouse Gas Emissions Odour Operating Conditions ENVIRONMENTAL PROTECTION LICENCE CONDITIONS Mine Operations 13 5 BASELINE DATA DUST MONITORING DATA Dust Deposition PM METEOROLOGICAL MONITORING 14 6 MANAGEMENT MEASURES AIR QUALITY Proactive Measures and Dust Controls Reactive Measures GREENHOUSE GAS EMISSIONS 18 7 DUST MONITORING PROGRAM DUST DEPOSITION HVAS PM TSP REAL -TIME MONITORING METEOROLOGICAL MONITORING 20 AIR QUALITY MANAGEMENT PLAN SMC-D i Stratford Coal Pty Ltd

4 TABLE OF CONTENTS (Continued) 7.5 ASSESSMENT OF DATA VALIDITY PROTOCOL FOR DETERMINING EXCEEDANCES REVIEW OF MONITORING RESULTS 21 8 DUST MANAGEMENT PROTOCOLS AND CONTINGENCY PLAN STANDARD PROTOCOL Source Identification Management Strategy Implementation Review CONTINGENCY PLAN 23 9 ANNUAL REVIEW AND IMPROVEMENT OF AQMP ANNUAL REVIEW AQMP REVIEW REPORTING AND MANAGEMENT PROTOCOLS REFERENCES 26 LIST OF TABLES Table 1 Table 2 Table 3 Management Plan Requirements Management Measures and Controls At-source Control Equipment LIST OF FIGURES Figure 1 Figure 2 Figure 3 Regional Location General Arrangement Meteorological and Air Quality Monitoring Locations LIST OF APPENDICES Appendix A Summary of Development Consent Conditions Relevant to Air Quality and Greenhouse Gas Management AIR QUALITY MANAGEMENT PLAN SMC-D ii Stratford Coal Pty Ltd

5 1 INTRODUCTION 1.1 STRATFORD MINING COMPLEX Stratford Coal Pty Ltd (SCPL), a wholly owned subsidiary of Yancoal Australia Limited (Yancoal), owns and operates the Stratford Coal Mine (SCM), which is located approximately 100 kilometres (km) north of Newcastle, New South Wales (NSW) (Figure 1). SCPL also owns and operates the Bowens Road North Open Cut (BRNOC), located to the immediate north of the SCM. Collectively, these mines, and the associated coal processing and handling facilities, are referred to as the Stratford Mining Complex (SMC). Yancoal also owns the Duralie Coal Mine (DCM), which is located approximately 20 km south of the SMC (Figure 1). Run-of-mine (ROM) coal from the DCM is transported by rail to the SMC, where it is processed along with ROM coal from the SCM and BRNOC. The SCM commenced in 1995 and is operated in accordance with Development Consent (DA 23-98/99) (the SCM Development Consent). The BRNOC commenced in 2003 and is operated under a separate Development Consent (DA ) (the BRNOC Development Consent). The general arrangement of the SMC approved under the SCM and BRNOC Development Consents is provided in Figure 2. At the time of writing (April 2017), construction and mining activities approved under the SCM Development Consent and the BRNOC Development Consent are suspended. However, the SMC continues to process ROM coal from DCM and transport ROM coal from the SMC by rail under the SCM Development Consent. On 29 May 2015, the NSW Planning Assessment Commission approved the Stratford Extension Project (SEP) (Development Consent SSD-4966) under the State Significant Development provisions (Division 4.1) of Part 4 of the NSW Environmental Planning and Assessment Act, 1979 (EP&A Act). The SEP involves the extension and continuation of mine operations at the SMC. SCPL has not commenced the SEP under Development Consent SSD PURPOSE AND SCOPE This Air Quality and Greenhouse Gas Management Plan (AQMP) has been prepared in accordance with the requirements of: Condition 21, Schedule 3 (Environmental Performance Conditions) of the SCM Development Consent; and Condition 6.2D, Schedule 2 of the BRNOC Development Consent. SCM and BRNOC operations are covered collectively in this AQMP. AIR QUALITY MANAGEMENT PLAN SMC-D 1 Stratford Coal Pty Ltd

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7 v Do Wheatleys MLA1 ROSEVILLE WEST PIT ML1733 v Lane BOWENS ROAD NORTH OPEN CUT Northern Waste Emplacement v Cr eek Creek STRATFORD ML1577 Trap ML1528 AVON RIVER g v Road le da Cox on Av Wenham v ML1409 Road ens Bow Roseville Pit (Backfilled) cce Main A Western Co-Disposal Area " STRATFORD MAIN PIT (Co-Disposal Area) v MLA2 Return Water Dam d ss Roa " Road Parkers/Bowens Road West Pit Void ROM Pad and Stockpiles " " Parkers Product Stockpile STRATFORD WASTE EMPLACEMENT " " Rail Loop ML1538 Road d Roa v WAY THE BUCKETTS ML1447 Workshops and Administration Upper Avon ML1360 Roseville Extended Pit (Partially Backfilled) v Bowens Stratford East Dam CHPP and Infrastructure ML1521 Avondale NO R TH COA S T Cre ek WAY R A IL CRAVEN " ETL Realignment GCL MPCF_201A Glen v Roa d ± 1 Kilometres GDA 1994 MGA Zone v 0 LEGEND Mining Lease Boundary Mining Lease Application Boundary Electricity Transmission Line STRATFORD MINING COMPLEX General Arrangement Source: LPI (2016); Geoscience Australia (2006); NSW Department of Industry (2016); SCPL (2016) Figure 2

8 1.3 STRUCTURE OF THE AQMP The remainder of the AQMP is structured as follows: Section 2: Section 3: Section 4: Section 5: Section 6: Section 7: Section 8: Section 9: Outlines the statutory requirements applicable to the AQMP. Describes key sources of emissions. Details the criteria and performance indicators that will be used to assess air quality impacts at the SMC. Provides detailed baseline data. Describes management measures. Describes the dust monitoring program. Provides a dust management protocol and a Contingency Plan to manage any unpredicted impacts and their consequences. Describes the annual review and improvement of environmental performance process. Section 10: Describes the management and reporting of incidents, complaints and non-compliances. Section 11: Lists the references cited. AIR QUALITY MANAGEMENT PLAN SMC-D 4 Stratford Coal Pty Ltd

9 2 STATUTORY REQUIREMENTS SCPL s statutory obligations relevant to the SMC are contained in: (i) the conditions of the SCM and BRNOC Development Consents; (ii) relevant licences and permits, including conditions attached to Mining Leases (MLs); and (iii) other relevant legislation. These are described below. 2.1 EP&A ACT DEVELOPMENT CONSENT The conditions of the SCM and BRNOC Development Consents relevant to air quality and greenhouse gas (GHG) management, and a description of where they are referenced in this AQMP, is provided in Appendix A. Except where explicitly stated in Section 2.1.1, the conditions of the BRNOC Development Consent relevant to air quality are identical to the conditions listed in the SCM Development Consent Air Quality and Greenhouse Gas Management Plan Condition 21, Schedule 3 (Environmental Performance Conditions) of the SCM Development Consent requires the preparation of an AQMP for the SMC. Condition 21 states: Air Quality & Greenhouse Gas Management Plan 21. The Applicant shall prepare and implement an Air Quality & Greenhouse Gas Management Plan for the Stratford mining complex to the satisfaction of the Director-General. This plan must: (a) (b) (c) be prepared in consultation with DECCW, and be submitted to the Director-General for approval by the end of May 2011; and describe the measures that would be implemented to ensure compliance with the relevant conditions of this consent, including the proposed real-time air quality management system; and include an air quality monitoring program, that uses a combination of real-time monitors, high volume samplers and dust deposition gauges to evaluate the performance of the development, and includes a protocol for determining exceedances with the relevant conditions of this consent. Condition 6.1(b), Schedule 2 of the BRNOC Development Consent also prescribes the requirement for an AQMP. The requirements of Condition 6.1(b) are the same in terms of content as those required for the SCM Development Consent (as detailed above), with the exception of Condition 6.2D(b), which states: 6.1 Air Quality Management and Monitoring... Dust Management Plan (b) The Applicant shall, prior to the commencement of construction or operation, prepare a Dust Management Plan or revise and update the existing Plan to address, detailing air quality safeguards and procedures for dealing with dust emissions from the construction and operation of the Bowens Road North mine, as modified by the modification application MOD , to the satisfaction of the Director-General. The Plan shall be prepared in consultation with the GSC and EPA and shall be updated as required by the Director-General. AIR QUALITY MANAGEMENT PLAN SMC-D 5 Stratford Coal Pty Ltd

10 2.1.2 Management Plan Requirements Condition 2, Schedule 5 of the SCM Development Consent outlines the management plan requirements that are applicable to the preparation of the AQMP. Table 1 presents these requirements and indicates where they are addressed within this AQMP. Table 1 Management Plan Requirements Development Consent Condition Condition 2 of Schedule 5 2. The Applicant shall ensure that the management plans required under this consent are prepared in accordance with any relevant guidelines, and include: AQMP Section (a) detailed baseline data; Section 5 (b) a description of: the relevant statutory requirements (including any relevant consent, licence or lease Section 2 conditions); any relevant limits or performance measures/criteria; Section 4 the specific performance indicators that are proposed to be used to judge the performance of, or guide the implementation of, the development or any management measures; (c) a description of the measures that would be implemented to comply with the relevant statutory requirements, limits, or performance measures/criteria; (d) a program to monitor and report on the: impacts and environmental performance of the development; effectiveness of any management measures (see c above); Sections 6 Sections 7 (e) a contingency plan to manage any unpredicted impacts and their consequences; Section 8 (f) a program to investigate and implement ways to improve the environmental performance of the development over time; Section 9 (g) a protocol for managing and reporting any: Section 10 incidents; complaints; non-compliances with statutory requirements; and exceedances of the impact assessment criteria and/or performance criteria; and (h) a protocol for periodic review of the plan. Section LICENCES, PERMITS AND LEASES In addition to the Development Consents, all activities at or in association with the SMC will be conducted in accordance with a number of licences, permits and leases which have been issued. Key licences, permits and leases pertaining to the SMC include: The conditions of Environment Protection Licences (EPLs) No (SCM) and No (BRNOC) issued under the NSW Protection of the Environment Operations Act, The conditions of the following MLs issued under the NSW Mining Act, 1992: - MLs 1360, 1409, 1447, 1538, 1521 and 1733 (SCM); and - MLs 1528 and 1577 (BRNOC). AIR QUALITY MANAGEMENT PLAN SMC-D 6 Stratford Coal Pty Ltd

11 The Stratford Mining Complex Mining Operations Plan (MOP). Mining and occupational health and safety related approvals granted by NSW Department of Industry, Skills and Regional Development Division of Resources and Energy and SafeWork NSW. 2.3 OTHER LEGISLATION SCPL will ensure that the SMC is consistent with the SCM and BRNOC Development Consents and any other legislation that is applicable to an approved Project under Part 4 of the EP&A Act. In addition to those Acts referred to in Section 2.2, the following NSW Acts may be applicable to the conduct of the SMC: Contaminated Land Management Act, 1997; Dangerous Goods (Road and Rail Transport) Act, 2008; National Parks and Wildlife Act, 1974; Noxious Weeds Act, 1993; Roads Act, 1993; Threatened Species Conservation Act, 1995; Work Health and Safety (Mines and Petroleum Sites) Act, 2013; Crown Lands Act, 1989; Dams Safety Act, 2015; Fisheries Management Act, 1994; and Petroleum (Onshore) Act, GREENHOUSE GAS AND ENERGY LEGISLATION National Greenhouse and Energy Reporting Act, 2007 SCPL has participated in the National Greenhouse and Energy Reporting Act, 2007 (NGER) reporting since SCPL will continue to assess and report the following for the SMC in accordance with NGER reporting requirements: Annual scope 1 GHG emissions, which are the direct result of activities at a facility under the operational control of Yancoal and its subsidiaries (i.e. SCPL), such as onsite diesel combustion. Annual scope 2 GHG emissions, which are the emissions associated with the generation of electricity that is purchased by Yancoal. These emissions are not under the operational control of Yancoal. Annual energy consumption, such as diesel and electricity consumption. Annual energy production, such as the energy in the extracted coal. Assessment and reporting of the above will be conducted in accordance with the following legislation subordinate to NGER: National Greenhouse and Energy Reporting Regulations, 2008; and National Greenhouse and Energy Reporting (Measurement) Determination, AIR QUALITY MANAGEMENT PLAN SMC-D 7 Stratford Coal Pty Ltd

12 2.4.2 Energy Efficiency Opportunities Act, 2006 Yancoal registered for participation in the Energy Efficiency Opportunities (EEO) Program in June 2010, in accordance with the requirements of the Energy Efficiency Opportunities Act, As such, Yancoal will assess energy usage from all aspects of its operations, including SMC operations, and publicly report the results of energy efficiency assessments, and the opportunities that exist for energy efficiency projects with a financial payback of up to four years. AIR QUALITY MANAGEMENT PLAN SMC-D 8 Stratford Coal Pty Ltd

13 3 SOURCE OF EMISSIONS 3.1 AIR QUALITY Substances Considered With respect to ambient air quality, particulate matter (i.e. dust) is considered in this AQMP, as per the requirements of the SCM Development Consent. This includes the following: total suspended particulate matter (TSP); and particulate matter < 10 micrometers (μm) (PM 10 ). Particulate matter with diameter less than 2.5 μm (PM 2.5 ) is not a relevant parameter in the SCM or BRNOC Development Consents. Therefore, PM 2.5 is not further considered in this AQMP. However, it should be noted that the management measures described in Section 6 will be relevant for the minimisation and control of all dust, including PM 2.5, PM 10 and TSP Sources of Particulate Matter Mining activities at the SMC are currently suspended. However, the SMC continues to process ROM coal from DCM and transport ROM coal from the SMC by rail (Section 1.1). Notwithstanding the above, sources of particulate matter emissions to air, generated as a direct result of activities at the SMC at full operation, are primarily due to (SCPL, 2002): topsoil stripping and stockpiling; drilling and blasting; waste rock removal, handling and stockpiling; coal mining, handling, crushing, sizing, conveying and stockpiling; loading and unloading trains; wheel generated dust from vehicle movement on unsealed roads (e.g. coal and hauling); and wind erosion of exposed, active surfaces (including disturbed areas and stockpiles). In addition, a small fraction of particulate matter emissions are generated from the combustion of diesel in mining equipment and vehicles. Other sources of anthropogenic and naturally occurring particulate matter emissions that affect air quality in the Gloucester Valley, but are not associated with SMC operations include (SCPL, 2002): agricultural activities; regional vehicle movement; bushfires; and dust storms. AIR QUALITY MANAGEMENT PLAN SMC-D 9 Stratford Coal Pty Ltd

14 3.2 GREENHOUSE GASES Substances Considered The following GHG are considered in this AQMP, as per the requirements of the National Greenhouse and Energy Reporting (Measurement) Determination, 2008: carbon dioxide (CO 2 ); methane (CH 4 ); and nitrous oxide (N 2 O) Sources of Greenhouse Gas Emissions Sources of GHG emissions associated with SMC operations include: diesel combustion in mining equipment and vehicles (scope 1); fugitive emissions of CH 4 released during mining of coal (scope 1); use of explosives (scope 1); and electricity generated off-site that is consumed by SCPL (scope 2). AIR QUALITY MANAGEMENT PLAN SMC-D 10 Stratford Coal Pty Ltd

15 4 AIR QUALITY CRITERIA AND PERFORMANCE INDICATORS 4.1 DEVELOPMENT CONSENT CONDITIONS Air Quality Assessment Criteria and Air Quality Acquisition Criteria Air quality assessment criteria and air quality acquisition criteria are provided in Conditions 18 and 19 respectively of Schedule 3 (Environmental Performance Conditions) of the SCM Development Consent. These Conditions are detailed below, and are the same in terms of content as Conditions 6.2A and 6.2B, Schedule 2 of the BRNOC Development Consent. Air Quality Assessment Criteria 18. The Applicant shall ensure that all reasonable and feasible avoidance and mitigation measures are employed so that particulate matter emissions generated by the Stratford mining complex do not exceed the criteria listed in Tables 5, 6, or 7 at any residence on privately-owned land or on more than 25 percent of any privately-owned land. Table 5: Long term criteria for particulate matter Pollutant Total suspended particulate (TSP) matter Particulate matter < 10 µm (PM 10 ) Averaging period Annual Annual d Criterion a 90 µg/m 3 a 30 µg/m 3 Table 6: Short term criterion for particulate matter Pollutant Particulate matter < 10 µm (PM 10 ) Averaging period 24-hour d Criterion a 50 µg/m 3 Table 7: Long term criteria for deposited dust Pollutant Averaging period Maximum increase in deposited dust level c Deposited dust Annual b 2 g/m 2 /month Notes to Tables 5-7: Maximum total deposited dust level a 4 g/m 2 /month a Total impact (i.e. incremental increase in concentrations due to the Stratford mining complex plus background concentrations due to all other sources); b Incremental impact (i.e. incremental increase in concentrations due to the Stratford mining complex on its own); c Deposited dust is to be assessed as insoluble solids as defined by Standards Australia, AS/NZS :2003: Methods for Sampling and Analysis of Ambient Air Determination of Particulate Matter Deposited Matter Gravimetric Method; d Excludes extraordinary events such as bushfires, prescribed burning, dust storms, sea fog, fire incidents, illegal activities or any other activity agreed by the Director-General in consultation with DECCW. Air Quality Assessment Criteria 19. If particulate matter emissions generated by the Stratford mining complex exceed the criteria in Tables 8, 9 or 10 at any residence on privately-owned land or on more than 25 percent of any privately-owned land, then upon receiving a written request for acquisition from the landowner the Proponent shall acquire the land in accordance with the procedures in Conditions 5-6 of Schedule 4. Table 8: Long term acquisition criteria for particulate matter Pollutant Total suspended particulate (TSP) matter Particulate matter < 10 µm (PM 10 ) Averaging period Annual Annual d Criterion a 90 µg/m 3 a 30 µg/m 3 AIR QUALITY MANAGEMENT PLAN SMC-D 11 Stratford Coal Pty Ltd

16 Table 9: Short term acquisition criteria for particulate matter Pollutant Particulate matter < 10 µm (PM 10 ) Particulate matter < 10 µm (PM 10 ) Averaging period 24-hour 24-hour d Criterion a 150 µg/m 3 b 50 µg/m 3 Table 10: Long term aquisition criteria for deposited dust Pollutant Averaging period Maximum increase in deposited dust level c Deposited dust Annual b 2 g/m 2 /month Maximum total deposited dust level a 4 g/m 2 /month Notes to Tables 8-10: a Total impact (i.e. incremental increase in concentrations due to the Stratford mining complex plus background concentrations due to all other sources); b Incremental impact (i.e. incremental increase in concentrations due to the Stratford mining complex on its own); c Deposited dust is to be assessed as insoluble solids as defined by Standards Australia, AS/NZS :2003: Methods for Sampling and Analysis of Ambient Air Determination of Particulate Matter Deposited Matter Gravimetric Method; d Excludes extraordinary events such as bushfires, prescribed burning, dust storms, sea fog, fire incidents, illegal activities or any other activity agreed by the Director-General in consultation with DECCW Greenhouse Gas Emissions Condition 17, Schedule 3 (Environmental Performance Conditions) of the SCM Development Consent (and is the same in terms of content as Conditions 6.1A, Schedule 2 of the BRNOC Development Consent) states the requirements for SCPL to minimise the release of GHG emissions from the SMC operations, as follows: Greenhouse Gas Emissions 17. The Applicant shall implement all reasonable and feasible measures to minimise the release of greenhouse gas emissions from the site to the satisfaction of the Director-General Odour Condition 16, Schedule 3 (Environmental Performance Conditions) of the SCM Development Consent (and is the same in terms of content as Condition 6.1, Schedule 2 of the BRNOC Development Consent) states the requirements for SCPL to prevent the release of offensive odours from the SMC, as follows: Odour 16. The Applicant shall ensure that no offensive odours are emitted from the site, as defined under the POEO Act Operating Conditions The operating conditions relating to air quality required under the SCM Development Consent are detailed in Condition 20, Schedule 3 (Environmental Performance Conditions) for the SCM. These operating conditions are detailed below, and are the same in terms of content as those listed in Condition 6.2C, Schedule 2 of the BRNOC Development Consent. AIR QUALITY MANAGEMENT PLAN SMC-D 12 Stratford Coal Pty Ltd

17 Operating Conditions 20. The Applicant shall: (a) implement best practice air quality management on site, including all reasonable and feasible measures to minimise the off-site odour, fume and dust emissions generated by the development, including any emissions from spontaneous combustion; (b) minimise any visible air pollution generated by the development; (c) regularly assess the real-time air quality monitoring and meteorological forecasting data and relocate, modify and/or stop operations on site to ensure compliance with the relevant conditions of this consent, to the satisfaction of the Director-General. 4.2 ENVIRONMENTAL PROTECTION LICENCE CONDITIONS Mine Operations In relation to air quality, EPL 5161 for the SCM and BRNOC states in Condition O3.1 and L4.1: O3.1 All operations and activities occurring at the premises must be carried out in a manner that will minimise the emission of dust from the premises.... L4.1 The licensee must not cause or permit the emission of offensive odour beyond the boundary of the premises. Similarly, in relation to air quality, EPL for the SCM and BRNOC states in Condition O3.1: O3.1 Activities occurring in or on the premises must be carried out in a manner that will minimise the generation, or emission of dust from the premises, of wind-blown or traffic generated dust. AIR QUALITY MANAGEMENT PLAN SMC-D 13 Stratford Coal Pty Ltd

18 5 BASELINE DATA 5.1 DUST MONITORING DATA PM 10 and dust deposition data are collected at the SMC. The SMC air quality monitoring network consists of (Figure 3): seven dust deposition gauges; five high volume air samplers (HVASs); one Tapered Element Oscillating Microbalance (TEOM) analyser; and a meteorological monitoring station. A detailed description of baseline air quality is provided in the Stratford Mining Complex Modification 1 Air Quality and Greenhouse Gas Assessment (Pacific Environment Limited [Pacific Environment], 2016) and a summary is presented below Dust Deposition Monitoring data since 2010 show that dust deposition levels are below the Environmental Protection Authority s (EPA) impact assessment of 4 gram per square metre per month (g/m 2 /month). The average across all sites between 2010 and 2015 is 0.7 g/m 2 /month (Pacific Environment, 2016) PM 10 Long-term PM 10 monitoring data have been collected by SCPL since 2011 using HVASs (at up to 5 locations). PM 10 monitoring data have also been collected by SCPL using a TEOM analyser since August PM 10 monitoring results show that since monitoring commenced in 2001, there have been no exceedances of the EPA annual average criterion of 30 microgram per cubic metre (µg/m 3 ). The average across all sites for the monitoring period is 11 µg/m³ (Pacific Environment, 2016). 5.2 METEOROLOGICAL MONITORING Meteorological monitoring is undertaken at the SMC in accordance with Development Consent and EPL requirements. The following data is collected by the weather station: daily rainfall; continuous wind speed and direction; humidity; and daily temperature statistics (e.g. average, maximum and minimum). A summary of monthly meteorological conditions is provided in the SMC Annual Review which is publicly available on the Stratford Coal website ( AIR QUALITY MANAGEMENT PLAN SMC-D 14 Stratford Coal Pty Ltd

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20 6 MANAGEMENT MEASURES 6.1 AIR QUALITY Air quality management at the SMC will continue to involve a combination of proactive and reactive management strategies, as well as at-source control measures. These measures will continue to be supported by a network of dust monitoring stations (refer to Section 7) Proactive Measures and Dust Controls Proactive dust management measures and dust emissions controls will be adopted to minimise dust emissions from the following key dust-generating activities: wind blown dust from exposed areas; and dust generated from mining activities. These management measures are listed in Table 2. Table 2 Management Measures and Controls Source Activity Management Measure Areas disturbed Only the minimum area necessary for mining will be disturbed. by mining Exposed areas will be reshaped, topsoiled and revegetated as soon as practicable. Wind Blown Dust Sources Mining Generated Dust Sources Waste rock emplacement areas Coal handling areas Exposed waste emplacement surfaces that are hauled on will be watered to suppress dust. Progressive rehabilitation (i.e. reshaping, topsoil placement and revegetation) of waste emplacement areas will continue throughout the life of the SMC. Coal-handling areas will be kept in a moist state using water carts to minimise wind blown and traffic generated dust. Coal stockpiles Automatic sprinklers are installed in the existing SMC product coal stockpile area and are activated when wind speeds exceed 5 metres per second (m/s), except during rain events. Haul road dust All roads and trafficked areas will be watered using water carts to minimise the generation of dust. Obsolete roads will be ripped and revegetated. Minor roads Development of minor roads will be limited and the locations of these will be clearly defined. Regularly used minor roads will be watered. Obsolete roads will be ripped and revegetated. Topsoil stripping Access tracks used for topsoil stripping during the loading and unloading cycle will be watered. Topsoil stockpiling Long term topsoil stockpiles will be revegetated with a cover crop. Drilling Dust aprons will be lowered during drilling. Water injection or dust suppression sprays will be used when high levels of dust are being generated. Blasting Fine material collected during drilling will not be used for blast stemming. Adequate stemming will be used at all times. Blasting will only occur following an assessment of weather conditions by the Environmental Officer to ensure that wind speed and direction will not result in excess dust emissions from the site towards adjacent residences (refer to the Blasting and Vibration Management Plan for further information). No blasting will occur in the SMC open cut when wind speeds exceed 5 m/s in a direction that would be likely to carry dust to a nearby receptor. Source: SCPL, AIR QUALITY MANAGEMENT PLAN SMC-D 16 Stratford Coal Pty Ltd

21 A summary of the equipment used for at-source dust control is provided in Table 3. These controls are generally consistent with best practice dust controls identified by Environment Australia (1998). Table 3 At-source Control Equipment Equipment Type Typical Control Area Water trucks Haul roads Other trafficked surfaces (including minor roads) Waste rock emplacements Coal handling areas Water sprays Primary crusher Product conveyors Dust collection system Drill rigs Automated sprinklers Product coal stockpiles Source: SCPL, 2002 The above mitigation/management measures are generally in accordance with the 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 [Katestone], 2010). Katestone (2010) also lists other potential mitigation measures (e.g. the use of chemical agents to assist with dust suppression watering), however this is not considered to be necessary at the SMC given the strong historical record of compliance with criteria. The findings of Katestone (2010) will be considered in future revisions of this AQMP Reactive Measures The implementation of the measures listed in Section will minimise dust generation and the need for responsive management measures. In instances where proactive management measure and dust controls, as described in Tables 2 and 3 respectively, fail to prevent significant dust generation (as identified by dust monitoring [Section 7], by visual observation or in response to a complaint), the following steps will be taken: 1. The Operations Manager and/or Environment & Community Superintendent (or delegate) will determine if excessive dust is being generated. 2. The Operations Manager and/or Environment & Community Superintendent (or delegate) will issue an instruction for the particular mining activity causing the excessive generation of dust to cease immediately. 3. The Environment & Community Superintendent (or delegate) will assess what additional mitigation measures can be applied, including intensive watering of the exposed or active surfaces, reducing the intensity of the activity (e.g. less vehicle movements, reduced vehicle speed and/or utilising a travel surface less prone to produce dust) or installation of mechanical measures (e.g. dust extractors on drill rigs). This assessment will include consideration of wind speed and direction in relation to receptors. 4. If the Environment & Community Superintendent (or delegate) is not satisfied that the additional measures will reduce dust emissions to an acceptable level (due to the prevailing weather conditions) the activity will not recommence until the additional measures have been implemented and/or more favourable weather conditions occur. 5. The Mining Supervisor and/or Environment & Community Superintendent (or delegate) will be responsible for monitoring the activity once it recommences to measure the effectiveness of control measures and to ensure dust emissions are acceptable. AIR QUALITY MANAGEMENT PLAN SMC-D 17 Stratford Coal Pty Ltd

22 Details as to how activities at the SMC may be further modified to reduce dust emissions, in addition to those presented above, will be issue-specific, and developed in consultation with an air quality expert. The development of dust control measures is expected to be an iterative process based on observations and empirical data. 6.2 GREENHOUSE GAS EMISSIONS SCPL has implemented a number of reasonable and feasible measures to minimise GHG emissions from the SMC. These measures are described below: Maximising energy efficiency as a key consideration in the development of the mine plan. For example, significant savings of GHG emissions (through increased energy efficiency) are achieved by mine planning decisions which minimise haul distances for ROM coal and waste rock transport, and therefore fuel use. SCPL has conducted a comprehensive analysis of energy usage and management strategies at the SMC, and has identified cost-effective energy saving opportunities, including: installation of power factor correction equipment to reduce the maximum electricity demand at the SMC by an estimated 10%; replacement of existing pumps in the Coal Handling and Preparation Plant (CHPP) with more efficient models; potential replacement of an existing compressor in the CHPP with a more efficient model; potential replacement of the CHPP rejects pipeline to increase pumping efficiency; and potential adjustment of the number and location of lights in mining and infrastructure areas. In addition, the following measures will be implemented: Regular maintenance of plant and equipment to minimise fuel consumption. Consideration of energy efficiency in the plant and equipment selection phase. The effectiveness of these measures to reduce SCPL s GHG emissions (and energy consumption) will be monitored, as SCPL will annually estimate GHG emissions and energy consumption in accordance with NGER and EEO requirements (refer to Section 2.4). The results of NGER and EEO reporting will also be used internally to identify the major sources of GHG emissions and energy consumption, and to inform future management measures. AIR QUALITY MANAGEMENT PLAN SMC-D 18 Stratford Coal Pty Ltd

23 7 DUST MONITORING PROGRAM The following monitoring program has been developed to ensure that potential air quality impacts are quantified to assist with the continued improvement of control measures. The dust monitoring program will continue to consist of networks of dust deposition gauges and HVASs. The results from these monitoring networks will be used to assess compliance with the criteria in Section for dust deposition and concentrations of particulate matter. In addition, the monitoring program will include a real-time monitor (i.e. a TEOM analyser), in accordance with Condition 21(c), Schedule 3 (Environmental Performance Conditions) of the SCM Development Consent. 7.1 DUST DEPOSITION Dust deposition will continue to be monitored on monthly basis using a network of seven static dust gauges. The seven dust gauges are located in all directions around the SMC (Figure 3). Dust deposition monitoring will continue to be conducted in accordance with the methods detailed in the Approved Methods for the Sampling and Analysis of Air Pollution in New South Wales (Department of Environment and Conservation [DEC], 2006). The dust collected in the deposition gauges will be analysed monthly for ash content, combustible matter and insoluble solids. The results will be compared with the dust deposition criteria in Section HVAS PM 10 A network of five HVASs (HVD1 to HVD5) will continue to measure PM 10 concentrations (Figure 3). In future, HVD1 may be relocated in response to changes associated with the SMC modifications and the addition of a TEOM, and would be renamed HVD6. Monitoring at HVD5 was intended for baseline data and has ceased until operations recommence at the SMC. PM 10 concentrations will be measured on a continuous basis at each site, on a six day cycle, in accordance with procedure AM-18 of the Approved Methods for the Sampling and Analysis of Air Pollution in New South Wales (DEC, 2006). HVAS results will be used to determine compliance with the 24-hour PM 10 concentration criteria in Section The rolling annual average will also be determined and recorded, to determine compliance with annual PM 10 criteria TSP A site-specific correlation between TSP and PM 10 concentrations was developed by SCPL, based on co-located HVASs measuring PM 10 and TSP. From the monitoring, approximately 45% of TSP was PM 10, which compares well with the relationship developed by the NSW Minerals Council for the Hunter Valley (NSW Minerals Council, 2000), which found that approximately 40% of TSP is PM 10. Concentrations of TSP will be calculated, based on this site-specific correlation between PM 10 and TSP. The calculated rolling annual average TSP concentrations will be used to assess compliance with the annual TSP criteria detailed in Section AIR QUALITY MANAGEMENT PLAN SMC-D 19 Stratford Coal Pty Ltd

24 7.3 REAL -TIME MONITORING In addition to the HVASs, a TEOM was installed to monitor real-time PM 10 concentrations. The TEOM monitors PM 10 concentrations in accordance with AS Determination of suspended particulate matter PM 10 continuous direct mass method using a tapered element oscillating microbalance analyser. The TEOM is positioned in close proximity to Stratford Village (Figure 3). This location has been chosen as, based on the results of air quality dispersion modelling, representative of receivers who may experience elevated dust concentrations. The TEOM records five minute instantaneous (i.e. real-time) PM 10 concentrations and rolling 24-hour average PM 10 concentrations. After the TEOM recorded 12 months of data, a five minute instantaneous performance indicator was determined, based on a relationship between five minute instantaneous PM 10 concentrations and 24-hour average PM 10 concentrations. The five minute instantaneous performance indicator was set at a level that allows predictive dust management if dust levels are expected to approach the 24-hour PM 10 Development Consent criteria (Section 4.1.1). The performance indicator will be incorporated into the first revision of this AQMP. When developed, an exceedance of the performance indicator will trigger the Standard Protocol described in Section METEOROLOGICAL MONITORING Wind speed and wind direction are monitored at the existing automated meteorological monitoring station at the SMC (Figure 3). The meteorological station also monitors rainfall, temperature and humidity Wind speed and wind direction data will be used in conjunction with all dust monitoring data, as described above, to further minimise the potential for dust emissions, and to provide useful information for review of the effectiveness of dust management practices. 7.5 ASSESSMENT OF DATA VALIDITY Where monitoring indicates a potential non-compliance against criteria detailed in Section it is necessary to assess the potential for the influence of the following factors: Extreme events, such as: bushfires; prescribed burning; dust storms; fire incidents; illegal activities; and other activities agreed by the Secretary of the Department of Planning and Environment (DP&E) and the Office of the Environment and Heritage (OEH). Irregular activities near monitoring sites such as: exposed areas of soil around the monitoring site; adjacent land use activities; and contamination from bird droppings, insects, etc. Reasonableness of data (e.g. is the equipment operating properly, providing reliable data and in calibration?). AIR QUALITY MANAGEMENT PLAN SMC-D 20 Stratford Coal Pty Ltd

25 7.6 PROTOCOL FOR DETERMINING EXCEEDANCES Monitoring results will be used to assess dust emissions from the SMC against the criteria detailed in Section If data analysis indicates that a criterion has been exceeded, an assessment will be made of the data validity (refer to Section 7.5). Monitoring results above the criteria levels are not exceedances until the data has been assessed and verified. If an exceedance of the criteria detailed in Section is recorded, the Standard Protocol detailed in Section 8.1 will be triggered. Dust deposition gauge and HVAS data will be assessed monthly. 7.7 REVIEW OF MONITORING RESULTS The results of dust and meteorological monitoring will continue to be recorded in a database for examination and assessment. This data will be used to investigate relationships between short-term variations in dust levels, and the number and distribution of any dust-related complaints. Results of this investigation will then be used in the review of the monitoring program. Monitoring results will be reported annually in the Annual Review. AIR QUALITY MANAGEMENT PLAN SMC-D 21 Stratford Coal Pty Ltd

26 8 DUST MANAGEMENT PROTOCOLS AND CONTINGENCY PLAN The dust management protocols outlined below have been formulated to facilitate the proactive and reactive management of dust emissions from the SMC. 8.1 STANDARD PROTOCOL The objective of the Standard Protocol is to facilitate the day-to-day management of dust emissions from SMC activities, and will be triggered if the performance indicator described in Section 7.3 is exceeded (when developed). Dust control will be actively carried out as a standard operating procedure to facilitate a safe working environment utilising techniques outline in Section 6. The Standard Protocol will be the responsibility of the Environment & Community Superintendent. The Standard Protocol can be broken into four steps as follows: 1. Source Identification. 2. Management Strategy. 3. Implementation. 4. Review Source Identification The first step of the protocol involves identification of the mining activities with the potential for excessive dust generation. Consideration will be given to the following: methods and types of equipment that will be used; timing of the activity; location of the activity (including surrounding topography and land use); the results of recent air quality monitoring data; and prevailing climatic conditions. The outcomes of the above process will determine whether there is the potential for exceedances of air quality criteria and therefore if it is necessary to implement the management strategy phase. Source identification is ongoing and conducted during the course of operations Management Strategy The management strategy component involves determination of the dust control and management measures that will be utilised to minimise air quality emissions, based on the results of the identification stage. Potential air quality mitigation and management measures are presented in Section Implementation This stage involves implementation of the dust control and management measures chosen in the management strategy process. The Environment & Community Superintendent will be responsible for the timely implementation of the selected measures (generally effective immediately once the management strategy is determined). AIR QUALITY MANAGEMENT PLAN SMC-D 22 Stratford Coal Pty Ltd

27 8.1.4 Review An important component of the protocol is the review of dust control and management measures. These will be assessed by comparing the results of the air quality monitoring program detailed in Section 7 with the air quality criteria outlined in Section Where necessary, the management strategy phase of the protocol will be reviewed. 8.2 CONTINGENCY PLAN In the event that an air quality criteria detailed in Section is considered to have been exceeded, SCPL will implement the following Contingency Plan: The Environment & Community Superintendent will report the likely exceedance to the General Manager within 24 hours of assessment completion. SCPL will report the exceedance of the air quality criteria to the EPA and the DP&E as soon as practicable (i.e. within 7 days). SCPL will identify an appropriate course of action with respect to the identified impact(s), in consultation with specialists and the EPA, as necessary. SCPL will, on request, submit the proposed course of action to the DP&E for approval. SCPL will implement the approved course of action to the satisfaction of the DP&E. AIR QUALITY MANAGEMENT PLAN SMC-D 23 Stratford Coal Pty Ltd

28 9 ANNUAL REVIEW AND IMPROVEMENT OF AQMP 9.1 ANNUAL REVIEW In accordance with Condition 3, Schedule 5 of the SCM Development Consent, SCPL will conduct an Annual Review of the environmental performance of the SMC by the end of December each year. The Annual Review meets the requirement for the Annual Environmental Management Report required by Condition 9.2 Schedule 2 of BRNOC Development Consent. The Annual Review will be made publicly available on the Stratford Coal website, in accordance with Condition 10, Schedule 5 of the SCM Development Consent. The Annual Review will specifically address the following aspects of Condition 3, Schedule 5, which are directly relevant to air quality and GHG management: include a comprehensive review of the monitoring results and complaints records for the SMC over the previous calendar year, including a comparison of these results against the: relevant statutory requirements, limits or performance measures/criteria; monitoring results of previous years; and relevant predictions in the Environmental Assessment; identify any non-compliance over the past year, and describe what actions were (or are being) taken to ensure compliance; identify any trends in the monitoring data over the life of the SMC; identify any discrepancies between the predicted and actual impacts of the SMC, and analyse the potential cause of any significant discrepancies; and describe what measures will be implemented over the next year to improve the environmental performance of the SMC. This AQMP will be reviewed within three months of the submission of an Annual Review, and revised where appropriate, as described in Section 9.2 below. 9.2 AQMP REVIEW In accordance with Condition 4, Schedule 5 of the SCM Development Consent, this AQMP will be reviewed, and if necessary revised to the satisfaction of the Secretary of the DP&E within three months of the submission of: an Annual Review, in accordance with Condition 3, Schedule 5; an incident report, in accordance with Condition 6, Schedule 5; an audit, in accordance with Condition 8, Schedule 5; or any modification to the conditions of SCM Development Consent. Where this review leads to revisions of the AQMP, the revised AQMP will be submitted for the approval of the Secretary of the DP&E. The revision status of this AQMP is indicated on the title page of each copy. This AQMP will be made publicly available on the Stratford Coal website, in accordance with Condition 10, Schedule 5 of the SCM Development Consent. A hard-copy will also be kept at the SMC. AIR QUALITY MANAGEMENT PLAN SMC-D 24 Stratford Coal Pty Ltd

29 10 REPORTING AND MANAGEMENT PROTOCOLS In accordance with Condition 2(g), Schedule 5 of the SCM Development Consent, SCPL has developed protocols for managing and reporting the following: incidents; complaints; non-compliances with statutory requirements; and exceedances of the impact assessment criteria and/or performance criteria. The management of incidents is described in detail in the Pollution Incident Response Management Plan. The management of complaints and non-compliances is described in detail in the Environmental Management Strategy. The management of exceedances of performance criteria is detailed in Sections 7 and 8 of this AQMP. AIR QUALITY MANAGEMENT PLAN SMC-D 25 Stratford Coal Pty Ltd

30 11 REFERENCES Department of Environment and Conservation (2006) Approved Methods for the Sampling and Analysis of Air Pollutants in New South Wales. Available from: < Environment Australia (1998) Best Practice Environmental Management in Mining: Dust Control. Department of the Environment. Katestone Environmental Pty Ltd (2010) NSW Coal Mining Benchmarking Study: International Best Practice Measures to Prevent and/or Minimise Emissions of Particulate Matter from Coal Mining, prepared for the New South Wales Department of Environment, Climate Change and Water (now Office of Environment and Heritage), December NSW Minerals Council (2000) Technical Paper Particulate Matter and Mining Interim Report. Pacific Environment Limited (2016) Stratford Mining Complex Modification 1 Air Quality and Greenhouse Gas Assessment. Stratford Coal Pty Ltd (2002) Dust Management Plan. AIR QUALITY MANAGEMENT PLAN SMC-D 26 Stratford Coal Pty Ltd

31 APPENDIX A SUMMARY OF DEVELOPMENT CONSENT CONDITIONS RELEVANT TO AIR QUALITY AND GREENHOUSE GAS MANAGEMENT AIR QUALITY MANAGEMENT PLAN SMC-D Stratford Coal Pty Ltd

32 Table A-1 Summary of Development Consent Conditions Relevant to Air Quality and Greenhouse Gas Management Schedule Section Condition Description Section of AQMP Schedule 3 Odour 16 The Applicant shall ensure that no offensive odours are emitted from the site, as defined under the POEO Act (Environmental Performance Conditions) Greenhouse Gas Emissions 17 The Applicant shall implement all reasonable and feasible measures to minimise the release of greenhouse gas emissions from the site to the satisfaction of the Director-General. Operating Conditions 20 The Applicant shall: (a) implement best practice air quality management on site, including all reasonable and feasible measures to minimise the off-site odour, fume and dust emission generated by the development, including any emission from spontaneous combustion; (b) minimise any visible air pollution (c) regularly assess the real-time air quality monitoring and meteorological forecasting data and relocate, modify and/or stop operations on site to ensure compliance with the relevant conditions of this consent, Air Quality & Greenhouse Gas Management Plan Meteorological Monitoring 21 The Applicant shall prepare and implement an Air Quality & Greenhouse Gas Management Plan for the Stratford mining complex to the satisfaction of the Director-General. This plan must: (a) be prepared in consultation with DECCW, and be submitted to the Director-General for approval by the end of May 2011; and (b) describe the measures that would be implemented to ensure compliance with the relevant conditions of this consent, including the proposed real-time air quality management system; and (c) include an air quality monitoring program, that uses a combination of real-time monitors, high volume samplers and dust deposition gauges to evaluate the performance of the development, and includes a protocol for determining exceedances with the relevant conditions in this consent. 22 During the life of the development, the Applicant shall ensure that there is a suitable meteorological station operating in the vicinity of the site that: (a) complies with the requirements in Approved Methods for Sampling of Air Pollutants in New South Wales guideline N/A AIR QUALITY MANAGEMENT PLAN SMC-D A-1 Stratford Coal Pty Ltd