Best Management Practice Air Quality Assessment ENVIRONMENTAL MANAGEMENT PLAN

Transcription

1 Doc Owner: Doc No: Environment and Community Coordinator EMP-D CVC Best Management Practice Air Quality Assessment ENVIRONMENTAL MANAGEMENT PLAN Author PAE Holmes / LakeCoal Cynthia Isley / Judith Cox / Chris Ellis Authorised by: Chris Ellis Environmental Specialist LD Operations Pty Ltd Date: 25/09/ /09/2012 NA 1 Environment and Community Page 1 of 38 Coordinator

2 Chain Valley Colliery EMP D Table of Contents 1 Introduction Background PRP Requirements Overview of CVC Operations Mining activity and Emission Factors Existing Measures used to Minimise Emissions Estimated Emissions No Controls Estimated Emissions Current Controls Ranked Emissions Current Controls Practicability of Implementing Additional Best Practice Measures Estimated Emissions for Practical BPM Implementation Evaluation Implementation of Practical BPM Monitoring and tracking the Effectiveness of BPM KPI-1 Emissions of PM10 per tonne of coal Recommendations for Ongoing improvement of KPI Document Control References & Associated Documents Definitions /09/08 25/09/10 1 Manager Mechanical Engineering Page 2 of 38

3 Chain Valley Colliery EMP D Introduction Chain Valley Colliery (CVC) is an underground coal mine located on the southern end of Lake Macquarie, approximately 100km north of Sydney and 60km south of Newcastle, adjacent to the Vales Point Power Station, producing thermal coal for the domestic and export markets. Operations at CVC include underground coal mining via continuous miner and miniwall methods, with coal being transported off-site for domestic customers or to the port of Newcastle for the export market. CVC operates under Environment Protection Licence (EPL) 1770, issued under the Protection of the Environment Operations Act, On the 21 December 2011 EPL 1770 was modified to include new conditions relating to conducting and implementing best management practice particulate matter control measures. The requirements of these new conditions, specifically U1.1, U1.2 and U1.3 are all covered by this assessment. 1.1 Background In June 2011, the NSW Environmental Protection Agency (EPA) a published the final best practice document NSW Coal Mining Benchmarking Study: International Best Practice Measures to Prevent and/or Minimise Emissions of Particulate Matter from Coal Mining (hereafter called the Best Practice Report ) (Donnelly et al., 2011). As an outcome of the Best Practice Report, the EPA developed a Pollution Reduction Program (PRP) that requires each NSW coal mine to prepare a report on the practicability of implementing best practice measures to reduce particle emissions. The Coal Mine Particulate Matter Control Best Practice PRP is a requirement of CVC s Environmental Protection Licence (EPL1770). 1.2 PRP Requirements The PRP requires the Licensee (Lake Coal) to conduct a site-specific Best Management Practice (BMP) and to prepare a report on the practicability of implementing measures to reduce emissions of particulate matter (PM). The report must include the following: The identification, quantification and justification of the measures that are currently being used to reduce PM emissions. The identification, quantification and justification of best practice measures that could be used to minimise PM emissions. An evaluation of the practicability of implementing the best practice measures. A proposed timeframe for implementing all practicable best practice measures. In preparing the report the Licensee must refer to the document entitled Coal Mine Particulate Matter Control Best Practice Site Specific Determination Guideline (referred to as the Guideline) (OEH, 2011), which details the process to be followed in preparing a PRP. It also provides the required content and format of the PRP. a The NSW EPA exists as a legal entity operated within the Office of Environment and Heritage (OEH) which came into existence in April OEH was previously part of the Department of Environment, Climate Change and Water (DECCW). The DECCW was also recently known as the Department of Environment and Climate Change (DECC), and prior to that the Department of Environment and Conservation (DEC). The terms NSW EPA, OEH, DECCW, DECC and DEC are used where appropriate in this report. 25/09/08 25/09/10 1 Manager Mechanical Engineering Page 3 of 38

4 Chain Valley Colliery EMP D Table 1:1 presents a summary of the Guideline requirements and a reference to the relevant section in this report. Table 1:1: PRP Guideline requirements and report reference 1) Identification, quantification and justification of existing measures that are being used to minimise particle emissions Guideline Requirement a. Estimate baseline emissions of TSP, PM 10 and PM 2.5 (tonne per year) from each mining activity using US EPA AP- 42 emission estimation techniques for both uncontrolled emissions (with no particulate matter controls in place) and controlled emissions (with current particulate matter controls in place). b. Rank the controlled emission estimates for TSP, PM 10 and PM 2.5 emitted by each mining activity from highest to lowest. c. Identify the top four mining activities that contribute the highest emissions of TSP, PM 10 and PM 2.5. Report Reference Section 2.1 and 2.2 Section 2.3 Section 2.3 2) Identification, quantification and justification of best practice measures that could be used to minimise particle emissions a. For each of the top four activities identified in Step 1(c) identify the measures that could be implemented to reduce emissions. b. For each of the top four activities identified in Step 1(c) estimate emissions of TSP, PM 10 and PM 2.5 from each mining activity following the application of the measures identified in Step 2 (a). Section 3 Section 3 25/09/08 25/09/10 1 Manager Mechanical Engineering Page 4 of 38

5 Chain Valley Colliery EMP D ) Evaluation of the practicability of implementing these best practice measures Guideline Requirement a. For each of the best practice measures identified in Step 2(a), assess the practicability associated with their implementation, by taking into consideration: i. Implementation costs ii. Regulatory requirements iii. Environmental impacts iv. Safety implications and v. Compatibility with current processes and proposed future developments. b. Identify those best practices that will be implemented at the premises to reduce particle emissions. Report Reference Section 3 Section 4 4) A proposed timeframe for implementing all practicable best practice measures a. For each of the best practice measures identified as being practicable in step 3(b), provide a timeframe for their implementation. Section 5 PAEHolmes has been commissioned by LakeCoal to assist in the development of a Coal Mine Particulate Matter Control Best Practice PRP for the CVC. 1.3 Overview of CVC Operations CVC is an underground coal mine, currently, coal mining methods include development of roadways in the coal seam, by continuous miner, known as first workings. These first workings develop panels to support the installation of a miniwall, a modern secondary coal extraction method. Coal from both the first and second workings are transported out of the mine via a conveyor system, where the coal is sized and transported by surface conveyor systems to product bins prior to transport and/or stockpiling. No coal washing is undertaken on site. If the coal is not able to be loaded and hauled directly from the product bins to the customer or port by truck, it is stored on the stockpile area, prior to being sold and transported from site to either domestic customers or to the port of Newcastle for the export market. 25/09/08 25/09/10 1 Manager Mechanical Engineering Page 5 of 38

6 Chain Valley Colliery EMP D Mining activity and Emission Factors The Best Practice Guideline list mining activities to be evaluated, not all of these activities occur at CVC, particularly as this is an underground mining operation. The relevant activities from this list comprise the following: Wheel generated particles on unpaved roads; Bulldozers on coal stockpiles; Wind erosion of exposed areas; Wind erosion of coal stockpiles; Trucks loading and unloading coal; Coal crushing; Material transfer of coal; and Coal screening. The relevant emission factors for each of these activities are presented in Appendix A. 2 Existing Measures used to Minimise Emissions Emissions were calculated using the relevant using USEPA AP-42 emission estimation techniques for both uncontrolled emissions and controlled emissions. A copy of the emission factors and data applied are presented in Appendix A and Appendix B. 2.1 Estimated Emissions No Controls TSP, PM 10 and PM 2.5 emission estimates have been calculated for mining activities that occurred during the 2011 calendar year at the CVC, using the relevant USEPA AP-42 emission factors as listed in Appendix A. Emission estimates have been made with no particulate matter controls in place (see Table 2:1.) as well as with current particulate matter controls in place (see Table 2:3). The following data/assumptions have been used; Truck movements have been determined from 2011 calendar year data. Bulldozer hours are from 2011 calendar year data. ROM coal production is from the 2011 calendar year Exposed areas have been calculated from spatial information Stockpile areas have been calculated from spatial information 25/09/08 25/09/10 1 Manager Mechanical Engineering Page 6 of 38

7 Chain Valley Colliery EMP D A summary of the emissions without dust controls is provided in Table 2:1. Table 2:1 Summary of PM emissions with no controls in place (tonnes / year) Activity TSP PM 10 PM 2.5 Bulldozers on coal stockpiles Coal crushing Coal screening Material transfer of coal (transfer points) Trucks loading coal (from stockpile) Trucks unloading coal (to stockpile) Wheel generated particles on sealed roads (non EPA activity category) Wheel generated particles on unsealed roads Wind erosion of exposed areas Wind erosion of stockpiles Total Estimated Emissions Current Controls Emissions were then recalculated taking into account various control factors for the dust controls that CVC has in place. These controls, as well as the control factor applied, are listed in Table 2:2. The control factors listed are sourced from the Best Practice Report (Donnelly et al., 2011). A series of photographs have also been included, to demonstrate dust control techniques in use on the CVC site. These include: Figure 2.1 Figure 2.2 Figure 2.3 Figure 2.4 Figure 2.5 Direct loading to trucks via conveyor, final bin and loading. Conveyor partially enclosed Main final product bin showing conveyors and enclosed transfer into bin. Bin design minimises drop height into trucks. 250 t product bin fed by enclosed conveyor. Enclosed transfer from conveyor to bin. Bin design minimises drop height to trucks. Enclosed conveyors Water cart operating on exposed working areas. 25/09/08 25/09/10 1 Manager Mechanical Engineering Page 7 of 38

8 Chain Valley Colliery EMP D Table 2:2: Emissions and existing controls Activity / Process Control Control Details Evidence of Control Wheel generated particulates on unpaved roads Crushing and Screening Trucks unloading coal (to coal stockpiles) Trucks loading coal (from coal stockpiles) Bulldozers on coal Stockpiles Wind erosion of coal stockpiles Wind erosion of exposed areas Material transfer of Coal (transfer points) 75% Level 1 watering (2 litres/m 2 /h - 50%) Speed reduction (20 km/h 50%) 85% 70% for enclosure and 50% (of remaining 30%) for water sprays. Note: Primary crusher is situated underground, secondary crushing and screening occurs above ground. See Figure 2.5. Photographs, water cart dockets sighted. Verified during site inspection 30% Low drop height. Verified during site inspection No - - Control No - - Control 30% Wind breaks Visible on aerial photographs. Verified during site inspection 50% Level 1 watering (2 litres/m 2 /h) See Figure 2.5. Photographs, water cart dockets sighted. varied 11 transfer points in total (mine surface to trucks loading) 4 transfer points are enclosed (70%) 3 transfer points have manually operated water sprays (50%) See Figure 2.4, Photographs. A summary of the predicted annual emissions incorporating existing dust controls is provided in Table 2:3. Table 2:3 Summary of PM emissions with current controls (tonnes / year) Activity TSP PM 10 PM 2.5 Bulldozers on coal stockpiles Coal crushing Coal screening Wheel generated particles on sealed roads (non EPA activity category) Wheel generated particles on unsealed roads Material transfer of coal (transfer points) Trucks loading coal (from stockpile) Trucks unloading coal (to stockpile) Wind erosion of stockpiles Wind erosion of exposed areas Total /09/08 25/09/10 1 Manager Mechanical Engineering Page 8 of 38

9 Chain Valley Colliery EMP D Figure 2.1: Direct loading to trucks via conveyor, final bin and loading. Conveyor partially enclosed. 25/09/08 25/09/10 1 Manager Mechanical Engineering Page 9 of 38

10 Chain Valley Colliery EMP D Figure 2.2: Main final product bin showing conveyors with enclosed transfer point. Bin design minimises drop height into trucks. Figure 2.3: 250 t product bin fed by enclosed conveyor. Enclosed transfer from conveyor to bin. Bin design minimises drop height to trucks. 25/09/08 25/09/10 1 Manager Mechanical Engineering Page 10 of 38

11 Chain Valley Colliery EMP D Figure 2.4: Enclosed conveyors Figure 2.5: Water cart operating on exposed working areas. 25/09/08 25/09/10 1 Manager Mechanical Engineering Page 11 of 38

12 Chain Valley Colliery EMP D Ranked Emissions Current Controls Activities are ranked in terms of total annual emission (existing controls) and presented in Table 2:4. Error! Reference source not found.in accordance with the Best Practice Guideline, the top four ranked activities according to estimated mass particulate emissions for TSP, PM 10 and PM 2.5 are shown in bold. An evaluation of Best Practice measures for the following activities is therefore presented in Section 3: Trucks loading coal from coal stockpiles; Trucks unloading coal to coal stockpiles; Bulldozers on coal stockpiles. Wheel generated particles on unpaved roads; Table 2:4: Ranked activities by mass emissions (controlled) Rank Mining Activity Emissions (t/y) TSP 1 Trucks loading coal from stockpile Trucks unloading coal to stockpile Bulldozers on coal stockpiles Wheel generated particles on unsealed roads Wind erosion of exposed areas Wheel generated particles (sealed roads) Coal screening Wind erosion of stockpiles Material transfer coal (transfer points) Coal crushing 0.3 PM 10 1 Bulldozers on coal stockpiles Trucks loading coal from stockpile Wheel generated particles on unsealed roads Trucks unloading coal to stockpile Wind erosion of exposed areas Coal screening Wind erosion of stockpiles Material transfer coal (transfer points) Wheel generated particles (sealed roads) Coal crushing 0.1 PM Trucks loading coal from stockpile Bulldozers on coal stockpiles Trucks unloading coal to stockpile Wheel generated particles on unsealed roads Wind erosion of exposed areas Wind erosion of stockpiles Material transfer coal (transfer points) Wheel generated particles (sealed roads) Coal crushing Coal screening /09/08 25/09/10 1 Manager Mechanical Engineering Page 12 of 38

13 EMP D Chain Valley Colliery 3 Practicability of Implementing Additional Best Practice Measures Based on the information presented in Section 2 it is clear that CVC already has a number of PMcontrol measures in place. With current controls, dust emissions are reduced by approximately 39% for TSP, 49% for PM 10 and 41 % for PM 2.5 compared with having no controls in place. A summary of the best practice measures (BPM) potentially available for the highest particulate generating activities, as well as the associated effectiveness, as documented within the Best Practice Report (Donnelly et al., 2011) is provided in this section. The following tables summarise the best practice measures for the top-ranking activities (in terms of dust emission). Table 3:1 BPM to reduce PM emissions trucks loading coal from stockpiles Table 3:2 BPM to reduce PM emissions trucks unloading coal to stockpiles Table 3:3 BPM to reduce PM emissions bulldozers on coal stockpiles Table 3:4 BPM to reduce PM emissions from wheel generated particles on unpaved roads In accordance with the Best Practice Guideline, for the BPM identified these tables, an evaluation of the practicality of implementation is required, taking into consideration: implementation costs; regulatory requirements; environmental impacts; safety implications, and Compatibility with current processes and proposed future developments. For each of the top activities identified, the emissions of TSP, PM 10 and PM 2.5 from each mining activity after applying BPM have been estimated. All potential BPM which are identified within the Best Practice Report (Donnelly et al., 2011) are presented, regardless of the practicality of implementation or likelihood of effectiveness. It is important to note that the values presented assume the current controls as presented in Table 2:2. The results of this evaluation are included within the abovementioned tables. Prior to an evaluation of implementation costs, a high level review of all the BPM identified has been undertaken to refine the list based on practicality and achievable environmental gain. In some cases the existing controls employed at the CVC achieve reductions in excess of these measures and hence no further evaluation of these measures is required. A discussion and further evaluation of the best practice measures is provided in Section 4. It is noted that for many of the top-ranking site activities (in terms of dust generation), existing controls are in place. Whilst further controls may be considered for these top-ranking activities, an assessment of the remaining site activities has also been undertaken in order to assess whether further controls may be appropriate. The remaining (lower ranking activities in terms of dust) have also been assessed and are included in Table 3:5. 25/09/08 25/09/10 1 Manager Mechanical Engineering Page 13 of 38

14 EMP D Chain Valley Colliery Table 3:1 BPM to reduce PM emissions trucks loading coal from stockpiles Best Practice Control Practicality Evaluation % control Current Use Regulatory Environmental Safety Compatibility Practicable Y/N Evaluation Comments from Mine Potential reduction in dust emission (t/y) dust emission as % of total site dust emission (current controls) Existing control efficiency of 0% is assumed, (see Table 2:2) TSP PM 10 PM 2.5 TSP PM 10 PM 2.5 Avoidance Bypass stockpiles 100% N* N Y Y N N *Direct loading and haulage will be preferentially undertaken as opposed to stockpiling. Dust emission calculations have conservatively assumed that 75% of coal is stockpiled and reclaimed. As coal production occurs 24-hours per day and load-out is approved only within certain hours, some level of stockpiling is currently unavoidable. Additionally stockpiling will at times be necessary based on production levels, shipping schedules and customer demand % 21% 27% Truck or loader dumping coal Minimise drop height (10m to 5m) Water sprays on pad 30% Y Current practice % 6% 8% 50% N Y Y Y N N Water sprays were used in the past on work area. These were replaced by water cart as it was able to more effectively keep the entire area moist than fixed sprays % 11% 14% 25/09/12 NA 1 Environment and Community Coordinator Page 14 of 38

15 EMP D Chain Valley Colliery Table 3:2 BPM to reduce PM emissions trucks unloading coal to stockpiles Best Practice Control Avoidance Truck or loader dumping ROM coal Bypass stockpile Replace trucks with conveyor stacker Minimise drop height (10m to 5m) Water sprays on pad % control Current Use Practicality Evaluation Regulatory Environmental Safety Compatibility 100% N N Y Y N N Practicable Y/N 100% N Y Y Y Y Y Evaluation Comments from Mine Direct loading and haulage will be preferentially undertaken as opposed to stockpiling. Dust emission calculations have conservatively assumed that 75% of coal is stockpiled and reclaimed. As coal production occurs 24-hours per day and load-out is approved only within certain hours, some level of stockpiling is unavoidable. Additionally stockpiling will at times be necessary based on production levels, shipping schedules and customer demand. Instead of loading to trucks, which load to the stockpile, the existing loading conveyor may be extended to load directly to the stockpile, which effectively removes one handling step (truck). dust emission (t/y) dust emission as % of total site dust emission (current controls) Existing control efficiency of 30% is assumed, (see Table 2:2) TSP PM 10 PM 2.5 TSP PM 10 PM % 15% 19% % 15% 19% 30% Y Current practice % N Y Y Y N N Water sprays were used in the past on work area. These were replaced by water cart as it was able to more effectively keep the entire area moist than fixed sprays % 7% 10% 25/09/12 NA 1 Environment and Community Coordinator Page 15 of 38

16 EMP D Chain Valley Colliery Table 3:3 BPM to reduce PM emissions bulldozers on coal stockpiles Best Practice Control Bulldozers on Coal (stockpile) Minimise travel speed and distance Keep travel routes and materials moist % control Not quantified Current Use Practicality Evaluation Regulatory Environmental Safety Compatibility Y % Y Practicable Y/N Evaluation Comments from Mine Site speed restrictions of 20 km/h apply. Distances travelled by bulldozers are minimal due to stockpile size and limited are for bulldozer to work within. Travel routes are kept moist. Water cart does operate on stockpile when required, however it is unclear whether this BPM would be entirely satisfied, hence no current control has been applied for this BPM. dust emission (t/y) dust emission as % of total site dust emission (current controls) Existing control efficiency of 0% is assumed (see Table 2:2 TSP PM 10 PM 2.5 TSP PM 10 PM % 15% 11% 25/09/12 NA 1 Environment and Community Coordinator Page 16 of 38

17 EMP D Chain Valley Colliery Table 3:4 BPM to reduce PM emissions from wheel generated particles on unpaved roads Best Practice Control Vehicle speed restrictions Surface improvements Reduction from 75 km/hr to 50 km/hr Reduction from 65 km/hr to 30 km/hr Pave the surface Low silt aggregate Oil and double chip surface % control Current use Regulatory Practicality Evaluation Environmental Safety Compatibility Practicable Y/N Evaluation Comments from Mine dust emission (t/y) dust emission as % of total site dust emission (current controls) Existing control efficiency of 75% is assumed (see Table 2:2) TSP PM 10 PM 2.5 TSP PM 10 PM % Y Current practice: 50% dust emission reduction is assumed for vehicle speed restrictions (20 km/h) % Y >90% N Y Y Y N N 30% N % N N N N N N Some areas of the site have been paved as appropriate, eg. Permanent roads and around weighbridge. Paving all equipment storage areas and hardstands is impractical due to equipment weight/crane use which would damage pavement. Road-base material for the CVC site is imported from off-site however silt levels not specified. Limited exposed areas which are already managed via water truck. Runoff from site is passed via sediment dams and then discharged offsite into Lake Macquarie, potential contamination of this runoff from oils are an environmental risk not considered justified given current controls % 11% 10% % 5% 5% % 4% 3% 25/09/12 NA 1 Environment and Community Coordinator Page 17 of 38

18 EMP D Chain Valley Colliery Best Practice Control Surface treatments Other Watering (standard procedure) Watering Level 1 (2 L/m2/h) Watering Level 2 (>2 L/m2/h) % control Current use Regulatory Practicality Evaluation Environmental Safety Compatibility Practicable Y/N 10-74% Y % Y % N Y N Y N N Suppressants 84% (d) N Y N Y N N Use of larger vehicles Conveyors Up to 40% 100% for haul section replaced N N N N N N Y Y Y Y Y Y Evaluation Comments from Mine Current practice: 50% dust emission reduction assumed for watering Current practice: 50% dust emission reduction assumed for watering Site water is obtained from potable water supply from Wyong Shire Council, site has specific measures aiming to reduce potable water use. Significantly increasing potable water use for increased watering is not seen as justified use of this water supply. Runoff from site is passed via sediment dams and then discharged offsite into Lake Macquarie, potential contamination of this runoff from chemical suppressants is an environmental risk not considered justified given current controls. Vehicles used for load-out only or stockpiling when load-out is not possible. Road vehicles are required (for transport of coal) and hence the size and capacity of the vehicles cannot be increased typically using large trucks already (B-doubles and truck and dog configurations). Conveyors are used extensively on site. There is the possibility of further use of conveyors for stacking product coal to the stockpile when direct load-out is not possible. This would reduce dust from wheelgenerated particles as shown (right), based on the decreased travel distance for trucks. dust emission (t/y) dust emission as % of total site dust emission (current controls) Existing control efficiency of 75% is assumed (see Table 2:2) TSP PM 10 PM 2.5 TSP PM 10 PM % 4% 4% % 15% 14% % 7% 7% % 6% 5% 25/09/12 NA 1 Environment and Community Coordinator Page 18 of 38

19 EMP D Chain Valley Colliery Table 3:5 BPM to reduce PM emissions remaining activities Best Practice Control % control Current Use Practicality Evaluation Regulatory Wind erosion of exposed areas (50 % control assumed) Environmental Safety Compatibility Practicable Y/N Evaluation Comments from Mine dust emission (t/y) dust emission as % of total site dust emission (current controls) Existing control efficiency (see Table 2:2) TSP PM 10 PM 2.5 TSP PM 10 PM 2.5 Surface stabilisation Wind speed reduction Watering 50% Y Current practice Chemical suppressants Paving and cleaning Application of gravel to stabilise disturbed open areas Fencing, bunding, shelterbelts 70-84% N Y Y Y N N Exposed areas at CVC encompass minor roads, stockpile area and hardstand area only. Imported road base material is used. Runoff from site is passed via sediment dams and then discharged offsite into Lake Macquarie, potential contamination 84% N* Y Y Y N N of this runoff from chemical suppressants is an environmental risk not considered % 3% 5% justified given current controls % 4% 5%-6% >95% N Y Y Y N N % 5% 6% 30-80% N Y N Y N N Windbreak from vegetation around site along with watering controls already used. Extensive fencing would require clearing additional vegetation around the site which are endangered ecological communities %- 3 % 2%- 6 % 2% - 8% 25/09/12 NA 1 Environment and Community Coordinator Page 19 of 38

20 EMP D Chain Valley Colliery Best Practice Control % control Current Use Practicality Evaluation Regulatory Wind erosion of coal stockpiles (30% control assumed) Avoidance Bypassing stockpiles Environmental Safety Compatibility 100% N Y Y Y N N Water sprays 50% N Y Y Y N N Practicable Y/N Evaluation Comments from Mine Direct loading and haulage will be preferentially undertaken as opposed to stockpiling. Dust emission calculations have conservatively assumed that 75% of coal is stockpiled and reclaimed. In practice, stockpiling rates would be lower than this. Percentages listed refer to dust emissions avoided if stockpiles were avoided for the remaining 75% of coal. As coal production occurs 24-hours per day and load-out is approved only within certain hours, some level of stockpiling is unavoidable. Additionally stockpiling will at times be necessary based on production levels, shipping schedules and customer demand. Water cart operates on stockpile, as it is unknown whether watering frequency complies with this BPM, no control has been applied. dust emission (t/y) dust emission as % of total site dust emission (current controls) Existing control efficiency (see Table 2:2) TSP PM 10 PM 2.5 TSP PM 10 PM 2.5 1% 2% 3% 1% 2% 3% 1% 1% 2% 1% 1% 2% Surface stabilisation Enclosure Chemical wetting agents Surface crusting agent Carry over wetting from load in Cover storage pile with a tarp during high 80-99% N Y Y Y N N Not practicable for product coal stockpile which is fairly constantly being loadedout. Materials are wet when stockpiled, however constant load-out would expose drier materials % 2% 2% - 3% 95% N Y Y Y N N % 2% 3% 80% N Y Y Y N N % 2% 2% 99% N Y Y N N N Not appropriate for product coal stockpile which is fairly constantly being loaded / management / loaded-out % 2% 3% 25/09/12 NA 1 Environment and Community Coordinator Page 20 of 38

21 EMP D Chain Valley Colliery Best Practice Control winds % control Current Use Practicality Evaluation Regulatory Environmental Safety Compatibility Practicable Y/N Evaluation Comments from Mine dust emission (t/y) dust emission as % of total site dust emission (current controls) Existing control efficiency (see Table 2:2) TSP PM 10 PM 2.5 TSP PM 10 PM 2.5 Vegetative windbreaks 30% Y Current practice Reduced pile height 30% N Y Y Y N N Pile height is determined by safety requirements and available area % 1% 1% Wind screens / fences 75->80% N Y Y Y N N Stockpile already has vegetative windbreak, additional screens/fences would require clearing additional vegetation around the site which are endangered ecological communities % 2% 3% Wind speed reduction Pile shaping/ orientation <60% N Y Y Y N N Size / orientation of stockpile is bounded by infrastructure and sediment containment structures % - 1% 0%- 1% 0%-2% Erect 3-sided enclosure around storage piles 75% N Y Y Y N N Access to stockpiles is required from 3 sides for typical operation. The forth side gives access for earthmoving equipment to clean our sediment dams. Enclosing would restrict and operations, require increased VKTs to operate stockpile which would increase PM emissions as a result % 2% 3% 25/09/12 NA 1 Environment and Community Coordinator Page 21 of 38

22 EMP D Chain Valley Colliery Best Practice Control % control Current Use Practicality Evaluation Conveyor and material transfer of coal (50% control assumed for transfer points) Regulatory Environmental Safety Compatibility Practicable Y/N Evaluation Comments from Mine dust emission (t/y) dust emission as % of total site dust emission (current controls) Existing control efficiency (see Table 2:2) TSP PM 10 PM 2.5 TSP PM 10 PM 2.5 Conveyors b Application of water at transfers Wind shielding-roof or side wall Wind shielding-roof and side wall 50% Y Current practice Conveyors on the CVC site vary in shielding, from completely shielded to 40% N Y Y Y N N partially shielded to not shielded. Unshielded conveyor sections are, in general, relatively short. Shielding would need to be retrofitted to older conveyors at significant cost % N Y Y Y N N Shielding is to be considered with future conveyor replacement/upgrades not independently given the above Belt cleaning and spillage minimisation Not quantified Y Staff employed full-time to ensure this b Wind erosion from surfaces of the conveyors not estimated as not considered a significant source. No costings were carried out for conveyor emission BPMs. 25/09/12 NA 1 Environment and Community Coordinator Page 22 of 38

23 EMP D Chain Valley Colliery Best Practice Control Transfers Application of water at transfers % control Current Use Practicality Evaluation Regulatory Environmental Safety Compatibility 50% Y Enclosure 70% N Y Y N N N Enclosure and fabric filters Not quantified Practicable Y/N Evaluation Comments from Mine 11 transfer points, 3 with water sprays. Values show dust reduction for water sprays at remaining points. 11 transfer points, 4 enclosed. Values show dust reduction for enclosure of remaining points. Enclosing all transfer points would increase safety risks confined space work, make maintenance more difficult and require specific design and manufacture of enclosures, accordingly is not practical. dust emission (t/y) dust emission as % of total site dust emission (current controls) Existing control efficiency (see Table 2:2) TSP PM 10 PM 2.5 TSP PM 10 PM % 1% 1% % 1% 2% N Y Y Y N N As above /09/12 NA 1 Environment and Community Coordinator Page 23 of 38

24 Chain Valley Colliery EMP D Estimated Emissions for Practical BPM LakeCoal has identified a BPM, not currently in place on the CVC site, which would be practicable (see Table 3:2 and Table 3:4). In this scenario, the existing short conveyor section on the final product bin, currently used to load trucks, would be replaced by a stacker conveyor that would load directly to the stockpile. Truck loading (for direct load-out) would continue to occur directly from product bin through existing loading points. Table 4:1 summarises BPM identified as practicable for the mining activities at CVC, the potential reduction of dust emissions due to implementing the BPM and the potential reduction of emissions as a percentage of the total dust emissions from CVC. In this case, the same BPM (stacker) would reduce emissions from wheel generated particles on unpaved roads (by replacing the section of haulage from the product bin to the stockpile) and it would also reduce emissions from trucks unloading coal to stockpiles (by removing this activity). In effect, the final transfer point from the conveyor (which is currently to trucks), would simply be moved to the stockpile. Further consideration of costs is provided in Section 4.1. Mining Activity Table 4:1: Estimated Emissions for Practical BPM BPM Dust Emissions for activity after BPM (t/y) Potential Reduction as % of total site dust emission Wheel generated particles on unsealed roads Trucks unloading coal to stockpiles Installation of stacker conveyor: fit stacker conveyor to section of conveyor which loads to trucks (which then load to stockpile) with a section of conveyor that loads directly to stockpile. TSP PM 10 PM 2.5 TSP PM 10 PM % 6% 5% % 15% 19% Total emission reduction 28% 20% 24% 4.1 Implementation Evaluation For the measures identified in Table 4:1, an additional cost evaluation was completed and summarised below. Full details are provided in Appendix C. For installation and operation of a stacker to load the stockpile, the net cost per tonne of PM 10 abated as a result would be of the order of $182,972.97/tonne-PM 10 in the first year, $9,729.73/tonne-PM 10 annually thereafter and a total of $270,540.54/tonne-PM 10 over 10 years. Accordingly, on a PM reduction cost basis alone the stacker is not a practicable option, however CVC has considered cost saving associated with reducing the rehandling of material and decided to proceed with the project on the basis of improved operational efficiencies, which also have a net benefit to PM reduction. Review Date Next Review Revision No Document Owner Page Date 25/09/12 NA 1 Environment and Community Coordinator Page 24 of 38

25 Chain Valley Colliery EMP D The measure will also require approval in accordance with the Environmental Planning and Assessment Act 1979 prior to installation. The project is expected to be permissible with consent, and as such consent will need to be sought from Wyong Shire Council. Should consent not be issued, the project would no longer be practicable 5 Implementation of Practical BPM A single practical BPM has been identified which involves the installation of a stacker conveyor to replace current transfers to trucks for stockpiling. This stacker will be installed by December 2013 which is expected to be sufficient time for final design, fabrication, approvals and construction and commissioning to occur. 6 Monitoring and tracking the Effectiveness of BPM On the 8 May 2012, the EPA held an information session and workshop to provide feedback to consultants and mines on the dust PRPs received to date. A key outcome of the workshop (referred to as Key Message 3 (EPA, 2012)) was that the control effectiveness of both existing and proposed BPM should be measured and reported, as follows: Control effectiveness must be supported by: - Key performance indicator - Monitoring method - Location, frequency and duration of monitoring - Monitoring data records and analysis - Management procedures In accordance with EPA expectations, the following Key Performance Indicator (KPI) is proposed for CVC. 6.1 KPI-1 Emissions of PM 10 per tonne of coal This headline KPI will provide an indication of the overall effectiveness of all PM controls (for all activities) at CVC, and makes direct use of the emissions inventory compiled for the PRP process. The value of the KPI will change each year depending not only on the application of control measures, but also on any changes in the distribution of mining activities (e.g. as the lengths of haul roads change). The KPI will be recalculated on an annual basis (Annual Return reporting period) using the PRP emissions inventory spreadsheet. The annual recalculation will be relatively straightforward, requiring input data on intensity for each mining activity (e.g. material production rates, VKT, dozer hours etc. It is also recommended that this KPI is improved by using site specific input data (silt content, moisture content, control efficiencies). An outline of the monitoring recommended for improvements to this KPI is outlined in Section 6.2. Review Date Next Review Revision No Document Owner Page Date 25/09/12 NA 1 Environment and Community Coordinator Page 25 of 38

26 Chain Valley Colliery EMP D Further details for this KPI are outlined in Error! Reference source not found., along with objectives and targets and reporting requirements. Table 6:1: KPI for BPM KPI-1 Annual emissions of PM 10 per tonne of ROM coal (kg PM 10/t ROM) Metric Method / Standard Objective / Target Frequency Report This KPI is defined as follows: 1 = Where: Annual dust emissions inventory using PRP emissions inventory template Downward trend in PM 10/ tonne of coal produced Annual (matching 12 month reporting period for Annual Return) Annual Return K1y is the value of KPI-1 (in kg of PM 10 per tonne of ROM coal) in year y E PM10 is the total emission of PM 10 from the mine (in kg, with current controls) in year y M ROM is the mass of ROM coal (in tonnes) mined in year y 6.2 Recommendations for Ongoing improvement of KPI Another key message from the EPA information sessions (referred to as Key Message 2 (EPA, 2012)) was the use of site specific data in deriving PM emissions estimates for the PRP, such as: Material parameters moisture and silt contents. Meteorology. Vehicle weight, speed, traffic volume. Activity data areas disturbed, stockpiles, material transfer. The available site specific data has been provided by the mine (refer Appendix B) and used for the PM emissions estimates presented in the report. However, due to time constraints the sampling and analysis of material properties was not completed. For ongoing evaluation against the KPI, it is recommended that improvements are made to emission estimates using site specific data and site specific control efficiencies are determined. The recommended monitoring for input into the KPI are outlined in Table 6:2. Measurement methods for determination of site specific controls for water are outlined in Table 6:3. Review Date Next Review Revision No Document Owner Page Date 25/09/12 NA 1 Environment and Community Coordinator Page 26 of 38

27 Chain Valley Colliery EMP D Table 6:2: Site specific measurements for improvements to KPI-1 Parameter Measurement Method / Standard Frequency % moisture content (product coal) % silt content ( product coal, unsealed roads) Dust Extinction Moisture Level (DEM 1 ) US EPA AP42 Appendix C.1 Procedures for Sampling Surface / Bulk Dust Loading US EPA AP42 Appendix C.2 Procedures for Laboratory Analysis of Surface Dust Loading Samples US EPA AP42 Appendix C.1 Procedures for Sampling Surface / Bulk Dust Loading US EPA AP42 Appendix C.2 Procedures for Laboratory Analysis of Surface Dust Loading Samples AS Coal Preparation Part 6: Determination of dust/moisture relationship for coal Annual Annual One off (ROM and product coal) Notes: 1 DEM is defined as the moisture level at which dustiness is reduced to a level of 10 (i.e. minor dust emissions expected during bulk handling operations) Table 6:3: Site specific control efficiencies Parameter Measurement Method / Standard Frequency Site Specific Watering Control Effectiveness Control Efficiency determined by linear relationship between control efficiency and moisture content of surface, shown below. Annual Moisture Ratio (M) as defined by US EPA AP 42 Chapter Unpaved Roads: = Moisture Content determined by: ASTM D Standard Test Methods for Laboratory Determination of Water (Moisture) Content of Soil and Rock by Mass ASTM D Standard Test Methods for Laboratory Compaction Characteristics of Soil Using Modified Effort (56,000 ft-lbf/ft (2,700 kn-m/m)) Review Date Next Review Revision No Document Owner Page Date 25/09/12 NA 1 Environment and Community Coordinator Page 27 of 38

28 Chain Valley Colliery EMP D Document Control This document and all others associated with the Environmental Management System shall be maintained in a document control system which is in compliance with the site Document Control Standard (STD-0058) which is available to all personnel. Any proposed change to this document shall be via the document control administrator who is the only person able to access the controlled documents. A Document Change / Review Request Form (FRM-0010) in compliance with Change Management Health and Safety Standard (HSSTD-0009) is required to be completed to modify controlled documents. 8 References & Associated Documents Donnelly, S.-J., Balch, A., Wiebe, A., Shaw, N., Welchman, S., Schloss, A., Castillo, E., Henville, K., Vernon, A., Planner, J. (2011). NSW Coal Mining Benchmarking Study: International Best Practice Measures to Prevent and / or Minimise Emissions of Particulate Matter from Coal Mining Prepared by Katestone Environmental Pty Ltd for Office of Environment and Heritage June EPA (2012) EPA Presentation Tuesday 8th May 2012 Dust Stop PRP Stage 1 Consultant Workshop. OEH (2011). Coal Mine Particulate Matter Control Best Practice - Site-specific determination guideline. November New South Wales Office of Environment and Heritage, Sydney. November USEPA (1998). AP-42 Compilation of Emission Factors, Section Western Surface Coal Mining, October USEPA (2004). AP-42 Compilation of Emission Factors, Section Crushed Stone Processing and Pulverized Mineral Processing, August USEPA (2006a). AP-42 Compilation of Emission Factors, Section Unpaved Roads. November USEPA (2006b). AP-42 Compilation of Emission Factors, Section Aggregate Handling and Storage Piles, November POL-0002 Environment & Community Policy FRM-0010 (D-12927) Document Change / Review Request Form STD-0058 (D-13510) Document Control Standard STD-0059 (D-13551) Record Keeping Standard OMP-D Environmental Management Strategy EPL1770 Environment Protection Licence number 1770 Review Date Next Review Revision No Document Owner Page Date 25/09/12 NA 1 Environment and Community Coordinator Page 28 of 38

29 Chain Valley Colliery EMP D Definitions AEMR Annual Environmental Management Report AQMP Air Quality management Plan BPM Best Practice Measure CH 4 Methane CVC LakeCoal - CVC DEM Moisture level at which dustiness is reduced to a level of 10 (i.e. minor dust emissions expected during bulk handling operations) EMS Environmental Management System EPA NSW Environment Protection Authority OEH NSW Office of Environment and Heritage PM Particulate matter PM 10 Particulate matter less than 10 microns in aerodynamic diameter PM 2.5 Particulate matter less than 2.5 microns in aerodynamic diameter TSP Total Suspended Particulates µg/m 3 micrograms per cubic meter µm micrometers (microns) ROM Run Of Mine g/m 2.month grams per square meter per month Review Date Next Review Revision No Document Owner Page Date 25/09/12 NA 1 Environment and Community Coordinator Page 29 of 38

30 Chain Valley Colliery EMP D APPENDIX A: EMISSION FACTOR EQUATIONS Review Date Next Review Revision No Document Owner Page Date 25/09/12 NA 1 Environment and Community Coordinator Page 30 of 38

31 EMP D Chain Valley Colliery Table A9:1: Emission Factors PRP activity Units TSP Emission Factor PM 10 Emission Factor PM 2.5 Emission Factor Source Wheel generated particulates on unpaved roads kg/vkt AP Wheel generated particulates on paved roads kg/vkt AP Bulldozing coal kg/t x TSP AP Table Wind erosion of (a) kg/ha/h * TSP exposed areas (0.5 from AP ) * TSP (0.075 from AP ) AP Table Unloading from coal stockpiles Trucks unloading coal kg/t * TSP AP Table kg/t * TSP AP Table /09/12 NA 1 Environment and Community Coordinator Page 31 of 38

32 EMP D Chain Valley Colliery PRP activity Units TSP Emission Factor PM 10 Emission Factor PM 2.5 Emission Factor Source Loading coal stockpiles kg/t AP (Note: AP Table has Train loading emission factor but footnote direct user to Chapter 13 for more accurate emissions factors.) Coal crushing kg/t No data AP Table Material transfer of coal (use for Loading coal to trucks) kg/t * TSP AP Table Screening kg/t No data AP Table Where: A = horizontal area (m 2 ) M = material moisture content (%) s = material silt content (or surface silt content in unpaved roads) (%) sl = road surface silt loading (g/m 2 ) u = wind speed (m/s) d = drop height (m) W = mean vehicle weight (tonnes) S = mean vehicle speed (km/h) 25/09/12 NA 1 Environment and Community Coordinator Page 32 of 38

33 EMP D Chain Valley Colliery Notes: (a) An alternative method for the estimation of wind erosion from exposed areas is contained within AP-42 Chapter The method takes into account site specific wind data, site-specific erodible material properties (threshold friction velocity, particle size distribution of the material eroded) and the frequency of material disturbance. Notwithstanding the data intensiveness of this approach, exercises in applying this method in to Hunter Valley mines to date (e.g. Integra Complex, Ravensworth Operations) has resulted in little or no wind initiated dust lift-off emissions being predicted from active mine sites. As such, the AP-42 Chapter approach has been adopted. This is considered both conservative and applicable to the estimation of wind erosion emissions over the longer term. 25/09/12 NA 1 Environment and Community Coordinator Page 33 of 38

34 EMP D Chain Valley Colliery APPENDIX B: MINE ACTIVITY DATA 25/09/12 NA 1 Environment and Community Coordinator Page 34 of 38

35 EMP D Chain Valley Colliery 1. COAL REMOVAL Activity Calculation Variable Variable description Value Units All truck loading and unloading operations (e.g. ROM coal > trucks, ROM coal > stockpile, ROM coal > hopper, etc.) Intensity Emission factor w Load,Coal Total weight loaded and unloaded 505,770 tonnes/year M Load,Coal Moisture content of coal 7.2 % Wheel generated particles on unpaved roads Intensity N Haul,Coal Number of trips 19,678 trips Emission factor L Haul,Coal Length of return trip 0.65 km W Haul,Coal Payload tonnes Unloaded vehicle weight 10 tonnes s Haul,Coal Silt content of haul road 10 % All material transfer operations Intensity (e.g. coal > ROM stockpile from conveyor, coal from ROM hopper to conveyor, unloading to trains from conveyor, etc.) Emission factor Screening Intensity Crushing Intensity w Trans,Coal Weight handled/transferred 674,360 tonnes/year N Trans,Coal Number of handling, transfer points 11 - Trans,Coal U Average wind speed 4.9 m/s M Trans,Coal Moisture content of coal 10 % w Screen,Coal Amount Coal screened tonnes/year Crush,Coal w Amount Coal Crushed tonnes/year Bulldozing on coal stockpiles Intensity Dozer,Coal N Number of dozers working on stockpiles 1 - T Dozer,Coal Time spent by each dozer on stockpiles 427 hours/year Emission factor s Dozer,Coal Silt content of coal 10 % M Dozer,Coal Moisture content of coal 7.2 % 25/09/12 NA 1 Environment and Community Coordinator Page 35 of 38