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Wambo Coal

Site Specific Particulate Matter Control

Best Practice Assessment

Report Number 610.11105.01000-R1

30 August 2012

Wambo Coal Pty Ltd

Jerry's Plain Road

Warkworth via Singleton NSW 2330

Version: Draft 2

Wambo Coal Pty Ltd Wambo Coal Site Specific Particulate Matter Control Best Practice Assessment

Report Number 610.11105.01000-R1 30 August 2012

Draft 2

SLR Consulting Australia Pty Ltd

Wambo Coal

Site Specific Particulate Matter Control

Best Practice Assessment

PREPARED BY:

SLR Consulting Australia Pty Ltd ABN 29 001 584 612

2 Lincoln Street Lane Cove NSW 2066 Australia

(PO Box 176 Lane Cove NSW 1595 Australia)

T: 61 2 9428 8100 F: 61 2 9427 8200

E: [email protected] www.slrconsulting.com

DOCUMENT CONTROL

Reference Status Date Prepared Checked Authorised

610.11105.01000 Draft 2 30-Aug-2012 Sandy Lonergan Martin Doyle

Gary Graham DRAFT

610.11105.01000 Draft 1 01-Jun-2012 Sandy Lonergan Martin Doyle

Gary Graham DRAFT



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EXECUTIVE SUMMARY


Background

Peabody Energy owns 75% and operates the Wambo Coal Colliery (WCPL), at Warkworth, near Singleton, New South Wales. WCPL is a combined open cut and underground mining operation in the Hunter Valley. It produces thermal coal for export and Pulverised Coal Injection coal for domestic customers.

The open-cut operations are been contracted out to Downer EDI mining, whilst the underground operation is operated by WCPL.

WCPL Open Cut Run of Mine coal produced was 4.015 million tonnes in the AEMR reporting period 2010/2011, while WCPL underground Run of Mine coal produced was 4.715 million tonnes. Following coal processing, the total WCPL coal product for the 2010/2011 AEMR reporting period was 5.68 million tonnes.

Current coal extraction operations at WCPL are in accordance with NSW Department of Planning and Infrastructure Consent Conditions under DA305-7-2003 and Environment Protection Licence number 529.

Pollution Reduction Program

In 2011, the NSW Environmental Protection Authority required, through a Pollution Reduction Program, that WCPL provide a report which examines in detail the potential measures which could be employed to further reduce particulate emissions from the mine. This is part of a larger program which aims to reduce particulate emissions from the coal mining industry as a whole in NSW.

Emissions were required to be quantified using United States Environmental Protection Agency approved emission factors without controls applied. Emission controls currently in place at WCPL were identified, and the control efficiency afforded by each applied measure, obtained through a literature review and site specific data were applied to these emissions.

Particulate emission sources were ranked according to the scale of emissions over a one year period with sources contributing to 95% of total site Total Suspended Particulate emissions identified and taken forward for further assessment. The assessment required that additional controls were investigated, and the feasibility of implementing each control option was assessed with consideration to implementation costs, regulatory requirements, environmental impacts, safety implications and compatibility with current processes and any proposed future developments.

Following this feasibility assessment, a timeframe for implementation of particulate management measures was required to be provided.

Findings

Particulate emission sources representing 95% of WCPL TSP emissions have been calculated to include haul roads, wind erosion from exposed areas and storage piles, the use of bulldozers on coal and the loading of trucks with coal and coarse reject material at the CHPP. Potential control measures for each of these sources have been investigated with regards to regulatory requirements, environmental impacts, safety implications and compatibility with current processes and any proposed future developments. Where these feasibility measures have been satisfied, the cost of implementation of each remaining measure has been calculated with those representing cost effective reductions taken forward for site trials.



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EXECUTIVE SUMMARY


Ongoing Actions and Implementation Timeframe

WCPL commit to the trial of the following dust suppression measures at the WCPL. Each trial will be complemented with a comprehensive field assessment to quantify particulate emissions from haul roads with and without the measure applied. A control efficiency will then be calculated which will assist in the confirmation of the assumptions used within this report.

Certain trials are currently being performed at the WCPL, including a trial of PetroTac (tar emulsion) which is planned to be extended.

Commitment 1 Polymer/tar and bitumen emulsions (PetroTac) will continue to be trialled on a 1 km stretch of the South Bates Haul Road over a period of 6 months. Following the trial, if measures are shown to provide reductions in particulate emissions at reasonable cost, widespread roll-out of measures will be implemented.

Commitment 2 Fencing and shelterbelts will be trialled on a 1 ha area of the RL160 dump over a period of 6 months. Following the trial, if the measure is shown to provide reductions in particulate emissions at reasonable cost, widespread roll-out of this measure will be implemented.

Commitment 3 Vegetative wind breaks and wind screens will be trialled on the ROM stockpile and on a 1 ha area of the product stockpile over a period of 6 months. Following the trial, if the measure is shown to provide reductions in particulate emissions at reasonable cost, widespread roll-out of this measure will be implemented.

Monitoring of Control Measures

The success of the trialled particulate reduction measures to be implemented at the WCPL will involve the monitoring of a range of parameters to ensure that each measure results in particulate reductions. A detailed monitoring plan will be designed for each trialled measure and may include (but not be limited to) the following monitoring methods:

The use of video cameras at the junction between treated and untreated haul roads to visually/subjectively identify the success of the measure in reducing haulage generated particulate matter emissions.

The sampling of the silt content of haul roads following the application of the PetroTac trial to allow the quantification of emission reductions (using emission estimation techniques).

The success of the installation of tree screens and shelterbelts will be measured through a site specific particulate monitoring program, with particulate measurements taken pre- and post- installation. In conjunction with meteorological data, this will allow the quantification of the success of the trial.



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TABLE OF CONTENTS


1 INTRODUCTION ............................................................................................................................ 9

1.1 Background .......................................................................................................................... 9

1.2 Guidance .............................................................................................................................. 9

1.3 Description of the Coal Mine ..............................................................................................11

1.3.1 Background to Wambo Coal Mine .........................................................................11

1.3.2 Mining and Coal Processing Operations ...............................................................11

1.4 Project Approval Conditions ...............................................................................................19

1.5 Environmental Licence Conditions.....................................................................................19

1.6 Environmental Performance ..............................................................................................20

2 IDENTIFICATION OF EXISTING CONTROL MEASURES & EMISSION ESTIMATION ...........22

2.1 Estimation of Baseline Particulate Emissions ....................................................................22

2.1.1 Activity Data ...........................................................................................................23

2.1.2 Uncontrolled Particulate Emissions .......................................................................26

2.2 Existing Control Measures .................................................................................................30

2.2.1 Behaviour and Operation Modification ..................................................................30

2.2.2 Rehabilitation .........................................................................................................31

2.2.3 Dust Suppression ..................................................................................................32

2.3 Ranking of Mining Activities and Identification of Top Four PM Sources ..........................42

3 POTENTIAL CONTROL MEASURES .........................................................................................43

3.1 Haul Roads ........................................................................................................................43

3.2 Wind Erosion ......................................................................................................................45

3.2.1 Exposed Areas and Overburden Emplacements ..................................................45

3.2.2 Coal Stockpiles ......................................................................................................46

3.3 Bulldozers on Coal .............................................................................................................48

3.4 Loading Coal and Reject Trucks ........................................................................................49

3.5 Quantification of Potential Particulate Management Measures .........................................49

4 EVALUATION OF ADDITIONAL CONTROL MEASURES ..........................................................69

4.1 Evaluation Findings – Haul Roads .....................................................................................70

4.1.1 Practicality of Implementation................................................................................70

4.1.2 Implementation Costs ............................................................................................72



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TABLE OF CONTENTS


4.2 Evaluation Findings – Wind Erosion of Overburden Dumps .............................................73



4.3 Evaluation Findings – Wind Erosion of Coal Stockpiles ....................................................75



4.4 Evaluation Findings – Bulldozer on Coal at CHPP ............................................................77



4.5 Evaluation Findings – Loading Coal to Trucks ..................................................................78



4.6 Evaluation Findings – Loading Coarse Rejects to Trucks .................................................79



4.7 Summary of Evaluation Findings .......................................................................................80

4.8 Cost Curves .......................................................................................................................84

4.9 Identification of Dust Control Measures for WCPL ............................................................86

4.9.1 Haul Roads ............................................................................................................87

4.9.2 Wind Erosion of the RL160 Overburden Dump .....................................................88

4.9.3 Wind Erosion of Coal Stockpiles ...........................................................................88

4.9.4 Monitoring of Control Measures ............................................................................89

5 IMPLEMENTATION TIMEFRAME ...............................................................................................90

6 REFERENCES .............................................................................................................................91

7 CLOSURE ....................................................................................................................................92

TABLES

Table 1 Production and Waste Summary, WCPL 2010.2011 12 Table 2 Details of Haul Roads 17 Table 3 Details of Conveyors 17 Table 4 Characteristics of Handled Materials and Haul Routes 18 Table 5 Material Handling Equipment, Tonnages Handled and Operational Hours 18 Table 6 Impact Assessment Criteria for Particulate Matter and Dust Deposition 19 Table 7 Particulate Emissions Sources and Relevant USEPA AP-42 Emission Factors 23 Table 8 Annual Activity Data for Material Handling Operations 24 Table 9 Annual Activity Data for Wind Erosion Sources 25 Table 10 Uncontrolled Annual Particulate Emissions – WCPL 27



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TABLE OF CONTENTS


Table 11 Annual Water Usage in Haul Road Dust Suppression (kL) 34 Table 12 Details of Haul Roads and Annual Water Usage in Haul Road Dust Suppression (kL) 34 Table 13 Water Application Intensity for Haul Routes 34 Table 14 Control Factors Assumed for Existing Control Measures 35 Table 15 Controlled Annual Particulate Emissions – WCPL 37 Table 16 Comparison of Uncontrolled and Controlled Particulate Emissions 40 Table 17 Controlled Particulate Matter Sources Representing 95% of Wambo Coal Mine TSP

Emissions 42 Table 18 Best Practice Control Measures - Haul Roads 45 Table 19 Best Practice Control Measures – Wind Erosion of Exposed Areas 46 Table 20 Best Practice Control Measures – Wind Erosion of Coal Stockpiles 48 Table 21 Best Practice Control Measures – Bulldozers 49 Table 22 Best Practice Control Measures – Loading Coal and Rejects to Trucks 49 Table 23 Control Factors Assumed for Potential Control Measures 50 Table 24 Locations of Estimated Emissions Tables - Controlled 51 Table 25 Estimated Emissions RL160 Dump Haul Road – Potential Controls 52 Table 26 Estimated Emissions Montrose Haul Road – Potential Controls 53 Table 27 Estimated Emissions South Bates Haul Road – Potential Controls 54 Table 28 Estimated Emissions Main Coal Haul Road, ROM to Open Cut Pit – Potential Controls55 Table 29 Estimated Emissions Main Coal Haul Road, ROM to Underground Stockpile – Potential

Controls 56 Table 30 Estimated Emissions Homestead Pit to ROM Haul Road – Potential Controls 57 Table 31 Estimated Emissions RL160 Dump – Wind Erosion – Potential Controls 58 Table 32 Estimated Emissions ROM Stockpile at CHPP – Wind Erosion – Potential Controls 59 Table 33 Estimated Emissions Product Coal Stockpile – Wind Erosion – Potential Controls 60 Table 34 Estimated Emissions Bulldozers at CHPP – Potential Controls 60 Table 35 Estimated Emissions Loading Coal to Trucks – Potential Controls 61 Table 36 Estimated Emissions Coarse Rejects to Trucks – Potential Controls 61 Table 37 Practicability of Implementing Control Measures on Haul Roads 70 Table 38 Practicability of Implementing Control Measures on Wind Eroded Areas – Overburden

Dumps 73 Table 39 Practicability of Implementing Control Measures on Wind Eroded Areas – Coal

Stockpiles 75 Table 40 Practicability of Implementing Control Measures for Bulldozers Operating on Coal 77 Table 41 Practicability of Implementing Control Measures on Dumping of ROM Coal to Trucks 78 Table 42 Practicability of Implementing Control Measures on Loading Coarse Rejects to Trucks79 Table 43 Summary of Control Options Evaluation 81 Table 44 Proposed PM2.5 / PM10 Particle Size Ratios 2

FIGURES

Figure 1 Current Mining Operations 14 Figure 2 Current Waste Emplacement Areas 16 Figure 3 High Volume Air Sampling (HVAS) Results for TSP – WCPL 2010/2011 20 Figure 4 Tapered Element Oscillating Microbalance (TEOM) Results for PM10 – WCPL

2010/2011 21 Figure 5 Dust Deposition Monitoring Results – WCPL 2010/2011 21 Figure 6 Uncontrolled Annual Particulate Emissions – WCPL 28 Figure 7 Watering Control Effectiveness for Unpaved Roads 33 Figure 8 Controlled Annual Particulate Emissions – Wambo Coal Mine 38 Figure 9 Comparison of Uncontrolled versus Controlled Particulate Emissions – Wambo Coal

Mine 39 Figure 10 Representation of Major Controlled Particulate Emission Sources -WCPL 41



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TABLE OF CONTENTS


Figure 11 Potential Reductions in PM Emissions due to Additional Controls Haulage on RL160 Dump Haul Road 62

Figure 12 Potential Reductions in PM Emissions due to Additional Controls Haulage on Montrose Haul Road 62

Figure 13 Potential Reductions in PM Emissions due to Additional Controls Haulage on South Bates Haul Road 63

Figure 14 Potential Reductions in PM Emissions due to Additional Controls Haulage on Main Coal Haul Road – ROM to Open Cut Pit 63

Figure 15 Potential Reductions in PM Emissions due to Additional Controls Haulage on South Bates Haul Road 64

Figure 16 Potential Reductions in PM Emissions due to Additional Controls Haulage on Main Coal Haul Road – ROM to Underground Stockpile 64

Figure 17 Potential Reductions in PM Emissions due to Additional Controls Haulage on Homestead Pit to ROM Haul Road 65

Figure 18 Potential Reductions in PM Emissions due to Additional Controls Wind Erosion from RL160 Dump 65

Figure 19 Potential Reductions in PM Emissions due to Additional Controls Wind Erosion from ROM Stockpile at CHPP 66

Figure 20 Potential Reductions in PM Emissions due to Additional Controls Wind Erosion from Product Coal Stockpile 66

Figure 21 Potential Reductions in PM Emissions due to Additional Controls Bulldozers on Coal at CHPP 67

Figure 22 Potential Reductions in PM Emissions due to Additional Controls Loading ROM Coal to Trucks 67

Figure 23 Potential Reductions in PM Emissions due to Additional Controls Loading Coarse Rejects to Trucks 68

Figure 24 PM10 Abatement Cost Curve 84

APPENDICES

Appendix A NSW EPA Coal Mine Particulate Matter Control Best Practice – Site Specific Determination Guideline

Appendix B USEPA AP-42 Emission Factors used in Calculation of Particulate Emissions Appendix C Assay Certificates for Material Composition Appendix D Standard Operating Procedures for Dust Management and Report Form Appendix E Detailed Cost/Benefit Tables for Selected Dust Management Measures



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1 INTRODUCTION

SLR Consulting Australia Pty Ltd (SLR Consulting) was commissioned by Wambo Coal Pty Ltd (WCPL, a subsidiary of Peabody Energy Australia Pty Ltd) to perform this assessment, which has included a site inspection, emissions estimation and the identification, quantification and justification of existing and proposed control measures for the site. The study was performed in accordance with the

Coal Mine Particulate Matter Control – Best Practice: Site Specific Determination Guideline1 issued by the New South Wales (NSW) Environmental Protection Authority (EPA) in November 2011.

The findings of this assessment are presented in the following report for submission to EPA.

1.1 Background

In 2010, the NSW EPA commissioned a detailed review of particulate matter (PM) emissions from coal mining activities in the Greater Metropolitan Region (GMR) of NSW. This review was completed in 2011 and issued as NSW (OEH) (2011) NSW Coal Mining Benchmarking Study: International Best Practice Measures to Prevent and/or minimise Emissions of Particulate Matter from Coal Mining (hereafter ‘the Katestone report’). One of the key recommendations of the study was that each mine should carry out a site-specific determination of best management practice. This recommendation has been adopted by the EPA through the implementation of the “Dust Stop” program.

The Dust Stop program aims to ensure that the most reasonable and practical particulate control options are implemented by each coal mine. Under this program, all coal mines in NSW are required to prepare a report that compares their current operation with international best practice. Mines are also required to report on the practicability of implementing each best practice measure and for any measures found to be practicable are required to provide a timetable for implementation. Once complete, copies of each report are required to be available on the mine’s website.

The Dust Stop program is being implemented through pollution-reduction programs (PRPs) as operating conditions under the Environmental Protection Licence (EPL). A PRP was issued to Wambo Coal in August 2011 requiring that a Site Specific Particulate Matter Control Best Practice Assessment be prepared for the site.

1.2 Guidance

EPA has provided guidance on the general structure and methodology of the assessment report. For clarification, the guidance provided has been reproduced in Appendix A.

Briefly, the process that is required is indicated below. For each required step in the procedure, reference has been provided to the relevant sections in this assessment report:

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

particle emissions Section 2

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

Section 3

3. Evaluate the practicability of implementing these best practice measures Section 4

4. Propose a timeframe for implementing all practicable best practice measures Section 5

Further to this provided guidance, EPA held a workshop for coal mining companies and their consultants on 8 May 2012. The outcome of this workshop was further clarified guidance relating to the requirements of EPA. These clarifications are summarised:

1 http://www.environment.nsw.gov.au/resources/air/20110813coalmineparticulate.pdf

http://www.environment.nsw.gov.au/resources/air/20110813coalmineparticulate.pdf



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The use of air quality monitoring data to identify that sites are complying with EPA ambient air quality criteria and therefore justify the need not to apply further controls is not acceptable. The aim of the PRP process is to reduce particulate emissions as a whole and is not primarily concerned with ambient concentrations.

More site specific data is required. For example, material (silt/moisture), meteorology, vehicles (weights, speeds) and activity data. Where such data is not available, the justification of what is used is required, with potentially a recommendation and commitment by the site to collect this data in the future.

Reports are required to be transparent and consistent with the mine AEMR.

Reports need to include further detail on the control effectiveness of measures applied to each source. Although the guideline document identifies that the Katestone report should be referred to, blindly following the Katestone report is not acceptable practice.

When control measures are recommended for implementation, some form of confirmation that controls are effective is required, or at least some indication of how the success of each measures implemetation will be measured. This might include KPI’s, methods of monitoring, the location, frequency and duration of monitoring, and procedures for management.

Economic review of each identified measure needs to consider depreciation (ATO rule TR2011/2012 for Coal Mining (Code 06000 and 10900). For off-highway trucks (including articulated, rigid dump, service, fuel and water trucks), the life of assets is classed as 10 years by the ATO.

The salvage value of, for example trucks also needs to be considered (end of mine life and replacements).

Implementation commitments will be written into Environmental Protection Licences in some form, but will be flexible if measures are not deemed to be viable at a later date.

Although the guidance document identifies that the top 4 emission sources should be assessed, some professional judgement is required. The top 4 should not be blindly assessed. For example, if the top 4 only contribute 50% to total site emissions then more sources should be included. The top 4 sources should cover about 95% of total site emissions.



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1.3 Description of the Coal Mine

1.3.1 Background to Wambo Coal Mine

Wambo Coal Pty Ltd (WCPL) is owned by Peabody Energy Australia Pty Limited (75%) and Sumiseki Materials Co, Ltd (25%). WCPL is an Open Cut and Underground mining operation located approximately 15 kilometres (km) west of Singleton near the locality of Warkworth. It is bounded by Wollombi Brook to the east, coal mining operations to the north, grazing land to the south and north-west and the Wollemi National Park to the west and south-west.

WCPL was granted development consent by Patrick Plains Shire Council in 1969 with Open Cut and Underground mining commencing shortly after. Subsequent development consents issued in 1972, 1974 and 1977 covered a range of early Open Cut and Underground operations. Singleton Shire Council (SSC) approved extensions to mining operations, construction activities and modifications to road haulage rates in the period between 1980 and 1991.

In July 1991, a Development Application (DA) was lodged with SSC seeking approval for the expansion of Open Cut and Underground mining activities and the consolidation of earlier development consents. Development consent was granted in February 1992.

The Homestead Underground Mine commenced in 1979 and operated until 1999. In 2003 the mine entries were sealed.

The Wollemi Underground Mine commenced production in 1997 and was placed under care and maintenance in October 2002 after the available longwall reserves were exhausted.

Open Cut operations were suspended between March 1999 and August 2001. Following the closure of the Wollemi Underground Mine, Open Cut operations were expanded to maintain an overall production rate of 3 million tonnes per annum (Mtpa) of product coal. Development of the North Wambo Underground Mine (the Underground) commenced in November 2005, with longwall operations commencing in October 2007.

Coal from the Open Cut and the Underground operations is washed at the Coal Handling and Preparation Plant (CHPP). Until June 2006 product coal was transported by highway rated trucks via the Golden Highway to the Mount Thorley Coal Loader for rail transport to the Port of Newcastle. The construction and commissioning of the WCPL Rail Development (WRD) in May 2006, which includes the rail line from Mount Thorley and WCPL rail spur and coal terminal, allows the direct rail transportation of all product coal from WCPL to the Port of Newcastle.

1.3.2 Mining and Coal Processing Operations

During the most recent Annual Environmental Management Report (AEMR) period of 2010/2011 (1 July 2010 to 30 June 2011), the quantities of coal production and waste generation were reported as presented in Table 1 (replicated from Table 2.1, AEMR, 2011 p21).



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Table 1 Production and Waste Summary, WCPL 2010.2011

Parameter Reporting Period 1 July 2010 to 30 June 2011

Topsoil stripped 194,750.5 m3

Topsoil Used/Spread 9,800 m3

Overburden Moved 27,583,359 bcm

Processing Waste 3.036 Mt

ROM Coal Mined 8.730 Mt

Open Cut 4.015 Mt

Underground 4.715 Mt

Product 5.680 Mt

Taken from Table 2.1, WCPL AEMR 2010/2011 p21

Coal Mining

Coal extracted from underground workings is conveyed to a stockpile with an approximate 70,000 tonne (t) capacity. When a sufficient stockpile is present, coal is loaded onto trucks and transported to the CHPP (AEMR, 2011 p22).

Downer EDI Mining are contracted to undertake open cut mining operations at WCPL. Open cut mining is divided into pits known as the Bates Pit, Bates South Pit, Montrose Pit and the Homestead Pit (refer Figure 1). Mining of the open cut areas commences with the removal of vegetation and topsoil.

Where possible, direct placement of topsoil onto re-profiled areas is preferred to stockpiling to avoid rehandling. However, during the reporting period 2010/2011 this was not possible. If topsoil stockpiles are to be left for more than three months, they are generally shaped into elongated mounds and seeded with pasture to keep the soil fertile, prevent weed growth and reduce soil loss (AEMR, 2011 p18).

Following land preparation, excavators and trucks remove any weathered material as a “free dig” operation. Material which can be removed in this way ranges from one metre to ten metres in thickness. Remaining overburden is drilled, blasted and removed using excavators and rear dump haul trucks to uncover coal.

Exposed coal is mined using excavators and loaded into haul trucks. Coal is mined without the need for blasting. The majority (approximately 80%) of ROM coal is delivered directly from the open cut operations to the ROM dump hopper using haul trucks with the balance (approximately 20%) temporarily stockpiled on the ROM coal stockpile pad.

Coal Processing and Load-Out

Coal from the underground and open cut operations is transferred to the CHPP via haul trucks on internal roads. Coal is tipped directly into the 400 t ROM bin or stockpiled adjacent to the ROM bin and subsequently loaded into the ROM crusher using a front-end-loader (FEL) as required.

Three stages are used to crush and screen the coal, with product coal being transferred to the clean coal stockpile. Underground reclaimers are used to transfer coal onto the load-out conveyor which transfers coal to the train load-out bin. Average coal recovery in the CHPP was 65% in the 2010/2011 AEMR reporting period (AEMR, 2011 p23).



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The WCPL train loading facility is designed to load trains at a rate of 4,500 tonnes per hour (tph). Appendix 1 of the AEMR (2011, Appendix 1 p19) indicates that a total of 6,038,011.82 tonnes of product coal was loaded to trains between 30 June 2010 and 29 June 2011. It is noted that the quantity of coal loaded to trains in the 2010/2011 reporting period was 388,011.8 t greater than the quantity of coal produced (refer Table 1). The capacity of the clean coal stockpile is 500,000 t which accounts for this discrepancy.



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Figure 1 Current Mining Operations

Source: AEMR 2010/2011, Figure 2.2 p24



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Waste Handling and Placement

Overburden Emplacement

Approximately 27,583,359 bank cubic metres (bcm) of overburden material were removed during the 2010/2011 AEMR reporting period (AEMR, 2011 Table 2.1 p21). During the reporting period, backfilling of the Wombat Pit (refer Figure 2) continued, reducing the need for out of pit dump space (AEMR, 2011 p23). A material density for overburden has been provided by WCPL as 2.36 t/bcm. For comparison, Coal & Allied (Hunter Valley Operations) reference an overburden density of 2.4 t/bcm, with USEPA AP-42 emission factor documentation (Chapter 11.9) stating an average overburden density of 2.09 t/bcm. A value of 2.36 t/bcm has been used in this assessment.

CHPP Reject Material

Rejects from the CHPP represent approximately 30-35% of processed ROM coal and are classified as either coarse or fine rejects. Coarse reject typically represent two-thirds of the material and are made up of <50mm fragments of carbonaceous shale, sandstone, mudstone and gravels. Coarse rejects are co-disposed of with overburden.

Fine rejects make up the remaining one-third and are a slurry material with a solids content of approximately 30% by weight. Tailings comprise <70 micrometer (µm) carbonaceous shale, sand and clay materials.

Several waste emplacement areas (tailings dams) have been approved, although many are now capped and/or rehabilitated. The Hunter Pit Tailing Dam (refer Figure 2) is the only current operational area for tailings.



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Figure 2 Current Waste Emplacement Areas

Source: AEMR 2010/2011, Figure 1.4 p12



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Material Movement

As previously outlined, material is moved around the Wambo Coal Mine by a combination of conveyor and haul truck on internal haul roads. All product coal is transported off site by trains.

Conveyors are located in the Homestead Pit to transport coal from the North Wambo Underground to the Underground ROM stockpile (70,000 t capacity) where coal is loaded onto trucks for transport to the CHPP. Coal extracted in the Montrose, Bates, Bates South and Homestead open cut is transported to the CHPP by haul trucks. Overburden generated in each of the open cut areas is transported to the RL160 Dump.

The length of each haul road is presented in Table 2 with information on the haul road width, annual use and mean vehicle weight.

Table 2 Details of Haul Roads

Haul Road Length (m)

Width (m)

Annual Trip Frequency

Mean Vehicle Weight (tonnes)

Main Coal Haul Road ROM to Open Cut 4,826 30 6,784 502

Main Coal Haul Road ROM to U/G Stockpile 2,531 35 17,074 249

RL160 Dump Road 3,570 40 20,332 502

Homestead Pit to ROM 1,918 30 9,990 324

South Bates Road 936 35 45,229 337

Montrose Road 1,937 35 33,479 337

Source: WCPL pers. comm. 2012

WCPL has provided details and number of conveyors on site. These are presented in Table 3.

Table 3 Details of Conveyors

Name Number Length (m)

Number of Transfer

Points

Quantity of Coal Conveyed (per year)

ROM Coal Conveyor 1 160 1 8.730 Mt

Coarse Reject Conveyor – Reject bin 1 60 0 2.017 Mt (35% of ROM^

and 66% of rejects≠)

Product Coal Conveyor 5 685 3 5.675 Mt (65% of ROM)^

Underground Inpit Conveyor 3 700 3 4.715 Mt

Overland Conveyor to Rail Load Out 2 980 2 6.038 Mt#

^ AEMR, 2011 p23

≠ AEMR, 2011 p26

# AEMR, 2011, Appendix 1 p19 – noted that coal loaded to trains in the 2010/2011 reporting period was 388,011.8 t greater

than the quantity of coal produced (refer Table 1). The capacity of the clean coal stockpile is 500,000 t which accounts for this discrepancy.

Material Placement

Coal

The majority of coal which is transported by haul truck to the CHPP is delivered directly to the ROM dump hopper with the balance temporarily stockpiled on the ROM coal stockpile pad (AEMR, 2011 p23). In the absence of further information and for the purposes of this assessment it has been assumed that 80% of coal transported to the CHPP is dumped directly into the ROM hopper, with 20% being stockpiled at the 200 m by 200 m (4 hectare [ha]) stockpile area which has a capacity of 250,000 tonnes (AEMR, 2011 p27).



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Overburden

Overburden transported to waste dumps is dumped by haul truck. Overburden is co-disposed with coarse reject material from the CHPP.

Material Characteristics

The characteristics of material handled on site are presented in Table 4. Assay certificates are presented in Appendix C.

WCPL engaged Steel River Testing to perform analysis of haul road soil samples at four locations:

CH1 Main Haul Road near CHPP;

CH2 Main Haul Road near Underground ROM;

CH3 RL160 Dump Haul Road; and,

CH4 Montrose Pit.

The results of this analysis are presented in Table 4, with assay certificates presented in Appendix C. Haul road moisture contents are not presented as these are variable given the use of water carts on site (refer Section 2.2). Moisture content is not required for the calculation of emissions from unpaved haul roads, although is required to calculate the efficiency of dust suppression measures. This is discussed further in Section 2.2.

Table 4 Characteristics of Handled Materials and Haul Routes

Material / Route

Silt Content

(%)

Moisture Content (%)

Validating Information Available?

Comments

Coal (ROM) 6 6.5 Assay certificates in Appendix C

Coal (Product) 1.1 6.5 Assay certificates in Appendix C

Overburden 7.1 3.3 Assay certificates in Appendix C

CH1 25.8 variable Assay certificates in Appendix C for silt content

CH2 42 variable Assay certificates in Appendix C for silt content



Excavator, Front End Loader and Bulldozer Operation

Excavators, front end loaders (FEL) and bulldozers are used at the Wambo coal mine to remove in-situ overburden, load haul trucks with coal and overburden, maintain stockpiles and shape overburden dumping areas. Information provided by WCPL has identified the list of equipment used on site as presented in Table 5.

Table 5 Material Handling Equipment, Tonnages Handled and Operational Hours

Equipment Number Quantity of Material Handled / Hours of Operation (per year)

Excavator 9 Coal 4,015,000 tonnes Overburden 65,096,727 tonnes

Bulldozers 10 Coal 4,848 hours (at CHPP) Overburden 210 hours (on waste dump)

Front End Loaders 6 Coal 4,715,000 tonnes Overburden 639,586 tonnes (on waste dump)



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Drilling and Blasting

The AEMR for the reporting period 2010/2011 identifies that a total of 318 boreholes were drilled for surface exploration purposes (AEMR, 2011 p18). Further to this, holes are drilled for the placement of blast charges and in the AEMR reporting period 2010/2011 totalled 34,219 for a total of 68 blasts (AEMR, 2011 p64).

Supplementary information provided by WCPL indicates that the typical area of each blast is 16,167 m

2 (1.6ha) with a typical depth of blast of 15.9 m. Moisture content of blasted material

(overburden only) is 3.3% (refer Table 4).

1.4 Project Approval Conditions

Project Approval Conditions for the WCPL under Section 75J of the Environmental and Planning Assessment Act 1979, dated 7 September 2010 include air quality criteria to ensure that the dust emissions generated by the Colliery do not cause additional exceedances of air quality criteria. These criteria are outlined in Table 6 and are not to be exceeded at any residence on privately owned land, or on more than 25% of any privately owned land.

Table 6 Impact Assessment Criteria for Particulate Matter and Dust Deposition

Pollutant Averaging Period Criterion

Total suspended particulate matter (TSP)

Annual 90 µg/m3

Particulate matter <10 µm (PM10)

Annual 30 µg/m3

24 hour 50 µg/m3

Maximum increase in deposited dust level

Maximum total deposited dust level

Deposited dust Annual 2 g/m2/month 4 g/m2/month

1.5 Environmental Licence Conditions

The EPA regulates the operations conducted at WCPL through an Environmental Protection Licence issued under the Protection of the Environment Operations Act 1997 (POEO Act). Environmental Protection Licence number 529 contains the following conditions in relation to dust (with the exception of the requirements in condition U1, which are considered within this report):

O3.1 The premises must be maintained in a condition which minimises or prevents the emission of dust from the premises.

O3.2 All trafficable areas, coal storage areas and vehicle manoeuvring areas in or on the premises must be maintained, at all times, in a condition that will minimise the generation, or emission from the premises, of wind-blown or traffic generated dust.

WCPL operates a complaints recording and management system as part of their over-arching management system and in accordance with Condition M4 of the EPL. In the last 12 months, WCPL has received two complaints relating to dust generation; both were made by DoPI officers.

EPA do not have any current Notices issued to WCPL.



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1.6 Environmental Performance

Considering the requirements of both the Project approval and EPL, WCPL operates an air quality monitoring program for TSP, PM10 and dust deposition.

WCPL currently performs TSP monitoring at four locations using High Volume Air Samplers (HVAS), PM10 is monitored using four real time TEOM units. Dust deposition monitoring is performed at a total of 16 locations surrounding the mine.

Monitoring results for TSP and PM10 are presented in Figure 3 and Figure 4 the period 15 October 2010 to 14 October 2011 and demonstrate that for both PM10 and TSP, compliance with the Project Approval Conditions is being achieved at the monitoring sites. Raw data can be seen in the AEMR (2011) in Appendix 2B.

Results of air quality monitoring are presented for contextual information only. It is acknowledged that evidence of compliance with Project Approval conditions is not adequate justification to not implement further dust controls on site.

Figure 3 High Volume Air Sampling (HVAS) Results for TSP – WCPL 2010/2011

High Volume Air Sampling

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Figure 4 Tapered Element Oscillating Microbalance (TEOM) Results for PM10 – WCPL 2010/2011

Monitoring results for dust deposition are presented in Figure 5 for the period 15 October 2010 to 14 October 2011. Dust deposition gauges D07 and D14 are located on WCPL owned land and therefore the dust deposition criteria do not apply. Site D07 is located near a regularly used internal unsealed road and site D14 is located directly west of the advancing open cut operations.

The results demonstrate that for dust deposition, compliance with the Project Approval Conditions is being achieved on privately owned land. Raw data can be seen in the AEMR (2011) in Appendix 2B.

Figure 5 Dust Deposition Monitoring Results – WCPL 2010/2011

Particulate Matter

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2 IDENTIFICATION OF EXISTING CONTROL MEASURES & EMISSION ESTIMATION

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

emissions

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

activity. This estimate must:

Utilise USEPA AP-42 emission estimation techniques (or other method as approved in

writing by the EPA),

Calculate uncontrolled emissions (with no particulate matter controls in place), and

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

Notes: These particulate matter controls must be clearly identified, quantified and justified

with supporting information. This means adding supporting information and evidence,

including monitoring data, record keeping, management plans and/or operator training.

1.2 Using the results of the controlled emission estimates generated from Step 1.1, rank the mining

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

year from highest to lowest.

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

TSP, PM10 and PM2.5.

2.1 Estimation of Baseline Particulate Emissions

In the estimation of baseline emissions of particulate matter, United States Environmental Protection Agency (USEPA) AP-42, Compilation of Air Pollutant Emission Factors estimation techniques have been utilised, as prescribed in the methodology presented in Appendix A and reproduced above.

AP-42 Chapter 11 (Mineral Products Industry) and AP-42 Chapter 13 (Miscellaneous Sources) have been referenced to estimate emissions from mining activities occurring at the WCPL.

Table 7 presents a summary of the AP-42 reference sections for the various emission factors used in this assessment report.



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Table 7 Particulate Emissions Sources and Relevant USEPA AP-42 Emission Factors

Emissions Source AP-42 Chapter Notes

Blasting Chapter 11.9 Western Surface Coal Mining (1998)

Drilling Chapter 11.9 Western Surface Coal Mining (1998)

Bulldozing coal Chapter 11.9 Western Surface Coal Mining (1998)

Front end loaders and excavators on coal

Chapter 11.9 Western Surface Coal Mining (1998)

Material transfer of coal by conveyor

Loading coal stockpiles Chapter 11.9 Western Surface Coal Mining (1998)

Wind erosion of coal stockpiles Chapter 11.9 Western Surface Coal Mining (1998)

Coal crushing Chapter 11.24 Metallic Minerals Processing (1982) Adopted in the NPI in absence of coal specific factors

Coal screening Chapter 11.24 Metallic Minerals Processing (1982)

Loading coal to trains Chapter 11.9 Western Surface Coal Mining (1998)

Loading coal to trucks Chapter 11.9 Western Surface Coal Mining (1998)

Bulldozing overburden Chapter 11.9 Western Surface Coal Mining (1998)

Front end loaders and excavators on overburden


Loading and dumping of overburden


Wind erosion of overburden Chapter 11.9 Western Surface Coal Mining (1998)

Wheel generated particulates on unpaved roads

Chapter 13.2.2 Unpaved Roads (2006)

Graders operating on unpaved roads / overburden


Appendix B outlines the emission factors used for each activity occurring at WCPL.

A discussion of the annual activity related to each action and the subsequent calculated emission rates of TSP, PM10 and PM2.5 are provided in Section 2.1.1. As required by the EPA, emissions are presented firstly as uncontrolled emissions, and secondly as emissions with controls currently employed in place.

2.1.1 Activity Data

Annual activity data for the activities presented in Table 7 are provided in Table 8 for material handling operations and in Table 9 for wind erosion sources. Information on haul roads has previously been provided in Table 2 and for conveyor systems in Table 3.



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Table 8 Annual Activity Data for Material Handling Operations

Operation / Activity Activity Rate (Annual)

Units Notes

COAL

UG Conveyor to ROM Transfer Pad 14,145,000 tonnes 3 Material transfer points (3 x 4,715,000 tonnes)

Loading Coal to UG Stockpile 4,715,000 tonnes

Loading Coal to Trucks 8,730,000 tonnes Loading trucks in pit

Dumping of ROM Coal at ROM Hopper (80%) 6,984,000 tonnes 80% of ROM Coal

Dumping of ROM Coal at ROM Stockpile (20%) 1,746,000 tonnes 20% of ROM Coal

Conveyor to CHPP 8,730,000 tonnes 100% of ROM Coal

Coal Crushing 8,730,000 tonnes as above

Coal Screening 8,730,000 tonnes as above

Coarse Rejects to Reject Bin (Conveyor) 2,017,000 tonnes 35% of ROM coal and 66% of total reject material

Coarse Rejects to Reject Bin 2,017,000 tonnes as above

Coarse Rejects to Trucks 2,017,000 tonnes as above

Product Coal to Product Stockpile Conveyor 5,675,000 tonnes 65% of ROM coal

Loading Product Coal Stockpile 5,675,000 tonnes as above

Bulldozers at CHPP 4,848 hours

Conveyor to Rail Load Out 6,038,000 tonnes 388,012 tonnes greater than ROM coal extracted. Stockpile capacity of 500,000 tonnes accounts for discrepancy

Loading Trains 6,038,000 as above

OVERBURDEN

Drilling 34,537 holes 34,219 for blast charge, 318 for surface exploration

Blasting 68 blasts Area of blast typically 16,167m2

Loading Overburden to Trucks 66,200,062 tonnes 27,583,359 bcm (density of 2.4 t/m3)

Trucks Dumping Overburden and Coarse Rejects 68,217,062 tonnes as above

Bulldozer on Overburden 210 hours



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Table 9 Annual Activity Data for Wind Erosion Sources

Open Area Total Area (ha)

Active Area (ha)

Emission Factor Applied to Active Area Notes

Highwall Clearance Area 55.7 55.7 Wind Erosion of Exposed Areas (AP-42 Chapter 11.9)

Mulch layer applied

Hunter Pit Tailings Dam 27.1 0.0 Wind Erosion of Exposed Areas (AP-42 Chapter 11.9)

Wet

North East Tailings Dam 24.1 12.0 Wind Erosion of Exposed Areas (AP-42 Chapter 11.9)

Assumed 50% wet

Sarah Marie Dump 42.1 42.1 Wind Erosion of Exposed Areas (AP-42 Chapter 11.9)

RL160 Dump 92.7 92.7 Wind Erosion of Exposed Areas (AP-42 Chapter 11.9)

Rug Dump 44.6 44.6 Wind Erosion of Exposed Areas (AP-42 Chapter 11.9)

Sarah’s Sister Dump 11.9 11.9 Wind Erosion of Exposed Areas (AP-42 Chapter 11.9)

Homestead Pit ROM Stockpile 1.3 1.3 Wind Erosion of Active Storage Pile (AP-42 Chapter 11.9)

ROM Stockpile at CHPP 4.0 4.0 Wind Erosion of Active Storage Pile (AP-42 Chapter 11.9)

Product Coal Stockpile 8.4 8.4 Wind Erosion of Active Storage Pile (AP-42 Chapter 11.9)



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2.1.2 Uncontrolled Particulate Emissions

Using the emission factors calculated in Appendix B and the annual activity data presented in Section 2.1.1, the annual (uncontrolled) particulate emissions from WCPL are presented in Table 10 and graphically in Figure 6.



Draft 2


Table 10 Uncontrolled Annual Particulate Emissions – WCPL

Emission Source TSP Emissions

(kg/year)

PM10 Emissions

(kg/year)

PM2.5 Emissions

(kg/year)

Cumulative % Contribution to Total TSP

Emissions

RL 160 Dump Haul Road 2,813,688 1,156,206 115,621 26.4

Montrose Haul Road 2,101,099 863,387 86,339 46.1

South Bates Haul Road 1,371,631 563,633 56,363 59.0

Main Coal Haul Road ROM to opencut pit 936,892 353,011 35,301 67.8

Main Coal Haul Road ROM t- U/G stockpile 745,093 265,824 26,582 74.8

Coal Screening 698,400 523,800 52,380 81.3

Loading Coal to Trucks 535,730 72,394 7,239 86.4

Homestead Pit - ROM Haul Road 371,923 132,689 13,269 89.9

Product Coal Stockpile - Wind Erosion 252,526 126,263 18,939 92.2

Coarse Rejects to Trucks 123,776 16,726 1,673 93.4

ROM Stockpile at CHPP - Wind Erosion 119,747 59,873 8,981 94.5

Bulldozers at CHPP 107,824 32,818 3,282 95.5

Coal Crushing 87,300 34,920 3,492 96.4

RL160 - Wind Erosion 78,787 39,393 5,909 97.1

Highwall Clearance Area - Wind Erosion 47,235 23,617 2,362 97.5

Homestead Pit ROM Stockpile - Wind Erosion 38,947 19,473 2,921 97.9

Rug Dump - Wind Erosion 37,927 18,964 2,845 98.3

Sarah Marie Dump - Wind Erosion 35,828 17,914 2,687 98.6

Trucks Dumping Overburden and Coarse Rejects 33,113 15,662 2,372 98.9

Loading Overburden to Trucks 32,134 15,198 2,301 99.2

Blasting 30,752 15,991 1,599 99.5

Drilling 20,377 10,188 1,019 99.7

North East Tailings Dam - Wind Erosion 10,221 5,111 511 99.8

Sarah's sister dump - Wind Erosion 10,098 5,049 757 99.9

UG Conveyor to ROM Transfer Pad 2,658 1,257 126 99.9

Conveyor to CHPP 1,640 776 78 99.9

Dumping of ROM Coal at ROM Hopper (80%) 1,312 621 94 99.9

Bulldozer on Overburden 1,215 252 25 99.9

Conveyor to Rail Load Out 1,135 537 54 100.0

Loading Trains 1,135 537 81 100.0

Product Coal to Product Stockpile Conveyor 1,066 504 50 100.0

Loading Product Coal Stockpile 1,066 504 76 100.0

Loading Coal to UG Stockpile 886 419 63 100.0

Coarse Rejects to Reject Bin (Conveyor) 379 179 18 100.0

Coarse Rejects to Reject Bin 379 179 27 100.0

Dumping of ROM Coal at ROM Stockpile (20%) 328 155 23 100.0

Hunter Pit Tailings Dam - Wind Erosion 0 0 0 100.0

TOTAL 10,654,246 4,394,025 455,460 -



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Figure 6 Uncontrolled Annual Particulate Emissions – WCPL



Draft 2




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2.2 Existing Control Measures

WCPL operate an Air Quality Management Plan with the measures identified in the following sections being implemented as part of that plan (refer Section 3.2.1, AEMR, 2011) p40). Where relevant, emission control factors for each dust suppression activity are provided. Control factors are sourced from a number of publications including:

Katestone Environmental 2010, “NSW Coal Mining Benchmarking Study: International Best Practice Measures to Prevent and/or Minimise Emissions of Particulate Matter from Coal Mining”, December 2010.

Australian Government Department of Sustainability, Environment, Water, Population and Communities 2012, “National Pollutant Inventory Emission Estimation Technique for Mining”, Version 3.1, January 2012.

Countess Environmental 2006, “WRAP Fugitive Dust Handbook”, September, 2006.

US Department of Health and Human Services 2012, “Dust Control Handbook for Industrial Minerals Mining and Processing”, January 2012.

It is acknowledged that emission control factors can be highly variable, and are generally based on site and material specific field trials. Where possible, the entire range of control factors for each relevant activity from the references above are presented with the most appropriate factor, taking into consideration the source of the data, being taken forward for application within this report.

Where a considerable level of uncertainty exists, or where the emission source has the potential to contribute a significant percentage to the site dust balance, further work is proposed.

2.2.1 Behaviour and Operation Modification

Induction training to all employees highlighting their responsibility to limit the level of dust produced.

Modifying mining operations during unfavourable weather conditions to reduce dust generation

There are no definitive rules governing the meteorological conditions under which mining operations are modified at WCPL. Rather, WCPL operates four dust monitoring stations (refer Section 1.6) that provide real time information to Downer EDI Mining operational personnel. This is achieved by an automatically produced SMS alert being sent from dust monitors to the Open Cut Examiner (OCE) in the event that high dust levels are detected.

Dust alarms are triggered when the 15 minute PM10 results are above 90µg/m3 for two consecutive 15

minute periods. If the 15 minute results come below 75µg/m3 and then go above 90µg/m

3 again it is

considered to be a new dust alarm. The alarms filter out wind conditions so alarms are only received when the wind is blowing from the direction of Wambo’s operations.

In the event that an SMS Alert for high dust level is received by the OCE or excessive dust is noted on site but an SMS Dust Alert has not been received the following steps are required to be taken be taken:

Identify the major sources of dust

Apply appropriate actions listed in ‘Dust Reduction Methods’:

Assign water cart to high priority areas

Reduce speed of trucks

Utilise lower RL dumps

Stop operations in high exposure areas i.e. topsoil loading and dumping, rehab areas



Draft 2


Minimise areas of operation (shut down a circuit/s)

Stop all operations

Record information in 4842-SE-F1027 Dust Management Response located in the OCE office.

This SWP and Dust Management Record form are included as Appendix D.

Given that no particular wind conditions are identified as being triggers for modification of activities, particulate control efficiencies cannot be calculated.

WCPL will review Dust Management Record forms and perform an analysis to identify if particular meteorological conditions result in dust alarms. Where conditions are identified as being likely to cause dust alarms, WCPL will provide the OCE with warnings when such meteorological conditions are anticipated.

Constraints on blasting operations to reduce impact of immediate neighbours (e.g. re-scheduling blasts when wind blowing towards immediate neighbours).

Implementing speed limits on roadways.

Haul road speeds are limited to 60 km/hr at WCPL. The USDHHS (2012) provide information that reducing vehicle speeds can reduce the potential generation of PM10 particles by approximately:

58% when speeds reduce from 40 km/hr to 16 km/hr.

42% when speeds reduce from 40 km/hr to 24 km/hr.

44% when speed limited to 40 km/hr.

Katestone Environmental (2010) reference the following effectiveness for vehicle speed restrictions on unpaved roads:

40% to 75% when speeds reduce from 75 km/hr to 50 km/hr

50% to 85% when speeds reduce from 65 km/hr to 30 km/hr

2.2.2 Rehabilitation

Rehabilitation of disturbed land on a progressive basis to reduce total disturbed area

In the AEMR reporting period (2010/2011), a total of 14.2 ha of land was rehabilitated (AEMR, 2011 p82).

Published particulate emission control factors following the rehabilitation of land are presented in DSEWPC (2012) as:

30% for primary rehabilitation.

40% for vegetation established but not demonstrated to be self-sustaining.

60% for secondary rehabilitation.

99% for revegetation.

100% for fully rehabilitated (release) vegetation.

Countess Environmental (1996) identify particulate control efficiencies for agricultural land (taken to be overburden type) as:

90% for cover crops.



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Rehabilitation monitoring is performed using the Ecosystem Function Analysis (EFA) tool. The data derived from the monitoring program provides a robust platform against which the effectiveness of rehabilitation techniques can be assessed and where required, amended. The purpose of the assessment is to determine whether rehabilitated areas are on a trajectory toward self sustainability and functionality (AEMR, 2011 p86). A summary of the EFA results can be found in the AEMR, p86.

Keeping disturbance areas to a minimum by minimising the disturbance in advance of mining operations until mining is due to commence in the area and clearly defining roads.

Revegetating topsoil stockpiles which are not planned to be used for over three months.

2.2.3 Dust Suppression

Dust suppression equipment is fitted and operated on drills

Dust skirts are used on drills with water injection use to minimise dust emissions. According to WCPL, 80% of holes are drilled in pit.

Particulate control efficiencies for the use of water when drilling and are dependent on the water flow, although Katestone Environmental (2010) quote control efficiencies of between 3.1% and 96.3% which is supported by the USDHHS (2012) which quotes wet drilling as achieving up to 96% dust control efficiency. DSEWPC (2012) quote a control efficiency of 70% when using water sprays during drilling operations.

The installation of a dust skirt on drill rigs is predicted to afford a 63% to 88% reduction in respirable particulate matter emissions from drill rigs (Katestone Environmental, 2010).

Performing drilling in pit will result in a reduction in particulate emissions due to shielding from the ambient wind. DSEWPC (2012) quote control efficiency for operations occurring in pit of 50% for TSP and 5% for PM10 emissions.

Designing blast holes with stemming to provide optimum confinement of the blast charge

Particulate emission control effectiveness due to appropriate stemming of blast holes is not quantified although is identified in all references as representing best practice.

Regular servicing of water carts for effective road watering and continual operation

Use of additional contractor water trucks to water frequently used roads around the CHPP as required

Operation of two water truck fill points during the reporting period to reduce the time between road watering

The use of water trucks on unpaved haul roads is discussed widely in the literature, due to its widespread use as a primary control of dust emissions at mine sites. Detailed discussion of wet suppression of unpaved roads is provided in Countess Environmental (2006). Particulate control efficiency is heavily dependent upon the time taken for the road to dry following water application. In turn, this is dependent upon:

The quantity of water (per unit road surface area) added during each application.

The period of time between applications.

The weight, speed and number of vehicles travelling over the watered road during the period between applications.

Meteorological conditions (temperature, wind speed, cloud cover etc.) that affect evaporation during the period.



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Figure 7 presents a simple relationship between haul road moisture content and instantaneous particulate control efficiency (Countess Environmental, 2006). The moisture ratio (M) is derived by dividing the surface moisture content of the watered road by the surface moisture content of the unwatered road. As the road surface dries, M is reduced and thus the particulate control efficiency is also reduced.

Figure 7 Watering Control Effectiveness for Unpaved Roads

DSEWPC (2012) provides generic particulate control efficiencies associated with haul road watering:

50% for Level 1 watering (2L/m2/hr).

75% for Level 2 watering (>2L/m2/hr).

Particulate control efficiencies are quoted in USDHHS (2012) for a range of trials as:

95% control for TSP for an application rate of 0.41 L/m2 for half an hour after watering.

74% control for TSP for an application rate of 1.5 L/m2 for 3 to 4 hours after watering.

However, as noted in US DHHS (2012), the control efficiency is highly variable and strongly related to road material type, traffic and weather conditions.

An empirical model for the calculation of the control efficiency of haul road watering has been developed by USEPA (1987) and uses the formula:

(

)

Where:

= potential average hourly daytime evaporation rate (mm/hr) = average hourly daytime traffic rate (veh/hr) = time between applications (hr) = application intensity (L/m

2)

For operations at the Wambo Coal Mine, four water trucks are in use, two with a capacity of 50,000 L and two with a capacity of 70,000 L. Information on the annual water use on all haul roads has been provided by WCPL and is provided in Table 11. More detailed information on water use on each haul road is provided in Table 12.



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Table 11 Annual Water Usage in Haul Road Dust Suppression (kL)

Water Use in Haul Road Dust Suppression Water Application (kL)

per hour 240

per day (summer) 3,360 (14 hours of application per day)

per day (winter) 2,160 (9 hours of application per day)

per year 1,004,640

To determine the control efficiency of this watering regime, an annual average evaporation rate of 0.3 mm/hr has been calculated using evaporation data contained within the AEMR (2011) for the period July 2010 to June 2011 (AEMR, 2011 Appendix 2A). The average daily traffic rate has been calculated from Table 2. The annual water use on each road has been provided by WCPL as presented in Table 12.

Table 12 Details of Haul Roads and Annual Water Usage in Haul Road Dust Suppression (kL)

Haul Road Length (m)

Width (m)

Calculated Daily Average

Trip Frequency

#

Annual Water Usage (kL)

Main Coal Haul Road ROM to Open Cut 4,826 30 282.7 119,656.58

Main Coal Haul Road ROM to U/G Stockpile 2,531 35 711.4 157,939.17

RL160 Dump Road 3,570 40 847.2 265,285.47

Homestead Pit to ROM 1,918 30 416.3 70,029.55

South Bates Road 936 35 1884.5 154,722.05

Montrose Road 1,937 35 1395.0 237,007.18

Total Water Usage 1,004,640

#Calculated from data in Table 2 divided by 24 hours

The application intensity (L/m2/hr) for each route has been calculated based on annual water usage

divided by the area of road surface. Application of water to 100% of the road area is not required, and the trafficked portion of the road has been assumed to be 40% of the total width. Application intensities for each route are presented in Table 13, assuming an annual average hours of watering of 11.5 hours per day (refer Table 11). The time between applications has been assumed to be 0.5 hours.

Table 13 Water Application Intensity for Haul Routes

Haul Road Area (m

2)

Annual Water

Usage (kL)

Water Application

Intensity (L/m

2/hr)

Calculated Control

Efficiency (%)

Main Coal Haul Road ROM to Open Cut 57,912 119,656.58 0.5 31.1

Main Coal Haul Road ROM to U/G Stockpile 35,434 157,939.17 1.1 19.6

RL160 Dump Road 57,120 265,285.47 1.1 8.1

Homestead Pit to ROM 23,016 70,029.55 0.7 31.1

South Bates Road 13,104 154,722.05 2.8 19.6

Montrose Road 27,118 237,007.18 2.1 19.6

Note: evaporation rate taken to be 0.3 mm/hr, time between applications taken to be 0.5 hours

The Downder EDI Standard Operation Procedure (SOP) for haul road watering is included as Appendix D to this report.



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Operation of water sprays during raw coal unloading at the ROM dump hopper.

Watering is the principal means of dust suppression at Wambo Coal Mine. Various emission control factors are quoted in literature, and include:

70% for water sprays during truck dumping operations (DSEWPC, 2012).

62% for continuous water spray at transfer point (Countess Environmental, 2006).

50% for water sprays on ROM bin (Katestone Environmental, 2010).

The particulate control efficiency of 62% taken from Countess Environmental (2006) uses the USEPA AP42 emission factor for batch loading and calculates the reduction in emissions due to an increase in the moisture content of the loaded material following water spraying. No information is available as to the change in moisture content of coal during dumping into the ROM hopper. However, for the purposes of this assessment, it is estimated that moisture content is increased by 2% during hopper loading (from 6.5% to 8.5%) following water spraying.

Inclusion of this moisture content increase results in a particulate control efficiency (using site specific wind speed measurements) of 45%.

To validate this assumption, WCPL will perform an assessment of coal moisture content prior to, during and following ROM dump hopper loading.

Cleaning up coal spillage around the CHPP to prevent dust.

Fitting dust suppression systems at transfer points where necessary.

As part of this assessment, a site audit was conducted in January 2012 to identify and verify the current dust control measures being implemented at WCPL. A summary of the existing control measures identified as currently being implemented at the WCPL is provided in Table 14.

Table 14 Control Factors Assumed for Existing Control Measures

Dust Mitigation Measure Applied Control Factor Additional Information

Induction Training NA No quantification can be made

Modification of operations (including blasting) in unfavourable weather conditions

NA No quantification can be made

Speed limits 40% Taken to be the lower quoted efficiency from Katestone Environmental (2010) for a reduction in speed from 75 km/hr to 50 km/hr

Rehabilitation of disturbed land 60% Taken to be for secondary revegetation

Minimising disturbed areas NA No quantification can be made

Revegetating topsoil stockpiles 30% Taken to be for primary revegetation

Dust suppression equipment on drills

96% From USDHHS (2012) for wet drilling. Assumed maximum quoted control efficiency due to additional use of dust skirts.

Blast hole stemming NA No quantification can be made

Haul Road Watering Between 8% and 31% Refer Table 13

Servicing of water carts NA No quantification can be made

Use of additional water trucks as NA No quantification can be made



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Dust Mitigation Measure Applied Control Factor Additional Information

required around CHPP

Operation of two water truck fill points

NA No quantification can be made

Water sprays on ROM dump hopper

45% Assuming a 2% increase in moisture content during spraying

Cleaning up coal spillage at CHPP NA No quantification can be made

Dust suppression systems at transfer points

NA No information available as

In addition to the dust management measures identified above, a progressive rehabilitation program is also undertaken at the WCPL (refer Section 5 of the AEMR, 2011 p82). Short term and long term measures are outlined with objectives in relation to air quality concerned with the minimisation of wind induced erosion.

Presented in Table 15 are the calculated particulate emissions from WCPL with current emission controls applied. These are also presented graphically in Figure 8. A comparison of the total emissions by source (controlled and uncontrolled) are presented in Figure 9.



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Table 15 Controlled Annual Particulate Emissions – WCPL


(kg/year)

PM10 Emissions

(kg/year)

PM2.5 Emissions

(kg/year)


Emissions

RL 160 Dump Haul Road 1,551,171 637,410 63,741 29.1


South Bates Haul Road 661,619 271,874 27,187 60.5



Main Coal Haul Road ROM t- U/G stockpile 359,400 128,222 12,822 84.6



Coarse Rejects to Trucks 61,888 8,363 836 91.0

RL160 - Wind Erosion 78,787 39,393 5,909 92.5



Highwall Clearance Area - Wind Erosion 47,235 23,617 2,362 95.6

Homestead Pit ROM Stockpile - Wind Erosion 38,947 19,473 2,921 96.3

Rug Dump - Wind Erosion 37,927 18,964 2,845 97.1

Sarah Marie Dump - Wind Erosion 35,828 17,914 2,687 97.7

Loading Overburden to Trucks 32,134 15,198 2,301 98.3

Blasting 30,752 15,991 1,599 98.9

Trucks Dumping Overburden and Coarse Rejects 29,802 14,095 2,134 99.5

North East Tailings Dam - Wind Erosion 10,221 5,111 511 99.7

Sarah's sister dump - Wind Erosion 10,098 5,049 757 99.8

UG Conveyor to ROM Transfer Pad 2,658 1,257 126 99.9

Bulldozer on Overburden 1,215 252 25 99.9

Loading Coal to UG Stockpile 886 419 63 99.9

Dumping of ROM Coal at ROM Hopper (80%) 722 341 52 99.9

Loading Product Coal Stockpile 587 277 42 100.0

Conveyor to CHPP 492 233 23 100.0

Drilling 489 391 39 100.0

Conveyor to Rail Load Out 340 161 16 100.0

Loading Trains 340 161 24 100.0

Product Coal to Product Stockpile Conveyor 160 76 8 100.0

Dumping of ROM Coal at ROM Stockpile (20%) 180 85 13 100.0

Coarse Rejects to Reject Bin (Conveyor) 114 54 5 100.0

Coarse Rejects to Reject Bin 57 27 4 100.0

Coal Crushing 0 0 0 100.0

Coal Screening 0 0 0 100.0

Hunter Pit Tailings Dam - Wind Erosion 0 0 0 100.0

TOTAL 5,329,957 2,025,245 213,792 -



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Figure 8 Controlled Annual Particulate Emissions – Wambo Coal Mine



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Figure 9 Comparison of Uncontrolled versus Controlled Particulate Emissions – Wambo Coal Mine



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Particulate emissions are presented by source group (wind erosion, haul roads, material handling and extraction and CHPP and coal loading operations at the CHPP and product stockpile areas) in Table 16.

Table 16 Comparison of Uncontrolled and Controlled Particulate Emissions

Emission Source Group Uncontrolled Emissions (kg/annum) Controlled Emissions (kg/annum)

TSP PM10 PM2.5 TSP PM10 PM2.5

Wind Erosion 631,315 315,657 45,912 445,178 222,589 31,952

Haul Roads 8,340,325 3,334,750 333,475 4,126,929 1,654,830 165,483

Material Handling and Extraction 656,865 131,361 14,745 633,666 119,998 13,528

CHPP and Coal Load Out 1,025,741 612,256 61,328 124,184 27,828 2,829

TOTAL 10,654,246 4,394,025 455,460 5,329,957 2,025,245 213,792



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Figure 10 Representation of Major Controlled Particulate Emission Sources -WCPL



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2.3 Ranking of Mining Activities and Identification of Top Four PM Sources

NSW EPA requirements for the assessment of particulate control measures are provided in Appendix A. This advice requires the top four controlled particulate emissions sources are assessed for the feasibility of further control measures being applied.

However, further advice from the EPA has indicated that these top four sources should represent a significant proportion of mine emissions. Within this report, the assessment of further control measures has been applied to all sources which cumulatively represent 95% of total site emissions (of TSP). These sources, and the corresponding emission totals, are presented in Table 17. Those data cover the broad emission sources of haul roads, wind erosion from exposed areas and storage piles, the use of bulldozers on coal and the loading of trucks with coal and coarse reject material at the CHPP.

Potential control measures to be applied to these sources are discussed in detail in Section 3.

Table 17 Controlled Particulate Matter Sources Representing 95% of Wambo Coal Mine TSP Emissions


(kg/year)

PM10 Emissions

(kg/year)

PM2.5 Emissions

(kg/year)


Emissions

RL 160 Dump Haul Road 1,551,171 637,410 63,741 29.1


South Bates Haul Road 661,619 271,874 27,187 60.5



Main Coal Haul Road ROM to U/G stockpile 359,400 128,222 12,822 84.6



Coarse Rejects to Trucks 61,888 8,363 836 91.0

RL160 - Wind Erosion 78,787 39,393 5,909 92.5





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3 POTENTIAL CONTROL MEASURES

2. Identify, quantify and justify best practice measures that could be used to minimise particle

emissions

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

implemented to reduce emissions, taking into consideration:

The findings of Katestone (June 2011) “NSW coal mining benchmarking study –

international best practice measures to prevent and/or minimise emissions of particulate

matter from coal mining”,

Any other relevant published information, and

Any relevant industry experience from either Australia or overseas.

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

and PM2.5 from each mining activity after applying the measures identified in step 2.1.

Current particulate matter controls being used at the mine must be clearly identified, quantified and

justified. This means adding supporting information and evidence, including monitoring data,

recorded keeping, management plans and/or operator training.

The emission reductions quoted within this Section are generic published control factors which do not take into account the specific nature of operations at Wambo Coal Mine. In the absence of costly site specific trials for each control measure being available, these generic factors are used to guide the selection of control measures which may be broadly appropriate for further investigation or application at the site.

Following an assessment of the feasibility of each measure (refer Section 4) some control measures are taken forward for an assessment of costs and benefits. Where a measure is identified as potentially providing particulate emissions reductions for a source at an acceptable cost, the implementation of the measure is committed to by WCPL, following site specific trials of the measure. These trials are essential and are proposed to:

1 Confirm current particulate emissions from the source in question.

2 Confirm the potential particulate emissions reductions following control measure implementation.

It is not considered to be appropriate to commit to widespread implementation of potentially costly and ineffective particulate control measures on the basis of non-site specific data.

Trials of each control measure will be implemented within 6 months of report submission, and a reassessment of the likely emission reductions afforded by each measure will be performed. Such reassessment will include field trials and comprehensive data collection and analysis.

Where measures are still identified as providing significant emission reductions at acceptable cost following these field trials, these will be implemented on a wider scale.

3.1 Haul Roads

Options for the control of dust emissions from unpaved haul roads fall into the following three categories:

Vehicle restrictions that limit the speed, weight or number of vehicles on the road.

Surface improvement by measures such as (a) paving or (b) adding gravel or slag to a dirt road.

Surface treatment such as watering or treatment with chemical dust suppressants.



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The applicability of the above control methods varies significantly due to the costs of installing and operating the various options, the timing of the implementation of the controls (for example at planning stage or applied retrospectively when the mine is operating) and the scale of the mining operation.

For example, vehicle restrictions that are considered at the mine planning phase might be relatively easy to apply, such as the replacement of a large number of small haul trucks with a smaller fleet of larger trucks, or other considerations such as upward facing vehicle exhausts. However, implementation of these control options retrospectively during mine operation would represent a significant capital expenditure. Vehicle speed restrictions may offer an effective control, but may pose a logistical or economic constraint if it restricts the transport of materials in the mine and may be difficult to manage and enforce.

Clearly, replacement of haul trucks with automated material handling systems, such as conveyors may offer a significant opportunity to reduce particulate emissions, if feasible.

The improvement of the road structure using non-sealed surfaces (such as gravelled surfaces) or substrata design (such as design to limit water penetration and pooling, and reduced surface wear through design of cambers and corners) are easier to implement during the planning phases rather than retrofitted improvements as they may require site planning considerations including the location / configuration of plant and processes to be altered. The use of non-sealed surfaces may require significant maintenance, particularly during adverse weather conditions or heavily trafficked periods. Surface improvements may not be cost-effective with heavy haul vehicles that require high-grade engineered road structures to carry the load without disintegration of the road structure.

Surface watering is a commonly applied control option, however the availability of water supplies may represent a significant constraint to its effective use, particularly during peak water demand periods such as during periods of high winds and/or prolonged dry episodes. The use of chemical suppressants or surface binding agents may offer enhanced dust control and may additionally reduce the volume, rate and/or frequency of water applications for dust suppression. In some instances, watering after the application of chemical suppressants may reduce the efficacy of the overall dust control offered by the chemical suppressants or water if applied independently of each other. Generally, chemical additives and suppressants offer improved dust control efficiency than water, but this generalisation may not be true in all situations, for example along temporary roads.

A summary of the potential control measures for minimising particulate emissions from haul roads and the corresponding estimate of their effectiveness is provided in Table 18 (Katestone, 2010).



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Table 18 Best Practice Control Measures - Haul Roads

Control Type Control Measure Effectiveness

Vehicle Restrictions Reduction from 75 km/hr to 50 km/hr 40-75

Reduction from 65 km/hr to 30 km/hr 50-85

Surface Improvements Pave the surface >90%

Low silt aggregate 30%

Oil and double chip surface 80%

Surface Treatments Watering (standard procedure) 10-74%

Watering Level 2 (>2 l/m²/hr) 75%

Watering twice a day for industrial unpaved road 55%

Hygroscopic salts1 Av. 45% over 14 days

82% within 2 weeks

Lignosulphonates 66-70% over 23 days

Polymer emulsions 70% over 58 days

Tar and bitumen emulsions 70% over 20 days

Other Use larger vehicles rather than smaller vehicles to minimise number of trips

90t to 220t: 40% 2

140t to 220t: 20%2

140t to 360t: 45% 2

Use conveyors in place of haul roads >95%

Note: 1 Use of hygroscopic salts can also act to extend the required time between watering by 33% to 50% (USDHHS, 2012)

2 Reductions achieved by the use of larger vehicles, conveyors and lower grader speeds have been calculated from the emission factors for these activities

SOURCE: Katestone (2010), Table 66

3.2 Wind Erosion

3.2.1 Exposed Areas and Overburden Emplacements

To control the generation and/or propagation of particulate emissions due to wind erosion, the following techniques have been identified, including those proposed as options in the Katestone report:

Minimise pre-strip areas as far as practicable.

Minimise out-of-pit dumping and maximise in-pit dumping to ensure that overburden dumps have shielding from the prevailing wind and the pit offers as much retention of liberated dust as possible.

Sealing of exposed surfaces through paving.

Providing upgraded non-sealed surfaces (e.g. gravel) to reduce surface fines content and to reduce the surface wind speed.

Fencing, bunding or shelterbelts to reduce near-surface wind speed and the resultant wind-shear velocity across open areas and/or overburden storage piles.

The temporary revegetation of exposed areas to minimise emissions of particulate matter from areas that may be exposed for an extended period of time.

Rehabilitation of land after use by revegetation and land contouring to produce the final post-mining land form.

Improved housekeeping, including the rapid and effective clean-up of material spillages.



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Surface watering to reduce weathering through increased soil particle cohesion, and the suppression of dust emissions.

The addition of chemical suppressants to minimise surface dust emission (‘lift-off’).

A summary of the potential control measures for minimising particulate emissions from wind erosion in exposed areas, and their effectiveness, is provided in Table 19, reproduced from Katestone (2011).

Table 19 Best Practice Control Measures – Wind Erosion of Exposed Areas

Control Type Control Measure Effectiveness1

Avoidance Minimise pre-strip. EMP should specify a benchmark for optimal performance and report annually against benchmark

100% per m2 of pre-strip avoided

Surface stabilisation Watering 50%

Chemical suppressants 70%

84%

Paving and cleaning >95%

Apply gravel to stabilise disturbed open areas 84%

Rehabilitation. EMP should specify a rehabilitation goal and report annually against progress to meeting goal.

99%

Wind speed reduction Fencing, bunding, shelterbelts or in-pit dump. Height should be greater than the height of the erodible surface

30%

70-80%

Vegetative ground cover 70%

Note 1 In some instances, the respective control has varying control efficiencies that are referenced through independent studies, and the table represents a simplified summary of those studies.


3.2.2 Coal Stockpiles

Stockpiles of coal provide a source (often elevated) for the potential generation of wind-eroded material and the subsequent propagation of emissions. In addition to stockpile dimensions, emissions generated by wind erosion from stockpiles are also dependent on the frequency of disturbance of the exposed surface. Over time the surface of an undisturbed stockpile will become depleted of erodible material and emissions of particulate matter will reduce correspondingly. However, the nature of ROM and product coal stockpiles is that they are frequently disturbed by the removal of materials and addition of fresh coal, causing a previously unexposed surface to be available for subsequent erosion

(Katestone, 2011).

For existing stockpiles, the control measures identified in the literature to minimise particulate emissions include:

Bypassing stockpiles to load directly into ROM bin or directly to off-site transportation (i.e. train wagons or haulage trucks).

Fencing, bunding or shelterbelts to reduce near-surface wind speed and the resultant wind-shear velocity across open areas and/or coal storage piles.

Watering to minimise lift-off, with automatic water application control through continuous cycling and variable application based on measured or forecast meteorological conditions.

The addition of chemical suppressants to bind loose fine surface material in response to adverse meteorological conditions.

Minimising residence time of coal in stockpiles, so that the surface material does not lose its erodible material.

Improved housekeeping, including the rapid and effective clean-up of material spillages.

The provision of surface covers.



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Structures can be used to reduce emissions of particulate matter, such as earth walls (berms), fences or mine buildings / structures. Berms can act as a windbreak by reducing the near-surface wind-shear velocity across the stockpile, and minimising the erosive and drying effects of the wind. Berms and wind screens can also reduce the amount of water and use of suppressants required for effective dust control, making it a cost-effective option in many cases. A study was conducted of the effectiveness of wind screens and determined that the most effective screens for reducing the wind speed had the following typical dimensional relationship to the dimensions of the corresponding stockpile (Katestone, 2011):

Height: 1.25 times the height of the stockpile.

Width: 1.5 times the height of the stockpile.

Distance upwind: 2.0 times the height of the stockpile.

Wind breaks and screens offer an alternative to reduce wind erosion from stockpiled materials or areas with no vegetative cover. Recent studies have demonstrated a wide range of control efficiencies for screens and windbreaks, as summarised in Katestone 2011. Vegetative wind breaks are reported with control efficiency of 30% and wind screens and fences up to 80%. Studies regarding windbreak design and size have been shown to influence its effectiveness, particularly its relative height to the height of the stockpile, its distance downwind and its structural porosity (Katestone, 2011). Reducing the height of the stockpile may also offer a significant reduction in the wind erosion potential by reducing the wind speed over the stockpile surface.

Similarly, stockpile size and orientation has been shown to affect the efficacy of wind breaks, with “smooth whaleback” profiles being more effective at reducing wind erosion than pointed stockpiles and orientation with the smallest face towards the prevailing wind offering increased protection from wind erosion. Studies suggest a control efficiency of 60% may be attributed to stockpile size, design and orientation.

Chemical binders and suppressants may be applied to the surface of stockpiles to enhance the cohesion of particles and reduce the potential for wind erosion. These binding agents are usually applied in solution and are sprayed onto the surface. Water sprays by themselves have been shown to offer in the region of 50% to 80% control efficiency. However, the effectiveness of spray additives is reduced by mechanical disturbance as it breaks the surface ‘crust’, which may be caused by stockpile working (i.e. the addition or removal of material), vehicle disturbance or the action of wild animals.

The use of multiple controls, such as the use of chemical stabilisers and binders with wind breaks may offer enhanced dust control. Studies have reported a reduction in windblown dust emissions of up to 85% for up to 10 days of moderate to high wind speeds through the combined use of chemical stabilisers and wind breaks (Katestone, 2011).

A summary of the potential control measures for minimising particulate emissions from wind erosion from coal stockpiles, and their effectiveness, is provided in Table 20 (Katestone, 2011).



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Table 20 Best Practice Control Measures – Wind Erosion of Coal Stockpiles

Control Type Control Measure Effectiveness1

Avoidance Bypassing stockpiles 100% reduction in wind erosion for coal bypassing stockpiles

Surface stabilisation Water spray 50%

Chemical wetting agents 80-99%

85%

90%

Surface crusting agent 95%

Carry over wetting from load in 80%

Enclosure Silo with bag house 100%

95-99%

99%

Cover storage pile with a tarp during high winds 99%

Wind speed reduction Vegetative wind breaks 30%

Reduced pile height 30%

Wind screens/wind fences >80%

75-80%

Pile shaping/orientation <60%

Erect 3-sided enclosure around storage piles 75%

Note 1 In some instances, the respective control has varying control efficiencies that are referenced through independent studies, and the table represents a simplified summary of those studies.


3.3 Bulldozers on Coal

Katestone (2011) presents a comprehensive summary of an options appraisal conducted by Connell Hatch for the control of particulate emissions from bulldozers at the RG Tanna Coal Terminal. Options considered in the study included:

Minimising travel speed and travel distance.

Stabilising bulldozer travel routes and use of water or suppressants on travel routes.

Manage coal moisture to ensure coal is sufficiently moist when working.

Modify design of the bulldozer to minimise emissions.

Based upon the data available, the emission of particulate from bulldozer operation can only be quantified by hours of operation, and not the speed of the vehicles.

A summary of the potential control measures for minimising particulate emissions from bulldozers, and their effectiveness, is provided in Table 21 (Katestone, 2011).



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Table 21 Best Practice Control Measures – Bulldozers

Control Measure Effectiveness

Bulldozer Minimise travel speed and distance Not quantified

Keep travel routes and materials moist 50%


3.4 Loading Coal and Reject Trucks

Loading trucks with ROM coal and coal rejects may give rise to particulate emissions as a result of the air turbulence induced by dropping of coal from height. The potential impacts of this process may be controlled by a range of factors including a reduction in the drop height, the application of water sprays to increase the moisture level in the material and to suppress emissions and through the erection of enclosures (where appropriate) to reduce the potential for entrainment in crosswinds.

A summary of the potential control measures for minimising particulate emissions from the loading of coal trucks, and their effectiveness, is provided in Table 22 (DSEWPC, 2012). It is noted that the loading of coal to trucks occurs by loader within the open cut or at the underground ROM, where loading of coal reject trucks occurs via the reject bin. Therefore, each control measure in Table 22 may not be appropriate for both sources. This is discussed further in Section 4.

Table 22 Best Practice Control Measures – Loading Coal and Rejects to Trucks

Control Measure Effectiveness

Enclosure 100%

Telescopic chute with water spray 75%

Water sprays 50%

Hooding with cyclones 70%

Hooding with scrubbers 85%

Hooding with fabric filters 83%

SOURCE: DSEWPC (2012), Table 4

3.5 Quantification of Potential Particulate Management Measures

Table 23 presents the emission control factors assumed in this assessment for the potential particulate management measures identified.



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Table 23 Control Factors Assumed for Potential Control Measures

Emission Source Control Measure Control Factor Assumed

Reference

Unpaved Haul Roads Pave the surface 90% Katestone (2011)

Low silt aggregate 30% Katestone (2011)

Oil and double chip surface 80% Katestone (2011)

Watering Level 2 (>2 l/m²/hr) 75% Katestone (2011)

Suppressants 84% Katestone (2011)

Hygroscopic salts 82% Katestone (2011)

Lignosulphonates 77% Katestone (2011)

Polymer emulsions 70% Katestone (2011)

Tar and bitumen emulsions 70% Katestone (2011)

Use conveyors in place of haul roads 95% Katestone (2011)

Wind Erosion Minimise pre-strip. EMP should specify a benchmark for optimal performance and report annually against benchmark

100% per m2 of pre-strip avoided

Katestone (2011)

Watering 50% Katestone (2011)

Chemical suppressants 70% Katestone (2011)

Paving and cleaning 95% Katestone (2011)

Apply gravel to stabilise disturbed open areas 84% Katestone (2011)


99% Katestone (2011)

Fencing, bunding, shelterbelts or in-pit dump. Height should be greater than the height of the erodible surface

30% Katestone (2011)

Vegetative ground cover 70% Katestone (2011)

Bulldozers on Coal Keep travel routes and materials moist 50% Katestone (2011)

Loading Coal / Rejects to Trucks

Enclosure 100% DSEPWC (2012)

Telescopic chute with water sprays 75% DSEPWC (2012)

Water sprays 50% DSEPWC (2012)

Hooding with cyclones 65% DSEPWC (2012)

Hooding with scrubbers 75% DSEPWC (2012)

Hooding with fabric filters 83% DSEPWC (2012)

Table 24 provides the location of each table providing the calculated controlled emissions for each source category and individual source.



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Table 24 Locations of Estimated Emissions Tables - Controlled

Source Category Source Table

Emissions from Unpaved Roads RL160 Dump Haul Road Table 25

Montrose Haul Road Table 26

South Bates Haul Road Table 27

Main Coal Haul Road, ROM to Open Cut Pit Table 28

Main Coal Haul Road, ROM to Underground Stockpile Table 29

Homestead Pit to ROM Haul Road Table 30

Wind Erosion RL160 Dumps Table 31

ROM Stockpile at CHPP Table 32

Product Coal Stockpile Table 33

Bulldozer on Coal Bulldozer on Coal at CHPP Table 34

Loading Coal Loading Coal to Trucks in Open Cut Table 35

Loading Coarse Rejects to Trucks at CHPP Table 36

In Table 25 to Table 36, the reported “Emissions (Controlled)” refer to the TSP, PM10 and PM2.5 emission estimates presented in Table 17.



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Table 25 Estimated Emissions RL160 Dump Haul Road – Potential Controls

Emission Source

Control Option Reduction Efficiency (%)

Reference Emissions (Controlled) Emissions (Controlled) plus Further Control


RL 160 Dump Haul Road

Pave the surface 90 Katestone (2011) 1,551,171 637,410 63,741 155,117 63,741 6,374

Low silt aggregate 30 Katestone (2011) 1,085,820 446,187 44,619

Oil and double chip surface 80 Katestone (2011) 310,234 127,482 12,748

Watering level 2 (>2 l/m²/hr) 75 Katestone (2011) 387,793 159,353 15,935

Suppressants 84 Katestone (2011) 248,187 101,986 10,199

Hygroscopic salts 82 Katestone (2011) 279,211 114,734 11,473

Lignosulphonates 77 Katestone (2011) 356,769 146,604 14,660

Polymer emulsions 70 Katestone (2011) 465,351 191,223 19,122

Tar and bitumen emulsions 70 Katestone (2011) 465,351 191,223 19,122

Use conveyors in place of haul roads

95 Katestone (2011) 77,559 31,871 3,187



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Table 26 Estimated Emissions Montrose Haul Road – Potential Controls

Emission Source




Montrose Haul Road

Pave the surface 90 Katestone (2011) 1,013,538 416,485 41,648 101,354 41,648 4,165

Low silt aggregate 30 Katestone (2011) 709,477 291,539 29,154









95 Katestone (2011) 50,677 20,824 2,082



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Table 27 Estimated Emissions South Bates Haul Road – Potential Controls

Emission Source




South Bates Haul Road

Pave the surface 90 Katestone (2011) 661,619 271,874 27,187 66,162 27,187 2,719










95 Katestone (2011) 33,081 13,594 1,359



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Table 28 Estimated Emissions Main Coal Haul Road, ROM to Open Cut Pit – Potential Controls

Emission Source




Main Coal Haul Road ROM to Open Cut Pit











95 Katestone (2011) 19,370 7,299 730



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Table 29 Estimated Emissions Main Coal Haul Road, ROM to Underground Stockpile – Potential Controls

Emission Source




Main Coal Haul Road ROM to Underground Stockpile











95 Katestone (2011) 17,970 6,411 641



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Table 30 Estimated Emissions Homestead Pit to ROM Haul Road – Potential Controls

Emission Source




Homestead Pit to ROM Haul Road

Pave the surface 90 Katestone (2011) 153,791 54,867 5,487 15,379 5,487 549




Suppressants 84 Katestone (2011) 24,607 8,779 878

Hygroscopic salts 82 Katestone (2011) 27,682 9,876 988





95 Katestone (2011) 7,690 2,743 274



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Table 31 Estimated Emissions RL160 Dump – Wind Erosion – Potential Controls

Emission Source




RL160 Dump – Wind Erosion

Minimise pre-strip 100 Katestone (2011) 78,787 39,393 5,909 0 0 0

Watering 50 Katestone (2011) 39,393 19,697 2,954

Chemical suppressants 70 Katestone (2011) 23,636 11,818 1,773

Paving and cleaning 95 Katestone (2011) 3,939 1,970 295

Apply gravel to stabilise disturbed open areas 84

Katestone (2011) 12,606 6,303 945

Rehabilitation 99 Katestone (2011) 788 394 59

Fencing, bunding, shelterbelts or in-pit dump 30

Katestone (2011) 55,151 27,575 4,136

Vegetative ground cover 70 Katestone (2011) 23,636 11,818 1,773



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Table 32 Estimated Emissions ROM Stockpile at CHPP – Wind Erosion – Potential Controls

Emission Source




ROM Stockpile at CHPP – Wind Erosion

Bypassing stockpiles 100 Katestone (2011) 59,873 29,937 4,491 0 0 0

Water sprays 50 Katestone (2011) 29,937 14,968 2,245

Chemical wetting agents 80 Katestone (2011) 11,975 5,987 898

Surface crusting agents 95 Katestone (2011) 2,994 1,497 225

Carry over wetting from load in 80 Katestone (2011) 11,975 5,987 898

Silo with bag house 95 Katestone (2011) 2,994 1,497 225

Cover storage pile with a tarp during high winds 99

Katestone (2011) 599 299 45

Vegetative wind breaks 30 Katestone (2011) 41,911 20,956 3,143

Reduced pile height 30 Katestone (2011) 41,911 20,956 3,143

Wind screens / wind fences 75 Katestone (2011) 14,968 7,484 1,123

Pile shaping / orientation 60 Katestone (2011) 23,949 11,975 1,796

Erect 3-sided enclosure around storage piles 75

Katestone (2011) 14,968 7,484 1,123



Draft 2


Table 33 Estimated Emissions Product Coal Stockpile – Wind Erosion – Potential Controls

Table 34 Estimated Emissions Bulldozers at CHPP – Potential Controls

Emission Source




Product Coal Stockpile – Wind Erosion

Bypassing stockpiles 100 Katestone (2011) 59,873 29,937 4,491 0 0 0

Water sprays 50 Katestone (2011) 29,937 14,968 2,245

Chemical wetting agents 80 Katestone (2011) 11,975 5,987 898

Surface crusting agents 95 Katestone (2011) 2,994 1,497 225

Carry over wetting from load in 80 Katestone (2011) 11,975 5,987 898

Silo with bag house 95 Katestone (2011) 2,994 1,497 225

Cover storage pile with a tarp during high winds 99

Katestone (2011) 599 299 45

Vegetative wind breaks 30 Katestone (2011) 41,911 20,956 3,143

Reduced pile height 30 Katestone (2011) 41,911 20,956 3,143

Wind screens / wind fences 75 Katestone (2011) 14,968 7,484 1,123

Pile shaping / orientation 60 Katestone (2011) 23,949 11,975 1,796

Erect 3-sided enclosure around storage piles 75

Katestone (2011) 14,968 7,484 1,123

Emission Source




Bulldozers at CHPP

Keep travel routes and materials moist 50

Katestone (2011) 59,303 18,050 1,805 29,652 9,025 902



Draft 2


Table 35 Estimated Emissions Loading Coal to Trucks – Potential Controls

Table 36 Estimated Emissions Coarse Rejects to Trucks – Potential Controls

Emission Source




Loading Coal to Trucks

Enclosure 100 DSEPWC (2012) 535,730 72,394 7,239 0 0 0

Telescopic chute with water sprays 75 DSEPWC (2012) 133,933 18,098 1,810

Water sprays 50 DSEPWC (2012) 267,865 36,197 3,620

Hooding with cyclones 65 DSEPWC (2012) 187,506 25,338 2,534

Hooding with scrubbers 75 DSEPWC (2012) 133,933 18,098 1,810

Hooding with fabric filters 83 DSEPWC (2012) 91,074 12,307 1,231

Emission Source




Coarse Rejects to Trucks

Enclosure 100 DSEPWC (2012) 61,888 8,363 836 0 0 0

Telescopic chute with water Sprays 75 DSEPWC (2012) 15,472 2,091 209

Water sprays 50 DSEPWC (2012) 30,944 4,181 418

Hooding with cyclones 65 DSEPWC (2012) 21,661 2,927 293

Hooding with scrubbers 75 DSEPWC (2012) 15,472 2,091 209

Hooding with fabric filters 83 DSEPWC (2012) 10,521 1,422 142



Draft 2


A comparison of emissions following each control measure application against original (with existing controls) emissions of particulate are presented in Figure 11 to Figure 23.

Figure 11 Potential Reductions in PM Emissions due to Additional Controls Haulage on RL160 Dump Haul Road

Figure 12 Potential Reductions in PM Emissions due to Additional Controls Haulage on Montrose Haul Road



Draft 2


Figure 13 Potential Reductions in PM Emissions due to Additional Controls Haulage on South Bates Haul Road

Figure 14 Potential Reductions in PM Emissions due to Additional Controls Haulage on Main Coal Haul Road – ROM to Open Cut Pit



Draft 2


Figure 15 Potential Reductions in PM Emissions due to Additional Controls Haulage on South Bates Haul Road

Figure 16 Potential Reductions in PM Emissions due to Additional Controls Haulage on Main Coal Haul Road – ROM to Underground Stockpile



Draft 2


Figure 17 Potential Reductions in PM Emissions due to Additional Controls Haulage on Homestead Pit to ROM Haul Road

Figure 18 Potential Reductions in PM Emissions due to Additional Controls Wind Erosion from RL160 Dump



Draft 2


Figure 19 Potential Reductions in PM Emissions due to Additional Controls Wind Erosion from ROM Stockpile at CHPP

Figure 20 Potential Reductions in PM Emissions due to Additional Controls Wind Erosion from Product Coal Stockpile



Draft 2


Figure 21 Potential Reductions in PM Emissions due to Additional Controls Bulldozers on Coal at CHPP

Figure 22 Potential Reductions in PM Emissions due to Additional Controls Loading ROM Coal to Trucks



Draft 2


Figure 23 Potential Reductions in PM Emissions due to Additional Controls Loading Coarse Rejects to Trucks



Draft 2


4 EVALUATION OF ADDITIONAL CONTROL MEASURES

3. Evaluate the practicability of implementing these best practice measures

3.1 For each of the best practice measures identified in step 2.1, assess how practicable each one is

to implement by taking into consideration:

implementation costs;

regulatory requirements;

environmental impacts;

safety implications; and,

compatibility with current processes and proposed future developments.

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

emissions.

As required by EPA, the practicability of implementing each of the particulate control options identified in Section 3 is to be assessed with due consideration given to:

implementation costs.

regulatory requirements.

environmental impacts.

safety implications.

compatibility with current processes and proposed future developments.

The following sections examine the measures that may constrain the implementation of the particulate control measures outlined in Table 23, namely the regulatory requirements, environmental impacts, safety implications and compatibility with current processes and future development.

Each measure is provided a risk rating (low, medium or high) which identifies the constraints which may result in the implementation of the measure not being practical at WCPL. Where any of the four measures of practicability are rated as high, these measures are not taken forward for an assessment of cost implication and feasibility.

Section 0 examines the potential control measures identified for haul road sources, Section 0 for wind erosion of overburden, Section 0 for wind erosion of coal stockpiles, Section 4.4 for the operation of bulldozers on coal, Section 4.5 for the loading of ROM coal to trucks and Section 4.6 for the loading of coarse rejects to trucks.



Draft 2


4.1 Evaluation Findings – Haul Roads

4.1.1 Practicality of Implementation

Table 37 provides a discussion of the feasibility of control measures for haul roads. Feasibility measures are provided considering all haul roads, as measures display commonality across the site.

Table 37 Practicability of Implementing Control Measures on Haul Roads

Control Measure – Haul Roads

Regulatory Requirements RISK

Environmental Impacts RISK

Safety Implications RISK

Compatibility with Current Processes and Future Developments RISK

Conclusions of Evaluation

Pave the surface

RISK = LOW Follow industry practice for the safe design of haul roads.

RISK = HIGH As part of mine development and rehabilitation, removal of the road will generate significant quantities of waste materials requiring disposal.

RISK = LOW Safety would likely be improved following paving as risk of accidents would be reduced. Speed restrictions would need to be closely monitored

RISK = HIGH Changes in pit locations etc would potentially require costly changes in haul road routes and repaving.

Not considered further in this assessment

Low silt aggregate

RISK = LOW Follow industry practice for the safe design of haul roads.

RISK = MEDIUM As part of mine development and rehabilitation, removal of the road will generate significant quantities of waste materials requiring disposal or re-use.

RISK = MEDIUM Safety may be compromised following application of gravelling as risk of accidents may be increased as risk of skidding increases. Speed restrictions would need to be closely monitored to ensure this is not an issue

RISK = LOW Compatible

Adopted potential measure HR1

Oil and double chip surface

RISK = LOW Ensure all chemicals are registered on-site with relevant MSDS at Stores

RISK = HIGH Very little information or data is available to support this control option, and as such it is not considered likely to represent best practice.

RISK = MEDIUM Ensure road surface provides adequate traction for haul trucks to prevent skidding/slipping.



Watering Level 2 (>2 l/m²/hr)

RISK = LOW Ensure that run off is appropriately captured, filtered and discharged or recycled to on-site dams







Draft 2








Hygroscopic salts


RISK = LOW Ensure that application rate is appropriate to avoid run off into watercourses. Ensure application is performed during appropriate meteorological conditions to avoid wash/blow off onto non-haul road areas Based on the MSDS, a spill management program should be formulated.


Ensure suitable storage and handling procedures are implemented to prevent harmful exposure to any chemicals in the suppressant product



Ligno-sulphonates







Polymer emulsions









Draft 2








Tar and bitumen emulsions








RISK = LOW Already considered for existing conveyors

RISK = LOW Additional use of electricity offset and likely surpassed by reduction in diesel fuel use

RISK = LOW Already considered for existing conveyors

RISK = HIGH Changes in pit locations etc would potentially require costly changes in conveyor routes and infrastructure.


4.1.2 Implementation Costs

As required by EPA, the cost implication of each potential particulate control measure has been assessed, taking into account (where applicable):

Estimated capital expenditure.

Labour costs.

Material costs.,

Potential cost savings.

An estimation of the cost and net cost per tonne of TSP, PM10 and PM2.5 suppressed is provided for each mitigation measure APPENDIX E.



Draft 2


4.2 Evaluation Findings – Wind Erosion of Overburden Dumps


Table 38 provides a discussion of the feasibility of control measures for wind erosion of overburden dumps.

Table 38 Practicability of Implementing Control Measures on Wind Eroded Areas – Overburden Dumps

Control Measure – Wind Erodible Areas





Conclusion of Evaluation

Watering RISK = LOW Ensure that run off is appropriately captured, filtered and discharged or recycled to on-site dams


RISK = MEDIUM Ensure electrical equipment is appropriately isolated. Ensure mists and sprays do not hinder mobile equipment operator vision


Adopted potential measure WE1

Chemical suppressants


RISK = LOW Ensure that application rate is appropriate to avoid run off into watercourses. Ensure application is performed during appropriate meteorological conditions to avoid wash/blow off onto other areas Based on the MSDS, a spill management program should be formulated.

RISK = MEDIUM Appropriate PPE required for water truck operative, and personnel involved in the mixing of suppressants with water (if required). If onsite storage required, appropriate signage required and emergency management plan required in event of spill/leakage



Paving and cleaning

RISK = LOW None

RISK = MEDIUM Significant additional runoff is likely following paving which would require additional controls to be implemented within the stormwater and sediment management plans Post-mining C&I waste would be increased. Sustainability benefits of paving at this site are questionable

RISK = LOW Safety would likely be improved following paving as risk of accidents would be reduced. Speed restrictions would need to be closely monitored when vehicles are travelling on paved areas

RISK = HIGH Not compatible for regularly disturbed areas – paved areas would need to be constantly cleared and relaid




Draft 2








Apply gravel to stabilise disturbed open areas

RISK = LOW None

RISK = LOW None

RISK = LOW None

RISK = HIGH Not compatible for regularly disturbed areas – gravelled areas would need to be constantly cleared and re-laid



RISK = LOW Currently undertaken

RISK = LOW None

RISK = LOW None


Not considered further in this assessment as already performed

Vegetative ground cover

RISK = LOW None

RISK = LOW None

RISK = LOW None


Not considered further in this assessment as already performed

Fencing, bunding, shelterbelts or in-pit dump.

RISK = LOW None

RISK = LOW None

RISK = LOW None






Labour costs.

Material costs.





Draft 2


4.3 Evaluation Findings – Wind Erosion of Coal Stockpiles


Table 39 provides a discussion of the feasibility of control measures for wind erosion of coal stockpiles.

Table 39 Practicability of Implementing Control Measures on Wind Eroded Areas – Coal Stockpiles







Bypassing stockpiles

RISK = LOW None

RISK = LOW Improvements in dust emissions would be realised

RISK = LOW None

RISK = HIGH Not compatible. Storage area is required for periods when coal cannot be accepted at the CHPP.


Water Sprays RISK = LOW Ensure that run off is appropriately captured, filtered and discharged or recycled to on-site dams




Not considered further in this assessment – already implemented

Chemical wetting agents


RISK = MEDIUM Ensure that application rate is appropriate to avoid run off into watercourses. Ensure application is performed during appropriate meteorological conditions to avoid wash/blow off onto other areas Based on the MSDS, a spill management program should be formulated.

RISK = MEDIUM Appropriate PPE required for water truck operative, and personnel involved in the mixing of suppressants with water (if required). If onsite storage required, appropriate signage required and emergency management plan required in event of spill/leakage

RISK = MEDIUM Not entirely compatible for regularly disturbed areas. Application of wetting agents would need to be performed constantly

Adopted potential measure WEC1*



Draft 2








Surface crusting agents


RISK = MEDIUM Ensure that application rate is appropriate to avoid run off into watercourses. Ensure application is performed during appropriate meteorological conditions to avoid wash/blow off onto other areas Based on the MSDS, a spill management program should be formulated.

RISK = MEDIUM Appropriate PPE required for water truck operative, and personnel involved in the mixing of crusting agents with water (if required). If onsite storage required, appropriate signage required and emergency management plan required in event of spill/leakage

RISK = MEDIUM Not entirely compatible for regularly disturbed areas. Application of crusting agents would need to be performed constantly


Enclosure (silo with bag house)

RISK = LOW None

RISK = LOW None

RISK = LOW None

RISK = HIGH Quantity of coal on ROM pad would make the installation of enclosure impractical


Cover storage pile with tarp during high winds

RISK = LOW None

RISK = LOW None

RISK = LOW None

RISK = HIGH Constant loading of ROM pad (24/7) would make the use of a tarp impractical


Vegetative wind breaks

RISK = LOW None

RISK = LOW None

RISK = LOW None



Wind screens / fences

RISK = LOW None

RISK = LOW None

RISK = LOW None



Erect 3-sided enclosure around storage piles

RISK = LOW None

RISK = LOW None

RISK = LOW None



Reduced pile height

RISK = LOW None

RISK = LOW None

RISK = LOW None

RISK = LOW None

Adopted potential measure WEC3

Pile shaping / orientation

RISK = LOW None

RISK = LOW None

RISK = LOW None


Adopted potential measure WEC4

NB * Measures combined with identical control factors, activity rates and risks





Draft 2



Labour costs.

Material costs.



4.4 Evaluation Findings – Bulldozer on Coal at CHPP


Table 40 provides a discussion of the feasibility of control measures for bulldozers operating on coal.

Table 40 Practicability of Implementing Control Measures for Bulldozers Operating on Coal

Control Measure – Bulldozers






Keep travel routes and materials moist with water sprays

RISK = LOW

Ensure that run off is appropriately captured, filtered and discharged or recycled to on-site dams

RISK = LOW

Ensure that run off is appropriately captured, filtered and discharged or recycled to on-site dams Additional GHG emissions due to fuel consumption

RISK = MEDIUM Ensure road surface provides adequate traction for dozers to prevent slipping.

RISK = LOW to MEDIUM Partially compatible; excess moisture in coal product would result in moisture being transported offsite with financial implications to purchaser and transport provider. E.g. additional 2% moisture (w/w) in product would result in 2 tonnes of water being transported per 100 tonnes coal – additional trucks/wagons required to transport.

Not considered further in this assessment as water spraying already occurs on the ROM pad at the CHPP and Product Stockpile




Labour costs.

Material costs.





Draft 2


4.5 Evaluation Findings – Loading Coal to Trucks


Table 41 provides a discussion of the feasibility of control measures for loading coal to trucks.

Table 41 Practicability of Implementing Control Measures on Dumping of ROM Coal to Trucks

Control Measure – Dumping of ROM Coal to Trucks






Enclosure RISK = LOW None

RISK = LOW None

RISK = LOW None

RISK = HIGH Enclosure of mobile equipment in variable locations is not practical


Telescopic Chute with Water Spray

RISK = LOW None

RISK = LOW None

RISK = LOW None

RISK = HIGH Not appropriate for the process


Water sprays RISK = LOW Ensure that run off is appropriately captured, filtered and discharged or recycled to on-site dams




Adopted potential measure DC1

Hooding with Cyclones

RISK = LOW None

RISK = LOW None

RISK = LOW None

RISK = HIGH Enclosure of mobile equipment in variable locations is not practical Not appropriate for the site


Hooding with Scrubbers

RISK = LOW None

RISK = LOW None

RISK = LOW None



Hooding with Fabric Filters

RISK = LOW None

RISK = LOW None

RISK = LOW None





Draft 2





Labour costs.

Material costs.



4.6 Evaluation Findings – Loading Coarse Rejects to Trucks


Table 41 provides a discussion of the feasibility of control measures for loading coarse rejects to trucks.

Table 42 Practicability of Implementing Control Measures on Loading Coarse Rejects to Trucks

Control Measure – Loading Coarse Rejects to Trucks






Enclosure RISK = LOW None

RISK = LOW None

RISK = LOW None

RISK = HIGH Enclosure of mobile equipment in variable locations is not practical


Telescopic Chute with Water Spray

RISK = LOW None

RISK = LOW None

RISK = LOW None


Adopted potential measure LCR1

Water sprays RISK = LOW Ensure that run off is appropriately captured, filtered and discharged or recycled to on-site dams




Adopted potential measure LCR2

Hooding with Cyclones

RISK = LOW None

RISK = LOW None

RISK = LOW None

RISK = HIGH Not considered to be appropriate control




Draft 2


Control Measure – Loading Coarse Rejects to Trucks






Hooding with Scrubbers

RISK = LOW None

RISK = LOW None

RISK = LOW None



Hooding with Fabric Filters

RISK = LOW None

RISK = LOW None

RISK = LOW None






Labour costs.

Material costs.



4.7 Summary of Evaluation Findings

A summary of the evaluation process for each control measure identified in Section 4 is presented in Table 43. Any control options rated as high risk for any of the feasibility considerations (regulatory considerations, environmental impacts, safety implications or site compatibility) have not been evaluated for their implementation costs, and are not presented in this summary table.

Emissions from Unpaved Roads RL160 Dump Haul Road

Montrose Haul Road


Main Coal Haul Road, ROM to Open Cut Pit

Main Coal Haul Road, ROM to Underground Stockpile


Wind Erosion RL160 Dump

ROM Stockpile at CHPP

Product Coal Stockpile

Bulldozer on Coal Bulldozer on Coal at CHPP

Loading Coal Loading Coal to Trucks in Open Cut

Loading Coarse Rejects to Trucks at CHPP



Draft 2


Table 43 Summary of Control Options Evaluation

Emission Source Group

Emission Source Control Measure Cost/Benefit

$/tonne PM10

Regulatory Considerations

Environmental Impacts Safety Implications Site Compatibility

Haul Roads RL160 Dump Haul Road

HR1: Low silt aggregate $747 Low Medium Medium Low

HR2: Watering Level 2 $1,089 Low Low Medium Low

HR3: Hygroscopic Salts $30 Low Low Medium Low

HR4: Ligno-sulphonate $346 Low Low Medium Low

HR5: Polymer emulsions $3,117 Low Low Medium Low

HR6: Tar and bitumen emulsions $7,763 Low Low Medium Low

Montrose Haul Road HR1: Low silt aggregate $543 Low Medium Medium Low







HR1: Low silt aggregate $402 Low Medium Medium Low






Main Coal Haul Road, ROM to Open Cut Pit

HR1: Low silt aggregate $3,306 Low Medium Medium Low



HR4: Ligno-sulphonate $1,532 Low Low Medium Low





Draft 2




$/tonne PM10



Main Coal Haul Road, ROM to Underground Stockpile














Wind Erosion of Overburden

RL160 Dump WE1:Watering $35,813 Low Low Medium Low

WE2: Chemical Suppressants $178,653 Low Low Medium Low

WE3: Fencing, bunding, shelterbelts

$1,810 Low Low Low Low

Wind Erosion of Coal Stockpiles

ROM Stockpile at CHPP

WEC1 Chemical wetting agents, surface crusting agents

$14,247 Low Medium Medium Medium

WEC2: Vegetative wind breaks, wind screens, 3-sided enclosures

$753 Low Low Low Low

WEC3: Reduce pile height $0 Low Low Low Low

WEC4: Pile shaping / orientation $0 Low Low Low Low

Product Coal Stockpile

WEC1: Chemical wetting agents, surface crusting agents

$13,927 Low Medium Medium Medium

WEC2: Vegetative wind breaks, wind screens, 3-sided enclosures

$386 Low Low Low Low

WEC3: Reduce pile height $0 Low Low Low Low

WEC4: Pile shaping / orientation $0 Low Low Low Low



Draft 2




$/tonne PM10



Loading Coal Loading Coal to Trucks in Open Cut

DC1: Water sprays $1,732 Low Low Medium Low

Loading Coarse Rejects to Trucks at CHPP

LCR1: Telescopic chute with water sprays

$9,996 Low Low Low Low

LCR2: Water sprays $14,995 Low Low Medium Low



Draft 2


4.8 Cost Curves

For each identified control measure evaluated as part of this process for the emission sources ranked as contributing the top 95% of TSP emissions in Table 17 a cost curve has been prepared to graphically display the relative effectiveness and relative cost of those controls. Displaying the collated data as a cost curve is a recognised industry-standard approach to visually identifying the preferential options.

The width of the each bar indicates the particulate mitigation afforded by each measure, with the height of each bar indicating the cost per unit of mitigation. Therefore, a wide and short bar indicates a measure that could potentially (and relatively) provide a greater level of particulate mitigation at a lower cost. These are the measures that should be prioritised for further investigation.

Figure 24 PM10 Abatement Cost Curve

Key:

1 ROM Stockpile at CHPP: WEC3: Reduce pile height

2 ROM Stockpile at CHPP: WEC4: Pile shaping / orientation

3 Product Coal Stockpile: WEC3: Reduce pile height

4 Product Coal Stockpile: WEC4: Pile shaping / orientation

5 South Bates Haul Road: HR3: Hygroscopic Salts

6 Montrose Haul Road: HR3: Hygroscopic Salts

7 RL160 Dump Haul Road: HR3: Hygroscopic Salts



Draft 2


8 Main Coal Haul Road, ROM to Underground Stockpile: HR3: Hygroscopic Salts

9 Main Coal Haul Road, ROM to Open Cut Pit: HR3: Hygroscopic Salts

10 Homestead Pit to ROM Haul Road: HR3: Hygroscopic Salts

11 South Bates Haul Road: HR4: Ligno-sulphonate

12 Montrose Haul Road: HR4: Ligno-sulphonate

13 RL160 Dump Haul Road: HR4: Ligno-sulphonate

14 Product Coal Stockpile: WEC2: Vegetative wind breaks, wind screens, 3-sided enclosures

15 South Bates Haul Road: HR1: Low silt aggregate

16 Montrose Haul Road: HR1: Low silt aggregate

17 RL160 Dump Haul Road: HR1: Low silt aggregate

18 ROM Stockpile at CHPP: WEC2: Vegetative wind breaks, wind screens, 3-sided enclosures

19 RL160 Dump Haul Road: HR2: Watering Level 2

20 Main Coal Haul Road, ROM to Underground Stockpile: HR4: Ligno-sulphonate

21 South Bates Haul Road: HR5: Polymer emulsions

22 Main Coal Haul Road, ROM to Open Cut Pit: HR4: Ligno-sulphonate

23 Montrose Haul Road: HR2: Watering Level 2

24 Loading Coal to Trucks in Open Cut: DC1: Water sprays

25 Homestead Pit to ROM Haul Road: HR4: Ligno-sulphonate

26 RL160 & Wombat Dumps: WE3: Fencing, bunding, shelterbelts

27 Montrose Haul Road: HR5: Polymer emulsions

28 Main Coal Haul Road, ROM to Underground Stockpile: HR1: Low silt aggregate

29 South Bates Haul Road: HR2: Watering Level 2

30 RL160 Dump Haul Road: HR5: Polymer emulsions

31 Main Coal Haul Road, ROM to Open Cut Pit: HR1: Low silt aggregate

32 Homestead Pit to ROM Haul Road: HR1: Low silt aggregate

33 South Bates Haul Road: HR6: Tar and bitumen emulsions

34 Main Coal Haul Road, ROM to Open Cut Pit: HR2: Watering Level 2

35 Montrose Haul Road: HR6: Tar and bitumen emulsions



Draft 2


36 Main Coal Haul Road, ROM to Underground Stockpile: HR2: Watering Level 2

37 RL160 Dump Haul Road: HR6: Tar and bitumen emulsions

38 Main Coal Haul Road, ROM to Underground Stockpile: HR5: Polymer emulsions

39 Loading Coarse Rejects to Trucks at CHPP: LCR1: Telescopic chute with water sprays

40 Homestead Pit to ROM Haul Road: HR5: Polymer emulsions

41 Homestead Pit to ROM Haul Road: HR2: Watering Level 2

42 Main Coal Haul Road, ROM to Open Cut Pit: HR5: Polymer emulsions

43 Product Coal Stockpile: WEC1: Chemical wetting agents, surface crusting agents

44 ROM Stockpile at CHPP: WEC1 Chemical wetting agents, surface crusting agents

45 Loading Coarse Rejects to Trucks at CHPP: LCR2: Water sprays

46 Main Coal Haul Road, ROM to Underground Stockpile: HR6: Tar and bitumen emulsions

47 Homestead Pit to ROM Haul Road: HR6: Tar and bitumen emulsions

48 Main Coal Haul Road, ROM to Open Cut Pit: HR6: Tar and bitumen emulsions

49 RL160 & Wombat Dumps: WE1:Watering

50 RL160 Dump: WE2: Chemical Suppressants

4.9 Identification of Dust Control Measures for WCPL

The methodology followed above is consistent with the broad outline methodology proposed by NSW EPA, which is reproduced in Appendix A.

Through the adoption of this procedure, WCPL’s emissions of particulate matter have been quantified with and without the range of existing control measures implemented on-site, and the top sources contributing to the cumulative 95% of TSP emitting sources identified.

The particulate control measures that are already implemented at WCPL are summarised in Table 14. It is noted that through the implementation of these controls, the monitoring undertaken around the WCPL demonstrates that the air quality criteria outlined in Project Approval conditions (refer to Table 6) are not exceeded. In this regard, it may be determined that the current controls implemented at the WCPL are adequate in controlling the impact of the mining operations and demonstrates compliance with the Project Approval and EPL conditions concerning the control of particulate emissions.

However, it is acknowledged that this process is designed to determine further controls which may assist in reducing particulate matter emissions from the WCPL as far as practicable. A range of additional control options for the processes operated at WCPL has been investigated. All identified control options have been assessed to account for the risk associated with compliance with regulatory requirements, the potential environmental impacts, safety implications and their compatibility with current processes and future developments approved or anticipated at the WCPL. Through this initial screening, any options that were considered to be high risk for the above measures were discounted, resulting in a range of 50 measures for which implementation costs were estimated.



Draft 2


The cost estimates have been prepared with reference to published and referenced data sources, experience or estimates from WCPL and a range of assumptions. All assumptions have been provided for clarification and transparency.

The cost / benefit ratio of the control options are presented in Table 43 and presented graphically in Figure 24. This analysis has identified the following control options as providing a significant potential to reduce the total emission of particulates from all sources at site.

4.9.1 Haul Roads

The use of low silt aggregate has been shown to provide cost effective particulate reductions for the following haul roads:

RL160 Dump Haul Road $747 per tonne PM10 suppressed

Montrose Haul Road $543 per tonne PM10 suppressed

South Bates Haul Road $402 per tonne PM10 suppressed

The use of hygroscopic salts has been identified as providing cost effective particulate reductions for the following haul roads:




Main Coal Haul Road ROM to Open Cut Pit $178 per tonne PM10 suppressed

Main Coal Haul Road ROM to Underground Stockpile $107 per tonne PM10 suppressed

Homestead Pit to ROM Haul Road $189 per tonne PM10 suppressed

Increased haul road watering has been identified as providing cost effective particulate reductions for the following haul roads:

RL160 Dump Haul Road $1,089 per tonne PM10 suppressed

A new water truck fill point has recently been installed at the WCPL to reduce the time taken for water trucks to travel between fill points. This will increase the rate of haul road watering at the WCPL.

The use of ligno-sulphonates have been identified as providing cost effective particulate reductions for the following haul roads:




Main Coal Haul Road ROM to Underground Stockpile $1,106 per tonne PM10 suppressed

The use of polymer or tar and bitumen emulsions have been identified as providing cost effective particulate reductions for the following haul roads:

South Bates Haul Road $3,625 per tonne PM10 suppressed

Main Coal Haul Road ROM to Open Cut Pit $34,386 per tonne PM10 suppressed

Main Coal Haul Road ROM to Underground Stockpile $23,364 per tonne PM10 suppressed

Homestead Pit to ROM Haul Road $34,225 per tonne PM10 suppressed



Draft 2


Certain trials are currently being performed at the WCPL, including a trial of PetroTac (tar emulsion) which is planned to be extended.

Commitments

WCPL commit to the trial of the following dust suppression measures at the WCPL. Each trial will be complemented with a comprehensive field assessment to quantify particulate emissions from haul roads with and without the measure applied. A control efficiency will then be calculated which will assist in the confirmation of the assumptions used within this report.

Commitment 1 Polymer/tar and bitumen emulsions (PetroTac) will continue to be trialled on a 1 km stretch of the South Bates Haul Road over a period of 6 months. Following the trial, if measures are shown to provide reductions in particulate emissions at reasonable cost, widespread roll-out of measures will be implemented.

4.9.2 Wind Erosion of the RL160 Overburden Dump

The use of shelterbelts have been identified as the most cost-effective particulate reduction measure on the overburden dumps at a cost of $1,810 per tonne of PM10 suppressed. Additional watering and the use of chemical suppressants were shown to be restrictively expensive options.

Commitments

WCPL commit to the trial of vegetative shelterbelts on the RL160 dump. A trial will be complemented with a comprehensive field assessment to quantify particulate emissions from overburden dumps with and without the measure applied. A control efficiency will then be calculated which will assist in the confirmation of the assumptions used within this report.

Commitment 2 Vegetative wind breaks and wind screens will be trialled on the RL160 Dump over a period of 6 months. Following the trial, if the measure is shown to provide reductions in particulate emissions at reasonable cost, widespread roll-out of this measure will be implemented.

In addition to this commitment, the majority of the RL160 Dump will have been rehabilitated by the end of October 2012.

4.9.3 Wind Erosion of Coal Stockpiles

The reduction in coal stockpile heights and pile shaping and orientation are shown to provide emissions reductions at no additional costs.

The use of vegetative wind breaks and wind screens have also been identified as potentially proving emissions reductions at costs of $753 per tonne PM10 at the ROM Stockpile and $386 per tonne PM10 at the Product Coal Stockpile.

Commitments

WCPL commit to the trial of vegetative wind breaks and wind screens on the ROM coal and Product coal stockpiles. A trial will be complemented with a comprehensive field assessment to quantify particulate emissions from coal stockpiles with and without the measure applied. A control efficiency will then be calculated which will assist in the confirmation of the assumptions used within this report.



Draft 2


Commitment 3 Vegetative wind breaks and wind screens will be trialled on the ROM stockpile and on a 1 ha area of the product stockpile over a period of 6 months. Following the trial, if the measure is shown to provide reductions in particulate emissions at reasonable cost, widespread roll-out of this measure will be implemented.

4.9.4 Monitoring of Control Measures

The success of the trialled particulate reduction measures to be implemented at the WCPL will involve the monitoring of a range of parameters to ensure that each measure results in particulate reductions. A detailed monitoring plan will be designed for each trialled measure and may include (but not be limited to) the following monitoring methods:

The use of video cameras at the junction between treated and untreated haul roads to visually/subjectively identify the success of the measure in reducing haulage generated particulate matter emissions.

The sampling of the silt content of haul roads following the application of the PetroTac trial to allow the quantification of emission reductions (using emission estimation techniques).

The success of the installation of tree screens and shelterbelts will be measured through a site specific particulate monitoring program, with particulate measurements taken pre- and post- installation. In conjunction with meteorological data, this will allow the quantification of the success of the trial.



Draft 2


5 IMPLEMENTATION TIMEFRAME

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

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

timeframe for their implementation.

As discussed in Section 4.9, a range of particulate control measures have been identified which are compatible with a range of considerations (regulatory, environmental, safety and site compatibility). The most cost effective measures have been identified and WCPL has committed to a trial of all measures which demonstrate particulate reductions at costs of less than $1,500 per tonne of PM10 suppressed.

The widespread implementation of any measure has not been committed to at this time, as the control efficiencies afforded by each measure have been taken from literature. Site specific measurements of the control efficiencies are proposed as they will enable a refinement of the likely particulate reductions expected, prior to commitment to measures which may not realise the reductions estimated.

A comprehensive test program will be implemented within 6 months of report acceptance.



Draft 2


6 REFERENCES

Countess Environmental (2006), WRAP Fugitive Dust Handbook.

Katestone (2010), NSW Coal Mining Benchmarking Study - International Best Practice Measures to Prevent and/or Minimise Emissions of Particulate Matter from Coal Mining.

US Department of Health and Human Services (2012), Dust Control Handbook for Industrial Minerals Mining and Processing.

USEPA (1995), AP 42, Fifth Edition, Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources, Technology Transfer Network - Clearinghouse for Inventories & Emissions Factors, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC 27711, USA.

USEPA (1998), AP 42, Chapter 11.9 Western Surface Coal Mining, Technology Transfer Network - Clearinghouse for Inventories & Emissions Factors, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC 27711, USA

USEPA (1982), AP 42, Chapter 11.24 Metallic Minerals Processing, Technology Transfer Network - Clearinghouse for Inventories & Emissions Factors, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC 27711, USA

USEPA (2006), AP 42, Chapter 13.2.2 Unpaved Roads, Technology Transfer Network - Clearinghouse for Inventories & Emissions Factors, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC 27711, USA

USEPA (2006), AP 42, Chapter 13.2.4 Aggregate Handling and Storage Piles, Technology Transfer Network - Clearinghouse for Inventories & Emissions Factors, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC 27711, USA.

USEPA (2006), AP 42, Chapter 13.2.5 Industrial Wind Erosion, Technology Transfer Network - Clearinghouse for Inventories & Emissions Factors, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC 27711, USA.

DCCEE (2011), National Pollutant Inventory Emission Estimation Technique Manual for Mining , Version 3, Australian Government Department of Sustainability, Environment, Water, Population and Communities.

WCPL (2011), Annual Environmental Management Report



Draft 2


7 CLOSURE

This report has been prepared by SLR Consulting Australia Pty Ltd with all reasonable skill, care and diligence, and taking account of the manpower and resources devoted to it by agreement with the client. Information reported herein is based on the interpretation of data collected and has been accepted in good faith as being accurate and valid.

This report is for the exclusive use of Wambo Coal Pty Ltd. No warranties or guarantees are expressed or should be inferred by any third parties. This report may not be relied upon by other parties without written consent from SLR Consulting.

SLR Consulting disclaims any responsibility to the client and others in respect of any matters outside the agreed scope of the work.

Appendix A Report Number 610.11105.01000-R1

Page 1 of 3


COAL MINE PARTICULATE MATTER CONTROL BEST PRACTICE – SITE SPECIFIC DETERMINATION GUIDELINE

PURPOSE OF THIS GUIDELINE

The purpose of this guideline is to provide detail of the process to be followed in conducting a site specific determination of best practice measures to reduce emissions of particulate matter from coal mining activities.

This guideline also provides the required content and format of the report required for the Pollution Reduction Program “Coal Mine Particulate Matter Best Practice - Assessment and Report”.

THE SITE SPECIFIC DETERMINATION PROCESS

In preparing the Report, the following steps must be followed, as a minimum:

5. Identify, quantify and justify existing measures that are being used to minimise

particle emissions 5.1. Estimate baseline emissions of TSP, PM10 and PM2.5 (tonne per year) from each

mining activity. This estimate must:

utilise USEPA AP42 emission estimation techniques;

calculate uncontrolled emissions (with no particulate matter controls in place); and

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

(Note: These particulate matter controls must be clearly identified, quantified and justified with supporting information). 5.2. Using the results of the controlled emissions estimates generated from Step 1.1,

rank the mining activities according to the mass of TSP, PM10 and PM2.5 emitted by each mining activity per year from highest to lowest.

5.3. Identify the top four mining activities from Step 1.2 that contribute the highest emissions of TSP, PM10 and PM2.5.

6. Identify, quantify and justify best practice measures that could be used to

minimise particle emissions 6.1. For each of the top four activities identified in Step 1.3, identify the best practice

measures that could be implemented to reduce emissions taking into consideration:

the findings of Katestone (2010), NSW Coal Mining Benchmarking Study - International Best Practice Measures to Prevent and/or Minimise Emissions of Particulate Matter from Coal Mining, Katestone Environmental Pty Ltd, Terrace 5, 249 Coronation Drive, PO Box 2217, Milton 4064, Queensland, Australia. http://www.environment.nsw.gov.au/resources/air/KE1006953coalminebmpreport.pdf ;

any other relevant published information; and

any relevant industry experience from either Australia or overseas. 6.2. For each of the top four activities identified in Step 1.3, estimate emissions of TSP,

PM10 and PM2.5 from each mining activity following the application of the best practice measures identified in Step 2.1.

http://www.environment.nsw.gov.au/resources/air/KE1006953coalminebmpreport.pdf

http://www.environment.nsw.gov.au/resources/air/KE1006953coalminebmpreport.pdf


Page 2 of 3


7. Evaluate the practicability of implementing these best practice measures 7.1. For each of the best practice measures identified in Step 2.1, assess the

practicability associated with their implementation, by taking into consideration:

implementation costs;

regulatory requirements;

environmental impacts;

safety implications; and

compatibility with current processes and proposed future developments. 7.2. Identify those best practice measures that will be implemented at the premises to

reduce particle emissions. 8. Propose a timeframe for implementing all practicable best practice measures

8.1. For each of the best practice measures identified as being practicable in Step 3.2, provide a timeframe for their implementation.

REPORT CONTENT

The report must clearly identify the methodologies utilised and all assumptions made.

The report must contain detailed information justifying and supporting all of the information used in each step of the process. For example, in calculating controlled emissions in Step 1, current particulate matter controls being used at the mine must be clearly identified, quantified and justified with supporting information and evidence including monitoring data, record keeping, management plans and/or operator training etc.

In evaluating practicability in Step 3, the licensee must document the following specific information:

estimated capital, labour, materials and other costs for each best practice measure on an annual basis for a ten year period. This information must be set out in the format provided in Appendix A;

The details of any restrictions on the implementation of each best practice measure due to an existing approval or licence;

Quantification of any new or additional environmental impacts that may arise from the application of a particular best practice measure, such as increased noise or fresh water use;

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

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

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

REPORT FORMAT

The report must be structured according to the process outlined above and submitted in both electronic format as .PDF format and hard copy format in triplicate. All emission estimates, costs and supporting calculations must be submitted in electronic format as .XLS format.

ABBREVIATIONS AND DEFINITIONS

USEPA AP42 Emission Estimation Techniques – all of the following:

USEPA (1995), AP 42, Fifth Edition, Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources, Technology Transfer Network - Clearinghouse for Inventories & Emissions Factors, United States Environmental Protection Agency, Office of Air Quality Planning and


Page 3 of 3


Standards, Research Triangle Park, NC 27711, USA. http://www.epa.gov/ttn/chief/ap42/index.html ;

USEPA (1998), AP 42, Chapter 11.9 Western Surface Coal Mining, Technology Transfer Network - Clearinghouse for Inventories & Emissions Factors, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC 27711, USA. http://www.epa.gov/ttn/chief/ap42/ch11/final/c11s09.pdf ;

USEPA (2006), AP 42, Chapter 13.2.2 Unpaved Roads, Technology Transfer Network - Clearinghouse for Inventories & Emissions Factors, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC 27711, USA. http://www.epa.gov/ttn/chief/ap42/ch13/final/c13s0202.pdf ;

USEPA (2006), AP 42, Chapter 13.2.4 Aggregate Handling and Storage Piles, Technology Transfer Network - Clearinghouse for Inventories & Emissions Factors, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC 27711, USA. http://www.epa.gov/ttn/chief/ap42/ch13/final/c13s0204.pdf ; and

USEPA (2006), AP 42, Chapter 13.2.5 Industrial Wind Erosion, Technology Transfer Network - Clearinghouse for Inventories & Emissions Factors, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC 27711, USA. http://www.epa.gov/ttn/chief/ap42/ch13/final/c13s0205.pdf .

PM10 – Particulate matter of 10 micrometres or less in diameter

PM2.5 - Particulate matter of 2.5 micrometres or less in diameter

Mining Activities – means:


Wind erosion of overburden

Blasting

Bulldozing Coal

Trucks unloading overburden

Bulldozing overburden

Front-end loaders on overburden

Wind erosion of exposed areas

Wind erosion of coal stockpiles

Unloading from coal stockpiles

Dragline

Front-end loaders on overburden

Trucks unloading coal

Loading coal stockpiles

Graders

Drilling

Coal crushing

Material transfer of coal

Scrapers on overburden

Train loading

Screening; or

Material transfer of overburden

TSP - Total Suspended Particulate Matter

http://www.epa.gov/ttn/chief/ap42/index.html

http://www.epa.gov/ttn/chief/ap42/ch11/final/c11s09.pdf




Appendix B Report Number 610.11105.01000-R1

Page 1 of 4

Emission Factors


Bulldozing coal

The emission factors for bulldozing coal are taken from Table 11.9-2 of Chapter 11.9 of AP-42 (USEPA, 1998):

( ⁄ ) ( )

( )

( ⁄ ) ( ( )

( ) )

( ⁄ ) ( ( )

( ) )

Where M is equal to the coal moisture content and s is equal to the coal silt content as provided in Table 4.

Front end loaders and excavators on coal and overburden

Specific emission factors for the operation of front end loaders and excavators on coal and overburden are not provided within AP-42. However, a default factor for TSP of 0.018 kg/t is provided in Table 11.9-4 of Chapter 11.9 of AP-42 (USEPA, 1998) for the activity of “truck loading by power shovel (batch drop)”. The note provided with this figure however, encourages the user to make use of the predictive emission factor equations in Chapter 13 of AP-42 instead.

The quantity of particulate emissions (kg) generated by a batch drop process (per tonne) (e.g. a truck dumping to a storage pile, or loading out from a pile to a truck) may be estimated using the following expression:

( ⁄ ) ( )

( )

Where EF is the emission factor for TSP, PM10 or PM2.5, k is the aerodynamic size multiplier (0.74 for TSP, 0.35 for PM10 and 0.053 for PM2.5), U is the mean wind speed in m/s and M is the moisture content of coal and overburden (refer Table 4).

An average wind speed of 1.9 m/s has been adopted for the WCPL, based on onsite meteorological monitoring for calendar year 2011.

Material transfer of coal by conveyor

Specific emission factors for the transfer of material by conveyor at transfer points are not provided within AP-42. The Environment Australia Document “National Pollutant Inventory for Mining (Version 3.0)” (June, 2011) identifies that emissions of particulates at miscellaneous transfer points (including conveying) are estimated using the same emission factor as outlined in Front end Loaders and excavators on coal and this emission factor has been adopted within this report, using specific information for coal as outlined in Table 4 of the main report.

Loading coal stockpiles

See Front end Loaders and excavators on coal.


Page 2 of 4

Emission Factors


Wind erosion of coal stockpiles and overburden/disturbed areas

The emission factors for wind erosion of coal stockpiles and overburden are taken from Table 11.9-2 of Chapter 11.9 of AP-42 (USEPA, 1998) as discussed in Section 2.1.1.

( ⁄ )

Where u is equal to the wind speed (m/s). Hourly wind speed data from the WCPL for 8,760 hours

monitored during 2008 has been adopted.

Based on this data, an emission rate of TSP of 37,882 kg/ha/yr has been applied within this assessment. This equates to an average emission rate of 4 kg/ha/hr.

As discussed in Section 2.1, the application of the AP-42 emission factor equation relating to industrial wind erosion of overburden (Chapter 13.2.5) yielded unrealistic emissions when the threshold friction velocity for overburden (and coal dust) was applied. Therefore the emission factor for coal stockpiles has been applied to all areas subject to wind erosion.

No emission factors for PM10 are provided for this emission source within Table 11.9-2 of Chapter 11.9 of AP-42. An assumption that 50% of the TSP is emitted as PM10 has been adopted for the purposes of this assessment. This is in line with the PM10/TSP ratio quoted within the “National Pollutant Inventory for Mining (Version 3.0)” (June, 2011) for wind erosion sources.

Certain emission factors contained within the US EPA emission factor handbook AP-42 do not contain emission factors for PM2.5 as often little validated research has been undertaken to assess the fraction of PM10 which would be emitted as PM2.5 from the wide range of sources involved.

Limited research has been conducted by the Midwest Research Institute (MRI) on behalf of the Western Regional Air Partnership (WRAP) with findings published within the document entitled ‘Background Document for Revisions to Fine Fraction Ratios Used for AP-42 Fugitive Dust Emission Factors’ (MRI, 2006). This document provides seven proposed PM2.5/PM10 ratios for fugitive dust source categories as presented in Table 44.

Table 44 Proposed PM2.5 / PM10 Particle Size Ratios

Fugitive Dust Source AP-42 Section Proposed PM2.5 / PM10 Ratio

Paved Roads 13.2.1 0.15

Unpaved Roads 13.2.2 0.1

Aggregate Handling and Storage Piles 13.2.4 0.1

Industrial Wind Erosion 13.2.5 0.15

Open Area Wind Erosion - 0.15

The PM2.5 / PM10 ratios presented in Table 44 have been used within this report to calculate the emissions of PM2.5 attributable to the activities occurring at WCPL, where specific PM2.5 emission factors or scaling factors are not provided.

Coal crushing and screening

Emission factors for coal crushing are not provided specifically in AP-42 but are taken from AP-42 Chapter 11.24 Metallic Minerals Processing (1982). This approach is also taken within the National Pollutant Inventory for Mining (Version 3.0, June 2011).

Of relevance to this report are emission factors relating to primary coal crushing of high moisture (>4% by weight) coal and coal screening. Default emission factors for TSP and PM10 are provided for coal crushing as:


Page 3 of 4

Emission Factors


( ⁄ )

( ⁄ )

And for screening as:

( ⁄ )

( ⁄ )

Loading coal to trains

The emission factors for loading coal to trains are taken from Table 11.9-4 of Chapter 11.9 of AP-42 (USEPA, 1998):

( ⁄ )

No PM10 or PM2.5 emission factors are available for this source within AP-42, and as previously discussed, the PM10 emission factor is derived by applying a factor of 0.5 to the TSP emission factor whilst the emission factor for PM2.5 is derived by applying the appropriate ratio of 0.1 (refer Table 44) to the PM10 emission factor. Resulting emission factors for PM10 and PM2.5 are presented below.

( ⁄ )

( ⁄ )

Loading coal to trucks

The emission factors for loading coal to trucks are taken from Table 11.9-2 of Chapter 11.9 of AP-42 (USEPA, 1998):

( ⁄ )

( )

( ⁄ )

( )

( ⁄ )

( )

Where M equals the material moisture content as provided in Table 4.

Bulldozing overburden

The emission factors for bulldozing overburden are taken from Table 11.9-2 of Chapter 11.9 of AP-42 (USEPA, 1998):

( ⁄ ) ( )

( )

( ⁄ ) ( ( )

( ) )

( ⁄ ) ( ( )

( ) )


Page 4 of 4

Emission Factors


Where M is equal to the coal moisture content and s is equal to the coal silt content as provided in Table 4.

Loading and dumping of overburden

The emission factors for loading and dumping of overburden are taken from Table 11.9-4 of Chapter 11.9 of AP-42 (USEPA, 1998):

( ⁄ )

No PM10 or PM2.5 emission factors are available for this source within AP-42, and as previously discussed, the PM10 emission factor is derived by applying a factor of 0.5 to the TSP emission factor whilst the emission factor for PM2.5 is derived by applying the appropriate ratio of 0.1 (refer Table 44) to the PM10 emission factor. Resulting emission factors for PM10 and PM2.5 are presented below.

( ⁄ )

( ⁄ )


The emission factors per vehicle kilometre travelled (VKT) for vehicles travelling on unpaved roads are taken from Chapter 13.2.2 of AP-42 (USEPA, 2006).

( ⁄ ) (

)

(

)

Where EF is the emission factor for TSP, PM10 or PM2.5, k is the aerodynamic size multiplier (4.9 for

TSP, 1.5 for PM10 and 0.15 for PM2.5), s is the silt content of the road (%) as taken from Table 4 W is

the average weight of vehicles travelling on the road (in tonnes) and a and b are empirical constants

(for TSP, a = 0.7 and 0.9 for PM10 and PM2.5, b = 0.45 for TSP, PM10 and PM2.5). A conversion from

lb/VKT to kg/VKT is also applied where 1 lb = 281.9 g).

Graders operating on unpaved roads

The emission factors for graders is taken from Table 11.9-2 of Chapter 11.9 of AP-42 (USEPA, 1998):

( ⁄ ) ( )

( ⁄ ) ( )

( ⁄ ) ( )

Where S is equal to the silt content of roads as provided in Table 4.

Appendix C Report Number 610.11105.01000-R1

Page 1 of 1

ASSAY CERTIFICATES


SOIL ANALYSIS REPORT

Client AECOM Job No. 2727

Project: 60248386 Page 1 of 4

Soil Samples

Description Received 16-Mar-12 Date: 23-Mar-12

Report To: Ralph Brown

Mass (g) = 360.3

WET SIZING

Cumulative

Mass (g) Mass % Mass %

+ 4.0 136.4 40.2 40.2

- 4.0 + 2.36 27.9 8.2 48.5

- 2.36 + 1.00 31.5 9.3 57.8

- 1.00 + 0.500 19.3 5.7 63.5

- 0.500 + 0.300 11.7 3.5 66.9

- 0.300 + 0.150 13.4 4.0 70.9

- 0.150 + 0.075 11.2 3.3 74.2

- 0.075 87.5 25.8 100.0

Total 338.9

Notes

1. Samples were wet sized using a series of square aperture sieves

Reported By:

Sample : CH1Sampled 16/03/12

FractionalSize Fraction (mm)

5/11 McIntosh Drive, Mayfield West NSW 2304

Phone 02 4967 7880




Soil Samples



Mass (g) = 356.0

WET SIZING

Cumulative


+ 4.0 63.8 19.2 19.2

- 4.0 + 2.36 18.7 5.6 24.8

- 2.36 + 1.00 24.2 7.3 32.1

- 1.00 + 0.500 19.9 6.0 38.0

- 0.500 + 0.300 16.6 5.0 43.0

- 0.300 + 0.150 27.5 8.3 51.3

- 0.150 + 0.075 22.2 6.7 58.0

- 0.075 139.9 42.0 100.0

Total 332.8

Notes


Reported By:

Sample : CH2Sampled 16/03/12

Size Fraction (mm) Fractional


Phone 02 4967 7880




Soil Samples



Mass (g) = 258.5

WET SIZING

Cumulative


+ 4.0 35.5 14.3 14.3

- 4.0 + 2.36 9.8 3.9 18.2

- 2.36 + 1.00 11.5 4.6 22.8

- 1.00 + 0.500 11.7 4.7 27.5

- 0.500 + 0.300 11.4 4.6 32.1

- 0.300 + 0.150 19.4 7.8 39.9

- 0.150 + 0.075 19.6 7.9 47.7

- 0.075 130.2 52.3 100.0

Total 249.1

Notes


Reported By:

Sample : CH3


Sampled 16/03/12


Phone 02 4967 7880




Soil Samples



Mass (g) = 504.2

WET SIZING

Cumulative


+ 4.0 32.9 6.8 6.8

- 4.0 + 2.36 4.3 0.9 7.7

- 2.36 + 1.00 6.7 1.4 9.1

- 1.00 + 0.500 14.2 2.9 12.0

- 0.500 + 0.300 17.5 3.6 15.7

- 0.300 + 0.150 77.9 16.2 31.8

- 0.150 + 0.075 76.6 15.9 47.7

- 0.075 252.1 52.3 100.0

Total 482.2

Notes


Reported By:

Sample : CH4


Sampled 16/03/12


Phone 02 4967 7880

Appendix D Report Number 610.11105.01000-R1

Page 1 of 1

Standard Operating Procedures for Dust Management at WCPL


Standard Work Practice

Dust Management

4842-SE-SWP1021 10/01/2012 Page 1 of 4

“Unless marked “CONTROLLED” in RED on the front page when printed, the printed copy is an uncontrolled document”

Application

To provide a standard work practice for the management of dust and response to SMS High Dust Alerts.

Key hazards

The key hazards associated with undertaking this task are:

Not applicable

References

DM-SE-F103 Downer EDI Mining Wambo Environmental Management Plan

DM-SE-P15 Downer EDI Mining dust monitoring and control

Wambo Environmental Protection Licence No. 529

EMS 001 Wambo Coal Environmental Management Strategy

EMP 008 Wambo Air Quality Monitoring Program

4842-DM-TR-SWP33 Operation of a Bulk Water Truck

Requirements

Wambo Coal operates four dust monitoring stations that provide real time information to Downer EDI Mining operational personnel. This is achieved by an automatically produced SMS alert being sent from dust monitors to the Open Cut Examiner (OCE) (Production 7) mobile phone in the event that high dust levels are detected. Dust alarms are triggered when the 15 minute PM10 results are above 90µg/m3 for two consecutive 15 minute periods. If the 15 minute results come below 75µg/m3 and then go above 90µg/m3 again it is a new dust alarm. The alarms filter out wind conditions so alarms are only received when the wind is blowing from the direction of Wambo’s operations.

Table 1: AQ1, AQ2, AQ3 and AQ4 Dust Monitoring Locations

AQ04

AQ01

AQ02

AQ03


Dust Management

4842-SE-SWP1021 10/01/2012 Page 2 of 4


1. General Dust Management (Daily Operations)

Ensure water carts are mobilised as first priority before trucks enter circuit

Call water carts to areas of priority

Ensure full utilisation of available water carts by scheduling re-fuelling, crib breaks and filling of carts so that they are not all parked up at the same time

Minimise travel time of empty water carts by directing water cart operators to ensure tanks are full before heading to areas that are a greater distance from the fill point.

2. Dust Reduction Methods (Low Level to High Level response)

Priority Dust Reduction Method

1 Assign water cart to high priority areas

2 Reduce speed of trucks

3 Utilise lower RL dumps

4 Stop operations in high exposure areas i.e. topsoil loading and dumping, rehab areas

5 Minimise areas of operation (shut down a circuit/s)

6 Stop all operations

3. SMS Received – First Response

In the event that an SMS Alert for high dust level is received by the OCE (Production 7) or excessive dust is noted on site but an SMS Dust Alert has not been received the following steps should be taken:

Identify the major sources of dust

Apply appropriate actions listed in ‘Dust Reduction Methods’

Record information in 4842-SE-F1027 Dust Management Response located in the OCE office.

Production 7 is responsible for responding to SMS High Dust alerts.

Competency required

None Applicable

Personal Protective Equipment (PPE) / Special equipment

As per site requirements.

Records

SMS Dust Alert responses and any exceptional actions taken to reduce dust emissions without the prompting of the SMS high dust alert must be recorded by the end of each shift. Completed records to be filed in Environment File 11 located in the HSE Office

4842-SE-F1027 Dust Management Response


Dust Management

4842-SE-SWP1021 10/01/2012 Page 3 of 4


4842-SE-SWP1021 - Assessment Paper

Employee Name: Assessors Name:

Employee Signature: Assessors Signature:

Project: Date:

/ /

The trainee is required to answer all questions correctly in order to be deemed to have adequate understanding of the SWP. The trainer/assessor shall re-train/re-assess all incorrect answers.

Question and Response R-T C

1. List 3 actions that can help manage daily dust levels on site.

1/_____________________________________________________________

2/_____________________________________________________________

3/_____________________________________________________________

2. Dust alarms are triggered when the 15 minute PM10 results are above 90µg/m3 for two consecutive 15 minute periods.

True False

3. What must the OCE do when a SMS Dust Alert is received?

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

4. Who is responsible for responding to SMS High Dust alerts?

_______________________________________________________________

_______________________________________________________________


Dust Management

4842-SE-SWP1021 10/01/2012 Page 4 of 4


5. List 2 ‘Dust Reduction Methods’.

1/_____________________________________________________________

2/_____________________________________________________________

6. What information relating to dust management should be recorded by the OCE at the end of each shift?

_____________________________________________________________

_____________________________________________________________

_____________________________________________________________

Assessor

Assessor Comments: (i.e. List any questions that were retrained / re-assessed)

Please sign and date when the “SWP Assessment” is completed.

The candidate is hereby deemed competent on the date of assessment.

Assessor Name (Print) Assessor Signature Date

/ /

Candidate Name (Print) Candidate Signature

I understand the requirements of this SWP.

Date

/ /

Document Revision History

Ver Date Author Reviewed Approved Reason RA Ref.

1 10/01/12 S.Steward K.McDermott e.g. Initial issue Insert RA No.

Dust Management Records

4842-SE-F1027 Dust Management Records 10/01/2012 Page 1 of 2

Name: Date: Time:

SMS alert prompt? YES / NO Monitoring Station (circle): AQ01 AQ02 AQ03 AQ04

What was your opinion of dust levels at the time?

What was the primary cause of dust?

What actions were undertaken to reduce dust levels?

Name: Date: Time:





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an a

s p

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itted b

y la

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o p

art o

f it may b

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pro

duced,

sto

red in

a re

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Dust Management Records

4842-SE-F1027 Dust Management Records 10/01/2012 Page 2 of 2

Name: Date: Time:





Name: Date: Time:





Appendix E Report Number 610.11105.01000-R1

Page 1 of 1

Cost Tables for Dust Suppression Measures -WCPL


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