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Print Date 19/10/2017

ORIGINAL ISSUE DATE 1 February 2003

VERSION / DATE OF ISSUE 5 / June 2017

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DOC # DRA_8-034_PRO_Air Quality Management and Monitoring Plan

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Anglo Coal (Drayton Management) Pty Ltd Policies and Procedures

Air Quality Management and Monitoring Plan

Drayton Management System Standard

Air Quality Management and Monitoring Plan

Author: Name Brooke York

Title Environmental Officer

Signature Date 18/10/2017

Reviewer: Name Matt Lord

Title Environmental Superintendent

Signature Date 18/10/2017

Authoriser: Name Darren Pisters

Title Mining Engineering Manager

Signature Date 18/10/2017

This document is controlled whilst it remains in the Drayton Intranet

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Print Date 19/10/2017

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VERSION / DATE OF ISSUE 5 / June 2017

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Revisions

Issue Issue Date Author Reviewer Authoriser

1 February 2003 P Simpson P Forbes T Hulme

2 November 2005 P Simpson P Forbes H Hayes

3 June 2008 P Simpson P Forbes M Heaton

4 November 2013 J Benson P Forbes C Robertson

5 June 2017 B York / N Dobbins (Hansen Bailey)

M Lord D Pisters

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Distribution List

Distributed to:

General Manager’s Office (current originals)

Administration Central File (originals of previous versions)

NSW Department of Planning and Environment

Anglo American website

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Table of Contents

1 PURPOSE ...................................................... 6

2 SCOPE ......................................................... 6

3 DEFINITIONS .................................................... 6

4 PROCEDURAL REQUIREMENT ...................................... 7

4.1 Responsibilities ............................................. 7

4.2 Audit/Review Schedule ....................................... 7

4.3 Records Management ........................................ 7

4.4 Revision Status ............................................. 7

4.5 References ................................................ 8

4.6 Air Quality Objectives and Targets .............................. 9

4.7 Air Quality Parameters ....................................... 9

4.8 Statutory Requirements ..................................... 10

4.9 Current Control and Mitigation Measures ........................ 13

4.10 Proactive and Reactive Management of Air Quality ................ 14

4.10.1 Overview ........................................... 14

4.10.2 Trigger Action Response Plan ........................... 14

4.11 Equipment Availability and Utilisation .......................... 17

4.12 Monitoring ................................................ 18

4.13 Reporting of and Effectiveness of Air Quality Management System .... 26

4.14 Spontaneous Combustion Odour and Fume Management ........... 26

4.15 Meteorological Monitoring ................................... 26

4.16 Complaints Handling ........................................ 27

4.17 Handling Exceedances ...................................... 27

4.18 Cumulative Impacts of Mining Operations ....................... 27

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5 APPENDICES ................................................... 28

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Document Information

1 PURPOSE

Anglo American’s Drayton Mine was granted project approval by the NSW Department of Planning on 1st February 2008 (DA 06_0202) to further extend current mining operations until 2017, incorporating increased production and additional infrastructure. In addition, Drayton was also granted approval for project modifications in October 2009 and February 2012. The purpose of this management plan is to provide a framework for air quality management, monitoring and controls to be implemented in relation to continued operations at Anglo American’s Drayton Mine. This procedure also covers operations within the Antiene Rail Spur and Drayton Rail Loop that are approved under DA 106-04-00 as issued November 2002. Mining operations ceased at the site in September 2016. The document has been revised to reflect the changes in staffing and responsibilities since mining operations ceased and include a Trigger Action Response Plan. Rehabilitation activities will continue to be undertaken, as guided by the Mining Operations Plan (MOP).

2 SCOPE

This procedure describes:

The Drayton air quality management system

Air quality objectives and targets

Legal and other requirements with regard to air quality

Controls and mitigation measures

Air quality monitoring program

Community and stakeholder engagement

Investigating complaints and exceedences

Reporting requirements of air quality

Managing the Cumulative Air Quality Impacts of Mining

3 DEFINITIONS

Air Quality The ambient levels of particulate matter and its constituents, which remain in the surrounding atmosphere

CHP Coal Handling Plant

DP&E NSW Department of Planning and Environment

EPA NSW Environmental Protection Authority

PM Particulate Matter – measured in micrograms per cubic meter (µg/m3)

UHAQMN Upper Hunter Air Quality Monitoring Network

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4 PROCEDURAL REQUIREMENT

4.1 Responsibilities

Environment Superintendent The Environment Superintendent shall be responsible for monitoring and recording all air quality parameters related to Anglo American’s Drayton Mine and associated Antiene Rail Spur. They shall ensure all air quality monitoring and analysis is undertaken in accordance with the relevant Australian Standard. The Environmental Superintendent is also responsible for supplying technical information regarding air quality issues and to assist in managing air quality at the Anglo American Drayton Mine and Antiene Rail Spur. The Environmental Superintendent is authorised to direct the modification or ceasing of works if environmental harm has occurred or is likely to occur. Mine Manager The Mine Manager shall ensure all mining equipment is operated to minimise dust emissions and shall also ensure all procedures and regulations are followed regarding the management of dust emissions. The Mine Manager shall ensure that there are sufficient resources to manage dust and those resources are allocated to dust management as required. Maintenance Superintendent The Maintenance Superintendent shall ensure all maintenance is scheduled and undertaken in a prompt and efficient manner on all equipment related to the minimisation of dust on equipment.

4.2 Audit/Review Schedule

This management plan shall be subject to a review every three years or as otherwise directed by the Director-General. It may also be reviewed as a result of findings from independent audits or in light of any significant changes, both operational and procedural to the approved Environmental Assessment. The Environmental Superintendent shall be responsible for coordinating such reviews.

4.3 Records Management

All records of monitoring details required under this management plan will be kept on file on the mine site for a period of not less than four years following measurement. Analysis data is entered into the Drayton Environmental Database. Data entry is the responsibility of the Environment Superintendent (or delegate).

4.4 Revision Status

November 2005 Changes in this revision include:

Updating into Anglo Coal Australia procedure format

Reorganisation of procedure

Updating responsibilities of key personnel This management plan was forwarded to Muswellbrook Shire Council and the Department of Environment and Conservation (EPA) on 19th September 2005 for review. No comments were received from either party consulted.

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June 2008 Changes to the original Air Quality Management Plan as a result of new Project Approval from the Department of Planning NSW are as follows:

Updating with impact assessment criteria

Updating land acquisition criteria

Review of operating conditions

Referencing spontaneous combustion management

Implementation of air quality monitoring plan October 2012 Scheduled review undertaken. Changes include: changes in position titles and accountabilities, changes in operational activities. This review takes into account conditions from Modification 2 approval. November 2013 This management plan was revised to include recommendation from the ‘Drayton 2012 Independent Environmental Compliance Audit’ and the introduction of a new interactive dust management system. This revision also included additional commitments under the Drayton Pollution Reduction Program. June 2017 This management plan was updated with the calibrated Trigger Action Response Plan.

4.5 References

Project Approval 06-0202 – Drayton Mine Extension (inc Mod 1 and Mod 2)

Development Consent 106-04-00 - Drayton Rail Loop and Antiene Rail Spur

Anglo Coal Drayton Mine Environmental Assessment 2007

Anglo Coal Drayton Mine Environmental Assessment Modification 1 (2009)

Anglo Coal Drayton Mine Environmental Assessment Modification 2 (2012) Environment Protection Licence 1323

Australian Standard 3580.9.3 - 2003 Methods For Sampling and Analysis of Ambient Air – Determination of Suspended Particulate Matter – Total Suspended Particulate Matter (TSP) – High Volume Sampler Gravimetric Method

Australian Standard 3580.9.6 – 2003 Methods For Sampling and Analysis of Ambient Air – Determination of Suspended Particulate Matter – PM (sub) 10 High Volume Sampler With Size-Selective Inlet – Gravimetric Method

Australian Standard 3580.10.1 – 2003 – Methods For Sampling and Analysis of Ambient Air – Determination of Particulate Matter – Deposited Matter – Gravimetric Method

SHE Calibration Procedure – Anglo American Drayton 2012

Community Complaints and Enquiries Procedure - Anglo American Drayton 2012

Spontaneous Combustion Management Plan – Anglo American Drayton 2012

‘The Anglo Environmental Way – Volume 2: Environmental Performance Standards’

Anglo American Reference Document 103 – Air Quality Performance Requirement

Blasting Monitoring and Management Plan – Anglo American Drayton 2012

Independent Environmental Compliance Audit_ Drayton Coal – Parsons Brinkerhoff

Independent Environmental Compliance Audit_ Drayton Coal – AECOM 2016 Drayton Coal Mine Pollution Reduction Program – Assessment and Best Practice – PAE Holmes 2012.

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4.6 Air Quality Objectives and Targets

Anglo American Metallurgical Coal has a ‘Zero Harm’ vision; “Our vision is to minimise harm to the environment by designing, operating and closing all of our operations in an environmentally responsible manner” It is Drayton’s objective that air quality shall be managed to a level that does not cause harm to the environment or community. Drayton will manage its operations to remain within air quality compliance criteria as listed in section 4.8 – Statutory Requirements. It is Drayton’s target to reduce dust emissions through the implementation of effective mitigation measures and controls. Annual Targets The following targets indicate the levels not to be exceeded at any residence, on privately owned land or on more than 25% of any privately owned land. An assessment of the analysis of monitoring data against these criteria will be included in Drayton’s Annual Environment Management Report.

Table 1: Long Term Impact Assessment Criteria for Particulate Matter

Pollutant Criterion Agency

Total Suspended Particulate Matter (TSP)

90µg/m³ (annual goal) NSW DP&E

Particulate Matter <10µm (PM10)

30µg/m³ (annual goal) NSW DP&E

Table 2: Short Term Impact Assessment Criteria for Particulate Matter

Pollutant Criterion Agency

Particulate Matter <10µm (PM10)

50µg/m³ (24 hr average)

NSW DP&E

Table 3: NSW DP&E Long Term Impact Assessment Criteria for Deposited Dust

Pollutant Averaging Period Maximum Increase in Deposited Dust Levels

Maximum Total Deposited Dust Level

Deposited Dust Annual 2g/m²/month 4g/m ²/month

(Dust is assessed as insoluble solids as defined in AS 3580 10.1-2003 (AM-19))

4.7 Air Quality Parameters

Specific parameters included in this Air Quality Management and Monitoring Plan include:

Dust deposition

Dust concentration – Particulate Matter

Dust Deposition Dust deposition (or fallout) refers to the amount of dust that is deposited on the ground over a set period of time. It is measured in units of grams per square metre per month (g/m2/month) and is a measure of amenity-based impacts. Dust Concentration Dust concentration refers to the amount of dust present in a specific volume of air (usually

measured in units of micrograms per cubic metre g/m3).

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Dust concentration can be categorised as Total Suspended Particulates (TSP) or Particulate

Matter < 10m diameter (PM10), < 2.5m diameter (PM2.5). TSP refers to the airborne fraction of dust that is respirable. These dust particles have an aerodynamic diameter of less than

50m. PM10 and PM2.5 refers to the portion that, on entering the lungs of people, may cause

respiratory problems. PM10 particles have an aerodynamic diameter of less than 10m while

PM2.5 particles have an aerodynamic diameter of less than 2.5m. TSP, PM10 and PM2.5 are a measure utilised for both short-term and long-term particulate matter criteria.

4.8 Statutory Requirements

Current statutory requirements are set out in Drayton’s development consents 06_0202 and 106-04-00, Environmental Protection Licence (EPL) 1323 and Mining Lease conditions. These are enforced by the DP&E, EPA and the Department of Resources and Energy respectively. Drayton’s EPL 1323 states 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, or wind-blown, or traffic generated dust. Relevant conditions within Development Consent 06_0202 and include:

Table 4: Statutory Requirements for Development Consent 06-0202

Condition Details Reference

S3.21 Impact Assessment Criteria: The Proponent shall ensure that the dust emissions generated by the project do not cause additional exceedences of the air quality impact assessment criteria listed in Tables 6. 7 and 8 at any residence, on privately-owned land, or on more than 25 percent of any privately-owned land.

4.6 4.7

S3.22 Land Acquisition Criteria: If the dust emissions generated by the project exceed the criteria in Table 8. 9 and 10 at any residence on privately-owned land, or on more than 25 percent of any privately-owned land, the Proponent shall, upon receiving a written request form the landowner, acquire the land in accordance with the procedures in conditions 8-10 of Schedule 4.

4.6

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S3.23 Operating Conditions: The Proponent shall: a) ensure any visible air pollution generated by the project is assessed regularly, and that

mining operations are relocated, modified, and/or stopped as required to minimise air quality impacts on privately owned land;

b) ensure that the real-time air quality monitoring and metrological monitoring data are assessed regularly, and that mining operations are relocated, modified and/or stopped as required to ensure compliance with the relevant air quality criteria; and

c) implement all practicable measures to minimise the off-site odour and fume emissions generated by any spontaneous combustion on site,

to the satisfaction of the Director-General.

4.6 4.7 4.9 4.10 4.11

S3.24 Spontaneous Combustion: The Proponent shall prepare and implement a Spontaneous Combustion Management Plan for the project to the satisfaction of the Director-General. This must be:

a) prepared in consultation with the OEH and DRE by suitable qualified expert/s whose appointment/s have been approved by the Director-General; and

b) submitted to the Director-General for approval within 6 months of this approval.

4.6 4.14

S3.25 Air Quality Management Plan: The Proponent shall prepare and implement an Air Quality and Greenhouse Gas Management Plan for the project to the satisfaction of the Director-General. This plan must:

a) be submitted to the Director-General by 31 October 2012 for approval; b) describe the measures that would be implemented(including a real time air quality

management system that employs both reactive and proactive mitigation measures) to ensure:

best management practice is being employed;

compliance with the relevant conditions of this approval: c) describe the proposed air quality management system; d) include an air quality monitoring program that;

uses a combination of real-time monitors and supplementary monitors to evaluate the performance of the development;

adequately supports the proactive and reactive air quality management system;

includes PM2.5 monitoring (although this obligation may be satisfied be the regional air quality monitoring network if sufficient justification is provided);

evaluates and reports on the effectiveness of the air quality management system;

includes a protocol for determining any exceedances of the relevant conditions of this consent; and

e) include a protocol that has been prepared in consultation with the owners of nearby mines (including the Mt Arthur mine) to minimise the cumulative air quality impacts of the mines.

4.6 4.10 4.12 4.13 4.17 4.18

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Anglo American also holds a Development Consent (106-04-00) that is designated for the operation of the Drayton Rail Loop and Antiene Rail Spur. The statutory requirement relevant to Development Consent 106-04-00 is included in Table 5.

Table 5: Statutory Requirements for Development Consent 106-04-00

Condition Details Reference

5.1 Air Quality Management and Monitoring: Dust Management Plan

a) The Applicant shall, within 3 months of this consent, prepare a Dust Management Plan for the Drayton rail loading facility, detailing air quality safeguards and procedures for dealing with dust emissions to the satisfaction of the Director-General. The Plan shall be prepared in consultation with the owners of the Bayswater rail loading facilities with the aim of achieving a consistent approach in the preparation of the Dust Management Plans for the Drayton and Bayswater rail facilities respectively. The plan shall include, but not limited to, details of:

The identification of dust affected properties and the relevant dust limits consistent with the EIS;

Specifications of the procedures for the dust monitoring program for the purposes of undertaking independent dust investigations, including joint investigations with the owners of the Bayswater rail loading facility and rail loop where necessary;

Outline the procedure to notify property owners and occupiers likely to be affected by dust from the operations

The establishment of a protocol for handling dust complaints that include recording, reporting and acting on complaints.

Appropriate mechanisms for community consultation.

Outlining mitigation measures to be employed to minimise dust emissions.

Equipment to be available and used to control dust generation.

Methods to determine when and how operations are to be modified to minimise the potential for dust emissions if the relevant criteria are exceeded.

Identification of longer-term strategies directed towards mitigating dust levels that exceed the relevant EPA dust amenity criteria.

Details of locations for dust monitoring and deposition gauges (including existing Drayton monitoring locations if proposed to be used.) at residential areas and frequency of monitoring, as agreed with the EPA.

A program to continue baseline monitoring undertaken prior to development consent.

Details of the integration of this plan with the Drayton mine dust management plan and this plan’s inter-relationship with the Bayswater rail facilities dust management plan.

Air Quality and Dust Monitoring b) The Applicant shall:

(i) Undertake monitoring at locations described in the Dust Management Plan (Condition 5.1(a));

(ii) Use existing relevant Drayton dust deposition and total suspended particulate (TSP) monitoring gauges for the Drayton Rail Loop and Antiene Rail Spur operations, including sites for monitoring impacts of dust at the nearest non-mined owned residences, and any additional locations as may be determined by the Dust Management Plan referred to in Condition 5.1(a);and

(iii) Provide all results and analysis of air quality monitoring in the AEMR, including a determination of the annual dust deposition rate in gm/m 2 /month, which shall be plotted in the AEMR.

c) Monitoring of dust deposition and the concentration of PM10 particulate matter in ambient air must be carried out at locations agreed to in consultation with the EPA. The sampling method, units of measure, interval and frequency of monitoring will be as set out in the "Approved Methods for Sampling and Analysis of Air Pollutants in NSW", or its latest version.

d) In the event that a landowner or occupier considers that dust from the project at their dwelling or over more than 25% of their vacant land is in excess of the relevant EPA dust amenity criteria, and the Director-General is satisfied that an investigation is required, the Applicant shall upon the receipt of a written request: (i) Consult with the landowner or occupants affected to determine their concerns; (ii) Make arrangements for and bear the cost of, in consultation with the owner of

the Bayswater rail loading facility and rail loop, appropriate independent dust investigations in accordance with the Dust Management Plan, and to the satisfaction of the Director-General, to quantify the impact and determine the source of the effect;

(iii) Modify the operation in accordance with the Dust Management Plan if exceedences are demonstrated to result from the operation. This shall include:

Introduction of additional controls, either of dust generation from individual sources on the site or on site operations or modify operations, to ensure that the dust criteria are achieved; and / or

4.6 4.7 4.10 4.12

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Enter into an agreement with the landowner, or provide such forms of benefit or amelioration as may be agreed between the parties as providing acceptable amelioration/benefit for the dust levels experienced. The agreement may also be made in consultation with the owner of the Bayswater rail loading facility and rail loop.

Note: Vacant land in this condition means the whole of the lot in a current plan registered at the Land Titles Office as at the date of this consent that does not have a dwelling situated on the lot and is permitted to have a dwelling on that lot.

e) If the independent dust investigations in sub-clause (e) above confirm that dust limits are in excess of the relevant EPA dust amenity criteria, the Applicant shall, at the written request of the owner, acquire the relevant property. Acquisition shall be in accordance with the procedures set out in Condition 10.1, 10.2 and 10.3.

f) Further independent investigations shall cease if the Director-General is satisfied that the relevant consent limits or relevant EPA dust amenity criteria are not being exceeded and are unlikely to be exceeded in the future.

5.2 Dust Suppression and Control c) Activities occurring at the premises must be carried out in a manner that will minimise

emissions of dust from the premises.

4.6 4.9

4.9 Current Control and Mitigation Measures

Drayton is committed to managing dust emissions by implementing operational controls that are necessary to assist in the management of emissions that may have adverse impacts on air quality. Some of the measures outlined below are long term strategies such as progressive rehabilitation and dumping and topsoil stripping practices. The following measures are used at Drayton to control air emissions:

Table 6: Air Quality Control Measures and Implementation Program

Measure By When By Who Current Status Implement available measures to keep visible dust as low as possible from offsite at all times

Immediate and ongoing

Mine Manager Implemented and ongoing

Water tankers to be utilised at all times that earthworks are being undertaken to minimise dust emissions from roads and work areas

Immediate and ongoing

Mine Manager Water trucks to be used at all times that dust suppression is required.

Overburden is dumped in low level lifts, with outer berms maintained by dozers

Immediate and ongoing

Mine Manager Implemented and Ongoing

Blasting is carried out using gravel stemming which contains blast within the ground and minimises dust

Immediate and ongoing

Mine Manager / Drill & Blast Coordinator

(if appointed)

Implemented and ongoing

Rehabilitation of mined areas is progressively achieved

Immediate and ongoing

Mine Manager / Environmental Superintendent

Rehabilitation targets set annually based on MOP and internal Anglo requirements. Areas are reported in AEMR.

In known or suspected high dust areas, processes are modified to ensure effective management of visible dust levels

Immediate and ongoing

Mine Manager Implemented and ongoing.

Operations, including those associated with rehabilitation are to be modified and/or ceased when visible dust emissions are unsatisfactory

Immediate and ongoing

Mine Manager Implemented and ongoing.

Monitoring of air quality emissions Immediate and ongoing

Environmental Superintendent or

Delegate

Monitoring program remains active. Data and analysis reported in AEMR

Implementation of TARPs as discussed in Section 4.10.2

Immediate and ongoing

Environmental Superintendent or

Delegate

Implemented and ongoing

Review TARPS and refine over time to reflect current operations

Ongoing Environmental Superintendent or

Delegate

Implemented and ongoing

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4.10 Proactive and Reactive Management of Air Quality

4.10.1 Overview

Drayton coal mine currently proactively forecast periods where air quality may be impacted due to mining operations. This is currently being conducted through the use of weather forecast derived from the Hunter Valley Meteorological Sounding Group that Drayton is a member. Drayton receives the predicted wind speed, wind direction and temperature for 23 different heights above the surface up to 1760m for each hour of the day at Drayton. This information, together with added forecasting parameters from an external consultancy such as rainfall, is assessed on a regular basis whist earthworks are being conducted and operational decisions can be made taking into account this information. Drayton also utilises ‘EnviroSuite’ software to provide action alerts when:

1. Unfavourable weather conditions are forecasted at Drayton; and 2. Real time dust monitors exceed predefined triggers.

Drayton has a number of PM10 real time dust monitors. These units provide feedback of real time PM10 dust levels to the Drayton operation where employees can monitor the data and make operational decisions based on this real time data. If PM10 dust levels exceed predefined triggers over a 30 minute period and the operation is causing the elevated dust levels, the Environmental Superintendent will be notified. The Environmental Superintendent will then assess visible dust within operational work areas to determine the appropriate course of action to reduce dust levels. The appropriate courses of action include those listed in Table 6 with specific consideration to modifying and/or ceasing activities. Alerts sent to relevant employees are based on a Trigger Action Response Plan (TARP) as detailed in Section 4.10.2. The Upper Hunter Air Quality Monitoring Network (UHAQMN) will be used to assess regional PM10 dust levels and to identify areas of high dust levels based on wind direction. Drayton relies on the UHAQMN Muswellbrook unit to monitor the PM2.5 levels in the local area. The Muswellbrook unit is approximately 8km from the Drayton operation and is the closest PM2.5 monitor to Drayton. Alerts from this monitor are sent to several staff at Drayton including the Environmental Superintendent who can investigate the potential impacts from the Drayton operation. During active mining, Drayton mine was operated 24 hours a day, 7 days a week. Although operations have presently ceased, visual dust levels continue to be monitored onsite to ensure that all trafficable areas, former coal storage areas and equipment manoeuvring areas are maintained in a condition that minimises the emissions of wind-blown or traffic generated dust. Complaints that are received in relation to air quality are managed as outlined in section 4.16.

4.10.2 Trigger Action Response Plan

The Drayton Coal Dust Management Trigger Action Response Plan (TARP) is based on:

Modelled weather forecast data;

Real-time weather station data;

Real-time PM10 (dust) monitoring data; and

Visual assessment.

The forecast and real-time data are generated and/or managed by the EnviroSuite system. EnviroSuite enables proactive management of dust from Drayton’s operations by:

Automatically generating a forecast dust risk report every morning, during periods where rehabilitation or other potential dust generation activities are taking place, to provide operations with advanced notice of expected weather conditions; and

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Sending real-time dust risk alerts, based on a set of tiered triggers, using continuous weather and PM10 monitoring data.

The data used for triggers in the Dust Management TARP are outlined in Table 7.

Table 7: Trigger Values

Parameter Source Method

Forecast weather data EnviroSuite – WRF(a) model Predictive modelling

Real-time weather data Automatic weather station Real-time monitoring

Real-time PM10 data E-Samplers (b) Real-time monitoring

Visual dust Operations personnel Real-time monitoring

a. Weather Research & Forecasting model

b. E-Sampler continuous particulate monitors

The trigger criteria will be subject to further refinement over time. As such, the triggers discussed in the following sections are indicative only. Predictive Triggers A forecast dust risk report is generated by EnviroSuite and distributed every morning to the relevant people on site. The meteorological parameters used to assess air quality include; wind, rain and atmospheric stability. The indicative wind trigger criteria for Drayton Coal include 1-hour average wind speeds and maximum 10-minute average wind gusts. Rain is considered when more than 2 mm of rainfall is predicted within an hour. Any less than this is considered “no rain”. The stability of the atmosphere plays a large role in determining the dispersion of a plume. For the purpose of the forecast and real-time triggers, the atmosphere is considered stable when the mixing height is less than 200 m. Table 8 outlines the indicative forecast dust risk triggers.

Table 8: Forecast Dust Risk Triggers

Risk Colour Wind Speed a Rain b Atmospheric Stability c Moderate Yellow Less than 1.5 m/s No rain Stable conditions

Low Green Less than 8 m/s Rain or No rain Unstable

Moderate Yellow Greater than 8 m/s No rain Unstable

High Orange Greater than 10 m/s No rain Unstable

Extreme Red Greater than 14 m/s No rain Unstable

a. 1-hour average wind speed

b. No rain = less than 2 mm in past hour

c. Stable atmosphere = mixing height less than 200m

Real-time Triggers Tiered dust-management alerts for real-time meteorological conditions are generated using data from the CHP automatic weather station. The indicative trigger conditions for these alerts are outlined in Tables 9 and 10.

Table 9: Real-time Weather Data Triggers

Alert Level Colour Wind Speed a Rain b Atmospheric Stability c

1 Yellow Less than 1.5 m/s No rain Stable conditions

0 Green Less than 8 m/s Rain or No rain Unstable

1 Yellow Greater than 8 m/s No rain Unstable

2 Orange Greater than 10 m/s No rain Unstable

3 Red Greater than 14 m/s No rain Unstable

a. 1-hour average wind speed

b. No rain = less than 2 mm in past hour

c. Atmospheric stability derived using real time parameters measured at weather station

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Table 10: Real-time Weather Data Triggers

Max wind gusts (m/s) Frequency a

1 2 3 4

<12 m/s

Low Low Low Low

12 -15 m/s Low Low Moderate Moderate

15 – 18 m/s Moderate Moderate High High

18 – 21 m/s Moderate High High Extreme

>21

m/s

High High Extreme Extreme

a. Number of 10-minute periods that record maximum gust value in a 1 hour period

Four e-samplers are strategically located around Drayton’s operations to calculate the mine’s PM10 contribution. PM10 is monitored continuously by the e-samplers and a new average concentration is sent to EnviroSuite every 5 minutes. The indicative trigger conditions relating to PM10 are shown in Tables 11 and 12.

Table 11: Real-time 3 hour Average PM10 Concentration Triggers

PM10 Concentration a, b E-Samplers

ES-

01

ES-02 ES-

03

ES-

04

<60 µg/m³ Low Low Low Low

60 – 80 µg/m³ Moderate Low Moderate Moderate

80 – 100 µg/m³ High Low High High

100 -135 µg/m³ Extreme Low Extreme Extreme

135 – 180 µg/m³ Extreme Moderate Extreme Extreme

180 – 225 µg/m³ Extreme High Extreme Extreme

> 225 µg/m³ Extreme Extreme Extreme Extreme

a. PM 10 concentration data are combined with wind criteria shown in Table 6 to determine mine dust contribution at

each e-sampler.

b. 3 hour rolling average mine contribution recorded at any e-sampler

c. Contribution from mine only (uses upwind/downwind values, over 36 consecutive 5 minute periods)

d. The higher trigger values for ES-02 account for its closer proximity to dust sources

Table 12: Wind Criteria to Determine Mine Dust Contribution

Downwind Sampler Wind Direction (from) Upwind Sampler a

ES-01 90o to 180o (E to S) ES-02

ES-03

ES-02 280o to 355o (W to N) ES-01

ES-03

ES-03 280o to 355o (W to N) ES-01

225o to 280o (SW to W) ES-04

175o to 225o (S to SW) ES-02

ES-04 355o to 90o (NNW to E) ES-01

ES-03

90o to 225o (E to SW) ES-02

a. Upwind sampler concentrations are subtracted from the downwind sampler when the wind criteria are met. If a

resulting mine PM 10 contribution meets the criteria in Table 5 then the corresponding Alert (shown in

Section 4) is generated.

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Table 13 provides a set of triggers based on 24 hour rolling average PM10 concentrations recorded at the locations of the onsite e-samplers.

Table 13: Real-time 24 hour Average PM10 Concentration Triggers

PM10 Concentration a, b E-Samplers c

ES-

01

ES-02 ES-

03

ES-

04

<45 µg/m³ Low Low Low Low

45 – 60 µg/m³ Moderate Low Moderate Moderate

60 – 75 µg/m³ High Low High High

75 - 100 µg/m³ Extreme Low Extreme Extreme

100 - 115 µg/m³ Extreme Moderate Extreme Extreme

115 - 130 µg/m³ Extreme High Extreme Extreme

> 130 µg/m³ Extreme Extreme Extreme Extreme

a. 24 hour average PM 10 concentration criteria apply to all wind directions.

b. 24 hour rolling average recorded at any e-sampler (i.e. 24 hour average that updates every 5 minutes based on

24 hours of consecutive 5 minute data).

c. The higher trigger values for ES-02 account for its closer proximity to dust source

A visual dust assessment is required whenever a real-time alert is generated as standard operating practice at Drayton Coal. This provides validation to automated alerts and allows the identification of false alerts. A daily forecast dust risk report is sent every morning to provide relevant people with an overview of expected weather conditions and dust risk for the next three days. Real-time Dust Management Alerts Real-time dust management alerts are sent if the trigger conditions are met and a new level is triggered. i.e. when the conditions increase to a higher alert level or when conditions return to a lower alert level. Alerts are sent via Email and SMS to the relevant personnel and are shown on the system interface.

4.11 Equipment Availability and Utilisation

Since the cessation of active mining and processing in 2016, Anglo American Drayton Mine utilises various methods of dust suppression. These can include:

Mobile water tankers for use on haul road dust suppression.

Transportable water sprays that are moved around the operation in dust prone areas.

Smaller water carts, utilised as required, for light vehicle roads, CHP roads and park up areas.

Portable water sprays used to soak dusty material prior to excavation In periods of elevated dust levels and prior to forecast adverse weather conditions, watercarts will be utilised for dust suppression activities on active haul roads, work areas and non-active areas of disturbance. Non-active areas of disturbance includes unused dumps, areas cleared of topsoil, and areas where potentially dust generating activities are taking place. Maintenance on watercarts will be scheduled where possible on night shift when evaporation rates and temperatures are reduced. Where the schedule allows, maintenance on watercarts will be conducted during periods of wet weather where possible. Drayton has two water fill points where water carts can fill from. A plan of the locations of water fill points is in Figure 2.

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4.12 Monitoring

Specific requirements relating to air quality monitoring are detailed in the NSW Department of Planning and Infrastructure Project Approval Conditions and all monitoring is conducted as set out in the “Approved Methods for Sampling and Analysis of Air Pollutants in NSW” (NSW OEH requirement). A registered offsite NATA accredited laboratory undertakes all analysis of dust samples. Air quality monitoring shall continue based on the current network of monitoring locations. A combination of dust fallout gauges, high volumes air samplers and real time monitoring currently monitor dust levels in areas surrounding the Drayton operation. Air quality monitoring currently focuses on the northern areas of Drayton as these are the nearest privately owned lands not used for heavy industry. On the western side of Drayton is the Mt Arthur open cut coal mine and to the east and south are Macquarie Generation’s Liddell and Bayswater power stations. Baseline monitoring and Environmental Assessment modelling have concentrated to the north of the operation to reflect near neighbours and current monitoring continues to reflect this. In addition, Drayton also operates an automatic weather station, which updates current weather conditions on a five-minute basis. This station complies with the requirements of the Approved Methods for Sampling of Air Pollutants in New South Wales guidelines. Real time information is downloaded to a central computer file, whereby information can be utilised to assist in the day-to-day operational issues as well as long-term analysis of environmental data.

All data is analysed and presented at Community Consultative Committee meetings and in Drayton’s Annual Environment Management Report.

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Figure 1: Dust Monitoring Locations

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Table 14 below provides a summary of the dust monitoring equipment illustrated in Figure 1.

Table 14: Dust Monitoring Equipment

Monitor Averaging Period

Coordinates East:South

Purpose

2197 Monthly 150°54’30.24” 32°19’40.90” Background deposition

2235 Monthly 150°55’3.34” 32°19’23.18” Resident dust deposition

2247 Monthly 150°55’30.28” 32°19’19.16” Resident dust deposition

2157 Monthly 150°55’37.97” 32°19’49.97” Background deposition

2208 Monthly 150°55’41.20” 32°19’33.55” Resident dust deposition

2230 Monthly 150°56’4.324” 32°19’21.34” Resident dust deposition

2175 Monthly 150°56’11.11” 32°19’31.24” Resident dust deposition

2130 Monthly 150°56’46.88” 32°19’50.60” Background deposition

Lot 22 24 hours 150°55’3.852” 32°19’10.42” TSP at Residence

TEOM 10 Minutes 150°56’7.897” 32°19’49.41” PM10 in Antiene Estate

E-Sampler 1 10 Minutes 150°54’40.02” 32°20’13.47” Operational PM10 levels

E-Sampler 2 10 Minutes 150°55’49.71” 32°20’53.74” Operational PM10 levels

E-Sampler 3 10 Minutes 150°55’8.708” 32°21’33.09” Operational PM10 levels

E-Sampler 4 10 Minutes 150°56’9.991” 32°22’26.02” Operational PM10 levels

Dust Fallout Monitoring Monthly dust monitoring is undertaken in and around the Drayton’s mining operation and the Antiene subdivision to the north of the site. A network of eight (8) gauges exist in the Antiene area to assess air quality impacts on the Antiene subdivision, directly to the north of the mine lease and are collected as a component of Drayton’s Environmental monitoring program on a monthly basis. Dust deposition gauges at Drayton will be used as supplementary monitors to provide long term trends. Dust fallout monitoring is undertaken as per Australian Standard 3580.10.1 - 2003 at locations illustrated in Figure 1. Suspended Dust Monitoring Suspended dust monitoring is also undertaken as per the NSW EPA 6 day cycle program. Drayton has one high-volume air sampler in operation in the Antiene subdivision measuring total suspended particulates (TSP). Total suspended particulate monitoring is undertaken as per Australian Standard 3580.9.3 - 2003 at locations detailed in Figure 1. Monitoring of air quality has been undertaken at Anglo American Drayton Mine since 1978, thus developing a long-term baseline of existing condition relating to air quality. This data can be utilised to compare current air quality performance against historical data both pre- and post-mining developments. The Lot 22 HVAS will be used as a supplementary monitor to sample TSP levels at a residential property on Balmoral Road. All data is analysed and presented in Drayton’s Annual Environment Management Report (AEMR). Real Time Air Quality Monitoring A TEOM (tapered element oscillating microbalance) is in operation in the Antiene area at Lot 9 to continuously monitor air quality in the community. This unit measures PM10 concentrations in real time and feeds the information back to the Drayton operation where it is monitored and assessed. Results of daily PM10 levels will be presented to the Drayton Community Consultative Committee and provided in the AEMR. This unit is used to assist in operational decision making as outlined in section 4.10.

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Drayton has 4 E-Samplers that measure PM10 levels around the open cut pits. These monitors have been situated upwind and downwind of the operation in consideration of dominant wind directions. As a result, these monitors provide Drayton with the ability to assess the operations contribution to dust levels in the region. The real time data from the E-Samplers is uploaded into a software package along with real time weather data, to provide alerts when Drayton’s contribution to dust levels is unacceptable. The trigger levels that determine unacceptable levels will initially be reviewed every 2 months as the system is being calibrated, and then on a quarterly basis. The location of the e-samplers will be reviewed every 6 months or as required as the mining operations change to ensure they provide realistic data that is representative of the dust levels around Drayton. Baseline Monitoring Anglo American Drayton Mine’s environmental monitoring program dates back to the late 1970s, with some current monitoring locations having in excess of 30 years monitoring data available for comparison. This detail is available for baseline and trending analysis to determine long-term variations and trends for dust emissions. Baseline data for the eight fallout gauges, high volume air sampler and TEOM results, all located in the Antiene area are shown in the following graphs.

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The sites depicted in the above graphs show seasonal variations of dust levels over an extended period. Linear trends are also shown on each graph. Drayton will continue to compare ongoing dust emissions with these graphs and the following table to determine ongoing trends as the mine continues to progress.

Table 15: Long Term Averages – Dust Fallout, High Volume Air Sampling and TEOM

Site Averaging Time Period Long Term Average

Averaging Period

2157 1982-2013 2.07 µg/m2 Monthly

2175 1986-2013 1.74 Monthly

2197 1986-2013 2.69 Monthly

2208 1986-2013 2.34 Monthly

2230 1986-2013 2.35 Monthly

2235 1986-2013 1.64 Monthly

2247 1983-2013 1.59 Monthly

Lot 22 Antiene 2001-2013 52.64 µg/m³ Daily

Lot 9 Antiene 1989-2010 26.85 Daily

TEOM 2010-2013 15.46 Daily

Data collection currently adds to this extensive database and shall continue to do so until site rehabilitation is completed.

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Figure 2: Water Fill Points

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4.13 Reporting of and Effectiveness of Air Quality Management System

The reporting of air quality data at Drayton will occur in different ways and at varying frequencies. On a monthly basis, air quality results will be reported publicly on the Anglo American Australia website. On a quarterly basis, air quality data will be presented to the Drayton Community Consultative Committee where committee members have the opportunity to discuss the results and receive further information on any exceedances of air quality criteria or incidents. On an annual basis, reporting of air quality monitoring forms a component of Drayton’s Annual Environment Management Report (AEMR), which is then forwarded to all relevant authorities. All results of monitoring and analysis shall be included in the AEMR. Within the AEMR the effectiveness of the air quality management system will also be discussed. If there are areas for improvement within the system, these will be outlined within the AEMR. This report also evaluates and reports on compliance with air quality impact assessments and land acquisition criteria in approval conditions. The Environment Superintendent or delegate is responsible for compiling all of these reports. Anglo American have internal audits on a periodic basis. The findings of Air Quality and dust audits will go towards assessing the effectiveness of the existing air quality management system. Audit findings that refer to air quality will be included into ‘Enablon’ where they can be tracked and managed.

4.14 Spontaneous Combustion Odour and Fume Management

Spontaneous combustion management at Drayton is outlined in Spontaneous Combustion Management Plan that can be viewed on the Anglo American Australia website. Odours and fume from mining operations occur at specific times at Drayton. Spontaneous combustion has a direct influence on odour emissions. These are discussed in the Spontaneous Combustion Management plan and are primarily managed through minimising the area affected by spontaneous combustion through clay capping. Fumes are also emitted at times from blasting operations. These result from product selection, wet blast holes, explosive product blending and incomplete combustion of products during blast initialisation. To control fumes from blasting, Drayton have developed a ‘Blast Fume Management Plan’ that identifies the preventative measures adopted at Drayton to prevent blast fume. The ‘Blast Fume Management Plan’ can be viewed as an appendix in the Drayton Blasting Management and Monitoring Plan that is located on the Anglo American Australia website.

4.15 Meteorological Monitoring

Drayton has operated an onsite meteorological station since 1981. This system operates on a wireless network and reports temperature, relative humidity, wind speed and direction and rainfall on a 5 minute basis. Data is summarised and is incorporated in onsite assessments for blasting, air quality, noise and blasting and is reported in the Annual Environment Management Report. As outlined in section 4.10, Drayton use predictive forecast from the Hunter Valley Meteorological Sounding Group to assist decision making onsite. Drayton also has access to real time data from the Drayton South Weather Station when necessary.

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4.16 Complaints Handling

In the event that a complaint or enquiry is received regarding air quality, it is immediately investigated. Details such as complainant name, contact details, nature of concern, date, time and method of receival are recorded. While details of the enquiry vary depending on the nature and source of the enquiry, the following actions may result:

Confirmation of whether the complainant would like the matter raised as a complaint or an enquiry

Identify further details which may assist in determining the cause of the complaint

Carry out an inspection of the site or conduct an assessment of monitoring results to identify the source

Identify if there is an exceedance or non-compliance with any consent or licence condition

Identify, where necessary and practical, methods to manage the source of the complaint and minimise the chance of a recurrence or further complaints.

Complaints are received via the ‘Drayton Complaints Hotline’ on 1800 814 195, by fax, email ([email protected]) or by post. Upon receiving the complaint, a Drayton employee will call the complainant to discuss the details of the complaint. This information is recorded and used to investigate the source of the air quality complaint. A follow up call is also made to the complainant after which time, all details pertaining to the incident are known and corrective actions have been determined to manage the issue. All enquiries and/or complaints are recorded in an enquiries database and are presented on a quarterly basis at the Drayton Community Consultative Committee as well as on an annual basis in the AEMR.

4.17 Handling Exceedances

If an exceedance of approval conditions or environment protection licence conditions occurs, the protocol follows that Drayton shall report the exceedance to the Department of Planning and Infrastructure and the Environmental Protection Agency as soon as the exceedance is known. A reportable exceedance will be a measured dust level that exceeds the air quality impact assessment criteria that is in the Drayton Development Consent 06_0202 as outlined in section 4.8. An internal investigation will be undertaken and findings will be forwarded to the two departments within 6 days of the initial notification. The exceedance will be captured in the Anglo American Safety Management System ‘Enablon’ and added as an environmental incident. Incident investigation details will be uploaded to ‘Enablon’ with corrective actions assigned to individuals tracked until completion. Details of any exceedance will also be included in the AEMR.

4.18 Cumulative Impacts of Mining Operations

Anglo Americans Drayton operation is one of many mining operations within the Hunter Valley. Due to multiple opencut mining operations in a concentrated area, cumulative impacts are a concern of many local residences. The Upper Hunter Air Quality Monitoring Network (UHAQMN) has been set up to provide information on the cumulative effects of mining. Monitors that form part of the network have been located in areas that receive the cumulative air quality impacts from multiple mining operations. Drayton’s closest mining operation is BHP’s Mt Arthur operation which share an operational boundary. Mt Arthur is situated on the western side of the Drayton operation with both operations sharing the Antiene rail spur that is north of the Drayton operation. Drayton and Mt Arthur are joint signatories to a document called the ‘Joint Acquisition Management Plan’ that outlines the actions of the two parties when the acquisition of land is necessary due to several reasons including the cumulative impacts of mining on air quality.

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In the event that Drayton receives a complaint from a nearby resident that can be attributed to the cumulative impacts of mining, Drayton will notify the Environmental Officer at Mt Arthur and dependent on weather conditions and visual observations the Environmental Officer/s from other nearby mining operations. In circumstances where Drayton’s dust monitors, weather station and/or a visual inspection identifies the likely source of elevated dust levels to be coming from a nearby mining operation, then Drayton will notify that mine’s environmental officer/s. Anglo American actively participates in the Upper Hunter Mining Dialog’s Air Emissions and Health Group that meets regularly to discuss the cumulative impacts of coal mining in the upper hunter. The targets and goals set by this group are pursued by the Drayton operation and community stakeholder meetings held with this group include contribution by Anglo American staff.

5 APPENDICES

Appendix 1 - Regulatory Correspondence: Copy of 2017 correspondence from DP&E and original approval of the Air Quality Monitoring Program that this plan supersedes.

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Appendix 1

Regulatory Correspondence

Document Reference

2017 DP&E Correspondence to Drayton Mine

Where addressed

18/09/2017 Approval for Air Quality Management Plan received Appendix 1

b) ii) Update Air Quality Management and Monitoring Plan resulting from 2015 Independent

Environmental Audit as follows:

Section 4.10.1

It is recommended that the Air Quality Management Plan be updated to reflect the current

practice of ESampler trigger levels being used on a one hour average basis rather than a

half hour; and

The Air Quality Management Plan should be updated with the calibrated Trigger Action

Response Plan.

Section 4.10.2

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