Protocol for Environmental Management Mining and Extractive Industries

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Protocol for Environmental Management (Mining and
Extractive Industries)
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PEM Mining and Extractive Industries

• Incorporated document to SEPP (AQM)
• Gazetted February 2008
• Is a statutory document same power as SEPP
• Industry must still comply with requirements of
  SEPP
• PEM just provides further interpretation and
  guidance
• Establishes a procedure for conducting an air
  quality assessment as part of an EES process, EPA
  Works Approval Application, Planning Permit
  Application or DPI Work Authority application

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SEPP (AQM)

• Sets out the statutory framework for managing
  emissions to the air environment
• Emissions are managed in such a way to ensure
  that
• Air quality objectives in SEPP (AAQ) are met
• Continuous improvement in Victorias air quality
  occurs
• All indicators in SEPP (AQM) must be managed by
  application of best practice
• Class 3 indicators by application of controls to
  maximum extent achievable (MEA)

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Best Practice and MEA

• In determining what constitutes best practice and
  MEA consideration must be given to the wastes
  hierarchy
• Avoidance
• Reuse
• Recycling
• Recovery of energy
• Treatment
• Containment
• disposal

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Best practice and MEA

• Best Practice - Best combination of eco-efficient
  techniques, methods, processes or technology used
  in an industry sector or activity that
  demonstrably minimises the environmental impact
  of a generator of emissions in that industry
  sector or activity
• MEA - A degree of reduction in the emission of
  wastes from a particular source that uses the
  most effective, practicable means to minimise the
  risk to human health from those emissions and is
  at least equivalent to or greater than that which
  can be achieved through application of best
  practice

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Best Practice and MEA

• Best practice
• Industry wide
• Determined for industries of similar size,
  location and operations
• MEA
• Goes beyond best practice to take into
  consideration what site-specific action can be
  taken
• This may include for example
• Ceasing operation for several hours under certain
  met conditions
• Increased water sprays or use of chemical dust
  suppressants
• Use of blast mats

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How to determine best practice or MEA?

• Most recent documented definition for the
  industry sector from national and international
  sources
• Most recent documented definition for the
  industry sector in Victoria (if any)
• Performance standards or benchmarks for the
  industry in terms of management of emissions,
  wastes, energy and resources and their impacts
• Any constraints that may apply to each situation
  (eg., availability, affordability or
  practicability)
• Comparison of different approaches currently used
  in the industry

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Assessment requirements

• Risk based
• Dependent on scale or size of operation
• Location of the site
• Irrespective of the level of assessment emissions
  must be controlled by application of best
  practice or MEA
• Level 1 most rigorous applies when
  developments are close to residential areas or in
  urban areas and have the potential to give rise
  to significant off-site impacts

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Assessment requirements

• Level 2 required when development is in rural
  area with residences in close proximity or where
  a small operation is located in an urban area.
• Level 3 required when development is in a rural
  location with no residences in close proximity
• For mines and quarries with less that 50,000
  tonnes per year extraction, no modelling is
  required
• Best practice (relevant to the site) applied to
  control of emissions on site

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Extraction

• For quarries the amount of soil and rock that is
  moved or extracted per year
• For above ground mines the amount of soil, rock
  or ore moved on site
• For underground mines that amount of soil, rock
  and ore moved above ground and brought to the
  surface of the mine. Any emissions from
  ventilation shafts of the mine must also be taken
  into account in the estimates of emissions where
  the shaft is part of the premises.

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Criteria for Assessment
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Indicators to be assessed

• PM10
• PM2.5
• Respirable crystalline silica
• Asbestos
• Arsenic
• Hydrogen Cyanide
• Heavy metals (eg, lead antimony)
• PAHs
• Radioactive isotopes

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Assessment criteria
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Assessment criteria

• Prior to Assessment
• Level 1 real-time continuous monitoring 24-hour
  average PM10 and PM2.5 for a 12 month period,
  analysis of RCS, deposited dust and heavy metals
• Level 2 - continuous monitoring 24-hour average
  PM10 and PM2.5 for a 12 month period, analysis of
  RCS, deposited dust and heavy metals
• Level 3 no monitoring required prior to
  assessment
• EPA has data for Melbourne, Geelong, Wangaratta,
  Latrobe Valley, Bendigo, Ballarat, Mildura,
  Shepparton, Warrnambool that is available on
  request.

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Modelling

• Modelling conducted for new or modified sources
• Modelling is conducted on emissions after the
  application of best practice and MEA
• Residual emissions
• Must use a regulatory model (currently Ausplume)
• If a proponent wants to use an alternative model,
  a modelling proposal must be approved by the
  Authority
• Follow the modelling requirements set out in
  Schedule C of the SEPP-AQM

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Modelling

• Ambient Background Concentrations Site
  Specific, Site Representative, Generic airshed
  values (70thiles) None
• Meteorological data - Site Specific and Site
  Representative
• Emissions Input Data Site specific factors or
  literature based factors (NPI or AP42)
• Regulatory Model AUSPLUME
• PM10 and PM2.5 must be modelled as a gas

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Background data

• Level 1 Real time continuous 24-hour PM10 and
  PM2.5 for a 12-month period, analysis of
  crystalline silica (PM2.5 fraction), deposited
  dust and heavy metal content (PM10) (where
  applicable)
• Level 2 - Continuous 24-hour PM10 and PM2.5 for
  a 12-month period, analysis of crystalline silica
  (PM2.5 fraction), deposited dust and heavy metal
  content (PM10) (where applicable)
• Level 3 No monitoring data required

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Modelling

• Modelling is undertaken over a twelve month
  period
• Should be undertaken for both construction and
  operational phases of the development
• The simulation(s) are for worst case emissions
  under normal operating conditions
• For example maximum earth moving activities,
  activities close to sensitive receptors
• Include background concentrations (address where
  datasets are biased by events)

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Sensitive Locations

• Sensitive locations include
• residences,
• schools,
• kindergartens,
• aged care facilities,
• hospitals,
• childcare centres and
• recreational areas.
• In assessing recreational areas the potential for
  exposure needs to be taken into account through a
  qualitative risk assessment process eg., whether
  activities are occurring on site when people are
  using the recreational area.

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Presentation of modelling results

• Time series plots at sensitive receptors,
  including total, mining/extractive contribution
  background presented separately

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Presentation of modelling results

• Contour Plots showing maximum concentrations from
  industry only, including residential areas and
  sensitive receptors

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Level 1 modelling

• 24-hour PM10 and PM2.5 predictions for a
  12-month period, including daily time varying
  background files
• Crystalline silica,arsenic and other indicators
  with long term health effects must include annual
  average background concentrations
• Nitrogen dioxide and carbon monoxide include
  70thile concentrations (single upper average
  value)
• For other indicators considered, justification
  must be provided for not using a background
  concentration

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Level 2 Modelling

• 24-hour PM10 and PM2.5 predictions for a
  12-month period, including daily time varying
  background files (EPA). A screening assessment
  may be applied using 70thiles
• Crystalline silica,arsenic and other indicators
  with long term health effects must include annual
  average background concentrations
• Nitrogen dioxide and carbon monoxide do not need
  to be considered
• For other indicators considered, justification
  must be provided for not using a background
  concentration

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Level 3 Modelling

• PM10, PM2.5, and RCS
• No background data is required for modelling
  purposes

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Risk management strategies

• When modelling predicts that assessment criteria
  may be exceeded
• Identify conditions (meteorological and
  operational) that lead to elevated levels
• Identify options for reducing exposure
• Identify further operational controls (i.e.
  stopping operation when winds from a direction
  are above a certain level)
• Relocating residents for periods when operations
  are expected to produce high levels of emissions
• Implement monitoring as part of a reactive
  management strategy
• Conduct a Health Risk Assessment - where all
  options are exhausted

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Health Risk Assessment

• In situations where the assessment criteria are
  exceeded and additional management strategies are
  not an option or are not economically viable, a
  health risk assessment can be conducted and
  submitted as part of the assessment.
• It is expected that a detailed quantitative
  health risk assessment will only be required in
  rare circumstances.
• A quantitative risk assessment should only be
  undertaken when all options for reducing
  emissions by changes in site management practices
  have been exhausted or are not economically
  viable. It should not be the first option taken.

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Health Risk Assessment

• In conducting the health risk assessment the
  following steps must be followed
• Review of the current information regarding the
  health effects associated with exposure to the
  indicator
• Collection of information on the local population
  including identification of susceptible groups
  within the affected population (eg percentage of
  children with asthma or people aged over 65
  years)
• Potential for exposure of the local population to
  levels of the indicators (obtained from air
  quality modelling) and,
• Calculation of the risk posed by this exposure

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Monitoring for approved developments

• Confirmation monitoring for limited time period
  (eg 12 months)
• Level 1 Real time continuous PM10 and PM2.5
  monitoring, nuisance dust monitoring at sensitive
  receptors and crystalline silica and metal
  monitoring (conducted using low-volume samplers
  for a period of 1 week per month)
• Level 2 1 in 6 day 24-hour PM10 and PM2..5
  monitoring, nuisance dust monitoring at sensitive
  receptors and limited crystalline silica and
  metal monitoring (conducted using low-volume
  samplers for a period of 1 week per month)
• Level 3 Nuisance dust monitoring at sensitive
  receptors
• Nuisance dust monitoring to be assessed using DPI
  criteria of 4 g/m2/month on a monthly basis (not
  an annual average) no more than 2 g/m2/month
  above background.

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Monitoring for Reactive Management

• For Level 1 and 2 facilities as part of site EMP
• A real-time tool to react to short term particle
  peaks which may impact on the overall daily
  concentration
• EPA can assist with short term trigger levels and
  advise on appropriate instrumentation
• Typically sited at the sensitive receptor that is
  predicted to be worst affected or boundary
  closest to that location
• Instrumentation not the same as that required for
  compliance monitoring
• Range of equipment available that is relatively
  inexpensive and portable that would be suitable

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CASANZ Issues

• If ambient background levels exceed the
  assessment criteria can different criteria be
  established? This is particularly relevant for
  fine particles and silica (especially for dust
  storms,strong wind periods, bushfires, fuel
  reduction burns, etc)?
• The assessment criteria are based on the
  protection of health. Alternative criteria cannot
  be used. However, in the presentation of results
  the background data needs to be presented
  separately to the modelled predictions from the
  mine or quarry so that existing air quality can
  be clearly identified.

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CASANZ Issues

• Is the Table 2 averaging period for RCS also to
  be interpreted as a Policy (AQM) intervention
  level (as for PM10 and PM2.5?) Can it be used as
  a modelling design criterion? This question also
  applicable for other Class 3 indicators
  hydrogen cyanide, arsenic, antimony).
• The assessment criteria in the PEM should not be
  considered as intervention levels. The assessment
  criteria apply for mining and extractive
  industries only when assessed in accordance with
  the procedures set out in the PEM. They are used
  for both design purposes and monitoring
  assessments.

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CASANZ issues

• Background levels (PM10, PM2.5 RCS, and deposited
  dust) are required for the air quality assessment
  if there is no site-specific data available. The
  Draft PEM Level 1 and 2 assessments require 1
  year of data be obtained prior to the preparation
  of the assessment. Given the significant costs
  and time to accumulate this data, is a shorter
  period of 4 to 6 months sufficient provided that
  the sampling is across the drier seasons?
• The purpose of collecting this data is to ensure
  that background data is available for the
  modelling. For Level 1 assessments daily varying
  background data is required for the model so data
  must be collected daily for a 12 month period.
• EPA has datasets available and the proponent
  should check with EPA on the availability and
  suitability of existing data.
• Note collecting background data only during dry
  windy months may not pick up other existing
  sources such as combustion sources (eg planned
  burning and wood heater emissions that contribute
  to existing air quality)

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CASANZ issues

• Will a preferred dispersion model be specified
  for large area intermittent source modelling
  associated with mining e.g. for excavation,
  blasting, and haulage activities? For example
  AUSPLUME, CALPUFF or TAPM?
• The current regulatory model is AUSPLUME, if the
  proponent wishes to use a non-regulatory model
  they have to provide a modelling proposal that is
  acceptable by the Authority.

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CASANZ issues

• Will a prescribed methodology for undertaking
  health risk assessment (if required) be
  recommended in the PEM Mining and Extractive
  Industry?
• Further guidance has been provided in the PEM but
  it is not prescriptive. A PEM for Risk Assessment
  is currently being developed that will provide
  detailed guidance to what EPA requires in a risk
  assessment to demonstrate compliance with SEPP
  (AQM). In the interim contact EPA for further
  guidance.

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CASANZ issues

• Will a preferred hierarchy of dust monitoring
  methods be included for the 3 proposed PEM
  controlled levels? The preferred monitoring
  method should also propose optional monitoring
  frequency with references to a standard
  (Australian Standard or International).
• No, if confirmation monitoring is required it has
  to be undertaken by at least one co-located
  reference method (AS , USEPA).
• Reactive management monitoring is undertaken
  using a continuous method (does not have to be a
  reference or equivalence method) as it is a
  trigger for review of site management if particle
  levels are increasing. It provides a reactive
  management approach to avoid a problem in real
  time.

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CASANZ issues

• If the monitoring method chosen is not preferred
  highest then it should be specified what
  cross-correlation is required. For example
  monitoring equipment options may be TEOM,
  Hi-Vol, Partisol, Microvol, OSIRIS, Dust Track
  Grimm, Dust Scan, Beta Attenuation Monitor,
  Nephelometer, Direction Deposition, deposition
  and other alternatives?
• Confirmation monitoring if required has to be
  undertaken by at least one co-located reference
  method (AS , USEPA).
• EPA is compiling a list of currently available
  instrumentation for both confirmation and
  reactive monitoring. Proponents should check with
  equipment suppliers to ensure that they have the
  assessed all available equipment suitable for
  either type of monitoring.

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