Chapter 4
Coal
Sources of coal emissions
4.1
Coal is a potential source of dust and particulates throughout its
lifecycle as a fuel. Coal is likely to be a source of significant air pollution
if not properly managed during extraction, storage, and transport. It is also a
source of significant CO2 emissions during burning. Evidence
provided from the NSW EPA indicated the contribution of coal mining to emission
levels in that State broadly, with mining for coal accounting to 27.6 per cent
of PM2.5 in the greater metropolitan region of Wollongong, Sydney
and Newcastle (GMR), 58.4 per cent of PM10 in the GMR. In the
Upper Hunter region (UHR), those levels are higher, at 66 per cent of PM2.5
and 87.6 per cent of PM10 emissions.[1]
4.2
The Minerals Council of Australia (MCA) recognised that coal mining is a
source of air pollution, but emphasised the importance of the different size of
particles and their respective impacts:
Without a doubt, the industry by its very nature makes a
contribution to particulate emissions. It digs, it has haul roads, it
transports material. But as part of that, and this is where the context comes
in, you need to look at the composition, the size and the very nature of those
particles. For example, if it is a rock it is not going to go very far. If it
is dust, depending on prevailing weather conditions, it will go a certain
distance but then it will drop out—especially if it is coarser particles. If it
is ultrafine particles, they are not sourced from mechanical digging. They are
not sourced from haul roads. They are sourced primarily from combustion sources....Without
a doubt, we recognise that the industry, by its very nature, contributes to
particle emissions.[2]
4.3
Coal dust and other particulates are produced during the extraction
process of coal, when diesel is burned operating mining machinery, 'blasting'
sends dust and other substances into the air, and draglines and trucks create
or re-mobilise dust.[3]
4.4
While coal is waiting to be loaded onto trains or boats, it is stored in
large mounds referred to as stockpiles. The committee heard that these
stockpiles are a potential source of coal dust. Community groups in particular
expressed concerns about the size of the stockpiles. It was reported to the
committee that the proposed stockpile at the Dudgeon Point coal terminal in
Mackay would cover 400 hectares; and be located two kilometres from residential
areas.[4]
4.5
The potential for coal trains to cause dust emissions was a key issue
throughout the committee's inquiry. While the amount and nature of pollution
emanating from coal trains was a contested point,[5]
it did appear that coal trains are a source of air pollution. Dust emissions
from coal can also be released during the loading and unloading of coal during
transport, whether by truck, train or conveyor.
4.6
Finally, coal is used extensively for power generation in Australia.
This process involves the burning of coal which results in the emission of
various compounds such as sulphur dioxide, oxides of nitrogen, and particulate
matter. The committee heard that combustion of coal in power plants was a
leading source of PM2.5:
In relation to PM2.5s electricity generation, coal fired and
coalmining are just two sources of particulate matter of PM-size 2.5 or less in
Australia. In relation to Victoria, four of Australia's six largest-emitting
single-emitting facilities of PM2.5 are in Victoria's Latrobe Valley, including
Loy Yang, Yallourn, Loy Yang B and Hazelwood power stations. Eight of the
nation's top ten emitters of PM2.5s around the country are power stations.[6]
Impact of coal dust on health
4.7
Dr Jeremijenko informed the committee that:
Coal dust is obviously a risk; it is all the impurities that
go along with it in the transport, as well. Coal may have arsenic, lead, heavy
metals, mercury.
...
The science is clear that coaldust is a killer if you are
exposed to it too much, so the simple thing is to remove that risk as much as
possible.[7]
4.8
It was asserted to the committee that emissions from coal extraction and
transport tended to be coarse particles rather than the fine particles that are
more harmful to health.[8]
As the Deputy Chief Executive Officer of NQBP argued:
The CSIRO work that I cited a moment ago clearly makes that
distinction. The point is this: there is a body of literature that clearly
links some health risks to the smaller finer particulate matter. Such a body of
literature does not seem to be evident for the larger material. I think the
point is that if we are trying to lump this all together and say 'all coal dust
is bad', frankly, the literature does not support that.[9]
4.9
As was noted earlier in this report, epidemiological research has shown
that there is no safe level of exposure to particulate matter. Although it is
unclear whether coal in and of itself is better or worse than other
particulates, there are locations where populations are exposed to large
volumes of air pollution because of the activities surrounding coal mining and
its transport or combustion. The committee heard from one Jondaryan resident
who related her health concerns:
We get burning eyes, a burning tongue, a sore throat and
burning throat. I am a bit croaky, that is from coal. We also suffer from itchy
skin, ringing in the ears, ringing in your brain. Sometimes at night, you go to
sleep and your brain is swishing like it is running around in your head. It
will wake you at 3.30 in the morning and you will not get to sleep again
because you will just sit there and hold your head. We suffer from lack of
concentration. We have jaw problems. Because of the noise from the plant we are
not sleeping properly. The dentist told me we are just clenching our teeth in
our sleep and that is causing us to have jaw problems. Of course, then we have
the fits of anger, hopelessness and depression that just go along with
frustration of nobody listening and nobody caring.[10]
4.10
The committee received similar anecdotal evidence from the
Moranbah Cumulative Impacts Group who indicated that there is a
heightened rate of asthma in the town, but that this is difficult to directly
attribute to coal dust rather than other sources of pollution such as smoking
and airborne pollens.[11]
The Asthma Foundation New South Wales argued that proximity to coalmines has
been linked to higher rates of asthma,[12]
and cited research from 2010:
In May 2010 the New South Wales government released a report
on child health which showed that nearly 40 per cent of nine-to-15-year-olds in
the Hunter Valley and the New England region had suffered at some stage from
asthma. That is significantly above the national average of 10 per cent. Other
areas that have expressed concerns are the Hunter Valley and Lithgow in the
Blue Mountains, which has a coalmine, a newly extended coal fired power station
and an asthma rate 80 per cent higher than the New South Wales average.[13]
4.11
The committee heard that some companies paid for annual health checks of
their workforce to protect against exposure and provided extensive written
guidance on protecting health, but that similar services were not provided to
nearby communities,[14]
which had to pay for their own healthcare.[15]
4.12
Greenpeace Australia Pacific argued that there has been insufficient
research undertaken to understand the impact on health of coal affected
communities, despite many communities reporting health concerns.[16]
The committee heard concerns that residents in Anglesea in Victoria who are
living half a kilometre from an open cut coal mine were unable to assess
whether their community was at risk because no independent monitoring is being
undertaken.[17]
4.13
A number of communities expressed their concerns to the committee about
the possible impact of coaldust on human health. Evidence from the Mackay group
Communities Protecting Our Regions explained:
We found very clearly that people were concerned about coal
dust. It was one of their main concerns about the Dudgeon Point coal port
proposal, and in fact we found that this was their primary concern. We found
this as we continued to campaign on the coal port—that is, that is one of the
main things that people are concerned about.[18]
4.14
The Moranbah Cumulative Impacts Group similarly informed the committee
that 'quite a lot of residents have become concerned for their health.'[19]
Protecting vulnerable communities
4.15
Occupational and environmental physician Dr Jeremijenko argued that it
is possible to significantly reduce the risk from coal mining and its
associated activities:
We know what works; we have applied it at the coalface and
there are other ways—like dust suppression, covering coal trains and
others—that we can reduce the risk.[20]
4.16
Furthermore, it was argued that protecting vulnerable communities
through pit to port dust management receives less emphasis than minimising
emissions at the coal-face:
There are a lot of areas where we could do a lot more work
and address this a lot more proactively. It is a high risk, in my view, and it
is a high risk that goes right past the homes and the schools of many people,
and it is not being treated and addressed with the same level of risk
management as we treat it with at the coalface.[21]
4.17
Broadly speaking, the committee has identified two categories of
protective measures that must be considered for these vulnerable communities:
minimising the creation of dust, and limiting human exposure to dust that is
unable to be managed. Some solutions put to the committee addressed both of these
measures, such as best practice loading techniques described below. Most
solutions identified, however, were directed towards limiting exposure to dust.
These may keep people away from the dust, minimise the time people are exposed
to a hazard, or involve the use of personal protective equipment such as face
masks.[22]
The use of personal protective equipment is not a realistic approach for
residents living near coal industry facilities, meaning that engineering,
planning and administrative solutions are critical.
4.18
It was recommended by several stakeholders, including the Lock the Gate
Alliance, that there should be 'an absolute minimum' mine set-back of two
kilometres from residential areas.[23]
The committee heard that in Queensland a two-kilometre minimum buffer exists
for towns above 1000 inhabitants.[24]
The committee heard that buffers are a useful solution because they are easily
verified by regulatory bodies:
I think the concept of buffer areas between the stockpile or
the mine, and the community is incredibly important, because in terms of
enforcement—and we talked about enforcement a little earlier—it is something
you can see. There is the mine and there is a two-kilometre buffer and you do
not have uncertainty as to whether the standards are being met through
complicated monitoring. You can see there is a gap.[25]
4.19
Although the two-kilometre minimum was put to the committee, it was
emphasized that the buffer necessary to protect residential populations would
depend on the size and characteristics of each individual mine.[26]
The MCA recognised that buffer zones are a means to reduce direct exposure to
particulate matter from coal mining.[27]
4.20
In an apparent recognition of the utility of keeping industrial and
residential areas separate, the committee was informed that in the case of
Jondaryan, the company's mine continuation plan involves moving the loading
facility 'well away from Jondaryan into the heart of the mining leases and well
away from any sort of urban or residential areas.'[28]
4.21
In addition to buffer zones, containing stockpiles by either covering or
the use of veneers was also identified as a possible engineering solution to
manage coal emissions. In response to questions regarding the use of covers of
stockpiles at storage facilities, the committee was informed that:
Over a certain size it just becomes impractical to cover coal
stockpiles. As we said, with veneers, these surface veneers are very effective
in high-wind conditions. The moisture controls and the veneering together
manage to control stockyard dust emissions, which is the major source of dust
in the coal terminal.[29]
4.22
It was clarified however that veneer is only useful when a stockpile is
not being reclaimed as once the veneer's surface is broken the stack once again
becomes a source of dust emissions, and therefore is only used when the
stockpile is not being actively reclaimed or stacked.[30]
4.23
In relation to coal dust emissions during transportation, the committee
heard that there are a number of ways that coal can be moved from mine, to
train, to ship using a number of different technologies. As Dr Smith explained,
best-practice loading techniques minimise dust emissions:
There are best-practice loading techniques for loading coal,
and that is typically having an overhead hopper and dropping the coal into the
wagons. That is not what is done at Jondaryan. They use dozers and front-end
loaders to load the coal. You can imagine that that causes a lot of dust. So
those sorts of suggestions seem to be things that would help to alleviate the
problem.[31]
4.24
The committee heard that in other towns such as Wynnum unloading takes
place in a shed to limit renegade particles; a practice that reportedly
produces better air quality for nearby residents.[32]
The committee was also informed of the dust minimisation systems used in the
port of Hay Point:
On rail receival, in the port of Hay Point we use best
practice techniques. Rail wagons are unloaded in a building with a roof and two
sides. We have dust extinguishment systems in which we collect any dust from
the rail dump hoppers and we extract that and contain it. With the in-loading
and stockyard conveyors, we have designed the conveyors to minimise dust
generation. Transfer sheets are sealed between entry at the head-sheet and exit
onto the downstream conveyor. We use belt scrappers and belt washing. Floors
under conveyors are sealed for elevating conveyors, draining to the coal
collection pit. I could go on, but I suspect there is not much value in me
giving you a full range of techniques.
...
The wagons in the port of Hay Point are all bottom-dump. The
coal is released into hoppers, and that is in a partially enclosed building
with dust-extraction systems. The coal is washed or brushed from the wheels of
the wagons, but the wagons themselves are not washed before they go back.
...
The other thing is that, in recent times—partly for dust and
partly for noise attenuation—these particular receival dump station sheds have
had those heavy clear PVC-type curtains put around them so that the fit of the
train through the aperture into the shed is a lot tighter now than it used to
be, to prevent dust emissions and to help with the noise attenuation.[33]
4.25
Some stakeholders suggested that the best way to manage dust from coal
trains was through the use of covered wagons.[34]
The committee heard that:
Closing the cabins and enclosing the coaldust seems like a
very sensible solution. I do not know why it has not been done...It is just
putting a top on the wagons. As they said, when you bring coaldust in it
vibrates and, even though you veneer some or all of them, some will still be
released. But as you go back again you have empty coal trains with coaldust at
the bottom; they do not empty totally. So it just seems to make good sense for
them to be covered. I think this is a risk that can be managed.[35]
4.26
The Asthma Foundation of NSW posited that as well as being a simple and
effective measure, covering coal wagons would reduce the exposure of large
populations in the towns and suburbs transited by rail infrastructure; groups
whose exposure is not directly offset with employment or other benefits.[36]
4.27
The New South Wales Minerals Council (NSWMC) queried the value of
covering wagons, however, stating: 'Research to date suggests that this would
be an extremely expensive action that would have little or no effect on dust
and air quality near rail lines.'[37]
This however appeared to be contradicted by evidence from the Queensland
Resources Council (QRC) that said that veneering in central Queensland had
significantly reduced dust emissions.[38]
4.28
The QRC provided the committee with an evaluation of the
cost-effectiveness of introducing wagon lids commissioned by Queensland Rail
Limited. Queensland Rail Limited estimated that the costs to provide and
operate lids on all coal wagons in Australia would be approximately $10 per
wagon, per day.[39]
While the evaluation concludes that it would not be cost effective for
Queensland Rail Limited to introduce lids at the current time, the analysis
notes that the introduction of covers on coal wagons 'would almost eliminate
coal dust emissions from the primary dust source'. Given this, the analysis
notes that its assessment of cost effectiveness 'cannot be taken at face value'.
The analysis further notes that the scores used to determine cost effectiveness
'are highly dependent upon the operational impact and reliability of the lids,
[neither] of which can be accurately estimated without a thorough investigation'.[40]
4.29
The QRC informed the committee that covered wagons used in some
international jurisdictions are utilised to protect the cargo from issues such
as ice and snow, not to reduce dust emissions.[41]
The QRC further claimed that covering wagons was unnecessary, as industry in
Queensland had commenced veneering coal wagons to reduce dust:
Veneering has proved itself worldwide to be the most
effective means of suppressing dust from coal wagons. As our submission notes,
there is no significant health or amenity benefit from putting lids on wagons,
just significant cost implications for everyone on the supply chain from pit to
port.[42]
...
Veneering is world-leading dust suppression technology. All
Queensland coalmines in Central Queensland and in the Surat Basin have
committed to introducing veneering by the end of 2013. In Central Queensland,
where the majority of mines are already veneering their coal, the practice has
led to dust reductions of up to 90 per cent.[43]
4.30
Similarly NQBP argued strongly in support of the use of veneering to
minimise dust from coal trains:
One of the things that we can take some comfort from is that
veneering of coal wagons with polymer veneers to suppress dust from blowing off
wagons has been demonstrated to be particularly effective. By the end of this
calendar year, all receiving coals to the port of Hay Point will be veneered.
That is just one simple measure that has been a continuous improvement that has
been applied and that is at the, I guess, sourced, port part of the supply.[44]
4.31
Representatives from NQBP provided evidence to the committee regarding
the mechanisms and strategies used to minimise dust emissions while in the
stockpile and during transit phases through the use of moisture management and
veneers:
There is a relationship between moisture content and dust
generation. We test each one to determine the optimum moisture content and we
aim to control the moisture content of that coal right from the mine all the
way through to the ship.
...
Probably the one major control at the port is the fact that
in the stockyards at Hay Point we have a dust control system to keep that coal
at its optimum moisture content. We have automatic water spray systems. We
estimate the evaporation from the coal stockpiles and those spray systems
automatically apply water to keep the coal at that optimum moisture content. If
the winds get too high and dry it out too fast for the stockyard sprays, the
veneer can be applied. Those veneers are very effective. We have had testing
done on dust suppression for the coals that indicates that, at certain wind
conditions, the veneer gets dust emissions down to zero.[45]
4.32
In relation to power generation, the committee heard that there is
technology available to reduce the emissions from coal fired power plants that
is used in other jurisdictions with tighter emissions standards:
Here, frequently the sulphur dioxide levels do exceed the 75
parts per million that would be allowed in the US. So yes, that is correct: it
frequently exceeds what would be allowed in the United States. And exceedences
are not uncommon, or occur on a semi-regular basis, certainly much more so in
the past at Anglesea than they do now, and that is because the company has put
in place a procedure of actually switching down the power station when the
sulphur dioxide levels exceed the accepted level. In fact, sulphur dioxide
pollution control measures that can be fitted to power stations exist. Those
could be fitted to the Anglesea power station, but the company has chosen
instead to implement a protocol whereby the output of the power station is
decreased when sulphur dioxide levels exceed the acceptable level.[46]
4.33
The committee also heard that reductions in coal combustion and fossil
fuel combustion generally, 'can improve human health directly by reducing
chronic disease risks from air pollution as well as indirectly from mitigation
of climate change'.[47]
Regulation
4.34
The regulation of coal mines, especially regarding their possible
environmental and health impacts, was a significant point of contention in the
evidence received by the committee. For the most part, the approval and
monitoring of coal mines is a function of State and Territory governments and
as such subject to variations between jurisdictions. As a result of this, the
committee heard that 'there is also considerable difference in transparency and
consistency in the application of air quality controls on different mines
within the same state jurisdiction and also between state jurisdictions.'[48]
Approval processes
4.35
Some stakeholders argued that the approval process for new mines did not
consider cumulative impacts of additional developments in a single area during
the approvals process:
There are plenty of EISs done on mining projects, and I
include especially the coal seam gas projects here in Queensland, where
cumulative impacts are not even looked at. When you put this particular project
in with a whole lot of other projects, there are no attempts to quantify what
that might mean, or, if they do it, they do it in the most offhand manner, as
has happened in Gladstone, just simply by saying, 'Gladstone is already over
allocated so it does not matter if we do one more.'[49]
4.36
The NSW EPA informed the committee that they had adopted air quality
targets in certain air sheds. The emissions from new developments would need to
be assessed against that target:
That was one of the points I was making about the fact that we
have now adopted this target level that we are trying to achieve for the Upper
Hunter. That is all around new mines that are being proposed, new activities,
and what is it that we have to do to achieve that target. So if you think about
that target of eight, for PM2.5, for that air shed that is a cumulative impact
target that we are talking about.[50]
4.37
The NSW EPA informed the committee that all coalmines have an
environmental protection licence that is issued by the EPA which includes
conditions covering environmental performance such as dust.[51]
Regulatory approaches
4.38
The committee received evidence that in Queensland companies are
responsible for monitoring and managing their dust emissions. Some submitters
argued that the system was not effective in controlling air quality:
[I]n this state we do not have a regulatory model, we have a
self-regulatory model. We do not have an EPA or a department of environment and
heritage protection, or whatever it is called these days, that actually does
audits of mine sites or audits of extractive industry. The companies do all of
that. All that the regulator does is gather audits on paper. They do paper
audits. They do not do on-site audits. They do not do on-site monitoring. All
the regulator does is respond to complaints. So it is a complaint driven
regulatory model with self-regulation as the main basis for the whole thing.
Basically a company has to put up its hand for a breach, if there is a breach.
It is never found out by the regulator itself.[52]
4.39
It was reported that a similar practice is adopted in Victoria where in
many places the EPA does not have the resources to monitor industry sources and
therefore relies on self-regulation.[53]
4.40
In addition to its general monitoring, the committee was told that, the
NSW EPA responds to community complaints regarding the activities from a mine
and will investigate further, either via the telephone or in person.[54]
Evidence provided by the NSW EPA appears to indicate a more proactive approach
to reducing emissions from coalmining in NSW:
In terms of where our priorities are, the Hunter Valley is
clearly one of those...We recognise, along with the community, that impacts of
particle pollution on the Hunter region are increasing and likely to increase
further in the absence of any action, because of the expansion of the coal
mining industry. Last year we established an interagency task force...to work
together on managing air quality by improving our planning and enforcement
activities.[55]
4.41
Mr Buffier reported to the committee that one of the reasons for the
establishment of this taskforce was 2012 data showing an increasing number of
exceedences of the PM2.5 advisory standards and PM10
levels.[56]
4.42
It was reported further that open cut coal mines across New South Wales
are subject to particular pollution reduction programs to minimise dust from
haul roads, stockpiles, and the operation of machinery which aims to reduce
particulate emissions from mines by 20 per cent.[57]
Enforceability
4.43
In order to be enforceable, regulations and permits must be sufficiently
explicit and prescriptive in what they require an operator to do, and the
standards to which they will be held to account. ANEDO, using the permit for
the Jondaryan mine as an example, highlighted that there is no reference to the
control of damaging fine particles,[58]
and the monitoring of PM10 is to be monitored 'at a sensitive place
downwind of the operational land', without specifying other factors such as
distance from the mine or proximity to residences.[59]
4.44
State government authorities also need to be appropriately resourced in
order to properly discharge their duties. The committee heard concerns that
recent or prospective cuts to regulatory authorities limit the capacity of the
public sector to appropriately monitor the private sector.[60]
Appropriate regulations for
vulnerable groups
4.45
The committee heard evidence, noted previously in this report, that
children are particularly vulnerable to health impacts of poor air quality. An
important point was raised by Dr Jeremijenko in relation to this fact:
The different effect of coal dust on children is quite
significant. Their lungs are developing. Coal dust has been shown to have a
much greater effect on children's developing lungs, so the standards written
for coal workers, even for the PM10s that are measured, are not the same as
what would be written for children. We need to consider that because these coal
trains are going through the suburbs. It is really important that the
children's health is protected as well as the health of adults in the
community. I think that has been totally ignored in this situation.[61]
4.46
In order to be effective guardians of community health, regulations must
take into account that a standard that is acceptable for one group or locations
may need to be more stringent for another, such as children. The committee
received evidence that coal trains and stockpiles are often proximate to
playgrounds, childcare centres and schools.[62]
Measurements undertaken by the Hunter Community Environment Centre, for
example, showed elevated levels of pollution in people's homes and gardens
compared to official monitoring.[63]
Balancing economic, environmental
and health concerns
4.47
Although the committee received a large body of evidence largely
critical of some of the current practices of the coal industry broadly, many
also believe that coal is an important source of employment and economic
activity – especially in smaller communities, but one that needed to be
monitored. The Asthma Foundation New South Wales noted for instance:
I do not think [communities] will want to see extreme
measures that are going to reduce economic benefits like employment, but I am
sure that responsible measures that would allow the coal industry to continue
to do its bit for Australia without causing a great degree of impact on the health
of Australian citizens would be very welcome.[64]
4.48
Similarly, Professor Jalaludin commented:
If you have a large number of small communities, the science
would suggest that, yes, in terms of equity they should not be exposed to high
levels of air pollution also. Ultimately it might come down to a political
decision about the costs of trying to reduce air pollution to such low levels
and what might be the benefits of it. If, for example, we are thinking of the
Hunter Valley and the coalmines, what are the benefits in terms of employment
and so on? That is a difficult decision to make, but I think we should not
forget the issue around equity. Is it fair to let one community be exposed to
high levels of air pollutants so that the larger population can benefit from
that? That is a difficult issue. I do not think there is a right or wrong
answer.[65]
Committee view
4.49
The committee accepts that coal, throughout its lifecycle, is a source
of air pollution that is harmful to human health. Those harms manifest
themselves in individual discomfort and at a cost to private and public purses.
Coal is also a part of the Australian economy both as an export earner and a
source of cheap electricity. Governments and communities together need to
decide what level of pollution they are willing to tolerate. It appears clear,
however, that there are some concrete steps that can be taken that would
minimise coal pollution and manage the risks associated with it. The committee
considers that measures such as the covering of coal wagons are appropriate
regulatory steps to take towards minimising the impact of coal emissions on vulnerable
communities.
Recommendation 6
4.50
The committee recommends that states and territories require industry to
implement covers on all coal wagon fleets.
Recommendation 7
4.51
The committee recommends that the Commonwealth develop and implement a
process for assessing cumulative impacts of coal mine developments that take
into account other mines in the region and their impact on resident health.
Recommendation 8
4.52
The committee recommends that health impact assessments be required as
part of the assessment process for all new developments.
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