Drayton South mine will exceed air quality limits and must be rejected

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Since Anglo American's application for a new Hunter Valley mine bases its air quality estimates on the hopelessly inadequate figures of its first Drayton mine, the application must be denied, writes Lachlan Barker.

RECENTLY, I took a look at Anglo American’s application for their new mine in the Hunter Valley, Drayton South.

Once I started digging, I found so much that was wrong with the application it turned into a major exercise.

I began documenting the issues. 

The major points are here at the top and you can examine the voluminous correspondence below about the various issues at your leisure:

  1. Anglo American’s air pollution data for their currently operating Drayton mine is hopelessly inadequate and does not reflect the true levels of pollution they have been releasing.
  2. Anglo used this hopelessly inadequate data as one of the central planks of their application for the new mine — Drayton South.

Since the modelling for Drayton South that claims the new mine will not exceed statutory NSW air pollution levels is based on utterly flawed data, the application for Drayton South has to be withdrawn and the NSW Environment Protection Authority (EPA) must investigate.

The EPA’s investigation has to find the true levels of air pollution that came out of Drayton Mine and, if they do indeed find that, it will clearly show that Drayton South will contravene the air pollution limits easily and so cannot be approved.

Drayton mine air pollution data is hopelessly inadequate

The pollutant that caught my eye is particulate matter less than or equal to 10 microns in diameter (PM10).

Anglo “record” the levels of PM10 using a one tapered electronic oscillating microbalance (TEOM) sensor and two high volume air samplers (HVAS) sensors. (I’m not too certain about the HVAS sensors, as you will see.)

Here is their PM10 data (as an example) from their 2013 Annual Environmental Management Report (AEMR):

(Source: Drayton AEMR.)

And here are the historical levels:

Source: AEMR

The yellow bars I have added, taking the numbers recorded from their environmental reports over this period.

For the period in question, Anglo claims that PM10 pollution levels have remained in a flat band around 15 µg/m3.

However, what is catching coal companies out now is that the National Pollutant Inventory (NPI) is also recording PM10 data and their figures for Drayton for the same period tell a different story.

Drayton mine coal tonnage: Anglo American Annual reports 2004-2015.

I will return to this chart periodically however, for this, the lines of note are the two blue lines and the red line.

The darker blue line shows what the NPI’s PM10 figures for Drayton. The red line shows what Anglo claim is their PM10 pollution release.

In the period from 2009-10 through 2011-12, the NPI says that Drayton’s PM10 release went up in a sharp peak — by 166% to 2010-11 and 176% to 2011-12.

Yet the red Drayton line shows no corresponding sharp jump.

The dashed blue line shows where I project the Drayton line should have gone if their recording of PM10 pollution release was adequate — clearly an anomaly here.

So I contacted air quality expert for Environmental Justice Australia (EJA), James Whelan, to get his thoughts.

I showed him my graphs and he agreed there was enough here to warrant further investigation.

Saying via email:

In general, your observation is accurate — that the annual PM10 concentrations reported by Anglocoal should approximately follow the trend of their NPI reported emissions.

During the last four years, Drayton’s NPI reports have shown a two-thirds reduction in PM10 emissions but the annual average PM10 concentrations have remained more or less unchanged.  

It’s also important to note that the annual average PM10 concentrations reported at the nearest three OEH monitoring sites were higher — 19.1ug/m3 at Muswellbrook, 20.5 at Maison Dieu and 16.7 at Muswellbrook North West.

The Office of Environment and Heritage (OEH) monitoring sites that James mentions, are part of the Upper Hunter Air Quality Monitoring Network (UHAQMN) and here is their location:

Here are their averages:


So as you see in the graph, Muswellbrook and Maison Dieu, particularly, show similar peaks of PM10 pollution in the years 2012 and 2013. (Maison Dieu wasn’t commissioned till 2011).

Why, then, is there a difference? Well, this is where the "inadequate" part comes in.

As far as I can tell, Drayton’s PM10 figures come from one sensor, the TEOM sensor located to the north and east of the mine. They also have the two HVAS sensors, which record PM10 but the data they present for PM10, only seems to be from the single TEOM site.


And here are the wind direction charts from the Drayton Environmental report 2014:


The first issue is that for the bulk of the year, the wind blows any PM10 pollution away from the TEOM sensor. Is it any wonder, then, that it records low, or do not reflect PM10 pollution figures?

Any scientist will tell you for an experiment’s results to be valid, it requires replication, so getting their data from one single sensor is clearly inadequate. To clarify that, here is what it says in the 2014 Annual Environmental Management Report (note singular TEOM):

Please note that neighbouring mine Mt Arthur has six TEOM sensors ringing the mine and their figures are dodgy enough. 

For Anglo to be claiming that Drayton’s PM10 release is regularly low is farcical. And it seems the EPA agrees with me, because they have recently ordered that Anglo install four extra sensors, known as e-samplers, to be placed at Drayton mine.

Seen here in green:


However, this is farcical as well, as Drayton mine is now winding down to a close and so what was needed was these e-samplers, in these positions, from the moment the mine began operating. Any data that comes from these e-samplers will now show low levels of PM10 as there is little or no coal mining going on.

Additionally I found this in the Drayton 2015 Annual Environmental Management Report:


It seems possible that the EPA may finally be checking as closely as the community of Muswellbrook desire.

Also, returning to our main graph, you may well ask why does the NPI report increased pollution in the peak years when the coal tonnage (seen in purple) of Drayton is dwindling away?


Well that is likely due to the type of mining going on. Any open cut coal mine gets the easiest coal – that closest to the surface – first (obviously). As the life of the mine wears on, they have to go deeper and harder to keep the same amount of coal coming up out of the ground.

In these pictures, you can see the changes in Drayton mine from 2011 (left) to 2012.

Here I’ve clarified that from Google Earth Pro:

The yellow outline shows the extent of mining in 2011, while this picture shows the current outline. The white circles indicate the north, east and south pits, where Anglo went deep and hard to get more difficult coal.

In the process of this, I conjecture the PM10 pollution into the atmosphere went up sharply.

This means that the PM10 pollution levels recorded by Anglo American are in no way adequate — and show why the NPI’s data varies from Anglo’s so significantly.

Part 2: The Drayton South proposal

All of this has come to light because the Drayton mine is winding down to closure and, to put off having to do the rehab, Anglo have applied for an extension of Drayton, called Drayton South.

A central plank of their application is that the new mine will not contravene the air quality exceedance levels. However, as shown above in copious wording since the air quality data from Drayton itself is hopelessly inadequate, the modelling for Drayton South’s air pollution which is based upon it is hopelessly flawed as well.

I did my checking and the first instance of this inadequate data was found in the Drayton South proposal. Here the environmental consultants Hansen Bailey report different figures from Anglo for Drayton’s PM10 pollution. I contacted Hansen Bailey and asked why there was a difference but got no reply.

Here is the email I sent:

(Also you may note 2014 is listed there twice, I have to assume this is a typo.)

Now, I say that Drayton South will contravene the PM10 exceedance levels and here’s why. For a start, the National Environment Protection Measure (NEPM) exceedance figure has been brought down from 30 to 25 µg/m3. However, the planning department in their final notes to have Drayton South reviewed by the PAC, use the old 30 µg/m3 figure. So, I contacted the planning department and asked them why they used the wrong exceedance level. Here is their reply:

The NEPM provides national guidance to all States and Territories on establishing air quality standards. However, each participating jurisdiction across Australia is responsible for the application of these standards under its own laws and policies.

Currently, the revised standards in the NEPM have not yet been adopted in NSW.

To that I respond with, well why is it on the NSW EPA website now?

However, the maths still applies, if you look again at this graph from the UHAQMN:

You will see that Maison Dieu exceeded the 25 µg/m3 limit in the heavily polluting years at Drayton.

Muswellbrook (in blue) also came close to 25.

Here is the location of Drayton South:


The horse studs of Woodlands – now known as Darley – and Coolmore are shown here because they are the main objectors to Drayton South going ahead.

And I’ve shown it more clearly here from Google Earth:

Drayton South is now much closer to the sensors at Jerry’s Plains and Maison Dieu. Furthermore, as the prevailing winds are south-east in summer and north-west in winter, then another sensor ought to be added, if Drayton South is approved, immediately to the north-west of the mine, to pick up the high PM10 release of the dry years of summer.

Drayton’s coal tonnage was around four million tonnes a year, while Drayton South is scheduled to bring up around five million tonnes a year (73.5 million tonnes over 15 years) — approximately a 20-25% bigger mine.

I would suggest that Drayton South will overtop the 25 µg/m3 limit at Jerry’s Plains and Maison Dieu from the moment it goes into full production.

Indeed, if you take the peak readings of 26 from Maison Dieu and multiply it by 125% you get 32.5 — and so, even with the old standards, this mine will top out into the illegal zone.

So thanks for being with me on the journey and here, at long last, are the repeated conclusions:

  1. The data on PM10 from Drayton mine is totally inadequate and so cannot be used in any fashion to model likely PM10 pollution release at Drayton South.
  2. Crude, broad brush stroke maths on increased coal tonnages shows that Drayton South will exceed the 25 – and likely 30 – µg/m3 limits at the Jerry’s Plains and Maison Dieu sensors.

Thus, the Drayton South application can be turned down flat and now, by the Planning and Assessment Commission, without need of further review.

Lachlan Barker blogs at You can follow him on Twitter at @cyclonecharlie8.

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