The above aerial photo from the 14.4.2018 with the 300 tonne dump truck in the foreground shows the sheer amount of water in the Maules Creek mine pit. It’s deeply concerning given that the Tarrawonga and Boggabri coal mines are both dry and that the original EIS modelling estimated only 36 ML of groundwater would have flowed into the Maules Creek coal pit over the last 12 months.

Without transparent data to the contrary, this raises the significant prospect of connectivity of the coal seams to the Maules Creek alluvial aquifer.

De-watering Pump

In order to drill, blast and excavate the coal, the mine is systematically de-watering the coal seams.

The de-watering pump in the Maules Creek coal mine can be seen in this short video. According to the 2014 Water Management Plan the discharge from this pump ends up in the Mine Water Dam to be used for dust suppression.

The question for local people is – is the mine only de-watering the coal seams?

One 100 mm pump such as those shown here could move a lot of water if operated 24 x 7, 365 days per year. A 150 mm pump could move much more.

With pit pumping conditions similar to those at the Maules Creek coal mine (70 m head and 800 m of lay flat hose), according to suppliers, a 100 mm pump could lift 30 – 50 litres per second, 2.5 – 4.0 ML per day or 946 – 1,575 ML per year.

The last few months have been dry (with approx 40% of average rainfall)¹ and the full pumping capacity should not be needed at the Maules Creek coal mine to manage pit inflows. 

Groundwater Modelling

The groundwater consultants (AGE) estimated in the Groundwater Impact Assessment very minor pit inflows or “seepage” when they simulated over 30 years the average groundwater inflows to the Maules Creek and adjacent mines.

(See Fig 6.10 Maules Creek coal mine Water Management Plan.)

AGE’s 2014 modelling predicts the average annual loss of recharge to the alluvium due to seepage into the Maules Creek coal mine is a mere 50 ML/year. Even less in year 5. In fact the Water Balance model of the mines water usage shows a decline in groundwater inflow over the first 5 years to just 36 ML in year 5.

However given the current dry patch, the lack of runoff and the significant volume of water in the pit, how realistic is the AGE estimate of 36 ML “seepage”?

Anecdotal evidence is that this pump has been running for much longer than 1 hour per day over the last 14 months. If true, this would indicate a substantial variation from what the State Government has approved. Without any transparent data to the contrary it is time for the regulators to act.

Regulation

The estimated pit inflows to the Maules Creek mine are the basis for the monitoring and the Adaptive Management requirements of the project approval. If monitoring of the groundwater inflow shows adverse groundwater impacts then this should trigger a management response as required by the 2014 Water Management Plan section 6.3.4;

“Should monitoring results be outside of the predictions made within the Groundwater Impact Assessment (as summarised above) and indicate a substantial variation beyond the trigger levels presented, then an investigation into the data will be implemented to confirm the reason for the variation and to implement the relevant actions. The process of investigation that will be implemented is described further in Section 7.0.”

This ties vaguely to Schedule 5 of the project approval which requires notification within 7 days;

“Incident Reporting

Schedule 3 Section 40 of the project approval referrd to in the Adaptive Management section of Schedule 5 says;

Now that water supplies in the Maules Creek area are running low, residents are questioning the impact of mining and the ability to improve water levels given the existing baseline data, the monitoring of mine water usage and the state governments regulatory processes.

The Maules Creek coal mine was approved with a series of conditions that required the development of groundwater management plans, the validation of computer modelling, the development of adaptive management triggers and response plans, and self regulation by the mine itself.

It is hardly a recipe for the early identification and resolution of problems without strong government oversight. Based on past experience with noise and dust, mine self-regulation is unlikely to work should anything threaten the mine’s operations and returns to it’s shareholders.

Unfortunately, the government itself is conflicted. At the same time as the mine was being approved and constructed, the Department of Water was being systematically gutted, with the removal of operational staff, technical experts and middle management, leaving only the licensing division and the politically connected senior management to “supervise” any complaints and then manage the fallout.

Now, as water levels decline, the regulatory regime will come under the microscope and it is important to note that the potential for groundwater impacts were raised strongly prior to the projects approval.

The Peer Reviewer of the Maules Creek coal mine groundwater modelling had serious doubts back in 2012.

“Using the MDBC guidelines checklist, the modelling is found to be deficient and/or lacking in the areas of calibration, verification, sensitivity analyses and uncertainty analyses – each to varying degrees.”

“The primary risks of impact being assessed are associated with the alluvial systems yet the connection between the alluvial and bedrock systems in the calibrated model are not assessed to the previous studies and conceptual model to provide the reader with any confidence the model is replicating reality.“

In fact groundwater specialists engaged by Maules Creek coal said exactly that on Page 62 of their Groundwater Impact Assessment;

“The model therefore simulates a continuous hydraulically interconnected aquifer system, which is not present in reality.”

Its inconceivable that the model didn’t represent reality raised no red flags for the miners, the Dept, the PAC and the regulators. The company simply paid another expert, as did the PAC, to confirm that everything was OK.

The Peer Reviewer for the local community gave a foretaste of the situation at the Werris Creek coal mine (and potentially at the Maules Creek mine) whereby the miner points to the results of their deficient theoretical groundwater model while blaming “the drought” for dry bores, while the mine pits are flooded with water. The Peer Reviewer lamented back in 2012 that the Groundwater Impact Assessment did nothing to assist with accountability should a groundwater problem arise.

“A clear method for identifying mining related loss of well yields from background yield losses should be defined up front to eliminate any confusion or difficulties after the fact.”

However it is this same deficient theoretical model which is now being use to regulate the mine 5 years later and it is time that the assumptions that were used are tested.

The Maules Creek Water Source Management Zone is part of the larger Namoi Water Sharing Plan (WSP). The Maules Creek Tributaries Management Zone (shown above) includes the Maules Creek coal mine which has a pump in the bottom of the pit that is de-watering the mine. This pump should, in theory, be covered by the Namoi WSP – but its all in the definitions.

Licences

The Maules Creek coal mine owns the 78 ML “Green Gully” water licence 12479 which is subject to the cease to pump rules in the Namoi WSP when less than 1 ML per day is flowing across Elfin Crossing.

The mine also owns the 138 ML licence (12811) that came with “Olivedeen” in Zone 5, the 3000 ML high security Namoi River licence (13050) and the newly created 300 ML Porous Rock licence (29588) which was granted on the 21st of June, 2012, for perpetuity.

The Porous Rock licence was granted just 4 months prior to the mines state planning approval on the 23rd of October 2012 and just 18 days after the Namoi WSP commenced on Oct 4, 2012.

Modelling

The “Green Gully” 78 ML per annum licence is sufficient to cover the .25 ML per day that the groundwater modelling in the EIS estimated would be lost from from Zone 11 groundwater.

However 78 ML is insufficient to cover the output of the de-watering pump so the remainder of the de-watering of the pit (based on the groundwater modelling estimates) relies on the newly created Porous Rock licence and its exemption in the newly commenced 2012 Namoi WSP.

Definitions

The WSP definition of Porous Rock would include coal seams.

“Porous Rock” means consolidated sedimentary rock containing voids, pores or other openings (such as joints, cleats and/or fractures) which are interconnected, in the rock mass and which are capable of transmitting water.

However the real world situation is not so cut and dry. We know from the geology of Maules Creek that the coal seams within the Maules Creek pit could extend out to underlie, intersect or otherwise connect to the Maules Creek alluvial aquifer.

Exemption

But, unfortunately the Namoi WSP Part 1, section 4 (5) (a) specifically excludes water from the Porous Rock from water sources managed under the WSP.

This means that water pumped from the coal seams that originated from the alluvial aquifer could circumvent the Namoi WSP cease to pump triggers.

If there is any suspicion that the alluvial aquifer water that was running across Elfin Crossing is now draining into the mine pit, for full transparency, the de-watering pump should be metered like other pumps in the region. Then the groundwater model can be independently verified.

The Maules Creek mine NSW planning approval provides a mechanism for independent verification of the groundwater model. It might be time to do just this.

Section 40 of the PAC approval concerning the Water Management Plan says that the proponent shall prepare a plan that is acceptable to the Secretary of the Dept of Planning including a 3 yearly independent review of the groundwater model and a plan to “respond”.

• a program to validate the groundwater model for the project, including an independent review of the model every 3 years, and comparison of monitoring results with modelled predictions; and
• a plan to respond to any exceedances of the performance criteria;
  

This Map and the legislative detail of the Namoi WSP for the Unregulated and Alluvial Water Sources is made under section 50 of the Water Management Act 2000.

According to the Namoi WSP, the Namoi Unregulated Rivers Water Sources include all water:

(a)  occurring naturally on the surface of the ground within the boundaries of the Namoi Unregulated Rivers Water Sources shown on the Plan Map, and

(b)  in rivers, lakes and wetlands within the boundaries of the Namoi Unregulated Rivers Water Sources shown on the Plan Map.

Groundwater Dependent Ecosystems (GDE):

Despite the presence of Stygofauna in the Maules Creek Alluvial Aquifer, the Namoi WSP does not identify any high priority GDE’s.

Shocker!

Maules Creek geology has a lot to do with the groundwater behaviour in the area. The above map was taken from the Upper Namoi Groundwater Source Status Report – 2006 – 2011, which provides a useful summary of groundwater history in Maules Creek – pre-mining.

Zone 11 is a small part of the Namoi Valley Groundwater Region (see map) but boasts a significant inventory of groundwater monitoring bores (12), including 5 with telemetry. Find out more here – Groundwater monitoring at Maules Creek.

The Status Report makes it plain the financial and operational pain that groundwater entitlement holders have shouldered, with allocations reduced by 75% in order to stabilise the declining groundwater levels in the district;

“At the commencement of the Plan on the 1st November 2006 groundwater entitlements in the Zone 11 were reduced from approximately 8.7 GL down to 2.2 GL.“

“The objective of the Plan is to reduce the total extraction in Zone 11 to 2,200 ML by the 2016 – 2017 water year.”

The objectives of the Plan were largely achieved by 2011 with a significant reduction in entitlements and annual groundwater usage, well before the 2016 – 2017 deadline.

Ironically, 2016 – 2017, could contain the biggest threat to Zone 11 groundwater levels that we’ve seen. And this threat could come not from the irrigation industry but from the connectivity of the alluvial aquifers with the coal seams  which underlie much of Maules Creek.

The drilling campaign through the Maules Creek alluvium and the underlying coal seams in the early 1980’s by Kembla, Coal and Coke showed dark grey coal. This information is freely available from the NSW Planning and Environment website “Minview”. It  shows the location of the boreholes in the alluvium and if you click on the location of the boreholes, the details of the borehole, gps coordinates, etc can be viewed.

1. MAC0034 on Harparary Road next to the Maules Creek Hall,
2. MAC0068 (near Horsearm Crossing),
3. MAC0020 (Maules Creek Crossing),
4. MAC0071 (Middle Creek Crossing),
5. MAC0067 (Middle Creek Road near cattle yards),
6. MAC0015 (Ellerslie Road).

A map of the Maules Creek Alluvial Aquifer can be seen here.

This map taken from the Aston Resources EIS shows Maules Creek running above and adjacent to the shallow coal seams. It hides the known extent of the coal seams that underlie the alluvium.

Its a real worry, as attested by the unconstrained pumping and rapidly declining groundwater near Chinchilla in Queensland due to CSG pumping. The pumping clearly illustrates that coal seams are permeable and transmit water – and that aquifers can dry up entirely if the extraction from the coal seams is allowed to continue.

It is a strong warning for Maules Creek residents. If the Maules Creek alluvium is directly connected to the coal seams or is affected by faults or other mechanisms, there is nothing to stop that groundwater flowing all the way to the coal pit operated by Whitehaven.

Because there are a number of coal seams in the Maules Creek area, only one or some of the seams are needed to transmit water and the original Groundwater Impact Assessment by AGE in the Aston EIS said as much on page 38;

“It can be seen from Figure 10 that the upper seams in the sequence are incomplete having been eroded by peat drainage systems and are therefore limited in extent and controlled by topography. This means that some of the shallow seams in the sequence do not extend under, or have a direct hydraulic connection to the alluvial aquifer as they do not form continuous layers on a regional scale.”

Said another way, some of the shallow seams do extend or have a direct hydraulic connection to the alluvium.

Now, 5 years on, it is incomprehensible that a precautionary approach was not taken prior to coal development. The rampant greed was a very ugly sight and with the high risk to our groundwater it is no wonder the donations flowed to smooth the way prior to the mines approval.

A Citizen Science group based in Maules Creek, near Narrabri, has been in Adelaide presenting at the national Australian Citizen Science Conference about the air pollution problems in coal mine affected communities in the NorthWest.

The Leard Forest Research Node has conducted dust monitoring in the vicinity of Maules Creek coal mine and Boggabri township, concluding that the current self-reporting by Whitehaven Coal does not reflect the lived experience of residents who experience excessive dust from open cut coal mines and uncovered coal train wagons.

Like other environmental groups, the LFRN has been critical of the high number of negative dust readings reported by Whitehaven Coal at its Maules Creek monitoring station, sometimes being up to 30% according to LFRN researcher Ms Amelie Vanderstock who last year won the University Medal for Science at the University of Sydney for her work on mine dust pollution in the Maules Creek-Boggabri area.

“My research revealed that more dust was deposited on the leaves of tomato plants along a 12 km transect closer to the Maules Creek, than was deposited further from the mine,” she said. “Yet Whitehaven argues that the dust is coming towards the mine from farms, forest and the outback.”

Another controversial aspect of Maules Creek mine reporting is the very high number of negative dust readings, which the NSW EPA appears to condone.

“The excuse for this high number of negative readings is that the air is too clean and causes the equipment to malfunction,” said Ms Vanderstock. ”However the number of negative values at Shenhua’s Breeza proposed mine – where there is currently no mine – is less than half of that at Maules Creek. Obviously the ‘air too clean’ theory requires further investigation”

“The 24-hour average PM10 concentrations self-reported by the company are often significantly low. Looking at all the monitoring data collected by the EPA in 45 locations around NSW, there are very few 24-hour average PM10 concentrations as low as Maules Creek, even in agricultural regions that have no open cut coal mines,” said Ms Vanderstock.

“There are many troubling question marks about the company’s self-reporting. The community has taken matters into its own hands and is now obtaining answers via the independent community science we do at Leard Forest Research Node,” said Ms Vanderstock.

Keynote Speaker at the conference was the Australian Chief Scientist, Dr Alan Finkel.

Groundwater levels are on the decline in Maules Creek. The graph (above) of the Green Gully groundwater monitoring station (GW967138.1.1) shows a decline in levels since mid 2016 with the short term graph below showing a 20 cm decline in the last 30 days with the station recording .5 C warmer groundwater.

This is confirmed by the Thornfield groundwater monitoring station (GW041027.1.1) short and long term graphs. The data shows that the situation is more pronounced further up the catchment with the long term graph showing groundwater levels at historical lows in upper Maules Creek.

Anecdotal evidence is that a number of bores in the district are starting to run low and some residents are seeking alternate supplies or cleaning out their bores to improve flow.

While fluctuations in the water table are normal the current situation is of concern because the district is not even in drought.

In fact the BOM historical rainfall data shows 923.6 mm fell at Mt Kaputar for 2017, with 320 mm falling in the final three months. This is only 4 mm below the annual average rainfall of 927.2, and the Oct – Dec 2017 total was 16 mm above the long term average of 301 mm. (Mt Dowe rainfall averages here)

At Elfin Crossing the groundwater monitoring station (GW967137.1.1) shows that water levels have declined by 6 cm over 30 days. Long term levels (below) appear to have remained comparatively constant over 2017.

This tells us what we already know: average rainfall is not enough to maintain groundwater in our district without regular surface water flows in the creeks to recharge the aquifer. The longer we go without stream flows, the less water there is in the aquifer – and the more important reliable groundwater becomes.

This situation can be exacerbated by:

1. Any changes to climate that reduces the number and/or duration of runs in the districts creek system that crosses recharge areas
2. Unmetered pumping by irrigators
3. A increase in surface water diversion or groundwater demand from coal mining

All could have big impacts for Maules Creek residents. When things are finely balanced, transparency of water use is paramount with reliable, real time data a necessity.

Despite there being a dozen or more mine owned water monitors as shown by this map, none of this data is available in real time. Nor is there objective data of rainfall and runoff diversion from the Maules Creek catchment. All residents have to go on is this short report of mine water usage via the Maules Creek coal mines water balance in the 2016 Annual Review. 

The water usage report indicates that there is negligible groundwater inflow into the pit but mentions significant capture of rainfall and runoff of 1860 ML. It appears that captured rainfall and runoff is not objectively measured. The figure is difficult to substantiate as it is based on predictions in water balance modelling conducted way back in 2014.

This means mine owned groundwater data and surface water capture data is not available in real time, nor can it be independently verified.

Groundwater shortages are beginning to be an issue now in early 2018 and the yet the best information that we will have, the 2017 Annual Review, is still a way off.

In the event of a landholders bore failure, the coal mine at Maules Creek says in it’s current Water Management Plan (last revised in 2014);

“Should the Project be determined to impact on the water supply at any privately owned bore, Maules Creek Coal will provide a suitable alternative water supply in consultation with the landholder. The process of determining the impact on the privately owned bore will also be undertaken in consultation with NOW and to the satisfaction of the Director-General, consistent with Statement of Commitment no 24 and Condition 40 of PA 10_0138.

Should drawdown attributable to mining be detected within any private bores within the predicted zone of depressurisation, the need to expand the bore census beyond the area visited as part of the 2011 EA will be assessed. A more expansive bore census will also be undertaken should any updates to the groundwater model indicate a more extensive zone of depressurisation.”

With the current information “asymmetry” landholders will find it difficult to determine where the fault may lie.

Details of bore numbers on your property and other helpful NSW Government water links can be found here on the MCCC website.

Further information about the Connected Waters Study from the UNSW that is developing tools to investigate the connectivity between surface and groundwater (and is based on research conducted at Maules Creek), can be found here.

Rather than fix their noise problems, Whitehaven coal are seeking to delete sound power controls from s12(a) of the noise approval conditions for its opencut coal mine at Maules Creek. The relevant clause says;

“(The proponent shall) ensure that all equipment and noise control measures deliver sound power levels that are equal to or better than the sound power levels identified in the EA, and correspond to best practice or the application of the best available technology economically achievable;”

The community reacted strongly to this push to water down noise conditions. In all there were 116 submissions, 16 NGO, 97 public submissions and 3 government agency. All NGO and public submissions objected to the proposed sound power modification. The agency submissions made comment.

Still the company is not listening to the community. You can see its Response to Submissions (RTS) here.

This process follows the findings of the Mandatory Noise Audit ordered by the EPA. The audit found that the Train Load Out and Train Load Out Transfer Station are noisy, exceeding Environmental Assessment limits by +12DBa, +11DBa. It is very likely that the exceedences of these noise limits have triggered the company to seek changes to its approval conditions – basically because it can’t comply.

Whitehaven disagree – saying it has a strong record of compliance and it’s merely the removal of duplicate wording that they are spending our time and their money on (LOL).

“The intent of removing this wording is to reduce duplication as similar wording already exists elsewhere in Project Approval 10_0138″

Despite it’s protests the company commissioned a new, and presumably expensive report from Global Acoustics (GA), 40 days after submissions closed. In doing so the company ignored due process by not giving the community opportunity to comment. The report by GA confirmed the companies non-compliance in relation to equipment sound power and control measures;

“Five fixed plant items exceeded relevant NMP sound power targets, including:

• secondary sizer
• raw coal transfer station

  

• CHPP product transfer stationary
• train load out transfer station and conveyor drives
• train load out”

Despite this, the GA report made no recommendations as which effective noise control measures the company could employ (as required by s12a) to meet its sound power obligations.

Whitehaven continues to ask the wrong question. i.e. How can it remove the noise controls, not how can it comply.