PPC Riebeek West Upgrade Rev 0_1

Project done on behalf of Aurecon (Pty) Ltd

PROPOSED UPGRADE TO PPC’S EXISTING CEMENT MANUFACTURING PLANT AND

ASSOCIATED OPERATIONS IN RIEBEEK WEST, WESTERN CAPE:

AIR QUALITY IMPACT ASSESSMENT

Report No.: 10AUR16 Rev 0.1

DATE: SEPTEMBER 2011

L W Burger

REPORT DETAILS

Reference 10AUR16

Status Revision 0.1

Report Title Proposed Upgrade to PPC’s Existing Cement Manufacturing Plant

and Associated Operations in Riebeek West, Western Cape: Air

Quality Impact Assessment

Date September 2011

Client Aurecon (Pty) Ltd

Prepared by Lucian Burger PhD (Natal), MSc Eng (Chem), BSc Eng (Chem)

Declaration of Independence

I, Lucian Burger as authorised representative of Airshed Planning

Professionals (Pty) Ltd hereby confirm my independence as a

specialist and declare that neither I nor Airshed Planning

Professionals (Pty) Ltd have any interest, be it business, financial,

personal or other, in any proposed activity, application or appeal in

respect of which Airshed Planning Professionals (Pty) Ltd was

appointed as air quality specialists in terms of the National

Environmental Management Act, 1998 (Act No. 107 of 1998), other

than fair remuneration for worked performed, specifically in connection

with the assessment summarised in this report. I further declare that I

am confident in the results of the studies undertaken and conclusions

drawn as a result of it – as is described in this report.

Signed………………….. Date………………….

Acknowledgement The authors want to thank Justin Dell and Gerswain Manuel of

Pretoria Portland Cement Company Limited for supplying all the

necessary technical information to complete the assessment.

Proposed Upgrade to PPC’s Existing Cement Manufacturing Plant and Associated Operations in

Riebeek West, Western Cape: Air Quality Impact Assessment Report No.: 10AUR16 Rev 0.1 Page ii

EXECUTIVE SUMMARY Airshed Planning Professionals (Pty) Ltd were appointed to assist Aurecon (Pty) Ltd in assessing the potential air pollution impacts associated with the proposed upgrade of the PPC Riebeeck cement manufacturing facility near Riebeek West, Western Cape. PPC already operates a manufacturing facility at the site and has the capacity to produce 570 000 tonnes of clinker per annum. PPC Riebeeck West proposes to upgrade the current cement plant through the incorporation of a new and efficient kiln together with a number of ancillary equipment, including raw mill and coal grinding/processing, and clinker product grinding. The existing infrastructure on the operational plant would be utilised with the ultimate scrapping of two old inefficient kilns currently operating on site. The proposed upgraded cement manufacturing facility is being designed for a clinker output capacity of 800 000 tonne per annum. This would enable the manufacturing of up 930 000 tonne per annum cement. TERMS OF REFERENCE The assessment required the impact quantification of the potential air pollution resulting from the upgraded cement manufacturing facility and associated mining activities. The scope of work included in the investigation may be summarised into the following three main tasks:

• Baseline assessment of current conditions in the study area; • Predicted air pollution impacts of the proposed project, including

o upgraded cement production facility; o mining processes; and o overburden dumping

• Air quality management plan (for incorporation into Environmental Management Plan)

ASSUMPTIONS AND LIMITATIONS Onsite meteorological data was only available for the period January 2010 to December 2010. The alternative would have been to perform the simulations with meteorological data from the nearest South Africa Weather Services’ station at Malmesbury. However, a comparison of the two datasets clearly shows that the latter observations do not reflect the influence of the Kasteelberg Mountain range in the wind field. Due to these differences, it was decided to rather use the year’s onsite dataset than the data available from the Malmesbury weather station. This limitation is not considered significant since the annual variations are generally not significant in the Western Cape region. No historical upper air data is available for the study area. As a result, upper air data for 2010 was obtained from the South African Weather Services’ Unified Model, which was extracted at a grid-point closest to the PPC Riebeeck facility.


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Long-term, baseline air quality monitoring was only conducted for dust fallout, and includes the period 2000 to 2010. A short, three-month monitoring campaign of airborne inhalable particulate matter was completed during 2007 (June to August). Sulphur dioxide and nitrogen dioxide were also monitored during 2007 for a month using passive diffusive sampling methods. Although there should be no reason why the results for the particulate, sulphur dioxide and nitrogen dioxide will vary significantly, it was nonetheless decided to conduct a further, albeit a similar short-term (May to June 2011) monitoring campaign for the current study. This campaign included inhalable particulate matter, sulphur dioxide, nitrogen dioxide and volatile organic compounds. Given the availability of information, it was assumed that the combination of these observational results and dispersion simulations of the main air pollutant sources, namely PPC Riebeeck West and agricultural activities, would adequately describe the current air quality in the study area. In order to estimate the current air quality in the study area use was made of emission measurement results and emission factors for stack emissions at cement manufacturing plant. Emission factors where used to estimate all fugitive emissions resulting from material transfer, mining activities and transport. Similarly, emission factors where used to quantify windblown dust originating from agricultural activities. These emission factors generally assume average operating conditions. Agricultural activities typical for the month had to be assumed. This therefore resulted in monthly average dust emission rates. Due to differences in individual farming practices and short-term meteorological conditions, these emissions can in reality vary significantly from day-to-day and diurnally. The predicted dust emissions from agricultural activities can therefore only be used for long term (monthly to annual) comparisons. Highest hourly and daily incidents cannot be predicted accurately. Due to the difficulty in quantifying emissions from all dust sources such as public gravel roads, these were not included in the baseline and predicted air concentration estimations. The air pollution impact of gases and dust generated by haul trucks (bag carriers and tankers) travelling to and from PPC were however included. PPC currently implements an unpaved road watering programme to minimise vehicle-generation fugitive dust from these sources. For the purposes of this assessment, it was assumed that the programme is implemented routinely and according to the plan, which would control the emissions by 75%. The same programme was assumed for the proposed upgrade. Although the main tasks of the construction phase were provided, the detail required to estimate emissions from every activity were insufficient to allow the establishment of an accurate emissions inventory. All of the planned improvements would be undertaken on the existing plant site and the approximate area of construction estimated. The construction impacts were therefore based on an area-wise emission factor, rather than activity-based. This limitation is not considered significant since the construction activities do not include major earthworks, which may otherwise have resulted in an under-estimate of the construction impacts. In order to estimate the air quality due to the proposed upgrade use was made of the Department of Environmental Affairs’ Minimum Emission Standards as prescribed by NEM-


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AQA (Section 21) and emission factors. Emission factors where used to estimate all fugitive emissions resulting from material transfer, mining activities and transport. METHODOLOGY The following steps were followed in the assessment:

• Obtain all existing air quality monitoring data for the immediate area; • Obtain surface and upper air meteorological data for the region; • Identify all sources of emission and their associated pollutants for the current

operation; • Complete an air quality monitoring campaign for those pollutants not included in

available database; • Obtain detailed descriptions of proposed mining plans, processing facility and waste

disposal; • Identify all sources of emission and their associated pollutants for the proposed

operation; • Quantify existing emissions from PPC Riebeeck and other potentially significant

sources such as the surrounding agricultural activities; • Quantify existing gaseous and particulate emissions from haul trucks, including bag

carriers and tankers, travelling from PPC Riebeeck.; • Simulate the atmospheric dispersion of current emissions using an internationally

recognised models; • Compare predictions to observations of key pollutants; • Quantify emissions from the proposed operation; • Quantify gaseous and particulate emissions from increased haul trucks due to

proposed facility travelling from PPC Riebeeck; • Simulate the atmospheric dispersion of emissions from the proposed operations

using the same models that were used to establish the current air quality; and • Analyse the significance of identified pollutants using human health and nuisance risk

criteria and vegetation impact. • Assess emissions with respect to NEM:AQA Listed Activities

RESULTS Current Air Quality A dust fallout monitoring network records deposition rates at four locations around the PPC facility. Apart from the monitor located near the quarry, all monitors indicate a net export from the PPC facility, ranging from 2.4% near the overburden dump to 6.6% at De Gift. The results from chemically analysing the sixteen fallout bucket samples indicate that the calcium fallout from the PPC facility is about 6%. The smallest amount of daily dust was collected during the winter season and the highest amount during the summer months, as shown below:

• winter season : 76 to 168 mg/m²/day


Riebeek West, Western Cape: Air Quality Impact Assessment Report No.: 10AUR16 Rev 0.1 Page v

• spring : 157 to 316 mg/m²/day • autumn : 189 to 438 mg/m²/day • summer season : 395 to 571 mg/m²/day

The measurements also indicated that the highest daily exports during summer, autumn and winter is towards the east. This is followed by the west, north and lowest to the south. During spring, the highest exports are to the west, followed by east, then south with the lowest to the north. On an annual basis the highest daily imports came from the south and east. A relatively short, one month sampling campaign at Delectus and the Rugby Field was performed from June to August 2007 to measure air concentration of PM10. No exceedences of the DEA limit value of 75 µg/m3 for PM10 was observed. The maximum daily average of 66 µg/m³ was recorded at the Rugby Field. The second campaign (May to June 2011) reflected similar observations at the Meteorological Station, with a maximum daily average recording of 50 µg/m3. Ambient air concentration levels of sulphur dioxide and nitrogen dioxide were determined using passive diffusive samplers during June/August 2007 and May/June 2011. These sampling units were located at three sites with the first campaign, namely the Rugby Field, Delectus and Vlakkerug. Low concentrations of both nitrogen dioxide (2.8 µg/m³) and sulphur dioxide (<1 µg/m³) were recorded during this period. These are well below even the annual average DEA limit values of 50 µg/m³ for sulphur dioxide and 40 µg/m³ for nitrogen dioxide, respectively. During the second campaign, the samplers were located at the following locations:

• PPC Meteorological Station (approximately south of the plant) • PPC Conference Centre (approximately east of the plant) • PPC Property Boundary West (approximately west of the plant) • PPC Property Boundary North (approximately north of the plant)

Both the SO2 and NO2 concentrations (maximum of 2 µg/m³ and 8 µg/m³, respectively) were slightly higher than that observed during the previous campaign; however they were still very low compared to the annual DEA limit values. The highest NO2 concentration was observed at the Meteorological Station, whilst the highest SO2 concentration was observed at the Conference Centre. Air concentration measurements of VOCs were also included during the second campaign at the same locations as for SO2 and NO2. Of all the VOC’s only toluene was observed at all four locations, with the highest value of 5.3 µg/m³ observed at the Meteorological Station. This station also observed the highest xylene concentration of 4.4 µg/m³. Xylene was also observed at the Conference Centre, but not at any of the other two locations. Ethylbenzene was only observed at the Conference Centre. With a detection threshold of 0.2 µg/m³, benzene could not be detected at any of the locations.


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Current Air Emissions The sources of air pollution at the PPC Riebeeck cement facility primarily include the quarry operations, haul roads and process emissions, as summarised below: • Processing

o Dry Kilns • Preparation

o Raw Materials Mill o Coal Mill o Cooler Grate o Finish Mill o Crushing & Screening

• Diffuse Sources o Limestone transfer o Cement Production and Storage o Material Handling o In-pit operations, including

drilling, excavation loading

o Haul roads

• Wind Erosion o Overburden dump o Coal stockpile o Limestone stockpile o Sand stockpile o Run of Mine o General open areas

Additional air pollution arises due to the various agricultural activities in the region and wheel entrainment on unpaved and paved public roads. The most significant pollutants associated with the operation include

• Airborne Particulates: o Inhalable particulates, with aerodynamic diameters less than or equal to 10

micron (PM10) from all mining and processing sources; o Total suspended particulates (TSP), which includes all particle sizes

(generally only up to about 100 µgm) from all mining and processing sources; • Gaseous Emissions, including

o Oxides of nitrogen (NO and NO2, collectively known as NOx); o Sulphur dioxide (SO2); o Carbon dioxide (CO2); o Carbon monoxide (CO); o Volatile Organic compounds (VOC), the most significant including benzene.

Although dioxins and furans would be emitted in small quantities, it was considered in the assessment due to its very toxic nature. Arsenic, cadmium, lead and mercury were similarly included due to public concern. Currently PPC uses FDG within their cement manufacturing process, which they purchase from ArcerlorMittal Saldanha Steel Works. FDG is mixed in the raw mill and then added to the kiln with the other milled materials for calcination. Therefore, in terms of Section 21 of the NEM: AQA, the proposed cement production process trigger Subcategory 5.4: Cement production (using alternative fuels and/or resources) rather than Subcategory 5.3 (using conventional fuels and raw materials). The difference in application between Subcategory 5.3 and Subcategory 5.4 is only due to the usage of FDG in the kiln, i.e. the use of


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alternative resources. The AEL would specifically state that the need for Subcategory 5.4 is due to the use of alternative resources and not using alternative fuels. Furthermore, the Authorities would stipulate in the AEL the nature and maximum allowable consumption rate of the FDG. If PPC wishes to use alternative fuel, this would trigger a new application process, which would require an EIA to demonstrate compliance and a re-application for an AEL. On the other hand, should PPC decide not to use alternative resources (FDG) once an AEL with Subcategory 5.4 has been issued, it is not expected that a new application for the less strict Subcategory 5.3 need to be submitted. This expectation is based on the fact that Subcategory 5.4 includes all the pollutants in Subcategory 5.3, and that these emission limits are all stricter in with the former subcategory. The emissions of pollutants which apply to the Subcategory 5.4 are summarised in Table A. Table A: Estimated pollutant emission rates in the kiln flue gas to be reported in AEL

Pollutant

Total Emissions

(g/s)

Emission Limit(a)

(mg/Nm³)

Stack Gas Concentration

(mg/Nm³) Kiln 1 Kiln 2

Particulate Matter 1.3 80 70 69 SO2 15.4 250 658 648 NOx 24.6 1200 1071 1004 Total Organic Compounds 0.08 10 4 3 Hydrogen chloride 0.4 10 18 17 Hydrogen Fluoride 0.007 1 0.3 0.3 Cadmium & Thallium 0.0001 0.05 0.005 0.005 Mercury (b) 0.0010 0.05 0.04 0.04 As+Sb+Pb+Cr+Co+Cu+Mn+V+Mn 0.06 0.5 2.4 2.3 Dioxins & Furans 3.3 ng/s 0.1 ng/Nm³ 0.1 ng/Nm³ 0.1 ng/Nm³Note: (a) – AEL Subcategory 5.4

(b) – Mercury emissions based on mass balance of all raw material into the kiln Bold entries indicate non-compliance

From Table B it is clear that the current SO2 emission concentrations exceed the limit value of 250 mg/m³, stipulated in AEL Category 5.4. Similarly, emissions of hydrogen chloride and the heavy metal combination of As+Sb+Pb+Cr+Co+Cu+Mn+V+Mn were shown to exceed the limit values. Based on recent mercury chemical analysis (completed in 2011) of all the feed material into the current kiln, and using the maximum measurement results, the mercury emission concentration was calculated to be about 0.04 mg/Nm³. This is marginally below AEL limit value of 0.05 mg/Nm³. The baseline included emissions from the current PPC Riebeek operation and the surrounding agricultural activities. The predicted maximum concentrations are given in Table B.


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Table B: Comparison of predicted current air concentrations to various guidelines and standards

Averaging Period Air Concentration (µg/m³)

SA(a) SANS(b) WB(c) WHO(d)/Other Predicted Maximum

Inhalable Particulates

24-hour 120(a1) 75(a2) 75 70 (h) 100 – 150

Annual 50(a1) 40(a2) 40 50 (h) 50

Nitrogen Dioxide 1-hour 200 200 - 200 291 (NOx) 6 (NO2) Annual 40 40 - 40 2.2

Sulphur Dioxide 1-hour 350 (350)(e) - - 184 24-hour 125 125 125 125 (20) (f) 11 Annual 50 50 50 (g) 1.3

Carbon Monoxide 1-hour 30 000 30 000 - 30 000 22

Benzene

Annual 10(a1) 5(a2) 5 - 1(i) 0.002

Dioxins and Furans Annual - - - 3.0 x 10-7 (j) 1 x 10-9

Mercury Annual 0.04(m) - - 1(d) 0.3(l) 0.00008

Hydrogen Chloride 1-hour - - - 2100(k) 5.0 Annual - - - 9(k) 0.04 Notes: (a) - Current South African Standards (a1) - Valid until 31 December 2014 (a2) - Valid from 1 January 2015 (b) - SANS 1929 Standards (c) - World Bank Guidelines (d) - World Health Organisation Guidelines (e) - Only 10-minute average standards, but a value of 350 has been included as an equivalent. (f) - The latest (2005) WHO guidelines reduced the daily guideline significantly reduced from 125

µg/m³ to 20 µg/m³ (g) - An annual guideline is given at not being needed, since “compliance with the 24-hour level will assure lower levels for the annual average”. (h) - WHO (2000) issued linear dose-response relationships for PM10 concentrations and various health endpoints with no specific guideline provided. WHO (2005) made available during early 2006 proposes several interim target levels (see Section 3). (i) - This value is based on 1 in hundred thousand cancer risk (US EPA). (i) - This value is based on 1 in hundred thousand cancer risk (WHO). (k) - California Office of Environmental Health Hazard Assessment (l) - US EPA inhalation reference Concentration (RfC). (m) - DEAT published limit intended to be protective given multiple pathways of exposure.


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As expected, the most significant pollutant is predicted to be airborne particulates, with predicted exceedances of the DEA daily average limit beyond the PPC cement facility, when considering emissions from other activities in the region (mainly agriculture). Transporting ore and overburden within the mining area and product out of the facility constitute the largest source of emissions. The simulations assumed the current practice of water sprays on the road surfaces. The watering programme controls these emissions by about 75%, which reduce the total TSP and PM10 emissions by about 54% and 40%, respectively. A further reduction can be achieved by controlling emissions from the crusher and screening process. None of the other pollutants considered in the assessment exceeded any of the DEA limit values and standards. Those pollutants which do not have DEA standards were compared to international best practice guidelines and similarly shown to be well within the guidelines. The EU introduced an annual limit value for SO2 of 20 µg/m³ that is protective for all ecosystems and which would be needed in regions without very sensitive ecosystems. The predicted annual average concentration for SO2 is 1.3 µg/m³. Similarly, the critical level for NOx, used by the United National Economic Commission for Europe to map exceedence areas, was given as 30 µg/m³ for annual means. The predicted annual average concentration for NOx is 2.2 µg/m³. The impact from these two pollutants in vegetation is therefore seen to be insignificant. The predicted dustfall level to outside PPC boundary is predicted to be "Slight", i.e. dustfall is barely visible to the naked eye. Nearby the facility and access road, the predictions indicate “medium” dustfall. The DME use the 1 200 mg/m2/day threshold level as an action level. In the event that on-site dustfall exceeds this threshold, the specific causes of high dustfall should be investigated and remedial steps taken. An attempt was made to estimate emissions from road haulage of cement products. Fugitive cement dust from bag carriers was calculated and the predicted daily average PM10 were estimated to be about 1 µg/m³. The predicted maximum daily fallout rate of cement from haul trucks on the side of the road could vary considerably, ranging from about 4 to 24 mg/m² per day within a zone of about 10 m from the road edge. Haul trucks are also responsible for airborne particulates from wheel entrainment and diesel particulate matter (DPM). The maximum daily average PM10 concentration for all particulate emissions from vehicles associated with PPC was calculated to be 13 µg/m³. DPM constitutes about 3% of this. The annual average DPM concentration was calculated to be 0.09 µg/m³, which is small compared to the US EPA’s inhalation Reference Concentration (RfC) of 5 µg/m³.


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The predicted air concentrations for heavy metal emissions were also compared to their relevant health risk guidelines. These compounds included potential carcinogens (arsenic, beryllium, cadmium and chromium), mercury, manganese and lead. The incremental cancer risks were calculated for arsenic, beryllium, cadmium, chromium were considerably less than 1 in a million. It is generally regarded that such a risk is trivial and therefore considered acceptable. The annual average air concentrations for mercury, manganese and lead were also well below the chronic reference limits provided by the US Environmental Protection Agency and the World Health Organisation. Impact of Proposed Upgrade As part of the upgrade, PPC would again be using FDG, requiring additional volumes. PPC also intends using slag within the proposed process, which could also be sourced from ArcerlorMittal. The emissions of pollutants which apply to the Subcategory 5.4 are summarised in Table C. From Table C it is clear that the proposed new kiln would be operated to comply with the requirements for particulate matter, NOx and SO2 emission concentrations, in spite of stricter emission limit requirements for new plants. It was further estimated that the emissions of hydrogen chloride and the combination of As+Sb+Pb+Cr+Co+Cu+Mn+V+Mn heavy metals would also meet the limit values. These emissions were estimated using emission factors rather than mass balances due to the difficulty in estimation the partitioning of metals in the flue gas and clinker. Table C: Estimated pollutant emission rates in the new Kiln/Raw Mill and Coal Mill flue gas to be reported in AEL

Pollutant Total

Emissions (g/s)

Emission Limit(a)

(mg/Nm³)

Stack Gas Concentration (mg/Nm³)

Kiln Coal Mill Particulate Matter 2.4 30 30 30 SO2 4.1 50 50 50 NOx 65.0 800 800 800 Total Organic Compounds 0.25 10 3 3 Hydrogen chloride 0.43 10 5 5 Hydrogen Fluoride 0.013 1 0.2 0.2 Cadmium & Thallium 0.0001 0.05 0.001 0.001 Mercury (b) 0.0019 0.05 0.02 0.02 As+Sb+Pb+Cr+Co+Cu+Mn+V+Mn 0.013 0.5 0.2 0.2 Dioxins & Furans 1.9 ng/s 0.1 ng/Nm³ 0.02 ng/Nm³ 0.003 ng/Nm³Note: (a) – AEL Subcategory 5.4

(b) – Mercury emissions based on mass balance of coal and FDG introduced into the kiln The mercury emissions were based on a chemical mass balance of the mercury contained in all the raw material feed. Coal and FDG represent the main sources of mercury. Using the maximum mercury concentration in the feed, the amount of mercury entering the kiln was estimated to be 0.0031 g/s. This would result in a stack gas concentration of about 0.04


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mg/Nm³. Applying a fabric filter removal efficiency of 39%, the concentration would reduce to about 0.02 mg/Nm³, which is below AEL limit value of 0.05 mg/Nm³. As for the baseline case, the most significant pollutant is predicted to be airborne particulates. The predicted maximum concentrations are given in Table E. With the estimated background particulate concentrations due to agricultural activities, there would be the potential to exceed the DEA daily and annual average limit beyond the PPC cement facility. Other emissions, including sulphur dioxide, oxides of nitrogen, carbon monoxide, hydrogen chloride, benzene, mercury, dioxins and furans have a low air impact, with none of DEA limit values and adopted air concentration guidelines being exceeded beyond the PPC facility. The predicted trace heavy metal impacts were estimated to be very low, including carcinogenic effects (see Table D). Table D: Predicted metal concentrations for proposed upgraded cement facility

Metal Predicted

Concentration (µg/m³)

Guideline (µg/m³)

Chronic Reference Limit 1:100 000 Cancer Risk

Silver (Ag) 0.0000005 - N/A Aluminium (Al) 0.01 - N/A Arsenic (As) 0.00004 0.03 (1) 0.02 (1) Barium (Ba) 0.0003 - N/A Beryllium (Be) 0.0000005 0.02 (1) 0.0001 (1) Calcium (Ca) 0.2 - N/A Cadmium (Cd) 0.000002 0.9 (1) 0.0003 (1) Chromium (Cr) 0.0001 0.1 (1) 0.1 [as Cr (VI)] (1) Copper (Cu) 0.004 - N/A Fluoride (F) 0.0007 - N/A Iron (Fe) 0.01 - N/A Mercury (Hg) 0.0001 1 N/A Potassium (K) 0.01 - N/A Manganese (Mn) 0.0001 0.15 (2) N/A Sodium (Na) 0.03 - N/A Lead (Pb) 0.001 0.5 (2) N/A Selenium (Se) 0.06 - N/A Thallium (Th) 0.2 - N/A Titanium (Ti) 0.0001 - N/A Zinc (Zn) 0.000004 - N/A Notes: (1) - US Environmental Protection Agency (2) - World Health Organisation (3) - Emissions are for total chromium. Typically 0.7% could be Cr(VI) (PCA 1992), but some

results have shown as high as 20% (Lizarraga 2003)

As seen in Table D, the predicted air concentrations for metal emissions were compared to their relevant health risk guidelines, where available. These compounds included potential carcinogens (arsenic, beryllium, cadmium and chromium), mercury, manganese and lead.


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The incremental cancer risks were calculated to be considerably less than 1 in a million for each of these. The highest risk was calculated for chromium of 1 in 10 million. In this calculation it was assumed that all chromium emissions are hexavalent (Cr(VI)); however, this is typically less than 20%. It is generally regarded that a risk of 1 in a million is trivial and therefore these impacts are acceptable. The annual average air concentrations for mercury, manganese and lead are well below the chronic reference limits provided by the US EPA and WHO. Transporting ore and overburden within the mining area and product out of the facility constitute the largest source of emissions. The simulations assumed the current practice of water sprays on the road surfaces. The watering programme controls these emissions by about 75%, which reduce the total TSP and PM10 emissions by about 54% and 40%, respectively. Table E: Comparison of predicted future air concentrations to various guidelines and standards




24-hour 120(a1) 75(a2) 75 70 (h) 100 – 150

Annual 50(a1) 40(a2) 40 50 (h) 50

Nitrogen Dioxide 1-hour 200 200 - 200 550 (NOx) 11 (NO2)Annual 40 40 - 40 3.2



Benzene

Annual 10(a1) 5(a2) 5 - 1(i) 0.006



Hydrogen Chloride 1-hour - - - 2100(k) 1.0 Annual - - - 9(k) 0.02 Notes: (a) - Current South African Standards


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(a1) - Valid until 31 December 2014 (a2) - Valid from 1 January 2015 (b) - SANS 1929 Standards (c) - World Bank Guidelines (d) - World Health Organisation Guidelines (e) - Only 10-minute average standards, but a value of 350 has been included as an equivalent. (f) - The latest (2005) WHO guidelines reduced the daily guideline significantly reduced from 125


The predicted annual average concentration for SO2 is 0.2 µg/m³, which is well below the EU annual limit value for SO2 of 20 µg/m³ that is protective for all ecosystems. Similarly, the United National Economic Commission for Europe’s limit value of 30 µg/m³ for annual means is predicted not to be exceeded. The predicted annual average concentration for NOx is 3.2 µg/m³. The impact from these two pollutants in vegetation is therefore seen to be insignificant. The predicted dustfall level to outside PPC boundary is predicted to be "Slight", i.e. dustfall is barely visible to the naked eye. Nearby the facility and access road, the predictions indicate “medium” dustfall. The South African Department of Minerals and Energy (DME) use the 1 200 mg/m2/day threshold level as an action level. In the event that on-site dustfall exceeds this threshold, the specific causes of high dustfall should be investigated and remedial steps taken. It was given that the proposed upgrading of the manufacturing plant would cease all operations before the proposed new plant starts up. CONCLUSIONS In terms of Section 21 of the NEM: AQA, the current and proposed cement production process trigger Subcategory 5.4: Cement production (using alternative fuels and/or resources). The AEL would stipulate the nature and maximum allowable consumption rate of the FDG in the process. If PPC wish to use alternative fuel, this would trigger a new application process, which would require a new EIA to demonstrate compliance and a re-application for an AEL. On the other hand, should PPC decide not to use alternative resources (FDG) once an AEL with Subcategory 5.4 has been issued, it is not expected that a new application for the less strict Subcategory 5.3 need to be submitted. This expectation is based on the fact that Subcategory 5.4 includes all the pollutants in Subcategory 5.3, and that these emission limits are all stricter in with the former subcategory.


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Table E: Air impact assessment summary table for the proposed upgrade of the cement manufacturing facility

Exposure Pollutant

Impact Spatial

Scale of Impacts

Magnitude of Impact

Duration of Impact

Probability of Impact

Confidence Rating

Significance Without

Mitigation With

Mitigation Human Health

PM10 Local High Long Term Definite Sure High Low NO2 Local Low (a) Long Term Definite Sure (b) (b) SO2 Local Low Long Term Definite Sure (b) (b) CO Local Low Long Term Definite Sure (b) (b) HCl Local Low Long Term Definite Sure (b) (b) Benzene Local Low Long Term Definite Sure (b) (b) Dioxins/Furans Local Low Long Term Definite Sure (b) (b) Mercury Local Low Long Term Definite Sure (b) (b)

Nuisance TSP Local Medium Long Term Definite Sure Medium Low Vegetation SO2 Local Low Long Term Definite Sure (b) (b)

NOx Local Low Long Term Definite Sure (b) (b) TSP Local Low Long Term Definite Sure (b) (b)

Notes: (a) - Medium when comparing all NOx emissions to NO2 standard, and Low when estimated NO2 fraction of NOx is compared to standard (b) - No additional mitigation required


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It was determined that the current operation does not comply with the Minimum Emission Limits stipulate in Subcategory 5.4, particularly for SO2, hydrogen chloride and the heavy metal combination of As+Sb+Pb+Cr+Co+Cu+Mn+V+Mn. The mercury concentration in the emission is estimated to be about 0.04 mg/Nm³, which is marginally below AEL limit value of 0.05 mg/Nm³. With the proposed new kiln, a significant reduction in air emission concentrations of particulate matter, NOx and SO2 will be realised to meet the AEL Minimum Emission Limits. It was further estimated that the emissions of hydrogen chloride, hydrogen fluoride and the heavy metal combination of As+Sb+Pb+Cr+Co+Cu+Mn+V+Mn would also meet the AEL limit values. The most significant pollutant is predicted to be airborne particulates. With the inclusion of the estimated background particulate concentrations due to agricultural activities, there is the potential to exceed the DEA daily and annual average limit beyond the PPC cement facility. Transporting ore and overburden within the mining area and product out of the facility constitute the largest source of emissions. The simulations assumed the current practice of water sprays on the road surfaces. The watering programme controls these emissions by about 75%, which reduce the total TSP and PM10 emissions by about 54% and 40%, respectively. Other emissions, including sulphur dioxide, oxides of nitrogen, carbon monoxide, hydrogen chloride, benzene, dioxins and furans have a low air impact, with none of DEA limit values and adopted air concentration guidelines being exceeded beyond the PPC facility. The significance of air pollution impact of the proposed upgrading of the cement facility was assessed through consideration of two phases, namely 2025 and 2040. Only the impact of particulates is expected to vary with each of these three phases, since the clinker and cement production rates were assumed constant. The impact rating is summarised uin Table E. RECOMMENDATIONS All of the planned improvements for the upgrade are to be undertaken on the existing plant site. Since these activities do not require major earthmoving and material transfer, it is not expected to generate significant amounts of fugitive dust. Any additional mitigation measure at the plant may therefore not specifically be necessary. However, it is expected that there would be an increased number of vehicles travelling to and from the site. This has the potential to generate more pollution associated with vehicles, especially entrained dust from access roads. This will be exacerbated during dry or windy conditions. If paving is not an option, regular water spraying has to be applied. It is therefore recommended that any unpaved road sections receive additional watering during periods of expected traffic peaks in the morning and afternoon. Furthermore, clear labelling of all vehicles associated with the contract will help to identify any vehicles that are causing unnecessary re-suspended or fugitive dust emissions.


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Minimising dust and mud from the site entrance or exit will help prevent fugitive emissions being spread outside the site boundary by site vehicles. The control measures outlined below should provide the most effective ways to prevent re-suspension of road dust from a construction site so that no mud or dirt is deposited outside the plant boundary:

• Put in place procedures for effective cleaning of vehicles and inspection. Since these vehicles could carry mud onto the road surface leading to the R311, wheel washing could be necessary. If this proves not to be adequate, total vehicle washing must be applied.

• Provide washing facilities at the exits including hose pipes, adequate water supply and pressure and mechanical wheel spinners or brushes.

• Ensure that loading of materials is done with the lowest drop height and those vehicles carrying dusty materials are securely and properly covered before they leave the site.

• Enter all information in a log book including all vehicles entering and leaving the site. • Sweeping tarred road entrances to reduce mud and dust carry through.

The control of vehicle tailpipe emissions may be achieved by ensuring that vehicles are in good working condition and to minimize idling of equipment when not in use. Based on the use of emission factors, it was indicated that the sum of trace metal emissions (As+Sb+Pb+Cr+Co+Cu+Mn+V+Mn) would be within the required AEL Minimum Emission Limits specified for Subcategory 5.4. The predicted ground level concentrations of these metals were also shown to be small and within the recommended health risk criteria. It is however, recommended that these emissions be quantified with isokinetic sampling methods and if deemed necessary by the Authorities, brought in line with the AEL requirements. It is expected that a virgin equivalent for the iron contained in FDG (such as conventional iron ore), would also be acceptable for use in the kiln. However, it is recommended that whenever such a change is made, emissions testing be conducted to ensure compliance with the requirements of Subcategory 5.4. It became clear from the predictions that inhalable particulates could be a concern outside the PPC Riebeeck West boundary, if no routine mitigation is applied. Fallout could potentially also result in a significant nuisance, albeit not to such a large extent. Transporting the ore, topsoil and overburden within the area constitute the largest source of emissions. Minimising these transport distances would obviously reduce emissions. It was shown that a minimum of 75% control efficiency must be applied to achieve the desired reduction in air concentrations. Recommended watering rates are included in Appendix E. A bag filter arrangement is regarded very efficient provided the availability can be kept as close to 100% as practically possible. The efficiency and availability of the proposed fabric filter abatement control can be ensured through engineering measures. The following measures are recommended to maximise efficiency of dust removal:

• Have a maintenance schedule for the unit; • Use broken bag detectors (triboelectric probes) to monitor for bag integrity;


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• Install a baghouse with some redundancy so that a cell in the baghouse can be isolated and repaired while the unit is still on-line

• Have an automatic bag cleaning system as part on the baghouse. Typical configurations use reverse airflow, mechanical shaking, vibration or compressed air pulsing

Great reliance is placed on the predictive capabilities of the emission factors and dispersion simulations employed in this investigation. It is therefore suggested that the conclusions derived in this investigation be verified through regular stack and ambient air monitoring. A comprehensive ambient monitoring and emissions monitoring programme is recommended. PPC currently has a dustfall monitoring programme in place and measures local meteorological parameters. Continuation of this programme is recommended with the added inclusion of PM10 air concentrations. Considering the relatively low concentrations predicted for all pollutants other than airborne particulates (e.g. sulphur dioxide, oxides of nitrogen and carbon monoxide), it is not specifically recommended to include the observation of other air pollutants in the air pollution monitoring network. The ultimate goal of such a network is to demonstrate compliance to the relevant authorities, the immediate community as well as interested and affected parties. The aim of the monitoring network would be to meet the following objectives:

Quantify the mine operation's impact in terms of both dust deposition (on-site and in the near-field) and suspended inhalable particulate concentrations;

Identify probable problem areas Demonstrate compliance with accepted air quality standards and dustfall limits; To prove information to management in the respect of the effectiveness of current

control and suppression methods Temporal trend analysis Spatial trend analysis Demonstrate continuous improvement; and Facilitate dispersion models calibration (when required).

The demonstration of compliance with the DEA’s NAAQS would necessitate the measurement of inhalable particulates (PM10) using gravimetric measurement methods. Furthermore, the draft DEA regulation on dustfall measurements must be consulted and the applicable method (currently proposed ASTM D1739) used in the fallout network. The current methodology does not conform to the ASTM D1739 methodology. It is recommended that the proposed PM10 monitoring instrument be co-located with the existing Meteorological Station. It is also recommended to position a dustfall instrument at this location. It is recommended that monthly reports be compiled incorporating the monitoring data. This data should be made available in the instance of public complaints.


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A continuous emissions monitoring system (CEMS) is recommended to monitor particulate emissions, sulphur dioxide and oxides of nitrogen at the new Kiln and Raw Mill Stack. The latter emissions are primarily to verify compliance of the DEA’s Minimum Emission Standards. A CEM is also proposed to monitor particulate emissions at the Grate Cooler Stack. The monitoring protocols and details of grab sampling campaigns are supplied in Section 12.


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TABLE OF CONTENTS

1. INTRODUCTION ........................................................................................................... 1-1

1.1. CURRENT PPC RIEBEEK WEST OPERATIONS ........................................................... 1-2 1.1.1. Current Cement Manufacturing Operation ..................................................... 1-5 1.1.2. Mining Operations .......................................................................................... 1-5 1.1.3. Overburden Disposal ..................................................................................... 1-6 1.1.4. Road and Rail Access ................................................................................... 1-6

1.2. PROPOSED PPC RIEBEECK WEST ACTIVITIES .......................................................... 1-6 1.2.1. Description of Proposed Operations .............................................................. 1-6 1.2.2. Proposed Mining Operations ......................................................................... 1-9 1.2.3. Proposed Overburden Disposal ..................................................................... 1-9 1.2.4. Road and Rail Access ................................................................................. 1-10

1.3. SENSITIVE RECEPTORS ......................................................................................... 1-11 1.4. PROJECT TERMS OF REFERENCE ........................................................................... 1-11 1.5. ISSUES RAISED BY INTERESTED AND AFFECTED PARTIES ....................................... 1-13 1.6. METHODOLOGY ..................................................................................................... 1-13

1.6.1. Baseline ....................................................................................................... 1-17 1.6.2. Predicted Impacts ........................................................................................ 1-19

1.7. ASSUMPTIONS AND LIMITATIONS ............................................................................ 1-21 1.7.1. Baseline Information .................................................................................... 1-21 1.7.2. Impact Assessment ..................................................................................... 1-22

1.8. REPORT STRUCTURE ............................................................................................. 1-23

2. POTENTIAL AIR POLLUTANT EMISSIONS ............................................................... 2-1

2.1. AIR POLLUTION FROM CEMENT MANUFACTURING FACILITIES .................................... 2-1 2.2. CURRENT PPC RIEBEECK WEST PLANT ................................................................... 2-3 2.3. PROPOSED PPC UPGRADE...................................................................................... 2-6

2.3.1. Cement Plant Technology ............................................................................. 2-6 2.3.2. Process Technology Alternatives .................................................................. 2-9 2.3.3. Proposed Limestone Mining .......................................................................... 2-9 2.3.1. Proposed Overburden Dumping .................................................................. 2-10 2.3.2. Construction and Commissioning ................................................................ 2-12 2.3.1. Decommissioning ........................................................................................ 2-12

3. POLLUTION HEALTH IMPACTS ................................................................................. 3-1

3.1. CARBON MONOXIDE (CO) ........................................................................................ 3-1 3.2. NITROGEN OXIDES .................................................................................................. 3-1 3.3. SULPHUR DIOXIDE ................................................................................................... 3-2 3.4. HYDROGEN CHLORIDE ............................................................................................. 3-3 3.5. ARSENIC ................................................................................................................. 3-4 3.6. CADMIUM ................................................................................................................ 3-5 3.7. LEAD ....................................................................................................................... 3-6 3.8. MERCURY ............................................................................................................... 3-7 3.9. PARTICULATE MATTER ............................................................................................ 3-8


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3.10. DIESEL PARTICULATE MATTER ............................................................................... 3-10 3.11. BENZENE .............................................................................................................. 3-11 3.12. FORMALDEHYDE .................................................................................................... 3-12 3.13. 1,3 – BUTADIENE ................................................................................................... 3-13 3.14. DIOXINS AND FURANS ............................................................................................ 3-13

4. VEGETATION EXPOSURE .......................................................................................... 4-1

4.1. OZONE .................................................................................................................... 4-1 4.2. SULPHUR DIOXIDE ................................................................................................... 4-3 4.3. OXIDES OF NITROGEN, NITRIC ACID AND AMMONIA ................................................... 4-6 4.4. SUSPENDED PARTICULATE MATTER (SPM) .............................................................. 4-9

5. REGULATORY CONTEXT ........................................................................................... 5-1

5.1. AIR POLLUTION LEGISLATIVE CONTEXT .................................................................... 5-1 5.2. EMISSION LIMITS AND THE NATIONAL AMBIENT AIR QUALITY STANDARDS .................. 5-2

5.2.1. Listed Activities .............................................................................................. 5-3 5.2.1. National Ambient Air Quality Standards ........................................................ 5-4 5.2.2. Dust Fallout .................................................................................................... 5-7

5.3. POLLUTION MANAGEMENT INTERVENTION CRITERIA ................................................. 5-9

6. DISPERSION POTENTIAL AND AIR QUALITY MEASUREMENTS ........................... 6-1

6.1. METEOROLOGICAL PARAMETERS ............................................................................. 6-1 6.1.1. Surface Wind Field ........................................................................................ 6-1 6.1.2. Ambient Air Temperature ............................................................................... 6-4 6.1.3. Rainfall and Evaporation Rates ..................................................................... 6-6 6.1.4. Mixing Depth and Atmospheric Stability ........................................................ 6-6

6.2. AMBIENT AIR QUALITY MONITORING ......................................................................... 6-7 6.2.1. Fallout Dust .................................................................................................... 6-7 6.2.2. Inhalable Particulates .................................................................................. 6-11 6.2.3. Sulphur Dioxide and Nitrogen Dioxide ......................................................... 6-11 6.2.1. Volatile Organic Compounds ....................................................................... 6-13

7. EMISSIONS INVENTORY OF CURRENT AND PROPOSED PPC RIEBEECK FACILITY .............................................................................................................................. 7-1

7.1. CURRENT OPERATION EMISSIONS ............................................................................ 7-1 7.1.1. Routine Process Emissions ........................................................................... 7-1 7.1.2. Upset Process Emissions .............................................................................. 7-4 7.1.3. Synopsis of Current PPC Riebeeck Process Air Emissions .......................... 7-5 7.1.4. Vehicle Generated Exhaust Emissions .......................................................... 7-8 7.1.5. Vehicle Generated Dust Emissions (Non-Exhaust) ..................................... 7-10

7.2. PROPOSED OPERATION EMISSIONS ......................................................................... 7-1 7.2.1. Routine Process Emissions ........................................................................... 7-1 7.2.2. Kiln / Raw Mill Stack ...................................................................................... 7-3 7.2.3. Clinker Cooler ................................................................................................ 7-3 7.2.4. Coal Mill ......................................................................................................... 7-3 7.2.5. Cement Mills .................................................................................................. 7-4 7.2.6. Exhaust Gas Composition ............................................................................. 7-4 7.2.7. Correction for moisture and oxygen ............................................................... 7-4


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7.2.8. Upset Process Emissions .............................................................................. 7-4 7.2.9. Vehicle Generated Exhaust Emissions .......................................................... 7-5 7.2.10. Vehicle Generated Dust Emissions (Non-Exhaust) ....................................... 7-6

7.3. AGRICULTURAL ACTIVITIES ...................................................................................... 7-3

8. BASELINE AIR POLLUTION ....................................................................................... 8-1

8.1. ATMOSPHERIC DISPERSION MODEL SELECTION ....................................................... 8-1 8.1.1. Modelling of Process, Fugitive Dust and Agricultural Sources ...................... 8-1 8.1.2. Modelling of Vehicle Emissions along Roads ................................................ 8-2

8.1. DISPERSION MODEL METEOROLOGICAL DATA REQUIREMENTS ................................. 8-3 8.1.1. AERMOD Model ............................................................................................ 8-3 8.1.2. CALINE Model ............................................................................................... 8-4

8.2. SOURCE DATA REQUIREMENTS................................................................................ 8-4 8.2.1. AERMOD Model ............................................................................................ 8-4 8.2.2. CALINE Model ............................................................................................... 8-4

8.3. MODELLING DOMAIN ................................................................................................ 8-4 8.3.1. AERMOD Model ............................................................................................ 8-4 8.3.2. CALINE Model ............................................................................................... 8-5

8.4. SIMULATION RESULTS ............................................................................................. 8-5 8.4.1. Inhalable Particulate Air Concentrations ........................................................ 8-5 8.4.1. Dust Fallout .................................................................................................. 8-10 8.4.1. Oxides of Nitrogen ....................................................................................... 8-11 8.4.1. Sulphur Dioxide ........................................................................................... 8-14 8.4.1. Mercury ........................................................................................................ 8-16 8.4.1. Benzene ....................................................................................................... 8-17 8.4.2. Dioxins and Furans ...................................................................................... 8-17

8.5. SUMMARY OF PREDICTED MAXIMUM GROUND LEVEL CONCENTRATIONS ................. 8-21 8.6. ANALYSIS .............................................................................................................. 8-24

9. PREDICTED AIR POLLUTION FOR PROPOSED PROJECT ..................................... 9-1

9.1. ATMOSPHERIC DISPERSION MODEL SELECTION ....................................................... 9-1 9.2. DISPERSION MODEL METEOROLOGICAL DATA .......................................................... 9-1 9.3. SOURCE DATA ........................................................................................................ 9-1 9.4. MODELLING DOMAIN ................................................................................................ 9-1 9.5. SIMULATION RESULTS ............................................................................................. 9-1

9.5.1. Inhalable Particulate Air Concentrations ........................................................ 9-1 9.5.2. Dust Fallout .................................................................................................. 9-11 9.5.3. Oxides of Nitrogen ....................................................................................... 9-11 9.5.1. Sulphur Dioxide ........................................................................................... 9-12 9.5.1. Mercury ........................................................................................................ 9-13 9.5.1. Benzene ....................................................................................................... 9-15 9.5.1. Dioxins and Furans ...................................................................................... 9-15

9.6. SUMMARY OF PREDICTED MAXIMUM GROUND LEVEL CONCENTRATIONS ................. 9-22 9.7. ANALYSIS .............................................................................................................. 9-24 9.8. IMPACT OF POTENTIAL OVERLAP OF EXISTING AND PROPOSED CEMENT PRODUCTION FACILITIES ........................................................................................................................ 9-24

10. MITIGATION MEASURES ...................................................................................... 10-1


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10.1. CONSTRUCTION .................................................................................................... 10-1 10.2. OPERATION ........................................................................................................... 10-2

10.2.1. Unpaved Road Surfaces .............................................................................. 10-2 10.2.2. Conveyor Belts ............................................................................................ 10-5 10.2.3. Overburden Dumps ..................................................................................... 10-5 10.2.4. Materials Handling ....................................................................................... 10-7 10.2.5. Particulate Emissions from Haul Trucks ...................................................... 10-8

11. IMPACT SIGNIFICANT RATING ............................................................................ 11-1

11.1. CONSTRUCTION PHASE ......................................................................................... 11-1 11.2. PROPOSED UPGRADING OF PLANT ......................................................................... 11-1

12. AIR POLLUTION MANAGEMENT SYSTEM .......................................................... 12-1

12.1. AMBIENT MONITORING ........................................................................................... 12-1 12.2. EMISSION MONITORING PROTOCOLS ...................................................................... 12-2

12.2.1. Continuous Emissions Monitoring System (CEMS) ..................................... 12-2 12.2.2. Isokinetic Sampling ...................................................................................... 12-3 12.2.3. Fugitive Emissions ....................................................................................... 12-4 12.2.4. Process Parameters .................................................................................... 12-5

12.3. PERFORMANCE INDICATORS .................................................................................. 12-5 12.4. ENVIRONMENTAL REPORTING ................................................................................ 12-6 12.5. PUBLIC/COMMUNITY LIAISON ................................................................................. 12-6

13. CONCLUSIONS AND RECOMMENDATIONS ....................................................... 13-1

13.1. BASELINE ANALYSIS .............................................................................................. 13-1 13.2. ANALYSIS OF PROPOSED UPGRADE ....................................................................... 13-6

13.2.1. Minimum Emission Limits ............................................................................ 13-6 13.2.2. Predicted Air Quality Impacts ...................................................................... 13-7

13.3. RECOMMENDATIONS ............................................................................................ 13-10 13.3.1. Construction Phase ................................................................................... 13-10 13.3.2. Operational Phase ..................................................................................... 13-11

14. REFERENCES ........................................................................................................ 14-1

15. APPENDIX A: MERCURY CONTENT OF RAW MATERIAL ................................. 15-1

16. APPENDIX B: GENERAL EMISSION INVENTORY METHODS ........................... 16-1

16.1. MASS BALANCE ..................................................................................................... 16-1 16.2. EMISSION FACTORS ............................................................................................... 16-1 16.3. CONTINUOUS EMISSIONS MONITORING SYSTEMS (CEMS) ..................................... 16-3 16.4. GRAB SAMPLING ................................................................................................... 16-4

16.4.1. Sulphur dioxide ............................................................................................ 16-4 16.4.2. Flow measurement ...................................................................................... 16-5 16.4.3. Isokinetic Testing ......................................................................................... 16-6 16.4.4. Particulate Matter ......................................................................................... 16-6 16.4.5. PM10 and PM2.5 ............................................................................................ 16-7 16.4.6. Metals .......................................................................................................... 16-7 16.4.7. Hydrogen Chloride (HCl) and Hydrogen Fluoride (HF) ................................ 16-8 16.4.8. Dioxins and Furans ...................................................................................... 16-9


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16.4.9. Fugitive Dust measurements ..................................................................... 16-10 16.4.10. Monitoring of Process Variables ............................................................ 16-11

17. APPENDIX C: TECHNICAL DESCRIPTION OF EMISSIONS FACTOR CALCULATIONS ................................................................................................................ 17-1

17.1. FUGITIVE DUST EMISSIONS .................................................................................... 17-1 17.2. FUGITIVE DUST EMISSIONS FROM GRADING OPERATIONS ....................................... 17-1 17.3. FUGITIVE DUST EMISSIONS FROM TIPPING OPERATIONS ......................................... 17-1 17.4. EXCAVATING ACTIVITIES ........................................................................................ 17-2 17.5. BLASTING AND DRILLING OPERATIONS ................................................................... 17-2 17.6. CRUSHING AND SCREENING OPERATIONS .............................................................. 17-3 17.7. WIND EROSION FROM EXPOSED AREAS ................................................................. 17-4 17.8. VEHICLE-ENTRAINED EMISSIONS FROM ROADS ...................................................... 17-7 17.9. GENERAL CONSTRUCTION ACTIVITIES .................................................................... 17-8 17.10. VEHICLE EMISSION FACTORS ............................................................................. 17-9

18. APPENDIX D: CHECKLIST FOR DUST CONTROL (AFTER ENVIRONMENT AUSTRALIA, 1998) ............................................................................................................ 18-1

19. APPENDIX E: WATERING PROGRAMME ............................................................ 19-1

19.1. RECOMMENDED WATERING PROGRAMME FOR CURRENT CEMENT FACILITY ............ 19-2 19.2. RECOMMENDED WATERING PROGRAMME FOR PROPOSED CEMENT FACILITY .......... 19-5

20. APPENDIX F: MONITORING GUIDE ..................................................................... 20-1

20.1. FILTER-BASED MONITORS ...................................................................................... 20-1 20.1.1. Filter-based, Off-line Samplers (SFUs, Sequential Samplers)..................... 20-1 20.1.2. Filter-based, On-line Samplers (TEOM, BAM)............................................. 20-2

20.2. NON-FILTER-BASED MONITORS .............................................................................. 20-5 20.3. DATA TRANSFER OPTIONS ..................................................................................... 20-5 20.4. SAMPLER AND DATA TRANSFER RECOMMENDATIONS ............................................. 20-5

21. APPENDIX G: METHOD OF ASSESSING THE ENVIRONMENTAL ISSUES AND ALTERNATIVES ................................................................................................................. 21-1


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LIST OF FIGURES

Figure 1-1: Location of PPC Riebeeck cement manufacturing facility ............................. 1-2 Figure 1-2: PPC Riebeeck West farms ............................................................................ 1-3 Figure 1-3: Current PPC Riebeeck West operations ....................................................... 1-4 Figure 1-4: PPC Riebeeck West proposed infrastructure ................................................ 1-7 Figure 1-5: PPC Riebeeck West plant proposed infrastructure (including existing

infrastructure to remain and to be demolished) during proposed upgrade .................... 1-7 Figure 1-6: PPC Riebeeck West plant proposed infrastructure ............................................. 1-8 Figure 1-7: Overburden dump alternative locations ....................................................... 1-10 Figure 2-1: Generic process flow diagram for the Portland cement manufacturing process

(US EPA Ap-42 Section 11.6) ....................................................................................... 2-1 Figure 2-2: General cement production process (PPC Background Document for the

Proposed Secondary Materials Co-Processing Programme, 2006) .............................. 2-1 Figure 2-3: Reaction zones and temperature profiles for gas and clinker in a kiln (Source:

Manning, D.A.C. (1995)) ................................................................................................ 2-4 Figure 2-4: Typical process flow sheet of an in-line calciner kiln system (5-stage

preheater) ...................................................................................................................... 2-8 Figure 2-5: Proposed extent of limestone mining ........................................................... 2-10 Figure 2-6: Proposed overburden dump sites ................................................................ 2-11 Figure 4-1: Simplified diagram of outer leaf cells ............................................................. 4-2 Figure 4-2: SO2 dose-response relationships pooling data from China (black & white

symbols), India (red symbols), Australia and the UK for different species and cultivars (Emberson et al., 2001) ................................................................................................. 4-4

Figure 5-1: Section 21 of NEMAQA, Listed Activities Category 5.1 Storage and Handling of Ore and Coal ............................................................................................................. 5-3

Figure 5-2: Section 21 of NEMAQA, Listed Activities Category 5.3 Cement Production (using conventional fuels and raw materials) ................................................................ 5-4

Figure 5-3: Section 21 of NEMAQA, Listed Activities Category 5.4 Cement Production (using alternative fuels and/or resources) ..................................................................... 5-5

Figure 6-1: Period, daytime and night-time wind roses for PPC Riebeeck West (January to December 2010) ............................................................................................................ 6-2

Figure 6-2: Seasonal wind roses wind roses for PPC Riebeeck West (January to December 2010) ............................................................................................................ 6-3

Figure 6-3: Diurnal and monthly variation of ambient air temperatures at PPC Riebeeck West 6-5

Figure 6-4: Locations of sampling sites relative to the mine and production facility .............. 6-8 Figure 6-5: Ambient air daily average PM10 concentrations observed at PPC Riebeeck

West’s Weather Station ............................................................................................... 6-12 Figure 6-6: Locations of SO2, NO2 and VOC passive samplers (May/June 2011) ......... 6-13 Figure 7-1: Results of laboratory analysis for mercury content in FDG and coal ............. 7-4 Figure 7-2: Summary of vehicle-related airborne particulate contributions for the current

PPC Riebeeck West operation as an average over the day ......................................... 7-1 Figure 7-3: Summary of vehicle-related airborne particulate contributions for the current

PPC Riebeeck West operation during peak hour .......................................................... 7-2


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Figure 7-4: Summary of vehicle-related airborne particulate contributions for the proposed upgraded PPC Riebeeck West operation as an average over the day ......................... 7-1

Figure 7-5: Summary of vehicle-related airborne particulate contributions for the current PPC Riebeeck West operation during peak hour .......................................................... 7-2

Figure 8-1: Predicted annual average inhalable particulate concentrations from agricultural sources ....................................................................................................... 8-6

Figure 8-2: Annual average inhalable particulate concentrations with PPC Riebeeck’s current operation including emissions from agricultural land. ........................................ 8-7

Figure 8-3: Predicted highest daily average inhalable particulates from PPC Riebeeck cement facility (this excludes emissions from agricultural land due to the difficulty in estimating these emissions on a short term basis) ........................................................ 8-8

Figure 8-4: Predicted daily average particulate air concentrations at various distances, perpendicular from the road edge ................................................................................. 8-8

Figure 8-5: Daily average PM10 predictions in Ongegund for 2010 (current conditions) .. 8-9 Figure 8-6: Daily average PM10 predictions in Riebeek West (north) for 2010 (current

conditions) ..................................................................................................................... 8-9 Figure 8-7: Predicted highest daily average dust fallout rates ....................................... 8-10 Figure 8-8: Predicted annual average particulate fallout rates from the cement facility . 8-11 Figure 8-9: Highest predicted hourly average oxides of nitrogen concentration (nitrogen

dioxide constitutes less than 2% of these emissions) ................................................. 8-12 Figure 8-10: Highest hourly average NOx concentration predictions for 2010 at Ongegund

8-13 Figure 8-11: Highest hourly average NOx concentration predictions for 2010 in the north of

Riebeek West residential area ..................................................................................... 8-13 Figure 8-12: Predicted annual average NOx concentrations for current PPC operation.. 8-14 Figure 8-13: Highest hourly average SO2 concentration predictions for 2010 at Ongegund8-

15 Figure 8-14: Highest hourly average NOx concentration predictions for 2010 in the north of

Riebeek West residential area ..................................................................................... 8-15 Figure 8-15: Predicted sulphur dioxide highest hourly average concentration for current

PPC operation ............................................................................................................. 8-16 Figure 8-16: Predicted sulphur dioxide highest daily average concentration for current PPC

operation 8-17 Figure 8-17: Predicted annual average sulphur dioxide concentration for current PPC

operation 8-18 Figure 8-18: Predicted chronic exposure to mercury emissions from the current PPC facility

8-19 Figure 8-19: Predicted long-term benzene concentrations from current PPC facility ....... 8-20 Figure 9-1: Highest daily average PM10 concentrations (2025) ........................................ 9-2 Figure 9-2: Highest daily average PM10 concentrations (2040) ........................................ 9-2 Figure 9-3: Annual average PM10 concentrations (2025) ................................................. 9-3 Figure 9-4: Annual average PM10 concentrations (2040) ................................................. 9-3 Figure 9-5: Highest daily average PM10 predictions for 2010 at Ongegund for 2025 ....... 9-5 Figure 9-6: Highest daily average PM10 predictions for 2010 at Ongegund for 2040 ....... 9-5 Figure 9-7: Highest daily average PM10 predictions for 2010 at Riebeek West (north) for

2025 9-6


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Figure 9-8: Highest daily average PM10 predictions for 2010 at Riebeek West (north) for 2040 9-6

Figure 9-9: Zone within which the 75 µg/m³ DEA daily average PM10 limit value would be exceeded for 4 or more days per year (2025) ............................................................... 9-7

Figure 9-10: Zone within which the 75 µg/m³ DEA daily average PM10 limit value would be exceeded for 4 or more days per year (2040) ............................................................... 9-8

Figure 9-11: Predicted PM10 concentrations nearby unpaved roads, assuming 4.5% silt and 5% moisture................................................................................................................... 9-9

Figure 9-12: Predicted maximum daily dust fallout (2025) ............................................... 9-10 Figure 9-13: Predicted maximum daily dust fallout (2040) ............................................... 9-10 Figure 9-14: Highest predicted hourly average oxides of nitrogen concentration for the

proposed upgrade ....................................................................................................... 9-12 Figure 9-15: Predicted numbers of hourly exceedances of the NO2 limit value of 200 µg/m³

for proposed upgraded PPC operation ........................................................................ 9-13 Figure 9-16: Predicted hourly average NOx concentrations in Ongegund for the

proposed upgrade ....................................................................................................... 9-14 Figure 9-17: Predicted hourly average NOx concentrations in Riebeek West (north) for the

proposed upgrade ....................................................................................................... 9-14 Figure 9-18: Predicted annual average NOx concentrations for proposed upgraded PPC

operation 9-15 Figure 9-19: Predicted sulphur dioxide highest hourly average concentration for

proposed PPC operation ............................................................................................. 9-16 Figure 9-20: Predicted hourly average SO2 concentrations in Ongegund for the proposed

upgrade 9-17 Figure 9-21: Predicted hourly average SO2 concentrations in Riebeek West (north) for

the proposed upgrade ................................................................................................. 9-17 Figure 9-22: Predicted sulphur dioxide highest daily average concentration for proposed

PPC operation ............................................................................................................. 9-18 Figure 9-23: Predicted annual average sulphur dioxide concentration for proposed PPC

operation 9-19 Figure 9-24: Predicted chronic exposure to mercury emissions from the proposed PPC

facility 9-20 Figure 9-25: Predicted long-term benzene concentrations from proposed PPC facility ... 9-21 Figure 10-1: Deposition of dust in the lee of topographic obstacles due to flow divergence

and reduction of the wind friction velocity. Dust deposition is prevented on windward slopes where flow convergence and speed-up occur. ................................................. 10-6

Figure 10-2: Relationship between the moisture content of the material being handled and the dust control efficiency provided for calculated based on the US-EPA predictive emission factor equation for continuous and batch drop operations. .......................... 10-7

Figure 15-1: A 2011 Material Safety Data Sheet for the Furnace Dust Granules ............ 15-1 Figure 15-2: Chemical analyses (Council for Geosciences 2011) for PPC Riebeeck West

raw material ................................................................................................................. 15-2 Figure 16-1: US EPA Method 5 isokinetic dust sampling train. ........................................ 16-6 Figure 16-2: US EPA compliant Method 29 sampling train for isokinetic metals emission

testing. 16-8 Figure 16-3: US EPA M26A Sampling Train Schematic .................................................. 16-9


Riebeek West, Western Cape: Air Quality Impact Assessment Report No.: 10AUR16 Rev 0.1 Page xxvii

Figure 16-4: US EPA Method 23 Dioxin and Furan Emission Measurement Sampling Train Schematic .................................................................................................................. 16-10

Figure 17-1: Relationship between particle sizes and threshold friction velocities using the calculation method proposed by Marticorena and Bergametti (1995) ................... 17-5

Figure 17-2: Contours of normalised surface wind speeds (i.e. surface wind speed / approach wind speed) (after EPA, 1996) .................................................................... 17-6

Figure 19-1: Calculated watering rates for unpaved roads with a maximum of 14 haul trucks per hour (current operation) without effect of rain. ............................................ 19-3

Figure 19-2 : Calculated watering rates for unpaved roads with a maximum of 14 haul trucks per hour (current operation) including rainfall. .................................................. 19-4

Figure 19-3: Calculated watering rates for unpaved roads with a maximum of 23 haul trucks per hour (future operation) without effect of rain. .............................................. 19-6

Figure 19-4: Calculated watering rates for unpaved roads with a maximum of 23 haul trucks per hour (future operation) including rainfall. .................................................... 19-7

Figure 20-1: Partisol-Plus sequential air sampler. ........................................................... 20-1 Figure 20-2: TEOM sampler linked to the ACCUTM conditional sampling system. ........... 20-4


Riebeek West, Western Cape: Air Quality Impact Assessment Report No.: 10AUR16 Rev 0.1 Page xxviii

LIST OF TABLES

Table 1-1: Air pollution issues identified during the consultation process. .................... 1-14 Table 2-1: Locations of significant air emissions and pollution types ............................. 2-1 Table 2-2: Approximate raw material usage (tonnes per annum) at current PPC Riebeeck

West plant...................................................................................................................... 2-3 Table 2-3: Approximate clinker and cement production rates at PPC Riebeeck West

Plant 2-5 Table 2-4: Proposed PPC Riebeeck raw material usage (tonnes per annum) ............... 2-7 Table 2-5: Proposed PPC Riebeeck production rate (tonnes per annum) ...................... 2-8 Table 2-6: Possible technology alternatives ................................................................... 2-9 Table 3-1: WHO air quality guidelines and interim guidelines for sulphur dioxide (WHO,

2005) 3-3 Table 3-2: WHO air quality guideline and interim targets for particulate matter (annual

mean) (WHO, 2005) .................................................................................................... 3-10 Table 3-3: WHO air quality guideline and interim targets for particulate matter (daily

mean) (WHO, 2005) .................................................................................................... 3-10 Table 4-1: Injury to plants due to various doses of sulphur dioxide (a) ............................. 4-4 Table 4-2: World Health Organisation guidelines for the protection of ecosystems........ 4-5 Table 4-3: Examples of plants’ sensitivity to exposure of sulphur dioxide ...................... 4-6 Table 4-4: Injury to plants caused by various dosages of NO2. ...................................... 4-7 Table 4-5: Deposition velocity of nitrogen-containing gases and aerosols (WHO 2000) 4-8 Table 5-1: National Ambient Air Quality Standards (NAAQS) ........................................ 5-6 Table 5-2: Dust deposition standards issued by various countries ................................. 5-7 Table 5-3: Bands of dustfall rates proposed for adoption ............................................... 5-8 Table 5-4: Target, action and alert thresholds for ambient dustfall ................................. 5-8 Table 6-1: Maximum, minimum and mean monthly temperatures at PPC Riebeeck West

(January to December 2010) ......................................................................................... 6-5 Table 6-2: Average monthly rainfall and evaporation rates at Malmesbury (2004 to 2007)

6-6 Table 6-3: Average annual total dust collected per bucket ........................................... 6-10 Table 6-4: Calcium and magnesium concentration in fallout bucket samples .............. 6-10 Table 6-5: Dust fallout results for 17 June to 17 July 2007 (Ecoserv) .......................... 6-11 Table 6-6: Summary of PM10 daily average ambient concentrations June 2007 to August

2007 at Delectus and Rugby Field monitoring sites and 14 May to 14 June 2011 at the Weather Station Site. ................................................................................................... 6-11

Table 6-7: Summary of sulphur dioxide and nitrogen dioxide ambient concentrations (June to July 2007) ...................................................................................................... 6-12

Table 6-8: Summary of sulphur dioxide and nitrogen dioxide ambient concentrations (12 May to 15 June 2011) .................................................................................................. 6-13

Table 6-9: Summary of selected volatile organic compound ambient concentrations (12 May to 15 June 2011) .................................................................................................. 6-14

Table 7-1: Chemical analysis of PPC Riebeeck clinker .................................................. 7-2 Table 7-2: Estimate of elements in road dust. ................................................................ 7-2 Table 7-3: Chemical analysis of FDG (Saldanha Steel 2001, Appendix A) .................... 7-3


Riebeek West, Western Cape: Air Quality Impact Assessment Report No.: 10AUR16 Rev 0.1 Page xxix

Table 7-4: Mercury content of clinker and feed streams (Council for Geosciences 2011, Appendix A) ................................................................................................................... 7-3

Table 7-5: Availability of electrostatic precipitators (%) October 2007 to June 2008 at PPC Riebeek ................................................................................................................. 7-5

Table 7-6: Airborne particulate emission rates for current PPC Riebeek facility............. 7-6 Table 7-7: Estimated elemental distribution of the most important elements in the

airborne particulates (all air emissions) ......................................................................... 7-7 Table 7-8: Estimated metal-associated compounds in all airborne particulate emissions .... 7-7 Table 7-9: Estimated pollutant emission rates in the kiln flue gas to be reported in AEL7-8 Table 7-10: Estimated vehicle exhaust emissions due to the current PPC Riebeeck West

operation 7-9 Table 7-11: Calculated daily average particulate emission rates for different vehicles... 7-10 Table 7-12: Calculated airborne particulate emission rates for different sources of

emissions (daily averages) .......................................................................................... 7-11 Table 7-13: Calculated airborne particulate emission rates for different vehicles (peak

hour) 7-11 Table 7-14: Calculated airborne particulate emission rates for different sources of

emissions (peak hour) ................................................................................................. 7-11 Table 7-15: Calculated airborne particulate emission rates for different gravel road

conditions ...................................................................................................................... 7-1 Table 7-16: Airborne particulate emission rates for upgraded PPC Riebeek facility ........ 7-1 Table 7-17: Estimated pollutant emission rates in the new Kiln/Raw Mill and Coal Mill flue

gas to be reported in AEL .............................................................................................. 7-2 Table 7-18: Estimated vehicle exhaust emissions due to the current and proposed PPC

Riebeeck West operation .............................................................................................. 7-6 Table 7-19: Calculated airborne particulate emission rates for different vehicles (daily

averages) for the proposed upgrade ............................................................................. 7-7 Table 7-20: Calculated airborne particulate emission rates for different sources of

emissions (daily averages) for the proposed upgrade ................................................... 7-7 Table 7-21: Calculated airborne particulate emission rates for different vehicles (peak

hour) for the proposed upgrade ..................................................................................... 7-7 Table 7-22: Calculated airborne particulate emission rates for different sources of

emissions (peak hour) for the proposed upgrade .......................................................... 7-3 Table 7-23: Calculated airborne particulate emission rates for different gravel road

conditions with the potential increased number of heavy vehicles for the proposed upgrade 7-3

Table 7-24: Estimated canopy and soil cover. .................................................................. 7-4 Table 7-25: Emission rate factors for farming activities. ................................................... 7-5 Table 7-26: Calculated emission rate from surrounding agricultural land. ........................ 7-6 Table 8-1: Calculated airborne particulate concentration rates for different gravel road

conditions (baseline) ...................................................................................................... 8-7 Table 8-2: Comparison of predicted current air concentrations to various guidelines and

standards ..................................................................................................................... 8-21 Table 8-3: Predicted metal concentrations for current cement facility .......................... 8-22 Table 8-4: Comparison of predicted air concentrations of current haul truck fleet

emissions in Riebeek West to relevant guidelines and standards ............................... 8-23


Riebeek West, Western Cape: Air Quality Impact Assessment Report No.: 10AUR16 Rev 0.1 Page xxx

Table 9-1: Calculated airborne particulate concentration rates for different gravel road conditions (upgrade) ...................................................................................................... 9-9

Table 9-2: Comparison of predicted future air concentrations to various guidelines and standards ..................................................................................................................... 9-22

Table 9-3: Predicted metal concentrations for proposed upgraded cement facility ...... 9-23 Table 10-1: Control Measures for Unpaved Roads (After EPA 1992) ............................ 10-3 Table 10-2: Calculated watering rates for current PPC Riebeeck West cement facility to

achieve 75% control efficiency from unpaved roads. These calculations excluded the effect of rainfall. ........................................................................................................... 10-4

Table 10-3: Calculated watering rates for the upgraded PPC Riebeeck West cement facility to achieve 75% control efficiency from unpaved roads. These calculations included the effect of rainfall. ....................................................................................... 10-4

Table 10-4: Control Methods in Conveyor Usage ........................................................... 10-5 Table 11-1: Air impact assessment summary table for the Construction Phase ............ 11-1 Table 11-2: Air impact assessment summary table for the proposed upgrade of the

cement manufacturing facility ...................................................................................... 11-2 Table 12-1: CEMS monitoring requirements ................................................................... 12-2 Table 12-2: Annual Grab Sampling Protocol. ................................................................. 12-4 Table 13-1: Estimated pollutant emission rates in the kiln flue gas to be reported in AEL13-

4 Table 13-2: Comparison of predicted current air concentrations to various guidelines and

standards ..................................................................................................................... 13-5 Table 13-3: Estimated pollutant emission rates in the new Kiln/Raw Mill and Coal Mill flue

gas to be reported in AEL ............................................................................................ 13-7 Table 13-4: Predicted metal concentrations for proposed upgraded cement facility ...... 13-8 Table 13-5: Comparison of predicted air concentrations to various guidelines and

standards. .................................................................................................................... 13-9 Table 17-1: Constants for unpaved road equation (US.EPA, 2003) ............................... 17-8 Table 17-2: Constants for paved road equation (US.EPA, 2003) ................................... 17-8 Table 18-1: Checklist for Dust Control (After Environment Australia, 1998) ................... 18-2 Table 19-1: Control Measures for Unpaved Roads (After EPA 1992) ............................ 19-1 Table 19-2: Calculated watering rates for current PPC Riebeeck cement facility to achieve

75% control efficiency from unpaved roads. ................................................................ 19-2 Table 19-3: Calculated watering rates for proposed PPC Riebeeck cement facility to

achieve 75% control efficiency from unpaved roads. .................................................. 19-5 Table 20-1: Comparison of TEOM and BAM performance. ............................................ 20-3 Table 21-1: Assessment criteria for the evaluation of impacts. ...................................... 21-1 Table 21-2: Definition of significance ratings. ................................................................. 21-1 Table 21-3: Definition of probability ratings. .................................................................... 21-2 Table 21-4: Definition of confidence ratings .................................................................... 21-3 Table 21-5: Definition of reversibility ratings ................................................................... 21-3


Riebeek West, Western Cape: Air Quality Impact Assessment Report No.: 10AUR16 Rev 0.1 Page 1-1

PROPOSED UPGRADE TO PPC’S EXISTING CEMENT MANUFACTURING PLANT AND ASSOCIATED

OPERATIONS IN RIEBEEK WEST, WESTERN CAPE: AIR QUALITY IMPACT ASSESSMENT

1. INTRODUCTION Pretoria Portland Cement Company Limited (“PPC”) PPC is a group whose principal activity is manufacturing cementations products, lime, and limestone. PPC Cement is the largest cement supplier with at least 35% of the market share in South Africa and currently has seven operating cement manufacturing cement plants in South Africa. These include Riebeeck (Riebeek West), De Hoek (Piketberg), Port Elizabeth, Jupiter (Germiston), Hercules (Pretoria), Dwaalboom (Thabazimbi), Slurry (northwest of Lichtenburg). In 2007/08 a study was undertaken for a proposed project comprising the construction and operation of a new cement kiln with a rated capacity of 1.2 million tonnes of cement per annum. It was proposed that the new facility would replace the existing facility and would therefore also require all associated infrastructure such as limestone storage and blending, other raw materials (including coal) storage and proportioning, water and electricity supply, gas cleaning, dust management, clinker storage, cement storage, packing, pelletising, dispatch and service roads, etc. Two optional locations for the proposed production facility were identified, Delectus and Vlakkerug and these options came about as a result of the potential future plans for mining limestone at Delectus and dumping space requirement for overburden material. The intention at that time was to double the plant production output, however, due to the recent global economic crisis which impacted on the South African construction industry, a re-evaluation of the earlier development plan and subsequent downscaling were undertaken, resulting in the previous plan being shelved in its entirety, and replaced with a new programme. PPC Riebeeck West proposes to upgrade the current cement plant through the incorporation of a new and efficient kiln together with a number of ancillary equipment, including raw mill and coal grinding/processing, and clinker product grinding. The existing infrastructure on the operational plant would be utilised with the ultimate scrapping of two old inefficient kilns currently operating on site. Airshed Planning Professionals (Pty) Ltd were appointed to assist Aurecon (Pty) Ltd in assessing the potential air pollution impacts associated with the proposed capacity expansion project. This report serves to provide a summary of the air pollution investigations completed for the current (Baseline) and predicted impacts of the proposed expansion. This information, in turn, would be utilised to inform the overall Environmental Impact Assessment (EIA), the application for an Atmospheric Emissions Licence (AEL) and the development of an Air Quality Management Plan (AQMP).



1.1. Current PPC Riebeek West Operations Current activities at PPC Riebeeck West include the production of Portland cement, a fine, typically grey powder comprised of gypsum and several silica and alumina-based compounds. Different types of Portland cements can be created depending on the application, as well as the chemical and physical properties desired. The exacting nature of Portland cement manufacture requires the use of large-scale, heavy machinery and equipment for mining, and large amounts of energy (20-25% of output costs are attributed to energy consumption). Coal is required to maintain high combustion levels in kilns – for every 100 tonnes of clinker produced, approximately 15 to 16 tonnes of coal has to be burnt.

Figure 1-1: Location of PPC Riebeeck cement manufacturing facility

As shown in Figure 1-1, PPC’s property in Riebeek West is located approximately 70 km, northeast from Cape Town. The property is currently made up of three farms (Figure 1-2) namely

• Ongegund (where the current quarry operation and cement plant facility are located); • Vlakkerug (which contains a future limestone deposit); and • Delectus (which contains a future limestone deposit).



Figure 1-2: PPC Riebeeck West farms



Figure 1-3: Current PPC Riebeeck West operations



The overall operation is made up of three main components, namely the cement manufacturing plant, the mining of limestone and the disposal of mined overburden. These are shown in Figure 1-3 and briefly discussed below.

1.1.1. Current Cement Manufacturing Operation The current cement manufacturing facility has the production capacity of 570 000 tonne per annum clinker. The facility consists of:

• Two dry long kilns on the Ongegund property • A crushing (primary, secondary and tertiary) system to reduce the size, of limestone

before it is sent to the manufacturing plant • A raw material stockpile facility. There are stockpile systems for storing limestone,

coal and other raw materials (i.e. gypsum, sand, clay and furnace dust granules) used to make cement

• Raw mills are used to grind the raw materials and coal • A clinker production facility • The cement milling facility. Roller mills are used to grind the clinker, together with

gypsum and extenders to produce cement. • Dispatch. Here some of the cement is packaged and palletised and despatched by

rail and road. The balance is despatched in bulk, also by rail or road.

The main raw materials used within the cement manufacturing process include limestone, which makes up the highest percentage (85%), shale (which makes up 8%), Furnace Dust Granules (FDG) (4%) and sand (3%). The ratio of raw materials could change depending on the quality of raw materials used. PPC purchases FDG from ArcerlorMittal in Saldanha. The material is an iron ore replacement which is used for the production of clinker. FDG is mixed in the raw mill and then added to the kiln with the other milled materials. The sand on PPC‟s property has been mined out (since 2008), and it is currently sourced mainly from the PPC facility at De Hoek, near Piketberg. Sand is delivered only when minimum stock levels have been reached.

1.1.2. Mining Operations Mining operations are via open cast and the raw materials mined on the property include limestone (calcium source) and shale (aluminium source). Shale is mined as part of the overburden stripping. PPC currently mines limestone from two pits namely Pit A and Pit B, with the former consisting of medium to low grade limestone whereas the latter pit, which extends southwards, contains high grade “sweetener” limestone. Ore from these two pits are blended to achieve the required feed specifications.



Mining includes the use of conventional mining methods such as drilling, blasting, loading and hauling. The blasting activity occurs once or twice per month.

1.1.3. Overburden Disposal Overburden is currently disposed of in the Vlakkerug waste dump and approximately 2 tonnes of waste rock needs to be removed to produce 1 tonne of limestone. This stripping ratio varies depending on mining depth and the geology within the pit. The overburden dumps are profiled through bulldozing, grading and terracing. Once profiled, they are covered in topsoil and re-vegetated as per the requirements for utilising the area for wheat farming.

1.1.4. Road and Rail Access The existing PPC access road from the R311 is a public road (Minor Road 346) and is located on PPC‟s property (refer to Figure 1-2 and Figure 1-3). All heavy vehicle trucks enter and exit the PPC‟s property from this entrance via the formalised gate house. According to the Transport Specialist Study (Robertson 2011), the total externally sourced input flow is some 2 898 tonnes/week, with some 10 201 tonnes cement produced each week leaving the site. Of the externally sourced material, 92.8% is conveyed by rail, while 7.1% is conveyed by road. Overall, 48% of commodities entering and leaving the PPC site is conveyed by road, with the balance (52%) by rail. The sand is conveyed via road freight traffic traveling from the north along the R311 and N7. Materials conveyed by rail are carried in 34 and 44 tonne capacity wagons (trucks). The road freight component is conveyed in vehicles with 32 and 36 tonne load capacities. On PPC‟s property there are a number of internal, private roads for machinery and trucks. Farmers also use the gravel road along the eastern boundary of PPC‟s property to access the land that PPC leases to them for agricultural activities.

1.2. Proposed PPC Riebeeck West Activities

1.2.1. Description of Proposed Operations PPC Riebeeck West proposes to upgrade the current cement plant through the incorporation of a new and efficient kiln together with a number of ancillary equipment, including raw mill and coal grinding/processing, and clinker product grinding. The existing infrastructure on the operational plant would be utilised with the ultimate scrapping of two old inefficient kilns currently operating on site (Figure 1-4, Figure 1-5 and Figure 1-6).



Figure 1-4: PPC Riebeeck West proposed infrastructure

Figure 1-5: PPC Riebeeck West plant proposed infrastructure (including existing infrastructure to remain and to be demolished) during proposed upgrade



Figure 1-6: PPC Riebeeck West plant proposed infrastructure

In summary, the proposed project will include:

• The replacement of the two existing kilns with one kiln line (adjacent to or near the existing Kiln 2);

• Decommissioning and removing the two existing kilns (Kiln 1 and Kiln 2); • Upgrading existing raw milling facility to accommodate increased production rate; • Installing a new coal mill for indirect firing and inert operations; Upgrading existing

cement milling facility to increase capacity to accommodate increased production rate;

• Converting each mill to a closed circuit operation via installation of a high efficiency separator;

• Upgrading existing conveying equipment to meet increased production rates; • Installation of emission abatement technology to improve air quality; • Additional on-site storage for fly-ash and slag; and • Overburden disposal options include the use of proposed waste dumps, construction

of surface overburden dumps, by concurrent backfilling of a pit during mining and by backfilling of a mined void on completion.

The following on-site operations remain unchanged:

• Existing mining infrastructure, crushing, screening and stockpiling activities;



• No changes to existing plant footprint; • Product storage; • Dispatch area; • On-site rail infrastructure and other plant infrastructure; and • Associated operations including waste handling facilities.

The proposed upgraded cement manufacturing facility is being designed for an output capacity of 800 000 tonne per annum clinker which would enable the manufacturing of up 930 000 tonne per annum cement. PPC Riebeeck would require approximately 1 122 000 tonnes of limestone, 105 000 tonnes of shale, 52 000 tonnes of FDG, 37 000 tonnes of gypsum, 48 000 tonnes of slag, and 23 000 tonnes sand to manufacture the 800 000 tonnes per annum of clinker. As part of the upgrade, PPC would require additional volumes of FDG and gypsum, but also intends using slag and fly-ash as extenders. The new upgraded plant would use approximately 90 tonnes of sand per day, as opposed to the current 54 tonnes per day. There are various potential sources of sand in the region, mainly located east of Riebeek West. .

1.2.2. Proposed Mining Operations It is proposed that the existing limestone pit would be deepened and extended in diameter towards the existing plant. The pit area would measure 128.5 ha. Most of the material required over 30 years would be mined from the northern portion. PPC intends to continue to mine shale at Delectus as part of the overburden stripping. As is current practise, mining includes the use of drilling, blasting, loading and hauling. It was given that the current blasting activity, which occurs once or twice per month, would not change significantly.

1.2.3. Proposed Overburden Disposal Various dump sites were considered by PPC for suitability of the proposed increased mining, however, only three of these sites were considered to be the most suitable considering a range of factors. These three sites include the Delectus berm, South dump and the Vlakkerug overburden dump (Figure 1-7). Dumping will take place concurrently on all three dump areas. Within these three locations various options for dumping between the sites were modelled. Concurrent rehabilitation would be undertaken on the overburden dumps. Where possible overburden would be dumped on the surface, forming an outside berm that is rehabilitated to screen the potential dust impacts associated with waste-rock tipping. The overburden dumps would then be in-filled and rehabilitated at various phases during the mining process



Figure 1-7: Overburden dump alternative locations

1.2.4. Road and Rail Access The limestone reserves would be accessed through the deepening and widening of the current pit, hence no new haul roads are required except for the extension of the road within the mining pit. The existing PPC access roads would remain the same, i.e. the public R311 and the Minor Road 346, which is located on PPC‟s property. As a result the additional number of road truck trips generated by the proposed upgrading of the Riebeek West plant amounts to an average increase of some 58 road vehicles trips per day, assuming a five working day week (Robertson 2011). Similarly an additional 62 rail trucks will be required on the input side, while a further 81 are necessary on the output cement delivery side of the production process. According to the Transport Impact Assessment (Robertson 2011), PPC has undertaken to direct all newly generated public road based truck traffic resulting from the increased mining and manufacturing activity via the R311 north to the N7 (south of Moorreesburg) thereby avoiding adding to the existing traffic through Riebeek West and Riebeek Kasteel (and for that matter through Malmesbury). Furthermore, since there would be no increase in the number of personnel employed on site, there will be no change in the number of vehicles used by staff and visitors.



PPC has indicated that at this stage it is difficult for them to predict sources and thus suppliers of sand in the future. PPC are, however investigating the possibility of purchasing sand from existing, permitted sand reserves near to the Bergriver area as these sites are closer to the plant. Should this happen, the haul vehicles transporting sand would be required to travel along the existing public gravel road between Riebeek West and Gouda. These specific vehicles would not travel through Voortrekker road (i.e. through the two Riebeek Towns) due to the location of the “Gouda” gravel road (DR1158) which links up on the side of the Town (see Figure 1-2).

1.3. Sensitive Receptors The predominant land use activities within the surrounding area of the PPC mine, cement manufacturing plant and overburden dump are mainly agriculture. Wheat farming activities dominate the near field. There is a rugby field on the southern portion of PPC‟s property which is used by the Rugby Performance Centre. There are also a number of farmsteads and farm labourers’ houses located on the farms surrounding PPC‟s property, including Bossiesvlei and Langvlei. The closest residential area is the existing Ongegund village, which is located to the south-western boundary of PPC‟s property on the opposite side of the R311. This residential village, currently consisting of about 80 houses is approximately 1.7 km from the existing plant and approximately 250 m from the overburden dumping location (proposed South overburden dump) on the south-western boundary of the site. The next two residential areas include Riebeek West which is situated south, approximately 4.1 km, from the existing plant and Riebeek Kasteel also south, approximately 8 km away from the plant. These two towns lie east and southeast of the Kasteelberg, respectively. The landuse between the two towns and on the lower slopes of the Kasteelberg is characterised by agricultural activities, most notably viticulture.

1.4. Project Terms of Reference The terms of reference for the air quality study are outlined below:

• Review the previous air quality assessment undertaken as part of the previous EIA for the PPC Expansion Project “Se Kika” (2006-2010) and utilise the information, where relevant, for the requisite air quality assessment report.

• Establish baseline conditions, by: o Identifying, collating and describing all existing information on the proposed

process, meteorological and air quality monitoring data in the study area, as well as other air pollution sources and sensitive receptors in the study area.

o Undertake appropriate ambient monitoring to inform study.



o Analysing any additional monitoring data, including particle air concentration and fallout measurements, which have taken place subsequent to the previous EIA for the PPC Expansion Project.

o Providing an overview of legislative and regulatory requirements pertaining to atmospheric emissions and ambient air quality, including local and international air quality guidelines and standards.

• Predict potential impacts of the proposed upgrade by: o Compiling an emissions inventory for the construction and operational phases

of the project, including routine and emergency conditions, as well as during shutdowns.

o Preparation of the dispersion model, including the adjusted and new air emissions.

o Undertaking stack height screening modelling to inform recommendations regarding a suitable stack height.

o Applying the air dispersion model to determine incremental and cumulative pollutant concentrations in the ambient air as a result of the construction and operational phases of the proposed upgraded facility and mining.

o Utilise onsite meteorological data to quantify dispersion potential. o Assess the impacts of mining in terms of air quality parameters. o Assess the air quality impacts of the transportation of product (including

comment on tailpipe emissions and wheel entrainment) from the plant (up to the R311) and comment on the route to the N7 via Moorreesburg.

o Comment on the potential air quality impacts of the sand HGVs travelling along the gravel road.

o Assessment of air quality impacts including: Evaluating emissions in terms of the potential to contribute to global

warming within the context of South Africa’s last reported contribution to greenhouse gases.

Undertaking a compliance and health risk analysis of the predicted results for the proposed upgrade. The health risk assessment is to consist of a comparison of predicted concentrations with guidelines published by the World Health Organisation, the US Environmental Protection Agency and similar international organisations.

Evaluating (a) magnitude, frequency of occurrence, duration and probability of impacts, (b) the local, regional, national and international significance of predicted impacts, and (c) the level of confidence in findings relating to potential emission impacts, (d) the degree to which the impact can be reversed, and (e) cumulative impacts that may occur as a result of the activity.

Commenting on the use of Furnace Dust Granules (FDG) in the cement manufacturing process.

Commenting specifically on the air quality and potential health risks to the Ongegund village residents.

o Recommendation of mitigating measures to address predicted impacts. • Update the Air Quality Management Plan developed by PPC, subsequent to the

previous EIA. • List additional or required permitting and/or licensing requirements.



• Compile an air quality assessment report that documents the tasks mentioned above, i.e. including a Baseline Assessment, Impact Assessment with mitigation options and an updated Air Quality Management Plan. The specialist report must contain all information specified in Regulation 32(3) of the NEMA EIA Regulations.

• Complete the NEM: AQA air emission licence application for the proposed plant using the AEL for the current PPC Riebeeck plant as a basis.

• Make available own report to all other specialists for alignment of the specialist reports.

• The study must take cognisance of the DEA&DP, DEA, Swartland Municipality and the West Coast District Municipality Air Quality Guidelines and requirements for air quality monitoring.

1.5. Issues Raised by Interested and Affected Parties A number of issues related to air pollution were identified during both the initial public engagement process as well as meetings with the local and provincial authorities. These have conveniently been grouped into six categories as given in Table 1-1. Where these issues have not already been covered by the terms of reference, they were added in the investigation.

1.6. Methodology The investigation may be summarised into the following three main segments:

• Baseline assessment of current conditions in the study area; • Predicted impacts of the proposed project, including

o mining processes; o cement production facility; and o disposal of overburden

• Air quality management plan The study approaches of these tasks are discussed below.



Table 1-1: Air pollution issues identified during the consultation process.

Issues Raised Response General Air Quality Concerns:

• Concerns about general air pollution due to the factory’s outputs • The potential air quality impacts are assessed in this investigation, as stipulated by the terms of reference

• A short term solution to the current air quality problems should be discussed and agreed upon by PPC and the West Coast District Municipality (WCDM)

• This was not part of the air quality specialist terms of reference. A meeting was held between PPC and the WCDM and an agreement was reached at the meeting.

• The air quality and health risk analysis study must demonstrate that the emissions that will result from the processes to be undertaken; will be able to meet the required standards as indicated in terms of Section 21 of the National Environmental Management Act: Air Quality Act, 2004 (NEM: AQA), Listed Activity Category 5, Subcategory 5.4

• This is a very important aspect. In the absence of actual emission rates provided by PPC, the investigation utilised emission factors (US EPA and Australian NPi) to quantify mass flow rates. Only the suppliers of equipment are in a position to demonstrate that the emission limits specified in Subcategory 5.4 will be met

• All public participation processes (PPP) would need to indicate that an application for an AEL [i.e. Atmospheric Emission License] has been submitted and also forms part of the application for the proposed upgrade of the facility. Comments for the AEL application would therefore also need to be submitted during the public participation process concerned

• Whilst technical information contained in this assessment and report will be provided for inclusion in the AEL, all PPP and comments are dealt with by Aurecon

Dust and Particulate Matter (PM10): • It is imperative that the air dispersion modelling that is undertaken

conforms to the following requirements and sufficient information must be provided to the Authorities to allow a full understanding of the results and how they were derived. Thus:

o A description of the input data, including source of data, validity of data and any assumptions must be provided.

o An electronic copy of all input files required to run the model must be provided together with a hard or electronic copy of the output text file.

o All plotted contours must be overlaid onto a current aerial photograph or topographic map or a street map.

• The assessment has been conducted using local and internationally acceptable methodologies and mathematical models. The methodology and sources of information will be provided in sufficient detail, including

o Model input data will be provided (source of data, validity of data and any assumptions).

o This will be prepared. .

o Concentration isopleths are overlaid on an aerial map



o Time series plots must also be provided to further support how the conclusions of compliance have been reached.

o The source site and closest sensitive receptors must be highlighted. Residential areas can also be shown as a single receptor.

o The scale selected should show all relevant ground level impacts. It must be shown as part of the output, either as labelled axes or as a separate scale bar.

o A discussion on the accuracy of the results and comparison with appropriate standards must be provided according to the various averaging periods that are applicable.

o Time series plots are included for Ongegund and Riebeek West o These are included in the aerial map o The concentration and distance scales are included on map

o The accuracy of the results is included as far as possible and compared with NAAQS according to the various applicable averaging periods

• Details of the ambient background levels of pollutants that were used and their source must be provided

• Historical monitoring data have been included. Additionally, a short monitoring campaign has been initiated to monitor ambient PM10, sulphur dioxide, nitrogen dioxide and Volatile Organic Compounds.

• The impact of the proposed operations on the ambient air quality must be demonstrated for the current plant as well as under normal and abnormal conditions for the proposed new plant

• The potential air quality impacts are assessed in this investigation, as stipulated by the terms of reference

• Recommend using the atmospheric dispersion model AERMOD to model the impact of the proposed installation on ambient air quality

• This model was selected for the air quality assessment

• Recommend that air dispersion modelling be conducted for NOx, SO2 and PM10

• These pollutants are included as a minimum

• Recommend that DEA&DP’s Model Ready Datasets for AERMOD be utilised for this purpose (Datasets will be available in June 2011). In the event that the delay in the availability of these datasets compromises current project progress, this requirement can be ignored

• The study has been initiated prior to the date of the dataset’s availability. The model has been developed with onsite data.

Transport Emissions: • Concerned about the impact of dust from vehicles on the Ongegund

community during the operations • The potential air quality impacts are assessed in this investigation, as

stipulated by the terms of reference



• Ninham Shand omitted to regard the emissions by trucks as an area to be studied in the previous study, it was only included after insistence by I&AP’s. All trucks and other vehicles during the construction and operational phase in addition to trucks transporting sand must be included in the study.

• The potential air quality impacts are assessed in this investigation, as stipulated by the terms of reference



1.6.1. Baseline The baseline study requires a review of the site-specific atmospheric dispersion potential, existing air emissions, legal requirements (including relevant air quality guidelines and limits) and existing ambient air quality in the study area. A description of the dispersion potential is important since it provides an understanding of the behaviour of pollutants once it is released into the boundary layer, i.e. the degree of dilution and transportation of air pollutants in the atmosphere. The dispersion potential is a function of both regional and local meteorology. The latter is best described using on-site monitoring data, whereas the former can be obtained from stations located away from the site of interest. Since a substantial amount of information was collected, developed and analysed as part of the previous EIA, which was completed for the PPC Expansion Project “Se Kika”, the first logical step was to review the previous air quality impact report (Burger and Olivier, 2008) and technical data used in the calculations. Of particular relevance, were the two information sections that covered ambient air quality monitoring analyses and the establishment of the baseline air emissions inventory. The former constituted observations only, whilst the latter required both measurements and predictive methods. Furthermore, the most significant sources of air emissions in the study area were identified as agricultural activities and those associated with the PPC Riebeeck West plant. Any information that became available subsequent to the pervious assessment was identified. In this regard, the only improved ambient information was the locally observed meteorological data and the continuation of monthly dust fallout rates. No additional air pollution concentration data were available. Although the air impact completed as part of the previous EIA indicated impacts in relatively close proximity to the PPC operations, it was decided to maintain the size of the study area as 20 km by 20 km. Where necessary, the spatial resolution was reduced to focus into specific areas of concern, e.g. air pollution concentration levels around transport routes. In the previous assessment, data from the closest South Africa Weather Services’ station, i.e. Malmesbury, was used in the analysis of atmospheric dispersion potential. Subsequently, one year’s (2010) onsite meteorological data became available for the analysis. Apart from dust deposition, no ambient air quality monitoring was conducted subsequent to the previous assessment. A relatively short monitoring campaign of one month was therefore included in the current assessment (May/June 2011). This campaign included the observation of inhalable particulate, sulphur dioxide, nitrogen dioxide and volatile organic compound air concentrations. The baseline was established as a combination of observational and predicted air quality data. A suitable and accepted atmospheric dispersion model was used to simulate the air emissions from the PPC Riebeeck West operation and agricultural activities, which allowed the establishment of air concentrations resulting from these air pollution sources.



Emissions Inventory An emissions inventory was established and comprised emissions from agricultural activities and the current cement manufacturing plant, mining activities, overburden disposal and transportation of raw material, waste and product. Since in the study area remained the same, the originally developed particulate emissions inventory from the agricultural sector (Burger and Olivier, 2008) was used again. More recent stack emissions monitoring data became available to allow improved estimates of particulate, sulphur dioxide and oxides of nitrogen. Due to the new stack emission data and the onsite observation of wind speeds, an improved emissions inventory for the PPC operation could be established. Whilst the main process emissions (stacks) were provided by PPC, emission rates were calculated using emission factors (e.g. kilogram pollutant per clinker production rate, kilogram pollutant per material transfer rate, etc.) developed by the US EPA and Australia’s National Pollution Inventory (NPi). The emissions calculated using these emission factors typically include fugitive dust emissions from material handling, crushing, wheel entrainment and wind erosion of stockpiles and exposed areas. Selection of Dispersion Model Gaussian-plume models are best used for near-field applications where the steady-state meteorology assumption is most likely to apply. The most widely used Gaussian plume model is the US-EPA Industrial Source Complex Short Term model (ISCST3). This model has however been replaced by the new generation AERMOD model and was used in this study. This model is based on the Gaussian plume equation with modifications to incorporate topographical features such as the Kasteelberg Mountains. The model has been the subject of a number of validation studies, and has shown to be an improvement to its predecessors. The model is been recommended for regulatory use in the USA, and accepts its uncertainty of between -50% and 200% (This may appear to be a large uncertainty, but covers a logarithmic scale). The accuracy improves with fairly strong wind speeds and during neutral atmospheric conditions. Input data types required for the AERMOD model include: source data, meteorological data (pre-processed by the AERMET model), terrain data and information on the nature of the receptor grid. Review and Preparation of Meteorological data AERMOD requires two specific input files generated by the AERMET pre-processor. AERMET is designed to be run as a three-stage processor and operates on three types of data (upper air data, on-site measurements, and the national meteorological database). Since the model was designed for the USA environment, various difficulties are found compiling the required dataset for the South African environment. The main data shortfalls include the following:



• No national meteorological database exists; • Upper air measurements are only measured at 5 locations in South Africa. However,

the South African Weather Services (SAWS) has modelled upper air data for the entire country on half degree intervals; and

• Surface meteorological stations seldom measure all the required parameters (such as solar radiation, cloud cover, humidity).

Hourly recorded surface meteorological data recorded on the PPC Riebeeck West site for 2010 was utilised in the simulations as well as simulated upper air data obtained from the SAWS for the same year. Receptor Grid The dispersion of pollutants was modelled for an area covering 20 km by 20 km. The area was divided into a grid matrix with a resolution of 200 m by 200 m, with the facility located approximately in the centre of the receptor area. AERMOD simulates ground-level concentrations for each of the receptor grid points. The height of each receptor point was set to 1.5 m above ground level to account for the breathing zone. Topography was also included in the model setup. Legal Review and Assessment Criteria It is important to summarise and discuss the ambient air and minimum emission standards as prescribed by the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) (NEM-AQA). Although the NEM-AQA already commenced on 11 September 2005, the Act was only brought into full force on the 1st of April 2010. The original publication of the NEM-AQA in the Government Gazette on 9 September 2005 omitted Sections 21, 22, 36 to 49, 51(1)(e),51(1)(f), 51(3),60 and 61. It is also important to put the requirements of the Act into context of international criteria used by institutions such as the World Health Organisation (WHO), US Environmental Protection Agency (US EPA), World Bank (WB), etc.

1.6.2. Predicted Impacts The impact assessment relies on predictions of air pollution emissions and their subsequent air concentrations using a suitable atmospheric dispersion model and representative meteorological data. This is followed by testing compliance of these predicted air concentrations with the National Ambient Air Quality Standards (NAAQS), which were promulgated as part of the NEM-AQA). For those pollutants not included in the NAAQS, comparison to other international authorities, such as the WHO and US EPA, may be included. In addition, emission concentrations (i.e. the concentration of the pollutant at source) need to be compared against the Minimum Emissions Limits if any of the proposed processes are included in the Listed Activities of Section 21 of the NEM-AQA.



Based on the results of the impact assessment, further emission controls and management practices may be required to address processes that result in non-compliance of the NEM-AQA. Emissions Inventory The emissions inventory was established and comprised emissions for the cement manufacturing plant, mining activities, overburden disposal and transportation of raw material, waste and product. All emission rates were calculated using emission factors as published in Australia’s NPi. The emissions calculated using these emission factors included gaseous emissions from the plant and fugitive dust emissions from material handling, crushing, wheel entrainment and wind erosion of stockpiles and exposed areas. As for the processing plant, mining and overburden disposal, haul truck emissions inventory was based in the application of emission factors (e.g. gram pollutant per kilometre per vehicle) developed for various vehicle and fuel types, vehicle speeds and road slopes. Emission factors apply to exhaust emissions, evaporative emissions (e.g. petrol tank), break and tyre ware, and wheel entrained particles. Vehicle emission factors for tailpipe exhaust emission were developed for the South African fleet and fuel specifications representative of the late 1990’s. The investigation formed an integral part (Phase II) of the Vehicle Emissions Project initiated by the Department of Minerals and Energy (DME). Both petrol and diesel driven vehicles were included in the project (Wong and Dutkiewicz (1998), Wong (1999) and Stone (2000)). Unfortunately, no recent publications on emission factors could be found that represented a more recent vehicle mix. As an alternative, a very comprehensive set of emission rate factors was developed by the European Environment Agency (EEA 1999 and Ntziachristos et al, 2007). The methodology covers regulated exhaust emissions of carbon monoxide, oxides of nitrogen, sulphur dioxide, particulate matter, volatile organic compounds (VOC) and lead, in addition to a number of other unregulated compounds. These emission factors also accommodate the dependence on vehicle types, engine types, fuel specification and vehicle speed. They also have reduction factors for the implementation of inspection and maintenance programme. Non-exhaust contribution to total particulate matter emissions due to tyre wear, brake wear and road surface wear were based on the EEA Emission Inventory Guidebook (European Environment Agency, 2009). Air emissions were calculated for the transport of raw material entering and the product leaving the PPC facility. Transport vehicle numbers were obtained from the Transport Specialist Study (Robertson 2011) Dispersion Model The AERMOD model used to predict the baseline conditions was also used to predict the impacts from the proposed operation. Concentration transects were calculated that illustrate the air concentration of a particular pollutant at increasing perpendicular distances away from the road edge. These transects allow for easy identification of zones of impact through the application of the assessment criteria discussed in the previous section. The US CALINE 4 (Benson, 1984) model was



selected to simulate the atmospheric dispersion of tail gas and fugitive particulates. This model has received wide acceptance internationally for the simulation of air concentrations near roadways and was therefore deemed the best selection for this project.

1.7. Assumptions and Limitations

1.7.1. Baseline Information As a minimum, one year’s historical hourly average meteorological data is required to describe the dispersion potential of the study area, and therefore the ability to predict the distribution of air pollutants. A year’s data is required to allow the inclusion of seasonal differences. This mainly applies to the variation in wind speed, wind direction, ambient air temperature and the structure of the boundary layer (i.e. atmospheric stability and inversion layers). However, it is also common practice to account for variations between different years, by including multiple years in the simulations. For this purpose, up to five years’ hourly average meteorological data would normally be adequate. Onsite meteorological data was available for the period January 2010 to December 2010. Although this meets the first criteria of including seasonal variations, it limits the simulations to reflect only a single year’s measurement. The alternative would have been to perform the simulations with meteorological data from the nearest South Africa Weather Services’ station at Malmesbury. However, a comparison of the two datasets clearly shows that the latter observations do not reflect the influence of the Kasteelberg Mountain range in the wind field. The prevailing wind direction observed at Malmesbury data is south to south-southwest and north-northwest to north. In contrast, the prevailing wind directions observed at the PPC site is southeast to east, and west to north-northwest. In addition, calm wind conditions (periods with wind speeds less than 1 metre per second) were observed to occur 39% at the Malmesbury station, whereas on 13% calm wind conditions occurred at the PPC Riebeeck West site. Due to these differences, it was decided to rather use the year’s onsite dataset than the data available from the Malmesbury weather station. Whilst the former dataset may not illustrate potential annual variations, it meets the more important seasonal variation criteria. This limitation is not considered significant since the annual variations are generally not significant in the Western Cape region. No historical upper air data is available for the study area. Three options exist in its absence, namely to use theoretical expressions contained in AERMOD to extrapolate from the surface layer to higher altitudes, direct measurements or to use the results from global atmospheric model simulations (e.g. MM5, Unified Model, etc.). Since elevated stack releases could potentially be influenced differently by atmospheric conditions at higher altitudes, it was considered important to use either direct measurements or the more complex models employed in a global atmospheric model instead of the AERMOD extrapolation techniques. However, since upper air measurements (e.g. Doppler Acoustic Soundings), would not be practical, the only other alternative is to employ simulated wind field data. As a result, upper air data for 2010 was obtained from the South African Weather Services’ Unified Model, which was extracted at a grid-point closest to the PPC Riebeeck facility. Given the alternatives, it was assumed that this represents the best option.



Long-term, baseline air quality monitoring was only conducted for dust fallout, and includes the period 2000 to 2010. A short, three-month monitoring campaign of airborne inhalable particulate matter was completed during 2007 (June to August). Sulphur dioxide and nitrogen dioxide were also monitored during 2007 for a month using passive diffusive sampling methods. Although there should be no reason why the results for the particulate, sulphur dioxide and nitrogen dioxide will vary significantly, it was nonetheless decided to conduct a further, albeit a similar short-term (1 month) monitoring campaign for the current study. This campaign included inhalable particulate matter, sulphur dioxide, nitrogen dioxide and volatile organic compounds. Given the availability of information, it was assumed that the combination of these observational results and dispersion simulations of the main air pollutant sources, namely PPC Riebeeck West and agricultural activities, would adequately describe the current air quality in the study area. In order to estimate the current air quality in the study area use was made of emission measurement results and emission factors for stack emissions at cement manufacturing plant. Emission factors where used to estimate all fugitive emissions resulting from material transfer, mining activities and transport. Similarly, emission factors where used to quantify windblown dust originating from agricultural activities. These emission factors generally assume average operating conditions. Agricultural activities typical for the month had to be assumed. This therefore resulted in monthly average dust emission rates. Due to differences in individual farming practices and short-term meteorological conditions, these emissions can in reality vary significantly from day-to-day and diurnally. The predicted dust emissions from agricultural activities can therefore only be used for long term (monthly to annual) comparisons. Highest hourly and daily incidents cannot be predicted accurately. Due to the difficulty in quantifying emissions from all dust sources such as public gravel roads, these were not included in the baseline and predicted air concentration estimations. The air pollution impact of gases and dust generated by haul trucks (bag carriers and tankers) travelling to and from PPC were however included. PPC currently implements an unpaved road watering programme to minimise vehicle-generation fugitive dust from these sources. For the purposes of this assessment, it was assumed that the programme is implemented routinely and according to the plan, which would control the emissions by 75%.

1.7.2. Impact Assessment Although the main tasks of the construction phase were provided, the detail required to estimate emissions from every activity were insufficient to allow the establishment of an accurate emissions inventory. All of the planned improvements would be undertaken on the existing plant site and the approximate area of construction estimated. The construction impacts were therefore based on an area-wise emission factor, rather than activity-based. This limitation is not considered significant since the construction activities do not include major earthworks, which may otherwise have resulted in an under-estimate of the construction impacts.



As for the baseline calculations, one year’s (2010) onsite meteorological monitoring data was used to calculate the anticipated air pollution impacts from the proposed upgrade. A comparison of this data and that observed at Malmesbury (SAWS) shows that the latter observations do not reflect the influence of the Kasteelberg Mountain range in the wind field. Upper air data for 2010 was obtained from the SAWS’s Unified Model, which was extracted at a grid-point closest to the PPC Riebeeck facility. Given the alternatives, it was assumed that these choices represented the best options. In order to estimate the air quality due to the proposed upgrade use was made of the Department of Environmental Affairs’ Minimum Emission Standards as prescribed by NEM-AQA (Section 21) and emission factors. Emission factors where used to estimate all fugitive emissions resulting from material transfer, mining activities and transport. The assessment assumes that coal is the only energy carrier. The use of alternative fuels may have different pollution emission rates and therefore air impacts. Since PPC currently implements an unpaved road watering programme to minimise vehicle-generation fugitive dust, the same programme was assumed for the proposed upgrade, viz. it was assumed that the programme is implemented routinely and control the emissions by 75%.

1.8. Report Structure Section 2 contains a short description of the air pollution associated with the current and proposed mining and cement production activities. This provides the basis for selecting the pollutants and health risk criteria which are discussed in Section 3. Section 4 is a discussion of air pollution impact on vegetation and includes information on all pollutants with known affects. Air quality criteria developed by governmental organisations (e.g. South African and US Environmental Protection Agency standards) and other institutes such as the World Health Organisation have been summarised in Section 5. Section 6 is a short description of the meteorological parameters important to describe the dispersion potential of the site. This section also contains the discussion of measured air quality data, including fallout and air concentrations. A summary of the emissions inventory for the current facility and the agricultural activities, and the proposed plant is given in Section 7. This is followed by a description of the dispersion model and the predicted air concentration results for the baseline in Section 8. Section 9 summarises the predicted air concentrations and fallout discussed for the proposed operation. Recommended mitigation measures are discussed in Section 10 with the impact significance rating summary given in Section 11.



A framework for air pollution management is summarised in Section 12. The conclusions and recommendations are summarised in Section 13.



2. POTENTIAL AIR POLLUTANT EMISSIONS

2.1. Air Pollution from Cement Manufacturing Facilities Cement manufacture is made up of various processes. These broadly encompass the following:

• Quarrying/Raw materials acquisition • Raw materials milling • Raw materials mix proportioning; • Kiln feed preparation and storage; • Coal milling and storage; • Calcining and clinker production • Clinker cooling • Clinker storage • Finish milling • Cement production and storage; • Packing and palletising; and • Bulk loading.

These processes are reflected in the block diagram in Figure 2-1 and Figure 2-2. Limestone is the principal raw material used in cement manufacture. Quarry operations normally consist of drilling, blasting, excavating, loading, hauling, crushing and screening. The crushed material is then blended by stacking and reclaiming from a stockpile built up in layers. Additional materials such as clay, sand and shale are required as sources of silica, alumina, and iron respectively. The blended limestone is proportioned with the additional materials, then dried and ground in the raw mill to produce raw meal. The heat required for drying the raw materials is supplied from the kiln exhaust gas. The sources of emissions and pollutants are shown in in Figure 2-1 and summarised in Table 2-1.. Table 2-1: Locations of significant air emissions and pollution types

Location Activities Pollutants Mining Land clearance, excavation,

scraping, wind erosion, haul trucks (wheel entrainment and exhaust emissions)

Mainly TSP and PM10, but vehicle tailpipe emissions including oxides of nitrogen, carbon dioxide, carbon monoxide, sulphur dioxide and particulates

Raw material transfer Haul truck loading and offloading, conveyer transfer and other tipping operations

TSP and PM10

Raw materials storage Stacking and reclaiming, wind erosion

TSP and PM10

Raw material preparation Crushing and milling TSP and PM10 Calcining and clinker production in the kiln

TSP and PM10, metals, sulphur dioxide, oxides of



Location Activities Pollutants nitrogen, carbon monoxide, carbon dioxide, gaseous chlorides, organic compounds

Product finishing Milling TSP and PM10 Product loading and transport

Tipping operation Wheel entrainment and exhaust gas

Mainly TSP and PM10, but vehicle tailpipe emissions including oxides of nitrogen, carbon dioxide, carbon monoxide, sulphur dioxide and particulates

Topsoil piles Tipping and bulldozing operations, wind erosion

TSP and PM10

Overburden dumps Tipping and bulldozing operations, wind erosion

TSP and PM10

Historically, the emission of dust has been the main environmental concern in cement manufacture. Point source dust emissions originate mainly from the raw mills, the kiln system, the clinker cooler, and the cement mills. The nature of the particulates generated is linked to the source material itself, i.e. raw materials (partly calcined), clinker or cement. Dust from fugitive sources in the plant area originates mainly from traffic movement on unpaved roads and materials storage and handling. As the chemical and mineralogical composition of dust in a cement plant is similar to that of natural rocks, it is commonly considered as a “nuisance” and not as a toxic product. Emissions of metal compounds from cement kilns can be grouped into three general classes, namely volatile metals (such as mercury), semi-volatile metals (including antimony, cadmium, lead, selenium, and zinc) and non-volatile metals (including chromium, arsenic, nickel, manganese, and copper). While volatile metals mainly concentrate in the primary gaseous emissions through the stack, non-volatile metals tend to accumulate in the clinker. The semi-volatile metals are partitioned between the clinker and primary exhaust. The exact level of partitioning of these metal groups is affected by kiln operating procedures. The kiln system is responsible for the most gaseous emissions in the cement manufacture process. The major gaseous emissions are oxides of nitrogen (NOx) and sulphur dioxide (SO2). Other emissions of less significance are VOCs (volatile organic compounds), carbon monoxide (CO), ammonia (NH3), hydrogen fluoride (HF), hydrochloric (HCl), and heavy metals. Carbon dioxide (CO2) as the main greenhouse gas is released in considerable quantities. NOx formation is an inevitable consequence of the high temperature combustion process, with a smaller contribution resulting from the chemical composition of the fuels and raw materials. Sulphur entering the kiln system via raw materials and coal is largely captured in the kiln products. However, sulphur contained in raw materials as sulphides (or organic sulphur compounds) is easily volatilised at fairly low temperatures (i.e. 400- 600° C) and may lead to SO2 emissions in the stack.



Figure 2-1: Generic process flow diagram for the Portland cement manufacturing process (US EPA Ap-42 Section 11.6)



Figure 2-2: General cement production process (PPC Background Document for the Proposed Secondary Materials Co-Processing Programme, 2006) Carbon dioxide emissions arise from the calcination of the raw materials and from the combustion of coal. CO2 resulting from calcination can be influenced to a very limited extent only. Other substances entering the kiln system which could give rise to undesirable emissions are either effectively destroyed in the high temperature combustion process or almost completely incorporated into the product. Thus, the inherent process conditions prevailing in cement kilns result in emissions being usually at insignificant levels for most of these substances such as VOCs, HCl, HF, NH3 or heavy metals. Chlorides and fluorides may enter into the kiln system with the raw materials and/or the fuels. The greater part is captured by the fine raw material particles and is discharged from the kiln system with the clinker. Small quantities leave the kiln system adsorbed on dust particles. Emissions of VOC, CO and NH3 can occur in the primary steps of the kiln process (preheater, precalciner), when impurities (such as organic matter) that are present in the raw materials are volatised as the raw mix is heated. The most significant VOC’s are expected to include benzene, toluene, xylene and formaldehyde. Emissions of chlorinated hydrocarbons such as dioxins and furans are usually well below existing limit values. Any chlorine introduced to the kiln combustion system in the presence of organic material may form polychlorinated dibenzodioxins (dioxins) and polychlorinated



dibenzofurans (furans), both of which are highly carcinogenic gases. Process conditions in cement kilns – i.e. high combustion temperatures and long retention times – will effectively destroy organic compounds in the fuels. Thus, dioxins and furans introduced with any fuel would not survive. However, dioxins and furans can also form in/after the pre-heater and in the air pollution control device if chlorine and hydrocarbon precursors from the raw materials are available in sufficient quantities. This formation of dioxins and furans is known to occur by de novo synthesis, and forms in the temperature range from 200 to 450°C. Rapid cooling as the gases leave the system would therefore reduce the formation of dioxins and furans through this process. In practice, this is what occurs in pre-heater systems as the incoming raw materials are preheated by the kiln gases. The US EPA (EPA 2000) has stated in a comprehensive report on dioxin generation, that dioxin or furan formation occurs principally in the post-combustion phase when the carbon and chloride in the raw materials are volatilised in the early pre-heater stages where is the temperatures are too low to combust the volatile organic carbon fractions. Without a conditioning tower the residence time of these gases, from when they leave pre-heater to when they are released to the atmosphere, could be as long as 15 – 20 seconds at temperatures greater 200 °C (i.e. in the de novo synthesis window). A conditioning tower (i.e. if an ESP is used) would result in these gases being cooled to below 200 °C within approximately 5 seconds. A large body of literature has appeared in the general and professional press since 1970 regarding the world-wide initiatives to utilise alternative fuels in cement kilns. Lately, this literature has been comprehensively reviewed by Sintef (Foundation for Scientific and Industrial Research at the Norwegian Institute of Technology (NTH)), the largest independent research organisation in Scandinavia, under the auspices of the Cement Sustainability Initiative of World Business Council for Sustainable Development. (Sintef 2005). The Sintef report evaluates more than 2 200 PCDD/F measurements as well as some measurements of polychlorinated biphenyls (PCBs) made from the 1970s until 2004. All the large capacity cement processing technologies are represented under both normal and worst case operating conditions, with and without alternative fuels, with wastes and hazardous wastes fed to the kiln burner, to the kiln inlet and to the pre-calciner. The main conclusions drawn from the report findings include:

• Most cement kilns can meet an emission level of 0.1 ng TEQ/Nm³ if primary measures are applied;

• Co-processing of alternative fuels and raw materials, fed to the main burner, kiln inlet or the pre-calciner does not influence or change the emissions of POPs (persistent organic pollutants);

• Data from dry pre-heater and pre-calciner kilns in developing countries presented in the report show very low emission levels, much lower than 0.1 ng TEQ/Nm³.

Input of other volatile components such as mercury may also potentially be present. Metals introduced into the kiln through the raw materials, such as the FDG (see Appendix A for a typical composition) or the fuel will be present in either the air releases or in the clinker. FDG contains primarily iron (typically 58%), calcium oxide (typically 22%), silica (typically



3%) and aluminium (typically 2%). However, small amounts (parts per million) of arsenic, cadmium, cobalt, chromium, mercury, manganese, lead, zinc, etc. also occur in the FDG. The vast majority of heavy metals are retained in the clinker. Extremely volatile metals such as mercury and thallium are not incorporated into the clinker to the same degree as other metals. At very high temperatures many heavy metals evaporate and then condense on the clinker, on partly reacted raw materials or dust particles. Whilst most of the metals on dust particles are removed with emission control devises such as bag filters, very volatile metals, such as mercury could still escape. No odour emissions are expected from the plant since these are mainly related to emissions from handling and storage of alternative fuels which is not being used at the facility.

2.2. Current PPC Riebeeck West Plant The current PPC plant produces cement from raw materials mined on the site and purchased from other companies (including sand and furnace dust granules), as provided in Table 2-2. Quarry operations consist of drilling, blasting, excavating, loading, hauling, crushing and screening. The limestone rock is quarried in form of lumps up to 1 m³ in size, and then crushed down to particles smaller than 19 mm. The blended limestone is proportioned with the additional materials, then dried and ground in the raw mill to produce raw meal. The heat required for drying the raw materials is supplied from the kiln exhaust gas. Additional materials such as clay, sand and FDG are required as sources of silica, alumina, and iron respectively. The blended limestone is proportioned with the additional materials, then dried and ground in the raw mill to produce raw meal. The heat required for drying the raw materials is supplied from the kiln exhaust gas. Table 2-2: Approximate raw material usage (tonnes per annum) at current PPC Riebeeck West plant

The powder is then fed into one of two long dry kilns fired with coal where the limestone (calcium carbonate, CaCO3) is decomposed to form lime and carbon dioxide (above 800 ̊C), viz. calcination. In calcining, the raw mix is heated to produce Portland cement clinkers. Clinkers are hard, grey, spherical nodules with diameters ranging from 0.2–5. cm created from the chemical reactions between the raw materials. The calcining system generally involves three steps:

• drying or preheating;

Raw Material Type Current Consumption Rate

Limestone 816 000 Shale 90 000 Sand 13 300 Gypsum 18 000 Slag/Fly-ash - Filter Dust Granules 16 000 Coal 104 000



• calcining;and • burning (sintering)

The cylindrical steel rotary kiln is mounted with the axis inclined slightly (~3°) to the horizontal and rotates at a few (~2.5) revolutions per second. Finely ground coal is burnt at one end of the kiln – the hot gases pass through the kiln and then upwards through a number of cyclones into an ‘induced draught fan’. The cold kiln feed/raw mix is dropped into the top of the preheater. Centrifugal forces throw the meal against the walls of the cyclones and the meal slides down by gravity into ducts below. The hot gases pick up the feed and sweep it into the next cyclone, once again exchanging heat. This semi-counter-current heat exchanger significantly reduces total heat consumption in the burning process.

Figure 2-3: Reaction zones and temperature profiles for gas and clinker in a kiln (Source: Manning, D.A.C. (1995))

The temperature of the feed is between 900 – 1 000°C as it enters the kiln. At this point, the compounds have split up into their individual constituents (CaO, MgO, SiO2, Al2O3) and chemical reactions take place (Figure 2-3). About 20 percent of the mix forms a molten phase, which acts as a reaction medium, with the components dissolving and reacting, and reaction products being precipitated from the melt. Most of the carbon dioxide contained in the limestone is driven off in the precalciner. New compounds (calcium aluminosilicate and alumino ferrite) form as the material approaches the lower end of the kiln. Aluminosilicate clinker is formed at temperatures of 1 450-1 500°C. The material leaving the burning zone is now called clinker. The clinker is then milled in the finishing mills before being mixed with gypsum and other additives to produce Portland cement.



Control of the raw meal chemical composition is achieved by proportioning of the raw materials based on an on-line monitoring system with appropriate feedback adjustments. In determining the proportions of the additional materials, allowance is made for the amount and composition of the ash from the coal used for firing the kiln. The current PPC Riebeeck facility utilise coal as the only fuel source (Table 2-2). Coal delivered to the plant facility is stored on a stockpile before being dried and ground in a dedicated mill. Kiln exhaust gas provides the heat required for drying. Pulverised coal is fired at the lower end of the kiln, and also in the precalciner. Clinker discharged from the kiln is cooled by the cross-flow of air in a grate cooler and then conveyed to silos for storage prior to milling into cement. The heated air from the cooler is used for combustion of coal in both the kiln and the precalciner At the cement milling stage, gypsum is added to the clinker at a controlled rate (of about 5%) to regulate the setting time of the final cement. Depending on the product being manufactured, an extender (supplementary material) such as limestone may be added at the milling stage in accordance with the required product composition. The cement fineness is closely controlled during milling by regulation of the feed rate and the mill and the internal dynamic separator settings. From the cement mill, the cement is conveyed to a multi-cell silo for storage prior to despatch, either by bulk transport via road or rail, or in bags. Bagged cement is palletised in unit loads for convenience of handling and speed of loading. The current production rates are summarised in Table 2-3, for clinker and Portland cement, respectively. Table 2-3: Approximate clinker and cement production rates at PPC Riebeeck West Plant

The gas streams vented from the process are cleaned in electrostatic precipitators and bag filters. Normal process operating conditions are sometimes disturbed by, inter alia, blockages, breakdowns or power failures. During these periods, material needs to be removed from the units/equipment concerned. This material is normally reprocessed through the raw milling system. This could include, for example, the dust from dust collectors, drag chains coating and refractory materials, material removed from the kiln during kiln relines and any cement spillages. Currently, PPC Riebeeck emissions do not present any risk of dioxins for the following reasons:

• Kiln 1’s emissions leave directly from the kiln after water injection and air bleed to cool to 375°C ahead of the ESP. Thus no preheating of raw material occurs outside

Product Current Production Rate Proposed Production Rate Clinker 570 000 800 000 Portland Cement 663 000 930 000



of the kiln and full combustion of organics occurs in the kiln, thereby removing all precursors to dioxin generation.

• Kiln 2’s kiln gases (at 450°C) are passed through a 1-stage pre-heater and 2 seconds later are cooled in a conditioning tower to 190 – 220 °C. The opportunity for dioxin formation after the pre-heater is therefore minimised by the short time period experienced by the pre-heater gases before they are cooled.

2.3. Proposed PPC Upgrade

2.3.1. Cement Plant Technology The proposed plant upgrade aims at replacing the two existing kilns with a very efficient kiln line capable of producing 800 000 tonnes per annum of clinker compared to the current production of 550 000 tonnes per annum. In order to do this upgrades for the existing equipment will be undertaken and this includes:

• Upgrading the existing raw milling facility (replacement of ball mills) to accommodate the increased production rate. New ball mills would be more efficient in terms of energy usage.

• Installing a new coal mill for indirect firing and inert operations; • Decommissioning and removing the two existing kilns (RK1 and RK2) which are

approximately 140 m long. This would also include the removal of the existing 76 m high stacks.

• The existing kilns would be replaced with a low-NOx, multi-stage cyclone preheater (pre-calciner), a shorter dry mill (third of the length of the current kiln lines) and garte cooler. This technology has the following advantages in terms of reduction of air emissions:

o Coal is introduced under reducing conditions causing a reduction in nitrogen oxide emissions;

o Better energy efficiency means less coal usage and lower sulphur dioxide emissions; and

o The limestone being introduced counter-current to the gas emission flow from the kiln acts as a scrubber for sulphur dioxide.

The multi-stage cyclone pre-heater would be the tallest structure at the plant, reaching between 79m to 94m depending on the technology used. The current stacks are 76m high. The cooler stack is proposed to be located between the grate cooler and the coal mill. The 45m long kiln is proposed to be located adjacent to or near to the existing kiln 2 and would be similar in diameter to the existing kilns

• Upgrading the existing cement milling facility to increase the current capacity to accommodate the increased production rate;

• Converting each mill to a closed circuit operation via the installation of a high efficiency separator;

• Installation of additional on-site storage for fly-ash and slag in the form of two separate silos including enclosed conveying to the cement mills;

• Upgrading the existing conveying equipment (currently covered) to meet the increased production rates via increasing the speed of the drives etc.; and



• More efficient abatement equipment is proposed for the plant with all emission points likely to have bagfilters rather than the current electrostatic precipitators thus reducing dust emission from the stacks.

The proposed PPC raw materials consumption rate is summarised and compared against the current rates in Table 2-4. The raw materials would be proportioned by weigh feeders, and fed to the raw grinding mill. Mill venting would be provided through a bag house and the drying of raw materials would be accomplished by the hot gases from pre-heater and if required from a hot air generator. The raw mix for production of cement has to be uniform in composition before it is fed into the pre-heater. The ground raw meal would be conveyed to blending/storage silos. Table 2-4: Proposed PPC Riebeeck raw material usage (tonnes per annum)

The proposed cement plant would be based on a dry process and preheater/precalciner technology. All the units in upstream and downstream of the kiln will be designed for an installed clinker production capacity of 3 000 tonnes per day (Table 2-5). In the cyclone preheater system, efficient heat transfer takes place to finely dispersed raw material particles when they come in contact with hot gases from the Kiln. The proposed preheater is a multi-stage cyclone system connected with gas ducts and meal chutes (see example in Figure 2-4). The raw meal is fed into 2nd stage/3rd stage cyclone gas ducts and is carried by hot gas streams into the cyclone. The material gets separated from gas in cyclones and then travels downward through meal chutes and is discharged into the next lower stage gas duct. In this way, material comes into contact with high temperature gases and gets preheated and partially calcined. The feed then travels down as the kiln rotates. The cylindrical steel rotary kiln is mounted with the axis inclined slightly (~3°) to the horizontal and rotates at a few (~2.5) revolutions per second. The kiln firing system is based on coal. A specially designed Low-NOx burner is preferred for firing into the kiln for lower NOx generation as compared to a conventional burner. The hot gases pass through the kiln and then upwards through the preheaters and precalciner. This counter-current heat exchange significantly reduces total heat consumption in the burning process. The chemical reaction gets completed when the material enters into the

Raw Material Type Current Consumption Rate Proposed Consumption Rate Limestone 816 000 1 122 000 Shale 90 000 105 000 Sand 13 300 23 300 Gypsum 18 000 37 000 Slag/Fly-ash - 48 000 Filter Dust Granules 16 000 52 000 Coal 104 000 119 000



burning zone where it gets sintered to form cement clinker. The temperature required for sintering the clinker is in the range of 1 400°C -1 450°C. Before discharging the clinker to cooler it gets cooled in cooling zone of kiln up to 1 200°C –1 300°C. The clinker cooler then cools the hot clinker down to 70°C to 80°C. Part of the hot air recuperated from the hot clinker is used as secondary air for combustion of fuel in the Kiln

Figure 2-4: Typical process flow sheet of an in-line calciner kiln system (5-stage preheater)

The proposed production rates are compared to the current plant in Table 2-5. Large size clinker pieces are crushed by a clinker breaker before being transported to a clinker stockpile. The raw materials clinker and gypsum are stored separately from where they are transported to the respective hoppers to the cement mill. They are blended before being fed to the mill. Table 2-5: Proposed PPC Riebeeck production rate (tonnes per annum)

Product Current Production Rate Proposed Production Rate Clinker 570 000 800 000 Portland Cement 663 000 930 000



2.3.2. Process Technology Alternatives The process alternatives which were considered as part of the upgrade, include pre-heater, mill (raw and coal mills) and abatement technology alternatives (kiln, raw mill, clinker cooler and coal mill). The possible technology alternatives are summarised in Table 2-6. Carbon and Energy Africa was appointed by Aurecon to perform an overall technical environmental evaluation of the technology alternatives. The proposed technologies were interrogated in terms of its potential positive and negative effect on the environment, which included energy (electricity, coal) use, Green House Gases (GHG) emissions, embodied energy (the total amount of energy required to produce a product or material), height of pre-heater structure, water use and dust emissions. Table 2-6: Possible technology alternatives

Process Alternatives Pre-heater alternatives 5–stage pre-heater 6–stage pre-heater Pre-heater structure Concrete 5/6–stage pre-heater Steel 5/6–stage pre-heater Coal mill Horizontal ball mill Vertical roller mill Air Emission Abatement Technology- raw milling and cement milling circuits

Electrostatic precipitators (ESPs)

Bag filters

Air Emission Abatement Technology- clinker cooler exhaust gas cleaning

Electrostatic precipitator (ESP) Bag filter

Milling options Upgrade one raw mill in conjunction with running the old raw mill and install a roller press in the front of the mill.

Upgrade both raw mills and install a roller press in the front of the mill.

In accordance with Carbon and Energy Africa‟s study findings of best available technology, the following process alternatives were included and assessed:

• Five-stage pre-heater; • Bag filtration for the removal of particulates (kiln, raw and cement mills); • ESP for clinker cooler exhaust gases • Vertical roller mills for coal milling; • Roller press technology for the raw mill ; and • Steel or concrete structure for the pre-heater tower.

2.3.3. Proposed Limestone Mining Limestone would be obtained from the existing pit (Figure 2-5). The existing limestone pit would be deepened to 80 m amsl and extended in diameter towards the existing plant. The pit area would measure 128.5 ha. Approximately 85% of the limestone required over 30



years would be mined from the northern portion (82.4 ha) with the remaining 15% of the material sourced from the southern portion. Approximately 6 000 000 tonne of high grade limestone would be sourced from the southern half of the current pit. Mining would thus occur concurrently from the north and south over at least a 30 year period and would therefore not allow for any backfilling of overburden into the pit without sterilising large amounts of limestone resource.

Figure 2-5: Proposed extent of limestone mining

2.3.1. Proposed Overburden Dumping From 2011 to 2040, PPC intend to mine approximately 30 000 000 tonne of limestone which would result in the generation of approximately 60 000 000 tonne of overburden. The three most suitable sites include the Delectus berm, South dump and the Vlakkerug overburden dump, as shown in Figure 2-6.



Figure 2-6: Proposed overburden dump sites

It is proposed that dumping will take place concurrently on all three dump areas. Within these three locations various options for dumping between the sites were considered. The main variations in the dump design and timing are related to the Vlakkerug overburden dump. The three options include:

1. Vlakkerug dumping V1 alternative: This option involves two phases, namely: a. Phase 1: The current overburden dump would be expanded to the south to

accommodate 18 000 000 tonne of overburden and would be constructed to a height of 240 m amsl

b. Phase 2: Initially dumping overburden on the outer perimeter of the dump footprint (on the north-eastern side of PPC‟s property) and then disposing of overburden inwards (in a westerly direction) towards the current/ existing overburden dump. A total of 42 000 000 tonne of overburden would be used to construct a 180 m amsl dump which would be profiled to a 1:7 gradient on the eastern and southern sides to enable long term stability and crop cultivation.

2. Vlakkerug dumping V2 alternative: 55 000 000 tonne of overburden would be dumped onto the existing overburden dump which would be developed to the south east and would reach an elevation of 260m amsl.



3. Vlakkerug dumping V3 alternative: The current overburden dump would be developed to the south east to an elevation of 260m amsl. The dump would accommodate 60 000 000 tonne of overburden.

Concurrent rehabilitation would be undertaken on the overburden dumps. Where possible overburden would be dumped on the surface, forming an outside berm that is rehabilitated to screen the potential dust impacts associated with waste-rock tipping. The overburden dumps would then be in-filled and rehabilitated at various phases during the mining process.

2.3.2. Construction and Commissioning The construction phase will be undertaken over a period of approximately 27 months. The construction period would be divided into the various phases, namely

• earthworks and foundations, • civil and structural work, • erection and installation of mechanical equipment, and finally, • erection and installation of electrical equipment.

The existing cement manufacturing plant will continue to operate until such time as the new equipment has been fully installed. The existing plant would have to be shut-down prior to commissioning the new kiln line. As a result, there would be no overlap period during which the three kilns would operate simultaneously. The commissioning period covers, two specific stages:

• “cold commissioning”. During the cold commissioning phase all equipment is firstly checked individually with all its interlocks, following which plant sections are tested in sequence, and all the process interlocks are checked for correct operation.

• “hot commissioning”. Fuel in the form of diesel followed by coal is introduced to dry out the refractory material in the kiln. This is following by feeding raw material into the equipment. Plant sections not requiring heating up are started up and fed with raw materials.

It is anticipated that from the start of commissioning it would take PPC a maximum of 6 months for the new cement manufacturing facility to achieve full production. When stable operation is achieved, performance testing is carried out to ensure that all equipment performs as required, which includes the measurement of output, efficiencies, emission levels, etc.

2.3.1. Decommissioning Existing plant infrastructure that will be replaced will be decommissioned and removed off-site. PPC have indicated that the decommissioning phase would last approximately 8 months



which is anticipated to occur from month 19 of the construction period once the new equipment is being commissioned. As a result, the decommissioning of Kiln 1 and 2, would have to take place before the new kiln line is commissioned. The existing two kilns would then be dismantled and sold for scrap.



3. POLLUTION HEALTH IMPACTS In addressing the impact of air pollution emanating from the PPC facility, some background on the health effects of the various pollutants need to be provided. Since the terms of reference exclude a detailed toxicological study, this discussion is limited to the most important health impact aspects of each pollutant. The concentration levels cited in this section should not be confused with the standards given in the next section. Although standards are generally based on human health impacts, they often include other factors, such as the economic feasibility of achieving health limit values. The discussion below is limited to the primary pollutants. The quantification and impact of secondary pollutants, such as ozone, were beyond the scope of this investigation. This does not exclude the importance of secondary pollutants, but these are not expected to be significant in the context of this operation.

3.1. Carbon Monoxide (CO) Carbon Monoxide (CO) is found in vehicle exhaust and is formed as a result of incomplete combustion of the fuel. It is an odourless gas that has no direct effect on the lungs. Instead, CO interferes with the oxygen carrying capacity of blood and weakens the contraction of the heart. Its actions reduce the volume of blood and oxygen delivered to various parts of the body. In a healthy person, CO can significantly reduce the ability to perform physical activities. In persons with chronic heart conditions, this effect can be life threatening. Adverse effects have been observed in individuals with heart conditions who are exposed to areas of heavy CO concentration, such as heavy traffic conditions. Exposure to CO has also been associated with increased incidence of heart failure among the elderly. The guideline values, and periods of time-weighted average exposures, have been determined in such a way that the carboxyhaemoglobin (COHb) level of 2.5% is not exceeded, even when a normal subject engages in light or moderate exercise. The guideline values for CO are 100 mg/m³ for 15 minutes, 60 mg/m³ for 30 minutes, 30 mg/m³ for 1 hour, and 10 mg/m³ for 8 hours (WHO 2000). A higher level of uptake impairs perception and thinking, slows reflexes, and may cause drowsiness, angina, unconsciousness, or death. An exposure to concentrations of 45 mg/m³ for more than two hours adversely affects a person’s ability to make judgements. Two to four hours of exposure at 200 mg/m³ raises the COHb level in the blood to 10-30 % and increases the possibility of headaches. Exposure to 1 000 mg/m³ raises the COHb level in the blood to 30 % and causes a rapid increase in pulse rate leading to coma and convulsions. One to two hours of exposure at 1 830 mg/m³ results in 40 % COHb in blood, which may cause death (MARC 1991).

3.2. Nitrogen Oxides Nitrogen oxide (NO) is one of the primary pollutants emitted by internal combustion engines (vehicle exhausts). Nitrogen dioxide (NO2) is formed through oxidation of these oxides once



released in the air. NOx is also a source of some of the particulate matter found in urban air: Airborne particles derived from NOx emissions react in the atmosphere to form various nitrogen-containing compounds, some of which may cause mutation. Examples of NOx-related particulate products thought to contribute to increased mutagenicity include the nitrate radical, peroxyacetyl nitrates, nitroarenes, and nitrosamines. NO2 is an irritating gas that is absorbed into the mucous membrane of the respiratory tract. The upper airways are less affected because NO2 is not very soluble in aqueous surfaces. Exposure to NO2 is linked with increased susceptibility to respiratory infection, increased airway resistance in asthmatics and decreased pulmonary function. Available data from animal toxicology experiments indicate that acute exposure to NO2 concentrations of less than 1 880 µg/m³ (1 ppm) rarely produces observable effects (WHO 2000). Normal healthy humans, exposed at rest or with light exercise for less than two hours to concentrations above 4 700 µg/m³ (2.5 ppm), experience pronounced decreases in pulmonary function; generally, normal subjects are not affected by concentrations less than 1 880 µg/m³ (1.0 ppm). The standards and guidelines of most countries and organisations are given exclusively for NO2 concentrations.

3.3. Sulphur Dioxide Sulphur dioxide (SO2) is formed when the sulphur in fossil fuels combines with oxygen at high temperature. SO2 is an irritant that is absorbed in the nose and aqueous surfaces of the upper respiratory tract, and is associated with reduced lung function and increased risk of mortality and morbidity. Adverse health effects of SO2 include coughing, phlegm, chest discomfort and bronchitis. All asthmatics are especially sensitive to the effects of sulphur dioxide. A wide range of sensitivity has been demonstrated, both among normal subjects and among those with asthma due to short-term exposures (less than 24 hours). Continuous exposure-response relationships, without any clearly defined threshold, are evident. At low levels of exposure (mean annual levels below 50 µg/m³; daily levels usually not exceeding 125 µg/m³) increased effects on mortality (total, cardiovascular and respiratory) and on hospital emergency admissions for total respiratory causes and chronic obstructive pulmonary disease (COPD), have been consistently demonstrated. Based upon controlled studies with asthmatics exposed to SO2 for short periods, the WHO (WHO 2000) recommends that a value of 500 µg/m³ (0.175 ppm) should not be exceeded over averaging periods of 10 minutes. Day-to-day changes in mortality, morbidity, or lung function led to a previous guideline 24-hour average value of 125 µg/m³ (0.04 ppm) for SO2. Similarly an annual exposure level of 50 µg/m³ has been suggested. However, at very high levels of exposure, it can cause lung edema (fluid accumulation), lung tissue damage, and sloughing off of cells lining the respiratory tract. Some population-based studies indicate that human health effects associated with fine particles show a similar association with ambient SO2 levels.



It is important to note that the WHO air quality guidelines (AQGs) published in 2000 for sulphur dioxide have recently been revised (WHO, 2005). Although the 10-minute AQG of 500 µg/m³ has remained unchanged, the previously published daily guideline has been significantly reduced from 125 µg/m³ to 20 µg/m³. The previous daily guideline was based on epidemiological studies. WHO (2005) makes reference to more recent evidence, which suggests the occurrence of health risks at lower concentrations. Although WHO (2005) acknowledges the considerable uncertainty as to whether sulphur dioxide is the pollutant responsible for the observed adverse effects (may be due to ultra-fine particles or other correlated substances), it took the decision to publish a stringent daily guideline in line with the precautionary principle. The WHO (2005) stipulates an annual guideline is not needed for the protection of human health, since compliance with the 24-hour level will assure sufficiently lower levels for the annual average. Given that the 24-hour WHO AQG of 20 µg/m³ is anticipated to be difficult for some countries to achieve in the short term, the WHO (2005) recommends a stepped approach using interim goals as shown in Table 3-1. Table 3-1: WHO air quality guidelines and interim guidelines for sulphur dioxide (WHO, 2005)

24-hour Average Sulphur Dioxide (µg/m³)

10-minute Average Sulphur Dioxide (µg/m³)

WHO interim target-1 (IT-1) (2000 AQF level) 125

WHO interim target-2 (IT-2) 50(a)

WHO Air Quality Guideline (AQG) 20 500

(a) Intermediate goal based on controlling either (i) motor vehicle (ii) industrial emissions and/or (iii) power production; this would be a reasonable and feasible goal to be achieved within a few years for some developing countries and lead to significant health improvements that would justify further improvements (such as aiming for the guideline).

3.4. Hydrogen Chloride

Hydrogen chloride is corrosive to the eyes, skin, and mucous membranes. Acute (short-term) inhalation exposure may cause coughing, hoarseness, inflammation and ulceration of the respiratory tract, chest pain, and pulmonary oedema in humans. Acute oral exposure may cause corrosion of the mucous membranes, oesophagus, and stomach, with nausea, vomiting, and diarrhoea reported. Dermal contact may produce severe burns, ulceration, and scarring. Chronic occupational exposure to hydrochloric acid has been reported to cause gastritis, chronic bronchitis, dermatitis, and photosensitization in workers. Prolonged exposure to low concentrations may also cause dental discolouration and erosion. No information is available on the reproductive or developmental effects of hydrochloric acid in humans. In rats exposed to hydrochloric acid by inhalation, severe dyspnoea, cyanosis, and altered oestrus cycles have been reported in dams, and increased foetal mortality and decreased foetal weight have been reported in the offspring. Similarly no information is available on the carcinogenic effects of hydrochloric acid in humans. In one study, no



carcinogenic response was observed in rats exposed via inhalation. The US EPA has not classified hydrogen chloride with respect to potential carcinogenicity.

The Reference Concentration (RfC)1 for hydrogen chloride is 20 µg/m3 for chronic exposure. The U.S. Environmental Protection Agency (EPA) estimates that inhalation of this concentration or less over a lifetime would not likely result in the occurrence of chronic effects. The California Office of Environmental Health Hazard Assessment (OEHHA) provides a screening level of 2 100 µg/m³ and 9 µg/m³ for acute (1 hr) and chronic exposure respectively. WHO have recommended an odour threshold value of 100 µg/m³

3.5. Arsenic Arsenic occurs naturally in soil and minerals and therefore it may enter the air, water, and land from wind-blown dust and may get into water from runoff and leaching. From both the biological and the toxicological points of view, arsenic compounds can be classified into three major groups: inorganic arsenic compounds; organic arsenic compounds; and arsine gas. The most common trivalent inorganic arsenic compounds are arsenic trioxide, sodium arsenite and arsenic trichloride. Pentavalent inorganic compounds include arsenic pentoxide, arsenic acid and arsenates, e.g. lead arsenate and calcium arsenate. Common organic arsenic compounds are arsanilic acid, methylarsonic acid, dimethylarsinic acid (cacodylic acid) and arsenobetaine (WHO, 2000). Arsenic released from combustion processes is usually attached to the emitted particulates and present mainly as inorganic arsenic. The major routes of arsenic absorption in the general population are ingestion and inhalation. Particulate arsenic compounds may be inhaled, deposited in the respiratory tract and absorbed into the blood. Inhalation of arsenic from ambient air is usually a minor exposure route for the general population. Assuming a breathing rate of 20 m3/day, the estimated daily intake may amount to about 20–200 nanogram in rural areas and 400–600 nanogram in cities without substantial industrial emission of arsenic (WHO 2000). Inhalation of high levels of inorganic arsenic is likely to result in a sore throat and irritated lungs. This may also result in the darkening of the skin and the appearance of small "corns" or "warts" on the palms, soles, and torso. A small number of the corns may ultimately develop into skin cancer. The exposure level that produces these effects is uncertain, but it is probably above 100 micrograms of arsenic per cubic meter (µg/m3) for a brief exposure. Longer exposure at lower concentrations can lead to skin effects, and also to circulatory and peripheral nervous disorders. Some data suggest that inhalation of inorganic arsenic may

1 The RfC is an estimate (with uncertainty spanning perhaps an order of magnitude) of a daily inhalation exposure of the human population (including sensitive subgroups) that is likely to be without an appreciable risk of deleterious effects during a lifetime. Inhalation RfCs were derived according to the Interim Methods for Development of Inhalation Reference Doses (U.S. EPA, 1994). RfCs can also be derived for the non-carcinogenic health effects of substances that are carcinogens. The RfC is not a direct estimator of risk but rather a reference point to gauge the potential effects. Exceedance of the RfC does not imply that an adverse health effect would necessarily occur. As the amount and frequency of exposures exceeding the RfC increase, the probability of adverse health effects also increases.



also interfere with normal fetal development, although this is not certain. An important concern is the ability of inhaled inorganic arsenic to increase the risk of lung cancer. This has been seen mostly in workers exposed to arsenic at smelters, mines, and chemical factories, but also in residents living near smelters and arsenical chemical factories. People who live near waste sites with arsenic may also have an increased risk of lung cancer (ASTD, 2003). There is some information suggesting that children may be less efficient at converting inorganic arsenic to the less harmful organic forms. For this reason, children may be more susceptible to health effects from inorganic arsenic than adults (ASTD, 2003). The US EPA’s unit inhalation cancer risk factor (the risk corresponding to lifetime exposure to 1 µg/m3) is 4.3x10-3 (µg/m³)-1, which is slightly higher than the WHO inhalation cancer risk factor of 4.3x10-3 (µg/m³)-1. The annual average air concentration at the position of maximum exposure corresponding with a cancer risk of one in a hundred thousand is therefore 0.002 µg/m3.

3.6. Cadmium Cadmium can enter the air from the burning of fossil fuels (e.g., coal fired electrical plants) and from the burning of household waste. The pattern of cadmium uses has changed in recent years. In the past cadmium was mainly used in the electroplating of metals and in pigments or stabilizers for plastics. In 1960, the engineering coatings and plating sector accounted for over half the cadmium consumed worldwide, but in 1990 this had declined to less than 8%. Nowadays, cadmium-nickel battery manufacture consumes 55% of the cadmium output and it is expected that this application will expand with the increasing use of rechargeable batteries and their potential use for electric vehicles. Food and cigarette smoke are the biggest sources of cadmium exposure for people in the general population. Smokers may double their daily intake of cadmium compared with non-smokers. Each cigarette may contain from 1 to 2 µg of cadmium, and 40-60% of the cadmium in the inhaled smoke can pass through the lungs into the body. This means that smokers may take in an additional 1-3 µg of cadmium into their body per day from each pack of cigarettes smoked (ASTD, 2003). The relationship between occupational exposure to cadmium and increased risk of cancer (specifically lung and prostate cancer) has been explored in a number of epidemiologic studies. For inhalation exposures, the results of epidemiology studies that evaluated cadmium’s effects on increased lung cancer are conflicting. Many of the studies had inadequate controls for confounding factors such as co-exposure with other metal carcinogens and smoking, and there are only a small number of lung cancer mortality cases in the only U.S. cohort studied. Overall, however, the results provide little evidence of an increased risk of lung cancer in humans following prolonged inhalation exposure to cadmium (ASTD, 2003). The controversy about the adequacy of the human cancer data for cadmium is reflected in the cancer classifications from different agencies. The Environmental Protection Agency EPA has classified cadmium as a probable human carcinogen by inhalation (Group Bl), based on its assessment of limited evidence of an increase in lung



cancer in humans (Thun et al. 1985) and sufficient evidence of lung cancer in rats (IRIS 1996; Takenaka et al. 1983). EPA has calculated an inhalation unit risk of 1.8x10-3 µg/m³ (IRIS 1996). The International Agency for Research on Cancer (IARC) has classified cadmium as carcinogenic to humans (Group 1) based on an assessment of sufficient evidence for carcinogenicity in both human and animal studies (IARC 1993). Using the US EPA’s cancer risk factor, the annual average air concentration at the position of maximum exposure corresponding with a cancer risk of one in a hundred thousand is therefore 0.0056 µg/m3.

3.7. Lead Lead is removed from the atmosphere by dry or wet deposition. The residence time of lead containing particles in the atmosphere varies according to a number of factors, such as particle size, wind currents, rainfall and height of emission. Soil and water pollution from from the emissions of industrial sources is limited mainly to the immediate vicinity. However, strong evidence indicates that a fraction of airborne lead is transported over long distances. As a result, a long-term global accumulation of lead has occurred in recent decades. This has been demonstrated convincingly by analyses of glacial ice and snow deposits in remote areas, such as the Greenland ice cap, until about 1960; however, subsequent measurements revealed a marked downward trend in the same glacial strata, corresponding to the global fall in the use of alkyl lead additives in petrol (WHO, 2000). Shortly after lead gets into the body, it travels in the blood to the "soft tissues" (such as the liver, kidneys, lungs, brain, spleen, muscles, and heart). After several weeks, most of the lead moves into the bones and teeth. In adults, about 94% of the total amount of lead in the body is contained in the bones and teeth. About 73% of the lead in children’s bodies is stored in their bones. Some of the lead can stay in bones for decades; however, some lead can leave the bones and re-enter blood and organs under certain circumstances, for example, during pregnancy and periods of breast feeding, after a bone is broken, and during advancing age (ASTD, 2003). The effects of lead are the same whether it enters the body through breathing or swallowing. The main target for lead toxicity is the nervous system, both in adults and in children. Long-term exposure of adults to lead at work has resulted in decreased performance in some tests that measure functions of the nervous system. Lead exposure may also cause weakness in fingers, wrists, or ankles. Lead exposure may also cause anemia. At high levels of exposure, lead can severely damage the brain and kidneys in adults or children. In pregnant women, high levels of exposure to lead may cause miscarriage. High-level exposure in men can damage the organs responsible for sperm production (ASTD, 2003). For this group the contribution of air lead to blood lead by way of inhalation alone underestimates the contribution of environmental lead to blood lead, as air lead can only be taken as a general indicator of lead pollution. Because of the behavioural characteristics of preschool children, outdoor lead deposition is the most important single explanation of differences between inner city and suburban areas in the blood lead of children. Lead in dust can make a substantial contribution to absorbed lead in small children, sometimes up to 80%



of the total amount. Since the placenta is no effective biological barrier, pregnant women represent a second group at increased risk because of exposure of the fetus to lead (WHO, 2000). The World Health Organisation provides an annual average lead concentration guideline of 0.5 µg/m³.

3.8. Mercury Mercury occurs naturally in the environment and exists in several forms. These forms can be organised under three headings: metallic mercury (also known as elemental mercury), inorganic mercury, and organic mercury. In humans, inhalation is a rapid route for mercury vapour intake. Mercury vapour is highly lipophilic and may readily cross the pulmonary air to blood barrier into the systemic circulation. The body burden of mercury is distributed between three main compartments; namely, blood, brain and kidneys (Roach, 1992b), but mercury is distributed to all tissues of the body. The highest levels of mercury are eventually found in the kidney, but accumulation also occurs in the cells of the mucous membranes of the gastrointestinal tract. Mercury vapour can readily penetrate the placental and blood-brain barrier and will be retained in the brain for a long time. Inorganic mercury compounds cross these barriers only slightly, but organic mercury compounds readily cross these barriers and have a high affinity for the brain following ingestion exposure in humans (Hrudey et al., 1996 and WHO, 1987). Mercury vapour, inorganic mercury salts and organic (alkyl or phenyl) mercury compounds that are chronically inhaled affect the central and peripheral nervous systems. The earliest sign of mercurialism is a characteristic tremor. Other symptoms are irritability and, in severe cases, depression, insomnia, hallucinations, delusions and mania. Ingestion of mercuric compounds may lead to gastro-intestinal and kidney damage. Chronic exposure over long time periods may cause permanent damage to the brain, kidney and developing foetus (Hrudey al. 1996 and Roach, 1992a). After exposure to mercury vapour the nervous system is the main target, but, depending on the dose, the oral mucosa and kidneys might also be affected. Short-term inhalation exposure to mercury vapour (in concentrations of 1.2 to 8.5 mg/m³) may cause headaches, cough, chest pains, chest tightness and difficulty in breathing. It may also cause chemical pneumonitis, soreness of the mouth, loss of teeth, nausea and diarrhoea. Long-term exposure to mercury concentrations in air at 100 µg/m3 or higher may lead to mercurialism, characterised by symptoms such as gingivitis (sore and swollen gums), hypersalivation and metal taste in the mouth. Conflicting epidemiological studies were published regarding a correlation between mercury exposure and an increased incidence of lung cancer mortalities. All of the studies have limitations and increased cancer rates could be attributable to other concurrent exposures or lifestyle factors. Data concerning genotoxic effects are of an equally equivocal nature (IRIS, 2001). IARC (1993) has classified elemental mercury as "unclassifiable as to carcinogenicity to humans" (Group 3). The US EPA Reference Concentration (RfC) for mercury is 0.3 µg/m3 for chronic exposure.



The approach of the WHO was to use the lowest-observed-effect-levels for the mildest adverse effect (proteinuria). The LOAEL was adjusted for continued exposure and a protection factor of 20 applied. Inorganic mercury compounds were estimated to be retained in the lungs about half as efficiently as inhaled mercury vapour, therefore the estimated guideline would be twice that of mercury vapour. The contribution of methylmercury to human intake by inhalation was considered negligible and guidelines were not given for this compound in ambient air (WHO, 1987). The annual guidelines arrived at are given below: Health endpoint : Proteinuria in exposed workers Ambient air quality guideline for mercury vapour : 1 µg/m³ Ambient air quality guideline for inorganic mercury : 2 µg/m³

(Source: WHO, 1987) The guideline for inorganic mercury was later adjusted to an annual average of 1 µg/m³ based on a lowest-observed-adverse-effect-level of 0.020 mg/m³ for renal tubular effects in humans (WHO, 2000). It is noted that the major pathway for mercury exposures is ingestion rather than inhalation. For this reason reference is made to the Department of Environmental Affairs and Tourism (DEAT) mercury guideline which was intended to be protective given multiple pathways of exposure. This guideline value (given as 0.04 µg/m³ for chronic exposures) was derived during a study initiated by DEAT (2001). This study included health-risk based research relating to human exposure to mercury and engineering reviews of treatment and disposal options for mercury waste. The purpose of such studies was twofold: (i) to support the drafting of national regulations for mercury waste disposal; and (ii) to provide specific guidance on how best to deal with the mercury waste stockpiled at the Thor Chemical's plant at Cato Ridge, Kwazulu-Natal. The health risk study determined that ambient long-term concentrations of mercury of lower than 0.04 µg/m³ would not result in unacceptable multi-pathway risk given local environments. This guidance is currently being used by the DEAT to assess the acceptability of mercury waste treatment and disposal options.

3.9. Particulate Matter Particulate matter (PM) from mining activities may either be produced directly from dust generation or fuel combustion, especially by diesel-fuelled vehicles (in the form of soot), or formed in the atmosphere through chemical interactions of combustion by-products. PM is also a result of dust from various activities, passing vehicles, and also friction from components such as tires, brakes, etc. The impact of particles on human health is largely depended on (i) particle characteristics, particularly particle size and chemical composition, and (ii) the duration, frequency and magnitude of exposure. The potential of particles to be inhaled and deposited in the lung is a function of the aerodynamic characteristics of particles in flow streams. The aerodynamic properties of particles are related to their size, shape and density. The deposition of particles in different regions of the respiratory system depends on their size.



The nasal openings permit very large dust particles to enter the nasal region, along with much finer airborne particulates. Larger particles are deposited in the nasal region by impaction on the hairs of the nose or at the bends of the nasal passages. Smaller particles (PM10) pass through the nasal region and are deposited in the tracheobronchial and pulmonary regions. Particles are removed by impacting with the wall of the bronchi when they are unable to follow the gaseous streamline flow through subsequent bifurcations of the bronchial tree. As the airflow decreases near the terminal bronchi, the smallest particles are removed by Brownian motion, which pushes them to the alveolar membrane (CEPA/FPAC Working Group, 1998; Dockery and Pope, 1994). Air quality guidelines for particulates are given for various particle size fractions, including total suspended particulates (TSP), inhalable particulates or PM10 (i.e. particulates with an aerodynamic diameter of less than 10 µm), and respirable particulates of PM2.5 (i.e. particulates with an aerodynamic diameter of less than 2.5 µm). Although TSP is defined as all particulates with an aerodynamic diameter of less than 100 µm, and effective upper limit of 30 µm aerodynamic diameter is frequently assigned. PM10 and PM2.5 are of concern due to their health impact potentials. As indicated previously, such fine particles are able to be deposited in, and damaging to, the lower airways and gas-exchanging portions of the lung. During the 1990s the World Health Organisation (WHO) stated that no safe thresholds could be determined for particulate exposures and responded by publishing linear dose-response relationships for PM10 and PM2.5 concentrations (WHO, 2005). This approach was not well accepted by air quality managers and policy makers. As a result the WHO Working Group of Air Quality Guidelines recommended that the updated WHO air quality guideline document contain guidelines that define concentrations which, if achieved, would be expected to result in significantly reduced rates of adverse health effects. These guidelines would provide air quality managers and policy makers with an explicit objective when they were tasked with setting national air quality standards. In a review of various epidemiological studies the Canadian Environmental Protection Agency (CEPA) could find no evidence of a threshold in the relationship between particulate concentrations and adverse human health effects, with estimates of mortality and morbidity increasing with increasing concentrations. As for the relationship expressed by the WHO, the lack of an apparent threshold suggests that it is problematic to select a level at which no adverse effects would be expected to occur as a result of exposure to particulate matter. The relative risk for PM10 was given by the CEPA as varying between 0.4% and 1.7% per 10 µg/m3 increases, with an un-weighted mean of 0.8% and a weighted mean of 0.5% per 10 µg/m3 increases (CEPA/FPAC Working Group, 1998). As a result the WHO Working Group of Air Quality Guidelines recommended that the updated WHO air quality guideline document contain guidelines that define concentrations which, if achieved, would be expected to result in significantly reduced rates of adverse health effects. These guidelines would provide air quality managers and policy makers with an explicit objective when they were tasked with setting national air quality standards. Given that air pollution levels in developing countries frequently far exceed the recommended WHO air quality guidelines (AQGs), the Working Group also proposed interim targets (IT) levels, in



excess of the WHO AQGs themselves, to promote steady progress towards meeting the WHO AQGs (WHO, 2005). The air quality guidelines and interim targets issued by the WHO in 2005 for particulate matter are given in Table 3-2 and Table 3-3. Table 3-2: WHO air quality guideline and interim targets for particulate matter (annual mean) (WHO, 2005)

Annual Mean Level PM10 (µg/m³)

PM2.5 (µg/m³) Basis for the selected level

WHO interim target-1 (IT-1) 70 35 These levels were estimated to be associated with about 15% higher long-term mortality than at AQG

WHO interim target-2 (IT-2) 50 25 In addition to other health benefits, these levels lower risk of premature mortality by approximately 6% (2-11%) compared to WHO-IT1

WHO interim target-3 (IT-3) 30 15 In addition to other health benefits, these levels reduce mortality risks by another approximately 6% (2-11%) compared to WHO-IT2 levels.

WHO Air Quality Guideline (AQG) 20 10

These are the lowest levels at which total, cardiopulmonary and lung cancer mortality have been shown to increase with more than 95% confidence in response to PM2.5 in the American Cancer Society (ACS) study (Pope et al., 2002 as cited in WHO 2005). The use of the PM2.5 guideline is preferred.

Table 3-3: WHO air quality guideline and interim targets for particulate matter (daily mean) (WHO, 2005)

Daily Mean Level PM10 (µg/m³)

PM2.5 (µg/m³) Basis for the selected level

WHO interim target-1 (IT-1) 150 75 Based on published risk coefficients from multi-centre studies and meta-analyses (about 5% increase of short-term mortality over AQG)

WHO interim target-2 (IT-2)* 100 50 Based on published risk coefficients from multi-centre studies and meta-analyses (about 2.5% increase of short-term mortality over AQG)

WHO interim target-3 (IT-3)** 75 37.5 Based on published risk coefficients from multi-centre studies and meta-analyses (about 1.2% increase of short-term mortality over AQG)

WHO Air Quality Guideline (AQG) 50 25 Based on relation between 24-hour and annual

levels * 99th percentile (3 days/year) ** for management purposes, based on annual average guideline values; precise number to be determined

on basis of local frequency distribution of daily means

3.10. Diesel Particulate Matter Diesel exhaust particulate matter consists of a solid core composed mainly of carbon, a soluble organic fraction, sulphates, and trace elements. The size distribution of diesel particles ranges from 0.1 to 1.0 μm (National Research Council, 1982). When a particle is



less than 1 micron (μm) in diameter it is small enough to be inhaled deeply into the lungs. From an acute exposure standpoint, diesel emissions are considered to be an irritant to the respiratory system, given sufficient episodic exposure and may cause a variety of inflammation-related symptoms (e.g. headache, eye discomfort, asthma-like reactions, nausea, etc.) depending on individual susceptibility to the diesel emission constituents. The primary chronic health concerns include non-malignant respiratory effects and lung carcinogenicity. An USA EPA human chronic exposure level without appreciable hazard (i.e., inhalation Reference Concentration, RfC) of 5 µg/m³ has been suggested (EPA 2003). This level was obtained from adverse non-cancer respiratory effects and is based on pulmonary inflammation and histopathology. Many of the organic compounds present on the diesel particles and in the gases, though in small quantities, are mutagenic and/or carcinogenic in their own right. Preliminary results indicate that diesel emissions show a pattern of statistically increased lung cancer in more than 20 (EPA 1999). In a study conducted by the US EPA the carcinogenicity of diesel particulate matter was assessed and unit risk estimates were estimated (EPA 1993). In other words, the EPA estimates that, if an individual were to breathe air containing diesel particulate matter at 0.0588 µg/m³, over his or her entire lifetime, that person would theoretically have no more than a one-in-a-million increased chance of developing cancer as a direct result of breathing air containing this chemical.

3.11. Benzene Benzene is a clear, colourless, aromatic hydrocarbon that is both volatile and flammable. Benzene is present in the exhausts of combustion sources (e.g. cement kiln, boilers, motor vehicles) and evaporative emissions (e.g. petrol and solvent storage tanks, motor vehicles). Benzene is quite stable in the atmosphere. The only benzene reaction, which is important in the lower atmosphere, is the reaction with hydroxy radicals. Yet even this reaction is relatively slow. The products of this reaction are primarily phenols and aldehydes, which react quickly and also, are removed by incorporation into rain. About 50% of inhaled benzene is absorbed (Onursal 1997). Part of the absorbed benzene is exhaled by respiration and eliminated through the urinary tract. Benzene maintained in the human body is concentrated in the fat tissue and bone marrow. Long-term exposure to high levels of benzene in air has been shown to cause cancer of the tissues that form white blood cells (leukaemia), based on epidemiological studies with workers. Leukaemia and lymphomas, as well as other tumour types, have been observed in experimental animals that have been exposed to benzene by inhalation or oral administration. Exposure to benzene has also been linked with genetic changes in humans and animals. Based on this evidence, the US EPA has concluded that benzene is a Group A, known human carcinogen. The International Agency for Research on Cancer (IARC) has also classified benzene as a human carcinogen (Group 1). The US-EPA calculated a cancer inhalation Unit Risk factor for benzene of 8.3x10-6 per μg/m³ based on the results of three epidemiological studies in benzene-exposed workers in which an increase of death due to nonlymphocytic leukaemia was observed (range of 2.2x10-6 per μg/m³ to 8.3x10-6 per μg/m³. The WHO provides a unit risk range between 4.4x10-6 per μg/m³ and 7.5x10-6 per μg/m³ (WHO 2000).



The US EPA therefore estimates that, if an individual were to breathe air, containing benzene at 0.12 µg/m³, over his or her entire lifetime, that person would theoretically have no more than a one-in-a-million increased chance of developing cancer as a direct result of breathing air containing this chemical. A number of adverse non-cancer health effects have also been associated with exposure to benzene. Benzene is known to cause disorders of the blood. People with long-term exposure to benzene at levels that generally exceed 50 ppm (162 500 μg/m³) may experience harmful effects on the blood-forming tissues, especially the bone marrow. These effects can disrupt normal blood production and cause a decrease in important blood components, such as red blood cells and blood platelets, leading to anaemia and a reduced ability to clot. Exposure to benzene at comparable or even lower levels can be harmful to the immune system, increasing the chance for infection and perhaps lowering the body's defence against tumours by altering the number and function of the body's white blood cells. In studies using animals, inhalation exposure to benzene may also indicate that it is a developmental and reproductive toxicant. Studies with pregnant animals show that breathing 10-300 ppm (32 500-975 000 μg/m³) of benzene has adverse effects on the developing foetus, including low birth weight, delayed bone formation, and bone marrow damage.

3.12. Formaldehyde Formaldehyde is a colourless gas at normal temperatures and is the simplest member of the family of aldehydes. Formaldehyde and acetaldehyde are the most prevalent aldehydes in combustion emissions and is formed from incomplete combustion of the fuel. Formaldehyde would also be released in processes were it is used as part of a resin, such as urea- and phenol formaldehyde. Other common sources of exposure include vehicle emissions, particleboard and similar building materials, carpets, paints and varnishes, foods and cooking, tobacco smoke, and the use of formaldehyde as a disinfectant. Aldehydes are absorbed in the respiratory and gastrointestinal tracts and metabolised. Once they are metabolised, they are excreted from the human body. Based on available exposure data (EPA 1993), maximum microenvironment exposure levels range from 4.9 μg/m³ from exhaust exposure at a service station to 41.8 μg/m³ from parking garage exposure. Formaldehyde is a known human irritant for the eyes, nose, and upper respiratory system at acute exposure levels as low as 62 μg/m³, although levels below this are not necessarily free from risk. Studies in experimental animals provide sufficient evidence that long-term inhalation exposure to formaldehyde causes an increase in the incidence of squamous cell carcinomas of the nasal cavity. Epidemiological exposure studies suggest that long-term inhalation of formaldehyde may be associated with tumours of the nasopharyngeal cavity, nasal cavity, and sinus. Based on this information, the US EPA has classified formaldehyde as a Group B1, probable human carcinogen. In the most recent review by the International Agency for Research on Cancer (IARC), twenty-six scientists from ten countries met in June 2004 to assess the carcinogenic hazard to humans of. The IARC concurs that formaldehyde is carcinogenic to humans (Group 1), on the basis of sufficient evidence in humans and sufficient evidence in experimental animals— this is a higher classification than previous IARC evaluations.



The US EPA calculated the present, and still official, cancer unit risk factor of 1.3x10-5 per μg/m³ for formaldehyde based on the results of a study in rats in which an increase in the incidence of nasal tumours was observed. Please note that the cancer unit risk estimate for formaldehyde is based on animal data and is considered an upper bound estimate for human risk. True human cancer risk may be as low as zero. Noncancer adverse health effects associated with exposure to formaldehyde in humans include irritation of the eyes and nose (0.1-1.0 ppm or 123-1 230 μg/m³), throat (0.05-2.0 ppm or 62-2 460 μg/m³), and lower airway at low levels (5.0-30 ppm or 6 150-36 900 μg/m³). There is also suggestive, but not conclusive, evidence in humans that formaldehyde can affect immune function. Adverse effects on the liver and kidney have also been noted in experimental animals exposed to higher levels of formaldehyde. The WHO (WHO 2000) provides a non-carcinogenic health endpoint of 100 μg/m³.

3.13. 1,3 – Butadiene 1,3-Butadiene is formed in all combustion processes. It occurs in vehicle exhausts due to the incomplete combustion of the fuel and is assumed not to be present in vehicle evaporative and refuelling emissions. The percentage of 1,3-butadiene in motor vehicle exhaust varies from roughly 0.4 to 1.0 percent depending on control technology and fuel composition. Short-term inhalation exposure to high concentrations of 1.3-butadiene would in humans most likely manifest as infertility (due to reduced fertility or early deaths) or spontaneous abortions (assumptions based on studies conducted on mice). The dominant lethal responses are believed to represent a genotoxic effect. From chronic exposure studies, the most sensitive reproductive effects were ovarian atrophy in female mice and testicular atrophy in male mice. Testicular atrophy was primarily a high-exposure effect. Ovarian atrophy, on the other hand, was observed at the lowest exposure level. The Reference inhalation concentration for a daily exposure as stipulated by the US-EPA is stated as 0.002 mg/m³. This is based on ovarian atrophy. Long-term inhalation exposure to 1,3-butadiene has been shown to cause tumours in several organs in experimental animals. Studies in humans exposed to 1,3-butadiene suggest that this chemical may cause cancer. Based on the inadequate human evidence and sufficient animal evidence, the US EPA has concluded that 1,3-butadiene is a Group B2, probable human carcinogen. The current cancer inhalation unit risk factor of 3x10-5 per μg/m³ recommended for use by the US EPA is based on the results of a study in mice in which an increase in the incidence of tumours in the lung and blood vessels of the heart, as well as lymphomas were observed.

3.14. Dioxins and Furans Much of the public concern revolves around the extreme toxicity of dioxins. These compounds have been shown to be extremely potent in producing a variety of effects in experimental animals at levels hundreds or thousands of times lower than most chemicals of environmental interest. Exposure to dioxins has been linked to a variety of health effects, including among others immunotoxicity, reproductive and developmental effects, and cancer.



Dioxins have been found throughout the world in practically all media including air, soil, water, sediment, fish and shellfish, and other food products such as meat and dairy products. A large proportion of human exposure to dioxins occurs through the food chain. For dioxin-like compounds, the WHO specifies a tolerable daily intake (TDI), which has been defined in units of toxicity equivalent (TEQ)2 uptakes. The upper range of the TDI is given by the WHO as being 4 pg TEQ/kg of body weight over a 24-hour averaging period. The WHO stresses that this should be considered as a maximal tolerable intake on a provisional basis and the ultimate goal is to reduce human intake levels to below 1pg TEQ/kg bodyweight. The TDI is given by the WHO as representing a tolerable daily intake for life-time exposure. Occasional short-term excursions above the TDI are given as having "no health consequences provided that the averaged intake over long periods is not exceeded" (WHO, 2000). Assuming that all of the dioxin to which a 70 kg person is exposed is absorbed, and given an average breathing rate of 1 m3/hr, the tolerable daily intake (TDI) of the US-EPA, ATSDR and WHO could be calculated to coincide with 24-hour inhalation concentrations of the following: US-EPA - 2.0 x 10-7 µg/m3 ATSDR - 2.91 x 10-5 µg/m3 WHO - 2.91 x 10-5 to 1.17 x 10-4 µg/m3 The USEPA unit cancer risk factor for dioxins is 33 (µg TEQ/m3)-1. The annual average air concentration at the position of maximum exposure corresponding with a cancer risk of one in a hundred thousand is 3.03 x 10-7 µg/m3. This does not take into account exposure through the other potential pathways.

2 The toxic equivalency (TEQ) is determined by multiplying the concentration of a dioxin congener by its toxicity factor. The total TEQ in a sample is then derived by adding all of the TEQ values for each congener. While TCDD is the most toxic form of dioxin, 90% of the total TEQ value results from dioxin-like compounds other than TCDD.



4. VEGETATION EXPOSURE In general, air pollution adversely affects plants in one of two ways. Either the quantity of output or yield is reduced or the quality of the product is lowered. The former (invisible) injury results from pollutant impacts on plant physiological or biochemical processes and can lead to significant loss of growth or yield in nutritional quality (e.g. protein content). The latter (visible) may take the form of discolouration of the leaf surface caused by internal cellular damage. Such injury can reduce the market value of agricultural crops for which visual appearance is important (e.g. lettuce and spinach). Visible injury tends to be associated with acute exposures at high pollutant concentrations whilst invisible injury is generally a consequence of chronic exposures to moderately elevated pollutant concentrations. The biological response of a plant to fumigation by air pollution is a function of a complex mix of biological, environmental, and climatic factors. Such factors include, among others: level and duration of pollution exposure, age of plant, genetic sensitivity of the plant, light, relative humidity, soil moisture and fertility, and general health of the plant. Given this kind of information, one could construct a reasonable, physical dose-response relationship – the physical damage function. However, the translation of this function into an economic damage function is fraught with another complex set of variables. Important aspects that one must consider here include: time and growing season, market value of the plant affected, the aesthetic value that might be attached to the plant, the nature of the harvesting and culturing costs for the particular affected crop, the adaptability of the site for growing a different crop, and the value of the site for alternative uses. Our current knowledge considers the most direct damaging air pollutants to vegetation to include

• Ozone • Sulphur dioxide; • Nitrogen oxides, nitric acid vapour, ammonia; • Peroxyayl nitrates (PAN); • Fluoride; and • Suspended particulate matter (SPM)

Other minor pollutants include:

• Chlorine; • Hydrogen chloride; • Hydrogen sulphide; and • Ethylene

4.1. Ozone Although the current and proposed mining and process plant do not specifically emit ozone as a primary pollutant, it is nonetheless included in the discussion for completeness. Ozone (O3) is an all-pervasive air pollutant produced primarily through chemical reactions in the



atmosphere driven by sunlight. Two key ingredients, namely volatile hydrocarbons and oxides of nitrogen, are required for the formation of O3 at the surface in the presence of sunlight. Natural sources consist of lightning activity during thunderstorms and downward intrusions of naturally produce O3 from the upper atmosphere. Diurnal peaks usually occur at midday, when the intensity of solar radiation is at a maximum and the NO2:NO ratio is large. Stagnant air would result in high concentrations. Thus, vegetation is exposed from a few hours to days of relatively high surface ozone concentrations at random with periods of relatively low concentrations. The surface of the epidermal cells seems to be folded, an effect that is caused by the water-repellent, waxy cuticle (see Figure 4-1). Ozone transfer via the leaf cuticle is negligible and the uptake is almost entirely through the stomata, resulting in the oxidation of the sensitive components of the plasmalemma (semi-permeable membrane that encloses the cell content, or cytoplasm and nucleus), and subsequently the cytosol. The inability to repair or compensate for altered membrane permeability can manifest as symptoms of visible injury (e.g. on broad-leafed plants could show symptoms of chlorosis (whitened areas of dying tissue where the pigments have broken down), bleaching, bronzing, flecking, stippling and uni- and bifacial necrosis), which are generally associated with short-term exposures to high ozone concentrations. Reductions in growth from chronic exposures can result in crop yield losses.

Figure 4-1: Simplified diagram of outer leaf cells

The first evidence for ozone-foliar injury in plants related to grapes was first observed and reported on in California (Richards et al, 1958). Subsequent reporting was made in Europe. Nothing similar on South African grapes could be sourced.



Primary symptoms occur mainly on the lower, older leaves and consist of numerous, small, discrete, brown-black punctate spots on the upper leaf surface. Secondary symptoms consist of leaf bronzing, yellowing, premature senescence, and leaf abscission.

4.2. Sulphur Dioxide Unlike ozone, it has been known for centuries that sulphur gases can have an adverse effect on vegetation (Evelyn, 1661). The degree to which a plant responds to SO2 is influenced not only by the SO2 concentration, duration, and frequency of exposure, but also by the variable mix of internal and external biotic and abiotic, as well as environmental factors, which can affect the response of the plant to the SO2. These factors include genetic make-up of the plant, the developmental stage of growth o the plant, plant and soil nutrient status, soil moisture status, and environmental components such as temperature, light, relative humidity, and precipitation. SO2 enters leaves through the stomata, but is also deposited at significant rates to wet surfaces, where it may dissociate to form sulphite or bisulphite and react with cuticular waxes. This can affect the cuticle to such an extent that a certain amount of SO2 can enter via the damaged cuticle. SO2 causes visible injury characterised by chlorosis of leaf tissue. Even when no visible injury is apparent, SO2 can cause a reduction in growth and yield – however, in sulphur deficient areas, low levels of SO2 may actually be beneficial. The visible injury response of plants under field conditions is commonly the response to a mixture of high concentration acute and low concentration chronic exposures. There have been numerous efforts to develop mathematical equations to express SO2 exposure-plant response relationships based on visible symptoms (e.g. Zahn 1963). Kercher and King (1985) reviewed some of the newer approaches for predicting or analysing the effects of SO2 on the growth and productivity of individual plants. Emmerson et al (2001) compared dose-response curves for different countries including China, India, Australia and the UK and found significant differences between crops and different countries (Figure 4-2). High concentrations of SO2 over short periods may result in acute visible injury symptoms. Such symptoms are usually observed on broad-leaved plants as relatively large bleached areas between the larger veins, which remain green. On grasses acute injury, usually caused by exposures to sub-lethal, long-term intermittent episodes of relatively low concentrations, may be observed as general chlorosis of the leaves (Lacasse and Treshow, 1976). This visible injury may decrease the market value of certain crops and lower the productivity of the plants. Sulphur dioxide impairs stomatal functioning resulting in a decline in photosynthetic rates, which in turn causes a decrease in plant growth. Reduction in plant yields can occur, even in the absence of visible foliar symptoms (Mudd, 1975). Relationships between plant injury and SO2 dosages are given in Table 4-1. Species that are sensitive to SO2 include spinach, cucumber and oats. These species may show decreases in growth at concentrations of 0.01 to 0.5 ppm (26 to 1309 µg/m³) (Mudd, 1975). Visible SO2 injury can occur at dosages ranging from 0.05 to 0.5 ppm (131 to 1309 µg/m³) for 8 hours or more (Manning and Feder, 1976). Maize, celery and citrus show much less damage at these low concentrations (Mudd, 1975).



Figure 4-2: SO2 dose-response relationships pooling data from China (black & white symbols), India (red symbols), Australia and the UK for different species and cultivars (Emberson et al., 2001)

Table 4-1: Injury to plants due to various doses of sulphur dioxide (a)

Symptoms Concentrations (µg/m³)

Concentrations (ppm)

Duration of

Exposure visible foliar injury to vegetation in arid regions 26179 10 2 hr

Coverage of 5% of leaf area of sensitive species with visible necrosis (b) 1309 – 2749 0.5 - 1.05 1 hr

visible injury to sensitive vegetation in humid regions 2618 1 5 min

Coverage of 5% of leaf area of sensitive species with visible necrosis (b) 785 – 1571 0.3 - 0.6 3 hr

visible injury to sensitive vegetation in humid regions 1309 0.5 1 hr



Symptoms Concentrations (µg/m³)

Concentrations (ppm)

Duration of

Exposure visible injury to sensitive vegetation in humid regions 524 0.2 3 hr

Visible injury to sensitive species 131 – 1309 0.05 - 0.5 8 hrs Decreased growth in sensitive species 26 – 1309 0.01 - 0.5 - Coverage of 5% of leaf area of sensitive species with visible necrosis (b) 524 – 680 0.2 - 0.26 6 - 8 hrs

Yield reductions may occur 524 0.2 monthly mean

Growth of conifers and yield of fruit trees may be reduced 262 0.1 monthly

mean Yield reductions may occur 209 0.08 annual

mean Growth of conifers and yield of fruit trees may be reduced 131 0.05 annual

mean Critical level for agricultural crops, forest trees and natural vegetation (c) 79 0.03 24-hrs

Critical level for agricultural crops (c) 26 0.01 annual mean

Critical level for forest trees and natural vegetation (c) 21 0.008 annual

mean Notes: (a) References: Laccasse and Treshow, 1976; Mudd, 1975; Manning and Feder, 1976; Harrison, 1990; Godish,

1991; Ferris, 1978 (b) Resistant species found to have threshold levels at three times these concentrations. (c) Refer to critical levels used by the United National Economic Commission for Europe to map exceedence

areas. These represent levels at which negative responses have been noted for sensitive receptors. WHO no longer advocates using a 24-hour guide value in their update of the Air Quality Guidelines in view of evidence confirming that peak concentrations are not significant compared with accumulated dose. Instead, they produced guidelines for annual and winter averages (Table 4-2). Table 4-2: World Health Organisation guidelines for the protection of ecosystems

Annual and Winter Mean Value (µg/m³) Target Affected 30 Crops 20 Forests / Natural Vegetation 15 Sensitive forests / Natural Vegetation 10 Lichens

The European Union introduced a limit value for SO2 that is protective for all ecosystems and which would be needed in regions without very sensitive ecosystems. It is therefore regarded as a ‘safety-net’ value designed to give protection to the majority of ecosystems within the EU Member States. The following limit value was adopted: 20 µg/m³ (annual and



winter mean), not to be exceeded over the year or the winter season. This was effective from 19 July 2001. Table 4-3: Examples of plants’ sensitivity to exposure of sulphur dioxide

Very Sensitive Plants Somewhat Resistant Plants Alfalfa, amaranthus, apple, apricot, ash (green and white), aspen, aster, bachelor’s button, barley, bean (broad and garden), beech, beet (table and sugar), begonia, bindweed, birch, blackberry, bluegrass (annual), broccoli, bromegrass, Brussels sprout, buckwheat, carrot, catalpa, centaurea, chickweed, China aster, clovers, columbine, cosmos, cotton, crab-apple, curly dock, dahlia, dandelion, Douglas fir, eggplant, elm, endive, fir (white), fleabane, forsythia, four o’clock, hawthorn (scarlet), larch, lettuce (garden and prickly), mallow, morning glory, mulberry, mustard, oat, okra, orchard grass, Pacific ninebark, peach, pear, pecan, pepper (bell and chilli), petunia, pine (Austrian, jack, loblolly, ponderosa, Virginia, white), plantain, polygonum, poplar, pumpkin, quince, radish, ragweed, raspberry, rhubarb, rockspirea, rose, rye, ryegrass, safflower, saltbush, smartweed, soybean, spinach, spruce, squash, strawberry, sumac, sunflower, sweet pea, sweet potato, Swiss chard, tomato, tulip tree, turnip, velvet weed, verbena, violet, wheat, and zinnia.

Arborvitae, box elder, cannas, castor bean, celery, chrysanthemum, citrus, corn, cucumber, ginkgo, gladiolus, gourds, hibiscus, honeysuckle, horseradish, iris, Johnsongrass, lilac, maple, milkweed, mock orange, muskmelon, most oaks, onion, potato, privet, purslane, shepherd’s purse, snowball, sorghum, tulip, viburnum, Virginia creeper, willow, and wisteria.

4.3. Oxides of Nitrogen, Nitric Acid and Ammonia Although nitrogen is a major component of the atmosphere, many nitrogenous compounds, which are found in the air, are detrimental to growth and productivity of plants. Various forms of nitrogen pollute the air, mainly nitric oxide (NO), NO2 and ammonia (NH3) as dry deposition, and NO3

– and NH4+ as wet deposition. Another contribution is from occult

deposition (fog and clouds). Human activities, both industrial and agricultural, have strongly increased the amount of biologically active nitrogen compounds, thereby disturbing the natural nitrogen cycle. It is generally believed that nitrogen oxides are less phytotoxic than sulphur dioxide and ozone. Nitrogen-containing air pollutants can affect vegetation indirectly, via chemical reactions in the atmosphere, or directly after being deposited on vegetation, soil or water. Most NO and NO2 enters leaves through stomata, although cuticular resistances to NO2 entry



are lower than for both SO2 and O3. The solubility of most gases, including NO, NO2 and NH3, is higher at lower temperatures, while the plant’s metabolic activity (and thus its detoxification capacity) is lower. On the other hand, stomatal conductivity and thus the influx of gases is generally lower at lower temperatures. In contrast with the view that NOx (and NH3) injury is greatest at low temperatures, Srivastava et al. (1975) found that inhibition by NOx of photosynthesis was greatest under optimal temperature and high light conditions, when stomatal conductance to the gas would be highest. The biochemical effects of most NO and NO2 are quite different and there is some uncertainty over which oxide is more toxic (CLAG 1996). NOx can reduce plant growth at high concentrations, although growth stimulations can be caused by low NOx concentrations, generally under situations sensitive to drought, pests and in some cases, to frost (CLAG 1996). Rare instances of visible injury caused by exposure to very high concentrations of NO2 are characterised by chlorotic areas on leaves associated with necrotic patches. Prolonged exposure to NOx has been shown to suppress plant growth via inhibition of photosynthesis. The indirect pathway includes complex atmospheric reactions: NO and NO2 are precursors for tropospheric ozone, which acts both as a phytotoxin and a greenhouse gas. Dinitrogen oxide (N2O) is a greenhouse gas and also contributes to the depletion of stratospheric O3, resulting in increasing ultraviolet radiation. Direct exposure to NOx may cause growth inhibitions in some plants (Table 4-4). Higher concentrations of NOx are usually needed to cause injury than for other pollutants such as ozone and sulphur dioxide. Chronic injury, such as chlorosis, may be caused by long-term exposures to relatively low concentrations of nitrogen dioxide but are reversible on young leaves. Acute injury is observed as irregularly shaped lesions that become white to tan, similar to those produced by SO2. Sensitive plants to NOx include beans and lettuce, whereas citrus and peach trees are rated as having an intermediary sensitivity. NOx may also impact indirectly on plants since the oxidation of NO2 to nitric acid contributes to acid rain problems. Acid rain serves to increasing the leaching of base cations from most soils in affected areas, resulting in the change in the acidity of the soils. Table 4-4: Injury to plants caused by various dosages of NO2.

Symptoms Concentration Duration of Exposure (µg/m³) (ppm)

Foliar injury to vegetation 3774 2 4 hr Slight spotting of pinto bean, endive, and cotton 1887 1 48 hr

Subtle growth suppression in some plant species without visible foliar markings 943 0.5 10-20 days

Decreased growth and yield of tomatoes and oranges 472 0.25 growing

season Reduction in growth of Kentucky bluegrass 189 0.1 20 weeks

References: (Ferris, 1978; Godish, 1990; Harrison, 1990; Quint et al., 1996).



In the majority of studies with NO and NO2 there were no significant effects at levels below 100 µg/m³ when applied singly, but in combination the effects are obvious. NO2 changed the response to O3 mainly with a less-than-additive interaction. In combination with SO2, NO2 acted more-than-additively in most cases (Ashenden and Mansfield 1978, CLAG 1996). It appears that a “melting” occurs of the fibrillous wax which in many species surround or fills the stomata as well as erosion of the cuticle. This makes it more difficult for plants to prevent water losses through their leaves. The leaves are also more prone to damage by parasitic fungi and insects. In general no interaction (and thus additivity) was found with CO2 and with NO. Two different types of effect threshold exist: critical levels and critical loads. The critical level (CLE) is the concentration in the atmosphere above which direct adverse effects on receptors, such as plants, ecosystems or materials, may occur according to present knowledge. The critical load (CLO) is a quantitative estimate of an exposure (deposition) to one or more pollutants below which significant harmful effects on specified sensitive elements of the environment do not occur according to present knowledge. Generally, for nitrogen-containing air pollutants, CLEs are expressed in terms of exposure (µg/m³ and exposure duration), while CLOs are expressed in terms of deposition (kg N/ha per year). Both the CLE and the CLO are intended to protect vegetation, and can be “translated” into each other using, for instance the deposition velocity as provided in Table 4-5. Table 4-5: Deposition velocity of nitrogen-containing gases and aerosols (WHO 2000)

Compound Deposition velocity (mm/s)

NO2 1–8

NO 0–1

NH3 12 (–5 to +30)

NH4+ 1.4 (0.03 to 15)

CLEs and CLOs are more or less complementary: CLEs focus on effect thresholds for short-term exposures (1 year or less), while CLOs focus on safe deposition quantities for the long term (1–100 years). CLEs are not intended to completely protect plants against adverse effects: No-observable-effect levels (NOELs) are usually lower. The WHO observed that information on gaseous NH3 and on NH4

+ in wet and occult deposition is still too limited to arrive at air quality guidelines, as they should have broad applicability. The have therefore not produced any CLE’s. To include the impact of NO, the WHO proposed a CLE for NOx instead of one for NO2. Furthermore, to take combination effects with SO2 and O3 into account, the CLEs for these compounds are included in the CLE for NOx. The original guideline CLE for an annual average NO2 concentration was 30 µg/m³. Subsequently, based on more recent information, the estimate for the no-effect level for an annual average is at around 15–20 µg/m³ for NO2, both when present as a single compound and in combination with SO2 and O3 (the nature of the NO2 effect changes, but not the no-effect level). For NO a no-effect level for an annual average was also estimated at around 15–20 µg/m³. The WHO finally proposed a CLE 30 µg/m ³ for the annual mean and a CLE for a 24-hour mean of 75 µg/m³.



Critical levels for NOx, used by the United National Economic Commission for Europe to map exceedence areas, are given as 30 µg/m3 for annual means and 95 µg/m3 for a 4-hour mean for agricultural crops, forest trees and natural and semi-natural vegetation.

4.4. Suspended Particulate Matter (SPM) Limited information is available (unlike ozone, sulphur dioxide and oxides of nitrogen) on the concentration and duration of exposure effects of SPM on vegetation. Current regulatory and research initiatives involving SPM are driven by (in order of importance) (Grantz et al, 2003):

• The effects on human health • The effects on visibility; and, lastly • The effects on the function of managed and natural ecosystems.

SPM is not a single pollutant, but rather a heterogeneous mixture of particles differing in size, origin and chemical composition. Exposure to a given mass of airborne SPM may lead to different phototoxic responses, depending on the particular mix of deposited particles. PM can damage vegetation both directly and indirectly: directly through deposition on foliar surfaces and indirectly through soil effects. The latter is usually the most significant because it can alter nutrient cycling and inhibit plant nutrient uptake (Grantz et al, 2003). Studies of direct effects of SPM on vegetation have not yet advanced to the stage of reproducible exposure experiments (Grantz et al, 2003). The impact upon vegetation is complex, given that impacts exerted upon them is caused by direct and indirect effects. In summary these impacts include (Godish, 1991):

• Indirect beneficial effects from soil neutralisation; • Reductions in yield and growth without visible injury; • Increase in disease incidence; • Severe injury to leaf cells; • Suppression of photosynthesis; • Death of vegetation; • Dust on leaves of crops, trees and shrubs inhibits photosynthesis and plant growth;

and • Particles carrying heavy metals can contaminate soil and vegetation.

SPM can produce a wide variety of effects on the physiology of vegetation that in many cases depend on the chemical composition of the particle. Heavy metals and other toxic particles have been shown to cause damage and death of some species as a result of both the phytotoxicity and the abrasive action during turbulent deposition. Heavy loads of particle can also result in reduced light transmission to the chloroplasts and the occlusion of stomata, decreasing the efficiency of gaseous exchange and hence water loss. They may also disrupt other physiological processes such as bud-break, pollination and light absorption/reflectance. Although extensive work has been done in Europe to establish dose-response relationships for a number of heavy metals on a number of vegetation types (Harmes et al, 2005)



(including arsenic, cadmium, chromium, copper, iron, mercury, nickel, lead, vanadium and zinc), unfortunately, no relationships could be obtained in the open literature on the general effect of particulates. Any SPM deposited on above ground plant parts may exert physical or chemical effects. The effects of ‘inert’ SPM are mainly physical, whereas those of toxic particles are both chemical and physical. The effects of dust deposited on plant surfaces or soil are more likely to be associated with their chemistry than simply with the mass of deposited particles (Farmer, 1993). Relatively high deposition rates (from 1 000 to 7 000 mg/m² for up to 130 days) of cement dust on cereals, have resulted in decreased respiration, catalase activity, oil content and overall yields (CEPA, 1998).



5. REGULATORY CONTEXT Prior to assessing the impact of the current and proposed cement facility, reference need be made to the environmental regulations and guidelines governing the emissions and impacts. This section provides the review of the current legislation and provides the current and proposed legal requirements pertaining to emission control and ambient air quality standards.

5.1. Air Pollution Legislative Context Although the NEMAQA already commenced on 11 September 2005, the Atmospheric Pollution Prevention Act (APPA) of 1965 was only repealed completed and the new Act only brought into full force on the 1st of April 2010. The original publication of the NEMAQA in the Government Gazette on 9 September 2005 omitted Sections 21, 22, 36 to 49, 51(1)(e),51(1)(f), 51(3),60 and 61. The new Act has shifted the approach of air quality management from source-based control to the control of the receiving environment. The act has also placed the responsibility of air quality management on the shoulders of local authorities that will be tasked with baseline characterisation, management and operation of ambient monitoring networks, licensing of listed activities, and emissions reduction strategies. The main objective of the act is to ensure the protection of the environment and human health through reasonable measures of air pollution control within the sustainable (economic, social and ecological) development framework. Previously under the Air Pollution Prevention Act (Act No 45 of 1965) (APPA) the focus was mainly on sourced based control with permits issued for Scheduled Processes. Scheduled processes, referred to in the Act, are processes which emit more than a defined quantity of pollutants per year, including combustion sources, smelting and inherently dusty industries. Best Practical Means (BPM), on which the permits are based, represents an attempt to restrict emissions while having regard to local conditions, the prevailing extent of technical knowledge, the available control options, and the cost of abatement. The Department of Environmental Affairs (DEA) is responsible for the administration of this Act with the implementation thereof charged to the Chief Air Pollution Control Officer (CAPCO). Although emission limits and ambient concentration guidelines were published, no provision was made under the APPA for ambient air quality standards or emission standards. The decision as to what constitutes the best practicable means for each individual case was reached following discussions with the industry. A registration certificate, containing maximum emission limits specific to the industry, was then issued. The new AQA has shifted the approach of air quality management from source-based control only to the control of the receiving environment. The act has also placed the responsibility of air quality management on the shoulders of local authorities that will be tasked with baseline characterisation, management and operation of ambient monitoring networks, licensing of listed activities, and emissions reduction strategies. The main objective of the act is to ensure the protection of the environment and human health through reasonable measures of



air pollution control within the sustainable (economic, social and ecological) development framework. The National Framework for achieving the Act was published in the Government Gazette on the 11th of September 2007. The National Framework is a medium- to long term plan on how to implement the Air Quality Act to ensure the objectives of the act are met. The National Framework states that aside from the various spheres of government responsibility towards good air quality, industry too has a responsibility not to impinge on everyone’s right to air that is not harmful to health and well-being. Industries therefore should take reasonable measures to prevent such pollution order degradation form occurring, continuing or recurring. In terms of NEMAQA, certain industries have further responsibilities, including:

• Compliance with any relevant national standards for emissions from point, non-point or mobile sources in respect of substances or mixtures of substances identified by the Minister, MEC or municipality.

• Compliance with the measurements requirements of identified emissions from point, non-point or mobile sources and the form in which such measurements must be reported and the organs of state to whom such measurements must be reported.

• Compliance with relevant emission standards in respect of controlled emitters if an activity undertaken by the industry and/or an appliance used by the industry is identified as a controlled emitter.

• Compliance with any usage, manufacture or sale and/or emissions standards or prohibitions in respect of controlled fuels if such fuels are manufactured, sold or used by the industry.

• Comply with the Minister’s requirement for the implementation of a pollution prevention plan in respect of a substance declared as a priority air pollutant.

• Comply with an Air Quality Officer’s legal request to submit an atmospheric impact report in a prescribed form.

• Taking reasonable steps to prevent the emission of any offensive odour caused by any activity on their premises.

• Furthermore, industries identified as Listed Activities (see Section 3.2) have further responsibilities, including:

o Making application for an Atmospheric Emission License (AEL) and complying with its provisions.

o Compliance with any minimum emission standards in respect of a substance or mixture of substances identified as resulting from a listed activity.

o Designate an Emission Control Officer if required to do so.

5.2. Emission Limits and the National Ambient Air Quality Standards The AQA makes provision for the setting of ambient air quality standards and emission limits on National level, which provides the objective for air quality management. More stringent ambient standards may be implemented by provincial and metropolitan authorities. Listed activities will be identified by the Minister and will include all activities regarded to have a significant detrimental effect on the environment, including health. In addition, the Minister



may declare priority pollutants for which an industry emitting this substance will be required to implement air pollution prevention plans.

5.2.1. Listed Activities The AQA was developed to reform and update air quality legislation in South Africa with the intention to reflect the overarching principles within the National Environmental Management Act. It also aims to comply with general environmental policies and to bring legislation in line with local and international good air quality management practices. Given the specific requirements of the NEMAQA, various projects had to be initiated to ensure these requirements are met. One of these included the development of the Listed Activities and Minimum National Emission Standards. These standards were published on 31 March 2010 (Government Gazette No. 33064). The project aimed to establish minimum emission limits for a number of activities identified through a consultative process at several forums. According to the process description, the Listed Activities that could potentially apply include:

• Subcategory 5.1: Storage and handling of ore and coal [Figure 5-1] • Subcategory 5.3: Cement production (using conventional fuels and raw materials)

[Figure 5-2] • Subcategory 5.4: Cement production (using alternative fuels and/or resources)

[Figure 5-3] Since the proposed plant will be storing coal onsite, Category 5.1 may apply. However, this activity only applies if the location is designed to hold more than 100 000 tonnes. Since the PPC facility is designed to hold less than this criterion, this category does not apply.

Figure 5-1: Section 21 of NEMAQA, Listed Activities Category 5.1 Storage and Handling of Ore and Coal

Currently PPC uses FDG within their cement manufacturing process, which they purchase from ArcerlorMittal Saldanha Steel Works. FDG is mixed in the raw mill and then added to the kiln with the other milled materials for calcination. As part of the upgrade, PPC would again be using FDG, requiring additional volumes. PPC also intends using slag within their



current and proposed process. Slag could also be sourced from ArcerlorMittal. Whereas FDG is used to produce the clinker in the kiln slag and fly-ash are used as extenders, i.e. mixed with the clinker. In terms of Section 21 of the NEM: AQA, PPC triggers Listed Activity Category 5 (Mineral processing, storage and handling) Subcategory 5.4: Cement production (using alternative fuels and/or resources) due to the usage of FDG to produce the clinker, rather than Subcategory 5.3 which refers to the usage of conventional fuels and raw materials. The proposed introduction of slag and fly-ash as raw materials into their cement manufacturing process after the clinker production does not apply here.

Figure 5-2: Section 21 of NEMAQA, Listed Activities Category 5.3 Cement Production (using conventional fuels and raw materials)

If on the other hand, PPC decides not to use alternative resources (i.e. FDG) once an AEL with Subcategory 5.4 has been issued, it is not expected that a new application for the less strict, Subcategory 5.3 need to be submitted. This expectation is based on the fact that Subcategory 5.4 includes all the pollutants in Subcategory 5.3, and that these emission limits are all stricter in with the former subcategory.

5.2.1. National Ambient Air Quality Standards Air quality guidelines and standards are fundamental to effective air quality management, providing the link between the source of atmospheric emissions and the user of that air at the downstream receptor site. These ambient air quality guideline values indicate safe daily exposure levels for the majority of the population, including the very young and the elderly, throughout an individual's lifetime.



Air quality guidelines and standards are normally given for specific averaging periods. These averaging periods refer to the time-span over which the air concentration of the pollutant was monitored (predicted or measured) at a location. Generally, five averaging periods are applicable, namely an instantaneous peak, 1-hour average, 24-hour average, 1-month average, and annual average.

Figure 5-3: Section 21 of NEMAQA, Listed Activities Category 5.4 Cement Production (using alternative fuels and/or resources)

Air quality standards are enforceable by law whilst guidelines are used primarily as an indication of the level of impact. The South African Bureau of Standards (SABS) was originally engaged to assist the DEA in the facilitation of the development of national ambient air quality standards. Standards were determined based on international best practice for PM10, dustfall, SO2, NO2, ozone, CO, lead (Pb) and benzene. These standards were developed around the objective to indicate safe daily exposure levels for the majority of the population, including the very young and the elderly, throughout an individual’s lifetime.



The proposed standards were first published for comment in the Government Gazette on 9 June 2007. These standards were revised and again published for comment in the Government Gazette on the 13th of March 2009. The final National Ambient Air Quality Standards (NAAQS) as published in the Government Gazette on the 24th of December 2009 are listed in Table 5-1. The application of these standards varies, with some pollutants allowed a certain number of exceedances of each of the Limit Values per year. Also, a Level of Tolerance has been set for some pollutants, e.g. the daily average PM10 limit. The daily average PM10 limit is currently at 120 µg/m³ and applies until 31 December 2014. From 1 January 2015, the limit reduces to 75 µg/m³. The number of allowable exceedances remains the same, i.e. 4 per annum. Table 5-1: National Ambient Air Quality Standards (NAAQS)

Pollutant Averaging Period

Limit Value Frequency of

Exceedance Compliance Date (µg/m³) (ppb)

Carbon Monoxide (CO)

1 hour 30 000 26 000 88 Immediate

8 hour (a) 10 000 8 700 11 Immediate

Nitrogen Dioxide (NO2)

1 hour 200 106 88 Immediate

1 year 40 21 0 Immediate

PM10 24 hour 120 - 4 Immediate – 31 Dec 2014 75 - 4 1 Jan 2015

1 year 50 - 0 Immediate – 31 Dec 2014 40 - 0 1 Jan 2015

Sulphur Dioxide (SO2)

10 min 500 191 526 Immediate 1 hour 350 134 88 Immediate 24 hour 125 48 4 Immediate 1 year 50 19 0 Immediate

Benzene 1 year 10 3.2 0 Immediate – 31 Dec 2014 5 1.6 0 1 Jan 2015

Lead 1 year 0.5 - 0 Immediate Ozone 8 hour (b) 120 61 11 Immediate Notes:

(a) - calculated on hourly averages (b) – running average

Ambient air quality limits are not published for all possible air pollutants to which the public may be exposed. Such limits are typically only set for commonly occurring air pollutants that result in relatively widespread public exposures. Suspended fine particulate matter, sulphur dioxide, nitrogen dioxide, carbon monoxide, lead and ozone are classified by most countries as ‘criteria pollutants’ with air quality limits being set for these pollutants.



5.2.2. Dust Fallout Dustfall is associated with nuisance rather than human health impacts. Given that the air quality impact study is concerned with assessing the potential for impacts on both human health and on the well-being of people it is necessary to determine the likely limits of acceptability for dustfall rates. Reference is therefore also made to dustfall limits published by other countries (Table 5-2). It is important to note that the limits given by Argentina, Australia, Canada, Spain and the USA are based on annual average dustfall. The standards given by Germany and South Africa are given for maximum monthly dustfall. In South Africa, dust deposition may be gauged according to the criteria published by SABS (SANS, 2009) and recently proposed by the DEA (Government Gazette No. 34307 of 27 May 2011). This includes a system of dust-fall rate assessment were dust deposition rates are evaluated against a four-band scale, as presented in Table 5-3 Target, action and alert thresholds for ambient dust deposition, as published by Standards SA, are given in Table 5-4. According to the SANS dust-fall limits an enterprise may submit a request to the authorities to operate within the Band 3 ACTION band for a limited period, providing that this is essential in terms of the practical operation of the enterprise (for example the final removal of a tailings deposit) and provided that the best available control technology is applied for the duration. No margin of tolerance will be granted for operations that result in dust-fall rates in the Band 4 ALERT. Table 5-2: Dust deposition standards issued by various countries

Country Annual Average (mg/m2/day) (based on monthly monitoring)

Maximum Monthly (mg/m2/day) (based on 30 day average)

Argentina 133 Australia 133 (onset of loss of amenity)

333 (New South Wales)

Canada Alberta: Manitoba:

179 (acceptable) 226 (maximum acceptable) 200 (maximum desirable)

Germany 350 (general areas) 650 (industrial areas)

South Africa The proposed DEA standards include a residential action level of 600 mg/m²/day and an industrial standard of 1200 mg/m²/day

Spain 200 (acceptable)



Country Annual Average (mg/m2/day) (based on monthly monitoring)

Maximum Monthly (mg/m2/day) (based on 30 day average)

USA: Hawaii Kentucky New York Pennsylvania Washington Wyoming

200 175 200 (urban, 50th percentile) 300 (urban, 84th percentile) 267 183 (residential areas) 366 (industrial areas) 167 (residential areas) 333 (industrial areas)

Table 5-3: Bands of dustfall rates proposed for adoption

Band Number

Band Description

Label

Dust-Fall Rate (D) (mg m-2 day-1,

30-Day Average) Comment

1 RESIDENTIAL D < 600 Permissible for residential and light commercial

2 INDUSTRIAL 600 < D < 1 200 Permissible for heavy commercial and industrial

3 ACTION 1 200 < D < 2 400

Requires investigation and remediation if two sequential months lie in this band, or more than three occur in a year.

4 ALERT 2 400 < D

Immediate action and remediation required following the first exceedance. Incident report to be submitted to relevant authority.

Table 5-4: Target, action and alert thresholds for ambient dustfall

Level Dust-Fall Rate (D)

(mg m-2 day-1, 30-Day Average)

Averaging Period

Permitted Frequency Of Exceedances

TARGET 300 Annual ACTION

RESIDENTIAL 600 30 days Three within any year, no two sequential months.

ACTION INDUSTRIAL 1 200 30 days

Three within any year, not sequential months.

ALERT THRESHOLD 2 400 30 days

None. First exceedance requires remediation and compulsory report to authorities.



5.3. Pollution Management Intervention Criteria The following system for the use of these in the managing of ambient air quality is recommended by SANS 1929:

Levels below 50 % of the NAAQS : No current significant impact

Levels above 50 % of the NAAQS : On-going monitoring of certain pollutants may be required

Levels of certain pollutants at 80 % or more of the NAAQS :

Some air pollution management intervention in the area required and careful assessment of any new facilities in the area

Levels above the NAAQS :Potential for air pollution health impacts in the area and any new plants in the area could make things worse



6. DISPERSION POTENTIAL AND AIR QUALITY MEASUREMENTS

6.1. Meteorological Parameters Meteorological mechanisms govern the dispersion, transformation and eventual removal of pollutants from the atmosphere. The extent to which pollution will accumulate or disperse in the atmosphere is dependent on the degree of thermal and mechanical turbulence within the earth’s boundary layer. Dispersion comprises vertical and horizontal components of motion. The stability of the atmosphere and the depth of the surface-mixing layer define the vertical component. The horizontal dispersion of pollution in the boundary layer is primarily a function of the wind field. The wind speed determines both the distance of downwind transport and the rate of dilution as a result of plume ‘stretching’. The generation of mechanical turbulence is similarly a function of the wind speed, in combination with the surface roughness. The wind direction, and the variability in wind direction, determines the general path pollutants will follow, and the extent of crosswind spreading. Pollution concentration levels therefore fluctuate in response to changes in atmospheric stability, to concurrent variations in the mixing depth, and to shifts in the wind field. Spatial variations, and diurnal and seasonal changes, in the wind field and stability regime are functions of atmospheric processes operating at various temporal and spatial scales. Atmospheric processes at macro- and meso-scales need therefore to be taken into account to accurately parameterise the atmospheric dispersion potential of a particular area. A qualitative description of the synoptic systems determining the macro-ventilation potential of the region may be provided based on the review of pertinent literature. Meso-scale systems may be investigated through the analysis of meteorological data observed for the region. Surface meteorological data, including hourly average wind speed, wind direction and ambient temperature recorded at the PPC Riebeeck West on-site weather station (Figure 6-4) was obtained for the period January to December 2010.

6.1.1. Surface Wind Field Hourly average data are necessary to facilitate a comprehensive understanding of the ventilation potential at the site, and to provide the meteorological input requirements for the dispersion simulations. Generally winds in the region are strong, occasionally reaching gale force. Hourly average wind speed and wind direction data was used to compile wind roses. A wind rose comprises 16 spokes, which represent the directions from which winds blew during the period. The colours reflected the different categories of wind speeds; the grey area, for example, representing winds of 1 m/s to 2 m/s. The dotted circles provide information regarding the frequency of occurrence of wind speed and direction categories. For the current wind roses, each dotted circle represents a 5% frequency of occurrence. The value given in the centre of the circle described the frequency with which calms occurred, i.e. periods during which the



wind speed was below 1 m/s. Period, day-time and night-time wind roses for PPC Riebeeck West site are presented in Figure 6-1.

Figure 6-1: Period, daytime and night-time wind roses for PPC Riebeeck West (January to December 2010)



Figure 6-2: Seasonal wind roses wind roses for PPC Riebeeck West (January to December 2010)



The most dominant wind direction for the period is south- south-westerly, with a frequency of occurrence of 18%. This wind direction dominates the day-time and night-time wind patterns. Furthermore, this wind component is characterised by relatively strong wind speeds. The percentage of calm conditions is given as 13.3%, 7.1% and 19.5% for the period, daytime and night-time respectively. Wind direction varies according to the seasons and blows predominantly from the southeast in summer and increasingly northwest in winter. The seasonal variation in wind-flow is shown in Figure 6-2. The wind roses for all the seasons show a predominance of the south- south-westerly winds, with frequencies of exceeding 15%.

6.1.2. Ambient Air Temperature Air temperature is important, both for determining the effect of plume buoyancy (the larger the temperature difference between the plume and the ambient air, the higher the plume is able to rise), and determining the development of the mixing and inversion layers. As the earth cools during the night-time the air in direct contact with the earth’s surface is forced to cool accordingly. This is clearly evident from Figure 6-3. The coldest time of the day appears to be between 06h00 and 08h00, which is just before or after sunrise. After sunrise, surface heating occurs and as a consequence the air temperature gradually increases to reach a maximum at approximately 15h00 in the afternoon. The atmospheric boundary layer constitutes the first few hundred metres of the atmosphere. This layer is directly affected by the earth’s surface, either through the retardation of flow due to the frictional drag of the earth’s surface, or as result of the heat and moisture exchanges that take place at the surface. During the daytime, the atmospheric boundary layer is characterised by thermal turbulence due to the heating of the earth’s surface and the extension of the mixing layer to the lowest elevated inversion. Radiative flux divergence during the night usually results in the establishment of ground-based inversions and the erosion of the mixing layer. Night-times are characterised by weak vertical mixing and the predominance of a stable (inversion) layer. These conditions are normally associated with low wind speeds, hence less dilution potential. Based on recorded temperature measurements, it is evident that Riebeek West is warm and mild. The hottest months of the year are January (average maximum temperature of 29.9ºC) and February (average maximum temperature of 30.4ºC). The winter months are much colder with July and August having an average minimum temperature of below 8ºC (PPC, 2000). Usually Riebeek West is hotter and drier than Cape Town with the summer months (October to March) reaching temperatures as high as 41ºC. The annual monthly maximum, minimum and mean temperatures are 33°C, 9°C and 18°C respectively. A maximum temperature of 41°C was recorded during February and March and a minimum temperature of 4°C in June (Table 6-2).



Figure 6-3: Diurnal and monthly variation of ambient air temperatures at PPC Riebeeck West

Table 6-1: Maximum, minimum and mean monthly temperatures at PPC Riebeeck West (January to December 2010)

Maximum

Temperature (°C) Minimum

Temperature (°C) Average

Temperature (°C) January 40 13 23.6 February 41 12 23.1 March 41 12 23.5 April 36 10 18.9 May 28 6 15.3 June 26 4 13.7 July 23 6 13.8 August 28 5 14.2 September 30 7 15.1 October 33 8 16.8 November 38 10 19.2 December 35 12 23 41 4 18.4



6.1.3. Rainfall and Evaporation Rates The climate in Riebeek West is characteristic of a warm, temperate Mediterranean climate. Most of the rainfall occurs in winter from May to August, while the summer months are characteristically hot and dry. During winter, rainfall occurs on average 14 days each month, while the summer months receive an average of only four to five days of rain each month. No rainfall data is available for the PPC Riebeeck West site and therefore rainfall data for the period 2004 to 2007 from the South African Weather Services station of Malmesbury was used in the study. Table 6-2 is a summary of the rainfall observations at Malmesbury and for comparison purposes also Atlantis, closer to Cape Town. During May, June, July and August temperatures drop considerably (see previous section) and most of the rain (64%) falls during these four months. The remaining months receive a monthly average of between 2 mm (December) to 45 mm (April). From the comparison with Atlantis, it would appear that the region receive less rainfall than closer to Cape Town. The evaporation rate for the region is also given in the table. Rainfall is required to estimate emission rates of fugitive dust from agricultural activities, wind erosion and road entrainment, etc. Rainfall and evaporation rates are also required to estimate the amount of watering required to control dust generation from road surfaces. Table 6-2: Average monthly rainfall and evaporation rates at Malmesbury (2004 to 2007)

Rainfall (mm) Evaporation Rate

(mm) Malmesbury Atlantis January 8 22 322 February 4 10 254 March 9 23 217 April 45 32 145 May 52 67 104 June 78 60 76 July 53 63 82 August 65 48 106 September 25 41 144 October 33 27 209 November 12 21 258 December 2 24 313 Annual 387 438 2 230

6.1.4. Mixing Depth and Atmospheric Stability Mixing depths and atmospheric stability, which provide an indication of the potential for vertical dispersion, are not readily measured and need therefore be estimated. The mixing layer may be estimated using prognostic models that derive the thickness from some of the other parameters that are routinely measured, e.g. solar radiation and temperature. The new generation air dispersion models differ from the models traditionally used in a number of



aspects, the most important of which are the description of atmospheric stability as a continuum rather than discrete classes. The atmospheric boundary layer properties are therefore described by two parameters; the boundary layer depth and the Monin-Obukhov length, rather than in terms of the single parameter Pasquill Class. The Monin-Obukhov length provides a measure of the importance of buoyancy generated by the heating of the ground and mechanical mixing generated by the frictional effect of the earth’s surface. Physically, it can be thought of as representing the depth of the boundary layer within which mechanical mixing is the dominant form of turbulence generation. The mixed layer ranges in depth from a few metres (i.e. stable or neutral layers) during nighttimes to the base of the lowest-level elevated inversion during unstable, daytime conditions. Elevated inversions may occur for a variety of reasons and on some occasions as many as five may occur in the first 1000 m above the surface (Tyson and Von Gogh, 1976). The lowest-level elevated inversion is located at a mean height above ground of 1 550 m during winter months with a 78 % frequency of occurrence. By contrast, the mean summer subsidence inversion occurs at 2 600 m with a 40% frequency.

6.2. Ambient Air Quality Monitoring Environmental and Hygiene Engineering cc has been contracted to determine the dust fall rates PPC Riebeeck. The monitoring network consists of two, twin-bucket monitors located at the Rugby Field and the Overburden Dump, and two, four-bucket DustWatch monitors located at De Gift and the Quarry. These locations are shown in Figure 6-4. The campaign started in 2000, and data has been collected continuously to date. Two additional, albeit short-term, air quality monitoring campaign were completed from June 2007 to August 2007 and again from May 2011 to June 2011. These campaigns included air concentrations of inhalable particulates (PM10), sulphur dioxide and nitrogen dioxide. The latter campaign also included VOCs. The results from these monitoring campaigns are summarised below.

6.2.1. Fallout Dust Fallout rates have been determined on a two-weekly collected basis. An attempt was made to distinguish dust imported into the mining and production facility and that exported from the facility. Imported dust would typically originate from agricultural activities in the region. The Quarry and Dump sites were noted to be positioned very near to potential sources of high localised dust as dumping and material handling took place around the sampling unit. A summary of the observation from the sites is presented below:

• Quarry Site: o Maximum period October to February. Levels between 500 mg/m²/day and

1200 mg/m²/day [considered HEAVY dustfall]



o Minimum period April to October. Levels < 300 mg/m²/day [SLIGHT to MODERATE]

• De Gift: o Maximum period October to February. Levels between 400 mg/m²/day and

1000 mg/m²/day [MODERATE to HEAVY] o Minimum period April to October. Levels < 200 mg/m²/day [SLIGHT]

• Rugby Field: o Maximum period October to April. Levels between 400 mg/m²/day and 1000

mg/m²/day [MODERATE to HEAVY o Minimum period May to October. Levels < 200 mg/m²/day [SLIGHT]

• Dump Unit: o Maximum period October to February Levels between 200 mg/m²/day and 800

mg/m²/day [MODERATE to HEAVY] o Minimum period March to October. Levels < 200 mg/m²/day [SLIGHT]

Figure 6-4: Locations of sampling sites relative to the mine and production facility

The smallest amount of daily dust was clearly collected during the winter season and the highest amount during the summer months. As part of an investigation into the potential contamination of soil from the cement facility, Lambrechts (2007) completed an analysis of the fallout data collected by Environmental and Hygiene Engineering cc. Lambrechts (2007)



found that except for the import buckets north and east at De Gift, the average daily autumn and spring collected dust in all the other buckets did not differ significantly, but was significantly smaller than the summer and larger than the winter collected dust. At the north import bucket at De Gift the average autumn collected dust did not differ significantly from the summer collected dust, while dust collected in east import bucket differed significantly in the following order: winter < spring < autumn < summer. Lambrechts (2007) further noted the following average daily dust rate ranges:

• winter season : 76 to 168 mg/m²/day • spring : 157 to 316 mg/m²/day • autumn : 189 to 438 mg/m²/day • summer season : 395 to 571 mg/m²/day

The results clearly indicate an increased fallout rate during the dry summer period and during autumn when the prevailing winds are generally stronger. The measurements indicate that the highest daily exports during summer, autumn and winter is to the east. This is followed by the west, north and lowest to the south. During spring the highest exports is to the west, followed by east, then south with the lowest to the north. On an annual basis the highest daily imports came from the south and east. The regional dust generation is clearly evident when considering the average for each location during all years:

• Dump unit : 212 mg/m²/day • Rugby Field : 241 mg/m²/day • Quarry unit : 298 mg/m²/day • De Gift : 333 mg/m²/day

The Quarry unit and De Gift observed the highest average fallout rates. The contribution to the Quarry unit is clearly from the mining activities, whereas the observation at the De Gift site is most likely a combination of mining, vehicle activity along the nearby roads, agricultural activities and the nature of the surface characteristics and vegetation cover of the surrounding environment (higher wind erosion potential). The De Gift unit is situated to the south-east of the main entrance to the PPC factory. The Rugby Field unit is situated in a fairly vegetated environment and also upwind of the prevailing wind direction and the cement facility. Table 6-3 is a summary of the annual average fallout rate for each bucket expressed an “import” and “export”. The highest export was recorded at De Gift 127 750 mg/m²/annum. This is followed by Quarry unit 106 884 mg/m²/annum, Rugby Field 89 182 mg/m²/annum and Dump unit 80 361 mg/m²/annum. The “import” fallout rates were slightly lower on average (97 633 mg/m²/annum) than the “export” fallout rates (101 044 mg/m²/annum). The difference is about 3.4% of the average “export” fallout rate, and hence providing some indication of the possible contribution of the existing mine and cement manufacturing facility to the general background fallout.



Table 6-3: Average annual total dust collected per bucket

Dust Bucket Transfer Direction

Annual Average

(mg/m²/a)

Import Average

(mg/m²/a)

Export Average

(mg/m²/a)

Difference

(mg/m²/a)

De Gift Import From north 109 378

119 375 8 375 (6.6%)

From south 136 814 From east 111 933

Export To east 127 750 127 750

Quarry Import From north 98 428

109 581 -2 697 (-2.5%)

From south 120 998 From west 109 318

Export To west 106 884 106 884

Dump Import From north 74 521 74 521 5 840 (2.4%) Export To north 80 361 80 361

Rugby Field Import From south 87 053 87 053 2 129 (3.4%) Export To south 89 182 89 182

Average 97 633 101 044 3 412 (3.4%) Lambrechts (2007) chemically analysed the sixteen fallout bucket samples that represented the total collected dust for 2004 and 2006 for the four export and four import buckets. The concentrations of calcium (Ca), magnesium (Mg) and carbonate (CO3) were determined and summarised in Table 6-4. The average increase in calcium levels in the export samples over the import samples is about 6% with an insignificant increase in magnesium levels. Table 6-4: Calcium and magnesium concentration in fallout bucket samples

Location Direction Years Calcium (%) Magnesium (%)

Year’s Average

Export/Import Average

Year’s Average

Export/Import Average

De Gift Export to East

2004 5.65

8.4

0.12

0.3

2006 8.73 0.29

Dump Export to North

2004 11.53 0.58 2006 7.88 0.24

Rugby Field

Export to South

2004 - - 2006 7.66 0.48

Quarry Export to West

2004 6.91 0.14 2006 10.26 0.16

De Gift Import to East

2004 5.64

7.9

0.15

0.3

2006 10.01 0.40

Dump Import to North

2004 7.96 0.26 2006 7.54 0.30

Rugby Field

Import to South

2004 7.47 0.24 2006 7.76 0.60

Quarry Import to West

2004 7.83 0.21 2006 9.01 0.16

PPC Contribution ≈ (Export-Import)/Export% 6% ~0%



The estimated annual average calcium deposition rate is therefore between 4 640 and 7 300 mg/m² per annum. Fallout measurements were separately done by Ecoserv (now SGS) at Delectus, Vlakkerug and the Rugby Field site for the period 17 June 2007 to 17 July 2007. Results are summarised in Table 6-5. The low fallout rates during the winter period confirm the results from Environmental and Hygiene Engineering. Table 6-5: Dust fallout results for 17 June to 17 July 2007 (Ecoserv)

Sample Location Days Sampled Fallout Rate (mg/m2/day)

Rugby Field 30 66 Delectus 30 27 Vlakkerug 30 45

6.2.2. Inhalable Particulates Two, one-month PM10 sampling campaigns were performed from June to August 2007 and also May to June 2011. The locations of the sampling sites are shown in Figure 6-4 and the results summarised in Table 6-6. A graph of the latter campaign is also given in Figure 6-5. The table indicates no exceedences of the DEA standard. The maximum daily average of 66 µg/m³ at the Rugby Field was recorded on a day during which the site was downwind of PPC Riebeeck. According to the management interventions outlined in Section 4.2, the approach to 80 % of the daily average standard of 75 µg/m3 at the Rugby Field site requires some air pollution management intervention and careful assessment of any new facilities in the area. Table 6-6: Summary of PM10 daily average ambient concentrations June 2007 to August 2007 at Delectus and Rugby Field monitoring sites and 14 May to 14 June 2011 at the Weather Station Site.

Delectus Rugby Field

Weather Station

Number of Days > 75µg/m3 0 0 0 Number of Days between 60 and 75 µg/m3 0 1 0 Number of Days between 35 and 60 µg/m3 0 2 2 Maximum Daily Average PM10 concentration (µg/m3) 17 66 50

6.2.3. Sulphur Dioxide and Nitrogen Dioxide Ambient air concentration levels of sulphur dioxide and nitrogen dioxide were determined using passive diffusive samplers. Two campaigns were initiated; with the first campaign occurring from June to July 2007 and the second from May to June 2011.



During the first campaign, the sampling units were located at three sites, namely the Rugby Field, Delectus and Vlakkerug, as shown in Figure 6-4 and summarised in Table 6-8.

Figure 6-5: Ambient air daily average PM10 concentrations observed at PPC Riebeeck West’s Weather Station

Table 6-7: Summary of sulphur dioxide and nitrogen dioxide ambient concentrations (June to July 2007)

Location Date Nitrogen dioxide (ppb)

Sulphur dioxide (ppb)

Rugby Field

05-June-07 to 19-Jun-07 1.39 0.06 19-June-07 to 08-July-07 1.49 0.10

Vlakkerug 19-June-07 to 08-July-07 0.89 0.05

Delectus 05-June-07 to 19-June-07 1.49 Below detection limit 19-June-07 to 08-July-07 Below detection limit Below detection limit

During the second campaign, the samplers were located at the following locations:


The location of the individual sampling points can be seen in Figure 6-6 and the results summarised in Table 6-8. Both the SO2 and NO2 concentrations (maximum of 0.8 ppb and



4.45 ppb, respectively) were slightly higher than that observed during the previous campaign (maximum of 0.1 ppb and 1.39 ppb, respectively), however they were still very low compared to the long-term limit values of 19 ppb and 21 ppb, respectively.

Figure 6-6: Locations of SO2, NO2 and VOC passive samplers (May/June 2011)

Table 6-8: Summary of sulphur dioxide and nitrogen dioxide ambient concentrations (12 May to 15 June 2011)

Location Nitrogen dioxide (ppb)

Sulphur dioxide (ppb)

Meteorological Station 4.45 0.42 Conference Centre 2.76 0.80 Boundary West 1.75 0.15 Boundary North 1.27 0.04 The highest NO2 concentration was observed at the Meteorological Station, whilst the highest SO2 concentration was observed at the Conference Centre.

6.2.1. Volatile Organic Compounds Air concentration measurements of volatile organic compounds were also included during the second campaign at the same locations as for SO2 and NO2. These measurements were



similarly done using diffusion tubes exposed for approximately a month’s period (12 May to 15 June 2011). A host of compounds is classified as volatile organic compounds (VOCs), including the more commonly found “BETX compounds”, viz. benzene, ethylbenzene, toluene and xylene (o-, p- and m- isomers). Of these BETX compounds, only toluene was observed at all four locations, with the highest value of 5.3 µg/m³ observed at the Meteorological Station. .This station also observed the highest xylenes concentration of 4.4 µg/m³. Xylene was also observed at the Conference Centre, but not at any of the other two locations. Ethylbenzene was only observed at the Conference Centre. With a detection threshold of 0.2 µg/m³, benzene could not be detected at any of the locations. The following compounds were all below the detection limit of the laboratory and concentrations could not be calculated for any of the samples: Pentane 3-Methylhexane n-Butyl acetate Ethanol Napthalene 2-Butoxyethanol Acetone (2-propanone) Styrene Cyclohexanone 2-Methylpentane Isooctane Isopropylbenzene (Cumene) 3-Methylpentane n-Heptane Propylbenzene n-Hexane Trichloroethylene

(Trichloroethene) 1,2,3-trimethylbenzene

Methyl Ethyl Ketone (MEK) Methylmethacrylate 1,2,4-trimethylbenzene Ethyl acetate Propyl acetate 1,3,5-trimethylbenzene 2-Methylhexane Methyl Isobutyl Ketone

(MIBK) 1-Heptene

Cyclohexane Perchloroethylene (Tetrachloroethene)

1-Decene

1-Pentene 1-Hexene 1-Octene 1-Nonene Table 6-9: Summary of selected volatile organic compound ambient concentrations (12 May to 15 June 2011)

Location Air Concentration (µg/m³) Benzene Ethylbenzene Toluene m-, p- Xylenes

Meteorological Station <0.2 <0.2 5.3 4.4 Conference Centre <0.2 0.7 2.2 0.2 Boundary West <0.2 <0.2 1.3 <0.2 Boundary North <0.2 <0.2 0.4 <0.2



7. EMISSIONS INVENTORY OF CURRENT AND PROPOSED PPC RIEBEECK FACILITY

7.1. Current Operation Emissions

7.1.1. Routine Process Emissions As indicated in Section 2, the atmospheric emissions from the current facility can broadly be grouped into the following sources: • Processing

o Dry Kilns • Preparation

o Raw Mil o Coal Mill o Clinker Cooler Grate o Finish Mill o Crushing and screening o Limestone transfer

• Diffuse Sources o Material Handling o In-pit operations, including drilling, blasting, excavation and loading o Wheel entrained dust on roads

• Wind Erosion o Overburden dump o Coal storage o Limestone o Sand o Run of Mine o Open Area

The most significant pollutants associated with the operation include







Although dioxins and furans would be emitted in small quantities, it needs to be considered in the assessment due to its very toxic nature. Particulate matter would typically include metal chlorides, nitrates and sulphates. Based on typical chemical analyses of the material found at the facility (Table 7-1 and Table 7-2), the most significant metals include calcium, silicon and aluminium. The metals in the airborne particulates would most likely be in the form of chlorides, sulphates, ammoniums and nitrates. Table 7-1: Chemical analysis of PPC Riebeeck clinker

PPC Clinker Chemical Analysis Metal Compound Composition (%) Metal Composition (%)

CaO 66.65 Ca 47.6 SiO2 22.12 Si 10.3 AI2O3 4.48 Al 2.5 Fe2O3 3.23 Fe 2.3 MgO 0.96 Mg 0.6 K2O 0.67 K 0.6

S 0.16 S 0.16 P2O5 0.13 P 0.1 SrO 0.32 Sr 0.3 TiO2 0.25 Ti 0.2

Mn2O3 0.07 Mn 0.05 Na2O 0.15 Na 0.1

Table 7-2: Estimate of elements in road dust.

Element Composition (%) Mine Road Plant Access Road

Ca 48.0 43.0 Si 7.0 7.8 Al 1.7 2.1 Fe 0.6 1.0 Mg 0.7 0.7 K 0.1 0.3 Cl 0.1 0.2 S 0.1 0.4 P 0.1 0.1 Zn trace trace Cu trace trace Ni trace trace Sr trace trace

Similarly, a relatively old (2001) chemical analysis of the FDG used in the production of clinker (Table 7-3) indicates that the main components are iron (58%), calcium (20%),



carbon (12%), silica (3%) and aluminium (2%). This analysis also indicates the presence of mercury levels that could be considered significant. As a result, a more detailed analysis of mercury content in the FDG, as well as all the other raw materials was commissioned in 2011. Raw material samples from the current factory at PPC Riebeeck West were sent out to an external lab for mercury analysis (see Appendix A, Council for Geosciences 2011). The two most significant sources of mercury include the coal and the FDG feeds. The mercury analyses of these two materials are shown in Figure 7-1. Table 7-4 represents a summary of the results indicating the maximum and average mercury content in all raw materials, including the current clinker production. The analysis shows a maximum of 1.4 ppm mercury in the FDG followed by coal with a maximum mercury content of 0.16 ppm. Table 7-3: Chemical analysis of FDG (Saldanha Steel 2001, Appendix A)

Filter Dust Granules Chemical Analysis

Main Compound

Composition (%)

Trace Elements

Metal Composition (ppm) Metal Composition

(ppm) Fe2O3 42 As 30 Mn 2 200

CaO 22 Ba 328 Pb 100

FeO 11 Cd 10 Se 5.3

Carbon 12 Co 2 Ti 902

Fe metal 5 Cr 22 Zn 250

SiO2 3 Hg 5.7 S 7 200

AI2O3 2 Table 7-4: Mercury content of clinker and feed streams (Council for Geosciences 2011, Appendix A)

Material Mercury Concentration (ppm) Average Maximum

Limestone 0.0033 ±0.00023 0.0034

Shale 0.0073 0.0073

Sand 0.0044 0.0044

Coal 0.1445 ±0.00610 0.1634

Filter dust granules 1.1394 ±0.04191 1.4000

Kiln feed 0.0230 ±0.02210 0.0250

Clinker 0.0005 ±0.00036 0.0006



Figure 7-1: Results of laboratory analysis for mercury content in FDG and coal

Other emissions from the kiln include hydrogen chloride (HCl), ammonia (NH3) and sulphur trioxide (SO3). NO2 is formed through oxidation of nitric oxide (NO) in air. NO is formed at high combustion temperatures in the kiln and emitted in the exhaust gas fumes. Ozone is formed from NOx and reactive hydrocarbons in the presence of sunlight. However, with the limited source of hydrocarbons, ozone formation is not expected to be significant. Secondary formation of sulphuric and nitric acid or their salts can occur when SO2 and NOx react with atmospheric moisture, oxygen and other particulate matter.

7.1.2. Upset Process Emissions The following are regarded as emergency conditions under which the current abatement equipment on the Kiln stack will be not operate efficiently or will be by-passed:

• High carbon monoxide concentrations • Kiln start-up • Kiln shutdown

On the current plant this will result in visible dust emissions from the stacks. PPC currently have procedures which make provision for the recording of any such excursions on their SCADA system. Table 7-5 below provides a breakdown of the number of carbon monoxide trips on the unit for the period and the incremental impact on the emissions from the kilns over an annual period.



Table 7-5: Availability of electrostatic precipitators (%) October 2007 to June 2008 at PPC Riebeek

Oct Nov Dec Jan Feb Mar Apr May Jun

Kiln 1 98.82 99.6 99.94 99.91 99.94 99.99 99.95 99.87 99.83

Kiln 2 99 99 99.99 99.99 99.99 99.99 99.97 99.95 99.96 The procedure makes further provision that should the upset condition last longer than 10 minutes production staff is notified so as to attempt to reduce the impact to a 30 minute period. The DEA Chief Air Pollution Control Officer (CAPCO) has to be notified of the condition should this extend beyond 30 minutes. Particulate emissions are the most significant pollutant during the upset conditions provided above. However, due to the relatively short duration of these conditions, the health risk impact, which is measured against a daily average exposure, is not significantly higher than the impact during normal operation. The increased emission during a daily excursion is calculated to be about 7.5% above the normal emission rate for 98% removal efficiency. Two shut-downs are normally planned annually. During the start-up period (about 15 hours), either oil or diesel can be used to perform the heating process. Only once the kiln has reached the appropriate temperature of 300°C to 320°C is coal fed into the system. If diesel fuel is used, the air emissions of particulates and sulphur dioxide would be less than oil and coal firing. The latter two fuels contain more sulphur and have the tendency to produce more visible particulate matter. PPC indicated that only diesel fuel is currently being used in the start-up procedure. The most significant pollutant emissions during start-up conditions are considered to be particulates, sulphur dioxide, oxides of nitrogen and carbon monoxide. During shut-down periods, air emissions of the same pollutants would occur. However, during the cooling period through the de novo synthesis window (200 to 450°C), there is the additional risk of increased dioxin and furan generation. Since the shut-down and start-up conditions occur relatively infrequent, the overall impact of the air pollution is considered to be more of a nuisance risk rather than a health risk. This also applies to the potential risk of increased dioxin/furan levels, as these emissions contribute relatively little to the annual emissions.

7.1.3. Synopsis of Current PPC Riebeeck Process Air Emissions The applicable emission factors for fugitive dust emissions are discussed in Appendix C. Estimated total annual uncontrolled TSP and PM10 emissions for each source type are given in Table 7-6. Entrainment from road surface due to haul vehicle activity is clearly the most significant airborne particulate (TSP) emitter, with a contribution of 69.6% to the total dust generated if



lef6t unmitigated. The quarry operations is estimated to be second (8.9%), followed by the kiln (6.4%) and clinker cooler (6.9%) emissions. Wind erosion was calculated to be a relatively small contributor, with the most significant source being the exposed areas around the facility. The crushing & screening and the milling operations contribute about 7.7% in total, with the raw mill being the most significant. The table also shows that the total particulate emissions can be more than halved by controlling unpaved road emissions by 75%. Similar to TSP, entrainment from road surface due to haul vehicle activity contributes the most PM10 to the total dust generated (50.4%). The kiln emissions is estimated to be second (14%), followed by the clinker cooler (13.8%) and the raw mill (8.9%) emissions. It was estimated that in-pit sources contribute about 5.7%. Similar to TSP, controlling the unpaved roads by 75%, the PM10 emissions can be reduce by about 40%. Table 7-6: Airborne particulate emission rates for current PPC Riebeek facility

Location Emissions (tpa) TSP PM10

Processing Pant Dry Kiln (emission control: ESP) 51.8 41.4 Clinker Cooler (emission control: ESP) 50.4 40.4

Materials Preparation Crushing and Screening (no emission control) 10.6 8.5 Limestone Transfer (no emission control) 0.2 0.1 Raw Mill (emission control: ESP) 32.6 26.1 Finish Mill (emission control: FF & ESP) 14.8 11.8

Miscellaneous Diffuse Sources Material handling/transfer points 0.93 0.33 In-pit operations (e.g. excavation) 67.1 16.8 Paved and unpaved roads:

uncontrolled 593.1 167.4 75% control 148.3 41.9

Wind Erosion Coal stockpile (no control) 0.16 0.01 Limestone stockpiles (no control) 0.0003 0.0001 Sand stockpiles (limited coverage) 0.01 0.004 Run of Mine stockpile (no control) 0.0001 0.00004 Exposed areas of continual activity (no control) 0.03 0.01 Discard dump 0.02 0.01 TOTAL

Uncontrolled Roads 821.8 312.9 75% Controlled Roads 377.0 187.4



The estimated metal composition of the overall particulate matter emissions from the site is given in Table 7-7. Calcium, followed by silicon, aluminium and iron are the major constituents. Chlorides and sulphates are the main salts as summarised in Table 7-8. Table 7-7: Estimated elemental distribution of the most important elements in the airborne particulates (all air emissions)

Element Estimated contribution (%) Ca 45% Si 8.2% Al 2.1% Fe 1.2% Mg 0.7% K 0.3% Cl 15% S 2.5% P 0.5% Zn 0.004% Cu 0.01% Ni 0.003% Sr 0.3% Ti 0.2%

Mn 0.05% Na 0.1%

Table 7-8: Estimated metal-associated compounds in all airborne particulate emissions

Compound Estimated contribution (%) PM10 Emission Rate (t/a) Chlorides 68 199 Sulphates 20 59 Nitrates 0.5 1.5 Ammonium 11 32 The process exhaust gases applicable to the requirements of the Minimum Emission Limit Standards are summarised in Table 7-9. The amount of mercury contained in the raw kiln feed was calculated using the chemical analysis given in Table 7-4. Using the maximum mercury concentration in the feed material, the amount of mercury entering the kiln was estimated to be 0.0014 g/s. This results in a stack gas concentration of about 0.06 mg/Nm³. Applying an ESP removal efficiency of 26% (Davis 2000), the concentration reduces to about 0.04 mg/Nm³, which is marginally below AEL limit value of 0.05 mg/Nm³. The heavy metal combination of As+Sb+Pb+Cr+Co+Cu+Mn+V+Mn is estimated to be about 2.3 to 2.4 mg/Nm³, which is above the required 0.5 mg/Nm³.



Table 7-9: Estimated pollutant emission rates in the kiln flue gas to be reported in AEL

Pollutant

Total Emissions

(g/s)

Emission Limit(a)

(mg/Nm³)





7.1.4. Vehicle Generated Exhaust Emissions Air pollution from vehicle emissions may be grouped into primary (CO2, CO, NOx, VOC, SO2, and PM) and secondary pollutants (NO2, ozone, sulphuric acid, sulphates and nitrates). Primary pollutants are those emitted directly into the atmosphere, and secondary, those pollutants formed in the atmosphere as a result of chemical reactions, such as hydrolysis, oxidation, or photochemical reactions. As with any form of combustion, the sole reason for carbon monoxide formation in the vehicle engine is due to a lack of available oxygen within the combustion zone. This is caused by an over rich mixture, or locally poor fuel volatilisation/mixing with air. Nitrogen oxides are formed during coinciding conditions of high temperature and pressure and excess air, and the residence time at these conditions. There are significant differences in this regard between petrol and diesel engines, with proportionately more NO2 in the exhaust of a diesel vehicle than a petrol vehicle, due to the excess air combustion system of the diesel engine, but with NO still the predominant form of NOx for both. Another differentiating feature is that NOx output increases with higher engine load, which is the workhorse role, traditionally performed by the diesel engine, hence the usual association between NOx and diesels. Particulate matter emissions can result from both petrol and diesel vehicles, proportionately more by mass from the latter due to the less volatile character of diesel. Particulates from diesel vehicles consist of three components – carbonaceous soot formed during combustion, heavy hydrocarbons condensed or adsorbed on the soot, and sulphates/bound water. Primary soot particulates are small spheres of graphitic carbon, and are formed mainly during the diffusion-burning phase of combustion, by the thermal decomposition of the fuel,



and rapid polymerisation of resulting unsaturates, such as acetylene, at moderately high temperatures under oxygen deficient conditions. Most of the soot formed during combustion is subsequently burned during the later portions of the expansion stroke; in a modern diesel engine less than 10% of the soot formed in the cylinder survives to be emitted. Perhaps the most significant balance is between the PM and NOx emission species, which are in direct conflict with regards to the optimised combustion conditions. Beyond this there will be the tendency for increased PM emission with poor engine service condition, particularly as affects the proper functioning of the fuel injection process, and air induction. Apart from soot itself, most of the particulate mass from a diesel engine consists of heavy hydrocarbons adsorbed or condensed on the soot. This is derived partly from the lubricating oil, partly from unburned fuel and partly from compounds formed during combustion. Diesel fuel has traditionally contained more sulphur than petrol, as only with the recent emissions regulatory attention has there been a drive to refine down the natural petroleum sulphur content. As sulphates comprise a significant proportion of the particulate mass, removing sulphur from the fuel makes a direct contribution to reducing PM emission. Table 7-10: Estimated vehicle exhaust emissions due to the current PPC Riebeeck West operation

Pollutant Baseline Emission (g/km-hr)

Peak Average CO 2 912.8 705.2 NOx 573.1 153.3 NO2 49.0 14.8 VOC 300.7 74.0 PM 6.5 2.0 CO2 105 889 28 559 SO2 10.8 3.4 Methane 10.2 2.6 Non-Methane VOC 275.5 67.6 1,3-butadiene 3.3 0.8 formaldehyde 6.2 1.6 toluene 31.6 7.6 ethlybenzene 8.8 2.1 m- and p-xylene 16.1 3.9 o-xylene 9.4 2.3 styrene 2.1 0.5 benzene 16.9 4.1

From the Traffic Assessment Report (Robertson 2011), it was determined that in total there are 198 loaded road trucks (HGV) entering and leaving the Riebeek West site each week when the plant is fully operational, with a similar number of empty vehicles arriving and departing. The total road truck traffic generated by the site is therefore 396 HGV’s/week, or on average some 79 HGV’s per working day assuming a 5-day week which gives the worst case situation. The reality is that the plant is not always fully operational, and that manufacturing activities do occur throughout the 7-day week. It follows there will be



occasions where road deliveries occur over weekends. The road based trips are fairly evenly distributed throughout the normal working day between 05:00 and 21:00, with the peak truck movements reaching some 12 trips per hour. The same study also determined that private vehicles add on average some 500 light vehicle trips, 25 minibuses and 2 bus trips per day. Emissions were calculated using the COPERT (Appendix B) methodology and summarised in Table 7-10. The particulate matter emission factors reported in COPERT refer to PM2.5, as the coarse fraction (PM10) is negligible in vehicle exhaust.

7.1.5. Vehicle Generated Dust Emissions (Non-Exhaust) The particulate matter emissions reported in the previous section refer to exhaust emissions only. Non-exhaust contribution to total PM emissions includes tyre wear, brake wear and road surface wear (European Environmental Agency, EEA 2009), and dust originating on the vehicle itself. The actual rate of tyre wear depends on a large number of factors, including driving style, tyre position, vehicle traction configuration, tyre material properties, tyre and road condition, tyre age, road surface age, and the weather. The particulate emission rates for the various vehicles and source locations were calculated with the vehicle information described in the previous section. In 1989 the US-EPA published a report that included total suspended particulates (TSP) emission factors for uncovered haul trucks (Countess Environmental, 2004). This emission rate is directly proportional to the air movement experienced by the exposed material (i.e. sum of wind speed and train speed). A total suspended particulate (TSP) emission factor equation for uncovered haul trucks was included in a report published by the US-EPA in 1989. The hourly emission rate for fugitives from uncovered haul trucks can be estimated from the following equation

( ) UsmmgTSP ⋅= 0506.0// 2 Where, U is the sum of the wind speed and vehicle speed in metres per second (m/s). [The original emission factor had units of lb/yd²/hr: TSP = 0.00015 U, and U in miles per hour]. PM10 is approximately 16.5% of TSP (from particle size distribution of product PPC). Taking into account different vehicle speeds (varying from 40 to 60 km/hr) and the prevailing wind speed for every hour, it was estimated that the average amount of cement-containing particulates from haul trucks per hour would be 59 g (TSP), 10 g (PM10) and 5 g (PM2.5) for the approximately 2.3 km through the town of Riebeek West. For peak hourly haul trucks, the estimates are 142 g (TSP), 23 g (PM10) and 13 g (PM2.5), respectively. Table 7-11: Calculated daily average particulate emission rates for different vehicles

Vehicle Type Particulate Emission Rate (g/km-hr)

TSP PM10 PM2.5 Passenger Cars 101.36 20.59 5.60 Light Delivery Vehicles 10.40 2.24 0.74 Heavy Vehicles 232.59 45.79 13.98



Total 344.35 68.62 20.33 Table 7-12: Calculated airborne particulate emission rates for different sources of emissions (daily averages)

Source of Emission

Particulate Emission Rate (g/km-hr) TSP PM10 PM2.5

Wheel Entrainment 312.54 59.99 14.51 Wear & Tear 3.09 1.89 1.05

Exhaust 2.41 2.41 2.41 Truck Load 26.30 4.33 2.36

Total 344.35 68.62 20.33

Table 7-13: Calculated airborne particulate emission rates for different vehicles (peak hour)


TSP PM10 PM2.5 Passenger Cars 1 618.11 325.83 85.97 Light Delivery Vehicles 163.51 32.97 8.97 Heavy Vehicles 581.62 115.44 36.51 Total 2 363.24 474.25 131.45

Table 7-11 is a summary of the emissions per vehicle type. Heavy vehicles clearly contribute the most particulate emissions (approximately 79%). The contributions per emission location are summarised in Table 7-12. Wheel entrained dust constitutes the greatest portion of the total with approximately 90% for TSP, 87% for PM10 and 71% for PM2.5, respectively. The various contributions are summarised in Figure 7-2 for the daily average condition and Figure 7-3, for the peak hourly condition, respectively. Table 7-14: Calculated airborne particulate emission rates for different sources of emissions (peak hour)

Source of Emission


Wheel Entrainment 2 245.98 431.12 104.30 Wear & Tear 37.73 23.62 13.02 Exhaust 7.68 7.68 7.68 Truck Load 71.86 11.84 6.45 Total 2 363.24 474.25 131.45

The particulate contribution due to passenger cars during the peak morning hours (Table 7-13) appears to be disproportionally larger than the average daily conditions (Table 7-11). This is due to the expected large number of passenger, minibuses and bus traffic during the early morning compared to the haul truck traffic.



Figure 7-2: Summary of vehicle-related airborne particulate contributions for the current PPC Riebeeck West operation as an average over the day



Figure 7-3: Summary of vehicle-related airborne particulate contributions for the current PPC Riebeeck West operation during peak hour



Particulate emissions from unpaved roads, such as the DR1158 are dominated by the wheel generated dust. These emissions are determined by vehicle speed, and the moisture and silt (particle sizes less than 75 µm) contents of the road surface. Moisture content could be as low as a few percent when dry to saturation after a good rainfall. Typical average values are in the range of 1% to 13%. Similarly, silt fractions can vary significantly with typical values ranging between 2% and 35%. The emission factors to estimate these emissions are provided in Appendix C. It was given from the Transport Assessment (Robertson 2011) that the current maximum daily average number of heavy duty vehicles on the DR1158 is 59 with approximately 409 other vehicles. Given that the road condition could vary significantly, a range of particulate emissions were calculated and summarised in Table 7-15. The average vehicle speed was assumed to be 88 km/hour. Table 7-15: Calculated airborne particulate emission rates for different gravel road conditions

Road Condition Particulate Emission Rate (g/km-hr)

TSP PM10 PM2.5 Silt = 35%; Moisture = 2% 20 767 7 537 754 Silt = 4.5%; Moisture = 5% 1 647 702 70 Silt = 1%; Moisture = 13% 549 257 26

7.2. Proposed Operation Emissions

7.2.1. Routine Process Emissions The two operating scenarios (years 2025 and 2040) were selected to illustrate the different phases of the proposed project. Whereas emissions from the cement production facility would remain the same, fugitive dust emissions would differ due to differences in road infrastructure and overburden dumping areas. Unmitigated and 75% emission control on the unpaved roads were also included. The emissions are summarised in Table 7-16. Table 7-16: Airborne particulate emission rates for upgraded PPC Riebeek facility


Processing Pant Precalciner/Preheater Kiln (emission control: FF) 68.0 54.4 Clinker Cooler (emission control: ESP) 24.7 19.7

Materials Preparation Crushing and Screening (emission control: FF) 0.7 0.6 Limestone Transfer (no emission control) 0.2 0.1 Coal Mill (emission control: FF) 8.9 7.1 Cement Mill (emission control: FF) 11.3 9.0

Miscellaneous Diffuse Sources Material handling/transfer points




2025 3.11 0.87 2040 3.90 1.09

In-pit operations (e.g. excavation): 2025 121.8 49.9 2040 158.9 65.6

Paved and unpaved roads (no control) 2025 uncontrolled 1584.3 447.2

2025 75% controlled 396.1 111.8 2040 uncontrolled 5284.5 1491.7 2040 75% controlled 1321.1 372.9

Wind Erosion Coal stockpile (no control) 0.16 0.01 Limestone stockpiles (no control) 0.0003 0.0001 Sand stockpiles (limited coverage) 0.01 0.004 Run of Mine stockpile (no control) 0.0001 0.00006 Exposed areas of continual activity (no control) 0.04 0.01 Discard dump 0.02 0.01 TOTAL

2025 uncontrolled unpaved roads 1823.2 588.9 2025 75% controlled unpaved roads 635.0 253.5

2040 uncontrolled unpaved roads 5561.3 1649.3 2025 75% controlled unpaved roads 1597.9 530.5

The emissions of pollutants which apply to the Minimum Emission Limit Standards are shown in Table 7-17. Table 7-17: Estimated pollutant emission rates in the new Kiln/Raw Mill and Coal Mill flue gas to be reported in AEL

Pollutant Total

Emissions (g/s)

Emission Limit(a)

(mg/Nm³)



(b) – Mercury emissions based on mass balance of coal and FDG introduced into the kiln



The amount of mercury contained in the raw kiln feed was estimated using the chemical analysis given in Table 7-4. Using the maximum mercury concentration in the kiln feed, the amount of mercury entering the kiln was calculated to be 0.0031 g/s. This results in a stack gas concentration of about 0.04 mg/Nm³. Applying a fabric filter removal efficiency of 39% (Davis 2000), the concentration would reduce to about 0.02 mg/Nm³, which is below AEL limit value of 0.05 mg/Nm³. The heavy metal combination of As+Sb+Pb+Cr+Co+Cu+Mn+V+Mn is estimated to be 0.2 mg/Nm³, which is within the required limit of 0.5 mg/Nm³.

7.2.2. Kiln / Raw Mill Stack It was assumed that all gas leaving the raw mill/s would be vented through the main kiln stack. There are two scenarios: raw mill on and raw mill off:

Raw mill off: Comparing volumetric flows estimated by the potential suppliers, the maximum gas flow was taken as 420 000 (actual) Am³/h at 240°C. Detailed information given by one supplier shows a stack height of 110m and an exit diameter of 3.4m. Comparison of preheater heights between the various suppliers indicates that this height may conservative and therefore a height of 100m has been selected. Based on these dimensions, the assumed exit velocity is 12.9 m/s.

Raw mill on: Assuming 40% of the exit gas is routed to the raw mill and is cooled to 90°C, and there is false air ingress and water vapour increasing the volume by approximately 10%, there will be approximately 130 800 Am³/h of gas at 90°C combining with 252 000 Am³/h gas at 240°C. A simple weighted average calculation gives a combined temperature of 188°C, and the combined gas flow at this temperature will be 392 500 Am³/h. The exit velocity under these conditions will be 12.0 m/s.

7.2.3. Clinker Cooler An average specific vent air flow of 1.0 Nm³/kg clinker was assumed, based on data given by the suppliers. It was also assumed that an electrostatic precipitator would be used for de-dusting, to allow the possible future installation of a co-generation plant. Typical vent air temperatures from the suppliers averaged at approximately 280°C (Dwaalboom kiln 2 cooler vent gas is at 290°C). Based on 2 300 t clinker per day, this equates to 95 800 Nm³/h vent air or 194 000 Am³/h. Based on layouts and building heights (including situation of the plant offices), a stack height of 35m was assumed, with an exit diameter of 2.5m. This equates to an exit velocity of 11 m/s.

7.2.4. Coal Mill Comparison with specific flow information from PPC’s De Hoek project, an exhaust gas flow of 45 000 Am³/h was assumed, at 80°C. This corresponds to information supplied by most of



the Riebeeck upgrade tenderers. Based on structure dimensions, a stack height of 40m was assumed, with an exit diameter of 1m, giving an exit velocity of 15.9 m/s.

7.2.5. Cement Mills There is a range of different options offered by the suppliers, varying in the number of dust collectors. For this assessment, it is assumed that there would be a single exit point for all of the process gas. Information from the suppliers provided the total flow to be de-dusted of approximately 75 000 Am³/h at 100°C. Assuming a stack height of 40m and an exit diameter of 1.7m, the air exit velocity will be 9.2 m/s.

7.2.6. Exhaust Gas Composition For the kiln / raw mill stack gas, and the coal mill stack gas, the maximum emissions will be (reported under dry conditions and at 10% oxygen): Dust: 30 mg/Nm³ NOx: 800 mg/Nm³ SO2: 50 mg/Nm³ When the raw mill is running, there will be a slight reduction in SO2 and NOx due to dilution and scrubbing, for the purpose of the assessment, it was assumed that the concentrations remain at these levels. For the clinker cooler and cement mills, there is no combustion gas involved and the only pollutant will be dust. The maximum specified dust emission is 30 mg/Nm³ for both processes.

7.2.7. Correction for moisture and oxygen To correct to conditions of dry gas and 10% oxygen, it has been assumed (based on Dwaalboom Kiln 2 data) that for the kiln / raw mill stack, the moisture content is 7.5% and the oxygen level is 7.5%. For the coal mill, the moisture content is 10.8% and the oxygen level is 8.8%. There is no correction for oxygen applicable to the clinker cooler and cement mills. It is assumed that the moisture content of the cooler gas is negligible and that of the cement mill exhaust gas is 20% (from water injection).

7.2.8. Upset Process Emissions The abatement equipment proposed for the new plant (kiln / raw mills, coal mill and finishing mills) are all bag filter arrangements, except the clinker cooler, which will be an electrostatic precipitator. There will be no ‘upset’ or ‘start-up’ issues since these filters operate effectively as soon as the plant starts. Under sever conditions, which would result in a major



temperature excursion in the kiln / raw mill filter, the filter material may be destroyed. However, there will be automatic systems in place to prevent this with emergency fresh air dampers. Bag filters do not lose efficiency; however, a bag filter can become inefficient under the following conditions:

• The fan feeding the bag house trips (mechanical failure); and • The bags become damaged.

The efficiency (and availability) can be ensured through engineering measures. The following measures are recommended to maximise efficiency of dust removal:

• Have a maintenance schedule for the unit; • Use broken bag detectors (triboelectric probes) to monitor for bag integrity; • Install a baghouse with some redundancy so that a cell in the baghouse can be

isolated and repaired while the unit is still on-line • Have an automatic bag cleaning system as part on the baghouse. Typical

configurations use reverse airflow, mechanical shaking, vibration or compressed air pulsing

The bag filter arrangement is most likely to be more efficient than the current ESPs, provided the availability can be kept as close to 100% as practically possible. It was estimated that on an annual basis, the incremental increase in upset dust emissions would only be 1%. However, during an event where the baghouse is bypassed, the emissions would be unacceptably high. The only ESP proposed for the new plant will be removing dust from the clinker cooler exhaust gas. Since the air used in the cooler contains carbon monoxide, there is no opportunity for a possible gas explosion. The ESP would also operate from the start of the plant, without needing special ‘start-up’ treatment. The only realistic upset condition, which could be associated with the ESP, would be a power failure when the ESP would become ineffective.

7.2.9. Vehicle Generated Exhaust Emissions From the Traffic Assessment Report (Robertson 2011), it was determined that in total there would be an additional 58 haul truck trips per day. It was also given that the private vehicles remain the same as for the baseline condition, i.e. some 500 light vehicle trips, 25 minibuses and 2 bus trips per day. As for the baseline, the road based trips are fairly evenly distributed throughout the normal working day between 05:00 and 21:00, with the peak truck movements reaching some 30 trips per hour.



Emissions were calculated using the COPERT (Appendix B) methodology and summarised in Table 7-18. The baseline emission rates have also been included in the table for comparison. The largest increases in emissions are predicted to be sulphur dioxide (61.7%), fine particulate matter (56.1%) and nitrogen dioxide (51.3%). This is due to the increased haul truck emissions. Table 7-18: Estimated vehicle exhaust emissions due to the current and proposed PPC Riebeeck West operation

Pollutant Emission Rate (g/km-hr)

Baseline Proposed Difference Peak Average Peak Average Peak Average

CO 2 912.8 705.2 2 930.1 711.9 0.6% 1.0% NOx 573.1 153.3 670.8 191.3 17.0% 24.8% NO2 49.0 14.8 68.5 22.4 39.9% 51.3% VOC 300.7 74.0 310.5 77.8 3.3% 5.2% PM 6.5 2.0 9.5 3.2 45.3% 56.1% CO2 105 889 28 559 123 204 35 293 16.4% 23.6% SO2 10.8 3.4 16.3 5.5 50.2% 61.7% Methane 10.2 2.6 11.0 2.9 7.5% 11.2% NMVOC 275.5 67.6 284.5 71.1 3.3% 5.2% 1,3-butadiene 3.3 0.8 3.6 1.0 8.9% 13.8% formaldehyde 6.2 1.6 7.0 1.9 12.3% 18.4% toluene 31.6 7.6 31.6 7.6 0.003% 0.005% ethlybenzene 8.8 2.1 8.8 2.1 0.000% 0.000% m-, p-xylene 16.1 3.9 16.2 3.9 0.6% 0.9% o-xylene 9.4 2.3 9.5 2.3 0.4% 0.6% styrene 2.1 0.5 2.2 0.5 2.5% 4.0% benzene 16.9 4.1 17.0 4.1 0.05% 0.09%

7.2.10. Vehicle Generated Dust Emissions (Non-Exhaust) The particulate matter emissions reported in the previous section refer to exhaust emissions only. Non-exhaust contribution to total PM emissions includes tyre wear, brake wear and road surface wear (European Environmental Agency, EEA 2009), and dust originating on the vehicle itself. The actual rate of tyre wear depends on a large number of factors, including driving style, tyre position, vehicle traction configuration, tyre material properties, tyre and road condition, tyre age, road surface age, and the weather. The particulate emission rates for the various vehicles and source locations were calculated with the vehicle information described in the previous section. Since the number of haul trucks travelling through Riebeek West remains the same as with the baseline, it was estimated that the average amount of cement-containing particulates from haul trucks per hour would be 59 g (TSP), 10 g (PM10) and 5 g (PM2.5) for the



approximately 2.3 km through the town of Riebeek West. For peak hourly haul trucks, the estimates are 142 g (TSP), 23 g (PM10) and 13 g (PM2.5), respectively. Table 7-19 is a summary of the emissions per vehicle type. Heavy vehicles clearly contribute the most particulate emissions (approximately 83%). The contributions per emission location are summarised in Table 7-20. Wheel entrained dust constitutes the greatest portion of the total with approximately 89% for TSP, 87% for PM10 and 72% for PM2.5, respectively. The various contributions are summarised in Figure 7-2 for the daily average condition and Figure 7-3, for the peak hourly condition, respectively. Table 7-19: Calculated airborne particulate emission rates for different vehicles (daily averages) for the proposed upgrade


TSP PM10 PM2.5 Passenger Cars 101.52 20.75 5.76 Light Delivery Vehicles 10.53 2.37 0.87 Heavy Vehicles 565.82 110.08 32.43 Total 677.87 133.20 39.06

Table 7-20: Calculated airborne particulate emission rates for different sources of emissions (daily averages) for the proposed upgrade

Source of Emission


Wheel Entrainment 606.25 116.37 28.15 Wear & Tear 4.35 2.60 1.44 Exhaust 3.76 3.76 3.76 Truck Load 63.52 10.47 5.70 Total 677.87 133.20 39.06

Table 7-21: Calculated airborne particulate emission rates for different vehicles (peak hour) for the proposed upgrade


TSP PM10 PM2.5 Passenger Cars 1 618.52 326.25 86.39 Light Delivery Vehicles 163.84 33.30 9.29 Heavy Vehicles 1 409.05 275.14 82.39 Total 3 191.41 634.68 178.07



Figure 7-4: Summary of vehicle-related airborne particulate contributions for the proposed upgraded PPC Riebeeck West operation as an average over the day



Figure 7-5: Summary of vehicle-related airborne particulate contributions for the current PPC Riebeeck West operation during peak hour



Table 7-22: Calculated airborne particulate emission rates for different sources of emissions (peak hour) for the proposed upgrade

Source of Emission


Wheel Entrainment 2 975.17 571.09 138.17 Wear & Tear 40.84 25.38 14.00 Exhaust 11.16 11.16 11.16 Truck Load 164.24 27.06 14.75 Total 3 191.41 634.68 178.07

The particulate emission rates from unpaved roads, such as the DR1158, were calculated using the emission calculation method summarised in Appendix C. It was given from the Transport Impact Assessment (Robertson 2011), that the daily average number of heavy duty vehicles on the DR1158 could potentially increase from 59 to 65, with approximately 409 other vehicles. To illustrate the effect of the road variability on the emissions, a range of particulate emissions were calculated and summarised in Table 7-23. The average vehicle speed was assumed to be 88 km/hour. Table 7-23: Calculated airborne particulate emission rates for different gravel road conditions with the potential increased number of heavy vehicles for the proposed upgrade

Road Condition Particulate Emission Rate (g/km-hr)

TSP PM10 PM2.5 Silt = 35%; Moisture = 2% 21 303 7 732 773 Silt = 4.5%; Moisture = 5% 1 689 720 72 Silt = 1%; Moisture = 13% 563 264 26

7.3. Agricultural Activities It is necessary to understand the agricultural activities in order to calculate of wind erosion potential and emissions from the use of farming equipment. Depending on the rain, sowing of seeds starts early in May up to about mid-June. The most optimum period is the first two weeks in May. Sprouting occurs approximately 10 to 14 days after sowing the seed. The plant growth up to the ripening phase requires approximately 130 days after sowing. Reaping occurs after the drying period and is approximately 150 days after sowing. Using this information, the canopy and soil cover were estimated as summarised in Table 7-24. The following farming activities were assumed in the calculations:

January Dicing, Tilling, Chiselling February Ripping, Sub-soiling March Land Planning & Floating April Weeding May Weeding June Weeding



July Weeding August Weeding September Harvesting October Harvesting November Stubble/Root Cutting December Root Cutting

Table 7-24: Estimated canopy and soil cover.

Month Canopy Cover Soil Cover January ~0% 50% February ~0% 5% March ~0% 5% April ~0% 5% May 27% ~0% June 50% ~0% July 57% ~0% August 68% ~0% September 82% ~0% October 85% ~0% November ~0% 50% December ~0% 50%

The wind erosion from the surrounding farming land was estimated using the methodology adapted by CARB (1997) which was based on the work by (Cowherd et al 1988):

''VkAIKCLE = Where E = particulate emission rate (tons/acre/yr) k = PM10/TSP factor (0.5) A = Portion of total wind erosion losses that would become suspended

(0.025) I = Erodibility (tons/acre/yr) K = Surface roughness factor C = Climatic factor L’ = Unsheltered Field Factor V’ = Residue Factor The climatic factor is calculated according to:

23 /0828.0 PEWSC = Where

WS = Mean monthly wind speed (km/hr) 10 metres above the ground PE = Thornthwaite’s precipitation-evaporation index



⎟⎠⎞

⎜⎝⎛

+=

2.1264.1

TPPE

Where

P = Average monthly precipitation (mm) where all values less than 12.5 mm have been assigned the value of 12.5 mm

T = Average monthly temperature (°C) The residue factor is obtained from the canopy and soil cover estimates, as follows

)201.0exp()(' 7366.0CCgrowingV −=

)0438.0exp()_(' SCharvestpostV −= Where, CC = Canopy cover (%) SC = Soil cover (%) According to the soil analyses of the region, the general classification is as follows: Sandy-Loam : 85% Loamy-Sand : 8% Clayey-Loam : 7% Based on this classification, the erodibility (I) was estimated to be 219 t/ha per annum. The unsheltered field width (L) was taken as 2000 ft (wheat) during the crop season and 759 (ft) during the rest of the year (Cowherd et al 1988). The surface roughness factor (K) was taken as 0.6 (wheat) during the crop season and 1 during the other months (Cowherd et al 1988). The particulate emissions from farming activities were estimated using single-valued emission factors, as given in Table 7-25. Table 7-25: Emission rate factors for farming activities.

Land Preparation Emission Rate (g/m²-pass) TSP PM10

Root Cutting 0.160 0.034 Dicing, Tilling, Chiseling 0.640 0.135 Ripping, Sub-soiling 2.455 0.516 Land Planning & Floating 6.672 1.401 Weeding 0.427 0.090

The calculated monthly average particulate emission rate is summarised in Table 7-26.



Table 7-26: Calculated emission rate from surrounding agricultural land.

Month Particulate Emissions Rate

(g/m²-s) Percentage Contribution

TSP PM10 Wind Erosion Farming Activities Jan 3.29E-07 9.20E-08 45% 55% Feb 3.47E-06 1.44E-06 85% 15% Mar 2.74E-06 6.49E-07 19% 81% Apr 1.72E-07 3.83E-08 10% 90% May 1.60E-07 3.37E-08 1% 99% Jun 1.65E-07 3.46E-08 ~0% ~100% Jul 1.59E-07 3.35E-08 ~0% ~100% Aug 1.59E-07 3.35E-08 ~0% ~100% Sep 1.28E-10 6.42E-11 ~100% ~0% Oct 5.94E-11 2.97E-11 ~100% ~0% Nov 8.03E-08 2.23E-08 42% 58% Dec 9.83E-07 4.74E-07 97% 3%



8. BASELINE AIR POLLUTION Measured and calculated emissions from the current PPC Riebeeck cement manufacturing facility were used to predict the ground level air concentrations and fallout rates in the vicinity of the operation. In addition, an attempt was made to estimate the contribution of particulate emissions from the surrounding agricultural land, which included wind erosion of exposed areas and farming activities. The following section provides a brief description of the dispersion model, the uncertainties typically associated with dispersion models, input parameters and the simulation results.

8.1. Atmospheric Dispersion Model Selection

8.1.1. Modelling of Process, Fugitive Dust and Agricultural Sources Dispersion models compute ambient concentrations as a function of source configurations, emission strengths and meteorological characteristics, thus providing a useful tool to ascertain the spatial and temporal patterns in the ground level concentrations arising from the emissions of various sources. Increasing reliance has been placed on concentration estimates from models as the primary basis for environmental and health impact assessments, risk assessments and emission control requirements. It is therefore important to carefully select a dispersion model for the purpose. Gaussian-plume models are best used for near-field applications where the steady-state meteorology assumption is most likely to apply. Apart from the Kasteelberg Mountain towards the south and southwest of PPC, the surrounding topography is fairly flat comprising of undulating hills. Perhaps the most widely used dispersion model internationally has been the US.EPA Industrial Source Complex Short Term model (ISCST3). This model is based on the Gaussian plume equation and therefore assumes a uniform wind field. This model has relatively recently been replaced by the new generation, AERMOD model, which albeit still based on the Gaussian plume, has been improved with respect to its treatment of atmospheric dispersion classifications and topography. AERMOD was developed with the support of the AMS/EPA Regulatory Model Improvement Committee (AERMIC), whose objective was been to include state-of-the-art science in regulatory models (Hanna et al, 1999). The AERMOD is a dispersion modelling system consists of three components, namely: AERMOD (AERMOD Dispersion Model), AERMAP (AERMOD terrain pre-processor) and AERMET (AERMOD meteorological pre-processor). AERMOD is designed to predict pollution concentrations from continuous point, flare, area, line and volume sources. AERMOD offers new and potentially improved algorithms for plume rise and buoyancy, and the computation of vertical profiles of wind, turbulence and temperature, however, retains the single straight line trajectory limitation of ISCST3 (Hanna et al, 1999).



The AERMET is a meteorological pre-processor for the AERMOD. Input data can come from hourly cloud cover observations, surface meteorological observations and twice-a-day upper air soundings. Output includes surface meteorological observations and parameters and vertical profiles of several atmospheric parameters. The AERMAP is a terrain pre-processor designed to simplify and standardize the input of terrain data for the AERMOD. Input data includes receptor terrain elevation data. The terrain data may be in the form of digital terrain data. Output includes, for each receptor, location and height scale, which are elevations used for the computation of air flow around hills. There will always be some error in any geophysical model, but it is desirable to structure the model in such a way to minimise the total error. A model represents the most likely outcome of an ensemble of experimental results. The total uncertainty can be thought of as the sum of three components: the uncertainty due to errors in the model physics; the uncertainty due to data errors; and the uncertainty due to stochastic processes (turbulence) in the atmosphere. The stochastic uncertainty includes all errors or uncertainties in data such as source variability, observed concentrations and meteorological data. Even if the field instrument accuracy is excellent, there can still be large uncertainties due to unrepresentative placement of the instrument (or taking of a sample for analysis). Model evaluation studies suggest that the data input error term is often a major contributor to total uncertainty. Even in the best tracer studies, the source emissions are known only with an accuracy of ±5%, which translates directly into a minimum error of that magnitude in the model predictions. It is also well known that wind direction errors are the major cause of poor agreement, especially for relatively short-term predictions (minutes to hourly) and long downwind distances. All of the above factors contribute to the inaccuracies not even associated with the mathematical models themselves. Similar to the ISCST3 a disadvantage of the model is that spatial varying wind fields, due to topography or other factors cannot be included. Also, the range of uncertainty of the model predictions is about -50% to 200%. Nonetheless, the US EPA regards the model to be satisfactory for regulatory purposes. The accuracy improves with fairly strong wind speeds and during neutral atmospheric conditions. Input data types required for the AERMOD model include: source data, meteorological data (pre-processed by the AERMET model), terrain data and information on the nature of the receptor grid

8.1.2. Modelling of Vehicle Emissions along Roads Modelling of air pollution from road sources has generally been accomplished well with the aid of Gaussian dispersion plume models. Furthermore, vehicular emissions are generally considered as a “line source” in air dispersion models. Although AERMOD is based on the Gaussian plume model, and is also capable of simulating line source configurations, it does not allow for the effects of vehicle wakes and therefore increased entrainment which leads to



increased dilution. Wakes are generated as a result of vehicular movements. They are one of the dominant factors in dispersing the pollutants in calm meteorological conditions when wind velocity is <1 m/sec (Chock, 1978). Gokhale and Khare (2007) found that during unstable atmospheric conditions, the increased dilution varies between 1.63 and 0.3 (wind near perpendicular to road) and 2.5 and 0.8 (winds near parallel to road). During neutral atmospheric conditions, the increased dilution is in the range of 0.84 to 0.4 (wind near perpendicular to road) and 1.7 to 0.7 (for winds near parallel to road). During stable atmospheric conditions, the increased dilution is in the range of 1.91 to 0.85 (wind near perpendicular to road) and 3.1 and 0.3 (winds near parallel to road). Due to their simplicity and direct applicability for estimates on a local scale, various versions of the Gaussian line source model have been used for dispersion evaluations from a road. Such models include HIWAY-2 (Petersen, 1980), CALINE-4 (Benson, 1984 and 1992), GM (Chock, 1978), GFLSM (Luhar and Patil, 1989), OMG (Kono and Ito, 1990) and CAR-FMI (Härkönen 1996). The ROADWAY (Eskridge and Catalano, 1987) and MGO (Berlyand et al., 1990) models are based on a K-theory (Eulerian) approach. An obvious advantage of the K-theory models is that they can readily include the interaction of diffusion processes and chemical transformation. Due to its widely accepted use, the dispersion model CALINE4, developed by the California Department of Transportation (Caltrans) was adopted in this project. CALINE4 is the last in a series of line source air quality models developed by Caltrans. It is based on the Gaussian diffusion equation and employs a mixing zone concept to characterise pollutant dispersion over the roadway. Given source strength, meteorology and site geometry, CALINE4 can predict pollutant concentrations for receptors located within 500 metres of the roadway.

8.1. Dispersion Model Meteorological Data Requirements

8.1.1. AERMOD Model AERMOD requires two specific input files generated by the AERMET pre-processor. AERMET is designed to be run as a three-stage processor and operates on three types of data (upper air data, on-site measurements and the national meteorological database). Since the model was designed for the USA environment, various difficulties are found compiling the required dataset in the desired format for other environments. The main data shortfalls include the following:

• No national meteorological database containing all the data fields in the desired format exists; and

• Surface meteorological stations seldom measure all the required parameters (such as solar radiation, cloud cover and humidity).

For the purpose of the current study use was made of PPC Riebeek West’s meteorological data recorded near the plant for a 2010. Upper air data for the region was obtained from the South African Weather Service.



8.1.2. CALINE Model The CALINE model requires hourly average wind speed, wind direction, ambient air temperature, atmospheric stability (1 to 7) and mixing height. Apart from mixing layer depths and atmospheric stability, these parameters were obtained directly from the observations made at the PPC Riebeek West meteorological station for 2010. Mixing depths and atmospheric stability, which provide an indication of the potential for vertical dispersion, are not readily measured and need therefore be estimated. The mixing layer depths were estimated using models that derive the thickness from some of the other parameters that are routinely measured, e.g. solar radiation and temperature. For the current study, day-time mixing heights were calculated with the prognostic equations of Batchvarova and Gryning (1990), while night-time boundary layer heights were calculated from various diagnostic approaches for stable and neutral conditions. Wind speed and solar radiation were used to calculate hourly atmospheric stabilities based on the Pasquill-Gifford Stability classification scheme as an indication of the dispersion potential of the region

8.2. Source Data Requirements

8.2.1. AERMOD Model The AERMOD model is able to model point, area, line and volume. All well-defined emissions (e.g. stacks) were simulated as point sources. Fugitive emissions were simulated either as area sources (e.g. wind erosion) or volume sources (e.g. transfer points). Emissions in the quarry were simulated as an “in-pit” source.

8.2.2. CALINE Model Only line sources can be simulated with the CALINE model. Different road section orientations (with respect to north) and widths were assumed to provide conditions that would illustrate the effect of wind direction.

8.3. Modelling Domain

8.3.1. AERMOD Model The dispersion of pollutants emanating from the processing facilities was modelled for an area covering 20 km by 20 km. The area was divided into a grid matrix with a resolution of 200 m by 200 m, with the facility located approximately in the centre of the receptor area. AERMOD simulates ground-level concentrations for each of the receptor grid points. The height of each receptor point was set to 1.5 m above ground level to account for the breathing zone. Topography was also included in the model setup.



8.3.2. CALINE Model Since the concentrations of vehicle emissions dilute relatively fast when traversed from the road edge, it is often more informative to illustrate the predicted concentrations as “transects” or “cut-outs” of the concentration profile perpendicular to the road. In this way, the concentration profile can be viewed at small spatial intervals, typically 2 to 5 m.

8.4. Simulation Results

8.4.1. Inhalable Particulate Air Concentrations The emissions from the surrounding agricultural land could only be quantified on a monthly basis. It is therefore believed that short-term excursions (i.e. daily average) could not be predicted with confidence. The annual average prediction of inhalable particulate emissions from agricultural sources is given in Figure 8-1. It has to be realised that these concentrations were from emissions within the 20 km by 20 km study area only. Since agricultural activities extend beyond this area, it is expected that additional airborne particulates could be imported into this study area. It should also be noted that the decreased concentrations towards the edges shown in the figure are due to the omission of dust emissions from agriculture beyond the modelling domain. Nonetheless, it is expected that the annual average concentration due to agricultural land in of the order of about 15 to 30 /m³. The estimated highest daily average concentration is in the order of about 100 to 200 µg/m³. Figure 8-2 is the annual average PM10 predictions of emissions from PPC Riebeeck and agricultural land. The maximum concentration predicted was about 50 µg/m³. Given that the contribution from agricultural land further outside the study area was not included, this concentration could potentially be higher (estimated at about 60 µg/m³). The contribution of PPC’s emissions is about 30 to 40 µg/m³ near the facility, reducing down to about 10 µg/m³, approximately 3 km downwind of the plant. The predicted annual average concentration is therefore expected to exceed the DEA annual average limit of 40 µg/m³ mainly within the PPC facility and perhaps about 1 km towards the north, with increased agricultural activities. The highest daily average predictions from the PPC cement facility is summarised in Figure 8-3. The highest concentration outside the facility (excluding the agricultural contribution) is about 42 µg/m³. The maximum observed concentrations at Delectus, the Rugby field and at the Meteorological Station (Section 6.2.2) were 17, 66 and 50 µg/m³, respectively, which indicate that the main contributor at these locations are most likely PPC. The predicted time series at Ongegund and Riebeek West (north), given as the highest daily average predictions in these areas with 2010 meteorological data, are shown in Figure 8-5 and Figure 8-6, respectively. The highest predicted value at Ongegund was about 3.7 µg/m³ and 4.8 µg/m³ along the northern parts of Riebeek West.



Figure 8-1: Predicted annual average inhalable particulate concentrations from agricultural sources

8.4.1.1. Paved Road Traffic Emissions

The emission rate of ambient cement particulates generated from passing haul trucks carrying cement bags (assume as worst-case, 40 trucks trips per day) were calculated and the dispersion of these predicted. Since these emissions are released from the back of the truck, the effective release height was assumed to be 3 m. During peak truck movements (i.e. worst-case, 12 trips per hour), the PM10 air cement concentration was predicted to be about 4 µg/m³, with the total PM10 air concentrations (i.e. including all other dust) predicted to be about 108 µg/m³. The daily average concentration transects for north-south and east-west orientations are summarised in Figure 8-4. The predicted daily average air concentration of inhalable cement is relatively low (less than 1 µg/m³). The daily maximum total suspended and PM10 concentrations including all sources as discussed in 7.1.4 and 7.1.5 were estimated to be about 64 µg/m³ and 13 µg/m³, respectively (Figure 8-4).



Figure 8-2: Annual average inhalable particulate concentrations with PPC Riebeeck’s current operation including emissions from agricultural land.

8.4.1.2. Unpaved Road Traffic Emissions

Due to the concern regarding the impact of airborne dust from gravel roads (e.g. the D1158), particulate emission rates were calculated (Section 7) to illustrate the existing air concentration potentialss nearby these roads. Table 8-1: Calculated airborne particulate concentration rates for different gravel road conditions (baseline)

Road Condition Location

Particulate Concentration (µg/m³) TSP PM10 PM2.5

Silt = 35%; Moisture = 2%

On road 3 860 1 401 140 50m from road 2 158 783 78

Silt = 4.5%; Moisture = 5%

On road 306 130 13 50m from road 171 73 7





Figure 8-3: Predicted highest daily average inhalable particulates from PPC Riebeeck cement facility (this excludes emissions from agricultural land due to the difficulty in estimating these emissions on a short term basis)

Figure 8-4: Predicted daily average particulate air concentrations at various distances, perpendicular from the road edge



Figure 8-5: Daily average PM10 predictions in Ongegund for 2010 (current conditions)

Figure 8-6: Daily average PM10 predictions in Riebeek West (north) for 2010 (current conditions)



Figure 8-7: Predicted highest daily average dust fallout rates

It is clear that under certain road conditions, i.e. dry silty surfaces (clayey roads), very high particulate concentrations can result, even at distances significantly far from the road. In areas were the silt loading is low (i.e. sandy roads), the particulate air concentrations could be significantly lower; by as much as 97%.

8.4.1. Dust Fallout The predicted dust fallout from the PPC cement facility is provided as the highest daily average (based on the maximum monthly fallout predictions) and the annual average fallout. The predicted daily average fallout is predicted to be relatively low (Figure 8-7) beyond the facility. The maximum fallout rate was predicted to be less than 100 mg/m² per day. This is partially attributed to the relatively fine character of the emissions from the facility, i.e. the particles remain airborne for considerable distances before being deposited. Large particles would deposit nearer to the source of emission, typically less than 200 m from the source (e.g. access road).



Figure 8-8: Predicted annual average particulate fallout rates from the cement facility

The predicted annual fallout rate is provided in Figure 8-8. The annual fallout nearby the facility is in the range of 1 800 mg/m² to 14 000 mg/m² (5 mg/ m² per day to 35 mg/m² per day for 365 days). From the composition in Table 7-7, the estimated calcium deposition is about 45% of the values given in Figure 8-8, i.e. between about 820 and 5 700 mg/m² per annum. The upper predictions are similar to the annual average calcium deposition estimated by Lambrechts (2007) (Section 6.2.1), which were based on measurements, i.e. 4 640 and 7 300 mg/m² per annum. The predicted maximum daily fallout rate of cement from haul trucks on the side of the road could vary considerably, ranging from about 4 to 24 mg/m² per day within a zone of about 10 m from the road edge.

8.4.1. Oxides of Nitrogen The highest hourly and annual average predictions for oxides of nitrogen emissions are given in Figure 8-9 and Figure 8-12, respectively.



Figure 8-9: Highest predicted hourly average oxides of nitrogen concentration (nitrogen dioxide constitutes less than 2% of these emissions)

Although the maximum NOx predicted concentrations (291 µg/m³) exceed the DEA NO2 hourly limit value of 200 µg/m³, it must be realised that NO2 constitutes a relatively small fraction (2%) of the total NOx. The NO2 concentration is therefore expected to be considerably less, i.e. well below the limit value of 200 µg/m³. The predicted time series at Ongegund and Riebeek West (north), given as the highest predictions in these areas per hour for 2010, are shown in Figure 8-10 and Figure 8-11, respectively. The highest predicted value at Ongegund was about 145 µg/m³ and 12.6 µg/m³ along the northern parts of Riebeek West. The predicted highest annual average concentration of 2 µg/m³ is below the DEA annual NO2 limit of 40 µg/m³. The predictions confirm the low NO2 concentrations observed at the monitoring site, with the maximum monthly observation of 8 µg/m³ at the PPC Meteorology Station.



Figure 8-10: Highest hourly average NOx concentration predictions for 2010 at Ongegund

Figure 8-11: Highest hourly average NOx concentration predictions for 2010 in the north of Riebeek West residential area



Figure 8-12: Predicted annual average NOx concentrations for current PPC operation

8.4.1. Sulphur Dioxide The highest hourly, daily and annual average predictions for sulphur dioxide emissions are given in Figure 8-15, Figure 8-16 and Figure 8-17, respectively. The maximum hourly concentration is 184 µg/m³, predicted to occur along the Kasteelberg mountain due to the elevated topography. This value is below the DEA hourly limit of 350 µg/m³. The predicted time series at Ongegund and Riebeek West (north), given as the highest predictions in these areas per hour for 2010, are shown in Figure 8-13 and Figure 8-14, respectively. The highest predicted value at Ongegund was about 91 µg/m³ and 7.1 µg/m³ along the northern parts of Riebeek West. Similarly, the highest daily and annual averages were predicted to be 11 µg/m³ and 1.3 µg/m³, which are below the DEA limits of 125 µg/m³ and 50 µg/m³, respectively.



Figure 8-13: Highest hourly average SO2 concentration predictions for 2010 at Ongegund

Figure 8-14: Highest hourly average NOx concentration predictions for 2010 in the north of Riebeek West residential area



Figure 8-15: Predicted sulphur dioxide highest hourly average concentration for current PPC operation

Similar to the findings for NO2 concentrations, the predictions confirm the low observed at the monitoring site, with the maximum monthly observation of 2 µg/m³ at the Conference Centre.

8.4.1. Mercury The Department of Environmental Affairs developed a mercury guideline which was intended to be protective given multiple pathways of exposure. This guideline value was given as 0.04 µg/m³ for chronic exposures. The predicted maximum annual average concentration is 0.00008 µg/m³ (Figure 8-18). These values are below the DEA guideline.



Figure 8-16: Predicted sulphur dioxide highest daily average concentration for current PPC operation

8.4.1. Benzene The SANS annual average limit for benzene is currently 10 µg/m³ (valid until 31 December 2014). The predicted annual average concentration of 0.002 µg/m³ is well below this limit. The estimated cancer risk for a lifetime exposure to this concentration is insignificant.

8.4.2. Dioxins and Furans The highest predicted annual average concentration for total dioxins and furans is 1x10-9 µg/m³. The estimated cancer risk for a lifetime exposure to this concentration is insignificant.



Figure 8-17: Predicted annual average sulphur dioxide concentration for current PPC operation



Figure 8-18: Predicted chronic exposure to mercury emissions from the current PPC facility



Figure 8-19: Predicted long-term benzene concentrations from current PPC facility



8.5. Summary of Predicted Maximum Ground Level Concentrations A summary of maximum predicted concentrations for various pollutants are summarised in Table 8-2. Table 8-2: Comparison of predicted current air concentrations to various guidelines and standards




24-hour 120(a1) 75(a2) 75 70 (h) 100 – 150

Annual 50(a1) 40(a2) 40 50 (h) 50




Benzene

Annual 10(a1) 5(a2) 5 - 1(i) 0.002




µg/m³ to 20 µg/m³ (g) - An annual guideline is given at not being needed, since “compliance with the 24-hour level will assure lower levels for the annual average”. (h) - WHO (2000) issued linear dose-response relationships for PM10 concentrations and various health endpoints with no specific guideline provided. WHO (2005) made available during early 2006 proposes several interim target levels (see Section 3).



(i) - This value is based on 1 in hundred thousand cancer risk (US EPA). (i) - This value is based on 1 in hundred thousand cancer risk (WHO). (k) - California Office of Environmental Health Hazard Assessment (l) - US EPA inhalation reference Concentration (RfC). (m) - DEAT published limit intended to be protective given multiple pathways of exposure.

Table 8-3: Predicted metal concentrations for current cement facility

Metal Predicted


Guideline (µg/m³)


Silver (Ag) 0.0000004 - N/A Aluminium (Al) 0.010 - N/A Arsenic (As) 0.00001 0.03 (1) 0.004(1) Barium (Ba) 0.0003 - N/A Beryllium (Be) 0.0000005 0.02 (1) 0.0001 (1) Calcium (Ca) 0.2 - N/A Cadmium (Cd) 0.000006 0.9 (1) 0.001(1) Chromium (Cr) 0.000006 (3) 0.1 (1) 0.007 [as Cr (VI)] (1) Copper (Cu) 0.004 - N/A Fluoride (F) 0.0006 - N/A Iron (Fe) 0.01 - N/A Mercury (Hg) 0.00008 1 N/A Potassium (K) 0.01 - N/A Manganese (Mn) 0.0006 0.15 (2) N/A Sodium (Na) 0.03 - N/A Lead (Pb) 0.001 0.5 (2) N/A Selenium (Se) 0.06 - N/A Thallium (Th) 0.1 - N/A Titanium (Ti) 0.0001 - N/A Zinc (Zn) 0.000004 - N/A Notes: (1) - US Environmental Protection Agency (2) - World Health Organisation (3) - Emissions are for total chromium. Typically 0.7% could be Cr(VI) (PCA 1992), but some




Table 8-4: Comparison of predicted air concentrations of current haul truck fleet emissions in Riebeek West to relevant guidelines and standards




24-hour 120(a1) 75(a2) 75 70 (h) 12.8

Annual 50(a1) 40(a2) 40 50 (h) 2.6

Diesel Particulate Matter Annual 0.6(i) 0.09

Cement Dust 24-hour 7.7 Annual 0.2

Nitrogen Dioxide 1-hour 200 200 - 200 14.3 Annual 40 40 - 40 0.6

Sulphur Dioxide 1-hour 350 (350)(e) - - 3.2 24-hour 125 125 125 125 (20) (f) 0.6 Annual 50 50 50 (g) 0.1


Benzene

Annual 10(a1) 5(a2) 5 - 1(i) 0.15

1,3-Butadiene Annual - - - 0.3(i) 0.03 Notes: (a) - Current South African Standards (a1) - Valid until 31 December 2014 (a2) - Valid from 1 January 2015 (b) - SANS 1929 Standards (c) - World Bank Guidelines (d) - World Health Organisation Guidelines (e) - Only 10-minute average standards, but a value of 350 has been included as an equivalent. (f) - The latest (2005) WHO guidelines reduced the daily guideline significantly reduced from 125

µg/m³ to 20 µg/m³ (g) - An annual guideline is given at not being needed, since “compliance with the 24-hour level will assure lower levels for the annual average”. (h) - WHO (2000) issued linear dose-response relationships for PM10 concentrations and various health endpoints with no specific guideline provided. WHO (2005) made available during early 2006 proposes several interim target levels (see Section 3). (i) - This value is based on 1 in hundred thousand cancer risk (US EPA).



8.6. Analysis As expected, the most significant pollutant is predicted to be airborne particulates, with predicted exceedances of the DEA daily average limit beyond the PPC cement facility, when considering emissions from other activities in the region (mainly agriculture). Transporting ore and overburden within the mining area and product out of the facility constitute the largest source of emissions. The simulations assumed the current practice of water sprays on the road surfaces. The watering programme controls these emissions by about 75%, which reduce the total TSP and PM10 emissions by about 54% and 40%, respectively. None of the other pollutants considered in the assessment exceeded any of the DEA limit values and standards. Those pollutants which do not have DEA standards were compared to international best practice guidelines and similarly shown to be well within the guidelines. The European Union introduced an annual limit value for SO2 of 20 µg/m³ that is protective for all ecosystems and which would be needed in regions without very sensitive ecosystems. The predicted annual average concentration for SO2 is 1.3 µg/m³. Similarly, the critical levels for NOx, used by the United National Economic Commission for Europe to map exceedence areas, was given as 30 µg/m³ for annual means. The predicted annual average concentration for NOx is 2.2 µg/m³. The impact from these two pollutants in vegetation is therefore seen to be insignificant. The predicted dustfall level to outside PPC boundary is predicted to be "Slight", i.e. dustfall is barely visible to the naked eye. Nearby the facility and access road, the predictions indicate “medium” dustfall. The South African Department of Minerals and Energy (DME) use the 1 200 mg/m2/day threshold level as an action level. In the event that on-site dustfall exceeds this threshold, the specific causes of high dustfall should be investigated and remedial steps taken. An attempt was made to estimate emissions from road haulage of cement products. Fugitive cement dust from bag carriers was calculated and the predicted daily average inhalable particulates (PM10) were estimated to be about 1 µg/m³. The predicted maximum daily fallout rate of cement from haul trucks on the side of the road could vary considerably, ranging from about 4 to 24 mg/m² per day within a zone of about 10 m from the road edge. Haul trucks are also responsible for airborne particulates from wheel entrainment and diesel particulate matter (DPM). The maximum daily average PM10 concentration for all particulate emissions from vehicles associated with PPC was calculated to be 13 µg/m³. DPM constitutes about 3% of this. The annual average DPM concentration was calculated to be 0.09 µg/m³, which is small compared to the US EPA’s inhalation Reference Concentration (RfC) of 5 µg/m³.



The predicted air concentrations for all emissions were compared to their relevant health risk guidelines. These compounds included potential carcinogens (arsenic, beryllium, cadmium, chromium), mercury, manganese and lead. The incremental cancer risks were calculated to be considerably less than 1 in a million. It is generally regarded that such a risk is trivial and therefore acceptable. The annual average air concentrations for mercury, manganese and lead are well below the chronic reference limits provided by the US EPA and WHO.



9. PREDICTED AIR POLLUTION FOR PROPOSED PROJECT As with the establishment of the current baseline air emissions and ground level concentrations, the anticipated emissions (Section 7.2) for the proposed upgraded PPC Riebeeck cement manufacturing facility were used to predict the ground level air concentrations and fallout rates in the vicinity of the operation. The results of the simulations are presented below.

9.1. Atmospheric Dispersion Model Selection The same dispersion models used to calculate the baseline air concentration distributions were utilised, i.e. the US EPA’s AERMOD for the cement plant and associated activities on site, and Caltrans’ CALINE4 model for vehicle emissions.

9.2. Dispersion Model Meteorological Data The same meteorological data used to calculate the baseline air concentrations were used to predict the future scenarios.

9.3. Source Data Two future scenarios were included in the simulations to illustrate the dumping and mining phases. The two future scenarios for 2025 and 2040 were chosen. The first scenario is applicable to dumping option V1 - Phase 1, V2 and V3. The second scenario is applicable to option V1 - Phase 2.

9.4. Modelling Domain The same modelling domain and spatial resolutions used in the baseline predictions were used in the future scenarios.

9.5. Simulation Results

9.5.1. Inhalable Particulate Air Concentrations The predicted particulate air concentrations assume the emission controls proposed for the upgrade, i.e. ESP for the clinker cooler, bag filters for other process dust sources and regular watering of unpaved haul roads. The current watering programme provides approximately 75% emission control, and the same was assumed for the upgrade. The highest daily average PM10 concentration predictions from the proposed PPC Riebeeck upgrade are given in Figure 9-1 and Figure 9-2 for the two scenarios, respectively.



Figure 9-1: Highest daily average PM10 concentrations (2025)

Figure 9-2: Highest daily average PM10 concentrations (2040)



Figure 9-3: Annual average PM10 concentrations (2025)

Figure 9-4: Annual average PM10 concentrations (2040)



High daily average PM10 concentrations were predicted on the PPC mine, plant and overburden areas, with the highest daily averages predicted for the two scenarios of 308 µg/m³ and 1 212 µg/m³, respectively. However, these concentration levels are confined to the PPC operations only. The predicted time series at Ongegund, given as the highest daily average predictions using 2010 meteorological data, are shown in Figure 9-5 and Figure 9-6 for the future scenarios 2025 and 2040, respectively. The highest predicted value at Ongegund was about 1.5 µg/m³ and 7.1 µg/m³, for these two scenarios respectively. Similarly, the highest concentrations along the northern parts of Riebeek West were predicted to be approximately 16.9 µg/m³ and 16.5 µg/m³ for the two scenarios, respectively (Figure 9-7 and Figure 9-8). These are all well within the DEA limit value for daily average PM10 concentrations of 120 (until 30 December 2014) and 75 µg/m³ (from 1 January 2015). The maximum daily average concentrations predicted to occur along the R311 are about 55 µg/m³ (2025) and 90 µg/m³ (2040), respectively. The DEA PM10 standard allows four daily exceedances of the limit value. The zone within which the daily average PM10 concentration is predicted to exceed the 75 µg/m³ on four or more days per year is shown by the dotted line in Figure 9-9 (2025) and Figure 9-10 (2040). These were superimposed on the same predicted concentrations as in Figure 9-1 and Figure 9-2. From these figures it is clear that, given the assumed emission controls, the predicted PM10 exceedances of the standard would be relatively close to the operations. No violation of the standard is predicted at the residential areas of Ongegund and Riebeek West. The results for the annual average PM10 concentrations for the two scenarios are shown in Figure 9-3 and Figure 9-4, respectively. The highest predicted annual average concentrations outside the PPC operation is approximately 25 µg/m³, with relatively low concentrations predicted at Ongegund (2 µg/m³) and Riebeek West (16 µg/m³). These are all well within the DEA limit value for daily average PM10 concentrations of 50 (until 30 December 2014) and 40 µg/m³ (1 January 2015). However, in Figure 8-1 it was shown that the estimated annual average concentration due to agricultural activities is in of the order of about 15 to 30 /m³. It can therefore be expected that the cumulative annual average PM10 concentration immediately outside the PPC operation could be fairly close to the DEA limit value with the proposed upgrading.

9.5.1.1. Paved Road Traffic Emissions Since there would be no increase in haul trucks carrying PPC product or raw material through Riebeek West, the impacts would be the same as determined for the baseline. During peak truck movements (i.e. 11 to 12 trips per hour), the PM10 air cement concentration was predicted to be about 4 µg/m³, with the total PM10 air concentrations (i.e. including all other dust) predicted to be about 108 µg/m³. The predicted daily average air concentration of inhalable cement is relatively low (less than 1 µg/m³). The daily maximum total suspended and PM10 concentrations including all sources were estimated to be about 64 µg/m³ and 13 µg/m³, respectively.



Figure 9-5: Highest daily average PM10 predictions for 2010 at Ongegund for 2025

Figure 9-6: Highest daily average PM10 predictions for 2010 at Ongegund for 2040



Figure 9-7: Highest daily average PM10 predictions for 2010 at Riebeek West (north) for 2025

Figure 9-8: Highest daily average PM10 predictions for 2010 at Riebeek West (north) for 2040



Figure 9-9: Zone within which the 75 µg/m³ DEA daily average PM10 limit value would be exceeded for 4 or more days per year (2025)



Figure 9-10: Zone within which the 75 µg/m³ DEA daily average PM10 limit value would be exceeded for 4 or more days per year (2040)



9.5.1.2. Unpaved Road Traffic Emissions There is a potential that some raw material (e.g. sand) may be transported on gravel roads (e.g. the D1158). The projected heavy vehicle numbers on these roads would be 65 per day, which an increase of 6 per day from the current 59 per day. The particulate emission rates were calculated in Section 7 and the resulting impacts summarised in Table 9-1 and Figure 9-11. The increased heavy vehicle traffic could therefore result in a potential 2.6% increase in the nearby particulate impacts. Using the DEA limit values of 120 µg/m³ and 75 µg/m³, the predictions (Figure 9-11) show a slight increase in distance of impact of about 1 m for the former and 3 m for the latter limit. Table 9-1: Calculated airborne particulate concentration rates for different gravel road conditions (upgrade)

Road Condition Location Particulate Concentration (µg/m³)

TSP PM10 PM2.5 Silt = 35%; Moisture = 2%

On road 3 960 1 434 143 50m from road 2 214 804 80

Silt = 4.5%; Moisture = 5%




Figure 9-11: Predicted PM10 concentrations nearby unpaved roads, assuming 4.5% silt and 5% moisture



Figure 9-12: Predicted maximum daily dust fallout (2025)

Figure 9-13: Predicted maximum daily dust fallout (2040)



9.5.2. Dust Fallout The predicted dust fallout from the PPC cement facility with the proposed upgrade is provided in Figure 9-12 and Figure 9-13 as the highest daily average (based on the maximum monthly fallout predictions) for the two illustrative scenarios, respectively. The predicted daily average fallout is predicted to be relatively low beyond the facility. The maximum fallout rate was predicted to be less than 100 mg/m² per day. As indicated previously, this is partially attributed to the relatively fine character of the emissions from the facility, i.e. the particles remain airborne for considerable distances before being deposited. Large particles would deposit nearer to the source of emission, typically less than 200 m from the source (e.g. access road).

9.5.3. Oxides of Nitrogen The highest hourly and annual average predictions for oxides of nitrogen emissions for the proposed upgrade project are given in Figure 9-14 and Figure 9-18, respectively. For comparison, the concentration isopleths were kept the same as that used to construct the figures for the current conditions, i.e. Figure 8-9 and Figure 8-12. The number of hours in the year that are predicted to have hourly average concentration in excess of the NO2 limit value of 200 µg/m³ is displayed in Figure 9-15. The predicted maximum hourly average concentration is 550 µg/m³, which is predicted to occur along the eastern and western slopes of the Kasteel Mountain. Although this is higher than the baseline, the ratio is lower than the ratio of the two emissions, i.e. Concentrationupgrade/Concentrationbaseline < Emissionupgrade/Emissionbaseline. This is due to the extra dilution which is afforded with the increased stack heights proposed for the upgrade. Although the maximum NOx predicted concentrations (291 µg/m³) exceed the DEA NO2 hourly limit value of 200 µg/m³, it must be realised that NO2 constitutes a relatively small fraction (2%) of the total NOx. The NO2 concentration is therefore expected to be considerably less, i.e. well below the limit value of 200 µg/m³. It was also predicted that the maximum number of hourly exceedances of the DEA limit is 19 hours per year, which is less than the allowabkle 88 hours per year. The predicted time series at Ongegund and Riebeek West (north), given as the highest hourly average predictions for NOx using 2010 meteorological data, are shown in Figure 9-16 and Figure 9-17, respectively. The highest predicted value at Ongegund and Riebeek West (north) was about 336 µg/m³ and 15.8 µg/m³, respectively. The highest annual average of about 3 µg/m³ is well below the DEA limit values 40 µg/m³ for the annual average.



Figure 9-14: Highest predicted hourly average oxides of nitrogen concentration for the proposed upgrade

9.5.1. Sulphur Dioxide The highest hourly, daily and annual average predictions for sulphur dioxide emissions for the proposed upgrade project are given in Figure 9-19, Figure 9-22 and Figure 9-23, respectively. For comparison, the concentration isopleths were kept the same as that used to construct the figures for the current conditions, i.e. Figure 8-15, Figure 8-16 and Figure 8-17, respectively. The predicted concentrations are significantly lower than the baseline condition, with the maximum SO2 hourly average concentration of 34 µg/m³, the highest daily average concentration of about 2 µg/m³, and the highest annual average of about 0.2 µg/m³. These are well below the DEA limit values of 350 µg/m³ for the hourly, 125 µg/m³ for the daily and 50 µg/m³ for the annual average.



The predicted time series at Ongegund and Riebeek West (north), given as the highest hourly average predictions for SO2 using 2010 meteorological data, are shown in Figure 9-20 and Figure 9-21, respectively. The highest predicted value at Ongegund and Riebeek West (north) was about 22.4 µg/m³ and 1.0 µg/m³, respectively.

Figure 9-15: Predicted numbers of hourly exceedances of the NO2 limit value of 200 µg/m³ for proposed upgraded PPC operation

9.5.1. Mercury The Department of Environmental Affairs developed a mercury guideline which was intended to be protective given multiple pathways of exposure. This guideline value was given as 0.04 µg/m³ for chronic exposures. The predicted maximum annual average concentration is 0.0001 µg/m³ with the inclusion of FDG (Figure 8-18). These values are below the DEA guideline.



Figure 9-16: Predicted hourly average NOx concentrations in Ongegund for the proposed upgrade

Figure 9-17: Predicted hourly average NOx concentrations in Riebeek West (north) for the proposed upgrade



Figure 9-18: Predicted annual average NOx concentrations for proposed upgraded PPC operation

9.5.1. Benzene The SANS annual average limit for benzene is currently 10 µg/m³ (valid until 31 December 2014). The predicted annual average concentration of 0.006 µg/m³ is well below this limit. The estimated cancer risk for a lifetime exposure to this concentration is insignificant.

9.5.1. Dioxins and Furans The highest predicted annual average concentration for total dioxins and furans is 4x10-10 µg/m³. The estimated cancer risk for a lifetime exposure to this concentration is insignificant.



Figure 9-19: Predicted sulphur dioxide highest hourly average concentration for proposed PPC operation



Figure 9-20: Predicted hourly average SO2 concentrations in Ongegund for the proposed upgrade

Figure 9-21: Predicted hourly average SO2 concentrations in Riebeek West (north) for the proposed upgrade



Figure 9-22: Predicted sulphur dioxide highest daily average concentration for proposed PPC operation



Figure 9-23: Predicted annual average sulphur dioxide concentration for proposed PPC operation



Figure 9-24: Predicted chronic exposure to mercury emissions from the proposed PPC facility



Figure 9-25: Predicted long-term benzene concentrations from proposed PPC facility



9.6. Summary of Predicted Maximum Ground Level Concentrations A summary of maximum predicted concentrations for various pollutants are summarised in Table 9-2. Table 9-2: Comparison of predicted future air concentrations to various guidelines and standards




24-hour 120(a1) 75(a2) 75 70 (h) 100 – 150

Annual 50(a1) 40(a2) 40 50 (h) 50




Benzene

Annual 10(a1) 5(a2) 5 - 1(i) 0.006




µg/m³ to 20 µg/m³ (g) - An annual guideline is given at not being needed, since “compliance with the 24-hour level will assure lower levels for the annual average”. (h) - WHO (2000) issued linear dose-response relationships for PM10 concentrations and various health endpoints with no specific guideline provided. WHO (2005) made available during early 2006 proposes several interim target levels (see Section 3).



(i) - This value is based on 1 in hundred thousand cancer risk (US EPA). (i) - This value is based on 1 in hundred thousand cancer risk (WHO). (k) - California Office of Environmental Health Hazard Assessment (l) - US EPA inhalation reference Concentration (RfC). (m) - DEAT published limit intended to be protective given multiple pathways of exposure.

Table 9-3: Predicted metal concentrations for proposed upgraded cement facility

Metal Predicted


Guideline (µg/m³)






9.7. Analysis The most significant pollutant is predicted to be airborne particulates, with predicted exceedances of the DEA daily average limit beyond the PPC cement facility, when considering emissions from other activities in the region (mainly agriculture). Transporting ore and overburden within the mining area and product out of the facility constitute the largest source of emissions. The simulations assumed the current practice of water sprays on the road surfaces. The watering programme controls these emissions by about 75%, which reduce the total TSP and PM10 emissions by about 54% and 40%, respectively. None of the other pollutants considered in the assessment exceeded any of the DEA standards. Those pollutants which do not have DEA standards were compared to international best practice guidelines and similarly shown to be well within the guidelines. The predicted annual average concentration for SO2 is 0.2 µg/m³, which is well below the EU annual limit value for SO2 of 20 µg/m³ that is protective for all ecosystems. Similarly, the United National Economic Commission for Europe’s limit value of 30 µg/m³ for annual means is predicted not to be exceeded. The predicted annual average concentration for NOx is 3.2 µg/m³. The impact from these two pollutants in vegetation is therefore seen to be insignificant. The predicted dustfall level to outside PPC boundary is predicted to be "Slight", i.e. dustfall is barely visible to the naked eye. Nearby the facility and access road, the predictions indicate “medium” dustfall. The South African Department of Minerals and Energy (DME) use the 1 200 mg/m2/day threshold level as an action level. In the event that on-site dustfall exceeds this threshold, the specific causes of high dustfall should be investigated and remedial steps taken. The predicted air concentrations for all emissions were compared to their relevant health risk guidelines. These compounds included potential carcinogens (arsenic, beryllium, cadmium, chromium), mercury, manganese and lead. The incremental cancer risks were calculated to be considerably less than 1 in a million. The highest risk was calculated for chromium of 1 in 10 million. In this calculation it was assumed that all chromium emissions are hexavalent (Cr(VI). However, typically only 0.7% could be Cr(VI) (PCA 1992), with some results showing up to 20% (Lizarraga 2003). It is generally regarded that a risk of 1 in a million is trivial and therefore these impacts are acceptable. The annual average air concentrations for mercury, manganese and lead are well below the chronic reference limits provided by the US EPA and WHO.

9.8. Impact of Potential Overlap of Existing and Proposed Cement Production Facilities

It was given that the proposed upgrading of the manufacturing plant would cease all operations before the proposed new plant starts up.



10. MITIGATION MEASURES As depicted through this study, TSP and PM10 are the pollutants of main concern for the proposed upgrade of the cement production facility at PPC Riebeeck. It does not imply that the other pollutants are insignificant, but rather that the proposed emission controls inherent in the proposed plant design are sufficient and that further reduction measures would not be necessary. It is however important that the availabilities of the proposed control equipment be maintained at a high level, typically 98% and more. It is further proposed that raw material stockpiles (excluding limestone and coal) will be covered to contain and control dust generated during stacking, and to keep the material dry to avoid handling problems. The limestone blending beds will not be covered but there will be a facility to spray water onto the material just before stacking to reduce fugitive dust emissions. The following abatement measures are listed in addition to serve as a guideline in the mitigation of emissions. It is important to consider that these may not always be logistically feasible.

10.1. Construction PPC is proposing to upgrade certain sections of the existing Riebeek West manufacturing plant through the following:

• Replacing of two existing kilns with a single more efficient component • Decommissioning and removal of the two existing kilns • Upgrading of the existing raw milling facility to accommodate the increased

production rate • Installing of a new coal mill for indirect and inert operations • Upgrading of the existing cement milling facility • Converting each mill to a closed circuit operation via the installation of a high

efficiency separator • Upgrading of existing conveyor equipment • Installation of emission abatement technology to improve air quality

It is anticipated that the construction would continue for approximately 22 months. All of the planned improvements are to be undertaken on the existing plant site. Since these activities do not require major earthmoving and material transfer, it is not expected to generate significant amounts of fugitive dust. Any additional mitigation measure at the plant may therefore not specifically be necessary. However, it is expected that there would be an increased number of vehicles travelling to and from the site. This has the potential to generate more pollution associated with vehicles. According to the Traffic Specialist Study (Robertson 2011) and based on estimates made by PPC, the number of additional persons that could be employed on site during this period



could possibly reach between 600 and 800 persons. However, it is planned that the majority of construction personnel will be transported by bus rather than private vehicle. It is expected that there would be some 19 busses entering and a similar number leaving the site each day, while it was estimated that an additional 320 car trips could be generated per day. The number of construction vehicle related trips has been estimated at between 2 and 20 per day. The numbers provided are estimates, and are likely to change as more is known nearer to the time that construction commences. This anticipated increased number of vehicles would potentially increase the rate of entrained dust from access roads. This will be exacerbated during dry or windy conditions. If paving is not an option, regular water spraying has to be applied. It is therefore recommended that any unpaved road sections receive additional watering during periods of expected traffic peaks in the morning and afternoon. Clear labelling of all vehicles associated with the contract will help to identify any vehicles that are causing unnecessary re-suspended or fugitive dust emissions. Minimising dust and mud from the site entrance or exit will help prevent fugitive emissions being spread outside the site boundary by site vehicles. The control measures outlined below should provide the most effective ways to prevent re-suspension of road dust from a construction site so that no mud or dirt is deposited outside the plant boundary:

• Put in place procedures for effective cleaning of vehicles and inspection. Since these vehicles could carry mud onto the road surface leading to the R311, wheel washing could be necessary. If this proves not to be adequate, total vehicle washing must be applied.




The control of vehicle tailpipe emissions may be achieved by ensuring that vehicles are in good working condition and to minimize idling of equipment when not in use.

10.2. Operation

10.2.1. Unpaved Road Surfaces Control techniques for fugitive dust sources generally involve watering, chemical stabilization, and the reduction of surface wind speed through the use of windbreaks and source enclosures. Watering represents a commonly used, relatively inexpensive option,



but only serves as a temporary form of dust control. Although chemical treatment of the exposed surfaces is more expensive it provides for longer dust suppression. The use of chemicals may, however, have adverse effects on the receiving biophysical environment if not carefully administered (Cowherd et al, 1988). Controls and techniques to mitigate this source of emissions are indicated in Table 10-1.

10.2.1.1. Current Operation Although an accurate assessment of the current level of emission control from road surfaces is not easily established, based on the watering programme, an emission reduction of about 75% is realistically achievable. Increased emission reduction from unpaved road surfaces can be achieved by increasing the frequency of watering, or by chemical treatment. Appendix E provides the calculation of watering rates required to achieve selected emission control efficiencies. As expected, the highest control with the same water application rate would be achieved during the rainy season. To ensure 75% control efficiency, the application rate varies between 0.112 litres per m2 (June) to 0.475 litres per m2 (January). The calculated watering rates for the different months are summarised in Table 10-2. Table 10-1: Control Measures for Unpaved Roads (After EPA 1992)

Control Technique Description Source extent reduction

• Speed reduction • Traffic reduction

These controls limit the amount of traffic on an unpaved road or strict enforcement of speed limits.

Source improvement

• Paving • Gravel surface

These controls alter the road surface. These techniques are “once-off” control methods, therefore ensuring that periodic treatments are not normally required.

Surface Treatment

• Watering • Chemical stabilization

These control techniques require periodic reapplications. These treatments fall into two main categories, (i) wet suppression and (ii) chemical stabilization. Water is usually applied, utilising a truck with a gravity or pressure feed. This is only a temporary measure and periodic reapplications are necessary to achieve a substantial level of control efficiency Chemical suppressants have less frequent reapplication requirements. These are designed to alter the roadway, such as cementing loose material into a fairly impervious surface (hereby simulating a paved surface) or forming a surface which attracts and retains moisture (simulating wet suppression)



Table 10-2: Calculated watering rates for current PPC Riebeeck West cement facility to achieve 75% control efficiency from unpaved roads. These calculations excluded the effect of rainfall.

Month Water Spray Rate (litres/m² per hour) January 0.475 February 0.374 March 0.320 April 0.214 May 0.153 June 0.112 July 0.121 August 0.156 September 0.212 October 0.308 November 0.380 December 0.461 Annual Average 0.274

10.2.1.2. Proposed Upgrade

Great reductions can also be achieved with 75% control efficiency applied to the haul roads of the proposed cement manufacturing facility. The calculated hourly water application rates for the proposed facility with 23 haul trucks per hour is provided in Appendix E (Figure 19-3 (no rain) and Figure 19-4 (including rain)). For a 75% control efficiency, the application rate varies between 0.184 litres per m2 (June) to 0.780 litres per m2 (January). The calculated watering rates for the different months are summarised in Table 10-3. Table 10-3: Calculated watering rates for the upgraded PPC Riebeeck West cement facility to achieve 75% control efficiency from unpaved roads. These calculations included the effect of rainfall.

Month Water Spray Rate (litres/m² per hour) January 0.780 February 0.615 March 0.525 April 0.351 May 0.252 June 0.184 July 0.199 August 0.257 September 0.349 October 0.506 November 0.625 December 0.758 Annual Average 0.450



It should be noted that watering can only be expected to practically achieve control efficiencies of up to 70 - 75%. Chemical suppression or gravel covering (e.g. waste rock) should also be considered for the main haul roads.

10.2.2. Conveyor Belts Although airborne particulate emissions are not expected to be significant from conveyor belts, possible mitigation measures for potential implementation are nevertheless presented in Table 10-4. Table 10-4: Control Methods in Conveyor Usage

Dust Control Dust Suppression Side wind guards

Sprays at transfer points to wet dust and particles and prevent liberation thereof.

Covers on high and/or steep parts of the conveyor (where applicable) Belt cleaning Dust collection systems (These systems are used to capture, transport and separate dust that has been emitted. Dust collection provides a cost effective means of controlling respirable dust emission while wet sprays are effective in suppressing visible dust) (Environment Australia, 1998) Enclosure maintenance.

10.2.3. Overburden Dumps It is important to note developments in the understanding regarding large areas of exposed areas such as the overburden dumps. It was initially believed that wind entrains dust from the top surface of dumps with very little being entrained from the side surfaces. Subsequent research conducted both locally and internationally, has shown that the majority of the dust entrained from the top one-third of the side slopes facing the prevailing wind direction(s). Such dust may, however, be deposited on the top surfaces of the dumps and re-entrained under higher wind speeds (i.e. greater wind velocities are required for deflation at the surface of the dump since the approach to surface wind speed ratio is lower). The conclusion reached is that the upper wind-ward slopes of dumps are subject to the highest wind erosion losses and therefore need careful attention within dust control plans. The implementation of dust controls on the surface of the dump reduces the potential for re-entrainment if material is deposited on the surface. Vegetal cover retards erosion by binding the residue with a root network, by sheltering the residue surface and by trapping material already eroded. Sheltering occurs by reducing the wind velocity close to the surface, thus reducing the erosion potential and volume of material removed. The trapping of the material already removed by wind and in suspension in the air is an important secondary effect. Vegetation is also considered the most effective control measure in terms of its ability to also control water erosion. In investigating the feasibility of vegetation types the following



properties are normally taken into account: indigenous plants; ability to establish and regenerate quickly; proven effective for reclamation elsewhere; tolerant to the climatic conditions of the area; high rate of root production; easily propagated by seed or cuttings; and nitrogen-fixing ability. The long-term effectiveness of suitable vegetation selected for the site will be dependent on the nature of the cover, and the availability of aftercare. Rock cladding or armouring of the sides of dumps has also been shown in various international studies to be effective in various instances in reducing wind erosion of slopes. Cases in which rock cladding has been found to be effective in this regard generally involve rock covers of greater than 0.5 m in depth (Ritchey, 1989; Jewell and Newson, 1997). Short- to medium-term (temporary) control measures include watering, chemical suppression, the construction of wind breaks, and plough ridging. Wind barriers control wind erosion by reducing wind speeds. The flow behind the barrier is influenced strongly by the aerodynamic interaction between the barrier and the upstream wind field. The presence of the barrier results in a windward wind speed reduction zone, an over-speed zone above the barrier and a leeward wind speed-reduction zone. Observations have shown that maximum reductions in the windward wind speed occur within a downwind distance of 10H from the barrier (i.e. on the leeward side), with the flow becoming fairly normal at about 30H (where H represents the height of the barrier) (Wang and Takle, 1995). The positioning of the barrier perpendicular to the angle of the incidence of the wind would have the greatest control efficiency as may be expected. Increasingly oblique winds would give rise to lower control efficiencies, with airflow which is parallel to the barrier length not providing any control.

Figure 10-1: Deposition of dust in the lee of topographic obstacles due to flow divergence and reduction of the wind friction velocity. Dust deposition is prevented on windward slopes where flow convergence and speed-up occur.

Artificial wind breaks include reed fences, strewn pebbles or boulders (stone-mulching) and ridge-ploughing of the surface. Ridge ploughing is considered an effective temporary measure to control dust on fine-grained, flat surfaces such as the top of mine tailings dams. The low-level wind turbulence induced by the ridges causes dust to be lifted from the crests of the ridges and to be deposited immediately in the adjacent valleys (Figure 10-1). Ridge ploughing is considered an effective temporary measure to control dust on fine-grained, flat



surfaces such as the top of the dump. The low-level wind turbulence induced by the ridges causes dust to be lifted from the crests of the ridges and to be deposited immediately in the adjacent valleys.

10.2.4. Materials Handling Control techniques applicable to materials handling are generally classifiable as comprising (i) source extent reduction (e.g. mass transfer reduction), (ii) source improvement related to work practices and transfer equipment (e.g. drop height reduction and moisture retention), and (iii) surface treatment (e.g. wet suppression). Wet suppression is frequently used to reduce emissions from materials handling operations and was therefore selected for the purpose of the current study to determine the control efficiencies possible for the proposed development. Control efficiencies from the application of liquid spray systems at conveyor transfer points have in practice been reported to be in the range of 42% to 75%. The control efficiency of pure water suppression can be estimated based on the US-EPA emission factor which relates material moisture content to control efficiency. This relationship is illustrated in Figure 10-2. From the relationship between moisture content and dust control efficiency it is apparent that by doubling the moisture content of the material an emission reduction of 62% could be achieved.

Figure 10-2: Relationship between the moisture content of the material being handled and the dust control efficiency provided for calculated based on the US-EPA predictive emission factor equation for continuous and batch drop operations.

General engineering guidelines which have been shown to be effective in improving the control efficiency of liquid spray systems are as follows:



• Of the various nozzle types, the use of hollow cone nozzles tend to afford the greatest

control for bulk materials handling applications whilst minimising clogging; • Optimal droplet size for surface impaction and fine particle agglomeration is about

500μm; finer droplets are affected by drift and surface tension and appear to be less effective; and

• Application of water sprays to the underside of conveyor belts has been noted by various studies to improve the efficiency of water suppression systems and belt-to-belt transfer points.

10.2.5. Particulate Emissions from Haul Trucks The particulate emissions from haul trucks were calculated and included fugitive emissions from cement bag carriers, wheel entrainment and diesel particulate matter (DPM). It was conservatively assumed that there would be adequate supply of cement available on the truck to ensure continuous emissions of particulates. Cognisance must be taken that this may not always be the case. The predictions therefore reflect worse-case conditions.



11. IMPACT SIGNIFICANT RATING

11.1. Construction Phase Since all of the planned improvements would be undertaken on the existing plant site, and since these activities do not require major earthmoving and material transfer, it is not expected to generate significant amounts of fugitive dust. It is anticipated that the construction would continue for approximately 22 months. Due to the fact that insufficient construction detail was available at the time of the investigation, no detailed dispersion simulations were undertaken for this phase. The amount of total suspended solids based on a maximum construction area of 1 ha is estimated to be about than 2.6 tonnes per month. Based on this emission rate and assuming that PM10 is 50% of the total suspended particulates (TSP), it was estimated that the impact distance to the DEA daily average limit value of 120 µg/m³ would be confined to the plant. This takes into account the combined impact of the plant and construction emissions. In assessing the potential significance of impacts which may be related to the proposed operations, reference was made to the impact assessment model applied by Aurecon. The rating model is described in Appendix G. Table 11-1: Air impact assessment summary table for the Construction Phase

Impact

Pollutants Respirable dust (PM10) impacting on human

health Dust fallout (nuisance)

Spatial Scale of Impacts Site Specific Site Specific Magnitude of Impact Low Low Duration of Impact Construction Period Construction Period Consequence of Impact Medium Medium Probability of Impact Probable Probable Confidence Sure Sure Reversibility Reversible Reversible

Significance Without Mitigation Low Low With Mitigation Low Low

11.2. Proposed Upgrading of Plant The significance of air pollution impact of the proposed upgrading of the cement facility was assessed through consideration of two phases, namely 2025 and 2040. Only the impact of particulates is expected to vary with each of these three phases, since the clinker and cement production rates were assumed constant.



Table 11-2: Air impact assessment summary table for the proposed upgrade of the cement manufacturing facility

Exposure Pollutant

Impact Spatial

Scale of Impacts

Magnitude of Impact

Duration of Impact

Probability of Impact

Confidence Rating

Significance Without

Mitigation With

Mitigation Human Health

PM10 Local High Long Term Definite Sure High Low NO2 Local Low (a) Long Term Definite Sure (b) (b) SO2 Local Low Long Term Definite Sure (b) (b) CO Local Low Long Term Definite Sure (b) (b) HCl Local Low Long Term Definite Sure (b) (b) Benzene Local Low Long Term Definite Sure (b) (b) Dioxins/Furans Local Low Long Term Definite Sure (b) (b) Mercury Local Low Long Term Definite Sure (b) (b)

Nuisance TSP Local Medium Long Term Definite Sure Medium Low Vegetation SO2 Local Low Long Term Definite Sure (b) (b)

NOx Local Low Long Term Definite Sure (b) (b) TSP Local Low Long Term Definite Sure (b) (b)

Notes: (a) - Medium when comparing all NOx emissions to NO2 standard, and Low when estimated NO2 fraction of NOx is compared to standard (b) - No additional mitigation required



The significance rating of the proposed cement facility is given in Table 11-2. The ratings were obtained by applying the assessment criteria detailed in Appendix G. Only inhalable particulates and suspended particulate fallout would potentially result in significant impacts outside the PPC boundary if inadequate mitigation is applied. The impact of fallout is mainly within the first 200 m from the source, such as access roads, whereas the extent of exceeding the inhalable particulate standard may be up to 2 km from the site. The most significant area of impact would be over the R311 running along the western boundary. With mitigation, i.e. primarily controlling emissions from unpaved haul roads (at least 75% control efficiency), the zone of impact, as defined by the DEA daily average standard for PM10, can be minimised to only have an impact up to the boundary of the facility.



12. AIR POLLUTION MANAGEMENT SYSTEM Since particulate air concentrations are the main concern associated with the upgrading of the cement production facility at PPC Riebeeck, air quality management planning needs to specifically focus on the management and monitoring of particulate emissions and air concentrations. It is recommended that an Air Pollution Control System (APCS) be developed to include the following, but not limited to:

• pollution control methods; • monitoring; • performance indicators; • environmental reporting; and • public/community liaison.

These components are aimed at being a guideline for the implementation of such a system. A checklist for dust control which may be incorporated into the APCS is provided in Appendix D. The APCS should be implemented and revised by plant personnel on an on-going basis.

12.1. Ambient Monitoring PPC currently has a dustfall monitoring programme in place and measures local meteorological parameters. Continuation of this programme is recommended with the added inclusion of PM10 air concentrations. Considering the relatively low concentrations predicted for all pollutants other than airborne particulates (e.g. sulphur dioxide, oxides of nitrogen and carbon monoxide), it is not specifically recommended to include the observation of other air pollutants in the air pollution monitoring network. The ultimate goal of such a network is to demonstrate compliance to the relevant authorities, the immediate community as well as interested and affected parties. The aim of the monitoring network would be to meet the following objectives:


Identify probable problem areas Demonstrate compliance with accepted air quality standards and dustfall limits; To proved information to management in the respect of the effectiveness of

current control and suppression methods Temporal trend analysis Spatial trend analysis Demonstrate continuous improvement; and Facilitate dispersion models calibration (when required).



The demonstration of compliance with the DEA’s NAAQS would necessitate the measurement of inhalable particulates (PM10) using gravimetric measurement methods. Furthermore, the draft DEA regulation on dustfall measurements must be consulted and the applicable method (currently proposed ASTM D1739) used in the fallout network. The current methodology does conform to the ASTM D1739 methodology. It is recommended that the proposed PM10 monitoring instrument be co-located with the existing Meteorological Station. It is also recommended to position a dustfall instrument at this location.

12.2. Emission Monitoring Protocols

12.2.1. Continuous Emissions Monitoring System (CEMS) Based on the anticipated Minimum Emissions Standards the requirements for continuous emission monitoring are summarised in Table 12-1 for the proposed new plant. Table 12-1: CEMS monitoring requirements

Location Measurement Method Number of Samples/Duration

Source of analytical method

New Kiln and Raw Mill Stack

Stack Velocity Pitot tube 95 % of each hour

CEN, BSI, ISO, US EPA, ASTM,DIN, VDI

Stack Gas Temperature Type K thermocouple 95 % of each hour


Stack Oxygen content

Paramagnetic, electrochemical or zirconium oxide cell

95 % of each hour


Stack dust concentration/emission rate

Cross-duct opacity 95 % of each hour


Stack NOX concentration/emission rate

NDIR or NDUV 95 % of each hour

Stack SO2 NDIR or NDUV 95 % of each hour



Location Measurement Method Number of Samples/Duration


concentration/emission rate

Grate Cooler Stack

Stack Velocity Pitot tube 95 % of each hour


Stack Gas Temperature Type K thermocouple 95 % of each hour


Stack Oxygen content

Paramagnetic, electrochemical or zirconium oxide cell

95 % of each hour



Cross-duct opacity or tribolectric

95 % of each hour


The following should be included as part of the CEMS monitoring system:

o Maintenance programme;

o Calibration checks according to the equipment manufacturer’s manuals or as

stipulated by the Department of Environmental Affairs; and

o A minimum of one validation check per year or as stipulated by the Department of

Environmental Affairs for each of the stacks using isokinetic methods (see Table 12-2

below).

12.2.2. Isokinetic Sampling The grab sampling protocol summarised in Table 12-2 is recommended for the validation of the CEMS and for the assessment of emissions of pollutants not measured by the CEMS. The frequency of the sampling should be according to the requirements stipulated by the Department of Environmental Affairs.



Table 12-2: Annual Grab Sampling Protocol.

Location Measurement Number of Samples/Duration


All Stacks

Stack Velocity 3 runs of 1 hour each on each of the stacks


Stack Gas Density 3 runs of 1 hour each on each of the stacks


Stack Moisture content 3 runs of 1 hour each on each of the stacks



3 runs of 1 hour each on each of the stacks


New Kiln and Raw Mill Stack

SO2, CO and NOX 3 runs of 1 hour each on each of the stacks


HCl and HF 3 runs of 1 hour each on each of the stacks


Metals 3 runs of 1 hour each on each of the stacks


Dioxins and Furans

2 runs of 3 hours each on each of the stacks plus one field blank


12.2.3. Fugitive Emissions Ideally the recommended monitoring of fugitive dust from the plant should be along the fence line at 1 km intervals. Additionally the following should be monitored and reported:

• Daily visual check for smoke

• Daily visual check for fugitive dust and plumes

• CCTV surveillance of key release points

• Particle characterisation of dust fallout results

• Particle size distribution (< 75 µm) and moisture content analysis of silt at areas of

high fugitive dust on the site

• Log of average vehicle kilometres measured per month on the site by vehicle class



12.2.4. Process Parameters The following process parameters should be noted and controlled to minimise impacts to air from the kiln:

• Raw materials and fuels:

o Sulphur content

o Heavy metals content

o Halogens content

• Meantime between stops

• Raw mill downtime

• Set kiln process control strategies for:

o Back-end O2

o NOX

o SO2

o CO

o Exhaust gas temperature

o Free lime content

12.3. Performance Indicators Key performance indicators against which progress may be assessed form the basis for all effective environmental management practices. In the definition of key performance indicators careful attention is usually paid to ensure that progress towards their achievement is measurable, and that the targets set are achievable given available technology and experience. Performance indicators must be selected to reflect both the source of the emission directly and the impact on the receiving environment. Ensuring that no visible evidence of wind erosion exists represents an example of a source-based indicator, whereas maintaining offsite dustfall levels to below 250 mg/m2/day represents an impact – or receptor-based performance indicator. Source-based performance indicators would include the following:

o Vegetation cover density to be at least 80% coverage on the entire slope up until 1m form the crest for the waste dumps;

o Early rehabilitation, i.e. as practical as possible, of dump surface area with vegetation;



o Visible reductions in fugitive dust resulting from mining activities; and o For unpaved haul roads, it is recommended that dustfall in the immediate vicinity of

the mining perimeter be less than 1200 mg/m2/day.

12.4. Environmental Reporting Periodic inspections and external audits are essential for progress measurement, evaluation and reporting purposes. According to the Guidelines of the Chamber of Mines (1996), every decommissioned residue deposit should be inspected at yearly intervals by a suitably qualified person and any alteration or deterioration of conditions at the deposit reported to the responsible authority. It is recommended that site inspections and progress reporting be undertaken at regular intervals (at least quarterly) during operations and rehabilitation, with annual environmental audits being conducted. Results from site inspections and off-site monitoring efforts should be combined to determine progress against source-and receptor-based performance indicators. Progress should be reported to all interested and affected parties, including authorities and persons that may be affected by the pollution.

12.5. Public/Community Liaison Stakeholder forums possibly provide the most effective mechanisms for information dissemination and consultation. It is recommended that specific intervals at which forums will be held must be stipulated, and information provided on how people will be notified of such meetings. Procedures on how the community can log complaints and obtain relevant data should be developed. Key principles for effective engagement between all these parties should include:

• Communication (Open and effective engagement) • Transparency (Clear and agreed information and feedback) • Collaboration (Seeking of mutual beneficial outcomes where feasible) • Inclusiveness (Recognising, understanding, and the involvement of

communities and stakeholders in the process) • Integrity (Engagement that is conducted with mutual respect and trust)



13. CONCLUSIONS AND RECOMMENDATIONS The air quality study forms an integral part of the of the environmental impact assessment underway for the proposed upgrade of the PPC Riebeeck West cement manufacturing facility. The specialist investigation conducted as part of the air quality assessment comprised two components, viz. a baseline study and an air quality impact and compliance assessment study.

13.1. Baseline Analysis A dust fallout monitoring network records deposition rates at four locations around the PPC facility. This network was commissioned in 2000 (Environmental and Hygiene Engineering cc). The monitoring network consists of two, twin-bucket monitors located at the Rugby Field and the Overburden Dump, and two, four-bucket DustWatch monitors located at De Gift and the Quarry. Additional, albeit short-term, air quality monitoring campaigns were completed during June 2007 to August 2007 (Ecoserv) and May 2011 to June 2011 (SGS SA), respectively. The latter campaigns included air concentrations of PM10, sulphur dioxide, nitrogen dioxide and VOCs. Apart from the monitor located near the quarry, all monitors indicate a net export from the PPC facility, ranging from 2.4% near the overburden dump to 6.6% at De Gift. The results from chemically analysing the sixteen fallout bucket samples indicate that the calcium fallout from the PPC facility is about 6%. This result ignores the potential for resuspension of previously deposited calcium which may have reported as “import”. The smallest amount of daily dust was collected during the winter season and the highest amount during the summer months, as shown below:

• winter season : 76 to 168 mg/m²/day • spring : 157 to 316 mg/m²/day • autumn : 189 to 438 mg/m²/day • summer season : 395 to 571 mg/m²/day

The measurements also indicated that the highest daily exports during summer, autumn and winter is towards the east. This is followed by the west, north and lowest to the south. During spring, the highest exports are to the west, followed by east, then south with the lowest to the north. On an annual basis the highest daily imports came from the south and east. A relatively short, one month sampling campaign at Delectus and the Rugby Field was performed from June to August 2007 to measure air concentration of PM10. No exceedences of the DEA limit value of 75 µg/m3 for PM10 was observed. The maximum daily average of 66 µg/m³ at the Rugby Field was recorded on a day during which the site was downwind of PPC Riebeeck. These results should be seen in light of the prevailing wet conditions during winter. The second campaign (May to June 2011) reflected similar observations at the Meteorological Station, with a maximum daily average recording of 50 µg/m3.



Ambient air concentration levels of sulphur dioxide and nitrogen dioxide were determined using passive diffusive samplers during June/August 2007 and May/June 2011. These sampling units were located at three sites with the first campaign, namely the Rugby Field, Delectus and Vlakkerug. Low concentrations of both nitrogen dioxide (2.8 µg/m³) and sulphur dioxide (<1 µg/m³) were recorded during this period. These are well below even the annual average DEA limit values of 50 µg/m³ for sulphur dioxide and 40 µg/m³ for nitrogen dioxide, respectively. During the second campaign, the samplers were located at the following locations:


Both the SO2 and NO2 concentrations (maximum of 2 µg/m³ and 8 µg/m³, respectively) were slightly higher than that observed during the previous campaign, however they were still very low compared to the annual DEA limit values. The highest NO2 concentration was observed at the Meteorological Station, whilst the highest SO2 concentration was observed at the Conference Centre. Air concentration measurements of VOCs were also included during the second campaign at the same locations as for SO2 and NO2. Of all the VOC’s only toluene was observed at all four locations, with the highest value of 5.3 µg/m³ observed at the Meteorological Station. This station also observed the highest xylene concentration of 4.4 µg/m³. Xylene was also observed at the Conference Centre, but not at any of the other two locations. Ethylbenzene was only observed at the Conference Centre. With a detection threshold of 0.2 µg/m³, benzene could not be detected at any of the locations. The following compounds were all below the detection limit of the laboratory and concentrations could not be calculated for any of the samples: Pentane 3-Methylhexane n-Butyl acetate Ethanol Napthalene 2-Butoxyethanol Acetone (2-propanone) Styrene Cyclohexanone 2-Methylpentane Isooctane Isopropylbenzene 3-Methylpentane n-Heptane Propylbenzene n-Hexane Trichloroethylene 1,2,3-trimethylbenzene Methyl Ethyl Ketone (MEK) Methylmethacrylate 1,2,4-trimethylbenzene Ethyl acetate Propyl acetate 1,3,5-trimethylbenzene 2-Methylhexane Methyl Isobutyl Ketone 1-Heptene Cyclohexane Perchloroethylene 1-Decene 1-Pentene 1-Hexene 1-Octene 1-Nonene The sources of air pollution at the PPC Riebeeck cement facility primarily include the quarry operations, haul roads and process emissions, as summarised below:



• Processing o Dry Kilns

• Preparation o Raw Materials Mill o Coal Mill o Cooler Grate o Finish Mill o Crushing & Screening

• Diffuse Sources o Limestone transfer o Cement Production and Storage o Material Handling o In-pit operations, including

drilling, excavation loading

o Haul roads

• Wind Erosion o Overburden dump o Coal stockpile o Limestone stockpile o Sand stockpile o Run of Mine o General open areas

Additional air pollution arises due to the various agricultural activities in the region and wheel entrainment on unpaved and paved public roads. The most significant pollutants associated with the operation include





Although dioxins and furans would be emitted in small quantities, it was considered in the assessment due to its very toxic nature. Arsenic, cadmium, lead and mercury were similarly included due to public concern. Currently PPC uses FDG within their cement manufacturing process, which they purchase from ArcerlorMittal Saldanha Steel Works. FDG is mixed in the raw mill and then added to the kiln with the other milled materials for calcination. Therefore, in terms of Section 21 of the NEM: AQA, the proposed cement production process trigger Subcategory 5.4: Cement production (using alternative fuels and/or resources). The emissions of pollutants which apply to the Subcategory 5.4 are summarised in Table 13-1. From the table it is clear that the current SO2 emission concentrations exceed the limit value of 250 mg/m³, required in AEL Category 5.4. Similarly, emissions of hydrogen chloride and the heavy metal combination of As+Sb+Pb+Cr+Co+Cu+Mn+V+Mn were shown to exceed their respective limit values.



Table 13-1: Estimated pollutant emission rates in the kiln flue gas to be reported in AEL

Pollutant

Total Emissions

(g/s)

Emission Limit(a)

(mg/Nm³)





The mercury emissions were based on a chemical mass balance of the mercury contained in the raw meal and coal (i.e. kiln feed). Coal and FDG represent the main sources of mercury. Using the maximum mercury concentration in the kiln feed, the amount of mercury entering the kiln was calculated to be 0.0014 g/s. This would result in a stack gas concentration of about 0.06 mg/Nm³. Applying an ESP removal efficiency of 26% (Davis 2000), the concentration would reduce to about 0.04 mg/Nm³, which is marginally below AEL limit value of 0.05 mg/Nm³. The baseline included emissions from the current PPC Riebeek operation and the surrounding agricultural activities. The predicted maximum concentrations are given in Table 13-2. As expected, the most significant pollutant is predicted to be airborne particulates, with predicted exceedances of the DEA daily average limit beyond the PPC cement facility, when considering emissions from other activities in the region (mainly agriculture). Transporting ore and overburden within the mining area and product out of the facility constitute the largest source of emissions. The simulations assumed the current practice of water sprays on the road surfaces. The watering programme controls these emissions by about 75%, which reduce the total TSP and PM10 emissions by about 54% and 40%, respectively. A further reduction can be achieved by controlling emissions from the crusher and screening process. None of the other pollutants considered in the assessment exceeded any of the DEA limit values and standards. Those pollutants which do not have DEA standards were compared to international best practice guidelines and similarly shown to be well within the guidelines.



Table 13-2: Comparison of predicted current air concentrations to various guidelines and standards




24-hour 120(a1) 75(a2) 75 70 (h) 100 – 150

Annual 50(a1) 40(a2) 40 50 (h) 50




Benzene

Annual 10(a1) 5(a2) 5 - 1(i) 0.002







The EU introduced an annual limit value for SO2 of 20 µg/m³ that is protective for all ecosystems and which would be needed in regions without very sensitive ecosystems. The predicted annual average concentration for SO2 is 1.3 µg/m³. Similarly, the critical levels for NOx, used by the United National Economic Commission for Europe to map exceedence areas, was given as 30 µg/m³ for annual means. The predicted annual average concentration for NOx is 2.2 µg/m³. The impact from these two pollutants in vegetation is therefore seen to be insignificant. The predicted dustfall level to outside PPC boundary is predicted to be "Slight", i.e. dustfall is barely visible to the naked eye. Nearby the facility and access road, the predictions indicate “medium” dustfall. The DME use the 1 200 mg/m2/day threshold level as an action level. In the event that on-site dustfall exceeds this threshold, the specific causes of high dustfall should be investigated and remedial steps taken. An attempt was made to estimate emissions from road haulage of cement products. Fugitive cement dust from bag carriers was calculated and the predicted daily average inhalable particulates (PM10) were estimated to be about 1 µg/m³. The predicted maximum daily fallout rate of cement from haul trucks on the side of the road could vary considerably, ranging from about 4 to 24 mg/m² per day within a zone of about 10 m from the road edge. Haul trucks are also responsible for airborne particulates from wheel entrainment and diesel particulate matter (DPM). The maximum daily average PM10 concentration for all particulate emissions from vehicles associated with PPC was calculated to be 13 µg/m³. DPM constitutes about 3% of this. The annual average DPM concentration was calculated to be 0.09 µg/m³, which is small compared to the US EPA’s inhalation Reference Concentration (RfC) of 5 µg/m³.

13.2. Analysis of Proposed Upgrade

13.2.1. Minimum Emission Limits In terms of Section 21 of the NEM: AQA, the cement production process could potentially trigger the following categories:

• Subcategory 5.1: Storage and handling of ore and coal • Subcategory 5.3: Cement production (using conventional fuels and raw materials) • Subcategory 5.4: Cement production (using alternative fuels and/or resources)

Although the proposed plant will be storing coal onsite the PPC facility is designed to hold less than the criterion 100 000 tonnes. Subcategory 5.1 therefore does not apply. Currently PPC uses FDG within their cement manufacturing process, which they purchase from ArcerlorMittal Saldanha Steel Works. FDG is mixed in the raw mill and then added to the kiln with the other milled materials for calcination. As part of the upgrade, PPC would



again be using FDG, requiring additional volumes. PPC also intends using slag within their current and proposed process. Slag could also be sourced from ArcerlorMittal. Whereas FDG is used to produce the clinker in the kiln slag and fly-ash are used as extenders, i.e. mixed with the clinker. In terms of NEM: AQA, PPC triggers Listed Activity Category 5 (Mineral processing, storage and handling) Subcategory 5.4: Cement production (using alternative fuels and/or resources) due to the usage of FDG to produce the clinker, rather than Subcategory 5.3 which refers to the usage of conventional fuels and raw materials. The proposed introduction of slag and fly-ash as raw materials into their cement manufacturing process after the clinker production does not apply here. The emissions of pollutants which apply to the Subcategory 5.4 are summarised in Table 13-3. Table 13-3: Estimated pollutant emission rates in the new Kiln/Raw Mill and Coal Mill flue gas to be reported in AEL

Pollutant Total

Emissions (g/s)

Emission Limit(a)

(mg/Nm³)



(b) – Mercury emissions based on mass balance of coal and FDG introduced into the kiln As for the current operation, the mercury emissions were estimated using a chemical mass balance of the mercury contained in the kiln feed material. Using the maximum mercury concentration in this feed, the amount of mercury entering the kiln was estimated to be 0.0031 g/s. This would result in a stack gas concentration of about 0.04 mg/Nm³. Applying a fabric filter removal efficiency of 39% (Davis 2000), the concentration would reduce to about 0.02 mg/Nm³, which is below AEL limit value of 0.05 mg/Nm³. The heavy metal combination of As+Sb+Pb+Cr+Co+Cu+Mn+V+Mn is estimated to be 0.2 mg/Nm³, which is below the required limit of 0.5 mg/Nm³. These emissions were estimated using emission factors rather than mass balances due to the difficulty in estimation the partitioning of metals in the flue gas and clinker.

13.2.2. Predicted Air Quality Impacts As for the baseline case, the most significant pollutant is predicted to be airborne particulates. The predicted maximum concentrations are given in Table 13-5. With the estimated background particulate concentrations due to agricultural activities, there would be



the potential to exceed the DEA daily and annual average limit beyond the PPC cement facility. Other emissions, including sulphur dioxide, oxides of nitrogen, carbon monoxide, hydrogen chloride, benzene, mercury, dioxins and furans have a low air impact, with none of DEA limit values and adopted air concentration guidelines being exceeded beyond the PPC facility. In spite of exceeding the stipulated Minimum Emission Limits required for Subcategory 5.4, the predicted mercury impacts are estimated to be very low. Similarly, the impact, including carcinogenic effects, was estimated to be insignificant for the other heavy metals (see Table 13-3). Table 13-4: Predicted metal concentrations for proposed upgraded cement facility

Metal Predicted


Guideline (µg/m³)






Table 13-5: Comparison of predicted air concentrations to various guidelines and standards.




24-hour 120(a1) 75(a2) 75 70 (h) 100 – 150

Annual 50(a1) 40(a2) 40 50 (h) 50




Benzene

Annual 10(a1) 5(a2) 5 - 1(i) 0.006







Transporting ore and overburden within the mining area and product out of the facility constitute the largest source of emissions. The simulations assumed the current practice of water sprays on the road surfaces. The watering programme controls these emissions by about 75%, which reduce the total TSP and PM10 emissions by about 54% and 40%, respectively. The predicted annual average concentration for SO2 is 0.2 µg/m³, which is well below the EU annual limit value for SO2 of 20 µg/m³ that is protective for all ecosystems. Similarly, the United National Economic Commission for Europe’s limit value of 30 µg/m³ for annual means is predicted not to be exceeded. The predicted annual average concentration for NOx is 3.2 µg/m³. The impact from these two pollutants in vegetation is therefore seen to be insignificant. The predicted dustfall level to outside PPC boundary is predicted to be "Slight", i.e. dustfall is barely visible to the naked eye. Nearby the facility and access road, the predictions indicate “medium” dustfall. The South African Department of Minerals and Energy (DME) use the 1 200 mg/m2/day threshold level as an action level. In the event that on-site dustfall exceeds this threshold, the specific causes of high dustfall should be investigated and remedial steps taken. It was given that the proposed upgrading of the manufacturing plant would cease all operations before the proposed new plant starts up.

13.3. Recommendations

13.3.1. Construction Phase All of the planned improvements for the upgrade are to be undertaken on the existing plant site. Since these activities do not require major earthmoving and material transfer, it is not expected to generate significant amounts of fugitive dust. Any additional mitigation measure at the plant may therefore not specifically be necessary. However, it is expected that there would be an increased number of vehicles travelling to and from the site. This has the potential to generate more pollution associated with vehicles, especially entrained dust from access roads. This will be exacerbated during dry or windy conditions. If paving is not an option, regular water spraying has to be applied. It is therefore recommended that any unpaved road sections receive additional watering during periods of expected traffic peaks in the morning and afternoon. Furthermore, clear labelling of all vehicles associated with the contract will help to identify any vehicles that are causing unnecessary re-suspended or fugitive dust emissions. Minimising dust and mud from the site entrance or exit will help prevent fugitive emissions being spread outside the site boundary by site vehicles. The control measures outlined below should provide the most effective ways to prevent re-suspension of road dust from a construction site so that no mud or dirt is deposited outside the plant boundary:



• Put in place procedures for effective cleaning of vehicles and inspection. Since these

vehicles could carry mud onto the road surface leading to the R311, wheel washing could be necessary. If this proves not to be adequate, total vehicle washing must be applied.




The control of vehicle tailpipe emissions may be achieved by ensuring that vehicles are in good working condition and to minimize idling of equipment when not in use.

13.3.2. Operational Phase In terms of Section 21 of the NEM: AQA, the current and proposed cement production process trigger Subcategory 5.4: Cement production (using alternative fuels and/or resources). The AEL would stipulate the nature and maximum allowable consumption rate of the FDG in the process. If PPC wish to use alternative fuel, this would trigger a new application process, which would require a new EIA to demonstrate compliance and a re-application for an AEL The study showed that the current SO2 emission concentrations exceed the limit stipulated by the AEL Minimum Emission Limits specified for Subcategory 5.4. Similarly, current emissions of hydrogen chloride, hydrogen fluoride and the heavy metal combination of As+Sb+Pb+Cr+Co+Cu+Mn+V+Mn were shown to exceed the limit values. The mercury concentration in the emission is estimated to be about 0.04 mg/Nm³, which is marginally below AEL limit value of 0.05 mg/Nm³. With the proposed new kiln, a significant reduction in air emission concentrations of particulate matter, NOx and SO2 will be realised to meet the AEL Minimum Emission Limits. It was further estimated that the emissions of hydrogen chloride, hydrogen fluoride, mercury and the heavy metal combination of As+Sb+Pb+Cr+Co+Cu+Mn+V+Mn would also meet the AEL limit values. It should be noted that these emissions were estimated using emission factors rather than mass balances due to the difficulty in estimation the partitioning of metals in the flue gas and clinker. It is therefore, recommended that these emissions be quantified with isokinetic sampling methods and if deemed necessary by the Authorities, brought in line with the AEL requirements. It was predicted that the ground level concentrations of these metals would be within the recommended health risk criteria. It is expected that a virgin equivalent for the iron contained in FDG (such as conventional iron ore), would also be acceptable for use in the kiln. However, it is recommended that



whenever such a change is made, emissions testing be conducted to ensure compliance with the requirements of Subcategory 5.4. It became clear from the predictions that inhalable particulates could be a concern outside the PPC Riebeeck West boundary, if no routine mitigation is applied. Fallout could potentially also result in a significant nuisance, albeit not to such a large extent. Transporting the ore, topsoil and overburden within the area constitute the largest source of emissions. Minimising these transport distances would obviously reduce emissions. It was shown that a minimum of 75% control efficiency must be applied to achieve the desired reduction in air concentrations. Recommended watering rates are included in Appendix E. A bag filter arrangement is regarded very efficient provided the availability can be kept as close to 100% as practically possible. The efficiency and availability of the proposed fabric filter abatement control can be ensured through engineering measures. The following measures are recommended to maximise efficiency of dust removal:

• Have a maintenance schedule for the unit; • Use broken bag detectors (triboelectric probes) to monitor for bag integrity; • Install a baghouse with some redundancy so that a cell in the baghouse can be

isolated and repaired while the unit is still on-line • Have an automatic bag cleaning system as part on the baghouse. Typical

configurations use reverse airflow, mechanical shaking, vibration or compressed air pulsing

Great reliance is placed on the predictive capabilities of the emission factors and dispersion simulations employed in this investigation. It is therefore suggested that the conclusions derived in this investigation be verified through regular stack and ambient air monitoring. A comprehensive ambient monitoring and emissions monitoring programme is recommended. PPC currently has a dustfall monitoring programme in place and measures local meteorological parameters. Continuation of this programme is recommended with the added inclusion of PM10 air concentrations. Considering the relatively low concentrations predicted for all pollutants other than airborne particulates (e.g. sulphur dioxide, oxides of nitrogen and carbon monoxide), it is not specifically recommended to include the observation of other air pollutants in the air pollution monitoring network. The ultimate goal of such a network is to demonstrate compliance to the relevant authorities, the immediate community as well as interested and affected parties. The aim of the monitoring network would be to meet the following objectives:


Identify probable problem areas Demonstrate compliance with accepted air quality standards and dustfall limits; To prove information to management in the respect of the effectiveness of current

control and suppression methods



Temporal trend analysis Spatial trend analysis Demonstrate continuous improvement; and Facilitate dispersion models calibration (when required).

The demonstration of compliance with the DEA’s NAAQS would necessitate the measurement of inhalable particulates (PM10) using gravimetric measurement methods. Furthermore, the draft DEA regulation on dustfall measurements must be consulted and the applicable method (currently proposed ASTM D1739) used in the fallout network. The current methodology does not conform to the ASTM D1739 methodology. It is recommended that the proposed PM10 monitoring instrument be co-located with the existing Meteorological Station. It is also recommended to position a dustfall instrument at this location. It is recommended that monthly reports be compiled incorporating the monitoring data. This data should be made available in the instance of public complaints. A continuous emissions monitoring system (CEMS) is recommended to monitor particulate emissions, sulphur dioxide and oxides of nitrogen at the new Kiln and Raw Mill Stack. The latter gaseous emissions are primarily to verify compliance of the DEAs Minimum Emission Standards. A CEM is also proposed to monitor particulate emissions at the Grate Cooler Stack. The monitoring protocols and details of grab sampling campaigns are supplied in Section 12.



14. REFERENCES . ARTEMIS (2006). Assessment and Reliability of Transport Emission Models and Inventory Systems, Research Project funded by the European Commission – Directorate General Transport and Energy. More information available at http://www.trl.co.uk/artemis/. Ashden T.W and Mansfield T.A 1978. Extreme pollution sensitivity to grasses when SO2 and NO2 are present in the atmosphere together. Nature, 273, 142-143. Batchvarova E And Gryning S-E 1990. Applied model for the growth of the daytime mixed layer, Boundary Layer Meteorology, 56, pp. 261-274. Benson, P. (1984). CALINE4 – A dispersion model for predicting air pollutant concentrations near roadways. FHWA/CA/TL-84/15, California Department of Transportation, Sacramento, CA. Benson, P. (1992). A review of the development and application of the CALINE3 and 4 models. Atmos.Environ. 26B:3, pp. 379-390. Berlyand, M.E., Burenin, N.S., Genikhovich, E.L., Onikul, R.I., Panfilova, G.A. and Tsyro, S.G. (1990). Experimental investigations of atmospheric pollution due to motor vehicles. Proceedings of the Soviet American symposium on mobile-source air pollution, Novgorod, p. 152. Chock, D.P, 1978. A simple Line-Source Model for Dispersion Near Roadways, Atmos. Environ.,12, pp. 823 - 829. Chock, D.P. (1980). General Motors sulfate dispersion experiment. An analysis of the wind field near a road. Boundary Layer Meteorology, 18, pp. 431-451. Csanady, G.T. (1972). Crosswind shear effects on atmospheric diffusion. Atmos. Environ., 6, pp. 221-232. CARB 1997, Section 7.11, Supplement Documentation for Windblown Dust – Agricultural Lands, California Air Resources Board, California, USA. CEPA/FPAC WORKING GROUP 1998. National Ambient Air Quality Objectives for Particulate Matter. Part 1: Science Assessment Document, A Report by the Canadian Environmental Protection Agency (CEPA) Federal-Provincial Advisory Committee (FPAC) on Air Quality Objectives and Guidelines. Chow J C and Watson J G 1998. Applicability of PM2.5 Particulate Standards to Developed and Developing Countries, Paper 12A-3, Papers of the 11th World Clean Air and Environment Congress, 13-18 September 1998, Durban, South Africa.



CLAG (1996). Critical Levels of Air Pollutants for the United Kingdom. Critical Loads Advisory Group, Institute of Terrestrial Ecology, Penicuik. Cochran L S and Pielke R A (1992). Selected International Receptor-Based Air Quality Standards, Journal of the Air and Waste Management Association, 42 (12), 1567-1572. Countess Environmental, (2004). WRAP Fugitive Dust Handbook Cowherd C and Englehart (1984). Paved Road Particulate Emissions, EPA-600/7-84-077, US Environmental Protection Agency, Washington DC. Cowherd C, Muleski GE and Kinsey JS (1988): Control of Open Fugitive Dust Sources, EPA-450/3-88-008, US Environmental Protection Agency, Research Triangle Park, North Carolina. Davis W.T (2000). Air Pollution Engineering Manual, 2nd Edition, Air & Waste Management Association, John Wiley & Sons, New York. Delhamn T. Edfors M-L. and Rylander R. (1968). Retention of cigarette smoke components in Human Lungs. Arch. Environ. Health. 17: 746-748. Dockery D W C and Pope III C A (1993). An Association between Air Pollution and Mortality in Six U.S. Cities, New England Journal of Medicine, 329, 1753-1759. DEAT (2001). Technical Background Document for Mercury Waste Disposal, Department of Environmental Affairs and Tourism. Republic of South Africa DEAT (2007a). AQA Implementation: Listed Activities and Minimum Emission Standards BID Rev01, Department of Environmental Affairs and Tourism, Republic of South Africa, July 2007. DEAT (2007b). The 2007 National Framework for Air Quality Management in the Republic of South Africa, Department of Environmental Affairs and Tourism, Republic of South Africa, 11 September 2007, DEAT (2009a). Policy on Waste Incineration and the Co-Processing of Waste as Alternative Fuels or Raw Materials in Cement Production. GN 777 of 2009, GG 32439 of 24 July 2009. Pretoria, Government Printing Works DEAT (2009b). National Environmental Management: Air Quality Act (39/2004): GN 1210, GG 32816 of 24 December 2009. Pretoria, Government Printing Works DEA (2010a). National Environmental Management: Air Quality Act (39/2004): GN 234, GG 33064 of 31 March 2010. Pretoria, Government Printing Works DEA (2010b). National Environmental Management: Air Quality Act (39/2004): GN 220, GG 33041 of 26 March 2010. Pretoria, Government Printing Works



Emberson, L.,D., M.R. Ashmore, Murray, F, Kuylenstierna, J.C.I., Percy, K.E., Izuta, T, Zheng, Y., Shimizu, H., Sheu, B.H., Liu, C.P., Agrawal, M., Wahid, A., Abdel-Latif, N.M., van Tienhoven, M., de Bauer, L.I., Domingos M. (2001). Impacts of air pollutants on vegetation in developing countries. Water, Air and Soil Pollution 130: 107-118. Evelyn J. (1661). Fumifugium or the Inconvenience of Aer and Smoake of London Dissipated: Together with Some Remedies Humbly Proposed. W. Godbid, London. EEA (1999). COPERT III. Computer Programme to Calculate Emissions from Road Transport - Methodology and Emission Factors, European Environment Agency, European Topic Centre on Air Emission, July 1999. EEA (2009), Emissions Inventory Guidebook, Road Vehicle Tyre, Brake Wear and Road Surface Wear EPA (1986). Air Pollution: Improvements Needed in Developing and Managing EPA’s Air Quality Models, GAO/RCED-86-94, B-220184, General Accounting Office, Washington, DC. EPA (1993). Motor Vehicle-Related Air Toxics Study, Technical Support Branch, Emissions Planning and Strategies Division, Office of Mobile Sources, U.S Environmental Protection Agency EPA, (1995a). Compilation of Air Pollution Emission Factors (AP-42), 5th Edition, Volume 1, as contained in the AirCHIEF (AIR Clearinghouse for Inventories and Emission Factors), US Environmental Protection Agency, Research Triangle Park, North Carolina. EPA, (1995b). Background Document to AP-42 Document, as contained in the AirCHIEF (AIR Clearinghouse for Inventories and Emission Factors), US Environmental Protection Agency, Research Triangle Park, North Carolina. EPA (1999). Compilation of Air Pollution Emission Factors (AP-42), 6th Edition, Volume 1, as contained in the AirCHIEF (AIR Clearinghouse for Inventories and Emission Factors), Environmental Protection Agency, Research Triangle Park, North Carolina. EPA (2000). Exposure and Human Health Reassessment of 2,3,7,8-Tetrachlorodibenzo-p-Dioxin (TCDD) and Related Compounds, EPA/600/P-00/001Bb, Environmental Protection Agency, Research Triangle Park, North Carolina. EPA (2003). Integrated Risk Information System, Diesel Engine Exhaust (CASRN N.A.), US Environmental Protection Agency, Research Triangle Park, North Carolina.



Faiz A. (1996). Air Quality from Motor Vehicles Standards and Technologies for Controlling Emissions, The International Bank for Reconstruction and Development/The World Bank, Washington, USA. Farmer A.M. (1993). The Effects of Dust on Vegetation – a Review, Environ Pollut, 79, 63– 75. Ferris B.G. (1978). Health Effects of Exposure to Low Levels of Regulated Air Pollutants: A Critical Review, Journal of the Air Pollution Control Association8 (5), 482 - 497. Godish T. (1990). Air Quality, Lewis Publishers, Michigan, 422 pp. Gokhale S and Khare M (2007). Vehicle wake factor for heterogeneous traffic in urban environments, International Journal of Environment and Pollution. 30.1 Grantza D.A, Garnerb J.H.B. and Johnsonc D.W. (2003). Ecological effects of particulate matter, Environment International, 29, 213-239 Härkönen, J., Valkonen, E., Kukkonen, J., Rantakrans, E., Lahtinen, K., Karppinen, A. and Jalkanen, L. (1996). A model for the dispersion of pollution from a road network. Finnish Meteorological Institute, Publications of Air Quality 23, Helsinki, 34 p. Harrison RM (1990). Pollution: Causes, Effects and Control, Royal Society of Chemistry, Cambridge, pp. 393. Hext P M, Rogers K O and Paddle G M (1999). The Health Effects of PM2.5 (Including Ultrafine Particles), CONCAWE Report No. 99/60, Brussels. IPPC (2001). Integrated Pollution Prevention and Control (IPPC) Guidance for the Cement and Lime Sector, British Environmental Agency Junker A and Schwela D (1998). Air Quality Guidelines and Standards Based on Risk Considerations, Paper 17D-1, Papers of the 11th World Clean Air and Environment Congress, 13-18 September 1998, Durban, South Africa. Kercher J.R and King D.A (1985). Modelling effects of SO2 on the productivity and growth of plants. In Sulphur Dioxide and Vegetation: Physiology, Ecology and Policy Issues, eds. W.E. Winner, H.A Mooney, and R.A. Goldstein. Stanford University Pres, Stanford, CA, p.357-372. Kono, H. and Ito, S. (1990). A micro-scale dispersion model for motor vehicle exhaust gas in urban areas – OMG VOLUME-SOURCE model. Atmos. Environ. 24B:2, pp. 243-251.



Lacosse N.L. and Treshow M. (1976). Diagnosing Vegetation Injury Caused by Air Pollution, United States Environmental Protection Agency Handbook, Air Pollution Training Institute. Lizarraga, S (2003), Chromium VI in Cements, 5th Colloquium for Managers and Technicians of Cement Plants, 25-27 February 2003, Seville, Spain. Lin S.-J and Hildemann, L.M (1997). A Generalised Mathematical Scheme to Analytically Solve the Atmospheric Diffusion Equation with Dry Deposition, Atmos. Environ, 31, pp 59-71. Loveday M (1995). Clean Air Around the World. National Approaches to Air Pollution Control, published by the International Union of Air Pollution Prevention and Environmental Protection Association, Brighton, 402 pp. Luhar, A.K. and Patil, R.S. (1989). A general finite line source model for vehicular pollution prediction. Atmos. Environ., 23, pp.555-562. Manning W.J. and Feder W.A. (1976). Effects of Ozone on Economic Plants, in T A Mansfield (Ed), Effects of Air Pollutants on Plants, Society for Experimental Biology, Seminar Series, Vol. 1, Cambridge University Press. Marland, G., T.A. Boden, and R.J. Andres. (2007). Global, regional, and national CO2 emissions. Trends: A Compendium of Data on Global Change. Carbon Dioxide Information Analysis Center, Oak Ridge National Laboratory, U.S. Department of Energy, Oak Ridge, Tenn., U.S.A. MARC (Monitoring and Assessment Research Centre) (1991). Health Implications of Averaging Times Shown, University of London, King’s College. Mudd J.B. (1975). Sulphur Dioxide, in J B Mudd and T T Kozlowski (eds), Response of Plants to Air Pollution, Academic Press, New York. Nagendra, S.M.S. and Khare, M. (2002), “Line source emission modeling” Atmos Environ, 36, pp 2083-2098. National Research Council (1982). Impacts of Diesel-Powered Light-Duty Vehicles: Diesel Technology, National Academy Press, Washington, D.C. Ntziachristos L, Kourdis C, Samaras Z and Zierock K-H (2007). Emission Inventory Handbook: Road Transport Rev 6.0, SNAP Codes 070100 to 070500 PCA (Portland Cement Association) (1992). An Analysis of Selected Trace Metals in Cement and Kiln Dust, SP109T, Portland Cement Association, Skokie, Illinois, USA, 56 pages.



Petersen, W. (1980). User’s guide for HIGHWAY2, a highway air pollution model, EPA-600/8-80-018, US Environmental Protection Agency, Research Triangle Park, North Carolina. Pope III, Arden C, Schwartz, J and Ransom M R (1992). Daily Mortality and PM-10 Pollution in Utah Valley, Archives of Environmental Health, 42(3), 211-217. Pope III, Arden C, Thun, M J, Namboordiri, N M, Dockery, D W, Evans J S, Speizer, F E and Heath Jr, C W (1995). Particulate Air Pollution as a Predictor of Mortality in a Prospective Study of U.S. Adults, American Journal of Critical Care Medicine, 151(3), 669-674. Preston-Whyte R A and Tyson P D (1988). The Atmosphere and Weather over South Africa, Oxford University Press, Cape Town, 374 pp. Quint M.D., Taylor D. and Purchase R. (1996) (eds). Environmental Impact of Chemicals: Assessment and Control, Royal Society of Chemistry, London, pp 243. Richards, B.L Middleton, J.T and Hewitt W.B (1958). Air Pollution with relation to agronomic crops. V. Oxidant stipple of grape. Agron. J. 50:559-561 Robertson E J (2011). PPC Transport Impact Assessment, E J Robertson Consulting, May 2011 Schulze B R (1986). Climate of South Africa. Part 8: General Survey, WB 28, Weather Bureau, Department of Transport, Pretoria, 330 pp. Schwela D (1998). Health and Air Pollution – A Developing Country’s Perspective, Paper 1A-1, Papers of the 11th World Clean Air and Environment Congress, 13-18 September 1998, Durban, South Africa. Srivastava, H.S. et al (1975). The effects of environmental conditions on the inhibition of leaf gas exchange by NO2. Canadian Journal of Botany, 53: 475–482. Stone A (2000). South African Vehicle Emissions Project: Phase II. Final Report: Diesel Engines, Engineering Research, Report No. CER, November 1998. WHO (2000). Air Quality Guidelines, World Health Organisation, April 2000, Geneva. Wong CT and Dutkiewicz R K (1998). Vehicle Emissions Project (Phase II). Volume I, Main Report, Engineering Research, Report No. CER 161, November 1998. Wong CT (1999). Vehicle Emissions Project (Phase II). Final Report, Engineering Research, Report No. CER, February 1999.



15. APPENDIX A: Mercury Content of Raw Material

Figure 15-1: A 2011 Material Safety Data Sheet for the Furnace Dust Granules



Figure 15-2: Chemical analyses (Council for Geosciences 2011) for PPC Riebeeck West raw material



16. APPENDIX B: GENERAL EMISSION INVENTORY METHODS Reporting of emissions of pollutants can be performed in a number of ways these are:

• Mass balance according to US AP-42 documentation (usually suitable for calculating

the total SO2 emissions from a facility)

• Emission factors according to US AP-42 documentation (related to feed processed)

• CEMS (usually in stack and requiring validation and initial setup)

• Grab sampling (usually to setup and validate CEMS).

The above methodologies will be discussed in light of the permitted and emitted pollutants on the site. The following must be noted regarding CEMS and Grab sampling. Pollutant emission monitoring requires the quantification of both the concentration of the gas or particulate at a point and its flux or velocity at that point. The combination of these results can determine the emission rate. If a further analysis, such as theoretical modelling of the fate of the emissions is required, the temperature of the gas should be recorded. Most established measurement methods cover both techniques.

16.1. Mass Balance The mass balance method for calculating emissions from a facility and is based on summing the inputs of a pollutant and subtracting them from the outputs. The residual mass is assumed to be the emissions from the process. This methodology is useful for the calculation of total emissions of in particular SO2 from a process. This is because sulphur content is relatively easy to measure in solid, liquid and gaseous form. The shortfall in this methodology is that emissions are generally a factor of 1000 less than the raw materials to a process or the products from a process. This can be illustrated by the fact that raw materials and products associated with a plant are typically measured in tonnes/hour while emissions are measured in kg/hour. This means that a 10 % error in the inputs and outputs to the mass balance could cause an order of magnitude error in the calculation of the emissions.

16.2. Emission Factors Emission factors are a methodology for estimating emissions from a process. The following description from the US EPA’s AP-42 documentation gives an explanation of the key points associated with this methodology: The Compilation of Air Pollutant Emission Factors (AP-42) prepared by US EPA gives emission factors for a wide variety of processes.



The following extract from the introductory section of AP-42 gives an idea of the applicability and use of emission factors: “Emission factors and emission inventories have long been fundamental tools for air quality management. Data from source-specific emission tests or continuous emission monitors are usually preferred for estimating a source’s emissions because those data provide the best representation of the tested source’s emissions. However, test data from individual sources are not always available and, even then; they may not reflect the variability of actual emissions over time. Thus, emission factors are frequently the best or only method available for estimating emissions, in spite of their limitations. An emission factor is a representative value that attempts to relate the quantity of a pollutant released to the atmosphere with an activity associated with the release of that pollutant. These factors are usually expressed as the weight of pollutant divided by a unit weight, volume, distance, or duration of the activity emitting the pollutant (e. g., kilograms of particulate emitted per mega gram of coal burned). Such factors facilitate estimation of emissions from various sources of air pollution. In most cases, these factors are simply averages of all available data of acceptable quality, and are generally assumed to be representative of long-term averages for all facilities in the source category (i. e., a population average). The general equation for emission estimation is:

E = A x EF x (1-ER/100) Where:

E = emissions, A = activity rate, EF = emission factor, and ER = overall emission reduction efficiency, %. ER is further defined as the product of the control device destruction or removal efficiency and the capture efficiency of the control system.

When estimating emissions for a long time period (e. g., one year), both the device and the capture efficiency terms should account for upset periods as well as routine operations. Emission factor ratings in AP-42 provide indications of the robustness, or appropriateness, of emission factors for estimating average emissions for a source activity. Usually data are insufficient to indicate the influence of various process parameters such as temperature and reactant concentrations. For a few cases, however, such as in estimating emissions from petroleum storage tanks, this document contains empirical formulae (or emission models) that relate emissions to variables such as tank diameter, liquid temperature, and wind velocity. Emission factor formulae that account for the influence of such variables tend to yield more realistic estimates than would factors that do not consider those parameters. The extent of completeness and detail of the emissions information in AP-42 is determined by the information available from published references. Emissions from some processes are



better documented than others. Each AP-42 emission factor is given a rating from A through E, with A being the best. A factor’s rating is a general indication of the reliability, or robustness, of that factor. Emission factor ratings are defined as follows: A — Excellent. Factor is developed from A- and B-rated source test data taken from many randomly chosen facilities in the industry population. The source category population is sufficiently specific to minimize variability. B — Above average. Factor is developed from A- or B-rated test data from a "reasonable number" of facilities. Although no specific bias is evident, it is not clear if the facilities tested represent a random sample of the industry. As with an A rating, the source category population is sufficiently specific to minimize variability. C — Average. Factor is developed from A-, B-, and/or C-rated test data from a reasonable number of facilities. Although no specific bias is evident, it is not clear if the facilities tested represent a random sample of the industry. As with the A rating, the source category population is sufficiently specific to minimize variability. D — Below average. Factor is developed from A-, B- and/or C-rated test data from a small number of facilities, and there may be reason to suspect that these facilities do not represent a random sample of the industry. There also may be evidence of variability within the source population. E — Poor. Factor is developed from C- and D-rated test data, and there may be reason to suspect that the facilities tested do not represent a random sample of the industry. There also may be evidence of variability within the source category population The relevant sections in the US-EPA, AP-42 document that were used to estimate emissions are given below.

• Portland Cement Manufacturing (section 11.6 of the US EPA AP-42 document)

16.3. Continuous Emissions Monitoring Systems (CEMS) CEMS are generally installed in a facility in order to give continuous measurements of pollutants exiting from a stack. In order to report concentrations and emission rates of pollutants a CEMS system should include a measurement of stack temperature and velocity as well as pollutant concentration. In the case of combustion sources oxygen content and moisture content needs to be measured or estimated in order to report concentration at Normal gas conditions (stipulated on most permits). CEMS are generally certified by an international environmental body such as the US EPA or German TUV certification. Such certification ensures that the monitoring equipment is capable of measuring in the environment it is placed and is capable of producing repeatable, defensible results. A CEMS system is only as good as its suitability for the measurement ranges expected in the duct, setup, validation and calibration. For this reason standard grab sampling methodologies are employed (see below) to setup such instruments and periodically validate their readings during parallel sampling. A further necessary check is periodic calibration against a traceable standard gas.



The Kiln stacks on the current plant had installed CEMS analysers for the measurement of sulphur dioxide and nitrogen oxides. These units undergoing commissioning during this study and so no data could be derived from them. Rather data from grab sampling campaigns at this plant were used to estimate emission rates.

16.4. Grab Sampling Grab sampling techniques are required to setup CEMS and validate them, these methods are also used for periodic sampling programmes to quantify the emissions of other pollutants (such as metals) that are too costly to monitor continuously. This report references US EPA standard methodologies as they are equivalent to ISO methods (if not more stringent) and environmental bodies in Australia and Canada defer to them. Methods covered in this section will include pollutants that are associated with this plant.

16.4.1. Sulphur dioxide 16.4.1.1. Wet chemical method

Traditional methods of sulphur dioxide emission measurement rely on the reaction of hydrogen peroxide with sulphur dioxide to form sulphur acid:

SO2 + H2O2 = H2SO4 In the event that sulphuric acid or oleum is anticipated in the sample, the gas stream is pre-treated by passing it through an isopropanol solution that removes the acid. In the instance where sulphuric acid is enters the peroxide solution, the sulphur dioxide content would be overstated. The methods (US EPA Method 8 or 6) require the analyst to react the gas with peroxide over a period and then to titrate the solution using barium-thorin to determine the acid concentration. The method is labour intensive and the end-point of the titration can be difficult to identify. Various modifications have been made to the standard method whereby the sulphate concentration is determined by specific ion electrode rather than titration. This reduces the complexity of the laboratory analysis but it has not been promulgated as a standard test method.

16.4.1.2. Electrochemical method An electrochemical method (US EPA Method 6c and 7e for NO) has been promulgated for the measurement of sulphur dioxide. This method relies on an analyzer that produces direct measurements of the gas concentration by means of electrochemical cells. There is no need to manage chemical solutions and the apparatus can typically be carried in briefcase-size bag. Units consist of:

• Probe



• Temperature sensor • Particulate filter • Electrochemical cell array • Flow meter • Pump • Data logger • Direct reading display • Batteries.

Provided regular calibrations are performed and sample flow measurements are carried out at the time of sampling, the reliability of these units has been found to be adequate. The samplers are easy to use and, with the exception of calibrations, minimal preparation is required relative to the wet chemical method. The electrochemical analysers typically have a further advantage in that they can measure other pollutant gases (such as nitrogen oxide) and oxygen and nitrogen concurrently. This may be useful in its own right for emissions reporting or as an indicator of process variation. The oxygen, nitrogen and carbon monoxide (with carbon dioxide by difference) can be used to calculate the gas density, as required for flow rate determinations. This methodology does have limitations in wet stacks, stacks with high concentrations (> 2000 ppm) and where there are cross contaminants to the electrochemical cells present such as ammonia.

16.4.2. Flow measurement Where gases are constrained in a duct, the flow measurement is normally performed by taking a series of measurements across the duct and then proportioning the flow by representative area to calculate the average duct velocity. It is critical that the flow be measured at a point in the duct where the velocity profile is established. Duct obstructions and bends can interfere with the flow profile or create turbulent profiles that are subject to variation during the test. In the instance of gas measurement, this may not be significant if the velocity varies slowly with time. The preferred flow measurement methodology is by differential pressure (US EPA Method 2). A pitot tube is exposed to the gas flow with a second tube positioned at 180° to the first (type S Pitot tube). The differential between the two pressures reflects the magnitude of the flow. It is necessary to measure the temperature and pressure of the gas and its molecular density simultaneously to complete this calculation. Where reliable data exists for the performance of forced draft fans it is possible to calculate flow into a duct based on the performance of the fan. It is recommended that the performance of the fane be validated against a method such as US EPA Method 2 before adopting the results from such a calculation. Periodic validation by Method 2 is also recommended. It must be noted that in order to give a valid flow it is necessary to measure the duct temperature and pressure at the same time as performing the flow calculation from the fan.



16.4.3. Isokinetic Testing Isokinetic sampling is generally required when the pollutant to be collected is no longer in the gaseous form. These methods then apply for the measurement of dusts, mists and aerosols. The objective of this sampling methodology is to draw a sample from a duct without disturbance. This implies that the velocity in the sample nozzle is the same as the velocity in the duct. The reason for this is so that there is no skewing of results to the fine or coarse size fractions by either sampling at too high a velocity or too low a velocity.

16.4.4. Particulate Matter Particulates are collected by drawing a known volume sample from the duct through a heated probe and over a heated filter. The gas is then cooled in a condenser in order to measure the gas moisture content by weight difference. The heated filter is then cooled and dried and weighed to 0.1 mg. Dust content is then calculated by dividing the collected dust weight by the normalised gas volume drawn through the sampling train. A schematic of a US EPA Method 5 sampling train is shown in Figure 16-1below:

Figure 16-1: US EPA Method 5 isokinetic dust sampling train.



Measurements for metals (Method 29), halides and halogens (Method 26A) use the same principles of Method 5 above, where they differ is that the gases are collected in impinge solutions other than water and are then analysed for the target compounds.

16.4.5. PM10 and PM2.5 PM10 and PM2.5 are measured under ambient conditions as they are the size fractions of particulate that are associated with health effects. In general TSP is measured from emission sources for the following reasons:

• On plants the sites emitting dust emit the majority of their particulates in the size fractions below 10 µm due to the high temperature nature of the process and due to dust removal devices such as cyclones that are efficient for the larger sized particles. So it is safe to assume that the majority of particles emitted from point sources are at least PM10.

• The PM10 and PM2.5 size fractions are difficult to measure in an industrial setting. Methods such as Method 201 exist but require the gas to be extracted from the duct isokinetically then diluted with ambient air and then sampled. This requires a large dilution train which is costly and difficult to configure on site.

If the size fractions are required it is generally acceptable to perform Method 5 and then perform a particle size analysis on the particulate. This has disadvantages where the particles are soluble as some particle size methods involve placing the sample in water during the analysis phase.

16.4.6. Metals The basic principle for the collection of heavy metal emissions from stationary sources (US EPA Method 29) is similar to that of isokinetic dust sampling. The only difference is that the gas after the filter is cooled and passed through a condenser containing first peroxide acidified with nitric acid and then through solutions of acidified potassium permanganate. Most of the heavy metals are collected on the filter paper which is digested in nitric acid and the resultant solution analysed by atomic absorption spectroscopy (AA). The heavy metals that are in the gaseous form such as Hg and Pb are collected in the condenser solutions and also analysed by AA. A schematic of a US EPA Method 29 sampling train is shown in Figure 16-2 below.



Figure 16-2: US EPA compliant Method 29 sampling train for isokinetic metals emission testing.

16.4.7. Hydrogen Chloride (HCl) and Hydrogen Fluoride (HF) The basic principle for the collection of HCl and HF emissions from stationary sources (US EPA Method 26) is similar to that of isokinetic dust sampling. The only difference is that the gas after the filter is cooled and passed through a condenser containing first 0.1N sulphuric acid and then through solutions of 0.1N NaOH. Each of the two solutions are analysed for the ionic chloride and fluoride species using ion chromatography (IC). A schematic of a US EPA Method 26A sampling train is shown in Figure 16-3 below.



Figure 16-3: US EPA M26A Sampling Train Schematic

16.4.8. Dioxins and Furans Measurement for dioxin and furan emissions is performed by extracting a sample isokinetically from the stack and passing it through a heated filter and a cooled resin trap containing XAD resin. Due to the low levels of the compounds that need to be detected a number of quality assurance techniques are used in the method to ensure accuracy of results these are:

• Running of field blank

• Used of ultrapure reagents for cleanup of the sampling train

• Assessment of the recovery of the compounds by introducing laboratory and field

“spikes” of the compound

• GC-MS analysis in a laboratory dedicated to low level analysis of dioxins and furans.



Figure 16-4: US EPA Method 23 Dioxin and Furan Emission Measurement Sampling Train Schematic

16.4.9. Fugitive Dust measurements For monitoring of fugitive dust from the plant he following is recommended by DEAT (2007a):

• Fence line dust deposition monitoring at 1 km intervals at the fence line of the plant

• Management of high dust generating areas if SANS standards (discussed below are

exceeded for 6 consecutive months

Additionally the British cement industry IPPC document recommends the following:

• Daily visual check for smoke

• Daily visual check for fugitive dust and plumes

• CCTV surveillance of key release points

• Particle characterisation of dust fallout results



16.4.10. Monitoring of Process Variables A number of process variables can have potential environmental impact and are recommended to be monitored1 to ensure optimum kiln operation:

• Raw materials and fuels:

o Sulphur content

o Heavy metals content

o Halogens content

• Mean time between stops

• Raw mill downtime

• Set kiln process control strategies for:

o Backend O2

o NOX

o O2

o CO

o Exhaust gas temperature

o Free lime content



4.1

3.1

)2/()2.2/(0016.0

MUETSP =

17. APPENDIX C: TECHNICAL DESCRIPTION OF EMISSIONS FACTOR CALCULATIONS

17.1. Fugitive Dust Emissions Emissions from materials handling operations associated with mining will depend on various climatic parameters, such as wind speed and precipitation, in addition to non-climatic parameters such as the nature (moisture content) and volume of the material handled. Fine particulates are most readily disaggregated and released to the atmosphere during the material transfer process, as a result of exposure to strong winds. Increases in the moisture content of the material being transferred would decrease the potential for dust emission, since moisture promotes the aggregation and cementation of fines to the surfaces of larger particles. The four main sources of fugitive particulate emissions associated with most mining operations are: (i) materials handling operations (e.g. loading to trucks/conveyors, stockpiling and reclamation of material); (ii) entrainment of roadway dust by on-site vehicles; (iii) wind erosion of stockpiles and open areas; and (iv) drilling and blasting operations.

17.2. Fugitive Dust Emissions from Grading Operations The following predictive equation was used to estimate emissions from grading operations:

E TSP = 0.0034 x S2.5 kg of dust / Vehicle kilometre travelled

E PM10 = 0.0034 x S2.0 kg of dust / Vehicle kilometre travelled

(1)

where, ETSP = Total Suspended Particulate emission factor (kg dust / VKT) S = mean vehicle speed (km/hr)

17.3. Fugitive Dust Emissions from Tipping Operations The following predictive equation was used to estimate emissions from material tipping operations:

(2) Where, ETSP = Total Suspended Particulate emission factor (kg dust / t transferred) U = mean wind speed (m/s)



3.1

2.1

)()(6.2

MsETSP =

75.0)(

)(45.04.1

5.1

10 ×=M

sEPM

M = material moisture content (%) k = particle size multiplier (dimensionless) The particle size multiplier varies with aerodynamic particle sizes and is given as a fraction of TSP. For PM30 the fraction is 74%, with 35% of TSP given to be equal to PM10, and the PM2.5 fraction is 11% of TSP (EPA, 1998a). Hourly emission factors, varying according to the prevailing wind speed, were used as input in the dispersion simulations. Moisture content for the different types of material were not available and use was made of the typical moisture contents given by US-EPA in the section pertaining aggregate handling and storage piles (EPA, 1998a).

17.4. Excavating activities No emission factor or equation exists for dust emissions from excavating operations. It was therefore decided to apply the US.EPA emission factor equation for dragline operations since this equation requires drop height and moisture content. Emissions from excavation of overburden were calculated using the following equation:

(3a)

and,

(3b)

where,

ETSP = Total Suspended Particulate emission factor (kg dust/hr)

EPM10 = Particulate emission factor (kg dust/hr) for particulates less than 10 µm

s = material silt content (%)

M = material moisture content (%)

17.5. Blasting and Drilling Operations Blasting and drilling operations represent intermittent sources of fugitive dust emissions. Single valued emission factors, published by the US-EPA for the quantification of fugitive dust emissions due to blasting operations involving overburden, is given as follows:



ETSP = 0.59 kg of dust / drill hole

EPM10 = 0.31 kg of dust / drill hole

(4)

5.100022.0 AETSP = kg/blast

)52.0(10 TSPPM EE = kg/blast (5a)

where, ETSP = Total Suspended Particulate emissions in kg/blast EPM10 = Respirable particulate emissions in kg/blast A = horizontal area (m²), with blast depth of ≤ 21 m. The Australian National Pollution Inventory (NPI) guideline for mining activities recommends the following equation for blasting activities:

8.19.18.0344 −−= DMAETSP kg/blast

TSPPM EE 52.010 = kg/blast (5b)

where, ETSP = Total Suspended Particulate emissions in kg/blast EPM10 = Respirable particulate emissions in kg/blast A = Horizontal area (m²)

M = Moisture content (%) D = Blast depth (m)

17.6. Crushing and Screening Operations Mineral processing typically involves the mining of ore from either open pit or underground mines; the crushing and grinding of ore; the separation of valuable minerals from matrix rock through various concentration steps; and at some operations, the drying, calcining, or palletizing of concentrates to ease further handling and refining. The number of crushing steps necessary to reduce ore to the proper size varies with the type of ore. Hard ores, including some copper, gold, iron, and molybdenum ores, may require as much as a tertiary crushing. Softer ores, such as some uranium, bauxite, and titanium/zirconium ores, require little or no crushing. Particulate matter emissions result from metallic mineral plant operations such as crushing and dry grinding ore, drying concentrates, storing and reclaiming ores and concentrates from storage bins, transferring materials, and loading final products for shipment. The particulate matter emission factors are provided for various metallic mineral process operations including primary, secondary, and tertiary crushing, dry grinding, drying, and material handling and transfer (US.EPA, 1995).



The emission factors provided below are for the process operations as a whole since at most mineral processing plants, each process operation requires several types of equipment. A single valued emission factor was used in the quantification of possible emissions due to uncontrolled primary crushing and screening activities for high moisture ore, viz.:

ETSP = 0.01 kg of dust / tonne of material crushed

EPM10 = 0.004 kg of dust / tonne of material crushed (6)

High moisture ore is regarded as ore exceeding 4% moisture. A single valued emission factor was used in the quantification of possible emissions due to uncontrolled secondary crushing and screening activities, viz.:

ETSP = 0.03 kg of dust / tonne of material screened

EPM10 = 0.0012 kg of dust / tonne of material screened (7)

A single valued emission factor was used in the quantification of possible emissions due to uncontrolled tertiary crushing and screening activities, viz.:

ETSP = 0.03 kg of dust / tonne of material screened

EPM10 = 0.001 kg of dust / tonne of material screened (8)

17.7. Wind Erosion from Exposed Areas Significant emissions arise due to the mechanical disturbance of granular material from disturbed open areas and storage piles. Parameters which have the potential to impact on the rate of emission of fugitive dust include the extent of surface compaction, moisture content, ground cover, the shape of the storage pile, particle size distribution, wind speed and precipitation. Any factor that binds the erodible material, or otherwise reduces the availability of erodible material on the surface, decreases the erosion potential of the fugitive source. High moisture contents, whether due to precipitation or deliberate wetting, promote the aggregation and cementation of fines to the surfaces of larger particles, thus decreasing the potential for dust emissions. Surface compaction and ground cover similarly reduces the potential for dust generation. The shape of a storage pile or disposal dump influences the potential for dust emissions through the alteration of the airflow field. The particle size distribution of the material on the disposal site is important since it determines the rate of entrainment of material from the surface, the nature of dispersion of the dust plume, and the rate of deposition, which may be anticipated (Burger, 1994; Burger et al., 1995). An hourly emissions file was created for each of these source groups. The calculation of an emission rate for every hour of the simulation period was carried out using the ADDAS model. This model is based on the dust emission model proposed by Marticorena and



Bergametti (1995). The model attempts to account for the variability in source erodibility through the parameterisation of the erosion threshold (based on the particle size distribution of the source) and the roughness length of the surface. In the quantification of wind erosion emissions, the model incorporates the calculation of two important parameters, viz. the threshold friction velocity of each particle size, and the vertically integrated horizontal dust flux, in the quantification of the vertical dust flux (i.e. the emission rate). The equations used are as follows:

( ) ( ) ( )( )6%134.010 −= clayiGiE (9)

for

( ) ( )( )23* 11261.0 RRugP

iG a −+⎥⎦

⎤⎢⎣

⎡=

and **

uu

Rt

=

where, E(i) = emission rate (g/m²/s) for particle size class i Pa = air density (g/cm³) g = gravitational acceleration (cm/s²) u*

t = threshold friction velocity (m/s) for particle size i u* = friction velocity (m/s)

Particle Size vs Threshold Friction Velocity

0.0

0.5

1.0

1.5

2.0

2.5

3.0

3.5

4.0

4.5

5.0

5.5

1 10 100 1000Particle Size (µm)

Thre

shol

d Fr

ictio

n Ve

loci

ty (m

/s)

Figure 17-1: Relationship between particle sizes and threshold friction velocities using the calculation method proposed by Marticorena and Bergametti (1995)



Figure 17-2: Contours of normalised surface wind speeds (i.e. surface wind speed / approach wind speed) (after EPA, 1996)

Dust mobilisation occurs only for wind velocities higher than a threshold value, and is not linearly dependent on the wind friction and velocity. The threshold friction velocity, defined as the minimum friction velocity required to initiate particle motion, is dependent on the size of the erodible particles and the effect of the wind shear stress on the surface. The threshold friction velocity decreases with a decrease in the particle diameter, for particles with diameters >60 µm. Particles with a diameter <60 µm result in increasingly high threshold friction velocities, due to the increasingly strong cohesion forces linking such particles to each other (Marticorena and Bergametti, 1995). The relationship between particle sizes ranging between 1 µm and 500 µm and threshold friction velocities (0.24 m/s to 3.5 m/s), estimated based on the equations proposed by Marticorena and Bergametti (1995), is illustrated in Figure 17-1. The logarithmic wind speed profile may be used to estimate friction velocities from wind speed data recorded at a reference anemometer height of 10 m (EPA, 1998a):

+= 10* 053.0 UU (10)

(This equation assumes a typical roughness height of 0.5 cm for open terrain, and is restricted to large relatively flat piles or exposed areas with little penetration into the surface layer.) The wind speed variation over the dump is based on the work of Cowherd et al. (1988). With the aid of physical modelling, the US-EPA has shown that the frontal face of an elevated pile



ba WskE )3

()12

(=

(i.e. windward side) is exposed to wind speeds of the same order as the approach wind speed at the top of the pile. The ratios of surface wind speed (us) to approach wind speed (ur), derived from wind tunnel studies for two representative pile shapes, are indicated in Figure 17-2 (viz. a conical pile, and an oval pile with a flat top and 37° side slope). The contours of normalised surface wind speeds are indicated for the oval, flat top pile for various pile orientations to the prevailing direction of airflow. (The higher the ratio, the greater the wind exposure potential.) Information regarding the nature of the source, the percentage of exposed surface area and the type of material was obtained from PPC personnel. Particle size fraction analysis for the storage piles was conducted by Malvern (Pty) Ltd including information on the clay percentage. Where no parameter information (i.e. height, dimensions, etc.) was available on the storage piles, the size was assumed to be equal to the amount (cubic metres) of material received over a monthly average.

17.8. Vehicle-Entrained Emissions from Roads

The force of the wheels of vehicles travelling on unpaved roadways causes pulverisation of surface material. Particles are lifted and dropped from the rotating wheels, and the road surface is exposed to strong air currents in turbulent shear with the surface. The turbulent wake behind the vehicle continues to affect the road surface once the vehicle has passed. The quantity of dust emissions from unpaved roads varies linearly with the volume of traffic. In addition to traffic volumes, emissions also depend on a number of parameters which characterise the condition of a particular road and the associated vehicle traffic, including average vehicle speed, mean vehicle weight, average number of wheels per vehicle, road surface texture, and road surface moisture (EPA, 1998b).

The unpaved road size-specific emission factor equation of the US-EPA was revised in their 1998 AP42 document on Unpaved Roads and was used in the quantification of emissions for the current study. It is given as follows:

(11) where, E = emissions in lb of particulates per vehicle miles travelled (lb/VMT) k, a and b = empirical constants (Table 17-1) s = surface material silt content (%) W = mean vehicle weight (tonnes)



02.191.0 )()( WsLkE =

The metric conversion from lb/VMT to grams (g) per vehicle kilometre travelled (VKT) is as follows:

1 lb/VMT = 281.9 g/VKT Table 17-1: Constants for unpaved road equation (US.EPA, 2003)

Constant PM2.5 PM10 PM30(a)

k (lb/VMT) 0.23 1.5 4.9 a 0.9 0.9 0.7 b 0.45 0.45 0.45

Notes: (a) PM-30 may be used as a substitute for TSP. The paved road size-specific emission factor equation of the US-EPA was revised in their 2011 AP42 document on Paved Roads and was used in the quantification of emissions for the current study. It is given as follows:

(12) where, E = emissions of particulates per vehicle kilometres travelled (g/VKT) K = empirical constants (Table 17-2) sL = silt loading (g/m²) W = mean vehicle mass (tonnes) Table 17-2: Constants for paved road equation (US.EPA, 2003)

Constant PM2.5 PM10 PM30(a)

k (g/VKT) 0.15 0.62 3.23 Notes: (a) PM-30 may be used as a substitute for TSP. Silt loadings typically range from 0.03 g/m² (for average daily volumes of more than 10 000 vehicles), 0.06 g/m² (for average daily volumes of 5 000 to 10 000 vehicles), 0.2 g/m² (for average daily volumes of 500 to 5 000 vehicles) to 0.6 g/m² (for average daily volumes of less than 500). 17.9. General Construction Activities

The US EPA provides a very general emission factor for construction activities based on the size of the construction area. Based on field measurements of total suspended particulate (TSP) concentrations surrounding apartment and shopping centre construction projects, the approximate emission factors for construction activity operations is:

E = 2.69 megagrams (Mg)/hectare/month of activity



This value is most useful for developing estimates of overall emissions from construction scattered throughout a geographical area. The value is most applicable to construction operations with: (1) medium activity level, (2) moderate silt contents, and (3) semiarid climate. Test data were not sufficient to derive the specific dependence of dust emissions on correction parameters. Because the above emission factor is referenced to TSP, use of this factor to estimate particulate matter (PM) no greater than 10 μm in aerodynamic diameter (PM-10) emissions will result in conservatively high estimates. Also, because derivation of the factor assumes that construction activity occurs 30 days per month, the above estimate is somewhat conservatively high for TSP as well.

Although the equation above represents a relatively straightforward means of preparing an area-wide emission inventory, at least two features limit its usefulness for specific construction sites.

First, the conservative nature of the emission factor may result in too high an estimate for PM-10 to be of much use for a specific site under consideration. Second, the equation provides neither information about which particular construction activities have the greatest emission potential nor guidance for developing an effective dust control plan. 17.10. Vehicle Emission Factors The very comprehensive set of emission rate factors were developed by the European Environment Agency, as summarised in their background documentation of COPERT III (Computer Programme to Calculate Emissions from Road Transport) (EEA 1999) and later updated in COPERT IV (Ntziachristos et al, 2007). The COPERT III methodology for hot emissions depend on a variety of factors including the distance that each vehicle is travelling, its speed, its age, engine size and mass. The basic formula for estimating hot emissions from all vehicle types, using experimentally obtained emission factors, is

jdijijjhotij VcVbaE ++=, (13)

Where, Eij, hot = Hot emission factor for pollutant, j, for vehicle type i (g/VKT) Vi = Average vehicle speed for vehicle type i (km/h) aj, bj, cj, dj = Experimentally derived constants for each pollutant, j COPERT IV introduced improvements for Euro 1 and post-Euro-1 vehicles based on the development in the framework of the Artemis project (ARTEMIS 2006). The generic functions used for petrol and diesel cars are slightly different:

Petrol Cars 2

2

, 1 ijij

ijijjhotij VdVb

VeVcaE

++

++= (14)



Diesel Cars iijij

ijijjhotij Vf

VdVb

VeVcaE /

1 2

2

, +++

++= (15)

Where, Eij, hot = Hot emission factor for pollutant, j, for vehicle type i (g/VKT) Vi = Average vehicle speed for vehicle type i (km/h) aj, bj, cj, dj, ej, fj = Experimentally derived constants for each pollutant, j Eleven different relatively complex functional forms were introduced for heavy duty vehicles and busses in the COPERT IV methodology, and will not be repeated here. Some pollutants, such as sulphur dioxide that is contained in the fuel, are determined on the basis of fuel consumption only. For example, sulphur dioxide emissions are estimated by assuming that all the sulphur in the fuel is transformed completely to SO2 using the formula:

ishotSOi FCkE 2,, 2= (16)

Where, EiSO2, hot = Hot emission factor for SO2, for vehicle type i (g/VKT) FCi = Estimated fuel consumption for vehicle type i (g/km) ks = Mass fraction of sulphur in fuel (kg/kg) Emissions of lead are estimated by assuming that 75% of lead contained in the fuel is emitted into air (Hassel et al., 1987). The formula used is:

CALCjmmPb

CALCjPb FCKE ××= ,, 75.0

(17) Where, KPb,m = weight related lead content of petrol (type m) in [kg/kg]. Similarly, carbon dioxide emissions are also based on the basis of fuel consumption. However, not all the carbon content of the fuel is assumed to be fully oxidised into carbon dioxide. The carbon contained in carbon monoxide and volatile organic compounds is subtracted from the total carbon available in the fuel. The methodology followed in both COPERT III and COPERT IV also includes corrections applied to the emission factors to accommodate variation of emissions according to road gradient and loads on heavy duty vehicles, improved fuels, vehicle age, enhanced inspection and maintenance schemes. The constants for these functions are given in COPERT III (EEA 1999) and COPERT IV (Ntziachristos et al, 2007) for different petrol engine sizes, diesel vehicle mass sizes and different vehicle speeds.



Several input data in applying the COPERT methodology can obviously be only estimates. Such data include total annual mileage, share of mileage to different driving modes (urban, rural, highway), mean travelling speeds, etc. There is a certain degree of uncertainty in estimating these data. The authors did not provide a specific uncertainty to the functions, but included correlation coefficients for each. A number of the COPERT III functions for Euro 1 to Euro 4 regulations had very low correlation coefficients (~0.1). However, in the COPERT IV revision, the majority of these functions resulted in correlation coefficients of 0.8 and higher. As an example, the functions for petrol passenger cars have the following correlation coefficients:



18. APPENDIX D: CHECKLIST FOR DUST CONTROL (After Environment Australia, 1998)



Table 18-1: Checklist for Dust Control (After Environment Australia, 1998)

ISSUE OUTPUTS PERFORMANCE MEASURES IMPROVEMENT Information and Planning

HAVE YOU, determined the sources of dust in the operations?

Potential sources of dust identified in the EIA Comprehensive list of individual sources Sources considered for each stage of the mine (i.e. exploration, construction, operation, decommissioning, rehabilitation and closure)

HAVE YOU attempted to characterise the types of dust and quantities produced (modelling)?

Estimates of dust types and levels to be produced Dust emission inventory and determination of dust emission factors

Estimates based on typical measured levels for a mining plant. Dust inventory is derived by analysing the mine plan to establish potential dust sources and estimate the level of dust-producing activity associated with each source. Emission factors are derived by assessing the quantifiable activities or aspects which generate dust, such as vehicle size, speed and distance travelled on haul roads.

Estimates, inventory and emission factors made for all potential sources for each stage of the mine (emission factors are only applicable when emissions are to be modelled).

DOES YOUR characterisation of the types and quantities of dust include diffuse dust sources?

All types and locations of dust emissions can be ranked and controls planned in a systematic manner

Quantitative estimates of dust emission rates from different classes of mining activity and land surface types

Use of models to produce estimates of dust types and levels across a wide range of operating and climatic conditions

HAVE YOU undertaken an impact assessment?

Identification of sensitive receptor areas Assessment of maximum levels to avoid impacts, significant concerns or discomfort

Assessment identifies dust levels likely to be experienced by workers and at key locations.

The potential health risk from dust is related to the size of dust particles. Mine dust lies in the range of 1-100 µ

HAVE YOU developed a draft management strategy, based on the impact assessment?

Incorporates input from the community and the regulatory authorities Addresses all environmental and social issues likely to arise from dust at the proposed project

Initial planning should include development of a draft management strategy which: • Identifies all the potential sources and risks • Sets out objectives for environmental protection and

risk minimisation • Provides a framework for evaluating different

options and choosing a design which reflects site conditions and environmental sensitivities

Consultation with key stakeholders during preparations of the draft management strategy

HAVE YOU devised approaches to mitigate impacts to acceptable levels?

Strategy incorporates “built in” design features to minimise the generation of dust at source

Strategy includes addressing the mitigation of dust The EIA and mine plan for the project set out in a framework based upon: Mine design to avoid the generation of dust Systems design and management to minimise the generation of dust during operations Treatment of dust problems through active monitoring and response, and redesign of strategies if required.

Information and Planning Continued HAVE YOU considered the probable regulatory requirements?

Level to which targets in the strategy conform to standards and regulations taking into account estimates of inputs from all

Dust strategy describes relevant standards and regulations



ISSUE OUTPUTS PERFORMANCE MEASURES IMPROVEMENT probable sources of dust.

ARE THE target levels developed in consultation with the community?

Documented agreement on maximum permissible levels between company and key community group/s

Maximum dust levels explained and agreed with the community

Establishment of formal and frequent consultation with the local community early in the planning process.

DO THE provisions of the dust management plan also apply to the decommissioning, rehabilitation, and closure stages?

Smooth transition from operational to decommissioning stages, with low risk of exceedance of dust control targets.

Decommissioning, rehabilitation and closure plans for all include provisions for control of dust.

Plans incorporate provisions which must reflect the specific activities involved at the end of mining.

Management and Operation HAVE YOU prepared an operational dust management plan?

Dust management plan The management plan: • sets out targets and management strategies for all

issues identified in the impact assessment and in community consultations

• must be integrated with other operational plans into an overall environmental management system

ISO 14001 accreditation may help to demonstrate the environmental commitment to regulators and other stakeholders.

IS the management plan known and understood by all staff including plant operators?

Staff awareness of the management plan and its contents Relevant documentation must be available to staff, regulators and auditors.

Management plan available to staff, staff instructions on the control of dust, regular checks on effectiveness of operational systems, dust included in environmental awareness training seasons.

HAVE YOU selected appropriate options to minimise the generation of dust?

Few significant issues related to dust at site Evidence of good design to reduce dust generation through mine design, choice of equipment, and work practices Consistent application of good design across all types of dust sources, including road transport outside the mining area.

The use of computer modelling to investigate the control measures needed to achieve targets.

HAVE YOU incorporated design features to mitigate the potential impacts from the dust generated at site?

Few significant issues related to dust at the site Evidence of installation of engineering works, equipment modification etc to minimise dust Any significant dust sources identified via monitoring have been objectively evaluated and remedial action taken.

All reasonable measures taken to reduce from all fixed and mobile equipment

DO YOU have operational systems to control dust in all areas with dust potential?

Procedures described in the mine plan and EIA implemented correctly, and dust control targets achieved.

The EIA and related manuals will set out procedures for dust management in all relevant areas of the site

Documented procedures need to cover all mining activities.

Management and Operation Continued IS THERE documentation to demonstrate that the dust management plan is carried out properly?

Assurance to managers that dust control targets for the operation are being met.

Regular reports (monthly) of dust management activities and assessment against control targets and requirements of the management plan.

Standard operating procedures for staff working in dusty areas, operating dusty equipment, and involved in drilling and blasting activity, setting out responsibilities, and methods for limiting and reporting dust levels and incidents.



ISSUE OUTPUTS PERFORMANCE MEASURES IMPROVEMENT DO YOU have a system in place to incorporate improvement?

Continual improvement and reduced probability of recurrence of undesirable dust events

Evidence of review and update of systems and equipment where unsatisfactory dust levels have been recorded.

Assessment of the adequacy of dust control should be incorporated in annual environmental audits of the project.

Monitoring and Assessment IS THERE a monitoring regime in place which addresses all of the possible areas for environmental and social impact from dust identified at the planning stage?

The level of performance of dust control and potential impacts on workers, the public and environment is well known to managers

Comprehensive monitoring regime which includes measurement of levels in worker areas and areas of the community sensitivity. Monitoring regime sets out: • Parameters to be monitored • Monitoring locations • Monitoring interval • Data and data analysis requirements for monitoring

reports • Reporting interval

Reporting and record keeping includes: Recording intervals Location of attended and unattended monitoring instruments Comparison of monitoring results with those from modelling (if applicable)

ARE environmental and community targets set, and are the layout, techniques, frequency, quality and sensitivity of monitoring and sampling appropriate to these targets?

Low probability of community concern provided dust is controlled to within levels agreed by the community.

Control targets agreed with the community are set out in the management plan and monitoring regime and are used as key benchmarks to evaluate adequacy of performance in regular monitoring reports.

Tools for effective dust monitoring include: Baseline sampling Control site sampling Dust deposition gauges (provides long term data) High volume samplers (quantitative data over 24hr periods) Continuous particle monitors (provides data relevant to sort term events) Size-selective samplers (samples dust in size fractions) Personal exposure samplers (worn by workers)

IS monitoring undertaken in accordance with appropriate standards?

High level of assurance or the reliability of dust monitoring results Evidence that monitoring techniques accord with appropriate standards

Measures outlined in the South African National Standards, SANS 1929:2004 are recommended.

Monitoring and Assessment Continued DOES monitoring include meteorological data?

Proactive management of site activities can be undertaken to avoid significant dust events in periods of bad weather.

Routine collection of data on predicted rainfall, temperature and wind velocity

The erection of a site specific meteorological is highly recommended.

ARE data collected in accordance with the requirements of the monitoring regime?

Low risk of regulatory non-compliance or of community concerns regarding dust.

Monthly and annual reports of dust data, which cross refer to monitoring requirements

ARE the data analysed and regularly reported to the regulatory authorities?

Assurance that all regulatory requirements for dust are being met continuously

Regular reports (i.e., monthly) provided, where deemed necessary.

Dust control performance is reported against community-agreed targets in public reports.

ARE non-compliance issues or abnormalities in the data routinely

Management aware of any areas of poor performance Management provides an ongoing measure of effectiveness of

Register of non-compliance and unplanned events, indicates time of event, time of action, type of action,

Regulatory authority advised immediately of all non-compliance and sign cant unplanned events.



ISSUE OUTPUTS PERFORMANCE MEASURES IMPROVEMENT recorded? the current system and past improvements result and interaction with authorities. IS THERE a system in place for significant dust events or issues to be addressed to reduce prospects of recurrence?

Reduced risk of recurrence of significant dust events Evidence that entries in the register of non-compliance and unplanned events are investigated properly and appropriate remedial action is identified and implemented promptly.

Standard deadline set for completion of actions to remedy dust events. Number of entries in the register and speed of actioning improvements can be used as reporting criteria to staff, management, regulators, and the community.

IS liaison with the community maintained in relation to dust issues?

Good community relationships maintained Documentation of regular community liaison that addresses issues of dust.

Community meetings / stakeholder forum held regularly with dust standing as an agenda item. Special meeting held immediately after a significant event raising community concern

IS a complaints register maintained and are complaints investigated?

Areas of poor dust control are addressed quickly so that the risk of recurrence is minimised Good community relationships must be maintained.

Documented complaints register which records details of complaints and any follow-up action.

Register records date, time, and type of event, which is the subject of the complaint; follow-up action, risk of recurrence. Reporting back to the complainant



19. APPENDIX E: WATERING PROGRAMME Control techniques for fugitive dust sources generally involve watering, chemical stabilization, and the reduction of surface wind speed through the use of windbreaks and source enclosures. Watering represents a commonly used, relatively inexpensive option, but only serves as a temporary form of dust control. Although chemical treatment of the exposed surfaces is more expensive it provides for longer dust suppression. The use of chemicals may, however, have adverse effects on the receiving biophysical environment if not carefully administered (Cowherd et al, 1988). Controls and techniques to mitigate this source of emissions are indicated in Table 19-1. It is highly recommended that up to 75% control efficiency on unpaved haul roads for the current facility be maintained. The recommended minimum control efficiency for the proposed facility is 75%. It should be noted that watering can only be expected to practically achieve control efficiencies of up to 70 - 75%. Chemical suppression or gravel covering (e.g. waste rock) should also be considered for the main haul roads. Table 19-1: Control Measures for Unpaved Roads (After EPA 1992)

Control Technique Description Source extent reduction

• Speed reduction • Traffic reduction

These controls limit the amount of traffic on an unpaved road or strict enforcement of speed limits.

Source improvement

• Paving • Gravel surface

These controls alter the road surface. These techniques are “once-off” control methods, therefore ensuring that periodic treatments are not normally required.

Surface Treatment

• Watering • Chemical stabilization

These control techniques require periodic reapplications. These treatments fall into two main categories, (i) wet suppression and (ii) chemical stabilization. Water is usually applied, utilising a truck with a gravity or pressure feed. This is only a temporary measure and periodic reapplications are necessary to achieve a substantial level of control efficiency Chemical suppressants have less frequent reapplication requirements. These are designed to alter the roadway, such as cementing loose material into a fairly impervious surface (hereby simulating a paved surface) or forming a surface which attracts and retains moisture (simulating wet suppression)

The efficiency afforded by the application of water or chemicals decays over time, requiring periodic reapplication to maintain the desired average efficiency (Cowherd et al, 1988). The



following empirical model for the estimation of the average control efficiency of watering, developed by the US-EPA (EPA, 1996), can be applied in the estimation of control efficiencies by unpaved road watering programmes:

ipdtC 8.0100 −=

Where:

C = average control efficiency (%) d = average hourly daytime traffic rate (hr -1) i = application intensity (litres per m2) t = time between applications (hr) p = potential average hourly daytime evaporation rate

(mm/hr)

19.1. Recommended Watering Programme for Current Cement Facility The calculated hourly water application rates for the current facility with 14 haul trucks per hour is provided in Figure 19-1 (no rain) and Figure 19-2 (including rain). For a 75% control efficiency, the application rate varies between 0.112 litres per m2 (June) to 0.475 litres per m2 (January). The calculated watering rates for the different months are summarised in Table 19-2. Both worst-case scenario (i.e. excluding the mitigation of rain) and the more realistic scenario (i.e. including the mitigation effect of rain) are included in the table. Table 19-2: Calculated watering rates for current PPC Riebeeck cement facility to achieve 75% control efficiency from unpaved roads.

Month of Year

Incorporating Mitigation due to Rain Excluding Mitigation due to Rainlitres/m² litres/m²

January 0.463 0.475 February 0.368 0.374 March 0.307 0.320 April 0.147 0.214 May 0.077 0.153 June 0.001 0.112 July 0.043 0.121 August 0.060 0.156 September 0.175 0.212 October 0.259 0.308 November 0.363 0.380 December 0.458 0.461 Average 0.227 0.274



Figure 19-1: Calculated watering rates for unpaved roads with a maximum of 14 haul trucks per hour (current operation) without effect of rain.



Figure 19-2 : Calculated watering rates for unpaved roads with a maximum of 14 haul trucks per hour (current operation) including rainfall.



19.2. Recommended Watering Programme for Proposed Cement Facility The calculated hourly water application rates for the proposed facility with 23 haul trucks per hour is provided in Figure 19-3 (no rain) and Figure 19-4 (including rain). For a 75% control efficiency, the application rate varies between 0.184 litres per m2 (June) to 0.780 litres per m2 (January), for an hourly application. The calculated watering rates for the different months are summarised in Table 19-3. As for the current operation, both worst-case scenario (i.e. excluding the mitigation of rain) and the more realistic scenario (i.e. including the mitigation effect of rain) are included in the table. Table 19-3: Calculated watering rates for proposed PPC Riebeeck cement facility to achieve 75% control efficiency from unpaved roads.

Month of Year

Incorporating Mitigation due to Rain Excluding Mitigation due to Rainlitres/m² litres/m²

January 0.760 0.780 February 0.605 0.615 March 0.504 0.525 April 0.242 0.351 May 0.126 0.252 June 0.001 0.184 July 0.070 0.199 August 0.099 0.257 September 0.288 0.349 October 0.426 0.506 November 0.596 0.625 December 0.753 0.758 Average 0.372 0.450



Figure 19-3: Calculated watering rates for unpaved roads with a maximum of 23 haul trucks per hour (future operation) without effect of rain.



Figure 19-4: Calculated watering rates for unpaved roads with a maximum of 23 haul trucks per hour (future operation) including rainfall.



20. APPENDIX F: MONITORING GUIDE Suspended particle samplers can be filter-based or non-filter-based, intermittent or continuous and off-line or near real time.

20.1. Filter-based Monitors Filter-based monitors include various off-line samplers, such as stacked filter units (SFU) and sequential air samplers, and certain continuous real-time monitors such as the Tapered Element Oscillating Microbalance (TEOM) and the beta gauge or beta-attenuation mass (BAM) monitors.

20.1.1. Filter-based, Off-line Samplers (SFUs, Sequential Samplers) Stacked filter units and sequential air samplers are most frequently used when elemental, ionic and/or carbon analyses are required of the measured particulates. Filters are required to be weighed prior to their being loaded in the sampler for exposure in the field. Following exposure the filters are removed are reweighed in a lab to determine the particulate concentration. The filters may then be sent for elemental (etc.) analysis. Teflon-membrane filters are commonly used for mass and elemental analysis.

Figure 20-1: Partisol-Plus sequential air sampler.

Sequential air samplers with sequential dichotomous configurations splits the PM10 sample stream into its fine (PM2.5) and coarse (particles between 2.5 and 10 µm in size) fractions - collecting the fine and coarse mode particulates simultaneously on two different filters.



Certain of these systems (e.g. Partisol-Plus Air Samplers, Figure 20-1) have capacities of up to 16 filter cassettes with an automatic filter exchange mechanism. (Filter changes can be triggered on a temporal basis or based on wind direction.) Once the 16 filters have been exposed, the filters would require collection and replacement. Key disadvantages of off-line filter-based samplers such as the SFU and sequential air sampler include: the labour intensive nature of this monitoring technique and the large potential which exists for filter contamination due to the level of filter handling required. Real-time measurements are also not possible through the application of these samplers making it impossible to identify pollution episodes on a timely basis.

20.1.2. Filter-based, On-line Samplers (TEOM, BAM) The TEOM is operates by continuously measuring the weight of particles deposited onto a filter. The filter is attached to a hollow tapered element which vibrates at its natural frequency of oscillation - as particles progressively collect on the filter, the frequency changes by an amount proportional to the mass deposited. As the airflow through the system is regulated, it is possible to determine the concentration of particulates in the air. The filter requires changing periodically, typically every 2 to 4 weeks, and the instrument is cleaned whenever the filter is changed. Different inlet arrangements are used to configure the instrument. TEOMs can monitor PM10, PM2.5, PM1 and TSP continuously. Data averages and update intervals include: 5-minute total mass average (every 2 seconds), 10-minute rolling averages (every 2 seconds), 1-hour averages, 8-hour averages, 24-hour averages (etc.). The TEOM has a minimum detection limit of 0.01 µg/m3. Beta attenuation monitors collect particulates on a filter paper over a specified cycle time. The attenuation of beta particles through the filter is continuously measured over this time. BAMs give real-time measurement of either TSP, PM10 or PM2.5 depending on the inlet arrangement. At the start of the cycle, air is drawn through a glass fibre filter tape, where the particulates deposit. Beta particles that are emitted from either a C14 or a K85 sources are attenuated by the particles collecting on the filter. The radiation passing through the tape is detected by a scintillator and photomultiplier assembly. A reference measurement is made through a clean portion of the filter, either during or prior to the accumulation of the particles - the measurement enables baseline shifts to be corrected for. Application of filter-based, on-line samplers such as either the BAM or TEOM monitors has several distinct advantages including:

- continuous, near-real-time aerosol mass monitoring,

- self-contained, automated monitoring approach requiring limited operator intervention following installation,

- a choice of averaging times from 1 minute to 24 hours,

- low labour costs, minimal filter handling and a reduction in the risk of filter contamination, and

- non-destructive monitoring methods providing the potential of supplying samples which my be submitted for chemical analysis.



The TEOM is US-EPA approved (EQPM-1090-079) as an equivalent method for measuring 24-hour average PM10 concentrations in ambient air quality. It represents the only continuous monitor which meets the California Air Resources Board acceptance criteria for 1-hour mass concentration averages. TEOM instrumentation also has German TÜV approval for TSP measurements. Not all beta gauges are US-EPA approved, with only the Andersen (FAG-Kigelfischer, Germany) and Wedding beta monitor having been approved. The performance of the TEOM ad BAM monitors are compared in Table 19-1. The TEOM tends to perform better than BAMs in many respects, particularly with regard to the precision of measurements made. An additional advantage of the TEOM (14000 series) is the optional inclusion of the ACCU system. This system allows for conditional sampling by time/date, particulate concentration and/or wind speed and direction. The application of the TEOM in combination with the ACCU system could therefore allow for the assessment of an operation's contribution to particulate concentrations occurring at a site on an on-line real-time basis. Table 20-1: Comparison of TEOM and BAM performance.

TEOM BAM Principle of operation

Measured mass on a filter based upon inertia (as fundamental as gravimetric method).

Inferred mass on a filter based upon the strength of a radioactive beam.

Measures only mass (represents a true mass measurement)

Do not measure mass but rather the transmission of beta rays

Advantages and disadvantages

Performs well under varying humidity conditions. Samples and measures at a defined filter face velocity and conditioning temperature to ensure standardized data under low humidity

Can produce erroneous measurements under changing humidity conditions

Not sensitive to particulate composition since it makes a mass-based measurement.

Sensitive to interferences (site/season specific) arising due to: particle composition, particle distribution across the filter, radioactive decay and the effect of air density in the radioactive beam.

Precision (measured by standard deviation)

Standard deviation for hourly data: ± 1.5-2.0 µg/m³. (Precision of ±5 µg/m3 for 10-minute averaged data.)

Beta monitors with strong source: standard deviation for hourly data: ± 15-20 µg/m³.

Beta monitors with weak source: hourly data not acceptable.

TEOMs have been found to typically under-predict actual particulate concentrations by a consistent amount (typically 18% to 25%). In the US TEOM results are typically multiplied by a factor of 1.3 to determine actual concentrations (this single factor is made possible by the consistency or high precision of the instrument). TEOMs tend to be less effective in



environments with elevated nitrate concentrations or high potentials for the adsorption of volatile compounds on particles. Beta attenuation monitors perform poorly in areas with soils that have a radioactive component.

Figure 20-2: TEOM sampler linked to the ACCUTM conditional sampling system.

A common disadvantage of the TEOM and BAM monitors is that they all require electricity to operate thus limiting the potential sites for the location of such monitors. A further disadvantage of the TEOM and BAM monitors are that they are relatively costly to purchase. Despite the relatively high costs of purchasing continuous real-time monitors such as the TEOM and beta gauge monitors, significant savings can be achieved in the operation of such monitors due to the low labour costs and the minimal filter handling required by these techniques.



20.2. Non-filter-based Monitors Locally-supplied, real-time but non-filter based monitors include the TSI DustTrak, the DustScan Sentinel Aerosol Monitor and the Topas Dust Monitor. Several of these monitors can be solar-powered negating the need for selecting a site with power access. Such monitors measures particle concentrations corresponding to various size fractions, including PM10, PM2.5 and PM1.0, and comprise many of the benefits of the TEOM and BAM monitors including:

• continuous, near-real-time aerosol mass monitoring, • a choice of averaging times from 1 minute to 24 hours, • limited operator intervention, and • minimal filter handling.

20.3. Data Transfer Options Although most analysers have internal data storage facilities, logging is usually carried out by means of a dedicated data logger (PC or specialised data logger). Data transfer may be undertaken in various ways:

• downloaded intermittently from the instrument - PC link cable required • real-time, continuous transfer via telemetry - telemetry control unit required • near real-time, intermittent transfer via radio link - requires transmitter & license to

use frequency • continuous download via satellite

In selecting the data transfer option possible future accreditation requirements must be taken into account, e.g.: (i) raw data is to be kept for minimum of 3 years, and (ii) all manipulations of data must be recorded.

20.4. Sampler and Data Transfer Recommendations The most suitable sampler type depends on the specific objectives of monitoring. Pertinent monitoring objectives in the case of the proposed PPC Riebeeck cement facility are expected to include: on-going compliance evaluation, on-going estimation of contribution to airborne particulate concentrations to background levels, and evaluation of the effectiveness of dust control measures implemented at the plant. Given the above objectives, and noting that international reference methods are likely to be the preferred approach during the promulgation of South African regulations for air quality monitoring it is recommended that PPC invest in the purchase of a filter-based, on-line monitor (e.g. TEOM, BAM). Real-time, continuous transfer of the measured concentrations (via telemetry, satellite, etc.) would contribute significantly to the use of such measurements to trigger rapid responses to pollution episodes.



Should the TEOM or BAM be considered too costly, investment in one of the non-filter based automatic monitors (e.g. DustTrak, DustScan, Topas). These instruments provide an indication of the range of particulate concentrations and despite possibly not being the preferred method for compliance monitoring, would provide the mine with a means of tracking progress made through emission reduction measure implementation.



21. APPENDIX G: METHOD OF ASSESSING THE ENVIRONMENTAL ISSUES AND ALTERNATIVES

The significant rating assessment methodology which has been recommended by Ninham Shand is discussed below. Table 21-1: Assessment criteria for the evaluation of impacts.

Criteria Category Description

Extent or spatial influence of impact

Regional Beyond a 20 km radius of the candidate site.

Local Within a 20 km radius of the candidate site.

Site specific On site or within the property boundary.

Magnitude of impact (at the indicated spatial scale)

High Natural and/ or social functions and/ or processes are severely altered

Medium Natural and/ or social functions and/ or processes are notably altered

Low Natural and/ or social functions and/ or processes are slightly altered

Very Low Natural and/ or social functions and/ or processes are negligibly altered

Zero Natural and/ or social functions and/ or processes remain unaltered

Duration of impact

Construction period Up to 3 years

Medium Term Up to 10 years after construction

Long Term More than 10 years after construction

The SIGNIFICANCE of an impact is derived by taking into account the temporal and spatial scales and magnitude. The means of arriving at a significance rating is explained in Table 21-2. Table 21-2: Definition of significance ratings.

Significance Ratings Level Of Criteria Required

High High magnitude with a regional extent and long term duration High magnitude with either a regional extent and medium term duration or a local extent and long term duration Medium magnitude with a regional extent and long term duration



Significance Ratings Level Of Criteria Required

Medium High magnitude with a local extent and medium term duration High magnitude with a regional extent and construction period or a site specific extent and long term duration High magnitude with either a local extent and construction period duration or a site specific extent and medium term duration Medium magnitude with any combination of extent and duration except site specific and construction period or regional and long term Low magnitude with a regional extent and long term duration

Low High magnitude with a site specific extent and construction period duration Medium magnitude with a site specific extent and construction period duration Low magnitude with any combination of extent and duration except site specific and construction period or regional and long term Very low magnitude with a regional extent and long term duration

Very low Low magnitude with a site specific extent and construction period duration Very low magnitude with any combination of extent and duration except regional and long term

Neutral Zero magnitude with any combination of extent and duration

Once the significance of an impact has been determined, the PROBABILITY of this impact occurring as well as the CONFIDENCE in the assessment of the impact would be determined using the rating systems outlined in Table 21-3 and Table 21-4, respectively. It is important to note that the significance of an impact should always be considered in conjunction with the probability of that impact occurring. Table 21-3: Definition of probability ratings.

Probability Ratings Criteria

Definite Estimated greater than 95 % chance of the impact occurring.

Probable Estimated 5 to 95 % chance of the impact occurring.

Unlikely Estimated less than 5 % chance of the impact occurring. Lastly, the REVERSIBILITY of the impact is estimated using the rating system outlined in Table 21-5.



Table 21-4: Definition of confidence ratings

Confidence Ratings Criteria

Certain Wealth of information on and sound understanding of the environmental factors potentially influencing the impact.

Sure Reasonable amount of useful information on and relatively sound understanding of the environmental factors potentially influencing the impact.

Unsure Limited useful information on and understanding of the environmental factors potentially influencing this impact.

Table 21-5: Definition of reversibility ratings

Reversibility Ratings Criteria

Irreversible The activity will lead to an impact that is in all practical terms permanent.

Reversible The impact is reversible within 2 years after the cause or stress is removed.

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PPC Riebeek West Upgrade Rev 0_1