AIR QUALITY IMPACT ASSESSMENT FOR THE MONDI MILL MODIFICATION, RICHARDS BAY

Project completed on behalf of SRK Consulting AIR QUALITY IMPACT ASSESSMENT FOR THE MONDI MILL MODIFICATION, RICHARDS BAY Report No.: APP/10/SRK-10 Rev 5 DATE: May 2011 Authors: GT Feig G Kornelius

Reference APP/10/SRK/10 Status Revision 5 Report Title Date June 2011 Client Prepared by Notice Declaration Copyright Warning Acknowledgements REPORT DETAILS Air Quality Impact Assessment for the third steam turbine at Mondi Richards Bay SRK Consulting Gregor T. Feig, PhD (Biogeochemistry, Mainz, IMPRS) Gerrit Kornelius PrEng PhD MBA BEng(Hons)(Chem) (Pretoria) Airshed Planning Professionals (Pty) Ltd is a consulting company located in Midrand, South Africa, specialising in all aspects of air quality, ranging from nearby neighbourhood concerns to regional air pollution impacts. The company originated in 1990 as Environmental Management Services, which amalgamated with its sister company, Matrix Environmental Consultants, in 2003. Airshed is an independent consulting firm with no interest in the project other than to fulfil the contract between the client and the consultant for delivery of specialised services as stipulated in the terms of reference. Unless otherwise noted, the copyright in all text and other matter (including the manner of presentation) is the exclusive property of Airshed Planning Professionals (Pty) Ltd. It is a criminal offence to reproduce and/or use, without written consent, any matter, technical procedure and/or technique contained in this document. We would like to thank Natalie Way-Jones from SRK Consulting for the help in preparing this report.

LIST OF ACRONYMS AND ABBREVIATIONS ACS American Cancer Society AQA Air Quality Act (South African) CAPCO Chief Air Pollution Control Officer DEA Department of Environmental Affairs. EC European Community EHS Environmental Health and Safety Guideline (WHO) EIA Environmental Impact Assessment g Gram GIIP Good International Industry Practice h Hour IFC International Finance Corporation of the World Bank IT Interim Target km Kilometre m Metre Mg Mega gram (10 3 kg) NA Not applicable NAAQS (SA) National Ambient Air Quality Standards ng nanogram (10 12 kg) PM 10 Particulate Matter with an aerodynamic diameter of less than 10 µm RBCAA Richards Bay Clean Air Association SABS South African Bureau of Standards SANS South African National Standard SAWS South African Weather Service TPA, tpa Mg per annum (10 3 kg/annum) TSP Total suspended Particulate, generally accepted as aerosols < 30 micron diameter UK United Kingdom µm Micron US EPA United States Environmental Protection Agency US EPA IRIS United States Integrated Risk Information System WHO World Health Organisation ii

Executive Summary Airshed Planning Professionals (Pty) Ltd was appointed by SRK Consulting to undertake an air quality impact assessment for the proposed modification of the power boiler facility and the installation of a chlorine dioxide storage facility at the Mondi Richards Bay pulp and paper mill. The proposed power boiler facility modification will consist of the refurbishment of the two existing coal fired boilers and the installation of a third steam turbine for the production of electricity, provision will be made for one of the boilers to be converted into a biomass boiler in the future. The chlorine dioxide facility will consist of two 250m³ above ground closed tanks. The aim of the investigation is to quantify the possible impacts resulting from the energy generating activities on the surrounding environment and on human health. To achieve this, a good understanding of the regional climate and local dispersion potential of the site is necessary. The primary pollutants of concern are the emissions of sulphur dioxide (SO 2 ) and oxides of nitrogen (NO x ) and particulate matter (PM 10 ) emissions from power generation activity. This study focused on the air quality impacts of the proposed Mondi Richards Bay modification including: Understanding the dispersion potential of the site based on regional meteorological data; Identification and quantification of all sources of air pollution from the steam boiler modification and from the construction of a 500m³ ClO 2 storage facility; Dispersion simulations to determine the impact zones from the refurbished steam boilers; Identification of the main sources of emission and impact and ranking of these sources for the purpose of mitigation measures to be implemented; and, Mitigation recommendations and management measures. Summary ClO 2 Storage Tank If the design of the chlorine dioxide storage tank meets the emission requirements of the National emission standards (HCl emission of 15mg/Nm³) it will be in accordance with the NEM:AQA. The ClO 2 storage tanks are sealed and not expected to release HCl. iii

Incremental Impact (Mondi Sources Only) Sulphur Dioxide (SO 2 ) The SO 2 emissions from the modified boilers at the Mondi Richards Bay facility are expected to reach a maximum of 2932 Mg/annum if the national emission limits are met. This is approximately 10.5% of the total annual SO 2 emission for the Richards Bay area. The Phase 1 scenario is expected to result in reduced ambient SO 2 concentrations due to the reduced SO 2 emission concentration and the lower total amount of SO 2 released annually. The direct impact of both the current and phase 1 operations at the power boilers is expected to be low, less than 10%, 25% and 34% of the annual, daily and hourly NAAQS standards respectively. Nitrogen Dioxide (NO 2 ) The scenarios show a significant difference in the NO 2 emissions between the current and Phase 1 boiler scenarios where the current NO 2 emission rate is 638.9Mg/annum and the phase 1 emission rate is expected to be 4383Mg/annum. This difference is due to the fact that the emission limits were used to determine the emission rate and probably represents an over estimation of what the actual emissions will be. The highest annual average ambient NO 2 concentration is expected to account for 4% of the NAAQS (National Ambient Air Quality Standard) under the current scenario and 15% of the NAAQS under the phase 1 scenario. For the hourly averaging period the highest NO 2 concentration from the current emissions is expected to be less than 15% of the NAAQS, while the highest hour from the Phase 1 scenario is expected to exceed the National standard but for less than the allowed 88 hours per year. Particulate matter (PM 10 ) The emissions of particulate matter from the modified Mondi Power boiler are expected to account for 7% of the total PM 10 emissions in the Richards Bay area. The impact from the modified boilers is likely to be small, less than 15% of the NAAQS for both the highest daily and annual averaging period. If the Phase 2 scenario is implemented it is expected that there will be a further reduction in the local PM 10 concentration due to the expected reduction in material handling related emissions. Cumulative Impact (Mondi Sources and Background) Sulphur Dioxide (SO 2 ) The cumulative impact of SO 2, where the other Richards Bay sources are included, shows exceedances of the NAAQS in the annual, daily and hourly averaging periods, From a study of the position of the areas of exceedance relative to the major sources and the individual impact of the Mondi Richards Bay power boiler sources, it is concluded that these exceedances are due to sources other than the Mondi Richards Bay power boilers. iv

Nitrogen Dioxide (NO 2 ) The cumulative NO 2 concentration does not show any exceedances of the NAAQS under either the current or the phase 1 scenarios for the annual averaging period, however there are exceedances in the hourly averaging period current and phase 1 scenarios although the number of exceedances is less than the 88 allowed annually. Particulate Matter When the cumulative impact of PM 10 is considered, exceedances of the NAAQS occur for both the annual and daily averaging periods. When the cumulative impacts are considered there are areas in exceedance of the NAAQS standards. From a study of the position of the areas of exceedance relative to the major sources and the individual impact of the Mondi Richards Bay power boiler sources, it is concluded that these exceedances are due to sources other than the Mondi Richards Bay power boilers. Conclusion The proposed modification of the power boilers at the Mondi Richards bay facility is likely to have a limited impact on the ambient air quality in the Richards Bay region, if the emission standards are met. Of the three pollutants that were considered during this study the greatest impact would be on the NO 2 concentrations, however this is a very conservative scenario using the national emission limits to determine the emission rate. There is expected to be a local increase in the PM 10 concentrations, mostly due to the increased coal handling to power the boilers, this however is likely to be reduced during the second phase of the modification when biomass is used as a fuel source. The ambient SO 2 concentrations are expected to decrease slightly with the modification if the national emission standards are met. v

Table of Contents LIST OF ACRONYMS AND ABBREVIATIONS...ii Summary...iii ClO 2 Storage Tank...iii Incremental Impact (Mondi Sources Only)...iv Cumulative Impact (Mondi Sources and Background)...iv Conclusion...v 1 Introduction... 1-1 1.1 Terms of Reference... 1-1 1.2 Project Description... 1-3 1.3 Outline of Report... 1-3 2 Methodology... 2-1 2.1 Site Description... 2-1 2.2 Sensitive Receptors... 2-1 2.3 Emissions Inventory... 2-1 2.4 Dispersion Model... 2-1 2.4.1 Methodology... 2-1 2.4.2 Dispersion Modelling Results... 2-3 2.5 Assumptions... 2-4 3 Legislative Overview of Air Quality Standards... 3-1 3.1 South African Legal Requirements According to the Air Quality Act No.39 of 2004... 3-1 3.2 National Ambient Air Quality Standards... 3-2 3.3 Listed Activities which may result in Air pollution... 3-4 4 BASELINE CHARACTERISATION... 4-1 4.1 Meteorological conditions... 4-1 4.2 Prevailing Synoptic Climatology... 4-2 4.3 Local Meteorology... 4-4 4.3.1 Surface Wind Field... 4-4 4.3.2 Temperature... 4-7 4.3.3 Precipitation... 4-9 vi

4.3.4 Mixing Height and Atmospheric Stability... 4-10 4.4 Existing sources... 4-12 4.4.1 Sources of Atmospheric Emissions... 4-12 4.4.2 Existing Sources of Emissions within the City of umhlathuze... 4-12 4.5 Ambient Air Quality... 4-18 4.5.1 Monitoring carried out in Richards Bay... 4-18 5 Impact Assessment... 5-1 5.1 Emissions inventory... 5-1 5.1.1 Chlorine Dioxide Storage Tank... 5-2 5.1.2 Stack emissions... 5-2 5.1.3 Material Handling Emissions... 5-3 5.2 Dispersion modelling results... 5-5 5.2.1 Sulphur Dioxide Concentrations... 5-5 5.2.2 Nitrogen Dioxide Concentrations... 5-19 5.2.3 Particulate Matter... 5-36 6 Summary and Conclusion... 6-1 6.1 Summary... 6-1 6.1.1 ClO 2 Storage Tank... 6-1 6.1.2 Incremental Impact (Mondi Sources Only)... 6-1 6.1.3 Cumulative Impact (Mondi Sources and Background)... 6-2 6.2 Conclusion... 6-2 7 References... 7-1 8 Appendix A: Methodology... 8-1 8.1 Calculation of Emission Factors... 8-1 8.1.1 Materials handling (confidence rating C- average)... 8-1 vii

Figures Figure 4-1: Major synoptic circulation types affecting southern Africa and their monthly frequencies of occurrence over a five year period (Preston-Whyte and Tyson 1988)... 4-4 Figure 4-2: Location of the five ambient monitoring stations within the study area (SGS 2010).. 4-5 Figure 4-3: Annual average wind roses depicting the wind profile at the RBCAA stations for the period January 2008 to December 2008... 4-6 Figure 4-4 Annual Wind roses for 2009 and 2010 for the meteorological station at Arboretum (SGS 2010)... 4-7 Figure 4-5 Temperature Profile for Richards Bay 2007-2010 (SGS 2010)... 4-9 Figure 4-6: & Petzer, 2006) 4-13 Location of all the main industries and mines within the area (after Liebenberg-Enslin Figure 4-7: Location of the five SO 2 ambient monitoring stations within the study area.... 4-19 Figure 4-8 Comparison of annual average SO2 for the period 2003 2010... 4-21 Figure 4-9 Daily average SO 2 concentration measured at Arboretum during 2008... 4-21 Figure 4-10 Daily average SO 2 concentration measured at Arboretum during 2009... 4-22 Figure 4-11 Daily average SO 2 concentration measured at Arboretum during 2010 (SGS 2010)... 4-22 Figure 4-12 Daily average SO 2 concentration measured at Brackenham during 2008... 4-23 Figure 4-13 Daily average SO 2 concentration measured at Brackenham during 2009... 4-23 Figure 4-14 Daily average SO 2 concentration measured at Brackenham during 2010 (SGS 2010). 4-24 Figure 4-15 Daily average SO 2 concentration measured at CBD during 2008... 4-24 Figure 4-16 Daily average SO 2 concentration measured at CBD during 2009... 4-25 Figure 4-17 Daily average SO 2 concentration measured at CBD during 2010 (SGS 2010)... 4-25 Figure 4-18 Daily average SO 2 concentration measured at Scorpio substation (cnr John Ross and West Central Arterial) during 2008... 4-26 viii

Figure 4-19 Daily average SO 2 concentration measured at Scorpio substation (cnr John Ross and West Central Arterial) during 2009... 4-26 Figure 4-20 Daily average SO 2 concentration measured at Scorpio substation (cnr John Ross and West Central Arterial) during 2010... 4-27 Figure 4-21 Daily average SO 2 concentration measured at Harbour West during 2008... 4-27 Figure 4-22 Daily average SO 2 concentration measured at Harbour West during 2009... 4-28 Figure 4-23 Daily average SO 2 concentration measured at Harbour West during 2010(SGS 2010) 4-28 Figure 4-24 Daily average PM 10 concentrations at the CBD during 2008... 4-31 Figure 4-25 Daily average PM 10 concentrations at the CBD during 2009... 4-31 Figure 4-26 Daily average PM 10 concentrations at Brackenham during 2008... 4-32 Figure 4-27 Daily average PM 10 concentrations at Brackenham during 2009... 4-32 Figure 5-1 Annual average SO 2 concentrations due to current Mondi Boiler operations (contours represent 0.38ppb blue, 0.76ppb green, 1.15ppb magenta and 1.53ppb orange).... 5-7 Figure 5-2 Annual average SO 2 concentrations Mondi Phase 1 sources only (contours represent 0.38ppb blue, 0.76ppb green, 1.15ppb magenta and 1.53ppb orange)... 5-7 Figure 5-3 Annual average SO 2 concentrations due to actual Mondi Boiler operations for 2010 (contours represent 0.38ppb blue, 0.76ppb green, 1.15ppb magenta and 1.53ppb orange).... 5-8 Figure 5-4 Annual cumulative SO 2 concentrations (Mondi current and background)... 5-9 Figure 5-5 Annual cumulative SO 2 concentrations (Mondi Phase1 and background)... 5-9 Figure 5-6 Annual cumulative SO 2 concentrations, Mondi actual 2010 and background)... 5-10 Figure 5-7 Highest Daily SO 2 concentrations, current Mondi boiler sources only. Contours represent 1.9ppb (blue), 3.8ppb (green), 5.8ppb (magenta) and 7.7ppb (orange).... 5-8 Figure 5-8 Highest Daily SO 2 concentrations, Mondi Phase 1 sources only. Contours represent 1.9ppb (blue), 3.8ppb (green), 5.8ppb (magenta) and 7.7ppb (orange).... 5-8 Figure 5-9 Highest Daily SO 2 concentrations, actual 2010 emissions Mondi boiler sources only. Contours represent 1.9ppb (blue), 3.8ppb (green), 5.8ppb (magenta) and 7.7ppb (orange).... 5-9 ix

Figure 5-10 Highest Daily SO 2 concentrations, Mondi current and background sources. Contours represent 28.8ppb (blue), 46.1ppb (green), 76.8ppb (magenta) and 115.2ppb (orange)... 5-10 Figure 5-11 Highest Daily SO 2 concentrations, Mondi Phase1 and background sources. Contours represent 28.8ppb (blue), 46.1ppb (green), 76.8ppb (magenta) and 115.2ppb (orange)... 5-10 Figure 5-12 Highest Daily SO 2 concentrations, Mondi 2010 actual and background sources. Contours represent 28.8ppb (blue), 46.1ppb (green), 76.8ppb (magenta) and 115.2ppb (orange)... 5-11 Figure 5-13 SO 2 Daily frequency of exceedance of the South African National Ambient Air Quality standard of 125 µg/m³ (48ppb), Baseline + Current contour represents area where standard is exceeded more than 4 days per annum... 5-12 Figure 5-14 SO 2 Daily frequency of exceedance of the South African National Ambient Air Quality standard of 125 µg/m³ (48ppb), Baseline + Phase 1 contour represents area where standard is exceeded more than 4 days per annum... 5-12 Figure 5-15 Pollution Rose for SO 2 for the Scorpio station 2010 (SGS 2010)... 5-12 Figure 5-16 Highest hourly SO 2 concentrations due to current Mondi activities. Contour lines represent 9.6ppb (blue), 19.2 ppb (green), 28.8 ppb (magenta) and 38.5ppb (orange).... 5-13 Figure 5-17 Highest hourly SO 2 concentrations due to Phase 1 activities. Contour lines represent 9.6ppb (blue), 19.2 ppb (green), 28.8 ppb (magenta) and 38.5ppb (orange).... 5-13 Figure 5-18 Highest hourly SO 2 concentrations due to the actual Mondi boiler activities in 2010. Contour lines represent 9.6ppb (blue), 19.2 ppb (green), 28.8 ppb (magenta) and 38.5ppb (orange). 5-14 Figure 5-19 Cumulative highest hourly SO 2 concentrations, Mondi current and background sources. Contours represent 67ppb (blue), 134ppb (green), 193ppb (magenta) and 269ppb (orange).... 5-15 Figure 5-20 Cumulative highest hourly SO 2 concentrations, Mondi Phase1 and background sources. Contours represent 67ppb (blue), 134ppb (green), 193ppb (magenta) and 269ppb (orange).... 5-15 Figure 5-21 Cumulative highest hourly SO 2 concentrations, Mondi actual 2010 and background sources. Contours represent 67ppb (blue), 134ppb (green), 193ppb (magenta) and 269ppb (orange).... 5-16 Figure 5-22 Frequency of exceedance of the South African National Ambient Air Quality standard of 350 µg/m³ (134ppb), Baseline and Current contour represents area where standard is exceeded more than 88 hours per annum.... 5-17 x

Figure 5-23 Frequency of exceedance of the South African National Ambient Air Quality standard of 350 µg/m³ (134ppb), Baseline + Phase 1 contour represents area where standard is exceeded more than 88 hours per annum.... 5-17 Figure 5-24 Annual average NO 2 concentrations, current power boiler sources only. Contours represent 0.15ppb (blue), 0.32ppb (green), 0.5ppb (magenta) and 0.64ppb (orange)... 5-20 Figure 5-25 Annual average NO 2 concentrations, Mondi Phase 1 sources only. Contours represent 0.15ppb (blue), 0.32ppb (green), 0.5ppb (magenta) and 0.64ppb (orange).... 5-20 Figure 5-26 Annual average NO 2 concentrations, actual 2010 power boiler sources only. Contours represent 0.15ppb (blue), 0.32ppb (green), 0.5ppb (magenta) and 0.64ppb (orange)... 5-21 Figure 5-27 Annual average NO 2 concentrations, baseline and Mondi current. Contours represent 0.53ppb (blue), 1.05ppb (green), 1.6ppb (magenta) and 2.6ppb (orange).... 5-22 Figure 5-28 Annual average NO 2 concentrations, baseline and Mondi Phase 1 sources. Contours represent 0.53ppb (blue), 1.05ppb (green), 1.6ppb (magenta) and 2.6ppb (orange)... 5-22 Figure 5-29 Annual average NO 2 concentrations, baseline and Mondi actual 2010. Contours represent 0.53ppb (blue), 1.05ppb (green), 1.6ppb (magenta) and 2.6ppb (orange).... 5-23 Figure 5-30 Highest hourly NO 2 concentrations, current sources only. Contours represent 5.3ppb (blue), 26.3ppb (green), 52.6ppb (magenta) and 106ppb (orange).... 5-25 Figure 5-31 Highest hourly NO 2 concentrations, Mondi Phase 1 sources only. Contours represent 5.3ppb (blue), 26.3ppb (green), 52.6ppb (magenta) and 106ppb (orange).... 5-25 Figure 5-32 Highest hourly NO 2 concentrations, actual 2010 sources only. Contours represent 5.3ppb (blue), 26.3ppb (green), 52.6ppb (magenta) and 106ppb (orange).... 5-26 Figure 5-33 Highest hourly NO 2 concentrations, Mondi current and background sources. Contours represent 26.3ppb (blue), 52.6ppb (green), 78.9ppb (magenta) and 106ppb (orange)... 5-27 Figure 5-34 Highest hourly NO 2 concentrations, Mondi Phase 1 and background sources. Contours represent 26.3ppb (blue), 52.6ppb (green), 78.9ppb (magenta) and 106ppb (orange)... 5-27 Figure 5-35 Highest hourly NO 2 concentrations, Mondi actual 2010 and background sources. Contours represent 26.3ppb (blue), 52.6ppb (green), 78.9ppb (magenta) and 106ppb (orange)... 5-28 Figure 5-36 Expected annual average NO 2 concentrations as a result of phase 1 activities at Mondi. 5-31 xi

Figure 5-37 Expected annual average NO 2 concentrations as a result of phase 2 activities at Mondi. 5-31 Figure 5-38 Expected annual average NO 2 concentrations as a result of phase 1 activities at Mondi plus background.... 5-32 Figure 5-39 Expected annual average NO 2 concentrations as a result of phase 2 activities at Mondi plus background.... 5-32 Figure 5-40 Expected highest hourly NO 2 concentrations as a result of phase 1 activities at Mondi.5-33 Figure 5-41 Expected highest hourly NO 2 concentrations as a result of phase 2 activities at Mondi.5-33 Figure 5-42 Expected highest hourly NO 2 concentrations as a result of phase 1 activities at Mondi plus Richards Bay baseline... 5-34 Figure 5-43 Expected highest hourly NO 2 concentrations as a result of phase 2 activities at Mondi plus Richards Bay baseline... 5-34 Figure 5-44 PM 10 annual average, Mondi current sources only... 5-37 Figure 5-45 PM 10 annual average, Mondi Phase 1 sources only... 5-37 Figure 5-46 PM 10 annual average, Mondi actual 2010 sources only.... 5-38 Figure 5-47 PM 10 annual average, Mondi current and background sources.... 5-39 Figure 5-48 PM 10 annual average, Mondi Phase 1 and background sources.... 5-39 Figure 5-49 PM 10 annual average, Mondi 2010 actual and background sources... 5-40 Figure 5-50 PM 10 highest daily, current sources only.... 5-42 Figure 5-51 PM 10 highest daily, Mondi Phase 1 sources only... 5-42 Figure 5-52 PM 10 highest daily, actual 2010 emissions Mondi power boiler sources only.... 5-43 Figure 5-53 PM 10 highest daily concentrations, baseline and current PM 10 emissions.... 5-44 Figure 5-54 PM10 highest daily concentration, baseline and Phase 1 PM 10 emissions... 5-44 Figure 5-55 Highest daily PM 10 concentrations, baseline and actual 2010 PM 10 emissions.... 5-45 Figure 5-56 Frequency of exceedance of the Daily PM standard of 75µg/m, baseline plus current Mondi emissions... 5-46 xii

Figure 5-57 Frequency of exceedance of the Daily PM standard of 75µg/m³, baseline plus Phase 1 Mondi emissions... 5-46 xiii

Tables Table 3-1 National Ambient Air Quality Standards (DEA 2009)... 3-3 Table 3-2 South African Emission Limits for Solid Fuel combustion installations (DEA 2010)... 3-4 Table 3-3 South African emission Limits for solid biomass combustion installations (DEA 2010)... 3-5 Table 3-4 South African emission Limits for Chlorine Dioxide Plant (DEA 2010)... 3-5 Table 4-1 Long-term minimum, maximum and mean temperature ( C) for Richards Bay for the period 1951-1984 (Schulze, 1986), and for 1970-1990 (SAWS, 2005)... 4-8 Table 4-2: Long-term average monthly rainfall (SAWS, 2005)... 4-10 Table 4-3: Atmospheric Stability Classes... 4-11 Table 4-4: All industrial sources within the study area and associated air pollutants... 4-14 Table 4-5 Percentage SO 2 data capture for 2007-2010... 4-20 Table 4-6: Comparison of SO 2 annual averages (ppb) for the period 2003-2010 (Ecoserv)... 4-20 Table 4-7: Highest SO 2 concentrations (ppb) measured at each station for 2007 to 2010 and percent of standards... 4-29 Table 4-8: Percentage PM 10 data capture and annual average concentrations for 2007-2010.. 4-30 Table 4-9 Maximum daily average particulate concentrations for 2007-2010... 4-30 Table 5-1 Emission rates from the boiler stack... 5-2 Table 5-2 Emission concentrations from the boiler stack... 5-3 Table 5-3 Particulate emissions from the material handling operations Phase 1 scenario... 5-4 Table 5-4 Summary of maximum modelled SO 2 Concentrations... 5-18 Table 5-5 Summary of Maximum Modelled NO 2 Concentrations... 5-35 Table 5-6 Summary of Maximum modelled PM 10 concentrations... 5-47 xiv

Air Quality Impact Assessment for the Mondi Mill Modification, Richards Bay 1 Introduction Airshed Planning Professionals (Pty) Ltd was appointed by SRK Consulting to undertake an air quality impact assessment for the proposed third steam turbine at the Mondi facility in Richards Bay. The aim of the investigation is to quantify the possible impacts resulting from the increased capacity of steam turbine operation on the surrounding environment and on human health. To achieve this, a good understanding of the regional climate and local dispersion potential of the site is necessary. The primary pollutants of concern are the emissions of sulphur dioxide (SO 2 ) and oxides of nitrogen (NO x ) and particulate matter (PM 10 ) from the steam turbine boiler. Sulphur dioxide is an important criteria pollutant due to its health effects, and is damaging to the human respiratory function (on exposure to bodily fluids sulphuric acid is formed). Exposure to sulphur dioxide concentrations above certain threshold levels increases the prevalence of chronic respiratory disease and the risk of acute respiratory illness. Due to it being highly soluble, sulphur dioxide is more likely to be adsorbed in the upper airways rather than penetrate to the pulmonary region. Nitrogen dioxide (NO 2 ) is a criteria pollutant with implications for human health. Human respiratory tract irritation represents a direct effect of NO x exposures. Due to it being relatively insoluble (relative to sulphur dioxide), NO 2 can penetrate deep into the lungs where tissue damage occurs. Effects of NO 2 exposure include alveolar tissue disruption and obstruction of the respiratory bronchioles. Longterm effects of exposure include increased potentials for lung infections (Koenig, 2000). Particulate matter from fly ash released from the steam boiler is a criteria pollutant. PM 10 (particulate matter less than 10µm in diameter) due to its small size has the ability to penetrate deep into lungs and therefore has important health implications. In addition small quantities of toxic and/or persistent organic compounds and heavy metals are likely to be adsorbed on to the surface of the particulate matter. 1.1 Terms of Reference The terms of reference for this study focused on the air quality impacts of the proposed Mondi Richards Bay power boiler modification including: 1-1

Understanding the dispersion potential of the site based on regional meteorological data; Identification and quantification of all sources of air pollution from the steam boiler modification and from the construction of a 500m³ ClO 2 storage facility; Dispersion simulations to determine the impact zones from the modified steam boiler operations; Identification of the main sources of emission and impact and ranking of these sources for the purpose of mitigation measures to be implemented; and Mitigation recommendations and management measures. 1-2

1.2 Project Description The Mondi Richards Bay steam boiler modification project is situated in the Mondi Mill facility in the town of Richards Bay in the umhlathuze municipality in the province of KwaZulu-Natal. The objective of project is to identify the changes in atmospheric emissions due to the modification of the current power producing facilities at the plant. The proposed power boiler facility modification will consist of the refurbishment of the two existing coal fired boilers and the installation of a third steam turbine for the production of electricity, provision will be made for one of the boilers to be converted into a biomass boiler in the future, which would use bark and other material unsuitable for pulping from the chipping facility. The modification proposed for this project (which are expected to have been completed by 2015) have the potential of producing a number of positive impacts on the air quality; firstly the refurbishment of the boilers will require the installation of flue gas desulphurisation infrastructure to ensure that the boiler emissions meet the National Emission Standards; secondly it is proposed that there will be the co-generation of steam and electricity, resulting in greater energy efficiency and a reduced reliance on Eskom for electricity supply. If the second phase is undertaken with the conversion of one of the boilers from a coal fuel source to a biomass fuel source it is expected that there will be a potential reduction in the SO 2 emissions (since biomass has a lower sulphur content than coal). This fuel substitution may result in a net reduction in greenhouse gas emissions (Baral and Guha 2004). For the purposes of this project all emission estimates were based on the national emission limits which have the same standard for both coal and biomass fired power generation. The findings are therefore valid for both the fuel types. It must however be noted that the sulphur content of biomass is likely to be much lower than that of coal. It is therefore expected that the ambient SO 2 concentration will be lower when biomass is used. A second section of the project is to determine the impact of installing a 500m³ chlorine dioxide storage facility to provide chlorine dioxide for the bleaching plant when the chlorine generator is out of service. The chlorine dioxide facility will consist of two 250m³ above ground closed tanks. It is not expected that the chlorine dioxide storage tanks would result in any releases on HCl, which is the pollutant of concern with this facility 1.3 Outline of Report This report is divided into eight sections: 1-3

Chapter 1 is the introduction which provides the terms of reference a description of the project and an outline of the most important parts of the study. Chapter 2 covers the methodology including a site description, a description of the sensitive receptor points in the region, a description of the emission inventory methodology and requirements, a description of the dispersion model and a list of the assumptions made during this study. Chapter 3 provides an overview of the legislation and guidelines pertaining to air quality in South Africa, including the Air Quality Act, National Ambient Air Quality Standards, and the National Emission Limits. Chapter 4 provides information on the background climate, weather, atmospheric dispersion potential and the background air quality. Chapter 5 covers the air quality impact assessment, including the emissions inventory, the dispersion modelling results Chapter 6 is the summary and conclusions, where the impacts are summarized and the impact discussed. Chapter 7 is a bibliography of the literature consulted for this study Appendix A is an in depth discussion of the methodology, including the emission factors that were used to calculate emissions from various material handling operations. 1-4

2 Methodology 2.1 Site Description Richards Bay is a harbour town situated on the KwaZulu-Natal North coast and contains the largest coal terminal in the southern hemisphere. Mondi operates a pulp and paper mill to the west of the port (28 76S and 31 99E) at an altitude of 33m above sea level. 2.2 Sensitive Receptors A number of sensitive receptors occur in the vicinity of the Mondi facility including the industrial area of Alton, located approximately 1km to the east of the plant; the harbour and coal terminal located 5km to the south east of the plant, the residential suburbs of Richards Bay 5km to the east and north east of the Mondi facility, Empangeni 8km to the west and Bhiliya 8km to the south west of the Mondi paper mill. 2.3 Emissions Inventory An emissions inventory was used to identify the most important air pollution sources and to estimate the total emissions from each of these sources. Where possible this was done using information provided by the client. Emissions from this project are expected to be due to two main sources, firstly the emissions from the stack; these were calculated from the emission limits published in the National Environmental Management: Air Quality Act (NEMAQA) (DEA 2004; DEA 2010) for sulphur dioxide (SO 2 ), nitrogen oxides (NO x ) calculated as nitrogen dioxide (NO 2 ) and particulate matter (PM 10 ) from the boilers. Particulate matter emissions from material handling operations were calculated using an emission factor derived from the Australian National Pollution Inventory documentation (NPi 2001). 2.4 Dispersion Model 2.4.1 Methodology The use of dispersion modelling by facilities in the Richards Bay area is standardised by the Richards Bay Clean Air Association (RBCAA) to the use of the HAWK model, which is run on-line for all the facilities in the Richards Bay area on a 5 minute time step. For predictive purposes the same model was used to enable a direct comparison between the results. This does have the advantage that all the other major industrial sources in the Richards Bay area are well characterised and therefore the background data is fairly good. 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. 2-1

Increasing reliance has been placed on ground level air pollution concentration estimates from models as the primary basis for environmental and health impact assessments, risk assessments and determining emission control requirements. In the selection of a dispersion model it is important to understand the complexity of the dispersion potential of the area (i.e. the terrain and meteorology), and the potential scale and significance of potential effects (i.e. other sources that might have an influence the ground level concentrations). It was decided to use the HAWK model currently utilised by the RBCAA for dispersion simulations within the study area. The HAWK dispersion model has the ability to simulate unsteady emissions and heavy clouds. The model allows calm, or no-wind conditions, as well as spatially and temporally varying wind fields produced by complex topography. The software package consists of a group of Lagrangian Puff-type models, each applicable to a different dispersion mechanism (e.g. neutral or buoyant normal gases, heavy gases, particles etc.). The choice of dispersion mechanism is done automatically by the code, depending on the factors listed above. The various models in the code were derived from internationally published articles, the accuracy of which is discussed by the respective authors. Input data types required for the HAWK model include: source data, meteorological data, and information on the nature of the receptor grid. 2.4.1.1 Source Data Requirements The HAWK model is able to model various source types point (stack/chimney/vent), area, line, volume and fire sources. The source groups included in the model only relate to industrial sources which are modelled as point sources. It is understood that there are a number of other sources in the area, but they have not been quantified in the RBCAA database. All sources require emission rates, coordinates, height above sea level and release height of emissions. In addition, point source parameters include stack height, stack diameter, exit temperature and volumetric flow rate. 2.4.1.2 Meteorological Requirements Meteorological parameters that were included in the Hawk model consisted of pressure, wind speed, wind direction, temperature, precipitation, solar radiation, and humidity. Meteorological data for the year 2008 was used for the dispersion simulations using the HAWK model. SGS provided the data on behalf of the RBCAA. 2-2

2.4.1.3 Receptor Grid A grid of 39 km east-west, and 30 km north-south was used to include industries within the umhlathuze and Mbonambi municipalities, with 2043 receptor points over the modelled area. 2.4.1.4 Model Accuracy 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. Nevertheless, dispersion modelling is generally accepted to be a valuable tool in air quality management practice. 2.4.2 Dispersion Modelling Results Simulations were undertaken to determine the ground level concentrations from the main pollutants of concern within the study area reflecting current operating conditions. Criteria pollutants included are inhalable particulate matter (PM 10 ) sulphur dioxide (SO 2 ) and nitrogen dioxide (NO 2 ). The predicted exposure periods include highest hourly, daily and annual averages. Dispersion simulations for SO 2 reflect concentration contours for emissions from all major industrial sources within the umhlathuze and Mbonambi areas. The predicted ambient SO 2 concentrations are shown for the hourly, daily and annual averaging periods. Data is presented for the current scenario, the phase 1 scenario and both current and phase 1 with the background modelled SO 2 concentration from all other sources in the Hawk model. Dispersion simulations for NO 2 reflect concentration contours for the annual and hourly averaging periods (no daily average limit values exist for NO 2 ). Data is presented for the current scenario, the phase 1 scenario and both current and phase 1 with the background modelled NO 2 concentration from all other sources in the Hawk model. 2-3

The predicted air concentrations of inhalable particles (PM 10 ) are shown as the highest daily and annual average periods for comparison to the respective ambient air concentration limits no hourly average limit values exist- for the current scenario, the phase 1 scenario and both current and phase 1 with the background modelled PM 10 concentration from all other sources in the Hawk model. Particulate matter from the industrial point sources was assumed to be within the PM 10 fraction, as control equipment limiting the emission of larger particles is fitted to the point sources. 2.5 Assumptions In utilizing a dispersion model and emissions inventory such as was done in this project it is necessary to make a number of assumptions, the most important of which relate to the inherent accuracy of the dispersion model that is used, the assumptions made during the emission calculations and the meteorology that is used. These assumptions include: Routine emissions were estimated and modelled. Atmospheric releases occurring as a result of accidents were not accounted for. A minimum of 1 year, and typically 3 to 5 years of meteorological data are generally recommended for use in atmospheric dispersion modelling for air quality impact assessment purposes. One year of meteorological data was analysed (2008), due to the extended running time of the HAWK model. The year 2008 was chosen since the Richards Bay background has been modelled for this year and it therefore provides an opportunity to compare the modified Mondi impacts against the background ambient air quality at Richards Bay. A comparison was made with the wind roses for and temperature profiles for the years 2009 and 2010 and these years show similar wind fields and meteorological conditions. We therefore feel confident that the meteorology for 2008 is representative of the conditions that occur in Richards Bay (see Figure 4-3, Figure 4-4 and Figure 4-5). Power boiler emission estimates were limited to include SO 2, NO x and PM 10., While other emissions are known to occur they were not modelled in this study. Operations were assumed to be twenty-four hours over a 365 day year as a conservative approach. 2-4

3 Legislative Overview of Air Quality Standards Prior to assessing the impact of the proposed modification steam boilers at the Mondi Richards Bay site, reference needs be made to the environmental regulations and guidelines governing the emissions and impact of such operations. 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. The 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 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. The application of these standards varies, with some countries allowing a certain number of exceedances of each of the standards per year. 3.1 South African Legal Requirements According to the Air Quality Act No.39 of 2004 Under the (now defunct) Atmospheric Pollution Prevention Act (Act No 45 of 1965) (APPA) the focus was mainly on source-based controls with Registration Certificates 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 and smelting. Best Practicable Means (BPM), on which the Registration Certificate requirements 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) was 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 by DEA, no provision was made under the APPA to publish formal ambient air quality standards or emission standards. The decision as to what constituted 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 APPA was outdated and not in line with international best practice. It also proved inadequate to facilitate the implementation of the principles underpinning the National Environmental Management 3-1

Act (NEMA) and the Integrated Pollution and Waste Management (IP&WM) white paper. In this light, the National Environmental Management: Air Quality Act (Act no. 39 of 2004) was drafted, shifting the approach from source based control to decentralised air quality management through an effectsbased approach. The new National Environmental Management: Air Quality Act (DEA 2004) has shifted the approach of air quality management from source-based control only to the reduction of impact on the receiving environment. The Act has also placed the responsibility of air quality management on the local authorities (district and metropolitan municipalities) who are 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. 3.2 National Ambient Air Quality Standards The Air Quality Act (AQA) makes provision for the setting of ambient air quality standards and emission limits at national level, which provides the objective for air quality management. More stringent ambient standards may be implemented by provincial and metropolitan authorities. National ambient standards were published on 24 Dec 2009 (GG 32816) as per Table 3-1 (DEA 2009). 3-2

Table 3-1 National Ambient Air Quality Standards (DEA 2009) Averaging Period Concentration Allowed Frequency of Exceedence Compliance Date Sulphur Dioxide (SO 2) 10 minutes 500µg/m³ (191ppb) 526 Immediate 1 hour 350µg/m³ (134ppb) 88 Immediate 24 hours 125µg/m³(48ppb) 4 Immediate 1 year 50µg/m³ (19ppb) 0 Immediate Nitrogen Dioxide (NO 2) 1 hour 200µg/m³ (106ppb) 88 Immediate 1 year 40µg/m³ (21ppb) 0 Immediate Particulate Matter (PM 10) 24 hours 120µg/m³ 4 Immediate- End 24 hours 75µg/m³ 4 1 January 2015 2014 1 year 50µg/m³ 0 Immediate-End 1 year 40µg/m³ 0 1 January 2015 2014 Ozone (O 3) 8 hours (running) 120µg/m³ (61ppb) 11 Immediate Benzene (C 6H 6) 1 year 10µg/m³ (3.2ppb) 0 Immediate-end 2014 1 year 5µg/m³ (1.6ppb) 0 1 January 2015 Lead (Pb) 1 year 0.5µg/m³ 0 Immediate Carbon Monoxide (CO) 3-3

Averaging Period Concentration Allowed Frequency of Exceedence Compliance Date 1 hour 30mg/m³ (26ppm) 88 Immediate 8 hour (calculated from 1 10 mg/m³ (8.7ppm) 11 Immediate hour averages) 3.3 Listed Activities which may result in Air pollution Listed activities were identified by the Minister and include all activities regarded to have a significant detrimental effect on the environment, including health. Emission limits are established at national level for each of these activities (DEA 2010) and an atmospheric emission licence will be required in order to operate. With the decentralisation of power to provincial and local authority level, district and metropolitan municipalities will be responsible for the issuing of licences for listed activities. An air quality officer appointed by local authorities and responsible for the issuing of atmospheric emission licences may require a company or person to submit atmospheric impact reports in order to determine the impact of the proposed emissions on ambient air quality. The proposed modification of the coal fired steam boilers falls under subcategory 1-1 of the regulations and must meet emission standards as given in Table 3-2 below. During phase 2 when one of the boilers is to be converted to operate on solid biomass the emission standards fall under subcategory 1.3: Solid biomass combustion installations. The installation of a chlorine dioxide storage facility may trigger listed activity Subcategory 9.4 relating to chlorine dioxide plants as given in Table 3-4 although the legislation refers to the production and use, rather than the storage of ClO 2. Table 3-2 South African Emission Limits for Solid Fuel combustion installations (DEA 2010) Description Solid fuels (excluding biomass) combustion installations used primarily used for steam raising or electricity generation Application All installations with design capacity equal to or greater than 50MW heat input per unit, based on the lower calorific value of the fuel used Substance or mixture of substances Plant Mg/Nm 3 under normal conditions of 10% Common Name Chemical symbol Status O 2, 273 Kelvin and 101.3 kpa Particulate matter N/A New 50 Existing 100 Sulphur Dioxide SO 2 New 500 Existing 3500 Oxides of nitrogen NO x expressed as New 750 NO 2 Existing 1100 3-4

Table 3-3 South African emission Limits for solid biomass combustion installations (DEA 2010) Description Solid biomass fuel combustion installations used primarily used for steam raising or electricity generation Application All installations with design capacity equal to or greater than 50MW heat input per unit, based on the lower calorific value of the fuel used Substance or mixture of substances Plant Mg/Nm 3 under normal conditions of 10% Common Name Chemical symbol Status O 2, 273 Kelvin and 101.3 kpa Particulate matter N/A New 50 Existing 100 Sulphur Dioxide SO 2 New 500 Existing 3500 Oxides of nitrogen NO x expressed as New 750 NO 2 Existing 1100 Table 3-4 South African emission Limits for Chlorine Dioxide Plant (DEA 2010) Description Production and use of chlorine dioxide for paper production Application All installations Substance or mixture of substances mg/nm³ under normal Common Name Chemical Symbol Plant Status conditions of 273 Kelvin and 101.3 kpa Hydrogen Chloride HCl New 15 Existing 30 3-5

4 BASELINE CHARACTERISATION 4.1 Meteorological conditions Meteorological characteristics of a site govern the dispersion, transformation and eventual removal of pollutants from the atmosphere (Pasquill and Smith 1983; Godish 1990). In the assessment of the possible impacts from air pollutants on the surrounding environment and human health, a good understanding of the regional climate and local air dispersion potential of a site is essential. 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 vertical component is defined by the stability of the atmosphere and the depth of the surface mixing layer. 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, determine the general path pollutants will follow, and the extent of cross-wind spreading (Shaw and Munn 1971; Pasquill and Smith 1983; Oke 1990).The analysis of hourly average meteorological data is necessary to facilitate a comprehensive understanding of the ventilation potential of the site. The vertical dispersion of pollution is largely a function of the wind field. The wind speed determines both the distance of downward transport and the rate of dilution of pollutants. The generation of mechanical turbulence is similarly a function of the wind speed, in combination with the surface roughness. Air temperature is an important parameter for the development of the mixing and inversion layers. It also determines the effect of plume buoyancy as the larger the temperature difference between ambient air and the plume, the higher the plume will rise. This in turn will affect the rate of dissipation of pollutants before it reaches ground level. Incoming solar radiation also determines the rate of development and dissipation of the mixing layer. Relative humidity is an inverse function of ambient air temperature, increasing as ambient air temperature decreases. Precipitation represents an effective removal mechanism of atmospheric pollutants and is therefore frequently considered during air pollution studies. Evaporation is a function of ambient temperature, wind and the saturation deficit of the air. Evaporation rates have important implications for the design and implementation of effective dust control programmes. Pollution concentration levels 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 4-1

seasonal changes, in the wind field and stability regime are functions of atmospheric processes operating at various temporal and spatial scales (Goldreich and Tyson 1988). Atmospheric processes at macro- and meso-scales need therefore be taken into account in order to accurately parameterise the atmospheric dispersion potential of a particular area. In characterising the meso-scale dispersion potential of the site reference is made to the RBCAA s five meteorological and ambient monitoring stations data (managed by Ecoserv Consulting). Ambient monitoring stations equipped with meteorological stations measure wind speed, wind direction, temperature and humidity. Meteorological data for the year 2008 was used in this study Parameters that need to be taken into account in the characterisation of meso-scale ventilation potentials include wind speed, wind direction, extent of atmospheric turbulence, ambient air temperature and mixing depth. 4.2 Prevailing Synoptic Climatology Situated in the subtropical high-pressure belt, southern Africa is influenced by several high-pressure cells, in addition to various circulation systems prevailing in the adjacent tropical and temperature latitudes. The mean circulation of the atmosphere over southern Africa is anticyclonic throughout the year (except near the surface) due to the dominance of three high-pressure cells, viz. the South Atlantic HP off the west coast, the South Indian HP off the east coast, and the continental HP over the interior. Five major synoptic scale circulation patterns dominate (Figure 4-1) (Tyson, Preston-Whyte et al. 1976; Preston-Whyte, Diab et al. 1977; Schulze 1980; Preston-Whyte and Tyson 1988). The most important of these is the semi-permanent, subtropical continental anticyclones that are shown by (Preston-Whyte and Tyson 1988) to dominate 70% of the time during winter and 20% of the time in summer. This leads to the establishment of extremely stable atmospheric conditions that can persist at various levels in the atmosphere for long periods. Seasonal variations in the position and intensity of the HP cells determine the extent to which the tropical easterlies and the circumpolar westerlies impact on the atmosphere over the subcontinent. The tropical easterlies, and the occurrence of easterly waves and lows, affect most of southern Africa throughout the year. In winter, the high-pressure belt intensifies and moves northward, the upper level circumpolar westerlies expand and displace the upper tropical easterlies toward the equator. The winter weather of South Africa is, therefore, largely dominated by perturbations in the westerly circulation. Such perturbations take the form of a succession of cyclones or anticyclones moving eastwards around the coast or across the country. During summer months, the anticyclonic belt weakens and shifts southwards, allowing the tropical easterly flow to resume its influence over South Africa. A weak heat low characterises the near surface summer circulation over the interior, replacing the strongly anticyclonic winter-time circulation (Schulze 1980; Preston-Whyte and Tyson 1988). 4-2

Anticyclones situated over the subcontinent are associated with convergence in the upper levels of the troposphere, strong subsidence throughout the troposphere, and divergence in the near-surface wind field. Subsidence inversions, fine conditions with little or no rainfall, and light variable winds occur as a result of such widespread anticyclonic subsidence. Anticyclones occur most frequently over the interior during winter months, with a maximum frequency of occurrence of 79% in June and July. During December such anticyclones only occur 11% of the time. Although widespread subsidence dominates the winter months, weather occurs as a result of uplift produced by localized systems. Tropical easterly waves give rise to surface convergence and upper air (500 hpa) divergence to the east of the wave resulting in strong uplift, instability and the potential for precipitation. To the west of the wave, surface divergence and upper-level convergence produces subsidence, and consequently fine clear conditions with no precipitation. Easterly lows are usually deeper systems than are easterly waves, with upper-level divergence to the east of the low occurring at higher levels resulting in strong uplift through the 500 hpa level and the occurrence of copious rains. Easterly waves and lows occur almost exclusively during summer months, and are largely responsible for the summer rainfall pattern and the northerly wind component that occurs over the interior. Westerly waves are characterised by concomitant surface convergence and upper-level divergence that produce sustained uplift, cloud and the potential for precipitation to the rear of the trough. Cold fronts are associated with westerly waves and occur predominantly during winter when the amplitude of such disturbances is greatest. Low-level convergence in the southerly airflow occurs to the rear of the front producing favourable conditions for convection. Airflow ahead of the front has a distinct northerly component, and stable and generally cloud-free conditions prevail as a result of subsidence and low-level divergence. The passage of a cold front is therefore characterised by distinctive cloud bands and pronounced variations in wind direction, wind speeds, temperature, humidity, and surface pressure. Following the passage of the cold front the northerly wind is replaced by winds with a distinct southerly component. Temperature decreases immediately after the passage of the front, with minimum temperatures being experienced on the first morning after the cloud associated with the front clears. Strong radiational cooling due to the absence of cloud cover and the advection of cold southerly air combine to produce the lowest temperatures. 4-3

Figure 4-1: Major synoptic circulation types affecting southern Africa and their monthly frequencies of occurrence over a five year period (Preston-Whyte and Tyson 1988) 4.3 Local Meteorology The meterorology and baseline emissions inventory used in this study was obtained from the Richards Bay Clean Air Association (RBCAA). The monitoring network currently consists of 10 stations (all except Mtunzini and St Lucia are presented in Figure 4-2). Meteorological measurements are conducted for all the stations except the CBD station (SGS 2010). 4.3.1 Surface Wind Field Each of the monitoring stations operated by the RBCAA (Richards Bay Clean Air Association), with the exception of the CBD station, is equipped with a weather station to measure wind speed, wind direction, temperature and humidity (Figure 4-2). 4-4

Figure 4-2: Location of the five ambient monitoring stations within the study area (SGS 2010). Annual average wind roses for the 4 stations for the period January 2008 to December 2008 are presented in Figure 4-3. Wind roses comprise 16 spokes, which represent the directions from which winds blew during the period. The colours used in the wind roses below, reflect the different categories of wind speeds; the yellow area, for example, representing winds of 1 m/s to 2.5 m/s. The table below the wind rose provides information regarding the frequency of occurrence of wind speed. The Wind Roses for the meteorological station at Arboretum are presented in Figure 4-4 for the years 2009 and 2010. When compared with the 2008 wind field with dominant northerly and south south westerly winds occurring similar wind field patterns are observed and therefore the use of the 2008 meteorological data is considered to be representative.. The prominence of west-south westerly to south-south westerly and north to north-easterly winds taken over an annual average is clear, with the most frequent occurrences of winds from the north (17 and 13% of the time) for Arboretum and Brackenham; and from the north-east (18 to 12% of the time) for Harbour West and Scorpio. Calm conditions (wind speeds less than 1 m/s) were noted to occur for between 1% (Arboretum) and 12% (Brackenham) of the period. 4-5

Figure 4-3: Annual average wind roses depicting the wind profile at the RBCAA stations for the period January 2008 to December 2008. 4-6

Figure 4-4 Annual Wind roses for 2009 and 2010 for the meteorological station at Arboretum (SGS 2010) Diurnal variations are due to the influence of land-sea breeze circulation on the airflow of the region. Land-sea breeze circulation arises due to the differential heating and cooling of land and water surfaces. During the day, the land is heated more rapidly than the sea surface; a horizontal pressure gradient develops with surface convergence and ascent over the land and decent and surface divergence over the sea (Atkinson, 1981). Sea breezes therefore characterise the daytime surface circulation resulting in the prevalence of on-shore airflow, with return currents dominating the upper airflow. By night, the land cools more quickly than the sea surface resulting in a reversal of the daytime sea breeze and upper air return currents and the onset of land breezes (off-shore) at the surface. Sea breezes are characterised by a marked increase in wind speed, and a reduction in the number of calms. 4.3.2 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. Ambient temperatures were recorded to range between 11.4 C and 30.0 C. Long-term average maximum, mean and minimum temperatures for Richards Bay (1951-1984) are shown in Table 4-1 (Schulze 1980). An annual mean temperature for Richards Bay is given as 21.8 C, based on the long-term record. The short term temperature profile for Richards Bay is presented in Figure 4-5 for the lowest recorded temperature in the month, the average temperature and the highest recorded temperature. 4-7

Table 4-1 Long-term minimum, maximum and mean temperature ( C) for Richards Bay for the period 1951-1984 (Schulze, 1986), and for 1970-1990 (SAWS, 2005) Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec 1951-1984 Maximum 30 29.6 29.3 27.3 25.1 23.4 23.4 24.0 25.4 26.1 27.6 29.5 Minimum 21.1 21.0 20.3 17.9 14.7 11.7 11.4 13.5 15.7 16.9 18.3 20.3 Mean 25.5 25.3 24.8 22.6 20.0 17.6 17.4 18.8 20.5 21.5 23.0 24.9 1970-1990 Maximum 29.2 28.9 28.9 27.0 24.8 23.1 23.0 24.0 24.9 25.4 26.7 28.7 Minimum 21.2 21.2 20.4 18.1 15.2 12.3 12.3 14.1 16.0 17.3 18.6 20.4 Mean 25.2 25.0 24.6 22.5 20.0 17.7 17.6 19.0 20.3 21.3 22.7 24.5 4-8

Figure 4-5 Temperature Profile for Richards Bay 2007-2010 (SGS 2010) 4.3.3 Precipitation Precipitation is important to air pollution studies since it represents an effective removal mechanism of atmospheric pollutants. Long-term monthly average rainfall figures for Richards Bay are given in Table 4-2. Long-term average total annual monthly rainfall is in the range of 57 mm to 172 mm. The study area falls within a summer rainfall region, with ~ 60 % of the annual rainfall occurring during the October to February period. 4-9

Table 4-2: Long-term average monthly rainfall (SAWS, 2005) 1970-1990 Month Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Sum Ave rainfall (mm) 172 167 107 109 109 57 60 65 77 105 114 86 1228 14% 13.6% 8.7% 8.9% 8.9% 4.6% 4.7% 5.3% 6.3% 8.5% 9.3% 7% 100% 12.4 11.5 9.9 8.4 7.2 5.8 5.9 7.1 9.3 12.0 13.1 11.3 113 Percentage of total Ave no. of rain days 4.3.4 Mixing Height and Atmospheric Stability The vertical component of dispersion is a function of the extent of thermal turbulence and the depth of the surface mixing layer. Unfortunately, the mixing layer is not easily measured, and must therefore often be estimated using prognostic models that derive the depth from some of the other parameters that are routinely measured, e.g. solar radiation and temperature. 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. 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. The mixing layer at the proposed site ranges in depth from 0 metres (i.e. only a stable or neutral layer exists) during night-times to the base of the lowest-level elevated inversion during unstable, day-time conditions. Atmospheric stability is frequently categorised into one of six stability classes. These are briefly described in Table 4-3. The hourly standard deviation of wind direction, wind speed and solar radiation were used to determine hourly-average stability classes (STAR method). 4-10

Table 4-3: Atmospheric Stability Classes A very unstable calm wind, clear skies, hot daytime conditions B moderately unstable clear skies, daytime conditions C unstable moderate wind, slightly overcast daytime conditions D neutral high winds or cloudy days and nights E stable moderate wind, slightly overcast night-time conditions F very stable low winds, clear skies, cold night-time conditions The atmospheric boundary layer is normally unstable during the day as a result of the turbulence due to the sun's heating effect on the earth's surface. The thickness of this mixing layer depends predominantly on the extent of solar radiation, growing gradually from sunrise to reach a maximum at about 5-6 hours after sunrise. This situation is more pronounced during the winter months due to strong night-time inversions and a slower developing mixing layer. During the night a stable layer, with limited vertical mixing, exists. During windy and/or cloudy conditions, the atmosphere is normally neutral. For elevated releases, the highest ground level concentrations would occur during unstable, daytime conditions. The wind speed resulting in the highest ground level concentration depends on the plume buoyancy. If the plume is considerably buoyant (high exit gas velocity and temperature) together with a low wind, the plume will reach the ground relatively far downwind. With stronger wind speeds, on the other hand, the plume may reach the ground closer, but due to the increased ventilation, it would be more diluted. A wind speed between these extremes would therefore be responsible for the highest ground level concentrations. The highest concentrations for low level releases would occur during weak wind speeds and stable (night-time) atmospheric conditions. Air pollution episodes frequently occur just prior to the passage of a frontal system that is characterised by calm winds and stable conditions. 4-11

4.4 Existing sources The identification of existing sources of emission in the region and the characterisation of existing ambient pollutant concentrations is fundamental to the assessment of the potential for cumulative impacts and synergistic effects given the proposed operation and its associated emissions. Existing sources of emissions in the Richards Bay area are discussed and available air pollution monitoring data presented in Sections 4.4 and 4.5, respectively. 4.4.1 Sources of Atmospheric Emissions Most of the main industrial role-players within the study area are members of the Richards Bay Clean Air Association (RBCAA). Emissions are reported to the RBCAA on a regular basis and included into a dispersion model (Hawk Model) managed by SGS South Africa. The emissions inventory compiled by Ecoserv on behalf of the RBCAA is largely limited to particulate and sulphur dioxide emission data and mainly includes the larger industrial operations. Furthermore, the particulate emissions data set is considered incomplete since fugitive dust sources are mainly omitted from the database. Some of the omitted fugitive sources such as the Richards Bay Coal Terminal have been quantified as part of the City of umhlathuze Spatial Development Framework project which included an Air Quality Study. The main description of the baseline characterisation was taken from this study (Liebenberg-Enslin and Petzer 2006). Sources of emission may be categorised in various ways, with distinctions most frequently being made between industrial versus non-industrial sources, point versus area sources, mobile versus stationary sources, and regulated versus un-regulated sources. Existing sources of emissions are discussed in the subsequent sections. 4.4.2 Existing Sources of Emissions within the City of umhlathuze Source types present in the area and the pollutants associated with such source types are noted with the aim of identifying pollutants which may be of importance in terms of cumulative impact potentials. Stack, vent and fugitive emissions from industrial operations Fugitive emissions from industrial, mining, commercial and miscellaneous operations Waste treatment facilities (i.e. water treatment plants, landfills, incinerators etc.) Various miscellaneous fugitive dust sources (agricultural activities, wind erosion of open areas, vehicle-entrainment of dust along paved and unpaved roads). Vehicle tailpipe emissions 4-12

Household fuel combustion Biomass burning (veld fires, forest fires and sugar cane burning) 4.4.2.1 Industrial Sources The main industries within the area include BHP Billiton s Bayside and Hillside aluminium plants, Mondi pulp and paper mills in Richards Bay and Felixton, Foskor, Tongaat Hulett Aluminuium, Lafarge Cement, Exxaro and Richards Bay Minerals (Figure 4-1). A synopsis of all the industrial and commercial processes identified within the study area is listed in Table 4-4 including the associated pollutants for each process (Liebenberg-Enslin and Petzer 2006) Figure 4-6: Petzer, 2006) Location of all the main industries and mines within the area (after Liebenberg-Enslin & 4-13

Table 4-4: All industrial sources within the study area and associated air pollutants. POLLUTANT SOURCES PM10 SO2 Hillside Aluminium Bayside Aluminium Mondi Richards Bay Exxaro Foskor Minerals (RBM) Richards Bay Coal Terminal (RBCT) Lafarge Cement Port Terminal (TNPA) NH3 VOC CO CO2 H2S SO3 Other AAFC (AECI) Transnet National HF Mondi Felixton Richards Bay NOx 4-14

Transnet Port Terminals (TPT) Tongaat-Hullet Richards Bay Bulk Storage (IVS) Tata Steel Pulp United In the quantification of the industrial sources use was made of the RBCAA database for 2007 (with the use of 2008 meteorological data) as provided by SGS South Africa. The Spatial Development Framework project was based on the 2004 emissions inventory from the RBCAA. As mentioned, the particulate emissions do not include all fugitive releases due to insufficient data available on these sources. The emissions included in the dispersion simulations are therefore not a true reflection of the concentrations within the study area. The total particulate emissions, for quantified sources, for the City of umhlathuze, were estimated to be 4,094 tpa. The total sulphur dioxide emissions were estimated to be 27,862 tpa. Based on the limited information, it is evident that the main pollutants of concern are particulates and sulphur dioxide (SO2). Since the particulates reflected in the database are predominantly from point source releases, and most of the industries indicated that they have dust control equipment in place, it was assumed that all particulates are PM10. 4.4.2.2 Miscellaneous sources of atmospheric pollution In addition to the partly quantified industrial sources of atmospheric pollutants a variety of other (less well quantified) sources can add to the atmospheric pollution load these include vehicular emissions, domestic coal and biofuel combustion, agricultural activities and biomass burning of natural vegetation (veld fires) and crop residue 4.4.2.2.1 Vehicular emissions Vehicle Tailpipe Emissions, air pollution from vehicle emissions may be grouped into primary and secondary pollutants. Primary pollutants are those emitted directly into the atmosphere, and 4-15

secondary, those pollutants formed in the atmosphere as a result of chemical reactions, such as hydrolysis, oxidation, or photochemical reactions. The significant primary pollutants emitted by motor vehicles include carbon dioxide (CO2), carbon monoxide (CO), hydrocarbons (HCs), SO2, oxides of nitrogen (NOx), particulates and lead. Secondary pollutants include: nitrogen dioxide (NO2), photochemical oxidants (e.g. ozone), HCs, sulphuric acid, sulphates, nitric acid, nitric acid and nitrate aerosols. Toxic hydrocarbons emitted include benzene, 1.2-butadiene, aldehydes and polycyclic aromatic hydrocarbons (PAH). Benzene represents an aromatic HC present in petrol, with 85% to 90% of benzene emissions emanating from the exhaust and the remainder from evaporative losses. Vehicle tailpipe emissions are also localised sources and unlikely to impacts far-field. The main roads in the vicinity of Richards Bay include the N2 and the R34 between Empangeni and Richards Bay. 4.4.2.2.2 Domestic coal and biofuel emissions Domestic coal combustion has been identified, based on both qualitative and quantitative observations, as being potentially the greatest source of airborne particulates within poor urban residential areas in South Africa. Quantitative indirect source apportionment of particulate, SO2 and NOx concentrations confirmed the predominance of the contribution of domestic coal combustion emissions to airborne particulate concentrations (Piketh, Annegarn et al. 1996). Coal burning emits a large amount of gaseous and particulate pollutants including sulphur dioxide, heavy metals, total and respirable particulates including heavy metals and inorganic ash, carbon monoxide, polycyclic aromatic hydrocarbons, nitrogen dioxide and benzo(a)pyrene. Pollutants arising from the combustion of wood include respirable particulates, nitrogen dioxide, carbon monoxide, polycyclic aromatic hydrocarbons, particulate benzo(a)pyrene and formaldehyde. Particulate emissions from wood burning within South Africa have been found to contain about 50% elemental carbon and about 50% condensed hydrocarbons (Terblanche et al., 1992). 4.4.2.2.3 Agricultural activities Agricultural activities are major sources of atmospheric emissions. Crop farming and mixed crop farming include land tilling operations, fertiliser and pesticide applications, and harvesting. By applying fertiliser and pesticides use are typically made of vehicles (tractors) driving on unpaved roads and exposed soil. Land tilling include dust entrainment on exposed surfaces, windblown dust and scraping and grading type activities resulting in fugitive dust releases. Both particulate matter (PM) and gaseous air emissions (mainly NO, NO2, NH3, SO2 and VOCs) are generated from the application of nutrients as fertilizers or manures (EPA, 1999). There are primarily 3 harvesting operations resulting in particulate emissions: (1) crop handling by the harvest machine, (2) loading of the harvested crop into trucks, and (3) transport by trucks in the field. Particulate matter, composed of soil dust and plant tissue fragments (chaff), may be entrained by wind (EPA, 1999). Burning of sugarcane prior to harvesting is an important source of biomass burning emissions. 4-16

4.4.2.2.4 Biomass burning Crop-residue burning and general wild fires (veld fires) represent significant sources of combustionrelated emissions associated with agricultural areas. Emissions are greater from sugar cane burning that for savannas wild fires due to sugar cane areas being associated with a greater availability of material to be burned. The quantity of dry, combustible matter per unit area is 25 ton per hectare for sugar cane, whereas it is on average 4.5 ton per hectare for savannas areas(sankaran, Hanan et al. 2005). Biomass burning is an incomplete combustion process with carbon monoxide, methane and nitrogen dioxide being emitted during the process. About 40% of the nitrogen in biomass is emitted as nitrogen, 10% remains in the ashes and it is assumed that 20% of the nitrogen is emitted as higher molecular weight nitrogen compounds. The visibility of smoke plumes from vegetation fires is due to their aerosol content (Andreae 1997; Levine, Parsons et al. 1997; Hobbs, Sinha et al. 2003; Korontzi, Justice et al. 2003; Sinha, Hobbs et al. 2003). 4-17

4.5 Ambient Air Quality The establishment of the contributions of various source types to total emissions represents a means of ranking sources by their emissions. In order to assess the significance of sources with regard to their potential impact it is necessary to account for various additional factors, including: atmospheric dispersion potentials, source configurations (particularly height of emission), proximity of potentially sensitive receptors, and the carrying capacity of the receiving environment. It is for this reason that the analysis of trends in ambient air quality is imperative. Temporal and spatial variations in ambient air pollution concentrations can be determined primarily through two approaches: (i) Through implementing ambient air pollution monitoring at representative sites to directly measure pollution concentrations, and (ii) Through the development of a comprehensive emissions inventory and the application of an atmospheric dispersion model, using relevant source, emissions and meteorological data as input, to simulate ambient air pollutant concentrations. The implementation of a combination of monitoring and modelling will produce the best results. Monitoring data generally provides accurate "snapshots" of air pollution concentrations at specific points, with dispersion models, which are by their nature associated with a greater level of uncertainty, serving to "paint the whole picture". In assessing the significance of ambient air pollutant concentrations monitored in the study area reference was made to local air quality standards. 4.5.1 Monitoring carried out in Richards Bay SGS South Africa on behalf of the RBCAA operates 10 monitoring stations in the Richards Bay area these include: Arboretum (Met, SO2) Brackenham (Met, SO2, PM10) CBD (situated at the sports complex) (SO2, TRS, PM10) Harbour West (near the entrance to the harbour) (Met, SO2) Scorpio (at the intersection of the John Ross highway and West Central Arterial) (Met, SO2) Mtunzeni (at the fish farm) (Met, PM10) St Lucia (Met, PM10) 4-18

Airport (Met) Bayside (at the Bayside aluminium smelter) (Met) And RBM at the Richards Bay minerals facility (Met) The monitoring network measures SO2 at Arboretum, Brackenham, CBD, Scorpio and Harbour West. Total reduced sulphurs (TRS) are measured at the CBD station while PM10 is measured at Brackenham, CBD, Mtunzeni and St Lucia. The St Lucia and Mtunzeni sites can be considered background stations since they are spatially removed from the industrial activity that occurs in the Richards Bay area and therefore are likely to represent the diffuse particulate sources such as biomass burning, sea salt aerosol particulates generated from unpaved roads and agricultural activity and long range transport. SGS is accredited by the SANAS for the measurement of SO2 and PM10. The subsections that follow briefly discuss measured pollutant concentrations compared to their respective standards to indicate compliance. This information was obtained from SGS South Africa. Figure 4-7: 4.5.1.1 Location of the five SO2 ambient monitoring stations within the study area. Sulphur Dioxide (SO2) The SO2 data capture was reported to be above 80% for all stations as can be seen in Table 4-5. 4-19

Table 4-5 Percentage SO2 data capture for 2007-2010 Station name Arboretum SO2 data capture (%) 92.2 (2007) 88.5 (2008) 97.9 (2009) 97.9 (2010) 95.6 (2007) 94.7 (2008) 97.5 (2009) 97.8 (2010) 94.8 (2007) 84.1 (2008) 96.7 (2009) 98.8 (2010) 97.3 (2007) 95.9 (2008) 98.9 (2009) 97.3 (2010) 98.9 (2007) 98.0 (2008) 99.8 (2009) 98.8 (2010) Brackenham CBD John Ross/Foskor intersection (Scorpio) Harbour West Table 4-6 lists the latest SO2 averages along with those of 2003 to 2009 for comparison (see also Figure 4-8). An increase in SO2 concentrations was measured at all monitoring sites from the period 2003 to 2005. The measured SO2 concentrations decreased from 2005 to current. The highest annual average SO2 concentration (2005) was measured at the John Ross/Foskor intersection, which is located closest to major industry (Foskor, Hillside Aluminium and Bayside Aluminium). The John Ross/Foskor intersection annual average SO2 concentration for 2005 was 63 % of the SA standard (19 ppb/50 µg/m³). The highest annual average SO2 concentration for 2010 was measured at the Harbour West station (at 7.2 ppb). The Harbour West annual average SO2 concentration for 2010 was 45 % of the SA standard (19 ppb/ 50 µg/m³). There has been a small increase in the annual average SO2 concentrations since 2009 but the SO2 concentrations are still generally low in comparison to the values recorded in 2005 and 2006. Table 4-6: Comparison of SO2 annual averages (ppb) for the period 2003-2010 (Ecoserv). Station name 2003 2004 2005 2006 2007 2008 2009 2010 Arboretum Brackenham 3.6 3.1 4.6 4.0 6.1 5.4 4.1 3.6 2.6 1.8 2.0 1.4 2.4 1.0 2.6 1.4 CBD John Ross/Foskor intersection (Scorpio) Harbour West 5.3 6.8 7.0 6.2 5.0 4.6 4.1 4.1 6.9 10.6 11.9 9.1 8.0 5.7 5.9 7.2 - - - 8.0 7.8 3.9 8.2 8.6 4-20

Figure 4-8 Comparison of annual average SO2 for the period 2003 2010 Trends in daily average SO2 at each of the monitoring stations are provided in Figure 4-9 to Figure 4-22. The limit (48 ppb/ 125µg/m³) is indicated on each graph. Figure 4-9 Daily average SO2 concentration measured at Arboretum during 2008 4-21

Figure 4-10 Daily average SO2 concentration measured at Arboretum during 2009 Figure 4-11 Daily average SO2 concentration measured at Arboretum during 2010 (SGS 2010) 4-22

Figure 4-12 Daily average SO2 concentration measured at Brackenham during 2008 Figure 4-13 Daily average SO2 concentration measured at Brackenham during 2009 4-23

Figure 4-14 Daily average SO2 concentration measured at Brackenham during 2010 (SGS 2010) Figure 4-15 Daily average SO2 concentration measured at CBD during 2008. 4-24

Figure 4-16 Daily average SO2 concentration measured at CBD during 2009. Figure 4-17 Daily average SO2 concentration measured at CBD during 2010 (SGS 2010) 4-25

Figure 4-18 Daily average SO2 concentration measured at Scorpio substation (cnr John Ross and West Central Arterial) during 2008 Figure 4-19 Daily average SO2 concentration measured at Scorpio substation (cnr John Ross and West Central Arterial) during 2009 4-26

Figure 4-20 Daily average SO2 concentration measured at Scorpio substation (cnr John Ross and West Central Arterial) during 2010 Figure 4-21 Daily average SO2 concentration measured at Harbour West during 2008 4-27

Figure 4-22 Daily average SO2 concentration measured at Harbour West during 2009 Figure 4-23 Daily average SO2 concentration measured at Harbour West during 2010(SGS 2010) The maximum daily and hourly average SO2 concentrations measured from 2007 to 2009 are shown in Table 4-7. One daily and one hourly exceedance was reported for the year of 2008 at the Scorpio station, and one daily and five hourly exceedance for 2009 for the Harbour West station. 4-28

Table 4-7: of standards. Highest SO2 concentrations (ppb) measured at each station for 2007 to 2010 and percent Station name Arboretum Brackenham CBD John Ross/Foskor intersection (Scorpio) Harbour West 4.5.1.2 Daily average (48 ppb) Max SO2 conc % limit 14.7 (2007) 31 14.5 (2008) 30 19.0 (2009) 40 19.0 (2010) 40 15.4 (2007) 32 10.0 (2008) 21 12.8 (2009) 27 10 (2010) 21 37.9 (2007) 79 29.3 (2008) 61 20.2 (2009) 42 33.7 (2010) 70 > 100 49.8 (2007) > 100 61.5 (2008) 33.1 (2009) 69 52 (2010) >100 > 100 53.0 (2007) 25.4 (2008) 53 > 100 133.8 (2009) >100 50 (2010) Hourly average (134 ppb) Max SO2 conc % limit 73.6 (2007) 55 60.0 (2008) 45 60.7 (2009) 45 82 (2010) 61 54.0 (2007) 40 133.1 (2008) 99 56.9 (2009) 42 41 (2010) 41 115.9 (2007) 87 91.8 (2008) 69 64.1 (2009) 48 72 (2010) 54 > 100 205.1 (2007) 133.8 (2008) 99.9 133.1 (2009) 99 125 (2010) 93 > 100 244.0 (2007) 84.9 (2008) 99 > 100 1547.4 (2009) >100 150 (2010) Thoracic Particulates (PM10) The monitoring network was expanded during 2004 to include the measurement of particulate matter (PM10) at Civic Centre (CBD), and in 2008 to include Brackenham. The Civic Centre station was relocated to the Central Sports Complex in December 2008. The SA limit for PM10 concentrations is given as 120 µg/m³ for a daily averaging period and 50 µg/m³ for an annual averaging period (immediate compliance), and as 75 µg/m³ for a daily averaging period and 40 µg/m³ for an annual averaging period (compliance 1 January 2015). Annual PM10 concentrations were slightly over the future limit at the CBD in 2007; however below the future limit in 2008 and 2009 for both stations (Table 4-8). (It is recommended that at least 80% of the data be available in order to make a comprehensive analysis of the data collected). The trend in daily average PM10 concentrations at the CBD is shown in Figure 4-24 (2008) and Figure 4-25 (2009). There were 3 (2008, although data availability was poor) and 5 (2009) exceedances of the future SA limit of 75 µg/m³. Daily average PM10 concentrations at Brackenham are shown in Figure 4-26 (2008) and Figure 4-27 (2009). There were 9 (2008) and 10 (2009) exceedances of the future SA limit of 75 µg/m³. The allowable frequency of exceedance of the 75 µg/m³ is four times per year. Measured PM10 concentrations are therefore exceeding the future SA standard at both locations, but are however in compliance with the immediate standards. Maximum daily average PM10 concentrations are shown in Table 4-9. 4-29

Table 4-8: Percentage PM10 data capture and annual average concentrations for 2007-2010. Station PM10 data capture (%) 66 (2007) 29 (2008) 93 (2009) 97.5 (2010) 68 (2008) 78 (2009) 98.9 (2010) 98.5 (2010) 97.2 (2010) CBD Brackenham Mtunzeni St Lucia Note: (1) PM10 annual average (1) (1) (1) (1) 2007 (µg/m³) 2008 (µg/m³) 2009 (µg/m³) 2010 (µg/m³) 41.4 33.8 28.5 31-32.3 35.2 30 26 20 The future SA annual PM10 limit is 40 µg/m³. Table 4-9 Maximum daily average particulate concentrations for 2007-2010 Station CBD Brackenham Mtunzeni St Lucia Note: (1) Maximum daily average PM10 concentration (µg/m³) 142 (2007) 105 (2008) 111 (2009) 59 (2010) 108 (2008) 172 (2009) 80 (2010) 130 (2010) 78 (2010) % limit >100 >100 >100 79 >100 >100 >100 >100 >100 (1) Number of Exceedances 10 (2010) 3 (2010) 1 (2010) 1 (2010) The future SA daily PM10 limit is 75 µg/m³. 4-30

Figure 4-24 Daily average PM10 concentrations at the CBD during 2008 Figure 4-25 Daily average PM10 concentrations at the CBD during 2009 4-31

Figure 4-26 Daily average PM10 concentrations at Brackenham during 2008 Figure 4-27 Daily average PM10 concentrations at Brackenham during 2009 4-32

5 Impact Assessment Four phases of development were considered in this study: Current; emissions rates and stack parameters were taken from the RBCAA database and represent the emissions as they currently occur when the plant is operated at full capacity. Actual: emission rates as they occurred for 2010, these are substantially lower than the current emissions since the power boilers did not operate at full capacity. Phase 1; power boiler facility modification will consist of the refurbishment of the two existing coal fired boilers and the installation of a steam turbine for the production of electricity, for this phase of the development the power generation capacity will increase from the current 98MW to 145MW thermal capacity. The emissions from the expanded power generation are to be modelled at the allowed South African Emission limit as published in the Emission Standards (DEA 2010). Included in the total emissions will be fugitive emissions from material handling steps. Phase 2 involves the conversion of one of the 50MW coal fuelled boilers to a biomass fuelled boiler, where the fuel will be waste material from the preparation of wood for the pulp plant. This will include bark and other material unsuitable for pulping. The emissions used for the dispersion modelling will be based on the South African emission limits (DEA 2010) for solid biomass combustion, which are the same as for solid fuel combustion. However the standard sulphur content for waste wood biomass are considerably lower than those of coal (0.1% for Mondi bark waste compared with the 1% sulphur coal that is expected to be used) and therefore the actual emissions are likely to be considerably lower. In addition the waste wood material is less likely to result in fugitive emissions during material handling operations. As a result the Phase 2 operations are likely to result in a reduction in air quality impact. However since the impact assessment is being undertaken using the emission limits (DEA 2010) which are the same for both scenarios, they should result in identical modelled ambient air quality impacts. 5.1 Emissions inventory Emission rates were obtained from two sources, the stack emissions which include emissions of SO2, NOx and particulate matter. Material handling operations will result in the production of particulate emissions. 5-1

5.1.1 Chlorine Dioxide Storage Tank Under the NEM:AQA emission limits of HCl from ClO2 generation and storage tanks need to be met however there is no associated ambient air quality standard for HCl. The required emission limit is 15mg/Nm³. Since the ClO2 storage tank is required for period when the CLO2 generator is out of operation it is not expected to run continuously. The vent emissions from the storage tank are expected to be scrubbed with NaOH or burnt in H2. 5.1.2 Stack emissions This report is based on three emission scenarios. Firstly the current emissions, these are the emission rates that the Mondi Power Boilers are allowed to produce and are the emission rates that are included in the RBCAA database as held by SGS. The second scenario is the Phase 1 or Phase 2 scenario, which looks at the assumed emission rates once the modifications to the Mondi power boilers have been completed. The final scenario looks at the actual emissions for 2010, this is different to the current scenario since the boilers were not running at maximum capacity during 2010 and as a result the emissions were lower than the emission limits for the plant. The stack emissions rates under the Phase 1 scenario from the steam boilers were calculated to equal the South African emission limit as presented in Table 3-2 and Table 3-3, since these are the maximum emissions that are permitted to occur. The emission limits for coal and biomass combustion are the same, and as a result in similar emission rates as presented in Table 5-1. The emission concentration for the various scenarios is presented in Table 5-2. By meeting the national emission standards the emission concentration of both SO2 and PM10 is substantially reduced from the current emissions concentrations. To achieve these emission levels for SO2 flue gas desulphurisation efficiency of approximately 68% is required for Phase 1 and approximately 54% for Phase 2 (assuming calorific value of the biomass of 17MJ/kg and an S content of 0.1%). The reason for the differing flue gas desulphurisation requirements for Phase 1 and Phase 2 is the reduced sulphur content of the biomass in Phase 2. Table 5-1 Emission rates from the boiler stack Pollutant SO2 (Mg/a) Actual Current (Licensed, as per RBCAA database) Phase 1 Phase 2 g/s Mg/annum g/s Mg/annum g/s Mg/annum g/s Mg/annum 38 1198.4 101.91 3213.8 93.0 2932.8 93.0 2932.8 5-2

NO2 (Mg/a) 10 315.4 20.26 638.9 139.4 4383.5 139.4 4383.5 PM10 (Mg/a) 4 126.1 9.26 292.0 9.3 293.2 9.3 293.2 Table 5-2 Emission concentrations from the boiler stack Pollutant Current (Licensed, as per RBCAA database)t Phase 1 Phase 2 Volume (m³/s at 273K and and 101.3kPa) 57.5 147.5 147.5 SO2 (mg/nm³) 1772.7 500 500 NO2 (mg/nm³) 352.4 750 750 PM10 (mg/nm³) 161.1 50 50 When the NO2 emissions are modelled at the national emission limit of 750mg/Nm³ this results in a NO2 emission that is considerably larger than expected from the coal combustion processes based on the NO2 emission factors from the Australian National Pollution Inventory (NPi 2010), which provides a NO2 emission factor of 2.5kg/Mg coal burnt in circulating fluidized bed boilers. Based on the estimated fuel requirements to provide 145MW of electrical energy at a fuel calorific value of 26.5 Mj/kg for coal (Phase 1 scenario) or 21.6MJ/kg (mix biomass and coal) the NO2 emissions are expected to total 36.00 g/s or 1135Mg/annum under the Phase 1 scenario and 44.13 g/s or 1391Mg/annum under the phase 2 scenario. This is approximately 25% -33% of the annual emission at the National emission limit (4383.5 Mg/annum), but 75%- 217% of the current annual emission of 638.9 Mg/annum. 5.1.3 Material Handling Emissions The emissions from the material handling operations are due to the transfer of coal, there are three material handling steps, including the direct unloading of the coal train to a hopper, the conveyor transfer to the coal stockpile and transfer to the boiler. The emission rates for the particulates are related to the rate of material transfer. Under the current scenario the coal transfer rate is 16 Mg/hour of coal, under Phase 1 with the addition of an extra coal fired boiler the material transfer rate will be 5-3

19.4 Mg/ hour and under Phase 2 where one of the boiler is converted to utilize biomass the coal transfer rate will be 10.3 Mg/hour. Particulate emissions from the handling of biomass are expected to be negligible due to the expected size of the wood chips or the fibrous nature of the bark material that would potentially be used. Table 5-3 Particulate emissions from the material handling operations Phase 1 scenario Phase 1 Unit 19.4 Mg/hour/ transfer point 0.17 kg/hour/transfer point 0.05 g/s/transfer point 1.48 Mg/a/transfer point 4.44 Mg/a 5-4

5.2 Dispersion modelling results Ambient air quality pertains to areas where the public has access and per definition excludes mining and industrial sites (if no people reside there). Thus in the assessment of health impacts, reference is usually made to areas outside the mine/industrial site boundary and specifically residential areas. For the purpose of this study off-site impacts were assessed. The limit values as provided by the South African National Ambient Air Quality Standards (NAAQS) (Table 3-1) were used as screening criteria. In the consideration of shorter-term isopleths figures it must be kept in mind that highest hourly and highest daily values are 1:8760 and 1:365 events in any one year respectively. The maxima may occur under meteorological circumstances different from normal values and the direction of the impact may therefore not correspond to the most prevalent wind direction. 5.2.1 Sulphur Dioxide Concentrations 5.2.1.1 Annual SO2 Concentration Mondi Current and Phase 1 The annual SO2 concentration standard under the NAAQS is 50µg/m³ (19ppb). The impact of the current boilers at the Mondi Richards bay plant is presented in Figure 5-1. The impact from the current operation is low (less than 10µg/m³ (3.8ppb)), and the zone of maximum impact occurs approximately 2km to the south west of the Mondi Richards Bay facility. When the impact of the modification of the Mondi Richards Bay boiler (scenario Phase1) is considered (Figure 5-2) it can be seen that the maximum concentration expected is below 5µg/m³ (1.9ppb); the maximum impact occurs in the same area as the current maximum impact. The future impact is expected to be somewhat reduced from the current impact, the reason for this is that the refurbishment of the boilers (with emissions based on the emission limit for new plant) will result in reduced total emissions and in an increased volume of air passing through the stack, resulting in the stack emissions having a greater exit velocity and therefore greater dispersion potential. The current emissions used in Figure 5-1 represent the licensed emission rates for the Mondi power boilers. However during 2010 the 5-5

boilers did not operate at full capacity and as a result the total emissions were reduced as shown in Figure 5-3. The actual emission rate resulted in a maximum ambient SO2 concentration of 2.6µg/m³ compared with a maximum concentration of 7.0µg/m³ for current (licensed) operation and an expected maximum phase 1 concentration of 4.1µg/m³ (for further information please see the summary Table 5-4. When the cumulative impact of the current Mondi boiler emissions and the background SO2 concentrations (Figure 5-4) are compared with the Phase1 boiler emissions and the background annual SO2 concentrations (Figure 5-5), there is very little difference between the two scenarios. It is predicted that an area to the south east of the Mondi Richards Bay plant, corresponding to the location of the aluminium smelters (please see Figure 4-6) is in exceedance of the NAAQS for annual SO2 concentration (19ppb), however the annual average SO2 concentration in the vicinity of the Mondi Richards Bay facility is in the range of 25-50µg/m³ (9.6-19ppb) and therefore within the NAAQS standards. Comparison with the monitoring results show that the model is over predicting the annual SO2 concentration since the highest measured annual SO2 concentration is 11.9 ppb for the Scorpio monitoring station for the worst year (2005). The actual 2010 emissions are presented in Figure 5-6 and show a similar pattern to the current and phase 1 scenario due to the small contribution made by the Mondi power boilers on the total projected SO2 concentrations. 5-6

Figure 5-1 Annual average SO2 concentrations due to current Mondi Boiler operations (contours represent 0.38ppb blue, 0.76ppb green, 1.15ppb magenta and 1.53ppb orange). Figure 5-2 Annual average SO2 concentrations Mondi Phase 1 sources only (contours represent 0.38ppb blue, 0.76ppb green, 1.15ppb magenta and 1.53ppb orange). 5-7

Figure 5-3 Annual average SO2 concentrations due to actual Mondi Boiler operations for 2010 (contours represent 0.38ppb blue, 0.76ppb green, 1.15ppb magenta and 1.53ppb orange). 5-8

Figure 5-4 Annual cumulative SO2 concentrations (Mondi current and background). Figure 5-5 Annual cumulative SO2 concentrations (Mondi Phase1 and background). 5-9

Figure 5-6 Annual cumulative SO2 concentrations, Mondi actual 2010 and background). 5-10

5.2.1.2 Highest Daily SO2 Concentration The maximum daily SO2 concentration standard under the NAAQS is 125µg/m³ (48ppb). The impact of the current boiler at the Mondi Richards bay plant is presented in Figure 5-7. The impact from the current operation is low (less than 30µg/m³ (11.5ppb)), and the predicted zone of maximum impact occurs approximately 2km to the south west of the Mondi Richards Bay facility. When the impact of the modification of the Mondi Richards Bay boilers (scenario Phase1) is considered (Figure 5-8) it can be seen that the maximum concentration expected is still below 30µg/m³ (11.5ppb) (24% of NAAQS), the maximum impact occurs in the same area as the current maximum impact. The future impact is likely to be somewhat reduced from the current impact, due to the changes in emissions and stack emission velocity. The current emissions used in Figure 5-7 represent the licensed emission rates for the Mondi Power Boiler, however during 2010 the boilers did not operate at full capacity and as a result the total emissions were reduced as shown in Figure 5-9. The maximum emission rates predicted in the different scenarios are presented in Table 5-4. When the cumulative impact of the current Mondi boiler emissions and the background SO2 concentrations (Figure 5-10) are compared with the Phase1 boiler emissions and the background annual SO2 concentrations (Figure 5-11), there is very little difference between the two scenarios. It is predicted that exceedances of the NAAQS for maximum 24 hours concentrations will occur in an area to the south east of the Mondi Richards Bay Plant, corresponding to the location of the aluminium smelters (please see Figure 4-6).Since there are exceedances of the highest daily SO2 standard, the number of daily exceedances that occur annually needs to be considered, since a maximum of 4 days of exceedance of the SO2 daily standard are allowed annually. The frequency of exceedance of the South African National Ambient air quality standard, 24 hour averaging period is presented in Figure 5-13 for the current plus baseline scenario and in Figure 5-14 for the phase 1 plus baseline scenario. An area to the south west of the Mondi facility shows more than the allowed 4 exceedances annually. There is no significant difference in the extent of the area where the SO2 daily average concentration exceeds the national standard between the current and future scenarios since the most important component in the SO2 concentrations over this region is due to the impact of sources other than the Mondi power boilers. When the number of predicted exceedances are compared with the measured number of exceedances there is an overprediction by the model, since the monitoring shows only one exceedance of the NAAQS for the year 2010. The actual 2010 emissions are presented in Figure 5-12 and show a similar pattern to the current and phase 1 scenarios due to the small contribution made by the Mondi power boilers on the total projected SO2 concentrations. The frequencies of exceedance for the actual 2010 emissions from the Mondi power boilers are not significantly different from the current or Phase 1 scenarios. 5-7

Figure 5-7 Highest Daily SO2 concentrations, current Mondi boiler sources only. Contours represent 1.9ppb (blue), 3.8ppb (green), 5.8ppb (magenta) and 7.7ppb (orange). Figure 5-8 Highest Daily SO2 concentrations, Mondi Phase 1 sources only. Contours represent 1.9ppb (blue), 3.8ppb (green), 5.8ppb (magenta) and 7.7ppb (orange). 5-8

Figure 5-9 Highest Daily SO2 concentrations, actual 2010 emissions Mondi boiler sources only. Contours represent 1.9ppb (blue), 3.8ppb (green), 5.8ppb (magenta) and 7.7ppb (orange). 5-9

Figure 5-10 Highest Daily SO2 concentrations, Mondi current and background sources. Contours represent 28.8ppb (blue), 46.1ppb (green), 76.8ppb (magenta) and 115.2ppb (orange). Figure 5-11 Highest Daily SO2 concentrations, Mondi Phase1 and background sources. Contours represent 28.8ppb (blue), 46.1ppb (green), 76.8ppb (magenta) and 115.2ppb (orange). 5-10

Figure 5-12 Highest Daily SO2 concentrations, Mondi 2010 actual and background sources. Contours represent 28.8ppb (blue), 46.1ppb (green), 76.8ppb (magenta) and 115.2ppb (orange). 5-11

Figure 5-13 SO2 Daily frequency of exceedance of the South African National Ambient Air Quality standard of 125 µg/m³ (48ppb), Baseline + Current contour represents area where standard is exceeded more than 4 days per annum. Figure 5-14 SO2 Daily frequency of exceedance of the South African National Ambient Air Quality standard of 125 µg/m³ (48ppb), Baseline + Phase 1 contour represents area where standard is exceeded more than 4 days per annum. 5-12

5.2.1.3 Highest Hourly SO2 concentrations The maximum hourly SO2 concentration standard under the NAAQS is 350µg/m³ (134ppb). The impact of the current boiler at the Mondi Richards bay plant is presented in Figure 5-16. The impact from the current operation is low (less than 120µg/m³ (46.2ppb) 34% of the NAAQS), and the zone of maximum impact occurs south of the Mondi Richards Bay facility. When the impact of the modification of the Mondi Richards Bay boilers (scenario Phase1) is considered (Figure 5-17) the maximum predicted ground level concentration is still expected to be below 120µg/m³ (46.2ppb), the maximum impact occurs in the same area as the current maximum impact. The future impact is likely to be reduced from the current impact due to the changes in stack emission velocity. The current emissions used in Figure 5-16 represent the licensed emission rates for the Mondi power boilers, however during 2010 the boilers did not operate at full capacity and as a result the total emissions were reduced as shown in Figure 5-18. The maximum emission rates predicted in the different scenarios are presented in Table 5-4. When the cumulative impact of the current Mondi boiler emissions and the background SO2 concentrations (Figure 5-19) are compared with the Phase1 boiler emissions and the background annual SO2 concentrations (Figure 5-20), there is very little difference between the two scenarios. It is predicted that an area to the south east of the Mondi Richards Bay plant, corresponding to the location of the aluminium smelters (please see Figure 4-6) is in exceedance of the NAAQS for Maximum Hourly SO2 concentration. Since there are exceedances of the highest hourly SO2 standard, the number of hourly exceedances that occur annually needs to be considered, because a maximum of 88 hours of exceedance of the SO2 hourly standard are allowed annually. The frequency of exceedance of the South African National Ambient air quality standard, 1 hour averaging period is presented in Figure 5-22 for the current plus baseline scenario and in Figure 5-23 for the phase 1 plus baseline scenario. An area to the south of the Mondi facility shows more than the allowed 88 exceedances annually and there are no significant differences between the current and phase 1 scenario. The predicted frequency of exceedance of the NAAQS is greater than the number of exceedances measured. The year with the highest number of recorded hourly SO2 exceedances was 2004 when 20 hourly exceedances measured. The most important component in the SO2 concentrations over this region is due to the impact of sources other than the Mondi power boilers. When one looks at the pollution roses presented in the 2010 annual air quality monitoring report this is confirmed since the highest pollution concentrations at the Scorpio station are from the northnortheast and northeasterly directions, while the Mondi facility is situated to the west Figure 5-15. The actual 2010 emissions are presented in Figure 5-12 and show a similar pattern to the current and phase 1 scenario due to the small contribution made by the Mondi Power boilers on the total projected SO2 concentrations. The frequencies of exceedance for the actual 2010 emissions from the Mondi power boilers are not significantly different to the current or Phase 1 scenarios. 5-11

Figure 5-15 Pollution Rose for SO2 for the Scorpio station 2010 (SGS 2010) 5-12

Figure 5-16 Highest hourly SO2 concentrations due to current Mondi activities. Contour lines represent 9.6ppb (blue), 19.2 ppb (green), 28.8 ppb (magenta) and 38.5ppb (orange). Figure 5-17 Highest hourly SO2 concentrations due to Phase 1 activities. Contour lines represent 9.6ppb (blue), 19.2 ppb (green), 28.8 ppb (magenta) and 38.5ppb (orange). 5-13

Figure 5-18 Highest hourly SO2 concentrations due to the actual Mondi boiler activities in 2010. Contour lines represent 9.6ppb (blue), 19.2 ppb (green), 28.8 ppb (magenta) and 38.5ppb (orange). 5-14

Figure 5-19 Cumulative highest hourly SO2 concentrations, Mondi current and background sources. Contours represent 67ppb (blue), 134ppb (green), 193ppb (magenta) and 269ppb (orange). Figure 5-20 Cumulative highest hourly SO2 concentrations, Mondi Phase1 and background sources. Contours represent 67ppb (blue), 134ppb (green), 193ppb (magenta) and 269ppb (orange). 5-15

Figure 5-21 Cumulative highest hourly SO2 concentrations, Mondi actual 2010 and background sources. Contours represent 67ppb (blue), 134ppb (green), 193ppb (magenta) and 269ppb (orange). 5-16

Figure 5-22 Frequency of exceedance of the South African National Ambient Air Quality standard of 350 µg/m³ (134ppb), Baseline and Current contour represents area where standard is exceeded more than 88 hours per annum. Figure 5-23 Frequency of exceedance of the South African National Ambient Air Quality standard of 350 µg/m³ (134ppb), Baseline + Phase 1 contour represents area where standard is exceeded more than 88 hours per annum. 5-17

Table 5-4 Summary of maximum modelled SO2 Concentrations SO2 annual (µg/m³) SO2 Max Daily (µg/m³) SO2 Max Hourly (µg/m³) Actual Actual and Base* Current Current and Base* Phase 1 Phase 1 and Base* 2.6 426.5 (0.6) 7.0 426.7 (1.6) 4.1 426.6 (1.0) 21.0 1141 (1.8) 56.7 1148.6 (4.9) 32.8 1143.2 (2.9) 53.6 3105 (1.7) 144.8 3136.4 (4.6) 140.5 3136.5 (4.5) * Figures in brackets denote Mondi s contribution to sum total concentrations. 5-18

5.2.2 Nitrogen Dioxide Concentrations The ambient concentrations of NO2 are regulated by guidelines set NAAQS under the annual (40µg/m³ 21ppb) and the hourly (200µg/m³ 106ppb with 88 hourly exceedances allowed per year) averaging periods as presented in Table 3-1. 5.2.2.1 Annual NO2 Concentrations The annual NO2 concentration standard under the NAAQS is 40µg/m³ (21ppb). The impact of the current boilers at the Mondi Richards bay plant is presented in Figure 5-24. The impact from the current operation is low (less than 1.5µg/m³ (0.8ppb) 4% of the NAAQS), and the zone of maximum impact occurs south west of the Mondi Richards Bay facility. When the impact of the modification of the Mondi Richards Bay boilers (scenario Phase1) is considered (Figure 5-25) it can be seen that the maximum concentration expected is considerably higher than the current scenario (up to 6 µg/m³ (3.2ppb) 15% of the NAAQS). The maximum impact occurs in the same area as the current maximum impact. The reason that the predicted future impact is likely to be greater than the current impact is because the Phase 1 scenario was modelled using an emission rate based on the emission limit for new solid fuel combustion installations of 750mg/Nm³. This results in an emission rate of 139.4g/s under the Phase 1 stack conditions, which is 6.9 times higher than the current emission rate of 20.26g/s. The Phase 1 scenario is therefore very conservative with regards to the NO2 concentration. The current annual NO2 concentration as a result of the Mondi Power Boiler activities is based on the Mondi Licence requirements. In 2010 the boilers operated at below capacity, resulting in NO2 emissions that were lower than expected. The actual projected NO2 impact from the power boiler operation is presented in Figure 5-26. When the cumulative impact of the current Mondi boiler emissions and the background NO2 concentrations (Figure 5-27) are compared with the Phase1 boiler emissions and the background annual NO2 concentrations (Figure 5-28), there is significant difference between the two scenarios. It is predicted that the region of most significant NO2 impact is to the south west of the Mondi Richards Bay plant. The highest impact of the current plus background scenario is significantly smaller than the Phase 1 plus background scenario. In this area the maximum annual average NO2 concentration does however not exceed 10µg/m³ (5.3ppb) which is less than 25% of the NAAQS (Figure 5-28). The Mondi plant appears to have large impact on the total NO2 concentration, this is partly because there are few other major NO2 sources in the Richards Bay area that have been characterised and included in the baseline (see Table 4-4). The actual 2010 NO2 emission and the baseline are presented in Figure 5-29, while a summary of the maximum NO2 concentration modelled under all the scenarios is presented in Table 5-5. The actual impact is expected to be smaller than the current (50%) or Phase 1 (10%) scenarios. 5-19

Figure 5-24 Annual average NO2 concentrations, current power boiler sources only. Contours represent 0.15ppb (blue), 0.32ppb (green), 0.5ppb (magenta) and 0.64ppb (orange). Figure 5-25 Annual average NO2 concentrations, Mondi Phase 1 sources only. Contours represent 0.15ppb (blue), 0.32ppb (green), 0.5ppb (magenta) and 0.64ppb (orange). 5-20

Figure 5-26 Annual average NO2 concentrations, actual 2010 power boiler sources only. Contours represent 0.15ppb (blue), 0.32ppb (green), 0.5ppb (magenta) and 0.64ppb (orange) 5-21

Figure 5-27 Annual average NO2 concentrations, baseline and Mondi current. Contours represent 0.53ppb (blue), 1.05ppb (green), 1.6ppb (magenta) and 2.6ppb (orange). Figure 5-28 Annual average NO2 concentrations, baseline and Mondi Phase 1 sources. Contours represent 0.53ppb (blue), 1.05ppb (green), 1.6ppb (magenta) and 2.6ppb (orange). 5-22

Figure 5-29 Annual average NO2 concentrations, baseline and Mondi actual 2010. Contours represent 0.53ppb (blue), 1.05ppb (green), 1.6ppb (magenta) and 2.6ppb (orange). 5-23

5.2.2.2 Highest Hourly NO2 Concentrations The highest hourly NO2 concentrations are controlled by the NAAQS standards to 200µg/m³ (106ppb). The current highest hourly NO2 ground level concentrations as a result of the Mondi Richards Bay power boilers did not exceed 29ug/m³ (15.2ppb) (Figure 5-30), which is 14.5% of the NAAQS standard concentration. The highest hourly emissions under the Phase 1 scenario (Figure 5-31) are significantly higher than for the current scenario and exceed the NAAQS for NO2 for the hourly averaging period. The differences between the current and phase 1 scenarios are due to the higher NO2 emission rate that was assumed for the phase 1 scenario. It is therefore expected that the phase 1 scenario gives give a worst case for the NO2 emissions allowed under the NEMAQA. The highest hourly ground level NO2 concentration expected for the phase 1 scenario is less than 210µg/m³ (110.5ppb). The NAAQS allow 88 hourly exceedances of the 200µg/m³ ambient NO2 concentration per year, this frequency of exceedance in not reached under the Phase 1 emission scenario. The current annual NO2 concentration as a result of the Mondi Power Boiler activities is based on the Mondi Licence requirements; however in 2010 the boilers operated at below capacity, resulting in NO2 emissions that were lower than expected. The actual projected NO2 impact from the power boiler operation is presented in Figure 5-32. When the current and background scenarios are combined to give the current cumulative emission scenario (Figure 5-33) the maximum hourly NO2 concentration is less than 205 µg/m³ located over the Mondi Richards Bay facility, but the 88 allowed hours of exceedance is not reached. When the phase 1 and the background scenario are combined to give the cumulative emission scenario (Figure 5-34) the area where the 200µg/m³ambient NO2 concentration is exceeded is slightly expanded but at no point does the frequency of exceedance of the NAAQS exceed the 88 allowed hours even with the extremely conservative Phase 1 emission scenario. The actual 2010 NO2 emissions and the baseline are presented in Figure 5-35. 5-24

Figure 5-30 Highest hourly NO2 concentrations, current sources only. Contours represent 5.3ppb (blue), 26.3ppb (green), 52.6ppb (magenta) and 106ppb (orange). Figure 5-31 Highest hourly NO2 concentrations, Mondi Phase 1 sources only. Contours represent 5.3ppb (blue), 26.3ppb (green), 52.6ppb (magenta) and 106ppb (orange). 5-25

Figure 5-32 Highest hourly NO2 concentrations, actual 2010 sources only. Contours represent 5.3ppb (blue), 26.3ppb (green), 52.6ppb (magenta) and 106ppb (orange). 5-26

Figure 5-33 Highest hourly NO2 concentrations, Mondi current and background sources. Contours represent 26.3ppb (blue), 52.6ppb (green), 78.9ppb (magenta) and 106ppb (orange). Figure 5-34 Highest hourly NO2 concentrations, Mondi Phase 1 and background sources. Contours represent 26.3ppb (blue), 52.6ppb (green), 78.9ppb (magenta) and 106ppb (orange). 5-27

Figure 5-35 Highest hourly NO2 concentrations, Mondi actual 2010 and background sources. Contours represent 26.3ppb (blue), 52.6ppb (green), 78.9ppb (magenta) and 106ppb (orange). 5-28

5.2.2.3 Expected NO2 Concentrations Using the emission standards is expected to result in a large overestimation of the resultant ambient NO2 concentrations. The expected incremental impacts of Phase 1 and Phase 2 combustion activities (Mondi sources only) are presented in Figure 5-36 and Figure 5-37 respectively (for the annual averaging period). Figure 5-38 and Figure 5-39 show cumulative impacts (other background sources considered) for phase 1 and 2 activities (annual averaging period). Figure 5-40 and Figure 5-41 show phase 1 and phase 2 for the incremental impacts (Mondi sources only) and Figure 5-42 and Figure 5-43 for Phase 1 and 2 for the cumulative impact (other background sources considered) for the highest hourly averaging period. The expected concentrations were calculated from the NPi emission factor (which is given as kg NOx/Mg coal combusted in a circulating fluidized bed boiler) and the coal use to obtain an emission rate in g/s. For the incremental impacts the expected annual average NO2 concentration is higher than the current levels but is still well below (>2µg/m³) the NAAQS of 40µg/m³. For the cumulative impact the annual concentrations are expected to be below 6µg/m³ in the Richards Bay area, although it must be noted that the NO2 emissions inventory for Richards Bay is limited. When the highest hourly NO2 concentrations are considered the expected concentrations as a result of the Mondi Activities are well below the NAAQS of 200µg/m³. When the cumulative concentrations are considered the pattern is very similar to the current scenario and it is expected that a similar exceedance distribution will occur. 5-30

Figure 5-36 Expected annual average NO2 concentrations as a result of phase 1 activities at Mondi. Figure 5-37 Expected annual average NO2 concentrations as a result of phase 2 activities at Mondi. 5-31

Figure 5-38 Expected annual average NO2 concentrations as a result of phase 1 activities at Mondi plus background. Figure 5-39 Expected annual average NO2 concentrations as a result of phase 2 activities at Mondi plus background. 5-32

Figure 5-40 Expected highest hourly NO2 concentrations as a result of phase 1 activities at Mondi. Figure 5-41 Expected highest hourly NO2 concentrations as a result of phase 2 activities at Mondi. 5-33

Figure 5-42 Expected highest hourly NO2 concentrations as a result of phase 1 activities at Mondi plus Richards Bay baseline. Figure 5-43 Expected highest hourly NO2 concentrations as a result of phase 2 activities at Mondi plus Richards Bay baseline. 5-34

Table 5-5 Summary of Maximum Modelled NO2 Concentrations Actual and Actual NO2 Annual (µg/m³) Base* Current Current and Phase 1 SA Base* limit Phase 1 SA Limit and base* Phase 1 Expected Phase 1 Expected and Base* Phase 2 Expected Phase 2 Expected and Base* 0.68 6.77 (10) 1.4 7.1 (19.7) 6.3 9.8 (64.3) 2.5 7.7 (32.5) 3.0 7.9 (40) 14.1 254.8 (5.5) 28.8 262.5 (11) 209.3 303.9 (68.9) 51.2 274.3 (18.7) 62.7 280.4 (22.4) NO2 Max Hour (µg/m³) * Figures in brackets denote Mondi s contribution to sum total concentrations. 5-35

5.2.3 Particulate Matter Particulate matter is a criteria pollutant in many countries, due to the health impacts that it can cause. The suspended particulate matter in the atmosphere can be grouped into various size classes including thoracic dust (aerodynamic diameter less than 10µm) which has the ability to penetrate into the lungs, and therefore has a health impact. Under the NAAQS PM10 concentration is controlled in both the annual and 24 hour averaging periods (see Table 3-1). 5.2.3.1 Annual PM10 The annual average PM10 concentration is limited to 40µg/m³ by the NAAQS. At present there is a margin of tolerance of 10µg/m³ to allow 50µg/m³ until the 31 December 2014 after which the margin of tolerance will be reduced to 0µg/m³. When the current scenario was considered Figure 5-44 the annual PM10 concentration as a result of the power boiler activities did not exceed 0.8µg/m³ (2% of the NAAQS). This is likely to be an underestimation because in the background scenario only the stack emissions are taken into account. When the phase 1 scenario was considered (Figure 5-45) (including material handling emissions) the annual PM10 concentration as a result of the power boiler activities did not exceed 6µg/m³ (15% of the NAAQS). The area where the PM10 impact was felt was limited to the area directly surrounding the Mondi Richards Bay facility. The difference in the location of the major impact is due to the additional local impact of the material handling operation, since the stack emission rates between the two scenarios are very similar. In the event of the Phase 2 scenario occurring it is expected that there will be a reduction in the local PM10 concentrations due to the reduced emissions during material handling operations. The current scenario as presented in Figure 5-44 is based on the licence conditions for the Mondi Boiler. However during 2010 the boiler facility was not operating at full capacity and as a result the actual emissions for 2010 were lower as presented in Figure 5-46 (please note the difference in concentration scales). A summary of the highest projected ambient PM10 concentrations is presented in Table 5-6. When the current scenario and baseline (Figure 5-47) and the baseline and the phase 1 Mondi activity are considered (Figure 5-51) it can be seen that there is a large region where the annual PM10 standards are exceeded. This region is located to the west of the harbour, corresponding to the coal facility and the aluminium smelters (see Figure 4-6). The area directly surrounding the Mondi facility that is impacted by the Phase1 operations is expected to remain within the NAAQS standards. The ambient impact as a result of the projected background and actual 2010 emissions is presented in Figure 5-49. There is very little difference in the pattern of ambient PM10 concentration since the Mondi Power boilers contributes a small proportion of the total PM10 concentration in the Richards Bay region. 5-36

Figure 5-44 PM10 annual average, Mondi current sources only. Figure 5-45 PM10 annual average, Mondi Phase 1 sources only. 5-37

Figure 5-46 PM10 annual average, Mondi actual 2010 sources only. 5-38

Figure 5-47 PM10 annual average, Mondi current and background sources. Figure 5-48 PM10 annual average, Mondi Phase 1 and background sources. 5-39

Figure 5-49 PM10 annual average, Mondi 2010 actual and background sources. 5-40

5.2.3.2 Highest Daily PM10 and Frequency of Exceedance The NAAQS provides a standard for daily PM10 concentrations of 75µg/m³ with a margin of tolerance of 45µg/m³ until 31 December 2014 after which the tolerance will be 0µg/m³. The guidelines allow four exceedances of the limit values annually. The highest daily PM10 concentration from current activity (Figure 5-50) does not exceed 6µg/m³, which is 8% of the NAAQS. When the highest daily PM10 concentrations as a result of the Phase 1 activities at the Mondi Richards Bay facility are considered (Figure 5-51) the highest daily PM10 concentration does not exceed 25µg/m³ (33% of the NAAQS). This area of elevated PM10 concentration is located directly over the Mondi Richards Bay facility and therefore does not significantly impact the surrounding communities. The difference in the location of the high PM10 concentrations is due to differences in the emission heights of the most important PM10 sources. Under the current scenario, the only source of PM10 that was considered from the RBCAA database is the stack, while the phase 1 scenario also considered the material handling emissions. These emissions occur at different heights and are therefore dispersed differently. The current PM10 emissions are based on the licence values for the power boilers, however during 2010 the power boilers were not operating at full capacity and as a result the actual PM10 emission was lower. The projected actual PM10 concentrations are presented in Figure 5-52 When the PM10 impact of the current scenario and baseline and the Phase 1 scenario and the baseline are considered (Figure 5-53 and Figure 5-54 respectively) a large area exceeds both the NAAQS and the allowed tolerance. This area is located predominantly around the coal terminal and the aluminium smelters sites (see Figure 4-6). There are no significant differences between the two scenarios. When the actual 2010 emissions and baseline are considered Figure 5-55 there is little difference in the pattern of PM10 concentration to the current or phase 1 scenarios, this is due to the comparatively small contribution that the Mondi boilers makes to the total projected PM10 concentrations in the Richards Bay area. For a comparison of the highest projected PM10 concentrations in the Richards Bay area see Table 5-6. Since 4 exceedances of the SA NAAQS are allowed annually consideration needs to be taken of the region where there are more than the 4 allowed exceedances of the daily standard annually for the Background plus current scenario (Figure 5-53) and the Background plus phase 1 scenario (Figure 5-57). The area where there are greater than 4 exceedances of the PM10 standard is limited to a region to the west of the port facility directly corresponding to the location of the aluminium smelters (Figure 5-56, Figure 5-57). The area directly impacted by the Mondi Richards Bay power boiler activity is not within this area of PM10 exceedance. 5-41

Figure 5-50 PM10 highest daily, current sources only. Figure 5-51 PM10 highest daily, Mondi Phase 1 sources only. 5-42

Figure 5-52 PM10 highest daily, actual 2010 emissions Mondi power boiler sources only. 5-43

Figure 5-53 PM10 highest daily concentrations, baseline and current PM10 emissions. Figure 5-54 PM10 highest daily concentration, baseline and Phase 1 PM10 emissions. 5-44

Figure 5-55 Highest daily PM10 concentrations, baseline and actual 2010 PM10 emissions. 5-45

Figure 5-56 Frequency of exceedance of the Daily PM standard of 75µg/m, baseline plus current Mondi emissions. Figure 5-57 Frequency of exceedance of the Daily PM standard of 75µg/m³, baseline plus Phase 1 Mondi emissions. 5-46

Table 5-6 Summary of Maximum modelled PM10 concentrations PM10 annual (µg/m³) PM10 Max Day (µg/m³) Actual Actual and Base Current Current and Base Phase 1 Phase 1 and Base 0.27 481.8 (0.1) 0.64 481.9 (0.1) 6.18 481.9 (1.3) 2.21 1531.3 (0.1) 5.2 1531.9 (0.3) 24.7 1531.9 (1.6) * Figures in brackets denote Mondi s contribution to sum total concentrations. 5-47

6 Summary and Conclusion 6.1 6.1.1 Summary ClO2 Storage Tank If the design of the chlorine dioxide storage tank meets the emission requirements of the National emission standards (HCl emission of 15mg/Nm³) it will be in accordance with the NEM:AQA. The ClO2 storage tanks are sealed and not expected to release HCl. 6.1.2 Incremental Impact (Mondi Sources Only) 6.1.2.1 Sulphur Dioxide (SO2) The SO2 emissions from the modified boilers at the Mondi Richards Bay facility are expected to reach a maximum of 2932 Mg/annum if the national emission limits are met. This is approximately 10.5% of the total annual SO2 emission for the Richards Bay area. The Phase 1 scenario is expected to result in reduced ambient SO2 concentrations due to the reduced SO2 emission concentration and the lower total amount of SO2 released annually. The direct impact of both the current and phase 1 operations at the power boilers is expected to be low, less than 10%, 25% and 34% of the annual, daily and hourly NAAQS standards respectively. 6.1.2.2 Nitrogen Dioxide (NO2) The scenarios show a significant difference in the NO2 emissions between the current and Phase 1 boiler scenarios where the current NO2 emission rate is 638.9Mg/annum and the phase 1 emission rate is expected to be 4383Mg/annum. This difference is due to the fact that the emission limits were used to determine the emission rate and probably represents an over estimation of what the actual emissions will be. The highest annual average ambient NO2 concentration is expected to account for 4% of the NAAQS (National Ambient Air Quality Standard) under the current scenario and 15% of the NAAQS under the phase 1 scenario. For the hourly averaging period the highest NO2 concentration from the current emissions is expected to be less than 15% of the NAAQS, while the highest hour from the Phase 1 scenario is expected to exceed the National standard but for less than the allowed 88 hours per year. 6.1.2.3 Particulate matter (PM10) The emissions of particulate matter from the modified Mondi Power boiler are expected to account for 7% of the total PM10 emissions in the Richards Bay area. The impact from the modified boilers is likely to be small, less than 15% of the NAAQS for both the highest daily and annual averaging period. If the Phase 2 scenario is implemented it is expected that there will be a further reduction in the local PM10 concentration due to the expected reduction in material handling related emissions. 6-1

6.1.3 Cumulative Impact (Mondi Sources and Background) 6.1.3.1 Sulphur Dioxide (SO2) The cumulative impact of SO2, where the other Richards Bay sources are included, shows exceedances of the NAAQS in the annual, daily and hourly averaging periods, From a study of the position of the areas of exceedance relative to the major sources and the individual impact of the Mondi Richards Bay power boiler sources, it is concluded that these exceedances are due to sources other than the Mondi Richards Bay power boilers. 6.1.3.2 Nitrogen Dioxide (NO2) The cumulative NO2 concentration does not show any exceedances of the NAAQS under either the current or the phase 1 scenarios for the annual averaging period, however there are exceedances in the hourly averaging period current and phase 1 scenarios although the number of exceedances is less than the 88 allowed annually. 6.1.3.3 Particulate Matter When the cumulative impact of PM10 is considered, exceedances of the NAAQS occur for both the annual and daily averaging periods. When the cumulative impacts are considered there are areas in exceedance of the NAAQS standards. From a study of the position of the areas of exceedance relative to the major sources and the individual impact of the Mondi Richards Bay power boiler sources, it is concluded that these exceedances are due to sources other than the Mondi Richards Bay power boilers. 6.2 Conclusion The proposed modification of the power boilers at the Mondi Richards bay facility is likely to have a limited impact on the ambient air quality in the Richards Bay region, if the emission standards are met. Of the three pollutants that were considered during this study the greatest impact would be on the NO2 concentrations, however this is a very conservative scenario using the national emission limits to determine the emission rate. There is expected to be a local increase in the PM10 concentrations, mostly due to the increased coal handling to power the boilers, this however is likely to be reduced during the second phase of the modification when biomass is used as a fuel source. The ambient SO2 concentrations are expected to decrease slightly with the modification if the national emission standards are met. 6-2

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8 Appendix A: Methodology 8.1 Calculation of Emission Factors The calculation of emission factors for the emission of PM10 Australian NPI document. In many cases the same methodology is used in both standards. Equations for the emission factor calculations for each of the material handling process are provided below. 8.1.1 Materials handling (confidence rating C- average) The Australian NPI (NPi 2001) provides emission factors for the handling of coal and for the handling of overburden. Using excavators, shovels and front end loaders The emission factor (kg/mg) is: Where, EF= Emission factor (kg/mg) K= 0.74 for TSP K= 0.35 for PM10 U= wind speed (m/s) M= material moisture (%) 8-1