TRANSNET PORT TERMINALS – SALDANHA TERMINALprojects.gibb.co.za/Portals/3/J7. WSP Saldanha...

TRANSNET PORT TERMINALS – SALDANHA TERMINAL Air Quality Compliance Review Draft February 2013

Project number: 34742 Dated: 2013/02/20 2 | 16 Revised:

Quality Management

Issue/revision Issue 1 Revision 1 Revision 2 Revision 3

Remarks Draft

Date February 2013

Prepared by S Doel

Signature

Checked by B Keiser

Signature

Authorised by S Doel

Signature

Project number 34742

Report number 1 of 1

File reference 34742_1

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TRANSNET Port Terminals – Saldanha Terminal Air Quality Compliance Review

2013/02/20

Client Transnet Port Terminals

Consultant WSP Environment and Energy Block A, 1 on Langford Langford Road, Westville Durban 3629 www.wspenvironmental.co.za

Registered Address WSP Environment & Energy South Africa 1995/008790/07 WSP House, Bryanston Place, 199 Bryanston Drive, Bryanston, 2191, South Africa

WSP Contacts Sean Doel Tel: 021 481 8700 Email: [email protected] Bradley Keiser Tel: 011 361 3600 Email: [email protected]


Table of Contents 1 Introduction ............................................................................... 5

2 Review of Monitoring Data ........................................................ 6

PM10 Results ........................................................................ 6 2.1 Dust Flux Results .................................................................. 6 2.2

3 Assessment of Compliance with Provisional AEL ................... 10

Dust Monitoring & Mitigation ................................................ 10 3.1 AEL Requirement .......................................................... 10 3.1.1 Relevant Documentation ............................................... 10 3.1.2 Assessment ................................................................... 10 3.1.3

SOP for Ore Transport......................................................... 11 3.2 AEL Requirement .......................................................... 11 3.2.1 Relevant Documentation ............................................... 11 3.2.2 Assessment ................................................................... 11 3.2.3

Vehicle Cleaning Facility...................................................... 12 3.3 AEL Requirement .......................................................... 12 3.3.1 Relevant Documentation ............................................... 12 3.3.2 Assessment ................................................................... 12 3.3.3

Marine Impact Study ............................................................ 12 3.4 AEL Requirement .......................................................... 12 3.4.1 Relevant Documentation ............................................... 12 3.4.2 Assessment ................................................................... 12 3.4.3

Communication Forum ........................................................ 13 3.5 AEL Requirement .......................................................... 13 3.5.1 Relevant Documentation ............................................... 13 3.5.2 Assessment ................................................................... 13 3.5.3

Noise Impact Study ............................................................. 13 3.6 AEL Requirement .......................................................... 13 3.6.1 Relevant Documentation ............................................... 13 3.6.2 Assessment ................................................................... 14 3.6.3

Dust Control Measures ........................................................ 14 3.7 AEL Requirement .......................................................... 14 3.7.1 Relevant Documentation ............................................... 14 3.7.2 Assessment ................................................................... 14 3.7.3

Alert System ........................................................................ 14 3.8 AEL Requirement .......................................................... 14 3.8.1 Relevant Documentation ............................................... 14 3.8.2 Assessment ................................................................... 14 3.8.3

Silt Loads on Roads ............................................................ 15 3.9 AEL Requirement .......................................................... 15 3.9.1 Relevant Documentation ............................................... 15 3.9.2 Assessment ................................................................... 15 3.9.3

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1 Introduction WSP Environmental (WSP) were appointed by Transnet Port Terminals (TPT) to undertaken an independent review and assessment of compliance of the TPT Saldanha operations with the Provisional AEL issued by the West Coast District Municipality (WCDM) reference no 12/3/1/11. WSP was furthermore required to advise TPT on any further actions that should be taken to management or mitigate air quality impacts associated with the TPT Saldanha operations.

WSP has extensive expertise and experience in air quality monitoring, modelling and impact assessments in South Africa as well as internationally. Our professional opinions in respect of TPT Saldanha, as expressed in this document, have been formulated based on a number visits to the TPT Saldanha operations and surrounding areas, as well as review of the following key documentation;

■ TPT Saldanha Provisional AEL, License No WS/WS/001, Ref No 12/3/1/11

■ WCDM Letters to TPT Ref No 12/3/1/11, dated 1 July 2011 and 17 August 2013

■ Monitoring reports for Dust and PM10 data from October 2006 to present

■ Saldanha Terminal Operational Environmental Management Plan, dated December 2012

■ Saldanha Terminal Dust Management Study undertaken by Environmental Management Consultants (ERM), dated May 2012

■ TPT Saldanha Dust Management Action Plan, dated XXXXX, Ref XXXX ?? (this must be a controlled, signed-off TPT document to have credibility with authorities)

■ Various TPT Work Instructions and Standard Operating Procedures (SOP) relevant in terms of the Provisional AEL

■ Study on The Impact of Fe2O3 on Marine Environment in Saldanha Bay undertaken by Anchor Environmental, dated October 2012

■ Environmental Noise Rating and Survey undertaken by Apex Environmental, dated October 2011

This report is structured in two parts. Firstly, our review and interpretation of air quality monitoring data from TPT Saldanha is presented in Section 2. Secondly, we present our assessment and recommendations in respect of compliance with conditions of the Provisional AEL (Section 3). We conclude with a summary and recommendations on the way forward.


2 Review of Monitoring Data TPT Saldanha has established a comprehensive air quality monitoring network with daily, monthly and quarterly reporting of data. There is an established historic record with earliest data dating back to 2002/3. Monitoring has included both PM10 as well as dust fallout, with the later specifically being used to assess the proportion of Fe2O3 in total dust.

PM10 Results 2.1Monitoring of the PM10 fraction of airborne dust is important as this represents the respirable fraction and hence component that could pose a human health risk. There are two real time monitoring stations that have been operated by Ecoserve/SGS since 2002, one at Vredenberg and the other at Blue Water Bay / TNPA Offices (the station has been shifted between these two locations over the history of monitoring). Both stations are well positioned in terms of the predominant southerly/south-westerly winds for the area.

We note the following from review of the PM10 data;

■ The daily average PM10 levels at the Vredenberg Site have been consistently very low. Averages from 2009 through to 2012 reported by SGS ranged between 17 and 19 µg/m3.

■ The daily average PM10 levels at the Blue Water Bay / TNPA Site were similarly very low. Averages from 2009 through to 2012 reported by SGS ranged between 17 and 27 µg/m3.

■ There is no evidence of any trend (increasing or decreasing) in terms of PM10 data, despite changes in volumes of materials handled at TPT Saldanha over time.

The reported levels are well below the National Ambient Standard of 120 µg/m3 and confirm the absence of any potential concern from a human health perspective. The monitoring data indicates that air quality in the TPT Saldanha area as well as Vedenberg, in terms of respirable dust, is very good.

Dust Flux Results 2.2Monitoring of dust fallout at Saldanha has been undertaken by uMoyo-Nilu and more recently (from October 2011) by Kayad Knight Piesold (KKP). The monitoring network is extensive. Due to the relatively high prevailing southerly winds, the monitoring has been based on collection of horizontal flux measurements as compared to traditional dust fallout buckets in accordance with the ASTM method. While there is scientific rationale for this approach, the flux data represents a mixture of suspended particulates as well as particulates that would be collected as dust fallout using the ASTM method. For this reason the data cannot be directly compared against dust fallout guidelines. TPT Saldanha have a process in place for adding ASTM compliant dust buckets to key flux monitoring stations to complement the existing flux monitoring network. This approach is strongly supported.

The above notwithstanding, the existing data set is very effective for tracking trends in particulate levels over time. The results of dust flux measurements from 2006 through to 2012 have been summarized in reports by uMoyo-Nilu, dated November 2011, and Kayad Knight Piesold, dated December 2012. These reports are provided in Appendix A for reference purposes and the results discussed below.

We have extracted below (Figures 1 and 2) the summarized flux data for the Blue Water Bay and Vredenberg flux monitoring stations as reported by uMoyo-Nilu.

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Figure 1: Monthly particulate (blue) and Fe2O3 (orange) flux in mg/m2/day at Blue Water (from uMoyo-Nilu,

Nov 2011)

Figure 2: Monthly particulate (blue) and Fe2O3 (orange) flux in mg/m2/day at Vredenberg for the static

sampler (top) and multi-directional sampler (bottom) (from uMoyo-Nilu, Nov 2011)


The data in Figures 1 and 2 shows a clear trend of improving (decreasing) levels of Fe2O3 flux with the levels from 2009 onward being notably lower than during 2007 and 2008. This trend of decreasing Fe2O3 flux levels is observed despite the increases in volumes of ore handled at the terminal and as summarized in Figure 3 below. This monitoring data thus demonstrates that the dust mitigation measures implemented by TPT Saldanha have had a significant beneficial impact in reducing dust emissions from operations.

Figure 3: Amount of iron ore received at the BTS tipplers (import) and leaving the port at the ship loaders (export) in tons per month (from uMoyo-Nilu, Nov 2011)

Review of dust flux data presented by KKP for 2012 similarly indicates a continued improving (decreasing) trend in dust flux levels. This is illustrated most pertinently in data from monitoring stations located on the terminal berth as shown in Figure 4 below.

Figure 4: Trend analysis of monthly Fe2O3 flux values from Oct 2011 to Sept 2012 for stations on the terminal berth (from KKP, Dec 2012)

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As is discussed later in this report, the ship loading section of the berth is the most singificant remaining area of the operations where meaningful improvements in dust mitigation can still be achieved. The data nevertheless demonstrates that efforts to date have already had singificant beneficial impacts in terms of dust supression.

The staining of surfaces and buildings as a result of Fe2O3 particulates is an internationally documented issue associated with iron ore terminals. There is irrefutable evidence of staining of buildings over time in various locations surrounding the Saldanha terminal, notably Blue Water Bay, Vredenberg and to a lesser degree Langebaan. Fe2O3 acts as a pigment and even trace amounts of fines on surfaces will result in visible staining with sufficient accumulation over time. The decreasing trends in flux levels observed in the monitoring data, however, indicate that the magnitude of this impact has in fact been continuously reducing over the last few years. Because of the accumulative staining effective of the material, this improvement is not likely to be apparent to residents in any of the above mentioned areas.


3 Assessment of Compliance with Provisional AEL The Provisional AEL issued by the WCDM to TPT Saldanha includes a number of standard as well as special license conditions that must be complied with before issue of a final license can be considered by the licensing authority. Special conditions are detailed under Section 7.7 (Investigation) of the Provisional AEL.

A review of compliance was undertaken by the WCDM on 24 July 2012 and feedback provided in a letter from WCDM to TPT Saldanha dated 17 August 2012. While no concerns regarding compliance with general license conditions such as routine reporting and record-keeping (Section 7.6 of the License) were raised, it was noted that not all conditions under Section 7.7 had been complied with to the satisfaction of the licensing authority. Furthermore, it was also specifically noted that TPT’s commitment to implement international best practices for dust management (as identified from the ERM Study discussed below) was not evident in the form of a detailed action plan with defined timeframes for implementation.

In this section we have reviewed each of the investigation conditions under Section 7.7 of the License along with relevant associated TPT documentation and specialist studies and provide our independent opinion in respect of compliance therewith. For each section we state the AEL requirement, followed by a list applicable documentation and then our assessment thereof.

Dust Monitoring & Mitigation 3.1

AEL Requirement 3.1.1Investigate the effectiveness of existing onsite dust monitoring systems and mitigation measures and submit to the authorities for approval action plans on how dust emanating from various operations can be further reduced and contained to the confines of the Port boundaries based on international best practices.

In this regard;

(a) The increase of direct loading operations must be investigated as a measure to control dust generation.

(b) The ship loading as well as conveyors feeding this activity should receive special focus.

(c) The reduction of open air stock piles must be investigated as a measure to control dust generation.

(d) All conveyors including the conveyor belt feeding the Arcelor Mittal stockpile must receive special focus.

Relevant Documentation 3.1.2■ Saldanha Terminal Dust Management Study undertaken by Environmental Management Consultants

(ERM), dated May 2012 (Appendix B)

■ Saldanha Terminal Operational Environmental Management Plan, dated December 2012 (Appendix B)

■ TPT Saldanha Dust Management Action Plan, dated XXXXX, Ref XXXX ?? (this must be a controlled, signed-off TPT document to have credibility with authorities) (Appendix B)

Assessment 3.1.3We have reviewed the ERM Dust Management Study in detail. This study provides a comprehensive review of all emission sources associated with TPT Saldanha operations and corrective action recommendations based on international best practice. We fully support and agree with the findings of the study based on our visual inspections of operations at TPT Saldanha.

The study specifically notes that the primary concern in terms of remaining sources of dust that can be more effectively controlled relate to ‘formation, removal and handling of belt carry back’. This issue occurs at the ship loading section of the berth and relates to the conveyor system at this location (not the ship loaders which are a

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comparatively minor source). The consequence of the current ineffective belt cleaning system is that significant quantities of fines accumulate on the ground in this area. Being highly exposed to winds travelling across the lagoon from any prevailing direction means that these fines will be far more readily dispersed than fines accumulated on landward portions of the site where frictional drag and other land barriers will comparatively reduce particulate entrainment.

TPT have extensive operational control measures and procedures in place (as detailed in the above referenced OEMP document). However, despite the best efforts by TPT to manually clean-up these spillages (the beneficial effects of which are already clearly evident in the monitoring data to date) this is an engineering design issue related to the conveyor system that requires an engineering solution to remedy.

The need for a clear commitment and timeline from TPT in terms of implementing a corrective engineering solution, along with commitment on the other action items raised in the ERM study was raised as a concern by WCDM in their review letter dated 17 August 2012. Having reviewed all documentation and being of similar view, this matter was further discussed between WSP and TPT.

In response TPT have, in addition to their existing OEMP, formulated a Dust Management Action Plan (referenced above and included in Appendix B) that includes action items and timelines commitments for implementation.

We have reviewed this Action Plan and are satisfied that (a) it includes all key action items recommended by ERM, and that (b) the timelines committed to by TPT are reasonable and adequate. Importantly, the commitment for implementation of the belt cleaning system is noted as July 2014. It is understood that TPT consider this to be realistically achievable based on the fact that they are already at advanced stages of their required internal feasibility studies, expenditure approval and design review processes.

In consideration of the above referenced documents and discussion, we are of the opinion that TPT have fully investigated the effectiveness of dust management measures and best practices options for dust management, as well as defined a clear set of action items with committed timelines as contemplated in terms of the AEL Section 7.7 investigation requirement.

SOP for Ore Transport 3.2

AEL Requirement 3.2.1Compile standard operating procedures (SOP) for contractors transporting iron ore fines and waste from the Port and ensure that off-site spillages are eliminated.

Relevant Documentation 3.2.2■ TPT Saldanha Waste and Scrap Monitoring Work Instruction, Reference TPT SLDT SHEQ/RS WI 007

(Appendix C)

The above work instruction was provided to WCDM during the review in July 2011.

Assessment 3.2.3The above work instruction was updated to include handling/transport of iron ore fines / waste from the Port. In terms of the work instruction all contractors/sub-contractors working for TPT are required to operate within the limits of this instruction. In event of accidental spillage they are required to report these to the TPT Environmental Manager who will inspect and sign-off when spills have been cleaned up to his/her satisfaction. This procedure is considered to address the objective of the license condition.


Vehicle Cleaning Facility 3.3

AEL Requirement 3.3.1Design and upgrade vehicle cleaning facilities that can cater for light as well as heavy vehicles and machinery. Also draft SOP to be implemented by responsible employees at vehicle cleaning facility and submit to the licensing authority for approval.

Relevant Documentation 3.3.2■ TPT Saldanha Washing of Dirty Vehicles Procedure, Reference TPT SLDT SHEQ/RS WI 011 (Appendix

D)


Assessment 3.3.3It was noted in the WCDM letter of 17 August 2011 that the vehicle washing facilities had been upgraded but were not yet functional.

The vehicle washing facility was observed in operation during site visits conducted by WSP in October 2012. The above referenced procedure adequately covers vehicle washing procedures and inspection obligations in terms of vehicles leaving the site. However, as there were instances when the facility was observed not to be operational subsequent to our first visit in October 2012, it is our view that there is a need for daily inspections of the facility to ensure routine operation. In our view the requirements of the AEL in terms of upgrading the washing facility have been met, but there is opportunity for TPT to improve effectiveness of this control measure by implementing regular inspections.

Marine Impact Study 3.4

AEL Requirement 3.4.1Commission a study complete with timeframes of implementation to determine the impact of increased Fe2O3 dust fall-out in the marine environment. The study should include stormwater runoff and contaminated water from wash bay. In this regard a stormwater master plan for the entire Port area must be compiled and submitted to the license authority for approval. Also indicate how ballast water discharge will be controlled effectively with the increase in vessels visiting the Port.

Relevant Documentation 3.4.2■ Study on The Impact of Fe2O3 on Marine Environment in Saldanha Bay undertaken by Anchor

Environmental, dated October 2012. (Document provided in Appendix E)

■ Stormwater master plan?? (Appendix E)

■ Port of Saldanha SOP 19 – Handling and Management of Ballast Water and Sediments in the Port (Appendix E)

SOP 19 was provided to WCDM during the review on 24 July 2012. The marine study report was not completed at time of the review but was submitted electronically by WSP to Piet Fabricius, WCDM on 15th February 2013.

Assessment 3.4.3Marine Study

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The marine study confirms the absence of any discernible negative trend in Fe loading to the sediments in the bay, this being attributed to the effectiveness of current control measures. It also noted that benthic macrofauna communities in the sediments in Saldanha Bay have been monitored along with trace metal since 1999 as part of the State of the Bay monitoring programme, and that no relationship between levels of Fe and abundance and biomass of macrofauna was observed in these samples.

The marine study confirms that the current levels of control by TPT are protective of marine impacts from dust fall-out. This investigation condition is considered to have been met and no further actions are considered to be required.

Stormwater Master Plan

……….

Ballast Water Management

It is not clear what the relevance of ship ballast water management is in respect of air quality management. This is not considered an appropriate condition for inclusion in the AEL.

Communication Forum 3.5

AEL Requirement 3.5.1Establish a communication forum with I&APs to, amongst others, continuously monitor the impact of iron ore fines on public and private property especially with regards to staining of property.

Relevant Documentation 3.5.2■ Environmental Stakeholders Forum Constitution (Appendix F)

Assessment 3.5.3An Environmental Stakeholders Forum has been formed with the first formal meeting taking place on 26th October 2011. This condition is considered to have been met.

Noise Impact Study 3.6

AEL Requirement 3.6.1Commission a plant wide noise investigation by an independent service provider to assess the total noise impact complete with recommendations for implementation as may be deemed necessary to the satisfaction of the licensing authority.

Relevant Documentation 3.6.2■ Saldanha Iron Ore Terminal – Tippler Operation Noise, JH Consulting, June 2009 (Appendix G)

■ Environmental Noise Rating and Survey, Apex Environmental, dated October 2011 (Appendix G)

The noise survey was noted as having been completed in the WCDM letter of 17 August but that the report was still to be submitted. The Apex Environmental report was submitted electronically by WSP to Piet Fabricius, WCDM on 15th February 2013.


Assessment 3.6.3It is questioned whether inclusion of noise related matters are appropriate as a condition of the AEL. This notwithstanding, noise surveys were carried out at TPT during 2008, 2009 and 2011. The 2011 Apex Report included monitoring of key noise sources along with assessment and recommendations as required in terms of the license condition. The condition is considered fulfilled.

It is well understood that the primary noise source from operations at TPT Saldanha relates to impact noise from rail truck couplings coming into contact with each other, and that brake cars thus need to be in working order and connected to Rail Trucks at all times during shunting operations.

Dust Control Measures 3.7

AEL Requirement 3.7.1Investigate and report on efficiency and availability of dust control measures and equipment and indicate how an efficiency of 75% for equipment such as sweeper, water truck, vacuum truck as well as fogging and canon sprayers, and 100% for tippler 1 & 2 bag house will be maintained.

Relevant Documentation 3.7.2■ TPT Saldanha Work instruction for efficiency calculation of mitigation measures, Reference TPT SLDT

SHEQ/RS WI 010 (Appendix H)


Assessment 3.7.3The above referenced work instruction documents the methods to be used to calculate efficiencies of control measures to meet requirements stipulated in the AEL (Section 7.1) along with both internal reporting requirements with TPT as well as to the licensing authority. The methods are considered to be sound and this requirement is considered to have been fulfilled.

Alert System 3.8

AEL Requirement 3.8.1A threshold alert system must be introduced in ambient monitoring programme. Specifications of such a system must be demonstrated to the authorities and submitted for approval.

Relevant Documentation 3.8.2■ TPT Letter to WCDM dated 8th July 2011 (Appendix I)

Assessment 3.8.3As indicated in the letter referenced above, an automated alert system with cell phone SMS notification is in operation linked to the ambient PM10 monitoring stations. It is noted that there are no regulatory limits for dust flux measurement nor is an automated alert system possible as collection and laboratory analysis of samples is required before results can be assessed. This condition is considered to have been fulfilled.

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Silt Loads on Roads 3.9

AEL Requirement 3.9.1Measurements to be undertaken to determine the silt load on roads in the Port. Should this be significantly higher than those assumed in the model a revised modelling study must be done.

Relevant Documentation 3.9.2■ Measurement of silt loading on roads, SGS March 2012 (Appendix J)

This study was provided to WCDM during the review in July 2011.

Assessment 3.9.3The testing of silt loading on roads was requested to confirm assumptions in the air quality impact study undertaken by SRK Consulting. It was assumed in the SRK study that silt content of unpaved roads was 10%. The test results indicate that the main haul roads have silt contents of 12.9% (TPT) and 1.1% (Mittal). The assumption of 10% is considered adequate in the SRK Study and the findings thereof would not be substantively altered by the test results of SGS. This is due in part to the fact that the haul roads are not the most significant dust source from TPT operations.

It is noted that surfaces around the stockpile and ship loading berth were found to have very high silt loads as would be expected from accumulation of fines in this locations. These are low volume roads and thus also not of concern in terms of the validity of the SRK Study.

This requirement is considered to have been fulfilled.

WSP Environment & Energy South Africa WSP Environment & Energy South Africa Block A, 1 on Langford Langford Road, Westville Durban 3629 South Africa Tel: +27 33 347 5391 Fax: +27 33 347 5391 www.wspenvironmental.co.za

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