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Address: 480 Smuts Drive, Halfway Gardens | Postal: P O Box 5260, Halfway House, 1685 Tel: +27 (0)11 805 1940 | Fax: +27 (0)11 805 7010 www.airshed.co.za ATMOSPHERIC IMPACT REPORT: WATERVAL SMELTER COMPLEX Project done on behalf of: Anglo American Platinum Report Compiled by: N Grobler Report No: 18AAP01 | Date: December 2018 Project Manager: H Liebenberg-Enslin

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Page 1: ATMOSPHERIC IMPACT REPORT: WATERVAL SMELTER COMPLEX · This investigation is necessary as it evaluates the impact of the Bafokeng Rasimone Platinum Mine and Mogalakwena Mine concentrate,

Address: 480 Smuts Drive, Halfway Gardens | Postal: P O Box 5260, Halfway House, 1685 Tel: +27 (0)11 805 1940 | Fax: +27 (0)11 805 7010

www.airshed.co.za

ATMOSPHERIC IMPACT REPORT:

WATERVAL SMELTER COMPLEX

Project done on behalf of: Anglo American Platinum

Report Compiled by: N Grobler

Report No: 18AAP01 | Date: December 2018

Project Manager: H Liebenberg-Enslin

Page 2: ATMOSPHERIC IMPACT REPORT: WATERVAL SMELTER COMPLEX · This investigation is necessary as it evaluates the impact of the Bafokeng Rasimone Platinum Mine and Mogalakwena Mine concentrate,

Atmospheric Impact Report: Waterval Smelter Complex

Report No.: 18AAP01 i

Report Details

Project Name Atmospheric Impact Report: Waterval Smelter Complex

Client Anglo American Platinum

Report Number 18AAP01

Report Version Draft

Date December 2018

Prepared by Nick Grobler, BEng (Chem), BEng (Hons) (Env) (University of Pretoria)

Reviewed by Hanlie Liebenberg-Enslin, PhD (University of Johannesburg)

Notice

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 as well as noise impact

assessments. The company originated in 1990 as Environmental Management

Services, which amalgamated with its sister company, Matrix Environmental

Consultants, in 2003.

Declaration

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.

Copyright Warning

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.

Revision Record

Version Date Section(s) Revised Summary Description of Revision(s)

Draft December 2018

Page 3: ATMOSPHERIC IMPACT REPORT: WATERVAL SMELTER COMPLEX · This investigation is necessary as it evaluates the impact of the Bafokeng Rasimone Platinum Mine and Mogalakwena Mine concentrate,

Atmospheric Impact Report: Waterval Smelter Complex

Report No.: 18AAP01 ii

Preface

Anglo American Platinum’s (AAP) subsidiary, Rustenburg Platinum Mines Limited (RPM), owns and operates the

Waterval Smelter Complex (WSC) to the east of Rustenburg in the North West Province. WSC is required to

comply with the Minimum Emission Standards (MES) published in terms of Section 21 of the National Environment

Management: Air Quality Act (Act No 39 of 2004) (NEMAQA).

The Listed Activities and associated MES, identified in terms of Section 21 of NEM:AQA require the WSC

operations to comply with the “New Plant‟ MES by 01 April 2020. WSC is working towards compliance with the

“New Plant‟ MES, effective on 1 April 2020, and is in the process of investigating additional management and

abatement options to mitigate Sulphur Dioxide (SO2) emissions to comply with the abovementioned New Plant

MES. This investigation is necessary as it evaluates the impact of the Bafokeng Rasimone Platinum Mine and

Mogalakwena Mine concentrate, both of which have a high sulphur content, to be processed in higher proportions

at the WSC. In addition, it is necessary for RPM to evaluate the impact of potential start/stop activities of the acid

plant on the 2020 MES limits. Several solutions are being investigated for mitigating the start / stop activities, which

potentially include improved gas and acid pre-heaters, use of different catalyst types, acid storage buffer and tail

gas scrubbing. The evaluation of the different potential solutions is still underway. Specific solutions are still being

evaluated to address the potential impact of the different feedstock types, however, it is envisaged that addressing

the start/stop activities may largely ensure compliance to the New Plant MES limits.

The additional abatement options are expected to be completed and fully ramped up by December 2023,

consequently, RPM wishes to apply for postponement until December 2023, of the New Plant MES (2020

Postponement Application) whilst it considers the outcome of the investigation and evaluation referred to above,

as well as the installation of appropriate abatement technology. It is requested that the Existing Plant MES of

3 500 mg/Nm³ be applicable during this time period.

In support of the submissions and to fulfil the requirements for these applications stipulated in NEMAQA and the

MES, air quality studies are required to substantiate the motivations for the extension.

Airshed Planning Professionals (Pty) Ltd (hereafter referred to as Airshed) was appointed by AAP to provide

independent and competent services for the compilation of an Atmospheric Impact Report as set out in the

Regulations Prescribing the format of the Atmospheric Impact Report, 2013, published under Government Notice

747 in Government Gazette 36904 of 11 October 2013 and detailing the results of the dispersion modelling

simulation, conducted in accordance with the Regulations Regarding Air Dispersion Modelling under Government

Notice R533, Government Gazette 37804 of 11 July 2014.

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Atmospheric Impact Report: Waterval Smelter Complex

Report No.: 18AAP01 iii

Table of Contents

Enterprise Details ........................................................................................................................................... 1

Enterprise Details .................................................................................................................................. 1

Location and Extent of the Plant ............................................................................................................ 2

Description of Surrounding Land Use (within 5 km radius) .................................................................... 2

Atmospheric Emission Licence and other Authorisations ...................................................................... 0

Nature of the Process ..................................................................................................................................... 1

Listed Activities ...................................................................................................................................... 1

Process Description ............................................................................................................................... 2

Unit Processes ...................................................................................................................................... 2

Technical Information ..................................................................................................................................... 5

Raw Materials Used and Production Rates ........................................................................................... 5

Production Rates ................................................................................................................................... 6

Appliances and Abatement Equipment Control Technology .................................................................. 6

Atmospheric Emissions .................................................................................................................................. 7

Point Source Parameters ...................................................................................................................... 7

Point Source Maximum Emission Rates during Normal Operating Conditions...................................... 8

Point Source Emission Estimation and Modelling Scenarios .......................................................... 10

Fugitive Emissions ............................................................................................................................... 10

Emission Summary .............................................................................................................................. 12

Emergency Incidents ........................................................................................................................... 13

Impact of Enterprise on the Receiving Environment .................................................................................... 15

Analysis of Emissions’ Impact on Human Health ................................................................................ 15

Study Methodology ......................................................................................................................... 15

Legal Requirements ........................................................................................................................ 17

Atmospheric Dispersion Potential ........................................................................................................ 22

Surface Wind Field .......................................................................................................................... 22

Temperature .................................................................................................................................... 24

Air Quality Monitoring data .................................................................................................................. 25

Dispersion Modelling Results .............................................................................................................. 31

Simulated SO2 Concentrations ........................................................................................................ 32

Simulated PM10 Concentrations ...................................................................................................... 38

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Atmospheric Impact Report: Waterval Smelter Complex

Report No.: 18AAP01 iv

Simulated NO2 Concentrations........................................................................................................ 40

Comparison of Measured and Modelled Concentrations ................................................................ 42

Conclusion ...................................................................................................................................... 44

Analysis of Emissions’ Impact on the Environment ............................................................................. 45

Effects of Particulate Matter on Animals ......................................................................................... 45

Effects of SO2 on Plants and Animals ............................................................................................. 45

Dust Effects on Vegetation .............................................................................................................. 46

Complaints ................................................................................................................................................... 47

Current Or Planned Air Quality Management Interventions ......................................................................... 54

Compliance And Enforcement History.......................................................................................................... 54

Additional Information ................................................................................................................................... 54

Annexure A – Declaration of Accuracy of Information .................................................................................. 55

Annexure B – Declaration of Independence ................................................................................................. 56

Annexure C – Information Required in the Air Dispersion Modelling Report as Per Code of Conduct (DEA,

2014) ..................................................................................................................................................................... 57

Annexure D – References ............................................................................................................................ 61

Annexure E – List of Electronic Files Submitted with the Report .................................................................. 63

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Atmospheric Impact Report: Waterval Smelter Complex

Report No.: 18AAP01 v

List of Tables

Table 1-1: Enterprise details ................................................................................................................................... 1

Table 1-2: Contact details of responsible person .................................................................................................... 1

Table 1-3: Location and extent of the plant ............................................................................................................. 2

Table 2-1: Listed activities ....................................................................................................................................... 1

Table 2-2: List of unit processes considered listed activities under NEMAQA ........................................................ 3

Table 2-3: List of non-listed activity unit processes ................................................................................................. 3

Table 3-1: Raw materials used ............................................................................................................................... 5

Table 3-2: Production Rates ................................................................................................................................... 6

Table 3-3: Appliances and abatement equipment control technology ..................................................................... 6

Table 4-1: Point source parameters ........................................................................................................................ 7

Table 4-2: Point source emission rates during normal operating conditions (modelled emission rates are shown in

bold) ........................................................................................................................................................................ 8

Table 4-3: Point Source Maximum Emission Rates during Start-up, Maintenance and/or Shut-down .................... 9

Table 4-4: Fugitive emission sources .................................................................................................................... 11

Table 4-5: Summary of Emissions from the WSC Operations .............................................................................. 12

Table 4-6: Summary of SO2 Emission Rates reported on the NAEIS system, 2015 to 2018 ............................... 12

Table 5-1: Model details ........................................................................................................................................ 16

Table 5-2: Simulation domain ............................................................................................................................... 16

Table 5-3: National Ambient Air Quality Standards for SO2, PM10, PM2.5 and NO2 ............................................... 17

Table 5-4: Listed Activity Subcategory 4.1: Drying and Calcining ......................................................................... 18

Table 5-5: Listed Activity Subcategory 4.16: Smelting and Converting of Sulphide Ores ..................................... 18

Table 5-6: Listed Activity Subcategory 4.20: Slag Processes ............................................................................... 19

Table 5-7: Summary of 2014 to 2017 Ambient Monitoring Results ....................................................................... 27

Table 5-8: Discreet Receptor Locations with Coordinates .................................................................................... 31

Table 5-9: Simulated SO2 concentrations at discreet receptor locations – Main Stack and ACP stack operating at

3 500mg/Nm³ and all other sources at the current emission rates ........................................................................ 32

Table 5-10: Simulated SO2 concentration at discreet receptor locations – Main Stack and ACP stack operating at

1 200 mg/Nm³ and all other sources at the current emission rates ....................................................................... 35

Table 5-11: Simulated PM10 concentration at discreet receptor locations – current operations. ........................... 38

Table 5-12: Simulated NO2 concentration at discreet receptor locations – current operations. ............................ 40

Table 6-1: Complaints received during 2017 and 2018 ......................................................................................... 48

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Atmospheric Impact Report: Waterval Smelter Complex

Report No.: 18AAP01 vi

List of Figures

Figure 1-1: WSC location with topography, sensitive receptors and the closest ambient monitoring stations shown

................................................................................................................................................................................ 0

Figure 1-2: WSC location with topography and major towns and industries shown - 50 km radius ........................ 0

Figure 2-1: Site Layout Map .................................................................................................................................... 1

Figure 2-2: Process flow chart indicating inputs, outputs and emissions ................................................................ 4

Figure 2-3: Process flow schematic ........................................................................................................................ 5

Figure 4-1: Source Contributions to SO2 Emissions – Main Stack and ACP Stack @ 3 500 mg/Nm³, all other

sources at 2015 to 2017 average emission rates.................................................................................................. 13

Figure 4-2: Source Contributions to SO2 Emissions – Main Stack and ACP Stack @ 1 200 mg/Nm³, all other sources

at 2015 to 2017 average emission rates ............................................................................................................... 13

Figure 4-3: Source Contributions to PM10 Emissions – All sources at 2015 to 2017 average emission rates ....... 14

Figure 4-4: Source Contributions to NOx Emissions – All sources at 2015 to 2017 average emission rates ........ 14

Figure 5-1: Period, day- and night-time wind rose for the period 2015 – 2017 (MM5 Data).................................. 23

Figure 5-2: Seasonal wind roses for the period 2015 – 2017 (MM5 Data) ............................................................ 23

Figure 5-3: Monthly average temperature (°C) profile for the period 2015 to 2017 .............................................. 24

Figure 5-4: Background (median) concentrations recorded at the eight APP monitoring stations for the period 2014

to 2017 .................................................................................................................................................................. 26

Figure 5-5: Annual average SO2 concentration recorded at the eight AAP monitoring stations (2014 to 2017). .. 28

Figure 5-6: Daily exceedances of the NAAQS limit value for SO2 recorded at the eight AAP monitoring stations

(2014 to 2017). ...................................................................................................................................................... 28

Figure 5-7: Hourly exceedances of the NAAQS limit value for SO2 recorded at the eight AAP monitoring stations

(2014 to 2017). ...................................................................................................................................................... 29

Figure 5-8: Annual average PM10 concentration recorded at the eight AAP monitoring stations (2014 to 2017). . 29

Figure 5-9: Daily exceedances of the NAAQS limit value for PM10 recorded at the eight AAP monitoring stations

(2014 to 2017). ...................................................................................................................................................... 30

Figure 5-10: Daily 99th Percentile PM10 Concentration recorded at the eight AAP monitoring stations (2014 to 2017).

.............................................................................................................................................................................. 30

Figure 5-11: Simulated annual average SO2 concentrations due to Main Stack and ACP stack operating at

3 500 mg/Nm³ and all other sources at the current emission rates ....................................................................... 33

Figure 5-12: Simulated 99th percentile daily SO2 concentrations due to Main Stack and ACP stack operating at

3 500 mg/Nm³ and all other sources at the current emission rates ....................................................................... 34

Figure 5-13: Simulated 99th percentile hourly SO2 concentrations due to Main Stack and ACP stack operating at

3 500 mg/Nm³ and all other sources at the current emission rates ....................................................................... 34

Figure 5-14: Simulated annual average SO2 concentrations due to Main Stack and ACP stack operating at

1 200 mg/Nm³ and all other sources at the current emission rates ....................................................................... 36

Figure 5-15: Simulated 99th percentile daily SO2 concentrations due to Main Stack and ACP stack operating at

1 200 mg/Nm³ and all other sources at the current emission rates ....................................................................... 37

Figure 5-16: Simulated 99th percentile hourly SO2 concentrations due to Main Stack and ACP stack operating at

1 200 mg/Nm³ and all other sources at the current emission rates ....................................................................... 37

Figure 5-17: Simulated annual average PM10 concentrations due to current operations ..................................... 39

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Atmospheric Impact Report: Waterval Smelter Complex

Report No.: 18AAP01 vii

Figure 5-18: Simulated 99th percentile daily PM10 concentrations due to current operations ............................... 39

Figure 5-19: Simulated 99th percentile hourly NO2 concentrations due to current operations .............................. 41

Figure 5-20: Modelled vs Measured Annual Average SO2 Concentrations at the AAP Monitoring Stations ........ 43

Figure 5-21: Modelled vs Measured 99th Percentile Daily SO2 Concentrations at the AAP Monitoring Stations .. 43

Figure 5-22: Modelled vs Measured 99th Percentile Hourly SO2 Concentrations at the AAP Monitoring Stations.

.............................................................................................................................................................................. 44

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Atmospheric Impact Report: Waterval Smelter Complex

Report No.: 18AAP01 1

Atmospheric Impact Report

ENTERPRISE DETAILS

Enterprise Details

The details of the Waterval Smelter Complex (WSC) operation are summarised in Table 1-1. The contact details

of the responsible person are provided in Table 1-2. Details regarding the location, surrounding land use and

communities are shown in Table 1-3 and Figure 1-1 to Figure 1-2.

Table 1-1: Enterprise details

Enterprise Name Anglo American Platinum, Rustenburg Platinum Mines (Pty)

Ltd, Waterval Smelter

Trading as Waterval Smelter (Pty) Ltd

Type of Enterprise Proprietary limited company

Company Registration Number 1931/003380/06

Registered Address Portion J of Waterval 303 JQ

Postal Address PO Box 404, Kroondal, 0350

Telephone Number (General) 014 591 5001

Fax Number (General) 014 591 4810

Industry Type/Nature of Trade Smelter, producing converter matte suitable for further

processing by the refineries

Land Use Zoning as per Town Planning Scheme Industrial / Mining

Land Use Rights if Outside Town Planning Scheme N/A

Table 1-2: Contact details of responsible person

Responsible Person Bayanda Mncwango

Telephone Number +27 (0)14 596 0494

Cell Number +27 83 2502060

Fax Number 014 591 4810

Email Address [email protected]

After Hours Contact Details 083 2502060/ 083 455 3165

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Atmospheric Impact Report: Waterval Smelter Complex

Report No.: 18AAP01 2

Location and Extent of the Plant

Table 1-3: Location and extent of the plant

Physical Address of the Plant Portion J of Waterval 303 JQ, Rustenburg District

Coordinates of Approximate Centre of Operations Latitude: -25.675037° S

Longitude: 27.324349° E

Extent 0.030 km²

Elevation Above Sea Level 1143

Province North West Province

Metropolitan/District Municipality Bojanala Platinum District

Local Municipality Rustenburg Local Municipality

Designated Priority Area Waterberg-Bojanala Platinum Priority Area

Description of Surrounding Land Use (within 5 km radius)

The surrounding area is a mixture of mining, industrial, agricultural and residential areas. The surrounding

residential areas include Nkaneng, Mfidikwe, Bokamosa, Thekwane, Photsaneng, Klipfontein North, Klipfontein,

Waterval village, Kroondal and Paardekraal.

There are numerous schools and clinics in the study area (more than fifty schools are present in the study domain

shown in Figure 1-1, schools are therefore not indicated in Figure 1-1) . Almost all of the residential areas shown

in Figure 1-1 has at least one school. The closest school to the WSC is Mfidikwe primary school, approximately

1.8 km to the north east of the operations. Several clinics and hospitals are located in the study area, with the

closest identified clinics located in the towns of Thekwane (3.5 km east) and Rustenburg (4.5 km west).

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Atmospheric Impact Report: Waterval Smelter Complex

Report No.: 18AAP01 0

Figure 1-1: WSC location with topography, sensitive receptors and the closest ambient monitoring stations shown

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Atmospheric Impact Report: Waterval Smelter Complex

Report No.: 18AAP01 0

Figure 1-2: WSC location with topography and major towns and industries shown - 50 km radius

Atmospheric Emission Licence and other Authorisations

The following authorisations, permits and licences related to air quality management are applicable:

• APPA Certificated:

o NWPG/DACET/Anglo-WS/SP1/01Apr06 – Sulphuric acid process

o NWPG/DACET/Anglo-WS/SP27/01Apr06 – Roasting process

• Atmospheric Emission License:

o Previous AEL – NWPG/WS/AEL 4.1, 4.16 & 4.20/MARCH 12

o Current AEL – BPDM/WSC/AEL4.1,4.16&4.20/MARCH2016

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Atmospheric Impact Report: Waterval Smelter Complex

Report No.: 18AAP01 1

NATURE OF THE PROCESS

Listed Activities

A summary of listed activities currently undertaken at the WSC is provided in Table 2-1. The site layout is shown

in Figure 2-1.

Table 2-1: Listed activities

Category of Listed Activity Sub-category of the Listed Activity Description of the Listed Activity

Category 4: Metallurgical Industry Subcategory 4.1: Drying Drying and calcining of mineral solids

including ore.

Category 4: Metallurgical Industry Subcategory 4.16: Smelting and

Converting of Sulphide Ores

Processes in which sulphide ores are

smelted, roasted, calcined or

converted.

Category 4: Metallurgical Industry Subcategory 4.20: Slag Processes The processing or recovery of

metallurgical slag by the application of

heat.

Figure 2-1: Site Layout Map

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Atmospheric Impact Report: Waterval Smelter Complex

Report No.: 18AAP01 2

Process Description

Flash driers

Drying of various concentrate materials to be fed to the electric furnaces and slag cleaning furnace (SCF).

Electric furnaces

The dried material from the flash driers as well as reverts are smelted in the furnace and furnace matte is granulated

and then fed to the Anglo Platinum Converting Process (ACP). The off gas, which has weak SO2 gas, is sent to

the ACP acid plant where SO2 is converted into sulfuric acid. The slag produced is treated in the Slag Mill and

flotation section.

Converter

Granulated or crushed matte form the electric furnace is sent to the ACP where excess iron sulfide is removed.

The converter matte product is slow cooled, crushed and sent to the Magnetic Concentration plant at the

Rustenburg Base Metals Refinery (RBMR). The slag is granulated and sent to the SCF. The off gas which has

strong SO2 gas is sent to the ACP acid plant where SO2 is converted into sulfuric acid.

Slag Cleaning

Granulated Waterval ACP Converter Slag (WACS), reductants, concentrates, reverts and silica is fed to the SCF.

Matte is produced and granulated (along with matte from the electric furnaces) and processed in the ACP. The

slag produced by the SCF is granulated to be further processed by the slag mill and floatation sections. The off-

gas which has weak SO2 gas is cleaned in the off gas plant. The effluent from the off gas plant is recirculated to

the Flash Driers. SCF1 is operational while SCF2 has an approved EIA/EMP in place but is not yet operational.

Unit Processes

Unit processes considered listed activities under the NEMAQA are summarised in Table 2-2. Other unit processes

that may result in atmospheric emissions which are not considered listed activities are summarised in Table 2-3.

The locations of the unit processes are shown in Figure 2-1.

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Atmospheric Impact Report: Waterval Smelter Complex

Report No.: 18AAP01 3

Table 2-2: List of unit processes considered listed activities under NEMAQA

Name of the Unit

Process Unit Process Function

Batch or Continuous

Process

Listed Activity

Sub-category

Drying Process Drying of various concentrate materials Continuous 4.1

Smelting Process Smelting of dried concentrate Continuous 4.16:

Converting

process

Removal of excess iron sulfide from the granulated

matte from the electric furnace. Continuous 4.16

Slag cleaning

furnace

Matte is produced and granulated (along with matter

form the electric furnace) and processed in the

converting process. The slag produced by the slag

cleaning furnace is granulated to be further processed

by the slag mill and floatation sections.

Continuous 4.20

Table 2-3: List of non-listed activity unit processes

Name of the Unit

Process Unit Process Function

Batch or

Continuous

Process

Matte granulation

and drying

Matte from the three furnaces is granulated using a closed water granulation

circuit. After granulation the slurry is dewatered to produce wet particulate matte

that is then dried and stored in a feed stock silo for ACP, while the water is

recirculated to the granulator.

Batch

Slag Mill and

Flotation

The slag from all three furnaces is milled and floated for the recovery of any

sulphur associated metals into a concentrate. This concentrate is returned to the

concentrate shed while the tails produced are discarded on the tailings dam.

Continuous

Casting and slow

cool

Waterval Converter Matte (WCM) is tapped out of the ACP Converter into ladles.

The WCM is then cast into moulds in the ground and covered by lids so that it

can cool slowly for approximately 3 days before the solidified WCM is removed

from the mould and allowed to cool further.

Batch

Crushing and

dispatch

The WCM that has been slow cooled is crushed to -3mm and is dispatched via

road tanker to the Magnetic Concentration (MC) plant at the Rustenburg Base

Metals Refinery (RBMR)

Batch

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Atmospheric Impact Report: Waterval Smelter Complex

Report No.: 18AAP01 4

Figure 2-2: Process flow chart indicating inputs, outputs and emissions

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Atmospheric Impact Report: Waterval Smelter Complex

Report No.: 18AAP01 5

Figure 2-3: Process flow schematic

TECHNICAL INFORMATION

Raw material consumption and production rates are tabulated in Table 3-1 and Table 3-2 respectively. Pollution

abatement technologies employed at WSC’s listed activities, and technical specifications thereof, are provided in

Table 3-3.

Raw Materials Used and Production Rates

Table 3-1: Raw materials used

Raw Material Type Design Consumption Rate Rate Unit

Concentrate 89 923 tonne/month

BMR (Base Metals Refinery) Residues 3 344 tonne/month

PMR (Precious Metals Refinery) Residues 850 tonne/month

External Furnace Mattes 27 992 tonne/month

Silica 11 030 tonne/month

51.5% Caustic 240 tonne/month

Coal (reductant) 3 500 tonne/month

Coke (reductant) 750 tonne/month

PGM Recycles 9 000 tonne/month

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Atmospheric Impact Report: Waterval Smelter Complex

Report No.: 18AAP01 6

Production Rates

Table 3-2: Production Rates

Product Type Design Production Rate Rate Unit

WCM (Converter Matte) 10 944 tonne/month

Slag Mill Tails 84 925 tonne/month

98% Sulfuric Acid (by-product) 26 006 tonne/month

Appliances and Abatement Equipment Control Technology

Table 3-3: Appliances and abatement equipment control technology

Appliance Name Appliance Type / Description

DCE Bag house – flash drier 2

DCE Bag house – flash drier 3

DCE Bag house – flash drier 4

HITEM Furnace 1 & 2 ceramic filter module 1

HITEM Furnace 1 & 2 ceramic filter module 1

HITEM Furnace 1 & 2 ceramic filter module 1

HITEM Furnace 1 & 2 ceramic filter module 1

HITEM Furnace 1 & 2 ceramic filter module 1

HITEM Furnace 1 & 2 ceramic filter module 1

Tower plant Tower plant

Contact plant Contact plant

Scrubber SCF off-gas HP quench pre-scrubber

Scrubber SCF off-gas HP venturi scrubber

Scrubber SCF off-gas alkaline scrubber

Scrubber Wet scrubber with neutralization

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Atmospheric Impact Report: Waterval Smelter Complex

Report No.: 18AAP01 7

ATMOSPHERIC EMISSIONS

The establishment of a comprehensive emission inventory formed the basis for the assessment of the air quality impacts from the WCM operations on the receiving environment.

Point source parameters used in the dispersion modelling simulations are shown in

Table 4-1. Emission rates during normal operations are shown in Table 4-2 with a qualitative description of upset conditions in Table 4-2. The emission estimation techniques

used to quantify emissions from each point source are described in Section 4.2.1 A list with the data sources that inform the tables below is included in Appendix F.

Point Source Parameters

Table 4-1: Point source parameters

Point Source

Number

Point Source

Name

Point Source

Coordinates

Height of

Release

above

Ground (m)

Height above

nearby building

(m)

Diameter at

Stack Tip or

Vent Exit

(m)

Actual Gas

Exit

Temperature

(°C)

Actual Gas

Volumetric

Flow Rate

(m³/hr)

Actual Gas

Exit Velocity

(m/s)

Type of

Emission

(Continuous

/Batch)

FD2 Flash Dryer 2 25.67453 S 27.32377 E 55 Not applicable (b) 1.44 102.3 101 715 17.35 Continuous

FD3 Flash Dryer 3 25.67456 S 27.32382 E 55 Not applicable (b) 1.44 102.0 100 513 17.14 Continuous

FD4 Flash Dryer 4 25.67457 S 27.32388 E 55 Not applicable (b) 2.00 104.7 198 524 17.55 Continuous

Main Stack Elec Furnaces 1

& 2 & Slag Mill 25.67437 S 27.32508 E 183

Not applicable (b) 4.62 70.8 93 040 1.54 Continuous

ACP ACP Converter

+ New AP 25.67597 S 27.33148 E 35

Not applicable (b) 2.55 51.5 208 858 11.36 Continuous

SCF1 SC Furnace 1 25.67535 S 27.32473 E 60 Not applicable (b) 2.00 30.0 50 894 4.50 Continuous

SCF2(a) SC Furnace 2* 25.67566S 27.32468 E 60 Not applicable (b) 2.00 30.0 50 894 4.50 Continuous

Notes: (a) Included in the AEL for WSC but not yet operational

(b) as per the Atmospheric Emissions License

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Point Source Maximum Emission Rates during Normal Operating Conditions

Table 4-2: Point source emission rates during normal operating conditions (modelled emission rates are shown in bold)

Point Source Number

Pollu-tant

Name

Average Emission Rates

Averaging Period

Duration of Emission

2015 to 2017 Isokinetic Sampling Average

Existing Plant MES New Plant MES

(mg/Nm3) (g/s) (t/a) (mg/Nm3) (g/s) (t/a) (mg/Nm3) (g/s) (t/a)

FD2

PM

89 1.5 49 100 1.7 54 50 0.9 27 24 Hours Continuous

FD3 17 0.3 9 100 1.7 54 50 0.9 27 24 Hours Continuous

FD4 39 1.3 41 100 3.3 105 50 1.7 53 24 Hours Continuous

Main Stack 88 1.5 48 100 1.7 54 50 0.9 27 24 Hours Continuous

ACP 33 1.4 43 100 4.1 129 50 2.0 65 24 Hours Continuous

SCF1 768 8.2 259 100 1.1 34 50 0.5 17 24 Hours Continuous

SCF2(a) 0 0.0 0 100 1.1 34 50 0.5 17 24 Hours Continuous

FD2

NOx

277 4.8 150 1 200 20.7 653 500 8.6 272 24 Hours Continuous

FD3 150 2.6 81 1 200 20.5 645 500 8.5 269 24 Hours Continuous

FD4 92 3.1 98 1 200 40.1 1 266 500 16.7 527 24 Hours Continuous

Main Stack 127 2.2 69 2 000 34.4 1 086 350 6.0 190 24 Hours Continuous

ACP 134 5.5 173 2 000 81.9 2 583 350 14.3 452 24 Hours Continuous

SCF1 54 0.6 18 2 000 21.4 674 350 3.7 118 24 Hours Continuous

SCF2(a) 0 0.0 0 2 000 21.4 674 350 3.7 118 24 Hours Continuous

FD2

SO2

108 1.9 59 1 000 17.2 544 1 000 17.2 544 24 Hours Continuous

FD3 42 0.7 23 1 000 17.1 538 1 000 17.1 538 24 Hours Continuous

FD4 51 1.7 54 1 000 33.4 1 055 1 000 33.4 1055 24 Hours Continuous

Main Stack 1 932 33.3 1 049 3 500 60.3 1 901 1 200 20.7 652 24 Hours Continuous

ACP 1 087 44.5 1 404 3 500 143.3 4 520 1 200 49.1 1 550 24 Hours Continuous

SCF1 274 2.9 93 2 500 26.7 843 1 500 16.0 506 24 Hours Continuous

SCF2(a) 0 0.0 0 2 500 26.7 843 1 500 16.0 506 24 Hours Continuous

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Table 4-3: Point Source Maximum Emission Rates during Start-up, Maintenance and/or Shut-down

Process Description of Nature of Potential Abnormal Release

(e.g. leakage, technology outage, etc.)

Pollutant(s) Released Briefly Outline Emergency Procedures

FD 2 Possible emission of ash during start-up and emergency

stop

Coal combustion

pollutants

Under normal conditions the HGG is vented through the flash dryer. Operation of

“caretaker” mode for longer than 30 minutes no longer procedural.

FD 3 Possible emission of ash during start-up and emergency

stop

Coal combustion

pollutants

Under normal conditions the HGG is vented through the flash dryer. Operation of

“caretaker” mode for longer than 30 minutes no longer procedural.

FD 4 Possible emission of ash during start-up and emergency

stop

Coal combustion

pollutants

Under normal conditions the HGG is vented through the flash dryer. Operation of

“caretaker” mode for longer than 30 minutes no longer procedural.

Main stack Emission of gas during emergency stop of ACP or tower

plant (furnace gas)

SO2 Only occurs for emergency/upset conditions

ACP High SO2 emissions from acid plant trips, off-gas temporarily

emitted through the ACP stack

SO2 Only occurs for emergency/upset conditions, off-gas is routed through the main

stack

SCF 1 Emission of gas/dust from emergency stack due to gas plant

failure

SO2, dust Emergency condition, plant is placed in a “holding “condition

A summary of upset conditions recorded during 2017 and 2018 is shown in Section 6.

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Point Source Emission Estimation and Modelling Scenarios

Point source emission of PM, SO2 and NO2 from the Flash Dryers and the SCF as given in Table 4-2 were

calculated from the average of emission rates recorded during the 2015, 2016 and 2017 isokinetic sampling

campaigns. Similarly, PM and NOx emissions from the Main Stack and ACP stack were also calculated from the

average emission rates recorded during the 2015 to 2017 isokinetic sampling campaigns.

Two scenarios were quantified and included in the dispersion modelling and impact assessment. The first scenario

is for the Main Stack and ACP stack at a constant average emission rate of 3 500 mg/Nm³ (the Existing Plant

MES). The second scenario is for the Main Stack and ACP stack at a constant average emission rate of

1 200 mg/Nm³ (the New Plant MES). For both of these scenarios SO2 emissions from the Flash Dryers and SCF

were included at 2015 to 2017 average emission rates as described above.

Fugitive Emissions

Over and above point source process emissions, WSC operations also result in some fugitive SO2 and PM

emissions released during tapping, casting and cooling. Fugitive emissions from the furnace area, SCF area and

ACP area were calculated based on 2017 production rates and US EPA AP42 Section 12.3 (Primary Copper

Smelting) emission factors. A summary of fugitive emission sources is given in Table 4-4.

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Table 4-4: Fugitive emission sources

Emission

Source Description

Latitude

(SW

corner)

Longitude

(SW

corner)

Length

(m)

Width

(m) Pollutant

Emissions

rate

(g/s)

Temporal

Variation

Flash

Driers Area

Flash Driers-

Drying

(emergency

stack and

HGG Stack)

25.6748 27.3241 23 48 PM, SO2,

NOx Only during emergencies

SCF Area

Slag Cleaning

Roof and

Emergency

Stack

25.6756 27.3249 60 19

PM 0.6 Dependent

on tapping

and

casting

schedule

SO2 0.5

Matte

Granulation

Area

Matte

Granulation

and Stacks

25.6756 27.3258 33 47

PM

Dependent on casting

schedule and wind

speed Matte

Granulation

Area

Matte Drying 25.6762 27.3273 30 18

Furnace

Area

Gas Cleaning

and Ceramic

Fans

25.6748 27.3253 44 35

SO2 0.3 Dependent

on tapping

and

casting

schedule

Tap holes and

Ladles (part of

furnaces)

25.6749 27.3246 20 164

PM 0.03 Electric

Furnaces 25.6758 27.3250 70 50

ACP Area ACP Slow

Cool Aisle 25.4037 27.1940 110 45

SO2 9.9 Dependent

on wind

speed and

building

ventilation

PM 0.3

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Emission Summary

A summary of all quantified emissions from the WSC, as described in Sections 4.1 and 4.3 are given in Table 4-5

and Figure 4-1 to Figure 4-4. A summary of SO2 emissions reported on the NAEIS system from 2015 to 2017 is

shown in Table 4-6.

Table 4-5: Summary of Emissions from the WSC Operations

Emission Source

Emission Rate (tonnes/annum)

SO2 (MS & ACP @ Existing Plant MES)

SO2 (MS & ACP @ New Plant MES)

PM10 NOx

Flash Dryer 2 59 59 48.6 150.5

Flash Dryer 3 23 23 8.9 80.9

Flash Dryer 4 54 54 41.0 97.5

Main Stack 1 901 652 48.0 68.8

ACP Stack 4 520 1 550 43.0 173.2

SCF1 93 93 258.7 18.1

SCF Area 14 14 19.3 -

Furnace Area 10 10 0.97 -

ACP Area 314 314 10.6 -

Table 4-6: Summary of SO2 Emission Rates reported on the NAEIS system, 2015 to 2018

Source Year SO2 emission rate (kg/a)

Flash Dryer 2

2015 8 909

2016 97 466

2017 69 204

Flash Dryer 3

2015 10 118

2016 29 808

2017 28 032

Flash Dryer 4

2015 18 957

2016 88 757

2017 53 261

ACP

2015 520 545

2016 457 307

2017 3 235 944

Main Stack

2015 46 822

2016 3 076 490

2017 25 492

SCF

2015 1 734

2016 286 510

2017 9 286

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Emergency Incidents

Emergency incidents at the ACP can occur if the Tower Plant is bypassed and off-gas from the ACP plant is directly

emitted through the ACP stack. Emergency incidents at WSC are investigated and evaluated on a case by case

basis. A summary of incidents recorded during 2017 and 2018 is shown in Section 6.

Figure 4-1: Source Contributions to SO2 Emissions – Main Stack and ACP Stack @ 3 500 mg/Nm³, all other

sources at 2015 to 2017 average emission rates

Figure 4-2: Source Contributions to SO2 Emissions – Main Stack and ACP Stack @ 1 200 mg/Nm³, all other

sources at 2015 to 2017 average emission rates

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Figure 4-3: Source Contributions to PM10 Emissions – All sources at 2015 to 2017 average emission rates

Figure 4-4: Source Contributions to NOx Emissions – All sources at 2015 to 2017 average emission rates

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IMPACT OF ENTERPRISE ON THE RECEIVING ENVIRONMENT

Analysis of Emissions’ Impact on Human Health

Study Methodology

The study methodology may be divided into a “preparatory phase” and an “execution phase”.

The preparatory phase included the flowing basic steps prior to performing the actual dispersion modelling and

analyses:

1. Understand Scope of Work

2. Assign Appropriate Specialists (See Annexure B)

3. Review of legal requirements (see Section 5.1.2)

4. Decide on Dispersion Model (see Section 5.1.1)

The Regulations Regarding Air Dispersion Modelling (Gazette No 37804 published 11 July 2014) (DEA, 2014) was

referenced for the dispersion model selection.

Three levels of assessment are defined in the Regulations regarding Air Dispersion Modelling:

• Level 1: where worst-case air quality impacts are assessed using simpler screening models

• Level 2: for assessment of air quality impacts as part of license application or amendment processes,

where impacts are the greatest within a few kilometers downwind (less than 50 km)

• Level 3: requires more sophisticated dispersion models (and corresponding input data, resources and

model operator expertise) in situations:

- where a detailed understanding of air quality impacts, in time and space, is required;

- where it is important to account for causality effects, calms, non-linear plume trajectories, spatial

variations in turbulent mixing, multiple source types, and chemical transformations;

- when conducting permitting and/or environmental assessment process for large industrial

developments that have considerable social, economic and environmental consequences;

- when evaluating air quality management approaches involving multi-source, multi-sector

contributions from permitted and non-permitted sources in an airshed; or,

- when assessing contaminants resulting from non-linear processes (e.g. deposition, ground-level

ozone (O3), particulate formation, visibility).

This study was considered to meet the requirements of a Level 2 assessment, and AERMOD was selected on the

basis that this Gaussian plume model is well suited to simulate dispersion where transport distances are likely to

be less than 50 km.

The execution phase (i.e. dispersion modelling and analyses) firstly involves gathering specific information in

relation to the emission source(s) and site(s) to be assessed. This includes:

• Source information: Emission rate, exit temperature, volume flow, exit velocity, etc.;

• Site information: Site building layout, terrain information, land use data;

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• Meteorological data: Wind speed, wind direction, temperature, cloud cover, mixing height;

• Receptor information: Locations using discrete receptors and/or gridded receptors.

The model uses this specific input data to run various algorithms to estimate the dispersion of pollutants between

the source and receptor. The model output is in the form of a predicted time-averaged concentration at the receptor.

These predicted concentrations are added to suitable background concentrations and compared with the relevant

ambient air quality standard or guideline. In some cases, post-processing can be carried out to produce percentile

concentrations or contour plots that can be prepared for reporting purposes.

AERMOD is an advanced new-generation model. It is designed to predict pollution concentrations from continuous

point, flare, area, line, and volume sources. AERMOD offers new and potentially improved algorithms for plume

rise and buoyancy, and the computation of vertical profiles of wind, turbulence and temperature however retains

the single straight-line trajectory limitation. AERMET is a meteorological pre-processor for AERMOD. Input data

can come from hourly cloud cover observations, surface meteorological observations and twice-a-day upper air

soundings. Output includes surface meteorological observations and parameters and vertical profiles of several

atmospheric parameters. AERMAP is a terrain pre-processor designed to simplify and standardise the input of

terrain data for AERMOD. Input data includes receptor terrain elevation data. The terrain data may be in the form

of digital terrain data. The output includes, for each receptor, location and height scale, which are elevations used

for the computation of air flow around hills.

A disadvantage of the model is that spatial varying wind fields, due to topography or other factors cannot be

included. Input data types required for the AERMOD model include: source data, meteorological data (pre-

processed by the AERMET model), terrain data and information on the nature of the receptor grid. Model details

and domain parameters are summarised in Table 5-1 and Table 5-2 below.

Table 5-1: Model details

Pollutants Model Version Executable

All pollutants AERMOD 7.2.5 EPA 09292

Table 5-2: Simulation domain

Simulation domain Details

South-western corner of simulation domain 521 195 m; 7 154 393 m

Domain size 22.5 x 12.5 km

Projection Grid: UTM Zone 35J, Datum: WGS 84

Resolution 100 m

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Legal Requirements

Atmospheric Impact Report

According to the NEMAQA, an Air Quality Officer (AQO) may require the submission of an Atmospheric Impact

Report (AIR) in terms of section 30, if:

• The AQO reasonably suspects that a person has contravened or failed to comply with the AQA or any

conditions of an AEL and that detrimental effects on the environment occurred or there was a contribution

to the degradation in ambient air quality.

• A review of a provisional AEL or an AEL is undertaken in terms of section 45 of the AQA.

The format of the Atmospheric Impact Report is stipulated in the Regulations Prescribing the Format of the

Atmospheric Impact Report.

National Ambient Air Quality Standards

Measured and modelled concentrations were assessed against National Ambient Air Quality Standards (NAAQS

– Table 5-3) published on 24th of December 2009 (Government Gazette 32816). Sulfur dioxide (SO2), Inhalable

Particulates (PM10 and PM2.5) and Nitrogen Dioxide (NO2) are the pollutants of concern in this assessment.

Table 5-3: National Ambient Air Quality Standards for SO2, PM10, PM2.5 and NO2

Pollutant Averaging Period Concentration (µg/m³) Frequency of Exceedance

Sulfur Dioxide (SO2)

10 minutes 500 526

1 hour 350 88

24 hour 125 4

1 year 50 0

PM10

24 hour 75 4

1 year 40 0

PM2.5

24 hour 40 4

1 year 20 0

Nitrogen Dioxide (NO2)

1 hour 200 88

1 year 40 0

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Minimum Emission Standards

The activities at WSC are considered Listed Activities (see Section 1.4) under Section 21 of NEM:AQA and require

an Atmospheric Emissions License (AEL) to operate. The Existing Plant and New Plant Minimum Emission

Standards (MES) for Subcategory 4.1: Drying and Calcining (applicable to the Flash Dryers), Subcategory 4.16:

Smelting and Converting of Sulphide Ores (applicable to the Main Stack and ACP stack) and Subcategory 4.20:

Slag Processes (applicable to the SCF) are given in Table 5-4,Table 5-5 and Table 5-6 respectively.

Current operations (Table 4-2) comply with the existing plant MES for all sources and all pollutants. It is anticipated

that, with the exception of SO2 from the Main Stack and ACP Stack (for which this postponement application is

made), all other pollutants from all other sources, including other pollutants from the Main Stack and ACP Stack,

will be in compliance with the New Plant MES by 1 April 2020.

Table 5-4: Listed Activity Subcategory 4.1: Drying and Calcining

Category 4.1: Drying and calcining of mineral solids including ore

Description: Drying and calcining of mineral solids including ore

Application: Facilities with capacity of more than 100 tonnes/month product

Substance or Mixture of Substances Existing Plant

emission limits:

mg/Nm³ under

normal conditions of

273K and 101.3kPa

New Plant emission

limits: mg/Nm³

under normal

conditions of 273

Kelvin and 101.3 kPa

Common

Name Chemical Symbol

Particulate Matter PM 100 50

Sulphur Dioxide SO2 1 000 1 000

Oxides of nitrogen NOx expressed as NO2 1 200 500

Table 5-5: Listed Activity Subcategory 4.16: Smelting and Converting of Sulphide Ores

Category 4.16: Smelting and Converting of Sulphide Ores

Description: Processes in which sulphide ores are smelted, roasted, calcined or converted

Application: All installations

Substance or Mixture of Substances Existing Plant

emission limits:

mg/Nm³ under

normal conditions of

273K and 101.3kPa

New Plant emission

limits: mg/Nm³

under normal

conditions of 273

Kelvin and 101.3 kPa

Common

Name Chemical Symbol

Particulate Matter PM 100 50

Oxides of nitrogen NOx expressed as NO2 1 200 500

Sulphur dioxide (feed SO2 >5% SO2) SO2 3 500 1 200

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Table 5-6: Listed Activity Subcategory 4.20: Slag Processes

Category 4.20: Slag Processes

Description: The processing or recovery of metallurgical slag by the application of heat

Application: All installations

Substance or Mixture of Substances Existing Plant

emission limits:

mg/Nm³ under

normal conditions

of 273K and

101.3kPa

New Plant emission

limits: mg/Nm³

under normal

conditions of 273

Kelvin and 101.3

kPa

Common

Name Chemical Symbol

Particulate Matter PM 100 50

Oxides of nitrogen NOx expressed as NO2 2 000 350

Sulphur dioxide SO2 2 500 1 500

Dispersion Modelling Guidelines

Air dispersion modelling provides a cost-effective means for assessing the impact of air emission sources, the

major focus of which is to determine compliance with the relevant ambient air quality standards. The Regulations

Regarding Air Dispersion Modelling was published in Government Gazette No 37804 published 11 July 2014 and

recommends a suite of dispersion models to be applied for regulatory practices as well as guidance on modelling

input requirements, protocols and procedures to be followed. The guideline to air dispersion modelling is

applicable:

(a) in the development of an air quality management plan, as contemplated in Chapter 3 of NEMAQA;

(b) in the development of a priority area air quality management plan, as contemplated in Section 19 of

NEMAQA;

(c) in the development of an atmospheric impact report, as contemplated in Section 30 of NEMAQA; and,

(d) in the development of a specialist air quality impact assessment study, as contemplated in Chapter 5 of

NEMAQA.

These regulations are therefore applicable to the development of this report. The first step in the dispersion

modelling exercise requires an objective of the modelling exercise and thereby gives clear direction to the choice

of the dispersion model most suited for the purpose. Chapter 2 of the Guideline presents the typical levels of

assessments, technical summaries of the prescribed models (SCREEN3, AERSCREEN, AERMOD, SCIPUFF,

and CALPUFF) and good practice steps to be taken for modelling applications.

Dispersion modelling provides a versatile means of assessing various emission options for the management of

emissions from existing or proposed installations. Chapter 3 of the Guideline prescribes the source data input to

be used in the models. Dispersion modelling can typically be used in the:

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• Apportionment of individual sources for installations with multiple sources. In this way, the individual

contribution of each source to the maximum ambient predicted concentration can be determined. This

may be extended to the study of cumulative impact assessments where modelling can be used to simulate

numerous installations and to investigate the impact of individual installations and sources on the

maximum ambient pollutant concentrations.

• Analysis of ground level concentration changes as a result of different release conditions (e.g. by

changing stack heights, diameters and operating conditions such as exit gas velocity and temperatures).

• Assessment of variable emissions as a result of process variations, start-up, shut-down or abnormal

operations.

• Specification and planning of ambient air monitoring programmes which, in addition to the location of

sensitive receptors, are often based on the prediction of air quality hotspots.

The above options can be used to determine the most cost-effective strategy for compliance with the NAAQS.

Dispersion models are particularly useful under circumstances where the maximum ambient concentration

approaches the ambient air quality limit value and provide a means for establishing the preferred combination of

mitigation measures that may be required including:

• Stack height increases;

• Reduction in pollutant emissions through the use of air pollution control systems (APCS) or process

variations;

• Switching from continuous to non-continuous process operations or from full to partial load.

Chapter 4 of the Guideline prescribes meteorological data input from on-site observations to simulated

meteorological data. The chapter also gives information on how missing data and calm conditions are to be treated

in modelling applications. Meteorology is fundamental for the dispersion of pollutants because it is the primary

factor determining the diluting effect of the atmosphere. Therefore, it is important that meteorology is carefully

considered when modelling.

New generation dispersion models, including models such as AERMOD and CALPUFF, simulate the dispersion

process using planetary boundary layer (PBL) scaling theory. PBL depth and the dispersion of pollutants within

this layer are influenced by specific surface characteristics such as surface roughness, albedo and the availability

of surface moisture:

• Roughness length (zo) is a measure of the aerodynamic roughness of a surface and is related to the

height, shape and density of the surface as well as the wind speed.

• Albedo is a measure of the reflectivity of the Earth’s surface. This parameter provides a measure of the

amount of incident solar radiation that is absorbed by the Earth/atmosphere system. It is an important

parameter since absorbed solar radiation is one of the driving forces for local, regional, and global

atmospheric dynamics.

• The Bowen ratio provides measures of the availability of surface moisture injected into the atmosphere

and is defined as the ratio of the vertical flux of sensible heat to latent heat, where sensible heat is the

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transfer of heat from the surface to the atmosphere via convection and latent heat is the transfer of heat

required to evaporate liquid water from the surface to the atmosphere.

Topography is also an important geophysical parameter. The presence of terrain can lead to significantly higher

ambient concentrations than would occur in the absence of the terrain feature. In particular, where there is a

significant relative difference in elevation between the source and off-site receptors large ground level

concentrations can result. Thus, the accurate determination of terrain elevations in air dispersion models is very

important.

The modelling domain would normally be decided on the expected zone of influence; the latter extent being defined

by the predicted ground level concentrations from initial model runs. The modelling domain must include all areas

where the ground level concentration is significant when compared to the air quality limit value (or other guideline).

Air dispersion models require a receptor grid at which ground-level concentrations can be calculated. The receptor

grid size should include the entire modelling domain to ensure that the maximum ground-level concentration is

captured and the grid resolution (distance between grid points) sufficiently small to ensure that areas of maximum

impact adequately covered. No receptors however should be located within the property line as health and safety

legislation (rather than ambient air quality standards) is applicable within the site.

Model Input

Meteorological Input Data

WSC operates eight meteorological stations co-located with the ambient monitoring stations surrounding WSC.

Hourly average wind speed, wind direction and temperature data from this station were available for the period

January 2014 to December 2017. In order to facilitate simulation of ground level pollutant concentrations with the

AERMOD dispersion model (for which upper air data is required), use was made of modelled hourly sequential

MM5 (Fifth-Generation NCAR / Penn State Mesoscale Model) meteorological data for the period January 2015 to

December 2017.

Land Use and Topographical Data

Readily available terrain and land cover data for use in AERMET and AERMAP was obtained from the Atmospheric

Studies Group (ASG) via the United States Geological Survey (USGS) web site at ASG. Use was made of Shuttle

Radar Topography Mission (SRTM) (30 m, 1 arc-sec) data and Lambert Azimuthal land use data for Africa.

Grid Resolution and Model Domain

The AERMOD modelling domain selected for the sources at WSC and the location of nearby sensitive receptor

locations extended over a modelling domain of 22.5 km by 12.5 km with a grid resolution of 100 m over the entire

modelling domain.

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Atmospheric Dispersion Potential

Meteorological mechanisms govern the dispersion, transformation, and eventual removal of pollutants from the

atmosphere. The analysis of hourly average meteorological data is necessary to facilitate a comprehensive

understanding of the dispersion potential of the site. The horizontal 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.

For this assessment, on-site measured meteorological data together with MM5 data provided the parameters

useful for describing the dispersion and dilution potential of the site i.e. wind speed, wind direction, temperature

and atmospheric stability, as discussed below. Measured on-site data was available for the period January 2014

to December 2017, while MM5 data was obtained for the period January 2015 to December 2017.

The MM5 data was obtained from Lakes Environmental (Canada), and was prepared for an on-site location

(25.67444S and 27.321389E) with a grid cell dimension of 12 km by 12 km.

Surface Wind Field

Wind roses comprise 16 spokes, which represent the directions from which winds blew during a specific period.

The colours used in the wind roses below, reflect the different categories of wind speeds; the red area, for example,

representing winds >11.1 m/s. The dotted circles provide information regarding the frequency of occurrence of

wind speed and direction categories. The frequency with which calms occurred, i.e. periods during which the wind

speed was below 0.5 m/s are also indicated.

The period wind field, diurnal and seasonal variability for the study area (based on the on-site MM5 meteorological

data) are provided in Figure 5-1 and Figure 5-2. The average wind speed for the period 2015 to 2017 was 2.98 m/s.

The predominant wind directions are from the northeast during the day with an increase in southernly and easterly

winds during the night. During spring and summer, the predominant wind direction is mainly from the northeast

while in winter and autumn an increase in wind from the south is seen.

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Figure 5-1: Period, day- and night-time wind rose for the period 2015 – 2017 (MM5 Data)

Figure 5-2: Seasonal wind roses for the period 2015 – 2017 (MM5 Data)

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Temperature

Air temperature is important, both for determining the effect of plume buoyancy (the larger the temperature

difference between the emission plume and the ambient air, the higher the plume is able to rise), and determining

the development of the mixing and inversion layers.

Average temperatures in the study area between 2015 and 2017 ranged between 1.2°C (recorded in July) and

34.5°C (recorded in December). During the day, temperatures increase to reach maximum at around 17:00 in the

afternoon. Ambient air temperature decreases to reach a minimum at around 06:00 i.e. near sunrise.

Figure 5-3: Monthly average temperature (°C) profile for the period 2015 to 2017

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Air Quality Monitoring data

Ambient concentrations of SO2 and PM10 are monitored by AAP at eight locations in the study area as shown in

Figure 1-1. Ambient monitoring results in comparison to the SA NAAQS are shown in Figure 5-5, Figure 5-6 and

Figure 5-7 for annual, daily and hourly SO2 and Figure 5-8, Figure 5-9 and Figure 5-10 for annual and daily PM10.

A summary of monitoring results is shown in Table 5-7. Background SO2 and PM10 concentrations (Figure 5-4)

were estimated by calculating the median (50th percentile) concentration over the four-year monitoring period.

During the 2014 to 2017 monitoring period, sampled annual average SO2 concentrations were in

compliance with the SA NAAQS at all eight sampling locations. Hourly and daily SO2 concentrations

exceeded the SA NAAQS at the Paardekraal sampling location during 2016 but were in compliance with

the SA NAAQS during 2014, 2015 and 2017. Sampled hourly and daily SO2 concentrations were in

compliance with the SA NAAQS at the other seven sampling locations for the entire period from 2014 to

2017.

Due to the arid nature of the study area and the prevalence of particulate emission sources such as numerous

underground and opencast platinum and chrome mines, various smelting, processing and other industrial

operations, rehabilitated and unrehabilitated tailings storage facilities, agricultural operations and low income

residential areas (where domestic fuel use is the primary way of heating and cooking), particulate concentrations

are considered high in the study area.

During the 2014 to 2017 sampling period, sampled annual and daily PM10 concentrations were only in compliance

with the SA NAAQS at the Bergsig monitoring station for the entire period. Sampled annual average PM10

concentrations at the Hexriver and Waterval sampling stations were in compliance with the SA NAAQS during

2014, 2016 and 2017 but exceeded the limit value of 40 µg/m³ in 2015. Daily PM10 concentrations exceeded the

SA NAAQS (4 exceedances of 75 µg/m³) at all sampling locations (except Bergsig) for all years in the sampling

period. In general, higher PM10 concentrations were recorded in 2015 (when the area was stricken by drought)

compared to the other years. The highest PM10 concentrations were recorded at the Wonderkop sampling location,

but concentrations recorded at the nearby Brakspruit and Klipfontein sampling locations indicate that these high

PM10 concentrations at Wonderkop are likely due to local particulate sources. There are numerous particulate

sources in the area, including mining activities (which includes stockpiles and tailings storage facilities), industrial

sources including smelters as well as agricultural sources.

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Figure 5-4: Background (median) concentrations recorded at the eight APP monitoring stations for the

period 2014 to 2017

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Table 5-7: Summary of 2014 to 2017 Ambient Monitoring Results

Sampling Location Bergsig

Brak-spruit Hexriver

Klip-fontein Mfidikwe

Paarde-kraal Waterval

Wonder-kop

Year Annual Average SO2 Concentration (SA NAAQS = 50 µg/m³)

2014 12 10 13 10 17 13 18 11

2015 14 18 12 14 22 24 20 15

2016 18 15 15 14 25 37 25 16

2017 14 17 6 18 24 32 20 19 Highest Daily SO2 Concentration (SA NAAQS = 125 µg/m³)

2014 57 37 51 47 167 66 108 45

2015 57 81 50 76 170 148 100 57

2016 56 79 65 74 182 441 170 116

2017 39 57 22 133 195 119 178 74 Daily Exceedances of the NAAQS Limit Value for SO2 (SA NAAQS = 4 exceedances)

2014 0 0 0 0 1 0 0 0

2015 0 0 0 0 4 1 0 0

2016 0 0 0 0 1 11 1 0

2017 0 0 0 1 3 0 1 0 Highest Hourly SO2 Concentration (SA NAAQS = 350 µg/m³)

2014 567 306 172 251 2 574 586 1 328 390

2015 489 502 284 680 2 206 1 010 1 504 398

2016 366 697 537 770 2 418 7 518 3 240 1 781

2017 208 336 127 1 106 3 977 658 1 020 555 Hourly Exceedances of the NAAQS Limit Value for SO2 (SA NAAQS = 88 exceedances)

2014 4 0 0 0 18 5 22 1

2015 2 4 0 3 39 20 15 2

2016 2 5 5 3 57 89 35 3

2017 0 0 0 4 46 21 22 2 Annual Average PM10 Concentration (SA NAAQS = 40 µg/m³)

2014 24 34 33 39 54 50 39 79

2015 29 43 41 57 56 63 50 110

2016 20 53 29 48 43 51 35 79

2017 32 42 8 35 49 52 40 83 Highest Daily PM10 Concentration (SA NAAQS = 75 µg/m³)

2014 53 207 200 134 153 176 102 371

2015 77 159 88 177 131 158 118 711

2016 155 172 79 124 160 160 101 244

2017 61 173 13 130 174 160 106 584 Daily Exceedances of the NAAQS Limit Value for PM10 (SA NAAQS = 4 exceedances)

2014 0 15 3 19 46 55 7 143

2015 1 15 5 62 62 90 22 225

2016 1 52 2 23 14 43 7 120

2017 0 2 0 8 49 32 12 163

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Figure 5-5: Annual average SO2 concentration recorded at the eight AAP monitoring stations (2014 to

2017).

Figure 5-6: Daily exceedances of the NAAQS limit value for SO2 recorded at the eight AAP monitoring

stations (2014 to 2017).

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Figure 5-7: Hourly exceedances of the NAAQS limit value for SO2 recorded at the eight AAP monitoring

stations (2014 to 2017).

Figure 5-8: Annual average PM10 concentration recorded at the eight AAP monitoring stations (2014 to

2017).

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Figure 5-9: Daily exceedances of the NAAQS limit value for PM10 recorded at the eight AAP monitoring

stations (2014 to 2017).

Figure 5-10: Daily 99th Percentile PM10 Concentration recorded at the eight AAP monitoring stations (2014

to 2017).

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Dispersion Modelling Results

Dispersion modelling results are presented in the following sections for each of the pollutants modelled. Two

dispersion modelling scenarios were included for SO2 namely;

• Main stack and ACP stack SO2 emissions at the Existing Plant MES for SO2 (3 500 mg/Nm³) with all other

sources at current (2015 to 2017 average) emission rates, and

• Main stack and ACP stack SO2 emissions at the New Plant MES for SO2 (1 200 mg/Nm³) with all other

sources at current (2015 to 2017 average) emission rates.

Dispersion modelling scenarios for PM10 (and PM2.5) as well as NO2 were conducted with all sources at current

(2015 to 2017 average) emission rates.

Ground-level pollutant concentrations were simulated for each receptor grid point as described in Table 5-2.

Isopleth plots represent the interpolated concentrations between each of the receptor grid points.

Pollutant concentrations were also simulated at fourteen identified discreet receptor locations as shown in Figure

1-1 and described in Table 5-8. Ambient monitoring stations were also included as discreet receptors to allow for

comparison between modelled and monitored concentrations. Discreet receptors were modelled with a flagpole

receptor height of 1.5 m. Major emission sources (Figure 2-1) are located as close as 30 m from the northern

property boundary (the Main Stack), 80 m from the southern boundary (the SCF), 120 m from the eastern boundary

(the ACP stack) and 100 m from the western boundary (the flash dryers).

The ambient air quality standards apply to areas where the Occupational Health and Safety regulations do not

apply, thus outside the facility boundary. Ambient air quality standards are therefore not occupational health

indicators but applicable to areas where the general public has access i.e. off-site.

Table 5-8: Discreet Receptor Locations with Coordinates

Receptor X (UTM 35S) Y (UTM 35S)

PMR 535012 7158398

RBMR 532832 7159236

Nkaneng 538483 7158347

Mfidikwe 534304 7161540

Bokamosa 534709 7160489

Thekwane 536897 7161981

Entabeni 533123 7162066

Waterkloof 531773 7156954

Photsaneng 537931 7159365

Boitekong 529162 7163573

Bleskop 536215 7157873

Klipfontein 537190 7156592

Waterval Village 532661 7158044

Kroondal 530870 7154880

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Simulated SO2 Concentrations

Main Stack and ACP Stack at 3 500 mg/Nm³ and all other sources at 2015 to 2017 average

Simulated ground level SO2 concentrations due to the Main Stack and ACP stack operating at 3 500 mg/Nm³ and

all other sources at the current (2015 to 2017 average) emission rates are shown in Figure 5-11, Figure 5-12 and

Figure 5-13 for the annual, daily and hourly averaging periods respectively. Background SO2 concentrations as

shown in Figure 5-4 were added to simulated daily and hourly SO2 concentrations, thus all isopleth plots shown

for these averaging periods represent cumulative impacts. Simulated SO2 concentrations and frequencies of

exceedance (FOE) of the NAAQS limit value at identified sensitive receptor locations as well as at the AAP

monitoring stations are show in Table 5-9.

Simulated annual average SO2 concentrations due the Main Stack and ACP stack operating at 3 500mg/Nm³ and

all other sources at the current (2015 to 2017 average) emission rates are in compliance with the SA NAAQS for

all areas outside the property boundary. Simulated daily and hourly SO2 concentrations exceed the SA NAAQS

approximately 200 m to the south and northeast of the plant boundary (hourly and daily) as well as at the elevated

areas on top of the ridges to the east of the operations (daily only) and on the slopes of the Magaliesberg mountains

in the south and west of Rustenburg (hourly and daily).

Simulated daily and hourly SO2 concentrations exceed the SA NAAQS to the east, west and north of the property

boundary, but are in compliance with the SA NAAQS at all discreet receptor locations as shown in Table 5-9. The

maximum 99th percentile daily (180 µg/m³) and hourly (570 µg/m³) simulated concentrations are shown to be at

the north-western property boundary (532 821 X and 7 160 657 Y).

Table 5-9: Simulated SO2 concentrations at discreet receptor locations – Main Stack and ACP stack

operating at 3 500mg/Nm³ and all other sources at the current emission rates

SO2 Annual

Average (µg/m³)

Highest Daily

(µg/m³)

Highest Hourly (µg/m³)

99th Percentile

Daily (µg/m³)

99th Percentile

Hourly (µg/m³)

Daily FOE of the

NAAQS Limit

Hourly FOE of

the NAAQS

Limit

SA NAAQS 40 - - 125 350 4 88

Bergsig AQMS 15 159 2 227 90.2 236 2 56

Brakspruit AQMS 7 47 925 31.1 6 0 9

Hexriver AQMS 9 34 492 24.1 92 0 3

Klipfontein AQMS 13 190 3 247 115.8 28 3 40

Mfidikwe AQMS 9 61 1 101 44.6 59 0 13

Paardekraal AQMS 10 50 624 28.8 99 0 5

Waterval AQMS 13 58 755 34.3 100 0 7

Wonderkop AQMS 11 215 4 577 125.5 11 4 22

PMR 8 35 570 20.4 53 0 3

RBMR 26 104 1 343 74.5 227 0 39

Nkaneng 11 146 3 184 107.8 13 3 24

Mfidikwe 9 77 1 122 45.9 67 0 13

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SO2 Annual

Average (µg/m³)

Highest Daily

(µg/m³)

Highest Hourly (µg/m³)

99th Percentile

Daily (µg/m³)

99th Percentile

Hourly (µg/m³)

Daily FOE of the

NAAQS Limit

Hourly FOE of

the NAAQS

Limit

Bokamosa 9 61 1 264 43.6 49 0 14

Thekwane 6 17 257 7.0 11 0 0

Entabeni 11 61 701 45.0 119 0 10

Waterkloof 9 43 472 20.8 48 0 1

Photsaneng 10 153 2 365 81.6 14 1 23

Boitekong 8 25 365 18.2 77 0 1

Bleskop 6 18 301 11.6 26 0 0

Klipfontein 11 162 1 975 80.8 28 1 35

Waterval Village 10 48 540 20.6 63 0 2

Kroondal 8 33 609 22.8 33 0 4

Figure 5-11: Simulated annual average SO2 concentrations due to Main Stack and ACP stack operating at

3 500 mg/Nm³ and all other sources at the current emission rates

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Figure 5-12: Simulated 99th percentile daily SO2 concentrations due to Main Stack and ACP stack operating

at 3 500 mg/Nm³ and all other sources at the current emission rates

Figure 5-13: Simulated 99th percentile hourly SO2 concentrations due to Main Stack and ACP stack

operating at 3 500 mg/Nm³ and all other sources at the current emission rates

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Main Stack and ACP Stack at 1 200 mg/Nm³ and all other sources at 2015 to 2017 average

Simulated ground level SO2 concentrations due to the Main Stack and ACP stack operating at 1 200 mg/Nm³ and

all other sources at the current (2015 to 2017 average) emission rates are shown in Figure 5-14, Figure 5-15 and

Figure 5-16 for the annual, daily and hourly averaging periods respectively. Background SO2 concentrations as

shown in Figure 5-4 were added to simulated daily and hourly SO2 concentrations, thus all isopleth plots shown

for these averaging periods represent cumulative impacts.

Simulated SO2 concentrations and frequencies of exceedance (FOE) of the NAAQS limit value at identified

sensitive receptor locations as well as at the AAP monitoring stations are show in Table 5-10. Simulated annual

average, daily and hourly SO2 concentrations due the Main Stack and ACP stack operating at 1 200mg/Nm³ and

all other sources at the current (2015 to 2017 average) emission rates are in compliance with the SA NAAQS for

all areas outside the property boundary except directly to the north west of the property boundary (there are no

sensitive receptors in this area as the land is currently occupied by a tailings storage facility).

The maximum 99th percentile daily (146 µg/m³) and hourly (480 µg/m³) simulated concentrations are shown to be

at the north western property boundary (532 821 X and 7 160 657 Y).

Table 5-10: Simulated SO2 concentration at discreet receptor locations – Main Stack and ACP stack

operating at 1 200 mg/Nm³ and all other sources at the current emission rates

SO2 Annual

Average (µg/m³)

Highest Daily

(µg/m³)

Highest Hourly (µg/m³)

99th Percentile

Daily (µg/m³)

99th Percentile

Hourly (µg/m³)

Daily FOE of the

NAAQS Limit

Hourly FOE of

the NAAQS

Limit

SA NAAQS 40 - - 125 350 4 88

Bergsig AQMS 9 62 875 35 105 0 10

Brakspruit AQMS 6 18 361 12 3 0 1

Hexriver AQMS 7 20 281 16 65 0 0

Klipfontein AQMS 8 79 1 149 42 12 0 22

Mfidikwe AQMS 7 50 1 101 31 30 0 11

Paardekraal AQMS 8 33 305 17 70 0 0

Waterval AQMS 10 44 753 26 63 0 6

Wonderkop AQMS 7 85 1 767 50 5 0 15

PMR 7 27 570 14 23 0 2

RBMR 16 91 1 343 56 114 0 37

Nkaneng 7 55 1 191 42 5 0 15

Mfidikwe 8 53 1 121 39 34 0 11

Bokamosa 8 60 1 264 39 21 0 14

Thekwane 5 13 237 5 5 0 0

Entabeni 9 43 411 30 104 0 5

Waterkloof 7 24 472 16 26 0 1

Photsaneng 7 57 886 30 5 0 13

Boitekong 7 19 361 13 46 0 1

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SO2 Annual

Average (µg/m³)

Highest Daily

(µg/m³)

Highest Hourly (µg/m³)

99th Percentile

Daily (µg/m³)

99th Percentile

Hourly (µg/m³)

Daily FOE of the

NAAQS Limit

Hourly FOE of

the NAAQS

Limit

Bleskop 6 7 137 6 11 0 0

Klipfontein 7 56 686 29 11 0 15

Waterval Village 7 21 384 14 30 0 1

Kroondal 7 30 609 19 22 0 4

Figure 5-14: Simulated annual average SO2 concentrations due to Main Stack and ACP stack operating at

1 200 mg/Nm³ and all other sources at the current emission rates

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Figure 5-15: Simulated 99th percentile daily SO2 concentrations due to Main Stack and ACP stack operating

at 1 200 mg/Nm³ and all other sources at the current emission rates

Figure 5-16: Simulated 99th percentile hourly SO2 concentrations due to Main Stack and ACP stack

operating at 1 200 mg/Nm³ and all other sources at the current emission rates

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Simulated PM10 Concentrations

Simulated incremental ground-level annual and daily PM10 concentrations due to current operations (2015 to 2017

average emission rates) are shown in Figure 5-17 and Figure 5-18. Simulated concentrations at identified sensitive

receptor locations are shown in Table 5-11.

Simulated incremental annual and daily PM10 concentrations due to current operations at WSC are in compliance

for all areas outside the property boundary, including at sensitive receptor locations. Cumulative PM10 impacts

were not assessed as baseline PM10 concentrations in the study area are already in exceedance of the SA NAAQS

at nearly all sampling locations (as described in Section 5.3) Simulated off-site concentrations are at a maximum

on the slopes of the Magaliesberg mountains in the south and west of Rustenburg, but incremental impacts at

these locations are well below the SA NAAQS.

Based on the low simulated incremental PM10 concentrations at sensitive receptor locations, it can be concluded

that PM2.5 concentrations at all sensitive receptor locations will be similarly low.

Table 5-11: Simulated PM10 concentration at discreet receptor locations – current operations.

PM10 Current Scenario

Annual Average (µg/m³) 99th Percentile Daily (µg/m³)

Bergsig AQMS 2.3 19.2

Brakspruit AQMS 0.8 5.3

Hexriver AQMS 1.0 6.8

Klipfontein AQMS 0.5 5.3

Mfidikwe AQMS 1.3 7.8

Paardekraal AQMS 1.2 28.3

Waterval AQMS 0.2 3.7

Wonderkop AQMS 1.5 20.5

PMR 0.4 3.3

RBMR 3.0 13.1

Nkaneng 0.8 18.6

Mfidikwe 0.6 5.6

Bokamosa 0.5 7.1

Thekwane 0.1 1.3

Entabeni 1.0 9.3

Waterkloof 0.6 3.4

Photsaneng 0.7 14.2

Boitekong 0.5 4.0

Bleskop 0.2 1.7

Klipfontein 0.6 9.4

Waterval Village 0.7 3.7

Kroondal 0.4 3.7

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Figure 5-17: Simulated annual average PM10 concentrations due to current operations

Figure 5-18: Simulated 99th percentile daily PM10 concentrations due to current operations

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Simulated NO2 Concentrations

Simulated ground-level hourly NO2 concentrations due to current operations are shown in Figure 5-19. Simulated

annual average NO2 concentrations are below 10% of the SA NAAQS, isopleth plots for annual average NO2 is

therefore not presented. All NOx was conservatively assumed to be NO2 as recommended by the Regulations

Regarding Dispersion Modelling. Simulated concentrations at identified sensitive receptor locations are shown in

Table 5-12.

Simulated incremental annual and hourly NO2 concentrations due to current operations at WSC are in compliance

at all areas outside the property boundary, including sensitive receptor locations. Ambient NO2 concentrations in

the study area are not currently measured, so only incremental impacts from the WSC operations are shown.

Simulated off-site concentrations are at a maximum on the slope of the Magaliesberg mountains in the south and

west of Rustenburg, but concentrations at these locations are well below the SA NAAQS.

Table 5-12: Simulated NO2 concentration at discreet receptor locations – current operations.

NO2 Current Scenario

Annual Average (µg/m³) 99th Percentile Hourly (µg/m³)

Bergsig AQMS 0.8 22.0

Brakspruit AQMS 0.3 6.1

Hexriver AQMS 0.3 7.3

Klipfontein AQMS 0.1 2.4

Mfidikwe AQMS 0.4 5.3

Paardekraal AQMS 0.3 0.8

Waterval AQMS 0.1 0.5

Wonderkop AQMS 0.4 2.2

PMR 0.2 3.0

RBMR 1.1 10.6

Nkaneng 0.3 1.0

Mfidikwe 0.2 2.6

Bokamosa 0.2 2.3

Thekwane 0.0 0.7

Entabeni 0.3 5.6

Waterkloof 0.2 2.6

Photsaneng 0.2 1.0

Boitekong 0.2 4.1

Bleskop 0.1 1.7

Klipfontein 0.3 1.9

Waterval Village 0.3 4.2

Kroondal 0.1 1.5

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Figure 5-19: Simulated 99th percentile hourly NO2 concentrations due to current operations

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Comparison of Measured and Modelled Concentrations

In this section a comparison is made between measured SO2 concentrations and simulated SO2 concentrations at

the AAP monitoring stations. It should be noted that the background concentration used in this section is the

median concentration at each station from 2014 to 2017 while the background concentration used for cumulative

impacts in Section 5.4.1 is the median concentration at all stations for the period 2014 to 2017.

The comparison of annual average measured and modelled (plus background) SO2 concentrations show a good

correlation at all sampling locations, with slight over-prediction of impacts at the furthest sampling locations to the

south of the operations (Bergsig and Klipfontein). A slight under-prediction of impacts is shown at the closest

monitoring stations to the north of WSC (Mfidikwe & Paardekraal) with very good correlation at the other sampling

locations (Brakspruit, Hexrivier, Waterval and Wonderkop).

A comparison of hourly and daily measured and modelled SO2 concentrations shows that hourly 99th percentile

concentrations at the closest sampling locations (Mfidikwe, Paardekraal and Waterval) are under-predicted by the

model. Reasons for this under prediction could include short term upset conditions such as temporary high

emission rates from WSC point sources, temporary high emission rates from WSC fugitive sources or a higher

impact from other (non-WSC) sources.

Conversely, a comparison of hourly and daily measured and modelled SO2 concentrations shows that hourly and

daily 99th percentile concentrations at the furthest sampling locations (Bergsig and Wonderkop) are significantly

over-predicted. Both of these sampling locations lie on the elevated areas where high SO2 concentrations were

simulated (Figure 5-12 and Figure 5-13)

Although it can only be conclusively stated that the dispersion model is overpredicting short-term (hourly and daily)

concentrations at these two discreet locations, it is highly probable that the dispersion model is overpredicting

ambient SO2 concentrations at other elevated areas along the ridges to the east (Figure 5-12) and on the slopes

of the Magaliesberg mountains in the south and west of Rustenburg (Figure 5-13).

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Figure 5-20: Modelled vs Measured Annual Average SO2 Concentrations at the AAP Monitoring Stations

Figure 5-21: Modelled vs Measured 99th Percentile Daily SO2 Concentrations at the AAP Monitoring

Stations

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Figure 5-22: Modelled vs Measured 99th Percentile Hourly SO2 Concentrations at the AAP Monitoring

Stations.

Conclusion

Sampled annual average SO2 concentrations during the period 2014 to 2017 were in compliance with the SA

NAAQS at all eight sampling locations. Hourly and daily SO2 concentrations exceeded the SA NAAQS at the

Paardekraal sampling location during 2016 but were in compliance with the SA NAAQS during 2014, 2015 and

2017. Sampled hourly and daily SO2 concentrations were in compliance with the SA NAAQS at the other seven

sampling locations for the entire period from 2014 to 2017.

During the 2014 to 2017 sampling period, sampled annual and daily PM10 concentrations were only in compliance

with the SA NAAQS at the Bergsig monitoring station for the entire period. At each of the other sampling locations

PM10 concentrations exceeded the NAAQS on at least one of the four years in the sampling period.

Simulated annual average SO2 concentrations due the Main Stack and ACP stack operating at 3 500 mg/Nm³ and

all other sources at the current emission rates comply with the SA NAAQS for all areas outside the property

boundary. Simulated daily and hourly SO2 concentrations exceed the SA NAAQS approximately 200 m to the

south and northeast of the plant boundary (hourly and daily) as well as at the elevated areas on top of the ridges

to the east of the operations and on the slopes of the Magaliesberg mountains in the south and west of Rustenburg.

Simulated annual average, daily and hourly SO2 concentrations due the Main Stack and ACP stack operating at

1 200 mg/Nm³ and all other sources at the current emission rates are in compliance with the SA NAAQS for all

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Report No.: 18AAP01 45

areas outside the property boundary except at the tailings storage facility directly (for approximately 200 m) to the

north west of the property boundary.

In conclusion, operation of the Main Stack and ACP stack at the Existing Plant MES of 3 500 mg/Nm³ will not result

in a discernible change in ambient SO2 concentrations at sensitive receptor locations, which ambient monitoring

results indicate is currently in compliance with the SA NAAQS.

Analysis of Emissions’ Impact on the Environment

There are no major water bodies in the zone of impact of the WSC operations, and neither is the pollutant

concentrations, which are in compliance with the SA NAAQS for most areas outside the property boundary, likely

to have a significant impact on soil quality. The impact of air pollutants on receptors other than humans were

assessed against the SA NAAQS (see Section 5.4). A literature survey (Section 5.5.1) indicates that most non-

human receptors are less susceptible to ambient SO2 and PM10 concentrations than human receptors and therefore

the SA NAAQS can be used as screening for these pollutants.

Effects of Particulate Matter on Animals

As presented by the Canadian Environmental Protection Agency (CEPA, 1998) experimental studies using animals

have not provided convincing evidence of particle toxicity at ambient levels. Acute exposures (4-6 hour single

exposures) of laboratory animals to a variety of types of particles, almost always at concentrations well above

those occurring in the environment have been shown to cause decreases in lung function, changes in airway

defence mechanisms and increased mortality rates.

The epidemiological finding of an association between 24-hour ambient particle levels below 100 µg/m3 and

mortality has not been substantiated by animal studies as far as PM10 and PM2.5 are concerned. With the exception

of ultrafine particles (0.1 µm), none of the other particle types and sizes used in animal inhalation studies cause

such acute dramatic effects, including high mortality at ambient concentrations. The lowest concentration of PM2.5

reported that caused acute death in rats with acute pulmonary inflammation or chronic bronchitis was 250 g/m3

(3 days, 6 hr/day), using continuous exposure to concentrated ambient particles.

Effects of SO2 on Plants and Animals

Experimental studies on animals have shown the acute inhalation of SO2 produces bronchioconstriction, increases

respiratory flow resistance, increases mucus production and has been shown to reduce abilities to resist bacterial

infection in mice (Costa and Amdur, 1996). Short exposures to low concentrations of SO2 (~2.6 mg/m³) have been

shown to have immediate physiological response without resulting in significant or permanent damage. In rabbits,

acute exposures (16 mg/m³ for 4 hours) to SO2 gas was irritating to the eyes and resulted in conjunctivitis, infection

and lacrimation (Von Burg, 1995). Short exposures (<30 min) to concentrations of 26 mg/m³ produced more

significant respiratory changes in cats but were usually completely reversible once exposure had ceased (Corn et

al., 1972).

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Sulfur dioxide can produce mild bronchial constriction, changes in metabolism and irritation of the respiratory tract

and eyes in cattle (Blood and Radostits, 1989 as cited in Coppock and Nostrum, 1997). An increase in airway

resistance was reported in sensitized sheep after four hours of exposure to 13 mg/m³. Studies report chronic

exposure can affect mucus secretions and result in respiratory damage similar to chronic bronchitis. These effects

were reported at concentrations above typical ambient concentrations (26-1 053 mg/m³) (Dalhamn, 1956 as cited

in Amdur, 1978).

Application of sulfur (no concentrations specified) to crops can reduce plant uptake of selenium (an essential

nutrient for livestock), deposition of sulfur dioxide might therefore also affect the selenium content of forage plants

(Khan et al., 1997).

Exposure to air pollutants is expected to result in similar adverse effects in wildlife as in laboratory and domestic

animals (Newman, 1979).

Dust Effects on Vegetation

Suspended particulate matter can produce a wide variety of effects on the physiology of vegetation that in many

cases depend on the chemical composition of the particle. Heavy metals and other toxic particles have been

shown to cause damage and death of some species as a result of both the phytotoxicity and the abrasive action

during turbulent deposition (Harmens et al., 2005). Heavy loads of particle can also result in reduced light

transmission to the chloroplasts and the occlusion of stomata (Harmens et al., 2005; Naidoo and Chirkoot, 2004,

Hirano et al., 1995, Ricks and Williams, 1974), decreasing the efficiency of gaseous exchange (Harmens et al.,

2005; Naidoo and Chirkoot, 2004, Ernst, 1981) and hence water loss (Harmens et al., 2005). Particulates may

also disrupt other physiological processes such as bud break, pollination and light absorption/reflectance (Harmens

et al., 2005). The chemical composition of the dust particles can also affect the plant and have indirect effects on

the soil pH (Spencer, 2001).

Naidoo and Chirkoot conducted a study during the period October 2001 to April 2002 to investigate the effects of

coal dust on Mangroves in the Richards Bay harbour. The investigation was conducted at two sites where 10 trees

of the Mangrove species (Avicennia marina) were selected and mature, fully expose, sun leaves tagged as being

covered or uncovered with coal dust. From the study it was concluded that coal dust significantly reduced

photosynthesis of upper and lower leaf surfaces. The reduced photosynthetic performance was expected to

reduce growth and productivity. In addition, trees in close proximity to the coal stockpiles were in poorer health

than those further away. Coal dust particles, which are composed predominantly of carbon, were not toxic to the

leaves; neither did they occlude stomata as they were larger than fully open stomatal apertures (Naidoo and

Chirkoot, 2004).

In general, according to the Canadian Environmental Protection Agency (CEPA), air pollution adversely affects

plants in one of two ways; either the quantity of output or yield is reduced, or the quality of the product is lowered.

The former (invisible) injury results from pollutant impacts on plant physiological or biochemical processes and can

lead to significant loss of growth or yield in nutritional quality (e.g. protein content). The latter (visible) may take

the form of discolouration of the leaf surface caused by internal cellular damage. Such injury can reduce the

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Report No.: 18AAP01 47

market value of agricultural crops for which visual appearance is important (e.g. lettuce and spinach). Visible injury

tends to be associated with acute exposures at high pollutant concentrations whilst invisible injury is generally a

consequence of chronic exposures to moderately elevated pollutant concentrations. However, given the limited

information available, specifically the lack of quantitative dose-effect information, it is not possible to define a

Reference Level for vegetation and particulate matter (CEPA, 1998).

While there is little direct evidence of what the impact of dust fall on vegetation is under an African context, a review

of European studies has shown the potential for reduced growth and photosynthetic activity in Sunflower and

Cotton plants exposed to dust fall rates greater than 400 mg/m²/day (Farmer, 1991).

COMPLAINTS

A complaints register is in place at the WSC operations. A summary of complaints received during the last two

years is given in Table 6-1.

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Table 6-1: Complaints received during 2017 and 2018

Complaint type

Name Date Time Complain description Plant conditions Findings Future recommendations

Ext

erna

l

Nav

a N

arai

d

30-J

an-1

7

02:0

6 pm

ACP was informed by Nava Narain (acting social performance manager), regarding a Community Engagement Meeting (CEF) which was held on 2/02/2017 with the local community leadership. The following concerns were raised by the leadership • Gas emissions at ACP – Leadership indicated that Monday evening there were emission from the ACP plant during the night that was suffocating. They stated that as Anglo we committed to reducing these emissions, putting up extra monitoring systems etc. and we have done nothing. They further highlighted that when it is cloudy and raining the emissions are more evident. • They enquired about the vendor that has been sourced to put up the dust monitoring buckets and would like his details be presented at the meeting since we have indicated he is local and from cluster one.

30 Jan 2017 @ 16:00: Contact plant online. Tower plant re-started at 16:21 after a stoppage due to high temperature in NOx absorber 30 Jan 2017 @ 17:00: Contact plant online. Tower plant emissions high due to start up 30 Jan 2017 @ 18:00: Contact plant online. Tower plant emissions high due to start up 30 Jan 2017 @ 19:00: Contact plant online. Tower plant emissions high due to start up 30 Jan 2017 @ 20:00: Contact plant online. Tower plant emissions high due to start up 30 Jan 2017 @ 21:00 to 00:00: Both contact and Tower plant running

Summary of the results: • The Air Emission Licence (AEL) daily average limit of 3500mg/Nm3 was not exceeded at the Main stack and the Acid plant stacks • There were no hourly exceedances recorded at the Mfidikwe ambient stations during the time of the complaint • The hourly emissions show that the AEL limit was not exceeded. • The wind was not blowing from Waterval Smelter Complex towards Mfidikwe

In the event of emissions being experienced, the Environmental Hotline must be called

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Complaint type

Name Date Time Complain description Plant conditions Findings Future recommendations

Inte

rnal

RB

MR

21-F

eb-1

7

16:4

5

On 22 February 2017and 27 February 2017 respectively, the ACP Environmental officer received e-mails from the Environmental Manager Process and the SHE Manager Western Limb Region, communicating the notification which went out to RBMR employees on 22 February 2017 and requested if ACP has any indication of this incident from the ACP data. The RBMR Notification details were as follow: Date: 21 February 2017 Time: 16:45 Location: RBMR Involved: L&P and E&S employees Impact: None Description: On the 21st of February 2017 at approximately 16:46 pm, a suspected SO2 blow-over from an outside source occurred across RBMR. The fire alarm was activated and all employees evacuated to the tea rooms, control rooms and offices at L&P and E&S. Outside sources were notified of the SO2 levels being recorded. Once the atmospheric SO2 levels were below the OEL (Occupational Exposure Level) of 2ppm, employees were returned to work. Comment: An investigation is underway to determine the source of the SO2 emissions.

• The Acid plant experienced blower and preheater trips that resulted in various start-ups on 21 February 2017 between 14:52 and 17:00 which resulted in emissions from the Acid plant stack. These trips were primarily due to a faulty solenoid valve on the preheater that kept cutting power to the acid plant blower. Waterval Smelter was running stable for the period in question and did not contribute to the incident reported

Summary of findings: • The prevailing climatic conditions and wind direction would have contributed to these emissions being detected at RBMR; • The Air Emission Licence (AEL) daily average limit of 3500mg/Nm3 was not exceeded at the Acid plant stack • The Air Emission Licence (AEL) hourly average limit of 3500mg/Nm3 was exceeded at the Acid plant stack at 16:00, 17:00, 18:00 and 19:00. • The Waterval ambient station experienced 3 hourly exceedances of the hourly standard (350µg/m3) at 18:00, 19:00 and 20:00

Way forward ACP management operate within the Atmospheric Emission license in terms of the National Air quality Act and we have short and long term action plans to reduce our emissions. ACP management is committed to operate the complex as stable and drive a continuous improvement culture and systems. We have also started the implementation of the Operating model and see many opportunities to improve equipment availability and reliability. We are busy with an investigation to see what other operations around the world do that is situated so close to communities/Operations to improve as best as practical possible. These startups were communicated with the BMR control room and regular feedback was provided until the emissions subsided as per our agreement.

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Report No.: 18AAP01 50

Complaint type

Name Date Time Complain description Plant conditions Findings Future recommendations

Ext

erna

l

Eric

a W

enho

ld

05-M

ay-1

7

11:0

0

Marietjie Schoeman received a call from Nishi informing me that Erica Wenhold called Vinesh related to emissions which she is concerned about and requested me to call Erica to get more information. I called her this morning. She explained that she noticed the notification in the Herald. Note, the notification is related to the FCE 2 shut (4 Feb 2017 to 20 May 2017) and ACP (6 Feb 2017 and 14 Feb 2017). It also mentions that intermitted visible emissions may occur during this period. She further mentioned she noticed ongoing emissions at the main stack for the past few weeks and also at some smaller stacks. She also had a meeting yesterday with members of Kroondal and they complain of sinus problems, coughing and burning eyes. I told her that we will investigate which includes our stack emissions, where she requested information from ambient stations as well as a comparison. I told her as soon as all information is ready, approved and signed off, we will give her feedback. She agreed and was pleased with the discussion

The Tower plant was offline most of the time with the contact plant which stopped and started on 21 April 2017. The Converter stopped feeding from 03:30am on the 4/04/2017 until 6:00am on the 05/04/2017

Based on the information provided on stack and ambient monitoring data, the following can be concluded: • The prevailing wind direction from 14 April 2017 to 4 May 2017 was from a Southerly direction, not blowing from Waterval Smelter Complex towards Kroondal. • There were no exceedances recorded at the Waterval ambient station at any given time. • It is therefore unlikely that the symptoms experienced by Kroondal residents could have been caused by emissions from Waterval Smelter Complex.

• In the event of symptoms suspected to be caused by emissions are experienced, the Environmental Hotline can be called on 083 455 3165 • All complaints need to be reported immediately to avoid a delay in the investigations and accurate collation of data. • Waterval Smelter Complex will continue to communicate with stakeholders in events of possible emissions.

CO

MP

LA

INT

TY

PE

NA

ME

,

SU

RN

AM

E

DA

TE

TIM

E

COMPLAIN DESCRIPTION Plant conditions Findings Future recommendations

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Complaint type

Name Date Time Complain description Plant conditions Findings Future recommendations

Ext

erna

l

E. W

enho

ld

27-F

eb-1

8

10:3

1

A complaint was raised by Erika Wenhold telephonically on 27 February 2018 as follow: • Me Wenhold mentioned that she received complaints from 2 individuals from Kroondal who complained about an acidic taste as well as respiratory irritation. She is however not sure of the exact date, but it was during the previous week. • She mentioned that she observed emissions from the main stack on Friday, 23 February 2018. • She mentioned that she and her husband experienced acidic taste for most of the day (26 February 2018).

• Waterval Smelter complex undertook planned maintenance of the Slag Cleaning Furnace from 1 to 28 February 2018, as well as ACP from 5 to 12 February 2018. Communication that as a result of the shutdown and ramp up activities, intermittent visible emissions may occur at the complex during this time, was sent to the Bojanala Platinum District on 24 January 2018 as well as to relevant stakeholders as per text message on 9 February 2018

Based on the information provided on stack and ambient monitoring data, the following can be concluded: • The prevailing wind direction from 19 to 26 February 2018 was from a South-easterly direction, not blowing from Waterval Smelter Complex towards the direction of Kroondal. • There were instances as indicated in table 2 where the wind was blowing in a Northerly direction (from Waterval Smelter Complex towards the direction of Kroondal). • There were no exceedances recorded at the Waterval ambient station at any given time. • It is therefore unlikely that the symptoms experienced by Kroondal residents could have been caused by emissions from Waterval Smelter Complex.

• In the event of symptoms suspected to be caused by emissions are experienced, the Environmental Hotline can be called on 083 455 3165 • All complaints need to be reported immediately to avoid a delay in the investigations and accurate collation of data. • Waterval Smelter Complex will continue to communicate with stakeholders in events of possible emissions.

Ext

erna

l

Chr

is d

e B

ruyn

12-A

pr-1

8

13:0

0

Received a phone call from Chris de Bruyn related to visible emissions from Waterval smelter and ACP on 12 April 2018 at about 13:00. I informed him I will get information on the reasons for emissions and give him feedback. He did not require formal feedback, only sms response.

Feedback was given to Chris de Bruyn the same day as follow: WVS: We had minor blowbacks and puffing around FD2. ACP: No2 at the Acid plant was a bit high but since then the stack has subsided. Reasons was due to Dc061 switched off on auto then DC062 switched off also preparing to flush. No formal response was requested by C. d Bruyn

N/A N/A

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Complaint type

Name Date Time Complain description Plant conditions Findings Future recommendations

Inte

rnal

PM

R

12 -

13

Apr

il

18

15:0

0

A complaint was raised by Mr. Agit Singh which relates to an SO2 incident which occurred at PMR in the evening of the 12th of April and the morning of 13 April 2019. It was reported to Mr. Bart Pieterse.

Feedback was given to PMR on 31 May 2018

N/A N/A E

xter

nal

Mfid

ikw

e

Sch

ool

Prin

cipl

e

23-M

ay-1

8

09:0

0

A complaint was received by Mfidikwe Primary School Principal regarding gas emissions. Feedback was given to him telephonically that there was a process upset condition which they are busy resolving.

Upset condition N/A N/A

Ext

erna

l

Vel

i Kho

za

23-M

ay-1

8

09:0

0

A complaint was received via the Social department of emissions at Mfidikwe / Bokomotso.

• On the 23rd of May 2018 at approximately 8h00 ACP experienced process upset conditions which lead to emissions. • The team immediately engaged in troubleshoot to identify the cause of the process upset, the trouble shooting identified a slight increase in the SO2 strength to the SO2 abatement as the cause of the emissions. • The response from the team was to immediately reduce the feed rate and to introduce additional oxygen at the acid to convert the additional SO2 to SO3 and sulfuric. • These Interventions were successful, and the emissions back down to normal at 9h10.

Based on the information provided on stack and ambient monitoring, it can be concluded that the visible emission from ACP occurred and only endured for a short duration, but it was immediately addressed and rectified.

• In the event of symptoms suspected to be caused by emissions are experienced, the Environmental Hotline can be called on 083 455 3165 • All complaints need to be reported immediately to avoid a delay in the investigations and accurate collation of data. • Waterval Smelter Complex will continue to communicate with stakeholders in events of possible emissions.

Inte

rnal

RB

MR

01-A

ug-1

8

20:0

0 -

21:0

0

Received an e-mail from Robert Black (metallurgist at RBMR) related to a spike in SO2 which they picked up at their fence line and requested ACP to check whether we had emissions which may have caused the spike on 1 August between 20:00 and 21:00

Fence line station: It indicates: • No SO2 exceedences picked up during this time • The wind direction is prevailing from a Southerly direction (away from RBMR) Ambient stations: No exceedances recorded at any of the 8 stations

N/A N/A

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Complaint type

Name Date Time Complain description Plant conditions Findings Future recommendations

Ext

erna

l

Eric

a W

enho

ld

29-S

ep-1

8

Ear

ly e

veni

ng

A complaint was raised by Me. Erika Wenhold telephonically on 1 October 2018. Me Wenhold mentioned that she received a complaint from one of the community members of Kroondal of an acidic smell on 29 September 2018 during the early hours of the evening while the person was jogging.

ACP have undergone planned maintenance at ACP Tower plant to improve operational availability for the duration from 26 September 2018 to 09 October 2018. Due to the shutdown and start up activities, intermittent visible emissions may have occurred at the Waterval Smelter Metallurgical Complex during this period.

N/A N/A E

xter

nal

Mfid

ikw

e / B

okom

oso

coun

sello

r

07-1

0-20

18

20:4

0 A complaint was raised via the Social department, Mr. Thabo Sibiya regarding an SMS received from the Ward Councillor of Mfidikwe and Bokamoso about alleged Emissions exceedance on 07 October 2018 at 20:40.

ACP have undergone planned maintenance at ACP Tower plant to improve operational availability for the duration from 26 September 2018 to 09 October 2018. Due to the shutdown and start up activities, intermittent visible emissions may have occurred at the Waterval Smelter Metallurgical Complex during this period.

N/A N/A

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CURRENT OR PLANNED AIR QUALITY MANAGEMENT INTERVENTIONS

The Waterval ACP SO2 Abatement Project was completed in 2002 at a total cost (at the time) of R1.3bn. The ACP

technology incorporated one sealed converter to replace six Pierce-Smith converters and two new acid plants

(Tower Plant coupled with Contact Plant). The ACP has been successful in reducing SO2 emissions from more

than 200 tonnes/day to less than 20 tonnes/day currently.

RPM is in the process of investigating abatement options to further mitigate Sulphur Dioxide (SO2) emissions to

comply with the New Plant MES. This investigation is necessary as it evaluates the impact of the Bafokeng

Rasimone Platinum Mine and Mogalakwena Mine concentrate, both of which have a high sulphur content, to be

processed at the WSC. In addition, it is necessary for RPM to evaluate the impact of potential start/stop activities

of the acid plant on the 2020 MES limits. Several solutions are being investigated for mitigating the start / stop

activities, which potentially include improved gas and acid pre-heaters, use of different catalyst types, acid storage

buffer and tail gas scrubbing. The evaluation of the different potential solutions is still underway. Specific solutions

are still being evaluated to address the potential impact of the different feedstock types, however, it is envisaged

that addressing the start/stop activities may largely ensure compliance to the New Plant MES limits.

The additional abatement options are expected to be completed and fully ramped up by December 2023,

consequently, RPM wishes to apply for postponement, until December 2023, of the New Plant MES (2020

Postponement Application), whilst it considers the outcome of the investigation and evaluation referred to above

as well as the installation of appropriate abatement technology.

COMPLIANCE AND ENFORCEMENT HISTORY

No air quality compliance or enforcement actions were undertaken against the WSC in the last five years.

ADDITIONAL INFORMATION

Additional information is provided in the following Annexures.

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ANNEXURE A – DECLARATION OF ACCURACY OF INFORMATION

DECLARATION OF ACCURACY OF INFORMATION – APPLICANT

Name of Enterprise:

Declaration of accuracy of information provided:

Atmospheric Impact Report in terms of section 30 of the Act.

I, [duly authorised], declare that the information provided in

this atmospheric impact report is, to the best of my knowledge, in all respects factually true and correct. I am

aware that the supply of false or misleading information to an air quality officer is a criminal offence in terms of

section 51(1)(g) of this Act.

Signed at on this day of

SIGNATURE

CAPACITY OF SIGNATORY

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ANNEXURE B – DECLARATION OF INDEPENDENCE

DECLARATION OF INDEPENDENCE - PRACTITIONER

Name of Practitioner: Name of Registration Body: Professional Registration No.:

Declaration of independence and accuracy of information provided:

Atmospheric Impact Report in terms of section 30 of the Act.

I, , declare that I am independent of the applicant. I have the

necessary expertise to conduct the assessments required for the report and will perform the work relating the

application in an objective manner, even if this results in views and findings that are not favourable to the applicant.

I will disclose to the applicant and the air quality officer all material information in my possession that reasonably

has or may have the potential of influencing any decision to be taken with respect to the application by the air

quality officer. The information provided in this atmospheric impact report is, to the best of my knowledge, in all

respects factually true and correct. I am aware that the supply of false or misleading information to an air quality

officer is a criminal offence in terms of section 51(1)(g) of this Act.

Signed at on this day of

SIGNATURE

CAPACITY OF SIGNATORY

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ANNEXURE C – INFORMATION REQUIRED IN THE AIR DISPERSION MODELLING REPORT AS

PER CODE OF CONDUCT (DEA, 2014)

Chapter 1: Facility and modellers’ information Submitted Comments, References Yes / No

1.1 Project identification information requirements

Applicant Yes Section 1.1

Facility identification Yes Section 1.1

Physical address of facility Yes Section 1.2

Air Emissions License reference number (if applicable) Yes Section 1.4

Environmental authorization reference number (if applicable) No

Modelling contractor(s), when applicable Yes Report Details

1.2 Project background requirements

Purpose(s) and objectives of the air dispersion modelling under consideration Yes Preface

General descriptive narrative of the plant processes and proposed new source or modification Yes Section 2.2

1.3 Project location requirements

1.3.1 Detailed scaled layout plan of proposed project area including the following: Yes Section 2.1

UTM coordinates of facility Yes Section 2.1

Property lines, including fence lines Yes Section 2.1

Roads and railroads that pass through property line Yes Section 2.1

Location and dimensions of buildings and/or structures (on or off property) which could cause downwash Yes Section 4.3

Location Yes Section 4.3

Length Yes Section 4.3

Width Yes Section 4.3

Height Yes Section 4.3

Indication of shortest distance to property line from significant sources Yes Section 5.4

1.3.2 Area map(s) that include the following: Section 1.2

Map of adjacent area (10 km radius from proposed source) indicating the following Yes Figure 1-1

Latitude/Longitude on horizontal and vertical axis Yes Figure 1-1

Nearby known pollution sources Yes Figure 1-2

Schools and hospitals within 10km of facility boundary Yes Section 1.3

Topographic features Yes Figure 1-1

Any proposed off-site or on-site meteorological monitoring stations Yes Figure 1-1

Road and railroad Yes Figure 2-1

Regional map that includes the following Yes Figure 1-2

UTM coordinates Yes Figure 1-2

Modelled Facility Yes Figure 1-2

Topography features within 50 km Yes Figure 1-2

Known pollution sources within 50 km None Figure 1-2

Any proposed off-site meteorological monitoring stations Yes Figure 1-1

1.4 Geophysical data

Discuss land use characterization procedures utilized to determine dispersion coefficients (urban or rural) Yes Section 5.1.3.2

Discuss the elevation data (DEM) and its resolution Yes Section 5.1.3.2

1.5 Elevation data (DEM) and resolution

Discuss DEM data utilized Yes Section 5.1.3.2

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Chapter 1: Facility and modellers’ information Submitted Comments, References Yes / No

Chapter 2: Emissions characterisation

Submitted Comments, References Yes / No

2.1 Emissions characteristics

Include fugitive and secondary emissions when applicable Yes Section 4.3

Emissions unit descriptions and capacities (including proposed emission controls) Yes Section 4.3

New structure or modification to existing structures as a result of the project Yes Section 4.3

2.2 Operating scenarios for emission units

Operation conditions simulated in the modelling study Yes Section 4.2

Normal Yes Section 4.2

Start-up Yes Section 4.2

Standby Yes Section 4.2

Shutdown Yes Section 4.2

2.3 Proposed emissions and source parameter table (s)

List all identifiable emissions Yes Section 4

Include parameter table (s) for each operating scenario of each emissions unit, which may include, but not limited to the following: Yes

Section 4.1, 4.2 and 4.3

Operating scenario(s) Yes Section 4.1

Source location (UTM Coordinates) Yes Section 4.1 and 4.3

Point source parameters Yes Section 4.1 and 4.2

Area source parameters Yes Section 4.3

Volume source parameters Yes Section 4.3

Include proposed emissions (and supporting calculations) for all identifiable emissions Yes Section 4

Chapter 3: Meteorological data

Submitted Comments, References Yes / No

3.1 Surface data discussions must include:

Off-site Yes Section 5.2

Source of data Yes Section 5.2

Description of station (location, tower height, etc) No MM5 Data

Period of record Yes Section 5.2

Demonstrate temporal and spatial representativeness Yes Section 5.2

Seasonal wind-rose(s) Yes Figure 5-2

3 year of representative off-site data Yes Section 5.2

Evaluate if off-site data complies with regulatory Code of Practice Yes Section 5.2

Program and version used to process data Yes Table 5-1

Method used to replace missing hours No No missing hours in MM5 data set

Method used to handle calm periods No On-site

Description of station (location, tower height, etc.) Yes Section 5.2

Period of record Yes Section 5.2

Demonstrate spatial representativeness No Station located on-site

Minimum 1-year of representative on-site data Yes

Evaluate if off-site data complies with regulatory Code of Practice Yes Yes recommended by Code of Practice

Program and version used to process data Yes Section 5.1.1.

Method use to replace missing hours Yes No missing hours in

MM5 data

Method used to handle calm periods No

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Chapter 1: Facility and modellers’ information Submitted Comments, References Yes / No

3.2 Discuss upper air data utilised

Discuss upper air data utilised from the most representative station No On-site MM5 data

used

Explain why it is “most representative” No On-site MM5 data

used

Chapter 4: Ambient impact analysis and ambient levels

Submitted Comments, References Yes / No

4.1 Standards Levels

National Ambient Air Quality Standards Yes Section 5.1.2.2

4.2 Background Concentrations

Specify background values used including supporting documentation Yes Section 5.3

Chapter 5: Modelling Procedures

Submitted Comments, References Yes / No

5.1 Model used in the study

Assessment level proposed and justification Yes Section 5.1.1.

Dispersion model used Yes Section 5.1.1

Supporting models and input programs Yes Table 5-1

Version of models and input programs Yes Table 5-1

5.2 Specify modelled emissions

Pollutants Yes Section 4

Scenarios and emissions that were modelled Yes Section 5.4

Conversion factor utilized for converting NO to NO2 None All NOx conservatively assumed to be NO2 as per Code of Conduct

5.3 Specify setting utilized within the model(s), which may include:

Recommended settings utilized within model Yes

Terrain settings (simple flat / simple elevated / complex) Yes Complex Terrain

Land characteristics (Bowen ratio, surface albedo, surface roughness) Yes Section 5.1.1

Specify assumptions (if applicable)

Include discussion of non-regulatory settings utilized and reasons why

No No non-regulatory settings utilized

5.4 Describe the receptors grids utilized within the analysis

Property line resolution Yes Section 5.1.3.3

Fine grid resolution Yes Section 5.1.3.3

Medium grid resolution(s) Same as

fine grid Section 5.1.3.3

Course grid resolution Same as

fine grid Section 5.1.3.3

Hotspots and sensitive location resolutions and sizes None Sensitive receptors modelled as discreet receptors

Figures that show locations of receptors relative to modelled facility and terrain features Yes Figure 1-1

Chapter 6: Ambient impact results documentation

Submitted Comments, References Yes / No

6 At a minimum, the Ambient Air Quality Standards results are to be documented as follows:

6.1 Table(s) of modelling results including Yes Section 5.4

Pollutant Yes Section 5.4

Averaging time Yes Section 5.4

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Chapter 1: Facility and modellers’ information Submitted Comments, References Yes / No

Operating scenario Yes Section 5.4

Maximum modelled concentration Yes Section 5.4

Receptor location of maximum impact (coordinates) Yes Section 5.4

Receptor elevation Yes Section 5.4

Date of maximum impact No Time series not modelled

Grid resolution at maximum impact Yes Section 5.4

Name of output e-file(s) where cumulative impact See next

section

6.2 Figure(s) showing source impact area including

1. UTM coordinates on horizontal and vertical axis Yes

2. Modelled facility Yes

Boundary Yes

Buildings No Shown on Figure 2-1

Emission points Yes

3. Topography features No Shown on Figure 1-2

4. Isopleths of impact concentrations Yes

5. Location and value of maximum impact Yes

6. Location and value of maximum cumulative impact Yes

Chapter 7: Ambient supporting documentation

Submitted Comments, References Yes / No

7.1 All warning and informational messages within modelling output files must be explained and evaluated

7.2 Required electronic files to be submitted with report

1. Input & output files for models Yes All model and pre and post processor input files included. Output files are available on request.

2. Input & output files for pre-processors Yes

3. Input & output files for post-processors Yes

4. Digital terrain files Yes

5. Plot files Yes Included in Section

5.4

6. Final report Yes

7.3 Report shall include a list and description of electronic files Yes Annexure F

7.4 Report shall include a discussion on deviations from the modelling protocol Yes

Deviations discussed in relative sections.

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ANNEXURE D – REFERENCES

Amdur, MO (1978) Effects of Sulfur Oxides on Animals. Sulphur in the Environment. Part II: Environmental

Impacts. John Wiley and Sons, Toronto. pp 61-74.

Carslaw, D.C. and K. Ropkins, (2012). openair — an R package for air quality data analysis. Environmental

Modelling & Software. Volume 27-28, 52-61.

Carslaw, D.C. (2013). The openair manual — open-source tools for analysing air pollution data. Manual for version

0.8-0, King’s College London.

CEPA/FPAC Working Group (1998). National Ambient Air Quality Objectives for Particulate Matter. Part 1:

Science Assessment Document, A Report by the Canadian Environmental Protection Agency (CEPA) Federal-

Provincial Advisory Committee (FPAC) on Air Quality Objectives and Guidelines.

Coppock, RW and Nostrum MS, (1997) Toxicology of oilfiend pollutants in cattle and other species. Alberta

Research Council, ARCV97-R2, Vegreville, Alberta pp 45-114.

Corn M, Kotsko N, Stanton D, Bell W, Thomas AP (1972). Response of Cats to Inhaled Mixtures of SO2 and

SO2-NaCl Aerosol in Air. Arch. Environ. Health, 24:248-256.

Costa, DL and MO Amdur. (1996) Air Pollution. In: Klaasen, CD, Amdur, MO, Doull, J (eds) Casarett and Doull’s

Toxicology. The Basic Science of Poisons. 5th ed. pp 857-882

DEA (2014) National Environmental Management: Air Quality Act, 2004 (ACT no 39 of 2004): Regulations

regarding air dispersion modelling. Government Gazette 589 of 2014).

Ernst WHO (1981). Monitoring of particulate pollutants. In: Steubing, L., Jager, H.-J. (Eds.), Monitoring of Air

Pollutants by Plants: Methods and Problems, 1981. (Eds.), Proceedings of the International Workshop, Osnabriick

(F.R.G.), September 24–25. Dr W Junk Publishers, The Hague.

Harmens H, Mills G, Hayes F, Williams P and De Temmerman L (2005), Air Pollution and Vegetation. The

International Cooperative Programme on Effects of Air Pollution on Natural Vegetation and Crops Annual Report

2004/2005.

Hirano T, Kiyota M, and Aiga I (1995). Physical effects of dust on leaf physiology of cucumber and kidney bean

plants. Environmental Pollution 89, 255–261.

Khan AA, Mostrom MS, Campbell CAJ, (1997) Sulfur-Selenium Antagonism in Ruminants. In:Chalmers, GA (ed)

A Literature Review and Discussion of the Toxicological Hazards of Oilfield Pollutants in Cattle. Alberta Research

Council, ARCV97-R2, Vergeville, Alberta. Pp 197-208

McNulty, T (1998) Developing innovative technology. Mining Engineering Weekly. Pg 50 -55

Naidoo G and Chirkoot D (2004). The effects of coal dust on photosynthetic performance of the mangrove,

Avicennia marina in Richards Bay, South Africa. Environmental Pollution 127 359–366.

Newman, JR and Schreiber (1984). Animals as Indicators of Ecosystem Responses to Air Emissions. Environ.

Mgmt., 8(4)309-324.

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Ricks, GR, and RJH Williams (1974) “Effects of atmospheric pollution on deciduous woodland part 2: effects of

particulate matter upon stomatal diffusion resistance in leaves of Quercus petraes (Mattuschka) Leibl.”

Environmental Pollution, 1974: 87–109.

Scire, J.S., D.G. Strimaitis, and R.J. Yamartino. (2000). A User’s Guide for the CALPUFF Dispersion Model

(Version 5), Earth Tech, Inc. Report, Concord, MA, January 2000.

Spencer S (2001). Effects of coal dust on species composition of mosses and lichens in an arid environment. Arid

Environments 49, 843-853.

Von Burg, R (1995). Toxicological Update. J .Appl. Toxicol 16(4):365-371

US EPA, (2005). Revision to the Guideline on Air Quality Models: Adoption of a Preferred General Purpose (Flat

and Complex Terrain) Dispersion Model and Other Revisions. North Carolina, U.S. Environmental Protection

Agency, 2005. Federal Register / Vol. 70, No. 216 / Rules and Regulations. Appendix W of 40 CRF Part 51.

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ANNEXURE E – LIST OF ELECTRONIC FILES SUBMITTED WITH THE REPORT

Description Scenario Filename

AERMET All AERMET.atz

AERMOD

SO2 Existing Plant MES SO2 Existing Plant MES.ami

SO2 New Plant MES SO2 New Plant MES.ami

PM10 Current PM10.ami

NO2 Current NO2.ami

Digital Terrain Files All topo.xyz

2015 Isokinetic Sampling Report – Waterval Smelter Iso 2015.pdf

2015 Isokinetic Sampling Report – ACP Iso 2015 ACP.pdf

2016 Isokinetic Sampling Report – Waterval Smelter Iso 2017.pdf

2016 Isokinetic Sampling Report – ACP Iso 2017 ACP.pdf

2017 Isokinetic Sampling Report – Waterval Smelter Iso 2017.pdf

2017 Isokinetic Sampling Report – ACP Iso 2017 ACP.pdf