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Air Quality Management Report: July - September 2010 Sonae Novobord FINAL REPORT: 19 JANUARY 2011 WSP Environment & Energy Q3 AQ Management Report

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Page 1: Air Quality Management Report: July - September 2010 Air quality reports/100425AQ... · 2015-11-13 · conclusions drawn from the monitoring results were as follows. ... As stated

Air Quality Management Report: July - September 2010

Sonae Novobord FINAL REPORT: 19 JANUARY 2011

WSP Environment & Energy

Q3 AQ Management Report

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QUALITY MANAGEMENT

WSP Environment & Energy 3rd Floor 35 Wale Street Cape Town 8001 P.O. Box 2613 Cape Town 8000, RSA Tel +27 (0)21 481 8700 Fax +27 (0)21 481 8799 http://www.wspenvironmental.co.za Reg. No: 1995/08790/07

Issue/revision Issue 1 Revision 1 Revision 2 Revision 3

Remarks Draft 1 Draft 2 Final

Date January 2011 January 2011 January 2011

Prepared by Zelda Burchell Zelda Burchell Zelda Burchell

Signature

Checked by Andrew Simpson Andrew Simpson Andrew Simpson

Signature

Authorised by Sean Doel Andrew Simpson Andrew Simpson

Signature

Project number 100425AQ 1004255AQ 1004255AQ

File reference 100425AQ_D1 100425AQ_D2 100425AQ_Final

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CONTENTS

EXECUTIVE SUMMARY 1

1 Introduction 2

2 Regulatory Framework Air Quality 2

3 Methodology 5

4 Results and Discussion 10

5 Conclusions 20

6 References 21

Appendix A Formaldehyde Laboratory Results 22

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WSP Environment & Energy Q3 AQ Management Report 1

EXECUTIVE SUMMARY

WSP Environment and Energy is commissioned to monitor various air quality impacts around the Sonae Novobord (Pty) Ltd - White River plant. For the three month period from July to September 2010, three key pollutant parameters were monitored, namely; particulate matter (PM10), dust deposition (fallout), and formaldehyde (HCHO). The conclusions drawn from the monitoring results were as follows.

Formaldehyde

In summary, all results to date indicate Sonae is compliant with the ASTDR MRL acute and chronic exposure standards of 49.4 µg/m3 and 9.8 µg/m3 respectively. Measurement is ongoing.

Particulate Matter

The PM10 concentrations measured for this quarter on Osiris instrument Sonae 1 indicated no exceedences of the NEM:AQA limit of 120 µg/m3 over a 24-hour period. Compared to the previous quarter, the overall PM10 concentrations appear to have decreased at this ‘downwind’ fenceline position; whereas exceedences were measured at this position prior to the commissioning of the dryer. It should be noted that this is a ‘worst case’ fenceline site according to the dispersion model and previous experience, and not a reflection of the overall ambient environment.

The PM10 concentrations measured for this quarter on Osiris instruments (Sonae 2 and 3/R) indicated particulate levels were well within the latest NEM:AQA standard.

Dust Fallout

The results for Quarter 3, 2010 show full compliance, with no excedences of the SANS 1929:2005 industrial recommended limit. Site SNBAQ7 continues to record the highest rates of dust deposition. This sample point has generally provided the highest fallout rates throughout previous months, given its close proximity to the chip piles that constitute a significant source of fugitive dust.

All measurements are ongoing and conditions of the AQMP and ROD are currently being met. Sample frequency and reliability is improved over previous years.

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WSP Environment & Energy Q3 AQ Management Report 2

1 INTRODUCTION

Sonae Novobord (Pty) Ltd (hereafter referred to as Sonae Novobord) currently operates a Medium Density Fibre Board (MDF) and Particle Board (PB) production facility in White River, Mpumalanga. The wood based products are utilised by various building and wood based manufacturing industries including furniture manufacturers, kitchen manufacturers, shop fitting, coffins, DIY etc as well as niche markets.

WSP Environment and Energy was appointed to monitor various aspects of air quality in and around the White River plant. This quarterly air quality monitoring report details the results of monitoring undertaken during July to September (Quarter 3), 2010.

Three parameters were monitored during this three-month period, namely formaldehyde (vapour phase), particulate matter (PM10) and dust deposition (fallout). All three parameters were monitored in terms of the requirements of the NEMA Section 24G Environmental Management Plan (EMP, March 2009) as well as the current SA Regulatory Framework (as and where applicable).

2 REGULATORY FRAMEWORK AIR QUALITY

The new National Environmental Management: Air Quality Act 39 of 2004 (NEM:AQA), which repeals the Atmospheric Pollution Prevention Act of 1965, came into effect on 11 September 2005, with the promulgation of regulations in terms of certain sections resulting in the APPA being repealed entirely on 1 April 2010. Key features of the current legislation include:

Decentralizing air quality management responsibilities;

Requiring significant emission sources to be identified, quantified, and addressed;

Setting ambient air quality targets as goals for driving emission reductions;

Recognizing source-based (command-and-control) measures in addition to alternative measures, including market incentives and disincentives, voluntary programmes, and education and awareness;

Promoting cost-optimized mitigation and management measures;

Stipulating air quality management planning by authorities, and emission reduction and management planning by sources; and

Providing for access to information and public consultation.

The NEM:AQA introduced a management system based on ambient air quality standards and corresponding emission limits to achieve them. Two significant regulations stemming from NEM:AQA have been promulgated recently, which are:

GNR 1210 on 24 December 2009 (Government Gazette 32816) National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) National Ambient Air Quality Standards.

GNR 248 on 31 March 2010 (Government Gazette 33064) National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) List of Activities Which Result in Atmospheric Emissions Which Have or May Have a Significant Detrimental Effect on the Environment, Including Health, Social Conditions, Economic Conditions, Ecological Conditions or Cultural Heritage.

The new national ambient standards for air quality were based primarily on guidance offered by two standards set by the South African National Standards (SANS), namely:

SANS 69:2004 Framework for implementing national ambient air quality standards.

SANS 1929:2005 Ambient air quality – Limits for common pollutants.

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SANS 69:2004 makes provision for the establishment of air quality objectives for the protection of human health and the environment as a whole. Such air quality objectives include limit values, alert thresholds and target values.

SANS1929:2005 uses the provisions in SANS 69 to establish air quality objectives for the protection of human health and the environment, and stipulates that limit values are initially set to protect human health. The setting of such limit values represents the first step in a process to manage air quality and initiate a process to ultimately achieve acceptable air quality nationally. The limit values presented in this standard are intended as information to be used in air quality management but have only become enforceable as revised under GNR 1210 since 24 December 2009. National ambient air quality standards for criteria pollutants generally have specific averaging periods, compliance dates (timeframes), permissible frequencies of exceedence and reference methods.

2.1 FORMALDEHYDE

There are currently no South African Standards for assessment of ambient formaldehyde levels in ambient air. In terms of the Record of Decision dated 14 May 2009, formaldehyde is to be assessed against latest recognised international standards (ASTDR MRLs specifically) until the South African Standards are promulgated.

The ASTDR MRL for chronic (long-term) formaldehyde exposure is 9.8 µg/m3. The ASTDR acute (short-term) exposure level is 49.2 µg/m3.

Ambient formaldehyde levels are measured using passive samplers provided and analysed by accredited national (SANAS) and / or international (ISO) laboratories. It is noted that the science of formaldehyde monitoring in ambient air is subject to continuous review to ensure that monitoring methodologies are in-line with current international best practice.

2.2 PARTICULATE MATTER

With regard to the setting of limit values for particulate matter, SANS 1929:2005 recognises the following:

different types of particles can have different harmful effects on human health;

there is evidence that risks to human health associated with exposure to man-made PM10 are higher than risks associated with exposure to naturally occurring particles in ambient air; and

as far as they relate to PM10, action plans and other reduction strategies should aim to reduce concentrations of fine particles as part of the total reduction in concentrations of particulate matter.

A summary of various local (South African) and international standards for ambient PM10 concentrations are presented in Table 1 below. These values are expressed in g/m³.

Table 1: Summary of the key local and international ambient standards for PM10 Ambient Standards

NEMAAQA (2004) NEMA: AQA (2009)

SANS 1929 (2005) & Draft Revised (2009)

US EPA (NAAQS) EU (directive) WHO

PM10 180µg/m3 (24-hr); 60µg/m3 (Annual)

120µg/m3 (24-hr); 50µg/m3 (Annual)

75µg/m3 (24-hr); 40µg/m3 (Annual)

150µg/m3 (24-hr)

50µg/m3 (24-hr); 40µg/m3 (Annual)

50µg/m3 (24-hr); 20µg/m3 (Annual)

Stringent Limit and Target Values for particulate matter (expressed in g/m³) have been suggested as guidelines in SANS 1929:2005, and revised 2009. These were developed by a panel of experts on the basis of best international practice. However, the latest regulations emanating from NEM:AQA (GNR 1210) were promulgated in late 2009 and stipulate a phased approach towards the implementation of national ambient air quality standards as tabulated below (Table 2).

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Table 2: Rollout of National Ambient Air Standards for Particulate Matter (PM10)

Averaging Period Concentration Permissible Exceedences (per calendar year) Compliance Date

24-hour 180 µg/m3 4 Prior to 1st January 2010 24-hour 120 µg/m3 4 1st January 2010 – 31st December 2014 24-hour 75 µg/m3 4 01-Jan-15 Annual 60 µg/m3 0 Prior to 1st January 2010 Annual 50 µg/m3 0 1st January 2010 – 31st December 2014 Annual 40 µg/m3 0 01-Jan-15

It must be noted that from a legal standpoint, only standards promulgated under the National Environmental Management: Air Quality Act (Act 39 of 2004) are applicable during the relevant timeframes as stipulated above. In addition, the ambient air quality standards are to be used to identify priority areas which require the attention of the regulatory authorities. It needs to be stressed that the ambient air quality standard will not be used for prosecution, but as a guide for action by the relevant local authorities.

2.3 DUST DEPOSITION

Dust deposition, commonly referred to as fallout or nuisance dust, has been observed to be of concern at and around the Sonae Novobord site. SANS 1929:2005 also sets out dust deposition rates, expressed in units of mg/m2/day over a typical 30-day averaging period. Dust deposition must be evaluated against a four-band scale as presented in Table 3.

Table 3: Dust Deposition Rates (SANS 1929:2005) Band Description Label Dust Rate, D (mg/m2/day) Comment Residential D <600 Permissible for residential and light commercial. Industrial 600 < D < 1 200 Permissible for heavy commercial and industrial.

Action 1 200< D < 2 400 Requires investigation and remediation if two sequential months lie in this band, or more than three occur in a year.

Alert 2 400 > D Immediate action and remediation required following the first incidence of dust fall rate being exceeded. Incident report to be submitted to relevant authority.

As stated in the Listed Activities and Associated Emission Standards Identified in terms of Section 21 of NEM:AQA, a three-month running average must not exceed the limit value for adjacent land use according to dust fallout standards promulgated in terms of Section 32 of NEM:AQA, in principal wind directions.

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3 METHODOLOGY

3.1 FORMALDEHYDE

The passive sampling technique chosen to monitor formaldehyde (HCHO) is based on the molecular diffusion of gases. It is therefore referred to as ‘diffuse’ or ‘passive’ sampling interchangeably. Samplers are strategically positioned on site and in surrounding community areas. They are ideally positioned at a height of approximately 1.5 metres above the ground, to measure in the breathing zone. Gas molecules diffuse into the samplers, where they are quantitatively collected on an impregnated filter or absorbent material, giving a concentration value integrated over the exposure time. The duration for which the samplers are required to be exposed to the gas molecules depends on the indicator being monitored, the anticipated concentration range and the stability of the indicator in the sampling medium. The monitoring of formaldehyde required that the samplers were exposed for a period of one week only at this concentration range. This is also because of the stability of volatiles in the sampling medium.

Passive (or diffusive) sampling was chosen as the preferred choice of monitoring because of three relevant factors as described below.

Cost: passive samplers are relatively cost-effective for impact studies, as opposed to expensive continuous monitoring that should only be implemented when there is good existing knowledge of a problem and precise real-time data are required.

Geography: passive samplers, because of their reduced cost compared with continuous monitoring, allow for a geographical spread of monitoring points. Such data enable a better assessment of ambient air quality over an area, compared with continuous monitoring at one or maybe two points (limited by cost constraints or precision).

Ease of use: passive samplers do not need electricity, and because of their small size, are not seen as a likely target for vandalism and theft.

The samplers used in this survey are manufactured by RadielloTM, but are locally supplied and analysed by Chemtech Laboratory Services, as well as Eurofins Product Testing A/S. It may be noticed that historically, samplers from different suppliers have been used; this follows from the inter-laboratory comparisons that were deemed useful to provide confidence in the data (discussed in the EIA Specialist Studies). All laboratories used by WSP are SANAS and/or ISO accredited.

Formaldehyde monitoring at the plant was conducted on one occasion during the three month study. One set of twelve samplers was deployed in September. After one week of exposure, the samplers were collected and sent to the Eurofins laboratory in Denmark for analysis. In addition two co-located samplers were supplied and analysed by IVL, Sweden; deployed at sites SNF01 and SNF05 over the same exposure period.

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Figure 1: Sampling locations for formaldehyde passive samplers at the Sonae Novobord, White River facility. SNF01-SNF07 indicates fenceline sites whilst SNC03 indicates a nearby community site.

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Figure 2: Sampling locations for formaldehyde passive samplers at the Sonae Novobord, White River facility. SNF01-SNF07 indicates fenceline sites whilst SNC01-SNC06 indicates the community sampling sites (this map including more distant sites).

3.2 SUSPENDED PARTICULATE MATTER (PM10)

Particulate matter was monitored through the use of a continuous environmental air quality instrument, the OsirisTM

continuous dust monitor. The OsirisTM analyser is capable of measuring a number of size fractions simultaneously, namely TSP, PM10, PM2.5 and PM1. The instrument is also equipped with a wind monitor that allows for emissions to be correlated with wind speed and direction data, making it possible for recorded dust emissions to be traced back to the probable source of the emissions. Permanent units have been installed at three locations as stipulated in the AQMP and ROD. The third unit (Sonae 3/R) may be used as a roving unit once fenceline trends have been established.

The three locations are described as follows, with reference to the site map (Figure 1):

Sonae 1: located at map point SNF01, approximately midway on the western fenceline (‘downwind’) in the visitors car park;

Sonae 2: located at map point SNF06, on the corner of the northern and eastern fencelines (‘upwind’) in the salvage yard; and

Sonae 3/R: located at map point SNF03 on the corner of the southern and western fencelines (‘background’) adjacent to the main road intersection.

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Figure 3: The Osiris™ continuous dust analyser. Three permanent units were sited at ‘upwind’, ‘downwind’ and in the ‘background’, respectively, of the Sonae Novobord plant. The permanent installations have a metal box cover for additional protection against the weather. The sample inlet is seen protruding at the front and the wind monitor is setup above the instrument to record exact vectors prevailing during recorded dust concentrations.

3.3 DUST DEPOSITION

Sonae Novobord has implemented an ongoing monitoring program for the assessment of nuisance dust deposition. The reference method recommended by the SANS 1929:2005 is the ASTM D1739. This technique makes use of fallout gauges (dust buckets), which are essentially open containers (or cylindrical buckets), filled with water and algaecide, and left at designated sites for a stipulated timeframe to collect solid and liquid particles that are typically greater than 10 m in diameter.

Coarser dust particles that settle out under gravity were viewed as a cause of nuisance during site observations over the past few years. Dust gauges are deployed as indicated in Figure 4. The dust that deposits in the gauges would be from a number of sources. The analytical laboratory is requested to quantify the proportion of carbonaceous dust in the total dust sample as a conservative estimate of the proportion of organic (wood) to inorganic (silica) matter. To achieve this, the total dust sample is weighed and then the carbonaceous material is burned off at 500°C in the loss on ignition (LOI) test. The remaining sample is weighed to determine the non-combustible silica type dust and the difference in weight compared to the original sample indicates the approximate proportion of wood dust.

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Figure 4: Sampling positions for dust deposition gauges at the Sonae Novobord White River facility. SNBAQ01-SNBAQ08 indicates fenceline sites whilst SNBAQ09-SNBAQ11 indicates community sites.

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4 RESULTS AND DISCUSSION

4.1 METEOROLOGICAL DATA

4.1.1 Results

The fully equipped Davis VantagePro IITM weather station has been measuring various meteorological parameters continuously since the EIA Specialist Studies were conducted in 2007. This assists with interpretation of the recorded levels of all monitored pollutants and provides data for dispersion modelling. The graph below shows the daily rainfall, average temperature and relative humidity for Quarter 3, 2010.

Figure 5: Meteorological Data Quarter 3, 2010 Figure 6 and Figure 7 below depict monthly wind roses from the on-site meteorological station for July, August and September 2010, and the wind rose for the third quarter as a whole.

Figure 6: July and August 2010 wind roses compiled from the on-site meteorological station.

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Figure 7: September 2010 wind rose and that for the third quarter as a whole, compiled from the on-site meteorological station.

4.1.2 Discussion

Figure 5 displays only a small number of precipitation events from the spring monitoring; i.e. a typically dry period. The temperature increased gradually towards September and the relative humidity is typically erratic.

Figure 6 and Figure 7 depicts monthly wind roses from the on-site meteorological station for July, August and September 2010. The primary nodes remained westerly and easterly for the most part of the quarter, with stronger westerly winds. The easterly wind is the dominant wind direction for a larger part of the year, with the westerly node only being significant during the winter months.

4.2 FORMALDEHYDE

4.2.1 Results

The samplers used in the July to September 2010 surveys are manufactured by RadielloTM, and are locally supplied by Chemtech Laboratory Services. Formaldehyde samplers could only be deployed in early October 2010 as WSP were awaiting the arrival of samplers from European laboratories, which close during the Northern Hemisphere summer. Results for the October survey were analysed by Eurofins, Denmark. In addition two co-located samplers were supplied and analysed by IVL, Sweden for the following locations: SNF01 and SNF05. All passive samplers were exposed for the recommended time of seven (7) days. The results are illustrated in the figure below, together with previously recorded data for comparison. A complete table of all formaldehyde concentrations recorded to date are attached in Appendix A.

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Figure 8: Quarterly formaldehyde sample results. 4.2.2 Discussion

Results from the passive samplers indicated that formaldehyde concentrations were generally lower than recorded in the previous quarters of 2010. The measured concentrations illustrate that Sonae Novobord is compliant with the accepted ASTDR MRL acute and long-term chronic exposure international standards.

The results from the two co-located passive samplers analysed by IVL in Sweden were slightly lower than those reported by Eurofins. The results followed a similar trend of the results recorded by Eurofins, and the results were well below the ASTDR MRL acute and chronic exposure standards.

The two highest concentrations of formaldehyde were recorded at sampling points on the western fenceline of the site (SNF01 and SNF02). These sampling points have consistently recorded the highest concentrations of formaldehyde.

As discussed in the previous quarter, it was suspected that a calibration issue of the formaldehyde analyser at the Chemtech laboratories could have attributed to the elevated formaldehyde concentrations in the first quarter, as there was no other plausible explanation for increased levels. The local laboratory denied any calibration error.

In summary, Sonae is compliant with the ASTDR MRL acute and chronic exposure standards of 49.4 µg/m3 and 9.8 µg/m3 respectively. Measurement is ongoing with surveys being repeated every three months.

4.3 SUSPENDED PARTICULATE MATTER (PM10)

4.3.1 Results

The OsirisTM continuous dust monitor is capable of measuring a number of size fractions simultaneously, namely; TSP, PM10, PM2.5 and PM1. However, only the PM10 is graphed below as this is the size range for which health effects are internationally accepted and therefore used for assessment of compliance in South African national standards for ambient air.

The instruments are also equipped with wind monitors that allows for peak emissions to be correlated with wind speed and wind direction data, making it possible for recorded dust emissions to be traced back to the probable source. As described in Section 3.3, three instruments were deployed according to the stipulations of the AQMP and ROD. The available results from each of these instruments are graphed in Figure 9, Figure 10 and Figure 11 below.

The Osiris™ instruments recorded significantly more complete data than in the previous quarter. The Osiris™ instrument Sonae 1 experienced a down time in the early part of July. The Osiris™ instrument Sonae 2 experienced a

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few days down time in September, and the Osiris™ instrument Sonae 3 experienced a few days down time in the early part of July and at again towards the end of August. As mentioned previously, continuous air quality analysers are very sensitive and limited down time was caused by various technical problems which are rectified as soon as practically possible. A detailed maintenance and servicing schedule has been implemented to minimise data loss.

Figure 9: 24-hour PM10 averages from the Osiris instrument Sonae 1 located near to the car park on the western fenceline for the period from July to September 2010.

Figure 10: 24-hour PM10 averages from the Osiris instrument Sonae 2 located near to the salvage yard on the north-eastern corner of the fenceline for the period from July to September 2010.

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Figure 11: 24-hour PM10 averages from the Osiris instrument Sonae 3/R located on the south western corner fenceline near to the robot on the R40 for the period from July to September 2010. 4.3.2 Discussion

The recorded data is indicative of the conditions experienced during the normal operation of the new dryer. The PM10 data shown in all the figures above indicates a sustained period of compliance with 24-hour average PM10 levels that do not exceed the NEM:AQA limit of 120 µg/m3 over a 24-hour period.

Compared to the previous quarter, the overall PM10 concentrations appear to have decreased significantly at the ‘downwind’ fenceline position (Sonae 1). This position has been known to record the highest particulate concentrations since the surveys began, with numerous exceedences of even the old (more lenient) standard prior to the commissioning of the dryer. It should be noted that this is a ‘worst case’ fenceline site according to the dispersion model and previous experience, and not a reflection of the overall ambient environment; i.e. it is near the typically downwind peak ground-level plume concentration position as predicted by the dispersion model. As it can be seen in Figure 9, the PM10 concentrations are well below the NEM:AQA limit of 120 µg/m3 over a 24-hour period which is a significant improvement compared to previous quarters.

The decrease of PM10 concentrations at Sonae 1 and increase of PM10 concentrations at Sonae 2 are likely a result of the wind field that prevails during the winter months (refer Figure 6). During July and August, a gentle westerly wind is common which effectively means that Sonae 1 becomes ‘upwind’ and Sonae 2 becomes ‘downwind’ for several hours each day; likely related to katabatic flow reversal from late evening until mid-morning, when anabatic or regional air flow resume. This is another benefit of having analysers in both positions. Data confirms that all 24-hour concentrations remain compliant at both sites.

The data for the Sonae 2, the ‘upwind’ location (Figure 10) indicates very low PM10 levels for most of the period. The PM10 concentrations for this location are comparable to that of previous quarters and the levels are within the required standards.

The Sonae 3 location adjacent to the Heidel Road and R40 intersection, (Figure 11) indicates the lowest PM10 levels that are well within the required standards.

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4.4 DUST DEPOSITION

4.4.1 Results

Dust buckets are deployed for a period of approximately thirty (30) days, in accordance with the requirements of SANS 1929:2005 and the results are compared with the South African limit values described in Table 1. The latest three sets of results from the ongoing monitoring program, as supplied by Talbot Laboratories (SANAS and ISO accredited), are shown in Figure 12, Figure 13 and Figure 14 below.

It is noted that the August 2010 sample SNBAQ2 could not be analysed due to a foreign object in the dust fallout bucket which compromised the integrity of the sample.

Figure 12: Dust Deposition Rates July 2010.

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Figure 13: Dust Deposition Rates August 2010.

Figure 14: Dust Deposition Rates September 2010.

There is a total of nine months dust deposition rate recordings for the Sonae site to-date in 2010. In order to enable ready comparison of latest results against this historic data, the graph below provides a summary in which the median and maximum values for each month are provided from January to September 2010.

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Figure 15: Comparison of Median and Maximum Dust Deposition Rates for 2010.

Compliance with limit values as a three month rolling average is now recommended, in accordance with the Listed Activities & Associated Emission Standards Identified in terms of Section 21 of the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004), Government Gazette, 31 March 2010.

The following figures show the three month running averages relevant to the study period.

Figure 16: Three-month Running Averages of Dust Fallout Rates for May, June, and July 2010.

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Figure 17: Three-month Running Averages of Dust Fallout Rates for June, July, and August 2010.

Figure 18: Three-month Running Averages of Dust Fallout Rates for July, August and September 2010

4.4.2 Discussion

The results for Quarter 3, 2010 indicate no exceedences of the SANS 1929:2005 industrial recommended limit.

The proportion of organic (wood dust) to inorganic (mineral) particulates that make up the total dust fallout remains largely similar to previous monitoring periods. A large portion of the dust measured at sites around the chipper and wood yard are organic whilst a much lower portion at some sites proves that wood-processing (Sonae) is not solely responsible for dust in the area; a fair amount of silica type dust is also being entrained from exposed lands, possibly harvested forestry compartments, and road traffic disturbance.

A comparison of the latest monitoring data against historic trends (Figure 15) indicates that the median dust fallout levels increase slightly towards September as well as recording the second highest recordings for the year, all of which were well within the SANS 1929:2005 industrial recommended limit. This trend is likely the result of persistent dry winter climatic conditions as shown in Figure 5.

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Rolling Average DFO Rates June, July, Aug 2010

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SANS Industrial

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Rolling Average DFO Rates July, Aug, September 2010

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With reference to Figures 16, 17 and 18, the three month running averages for each of the relevant periods were compliant with the relevant limit values for adjacent land use according to dust fallout standards promulgated in terms of Section 32 of NEM:AQA, 2004 (Act No. 39 of 2004).

The peak values for each sampling period have always been at locations on the downwind side of the plant (SNBAQ7 and SNBAQ8) as would be expected given proximity to the chip piles and dominant wind vectors. Results have varied from month to month. Katabatic conditions described in Section 4.3.2 will not affect the entrainment and deposition of coarser particles (measured as dust fallout) significantly owing to low speeds (typically less than 2 m/s). The spatial distribution of dust fallout is more closely correlated with proximity to source, as such particles remain in suspension for less time and are, therefore, not transported far under calm conditions.

With the exception of sampling position SNBAQ7, the mean results for all other locations for each of the three months of monitoring are all comfortably below the SANS industrial and residential standard.

In spite of achieving industrial compliance with all particulate monitoring results for the available data during this quarter, the Environmental Officer was still required to note any dust incidents. Minor dust spill incidents were recorded, but these were effectively controlled by wetting and then removing the dust.

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5 CONCLUSIONS

The three key pollutant parameters monitored for Quarter 3, 2010 included formaldehyde, particulate matter (PM10), and dust deposition (fallout rate). The conclusions drawn from the results are described as follows.

Formaldehyde

In summary, all results to date indicate Sonae is compliant with the ASTDR MRL acute and chronic exposure standards of 49.4 µg/m3 and 9.8 µg/m3 respectively. Measurement is ongoing.

Particulate Matter

The PM10 concentrations measured for this quarter on Osiris instrument Sonae 1 indicated no exceedences of the NEM:AQA limit of 120 µg/m3 over a 24-hour period. Compared to the previous quarter, the overall PM10 concentrations appear to have decreased at this ‘downwind’ fenceline position. This position has been exceeded prior to the commissioning of the dryer. It should be noted that this is a ‘worst case’ fenceline site according to the dispersion model and previous experience, and not a reflection of the overall ambient environment.

The PM10 concentrations measured for this quarter on Osiris instruments (Sonae 2 and 3/R) indicated particulate levels were well within the latest NEM:AQA standard.

Dust Fallout

The results for Quarter 3, 2010 show full compliance, with no exceedences of the SANS 1929:2005 industrial recommended limit. The dust bucket at SNBAQ7 continues to record the highest dust deposition rates. This sample point has generally provided the highest fallout rates throughout previous months, given its close proximity to the chip piles that constitute a significant source of fugitive dust.

All measurements are ongoing and conditions of the AQMP and ROD are currently being met. Sample frequency and reliability is improved over previous survey periods.

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6 REFERENCES

Republic of South Africa (1965). Atmospheric Pollution Prevention Act, No. 45 of 1965. Available online at: http://www.environment.gov.za

Republic of South Africa (2004). National Environmental Management: Air Quality Act, No. 39 of 2004. Available online at: http://www.environment.gov.za

Standards South Africa (2005). Ambient air quality – Limits for common pollutants. South African National Standard 1929:2005.

WSP (2008). Specialist Air Quality Study Sonae Novobord May 2008. EIA Specialist Report-Unpublished.

WSP (2009). Air Quality Management Report: July to September 2009. Sonae Novobord – Unpublished

WSP (2009). Air Quality Management Report: October to December 2009. Sonae Novobord – Unpublished.

WSP (2010). Air Quality Management Report: January to March 2010. Sonae Novobord – Unpublished.

WSP (2010). Air Quality Management Report: April to June 2010. Sonae Novobord – Unpublished.

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Appendix A Formaldehyde Laboratory Results

IVL – Swedish Environmental Research Institute

Analysuppdrag: AG2010-3938

Analysresultat 2010-12-16

Beställare:

Inkom 2010-11-22 Upparbetning: Ann Sjöblom Analysdatum: 2010-12-02 Martin Ferm

Lab-ID Client ID Start Date End Date Formaldehyde Acetaldehyde

ug/m³ ug/m³

AG2010-3938:1 SNF05 2010/10/8 10:15 2010/10/15 09:50 1.8 0.38 AG2010-3938:2 SNF01 2010/10/8 09:20 2010/10/15 09:05 3.7 0.33

Sorbent is partly consumed for both samples.

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