Mamatwan Mine Environmental Management Plan Amendment: …

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

Mamatwan Mine Environmental Management Plan Amendment: Air Quality Specialist Opinion as part of the

Section 24G Requirements

Project done on behalf of SLR Consulting (South Africa)(Pty) Ltd

Project Compiled by H Liebenberg-Enslin

Report No: 18SLR23 | Date: September 2019

Mamatwan Mine Environmental Management Plan Amendment: Air Quality Specialist Opinion as part of the Section 24G Requirements

Report No.: 18SLR23 i

Report Details

Report number 18SLR23

Status Final

Report Title Mamatwan Mine Environmental Management Plan Amendment: Air Quality Specialist Opinion

as part of the Section 24G Requirements

Date September 2019

Client SLR Consulting (South Africa)(Pty) Ltd

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

Reviewed by Nick Grobler, BEng (Chem) (University of Pretoria)

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

Revision Number Date Reason for Revision

Draft Rev 0 16 September 2019 Draft for client review

Final Rev 1 18 October 2019 Addressed client comments


Report No.: 18SLR23 ii

Competency Profiles

Report author: H Liebenberg-Enslin (PhD Geography (University of Johannesburg)

Hanlie Liebenberg-Enslin started her professional career in Air Quality Management in 2000 when she joined Environmental

Management Services (EMS) after completing her Master’s Degree at the University of Johannesburg (then RAU) in the same

field. She is one of the founding members of Airshed Planning Professionals in 2003 where she has worked as a company

Director until she took over as Managing Director in May 2013.

She has extensive experience on the various components of air quality management including emissions quantification for a

range of source types, using different dispersion models, and conducting impact assessments and health risk screening

assessments. Hanlie was the project manager on a number of ground-breaking air quality management plan (AQMP) projects

and the principal air quality specialist on regional environmental assessments. Her work experience, although mostly in South

Africa, range over various countries in Africa, including extensive experience in Namibia, providing her with an inclusive

knowledge base of international legislation and requirements pertaining to air quality.

Hanlie has lectured several Air Quality Management Courses and is actively involved in the International Union of Air Pollution

Prevention and Environmental Protection Associations (IUAPPA) and the South African National Association for Clean Air

(NACA), where she served as President for both organisations. Being an avid student, she received her PhD from the

University of Johannesburg in June 2014, specialising in Aeolian dust transport.

The CV of Hanlie Liebenberg-Enslin is provided in Appendix A.

Specialist Declaration

I, Hanlie Liebenberg-Enslin, as the appointed independent air quality specialist for the Mamatwan Mine Section 24G activities,

hereby declare that I:

• acted as the independent specialist in this Environmental Clearance Certificate application;

• performed the work relating to the application in an objective manner;

• regard the information contained in this report as it relates to my specialist input/study to be true and correct,

• do not have and will not have any financial interest in the undertaking of the activity, other than remuneration for

work performed in terms of the Environmental Impact Assessment;

• declare that there are no circumstances that may compromise my objectivity in performing such work;

• have expertise in conducting the specialist report relevant to this application;

• have no, and will not engage in, conflicting interests in the undertaking of the activity;

• have no vested interest in the proposed activity proceeding;

• undertake to disclose to the applicant and the competent authority all material information in my possession that

reasonably has or may have the potential of influencing the decision of the competent authority; and

• all the particulars furnished by us in this specialist input/study are true and correct.

Signature of the specialist:

Name of Specialists: Hanlie Liebenberg-Enslin

Date: 16 September 2019


Report No.: 18SLR23 iii

NEMA Regulation (2017), Appendix 6

NEMA Regulations (2017) - Appendix 6 Relevant section in report

1.a) Details of the specialist who prepared the report. Report details (page ii)

The expertise of that person to compile a specialist report including curriculum vitae.

Report details (page ii)

Appendix A

1.b) A declaration that the person is independent in a form as may be specified by the competent authority.

Report details (page ii)

1.c) An indication of the scope of, and the purpose for which, the report was prepared.

Executive Summary

Section 1: Introduction

An indication of the quality and age of base data used for the specialist report.

Section 3.2: Atmospheric Dispersion Potential

Section 3.3: Baseline Air Quality

A description of existing impacts on the site, cumulative impacts of the proposed development and levels of acceptable change.


Section 4.2: Qualitative Air Quality Assessment

1.d) The duration date and season of the site investigation and the relevance of the season to the outcome of the assessment.

Section 3.2: Atmospheric Dispersion Potential


1.e) A description of the methodology adopted in preparing the report or carrying out the specialised process inclusive of equipment and modelling used.

Section 1.1: Brief Process Description

Section 1.2: Assumptions and Limitations


1.f) Details of an assessment of the specific identified sensitivity of the site related to the proposed activity or activities and its associated structures and infrastructure inclusive of a site plan identifying site alternatives.

Section 3.1: Site Description

1.g) An identification of any areas to be avoided, including buffers. Not applicable

1.h) A map superimposing the activity including the associated structures and infrastructure on the environmental sensitivities of the site including areas to be avoided, including buffers.

Section 3.1: Site Description

1.i) A description of any assumptions made and any uncertainties or gaps in knowledge.

Section 1.3: Assumptions and Limitations

1.j) A description of the findings and potential implications of such findings on the impact of the proposed activity or activities.


1.k) Any mitigation measures for inclusion in the environmental management programme report

Section 4.3: Management and Mitigation Measures

1.l) Any conditions for inclusion in the environmental authorisation Section 4.3: Management and Mitigation Measures

1.m) Any monitoring requirements for inclusion in the environmental management programme report or environmental authorisation.

None identified

1.n) A reasoned opinion as to whether the proposed activity, activities or portions thereof should be authorised.

Section 5: Conclusion and Recommendations

A reasoned opinion regarding the acceptability of the proposed activity or activities.

Section 5: Conclusion and Recommendations

If the opinion is that the proposed activity or portions thereof should be authorised, any avoidance, management and mitigation measures that should be included in the environmental management programme report, and where applicable, the closure plan.

Section 4.3: Management and Mitigation Measures

Section 5.3: Recommendations

1.o) A description of any consultation process that was undertaken during the course of carrying out the study.

Not applicable


Report No.: 18SLR23 iv

NEMA Regulations (2017) - Appendix 6 Relevant section in report

1.p) A summary and copies if any comments that were received during any consultation process.

Not applicable

1.q) Any other information requested by the competent authority. Not applicable.


Report No.: 18SLR23 v

Abbreviations

AEL Atmospheric Emissions License

Airshed Airshed Planning Professionals (Pty) Ltd

Australian EPA Australian Environmental Protection Agency

AQA Air Quality Act

CE Control Efficiency

CTPP Carbon Tax Policy Paper

DEA Department of Environmental Affairs

DEFF Department of Environment, Forestry and Fisheries

DMS Dense Medium Separation

DPM Diesel Particulate Matter

EIA Environmental Impact Assessment

EMP Environmental Management Program

EMPR Environmental Management Program Report

GHG Greenhouse Gas

MMT Mamatwan Mine

MES Minimum Emission Standards

m metre

m² Metre squared

m/s Metre per second

mg/m².day Milligram per metre squared per day

NAAQS National Ambient Air Quality Standards

NAEIS National Atmospheric Emissions Inventory System

NAERR National Atmospheric Emission Reporting Regulations

NDCR National Dust Control Regulations

NPI National Pollutant Inventory (Australia)

PM Particulate Matter

PM10 Particulate Matter with an aerodynamic diameter of less than 10

PM2.5 Particulate Matter with an aerodynamic diameter of less than 2.5

PPP Pollution Prevention Plans

SAAELIP South African Atmospheric Emission Licensing & Inventory Portal

SAAQIS South African Air Quality Information System

SANS South African National Standards

TSP Total Suspended Particles

US-EPA United States Environmental Protection Agency

WHO World Health Organisation

WRD Waste Rock Dump

°C Degrees Celsius

µg/m³ Microgram per cubic metre


Report No.: 18SLR23 vi

Executive Summary

Airshed Planning Professionals (Pty) Ltd was appointed by SLR Consulting (South Africa) (Pty) Ltd to qualitatively assess the

potential for air quality related impacts from the Mamatwan Mine Section 24G activities, not covered by the 2005 Environmental

Management Program Report (EMPr), on the surrounding environment and human health. This will be used to inform the

NEMA Section 24G requirements.

Mining operations include open pit mining methods (drilling, blasting and excavation of ore and waste rock), with haul roads

linking the pits with the surrounding waste rock dumps (WRDs) and a processing plant where a Sinter Plant is operational.

The EMPr approved in 2005 allowed for the tailing’s material generated by the Sinter Plant to be disposed into the Adams pit

via conveyor. Adams pit is currently also used for the disposal of general waste (old and used conveyors and metal) and the

storage of Sinter de-dust retained in de-dust bags from the Sinter plant. The use of Adam’s pit for these activities are not

catered for in the approved EMPr. Storage of topsoil on a topsoil stockpile is covered in the 2005 EMPr but the north-eastern

topsoil stockpile on the eastern side of the North East WRD is not covered in the approved EMPr.

The prevailing wind field at the mine is from the south-southeast and south with the strong winds mostly from the west.

Frequent winds also occur from the north. During the day, winds are more frequent from the westerly and the northerly sectors,

with the strongest winds directly from the west. The wind shifts during the night to south-southeasterly and southerly winds.

Dustfall collected at eight locations at and around the mine during 2018 indicate low dust fallout rates, well below the National

Dust Control Regulation (NDCR) limit for residential areas (600 mg/m²/day) and non-residential areas (1 200 mg/m²/day).

The main findings from the qualitative assessment for the Section 24G activities at Mamatwan Mine are as follow:

• The main pollutant of concern from all the Section 24G activities is particulate matter (PM), with PM10 and PM2.5

concentrations related to health impacts and dust fallout related to nuisance impacts.

• The disposal of general waste (old and used conveyors and metal) and the storage of Sinter de-dust is done using trucks.

PM from the storage of Sinter de-dust may arise when the material is tipped into Adam’s pit. The potential exists for the

transported material to be blown from the uncovered trucks during high wind speeds. Under these conditions there is a

potential for PM10 and PM2.5 impacts to the east of the plant but these concentrations are likely only to be high close to

the source and decrease rapidly up to a distance of 250 m with no sensitive receptors within this zone.

• Tipping of Sinter de-dust into the open pit is unlikely to result in significant off-site impacts since dust generation from the

tipped material is below surface level (in the pit), allowing for pit retention to dilute the concentrations before reaching the

surface.

• The potential for windblown dust from the exposed surfaces of the north-eastern topsoil stockpile exists under strong

wind conditions. The impacts from windblown topsoil is likely to be high near the north-eastern topsoil stockpile and

reduce significantly further away from the stockpile. The significance of the impacts would however depend on the height

and footprint of the exposed areas of the stockpile.

• Land clearing activities using dozers and scrapers could result in significant dust generation, but the significance from

these activities would depend on the duration of scraping and grading as well as the size of the area being cleared.

• Cumulatively, the contributions from the various Section 24G activities (windblown dust from the open trucks, dust from

tipping of material into the pit, windblown dust from the north-eastern topsoil stockpile and land clearing activities for the


Report No.: 18SLR23 vii

north-eastern topsoil stockpile) are likely to be concealed by the current mining operations, both from Mamatwan Mine

and the neighbouring Tshipi Borwa Mine.

The following mitigation measures are recommended:

• Trucks transporting material: cover the trucks or spray the material to reduce the potential for windblown dust from

the open trucks.

• Adams Pit: Materials transfer points could be managed using water sprays at the tip points – this should result in a

50% CE. Tipping of the material should be done as far down in the pit as possible, to be below the surface. The

drop height of material should be reduced to a minimum.

• North-Eastern Topsoil Stockpile: Water sprays should be used to keep surface material moist and wind breaks

installed to reduce wind speeds over the exposed areas – this should have CE of 50%. The dormant areas should

be re-vegetated to ensure full cover at all times – this should have control efficiency of 90%. Recommended

mitigation for land clearing activities include water sprays; which could result in 50% CE.

It should be noted that South32 is proposing to re-process the material located in Adams pit in the near future. Authorising the

re-processing of material within Adams pit will require environmental authorisation from the DMR. A separate process will

need to be undertaken to authorise the proposed re-processing activities.


Report No.: 18SLR23 viii

Table of Contents

1 Introduction....................................................................................................................................................................... 1

1.1 Brief Process Description ....................................................................................................................................... 4

1.2 Assumptions and Limitations .................................................................................................................................. 6

2 Legal Review .................................................................................................................................................................... 7

2.1 National Framework ............................................................................................................................................... 8

2.2 Listed activities ....................................................................................................................................................... 8

2.3 National Ambient Air Quality Standards ................................................................................................................. 9

2.4 National Regulations for Dust Deposition ............................................................................................................. 10

2.5 National Atmospheric Emission Reporting Regulations (NAERR) ....................................................................... 10

2.6 Greenhouse Gas Emissions ................................................................................................................................. 11

3 Description of the Receiving Environment ..................................................................................................................... 12

3.1 Site Description .................................................................................................................................................... 12

3.2 Atmospheric Dispersion Potential of the Site ....................................................................................................... 13

3.2.1 Surface Wind Field .......................................................................................................................................... 13

3.2.2 Temperature .................................................................................................................................................... 15

3.2.3 Precipitation ..................................................................................................................................................... 15

3.2.4 Atmospheric Stability ....................................................................................................................................... 16

3.3 Baseline Air Quality .............................................................................................................................................. 17

3.3.1 Dustfall Monitoring network ............................................................................................................................. 17

4 Qualitative Air Quality Assessment ................................................................................................................................ 20

4.1 2019 Air Quality Impact Assessment .................................................................................................................... 20

4.2 Qualitative Air Quality Impact Assessment for Section 24G Activities ................................................................. 20

4.2.1 Adams Pit ........................................................................................................................................................ 20

4.2.2 Topsoil Stockpile .............................................................................................................................................. 21

4.2.3 Cumulative Impacts ......................................................................................................................................... 22

4.3 Management and Mitigation Measures ................................................................................................................ 22

4.3.1 Adams Pit ........................................................................................................................................................ 22

4.3.2 Topsoil Stockpile .............................................................................................................................................. 23

5 Conclusion and Recommendations................................................................................................................................ 24

5.1 Main Findings ....................................................................................................................................................... 24

5.2 Conclusion ............................................................................................................................................................ 24

5.3 Recommendations ................................................................................................................................................ 24


Report No.: 18SLR23 ix

6 References ..................................................................................................................................................................... 26

7 Appendix A - Specialist Curriculum Vitae ....................................................................................................................... 27

List of Tables

Table 1: Current mining activities at Mamatwan Mine with associated pollutants .................................................................... 4

Table 2: Section 24G Activities with expected pollutants ........................................................................................................... 4

Table 3: Legislation applicable to the project ............................................................................................................................ 7

Table 4: Applicable Listed Activity for Sinter Plant Operations .................................................................................................. 9

Table 5: South African National Ambient Air Quality Standards (Government Gazette 32816, 2009) ...................................... 9

Table 6: Acceptable Dustfall Rates .......................................................................................................................................... 10

Table 7: Minimum, average and maximum temperatures (SAWS Kuruman data; 2015 to 2017) ........................................... 15

Table 8: Atmospheric stability classes and percentage occurrence (SAWS Kuruman data; 2015 to 2017) ............................ 16

Table 9: Dustfall rates from the single dustfall units at Mamatwan Mine ................................................................................. 17

List of Figures

Figure 1: Mamatwan Mine mining and processing infrastructure ............................................................................................. 2

Figure 2: Process flow diagram ................................................................................................................................................. 3

Figure 3: Location of the Section 24G Activities ....................................................................................................................... 5

Figure 4: Identified air quality sensitive receptors near the Mamatwan Mine .......................................................................... 12

Figure 5: Period and annual wind roses (SAWS Kuruman data; 2015, 2016 and 2017) ......................................................... 14

Figure 6: Period, daytime and nigh-time wind roses (SAWS Kuruman data; 2015 to 2017) ................................................... 14

Figure 7: Wind speed categories (SAWS Kuruman data; 2015 to 2017) ................................................................................. 15

Figure 8: Monthly precipitation (SAWS Kuruman data; 2015 to 2017) .................................................................................... 16

Figure 9: Monitoring Network at Mamatwan Mine ................................................................................................................... 17

Figure 10: Box-and-whisker plot of on-site dustfall for the year 2018 ...................................................................................... 18

Figure 11: Box-and-whisker plot of on-site dustfall for the year 2019 ...................................................................................... 19

Figure 12: Impact distance from the conveyor assuming an emission rate ............................................................................ 21


Report No.: 18SLR23 1

1 INTRODUCTION

Mamatwan Mine (MMT), situated south of Hotazel and north of Kuruman, is an open cast manganese mine which commenced

mining in 1963. The mine falls within the Joe Morolong Local Municipality and the John Taolo Gaetsewe District Municipality

in the Northern Cape Province. Tshipi Borwa Mine, also an open pit manganese mine, borders MMT to the west. MMT currently

holds the following authorisations:

• A Mining right (Reference number: NC 256 MR) issued and approved by the former Department of Minerals and

Energy (DME) (currently the Department of Mineral Resources (DMR)) in May 2006;

• An Environmental Management Programme (EMPr) (Reference number: NC 6/2/2/118) issued and approved by the

former DME (currently the DMR) in November 2005;

• An Air Emissions Licence (AEL) (Licence number: NC/AEL/NDM/ZRH01/2014) issued by the Northern Cape

Department of Environment and Nature Conservation (DENC) in March 2015;

• An amended Integrated Water Use Licence (IWUL) (License number: 10/D41K/KAGJ/1537) issued by the

Department of Water and Sanitation (DWS) in January 2012;

• An Environmental Authorisation (Reference number: NC/KGA/HOT3/07) for bulk fuel storage issued by former

Department of Tourism, Environment and Conservation (currently DENC) in July 2007; and

• An Environmental Authorisation (Reference number: NC 30/5/1/2/3/2 (252) MR for the merging of the MMT

Sinterfontein Waste Rock Dump with the Tshipi Eastern Waste Rock Dump from the DMR in January 2020.

Mining operations include open pit mining methods (drilling, blasting and excavation of ore and waste rock), with haul roads

linking the pits with the surrounding waste rock dumps (WRDs) and processing plant. Ore is hauled from the open pit and

tipped at the run-of-mine (ROM) stockpile from where it is sent to the primary crusher, following which it is fed to the secondary

crushing and screening plant. Waste rock is hauled from the pit to five existing WRDs – North Eastern-; Central-; South East-

; South- and Sinterfontein WRDs. Other infrastructure at the mine, amongst others, includes a conveyor, explosives magazine,

topsoil dump, Dense Medium Separation (DMS) discard dump and product stockpile area, etc. The old tailings dams and

Adams WRDs have been decommissioned and rehabilitated. The current mine layout is shown in Figure 1.

A Sinter Plant is operational at the mine. Ore from the open pit is transported to the primary crusher, either directly or stockpiled

first, before being conveyed to the Run of Mine (ROM) stockpile. From here the material is fed to the processing plant where

it is washed and screened, and where selective Low Grade (LG) and High Grade (HG) ores are blended in. The screening

process separates the DMS feed, sinter feed, lumpy product and the slimes. The slimes used to go to the tailings dam but is

now disposed of at Adams pit. At the DMS plant, the material is stockpiled and separated into three different products – M1FT,

sinter feed low grade and sinter feed high grade. The sinter feed from the screening process is also fed to the sinter feed low

grade stockpile. Material from the two sinter feed stockpiles goes to the sinter plant where high- and low-grade sinter are

produced. Sinter fines are returned to the process. Sinter de-dust results from the cleaning equipment (bag house) and this

gets dumped at the Adams pit together with the waste (GRIT) from the DMS plant. The processing plant operations is illustrated

in Figure 2.

The EMPr approved in 2005 allowed for the tailing’s material generated by the Sinter Plant to be disposed into the Adams pit

via conveyor. The same EMPr allows for product storage from the Sinter Plant (Sinter fines) into Adams pit. However, Adams

pit is currently also used for the disposal of general waste (old and used conveyors and metal) and storage of Sinter de-dust.

These materials are not catered for in the approved EMPr. Storage of topsoil on a topsoil stockpile is covered in the 2005

EMPr. The north-eastern topsoil stockpile on the eastern side of the north WRD is however not covered in the 2005 EMPr.



Figure 1: Mamatwan Mine mining and processing infrastructure



Figure 2: Process flow diagram



Airshed Planning Professionals (Pty) Ltd was appointed by SLR Consulting (South Africa) (Pty) Ltd to qualitatively assess the

potential for air quality related impacts from the unauthorized activities, not covered by the 2005 EMPr, on the surrounding

environment and human health. This will be used to inform the NEMA Section 24G requirements.

The scope of work includes:

• Review and collate available information on the unauthorized activities;

• Review of relevant legal requirements;

• Characterization of the receiving environment;

• Qualitative assessment of potential air quality impacts; and

• Compile a specialist opinion report including management and mitigation measures.

1.1 Brief Process Description

The current mining activities, with associated air pollutants, are listed in Table 1. The Section 24G activities with associated

air pollutants are listed in Table 2 with the location of the Section 24G activities indicated in Figure 3.

Table 1: Current mining activities at Mamatwan Mine with associated pollutants

Activity Associated pollutants

Mining Operations

Open Pit: Drilling and blasting Particulate matter (PM)(a), sulfur dioxide (SO2); oxides of nitrogen (NOx); carbon

monoxide (CO); and carbon dioxide (CO2)(b)

Open Pit: Excavation of ore and waste mostly PM, gaseous emissions from mining equipment (PM, SO2; NOx; CO; CO2)

Open Pit: Removal and stockpiling of topsoil mostly PM, gaseous emissions from excavation equipment (PM, SO2; NOx; CO; CO2)

Haulage of ore, waste and topsoil PM from road surfaces, windblown dust from trucks, gaseous emissions from truck

exhaust (PM, SO2; NOx; CO; CO2)

Construction of access roads using mine

residue

mostly PM, gaseous emissions from machinery (PM, SO2; NOx; CO; CO2)

WRDs (North Eastern-; Central-; South East-;

South- and Sinterfontein WRDs)

PM from tipping, windblown dust, gaseous emissions from truck exhaust (PM, SO2;

NOx; CO; CO2)

Primary crushing and screening mostly PM, gaseous emissions from machinery (PM, SO2; NOx; CO; CO2)

Conveyors mostly PM from transfer points, windblown dust from conveyor

Adams Pit (waste disposal) mostly PM, gaseous emissions from machinery and trucks (PM, SO2; NOx; CO; CO2)

Processing Operations

Secondary crushing and screening mostly PM, gaseous emissions from machinery (PM, SO2; NOx; CO; CO2)

Sinter plant PM, SO2; NOx; CO; and CO2

Other Activities

Explosives magazine gaseous emissions from open burning (PM, SO2; NOx; CO; CO2)

Notes: (a) Particulate matter (PM) comprises a mixture of organic and inorganic substances, ranging in size and shape and can be divided into coarse and

fine particulate matter. Total Suspended Particulates (TSP) represents the coarse fraction >10m, with particulate matter with an aerodynamic

diameter of less than 10m (PM10) and particulate matter with an aerodynamic diameter of less than 2.5m (PM2.5) falling into the finer inhalable

fraction. TSP is associated with dust fallout (nuisance dust) whereas PM10 and PM2.5 are considered a health concern.

(b) CO2 and methane are greenhouse gasses (GHG).

Table 2: Section 24G Activities with expected pollutants

Location Unauthorised Activities Potential air pollutants

Adams Pit General waste – includes old and used conveyors and metal

(general waste)

PM(a), heavy metals and gaseous

emissions (minor – from truck exhaust)

Sinter de-dust from the Sinter plant



Location Unauthorised Activities Potential air pollutants

North Eastern

Topsoil Stockpile

Storage of topsoil PM(a) and gaseous emissions (minor –

from truck exhaust)

Notes: (a) Particulate matter (PM) comprises a mixture of organic and inorganic substances, ranging in size and shape and can be divided into coarse and

fine particulate matter. Total Suspended Particulates (TSP) represents the coarse fraction >10m, with particulate matter with an aerodynamic

diameter of less than 10m (PM10) and particulate matter with an aerodynamic diameter of less than 2.5m (PM2.5) falling into the finer inhalable

fraction. TSP is associated with dust fallout (nuisance dust) whereas PM10 and PM2.5 are considered a health concern.

Figure 3: Location of the Section 24G Activities



1.2 Assumptions and Limitations

The study followed a qualitative approach, with no emissions quantified for the Section 24G activities.

The main assumptions, exclusions and limitations are summarized below:

• No onsite meteorological data was available and weather data from the South African Weather Services (SAWS)

Kuruman station was obtained for the period January 2015 – December 2017, which falls within the dispersion

modelling timeframe criteria (three years of data within the latest five-year period) of the Department of Environment,

Forestry and Fisheries (DEFF). The weather station is located approximately 42 km to the east-southeast of

Mamatwan mine and regarded representative of on-site weather conditions. This is the nearest weather station to

the mine that records wind speed, wind direction, temperature, solar radiation and pressure.

• MMT operates a dustfall network comprising of eight single dustfall units (of which one has been decommissioned)

and three (3) directional dustfall units. Since results from the directional units cannot be compared to the NDCR

limits, only results from the single dustfall units are reported on. Results from the annual report for 2018 and 2019

is reported on.

• The Tshipi Borwa Mine is not considered a sensitive air receptor given that occupational risks are managed under

the Occupational Health and Safety Act and Regulations (No. 85 of 1993);The current mining and processing

operations were not assessed – this forms part of the EIA currently underway. The Air Impact Report (AIR)

conducted in 2019 as part of the Sinter Plant AEL renewal was used as an indication for air quality impacts together

with the dustfall results.

• Only the Section 24G activities are assessed in this report to understand the contribution of these activities to the

overall impact of the mine.

• MMT does not undertake ambient air quality monitoring of PM concentration levels at sensitive air receptors. In

support of a minimum emission’s standard postponement application for the Sinter plant stack emissions, Golder

Associates undertook dispersion modelling. In the absence of ambient air quality PM monitoring data, the results of

the Golders Associates dispersion modelling were used to inform the impact assessment for the project. The PM

dispersion modelling undertaken by Golders Associates is based on the emission rates measured in 2016 and 2017

and not the MES. It is therefore assumed that as long as the emission rates currently are not significantly higher

than those previously measured, the impact at sensitive receptors will be very low.

• The CE percentages specified in the Air Study are based on literature references and are deemed achievable.

• MMT is not committed to undertake ambient particulate concentration monitoring at sensitive receptors. Based on

the very low dust fallout rates it is assumed that ambient particulate concentrations are similarly low, and likely in

compliance with the NAAQS at sensitive receptor locations for MMT sources.



2 LEGAL REVIEW

The last issued and approved EMPr was in November 2005 (Reference number: NC 6/2/2/118). Subsequently, there have

been additions and changes to the National Environmental Management: Air Quality Act (Act no.39 of 2004). The Act

commenced with on 11 September 2005 as published in the Government Gazette on 9 September 2005 with sections omitted

from the implementation (Sections 21, 22, 36 to 49, 51(1)(e),51(1)(f), 51(3), 60 and 61). The Act was fully implemented on

1 April 2010, including Section 21 on the Listed Activities and Minimum National Emission Standards (MES) with the revised

MES published on 22 November 2013 (Government Gazette 37054, Notice No. 893). Amendments to the Act, primarily

pertaining to administrative aspects, were published in 2014 (Government Gazette 37666, Notice No. 390 on 14 May 2014).

Air quality legislation that came into play after 2005 that is relevant to the project is provided in Table 3.

Table 3: Legislation applicable to the project

Air Quality Legislation Implementation/ revision dates

Reference Affected Project Activity

National Framework updated Dec 2012 Government Gazette 37078, 29 Nov 2013

Industry legal responsibilities

Section 21 – Listed Activities Implemented:

1 April 2010

Revised: 2013

Amendments: 2015

Government Gazette 37054, 22 Nov 2013

Government Gazette 38863, 12 Jun 2015

Sinter Plant (still to be established)

National Ambient Air Quality Standards (NAAQS)

24 December 2009

29 July 2012

Government Gazette 32816, 24 Dec 2009

Government Gazette 35463, 29 Jun 2012

PM10 and PM2.5 ground level concentrations as a result from the mining activities

National Dust Control Regulations (NDCR)

1 November 2013 Government Gazette 37054, 22 Nov 2013

Dust fallout rates as a result from the mining activities

National Atmospheric Emission Reporting Regulations (NAERR)

2 April 2015 Government Gazette 3863, 2 Apr 2015

Emissions reporting on mining operations

Emissions reporting on Listed Activity (Sinter Plant to be established)

Regulation on Administrative Fines and Air quality offsets guideline

18 March 2016 Government Gazette 39833, 18 Mar 2016

Sinter Plant has a valid AEL until 31 March 2020

Declaration of Greenhouse Gases (GHG) as Priority Air Pollutants

Draft in 2016 Government Gazette 40996, 21 Jul 2017

N.A.(a)

National Pollution Prevention Plans (PPP) Regulations

Draft in 2016 Government Gazette 40996, 21 July 2017

N.A.(a)

National Greenhouse Gas (GHG) Emission Reporting Regulations

3 April 2017 Government Gazette 40762, 3 April 2017

Mining and quarrying to report on all stationary combustion emissions above 10 MW(th)

Notes: (a) only apply to direct emission of GHG in excess of 0.1 Megatonnes (Mt) annually measured as carbon dioxide equivalents (CO2-eq)



2.1 National Framework

The National Framework (first published in Government Gazette Notice No. 30284 of 11 September 2007) was updated in

2013) and provides national norms and standards for air quality management to ensure compliance. The National Framework

states that aside from the various spheres of government’s responsibility towards good air quality, industry too has a

responsibility not to impinge on everyone’s right to air that is not harmful to health and well-being. Industries therefore should

take reasonable measures to prevent such pollution order degradation from occurring, continuing or recurring.

In terms of AQA, certain industries have further responsibilities, including:

• Compliance with any relevant national standards for emissions from point, non-point or mobile sources in respect of

substances or mixtures of substances identified by the Minister, MEC or municipality.

• Compliance with the measurement requirements of identified emissions from point, non-point or mobile sources and the

form in which such measurements must be reported and the organs of state to whom such measurements must be

reported.

• Compliance with relevant emission standards in respect of controlled emitters if an activity undertaken by the industry

and/or an appliance used by the industry is identified as a controlled emitter.

• Compliance with any usage, manufacture or sale and/or emissions standards or prohibitions in respect of controlled fuels

if such fuels are manufactured, sold or used by the industry.

• Comply with the Minister’s requirement for the implementation of a pollution prevention plan in respect of a substance

declared as a priority air pollutant.

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

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

• Furthermore, industries identified as Listed Activities have further responsibilities, including:

• Making application for an AEL and complying with its provisions.

• Compliance with any minimum emission standards in respect of a substance or mixture of substances identified as

resulting from a listed activity.

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

• Section 51 of the Air Quality Act lists possible offences according to the requirements of the Act with Section 52

providing for penalties in the case of offences.

2.2 Listed activities

Sinter Plants fall under Category 4: Metallurgical Industry, Sub-category 4.5: Sinter Plants. An Atmospheric Emission License

(AEL) has been issued in March 2015 and is valid until 31 March 2020.

The Minimum Emission Standards (MES) as set out for the Sinter Plant operations are provided in Table 4. There are two

sets of MES applicable to:

• New Plants (plant or process where the application in terms of NEMA was made on or after 1 April 2010); and

• Existing Plants (plant or process that was legally authorized to operate before 1 April 2010 or where an application

in terms of NEMA was made before 1 April 2010).

MMT Sinter Plant must comply with the New Plants standards1.

1 All Listed Activities must comply with new plant standards by 1 April 2020



Table 4: Applicable Listed Activity for Sinter Plant Operations

Category 4 - Metallurgical Industry; Subcategory 4.5 – Sinter Plants

Description: Sinter plants for the agglomeration of fine ore using heating process, including sinter cooling where applicable

Application: All installations

Substance or Mixture of Substances Plant Status mg/Nm³ under normal conditions of 6% O2, 273

Kelvin and 101.3 kPa Common Name Chemical Symbol

Particulate matter N/A New 50

Existing 100

Sulphur dioxide SO2 New 500

Existing 1000

Oxides of nitrogen NOx expressed as NO2 New 700

Existing 1200

2.3 National Ambient Air Quality Standards

The South African Bureau of Standards (SABS) assisted the Department of Environmental Affairs (DEA) in the development

of ambient air quality standards. National Ambient Air Quality Standards (NAAQS) were determined based on international

best practice for PM2.5 PM10, SO2, NO2, ozone (O3), CO, lead (Pb) and benzene. The NAAQS were published in the

Government Gazette (no. 32816) on 24 December 2009, thus after the 2009 EIA was competed. NAAQS for PM2.5 was

published on 29 July 2012. The NAAQS are listed in Table 5.

Table 5: South African National Ambient Air Quality Standards (Government Gazette 32816, 2009)

Substance Molecular formula / notation

Averaging period Concentration limit (µg m-3)

Frequency of exceedance(a)

Compliance date(b)

Sulfur dioxide SO2 10 minutes 500 526 Currently enforceable

1 hour 350 88 Currently enforceable

24 hours 125 4 Currently enforceable

1 year 50 - Currently enforceable

Nitrogen dioxide

NO2 1 hour 200 88 Currently enforceable


Particulate matter

PM10 24 hours 75 4 Currently enforceable


Fine particulate matter

PM2.5 24 hours 40 4 1 Jan 2016 – 31 Dec 2029

25 1 Jan 2030

1 year 20 - 1 Jan 2016 – 31 Dec 2029

15 1 Jan 2030

Ozone O3 8 hours (running) 120 11 Currently enforceable

Benzene C6H6 1 year 5 - Currently enforceable

Lead Pb 1 year 0.5 - Currently enforceable

Carbon monoxide

CO 1 hour 30 000 88 Currently enforceable

8 hours (based on 1-hourly averages)

10 000 11 Currently enforceable

Notes: (a) The number of averaging periods where exceedance of limit is acceptable.

(b) Date after which concentration limits become enforceable.



2.4 National Regulations for Dust Deposition

South Africa’s Draft National Dust Control Regulations were published on the 27 May 2011 with the dust fallout standards

passed and subsequently published on the 1st of November 2013 (Government Gazette No. 36974) with changes in

regulations published in 2018 (Notice 517 GG 41650 of 25 May 2018). These are called the National Dust Control Regulations

(NDCR). The purpose of the regulations is to prescribe general measures for the control of dust in all areas including residential

and light commercial areas. SA NDCRs that were published on the 1st of November 2013. Acceptable dustfall rates according

to the regulation are summarised in Table 6.

Table 6: Acceptable Dustfall Rates

Restriction areas Dustfall rate (D) in mg/m²-day over a 30-day average

Permitted frequency of exceedance

Residential areas D < 600 Two within a year, not sequential months.

Non-residential areas 600 < D < 1 200 Two within a year, not sequential months.

The regulation also specifies that the method to be used for measuring dustfall and the guideline for locating sampling points

shall be ASTM D1739 (1970), or equivalent method approved by any internationally recognized body. It is important to note

that dustfall is assessed for nuisance impact and not inhalation health impact.

2.5 National Atmospheric Emission Reporting Regulations (NAERR)

The National Atmospheric Emission Reporting Regulations (NAERR) was published on the 2nd of April 2015 by the Minister

of Environmental Affairs. The regulation aims to standardize the reporting of data and information from an identified point,

non-point and mobile sources of atmospheric emissions to an internet-based National Atmospheric Emissions Inventory

System (NAEIS), towards the compilation of atmospheric emission inventories (DEA , 2015).

Annexure 1 of the NAERR classify mines (holders of a mining right or permit in terms of the Mineral and Petroleum Resources

Development Act, 2002 (Act No. 28 of 2002)) as a data provider under Group C. Listed Activities as published in terms of

Section 21(1) of the AQA falls under Group A.

Sections of the regulation that applies to data providers are summarized below.

With regards to registration, the regulation stipulates that:

(a) A person classified as a data provider must register on the NAEIS within 30 days from the date upon which these

Regulations came into effect;

(b) A person classified as a data provider and who commences with an activity or activities classified as emission

source in terms of the regulation 4(1) after the commencement of these Regulations, must register on the NAEIS

within 30 days after commencing with such an activity or activities.

With regards to reporting and record keeping, the regulation stipulates that:

(a) A data provider must submit the required information for the preceding calendar year, as specified in Annexure 1 to

the Regulations, to the NAEIS by 31 March of each calendar year.

(b) A data provider must keep a record of the information submitted to the NAEIS for five years and such record must,

on request, be made available for inspection by the relevant authority.



With regards to verification of information, the regulation requires data providers to verify requested information within 60 days

after receiving the written request from the relevant authority.

2.6 Greenhouse Gas Emissions

Greenhouse gasses – CO2, CH4, N2O, HFCs, PFCs and SF6 – have been declared priority pollutants under Section 29(1) of

the Air Quality Act (Government Gazette 37421 of 14 March 2014). The declaration provides a list of sources and activities

including (i) fuel combustion (both stationary and mobile), (ii) fugitive emission from fuels, (iii) industrial processes and other

product use, (iv) agriculture; forestry and other land use and (v) waste management. GHGs in excess of 0.1 Megatons or

more, measured as CO2-e, is required to submit a pollution prevention plan to the Minister for approval.

Regulations pertaining to GHG reporting using the NAEIS was published on 3 April 2017 (Government Gazette 40762,

Notice 275 of 2017). The South African mandatory reporting guidelines focus on the reporting of Scope 1 emissions only. The

three broad scopes for estimating GHG are:

• Scope 1: All direct GHG emissions.

• Scope 2: Indirect GHG emissions from consumption of purchased electricity, heat or steam.

• Scope 3: Other indirect emissions, such as the extraction and production of purchased materials and fuels, transport-

related activities in vehicles not owned or controlled by the reporting entity, electricity-related activities not covered in

Scope 2, outsourced activities, waste disposal, etc.

The NAEIS web-based monitoring and reporting system will also be used to collect GHG information in a standard format for

comparison and analyses. The system forms part of the National Atmospheric Emission Inventory component of South African

Atmospheric Emission Licensing & Inventory Portal (SAAELIP) and South African Air Quality Information System (SAAQIS).

The DEA is working together with local sectors to develop country specific emissions factors in certain areas; however, in the

interim the Intergovernmental Panel on Climate Change’s (IPCC) default emission figures may be used to populate the

SAAQIS GHG emission factor database. These country specific emission factors will replace some of the default IPCC

emission factors.

A draft carbon tax bill was introduced for a further round of public consultation. The Carbon Tax Policy Paper (CTPP)

(Department of National Treasury, 2013) stated consideration will be given to sectors where the potential for emissions

reduction is limited. GHG in excess of 0.1 Mt, measured as CO2-eq, is required to submit a pollution prevention plan to the

Minister for approval.



3 DESCRIPTION OF THE RECEIVING ENVIRONMENT

3.1 Site Description

MMT has Tshipi Borwa Manganese Mine located immediately to the west and a Solar PV plant about 1 km to the east of the

mine. The site is surrounded by farmland used for grazing. Air quality sensitive receptors (AQSRs) in the immediate vicinity of

the mine include a farmhouse (N Fourie) 2 km south-southwest of the mine and a farmhouse (D van den Berg) located 4 km

to the southwest. The Farmhouse of A Pyper is about 4.8 km to the west with the old railway housing 300 m east of one of the

dormant WRDs. The AQSRs can be listed as follows:

• AQSR1 (Farmstead- Dries Van Den Berg)

• AQSR2 (Farmstead- Nic Fourie)

• AQSR3 (Eskom Sub-Station)

• AQSR4 (Solar PV Plant)

• AQSR5 (Farmstead- Farm workers)

• AQSR6 (Farmstead – A Pyper)

• AQSR7 (Farmstead – M Kruger)

Operating mines include the neighboring Tshipi Borwa Manganese Mine and United Manganese of Kalahari (UMK) Mine

approximately 2 km to the north. UMK also have on-site sintering (Krause & Liebenberg-Enslin, 2009). Another large opencast

mine in the area is Sishen Iron Ore Mine, located 33 km to the south of Mamatwan Mine. Closed or dormant mines include

Middelplaats, Adams, Smartt and Perth.

The area surrounding the site is mostly flat with ridges to the west (about 40 km away) and to the east (about 20 km away).

Within a 10 km radius around the mine the terrain is fairly flat with s slight slope from the southeast to the northwest.

The identified AQSRs and other mines are shown in Figure 4.

Figure 4: Identified air quality sensitive receptors near the Mamatwan Mine

Tshipi Borwa Mine

Solar PV plant



3.2 Atmospheric Dispersion Potential of the Site

Physical and 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. Parameters useful in describing the dispersion and dilution potential of the site i.e. wind

speed, wind direction, temperature and atmospheric stability, are subsequently discussed.

Mamatwan Mine does not have a weather station and use was made of the South African Weather Services (SAWS) Kuruman

Weather Station (located approximately 43 km to the southwest of the mine). Data for the period 1 January 2015 –

31 December 2017 was obtained for inclusion in the report. The data availability varied between the years with poor data

availability of 63% (specifically on the wind field) in 2015 but good data availability of 93% and 90% for 2016 and 2017,

respectively.

3.2.1 Surface Wind Field

The wind field determines both the distance of downward transport and the rate of dilution of pollutants. The generation of

mechanical turbulence is a function of the wind speed, in combination with the surface roughness. The wind field for the study

area is described with the use of wind roses. 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

yellow area, for example, representing winds in between 2 and 3 m/s. The dotted circles provide information regarding the

frequency of occurrence of wind speed and direction categories. Calm conditions are periods when the wind speed was below

1 m/s. These low values can be due to “meteorological” calm conditions when there is no air movement; or, when there may

be wind, but it is below the anemometer starting threshold.

The annual average wind roses for the years 2015, 2016 and 2017 are shown in Figure 5 with the period average wind field

(2015-2017) and diurnal variability in the wind field provided in Figure 6. The predominant wind direction is from the south-

southeast and south with most of strong winds from the west. Frequent winds also occur from the north. Over the three-year

period, the frequency of occurrence of south-southeasterly wind is between 12% and 17%, with winds with a westerly

component occurring approximately 15% of the time. Winds occur less frequently from the easterly sector. The year 2015 had

low data availability for wind speed and wind direction (63%), which may account for the seemingly less frequent winds from

the south-southeast.

As shown in Figure 6, during the day winds are more frequent from the westerly and the northerly sectors, with the strongest

winds directly from the west. The wind shifts during the night-time to dominantly south-southeasterly and southerly winds.

Day-time calms occurred for 9% of the time, with night-time calms for 24% of the time.

The prevailing wind field is similar to the data used in the 2009 study, with a slight shift in the overall wind field from south-

east and south-southeast (2001-2005 data) to the south-southeast and south (2015-2017). Similarly, the 2001-2005 Kuruman

data had more prevalent north-westerly winds with a shift to more westerly winds in the later dataset.



Annual Wind Rose 2015 Annual Wind Rose 2016 Annual Wind Rose 2017

Figure 5: Period and annual wind roses (SAWS Kuruman data; 2015, 2016 and 2017)

Period Daytime Night-time

Figure 6: Period, daytime and nigh-time wind roses (SAWS Kuruman data; 2015 to 2017)

According to the Beaufort wind force scale (https://www.metoffice.gov.uk/guide/weather/marine/beaufort-scale), wind speeds

between 6-8 m/s equates to a moderate breeze, with wind speeds between 14-17 m/s near gale force winds. Based on the

three years of SAWS data, wind speeds exceeding 6 m/s occurred for only 1% of the time, with a maximum wind speed of

10 m/s. The average wind speed over the three years was 2.06 m/s. Calm conditions (wind speeds < 1 m/s) occurred for 17%

of the time (Figure 7). The US EPA indicates a friction velocity of 5.4 m/s to initiate erosion from a coal storage piles (US EPA,

2006) and (Mian & Yanful, 2003). Thus, the likelihood exists for wind erosion to occur from open and exposed surfaces, with

loose fine material, when the wind speed exceeds at least 5.4 m/s. Wind speeds exceeding 5.4 m/s occurred only for 2% over

the three years (2015 -2017).



Figure 7: Wind speed categories (SAWS Kuruman data; 2015 to 2017)

3.2.2 Temperature

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

the plume and the ambient air, the higher a pollution plume is able to rise and determining the development of the mixing and

inversion layers). The monthly temperature pattern is provided in Table 7. The area experiences hot temperatures during

summer, with maximum of 42.6°C for the month of January. Winter temperatures are relatively low especially in the months

of June to August. Daily maximum temperatures range between 43°C in January to 25°C in June, with daily minima between

-4.2°C in August to 10°C in January.

Table 7: Minimum, average and maximum temperatures (SAWS Kuruman data; 2015 to 2017)

Jan Feb March April May June July Aug Sep Oct Nov Dec

Min 10.1 10 6.4 3.3 2 -3.2 -3.9 -4.2 2.2 2.7 4.3 9.6

Ave 25.1 24.3 22.2 17.9 14.0 10.7 10.8 13.8 18.5 21.7 23.5 26.4

Max 42.6 38.8 35.6 35.3 28.8 25.3 27.1 31.3 34.7 38.5 39.5 39.9

3.2.3 Precipitation

Precipitation is important to air pollution studies since it represents an effective removal mechanism for atmospheric pollutants

and inhibits dust generation potentials. Monthly rainfall for Kuruman is shown in Figure 8. Months wherein the most rain

occurred ranged between October and May. The most rain was received during the months of January and February in 2017,

and April 2016. Total rainfall during 2015 was 397.6 mm, 821.6 mm in 2016 and 498.4 mm in 2017.



Figure 8: Monthly precipitation (SAWS Kuruman data; 2015 to 2017)

3.2.4 Atmospheric Stability

The new generation air dispersion models differ from the models traditionally used in several aspects, the most important of

which are the description of atmospheric stability as a continuum rather than discrete classes. The atmospheric boundary

layer properties are therefore described by two parameters; the boundary layer depth and the Monin-Obukhov length, rather

than in terms of the single parameter Pasquill Class. The Monin-Obukhov length (LMO) provides a measure of the importance

of buoyancy generated by the heating of the ground and mechanical mixing generated by the frictional effect of the earth’s

surface. Physically, it can be thought of as representing the depth of the boundary layer within which mechanical mixing is the

dominant form of turbulence generation (CERC, 2004).

The atmospheric boundary layer constitutes the first few hundred metres of the atmosphere. During the daytime, the

atmospheric boundary layer is characterised by thermal turbulence due to the heating of the earth’s surface and the

predominance of an unstable layer. In unstable conditions, ground level pollution is readily dispersed thereby reducing ground

level concentrations. Night-times are characterised by weak vertical mixing and the predominance of a stable layer. These

conditions are normally associated with low wind speeds and less dilution potential. During windy and/or cloudy conditions,

the atmosphere is normally neutral.

Atmospheric stability is frequently categorised into one of six stability classes – these are briefly described in Table 8. For low

level releases, such as activities associated with mining operations, the highest ground level concentrations would occur

during weak wind speeds and stable (night-time) atmospheric conditions. However, windblown dust will occur under high

winds, thus more likely neutral conditions.

Table 8: Atmospheric stability classes and percentage occurrence (SAWS Kuruman data; 2015 to 2017)

Designation Stability Class Atmospheric Condition

A Very unstable calm wind, clear skies, hot daytime conditions

B Moderately unstable clear skies, daytime conditions

C Unstable moderate wind, slightly overcast daytime conditions

D Neutral high winds or cloudy days and nights

E Stable moderate wind, slightly overcast night-time conditions

F Very stable low winds, clear skies, cold night-time conditions

http://www.enviropedia.org.uk/Air_Quality/Measuring.php



3.3 Baseline Air Quality

3.3.1 Dustfall Monitoring network

A dustfall monitoring network is in place at Mamatwan Mine, comprising of eight (8) single dustfall units (one has been

decommissioned) and three (3) directional dustfall units. Since the NDCRs are based on single dustfalll units following the

ASTM D1739 method, the directional units cannot be compared to the NDCR limits. Dustfall results for the period

January 2018 to December 2018 for the single units are provided in Table 9. The dustfall locations are shown in Figure 9.

Figure 9: Monitoring Network at Mamatwan Mine

The dustfall over the year 2018 and 2019 was low and well below the NDCR for residential (600 mg/m²/day) and non-

residential areas (1 200 mg/m²/day). The highest dustfall rates were recorded at MMT07 for most of the months. The annual

average ranged between 48 mg/m²/day (MMT05) to 151 mg/m²/day (MMT07).

Table 9: Dustfall rates from the single dustfall units at Mamatwan Mine in 2018

Jan-18

Feb-18

Mar-18

Apr-18

May-18

Jun-18

Jul-18(a)

Aug-18

Sep-18(a)

Oct-18(b)

Nov-18

Dec-18(a)

MMT01 180 150 26 94 111 126 196 ND 27 124 ND 108

MMT02 128 127 54 39 44 56 57 ND 45 80 80 123

MMT03 87 74 57 89 60 84 147 ND 134 118 67 207

MMT04 63 52 19 84 119 39 35 ND 50 124 33 30

MMT05 131 38 18 16 33 8 67 ND 59 81 45 32

MMT06 Decommissioned

MMT07 252 241 109 97 228 147 75 ND 101 201 173 38

MMT08 153 68 47 118 212 90 49 ND 58 62 58 57

MMT09 58 97 41 51 74 24 214 ND 69 136 82 175

Notes: (a) Samples were over exposed (more than the allowable 30(±2) days

(b) Samples were under exposed (less than the allowable 30(±2) days

ND – No Data



Table 10: Dustfall rates from the single dustfall units at Mamatwan Mine in 2019

Jan-19 Feb-19 Mar-19 Apr-19 May-19 Jun-19 Jul-19 Aug-19 Sep-19 Oct-19 Nov-19 Dec-19

MMT01 98 49 205 89 248 95 271 464 162 196 339 843

MMT02 51 ND 233 102 126 87 107 223 135 166 188 144

MMT03 87 68 124 47 18 39 71 143 76 ND 119 98

MMT04 40 111 76 20 149 84 98 109 64 21 90 47

MMT05 63 137 108 29 169 76 92 164 51 61 170 76

MMT06 Decommissioned

MMT07 86 85 119 60 119 34 83 220 38 99 122 38

MMT08 102 79 89 32 73 16 46 58 56 48 52 66

MMT09 94 80 ND 87 88 76 117 146 ND 65 124 35

Notes: ND – No Data

To assess or identify trends in dustfall rates, a box-and-whisker plot of on-site dustfall rates samples for the calendar year

2018 is included in Figure 10 and Figure 11. A box-and-whisker plot shows the median, the upper quartile (25% of data

greater than the median), lower quartile (25% of data less than the median), and the minimum and maximum values. Dustfall

rates varied throughout the year with the highest 2018 rates collected during the summer months (Jan, Feb and Dec) as well

as during May and July. During 2019, the highest dustfall rates were during March, May and November. There is no clear

seasonal trend which indicated varying operations at and around the mine.

Figure 10: Box-and-whisker plot of on-site dustfall for the year 2018



Figure 11: Box-and-whisker plot of on-site dustfall for the year 2019



4 QUALITATIVE AIR QUALITY ASSESSMENT

4.1 2019 Air Quality Impact Assessment

An air quality study was conducted in 2019 for the Mamatwan Sinter Plant Application for Postponement of Compliance

timeframes. The study assessed only source activities associated with the Sinter plant, so no mining related activities formed

part of the AIR (Golder Associates Africa, 2019). A comprehensive air quality impact assessment, where all sources of air

pollution associated with the Mamatwan mining and processing operations are assessed, is currently underway as part of the

EMPr amendment.

As part of the AIR, dispersion simulations were undertaken for PM10, SO2 and NO2 from the sinter plant operations only.

Modelled results indicated low ground level concentrations at all receptors for all pollutants compared against the relevant

NAAQS.

Impact from the mining operations are expected to result in higher PM10 and PM2.5 ground level concentrations with the

potential for exceedances of the NAAQS at the nearby AQSRs. This will be determined as part of the AQIA currently underway.

Dust fallout rates are expected to be high close to the source but unlikely to exceed the NDCR off-site and at any of the

AQSRs. The expected low dust fallout impacts are supported by the dust fallout results for 2018 (see Section 3.3.1).

4.2 Qualitative Air Quality Impact Assessment for Section 24G Activities

The Section 24G activities with associated air pollutants are listed in Table 2 and the location of the activities shown in Figure 2.

The main pollutant of concern from these activities is PM, with concern for health impacts from PM10 and PM2.5 concentrations

and nuisance impacts from dust fallout.

4.2.1 Adams Pit

Adams pit is used for the following:

• Disposal of general waste, which include old and used conveyors and metal - this forms part of current mine

practices.

• Storage of Sinter de-dust stored in de-dust bags from the Sinter plant – this forms part of current mine practices.

All material is transported via trucks to the pit. It is not known whether the trucks are covered or open, so it was assumed to

be open.

PM comprising of Sinter de-dust may arise from the trucks under windy conditions and when the material is tipped into the pit.

The road is approximately 1 km long of which about 860 m is orientated in a north-westerly direction from the plant to the pit.

The prevailing wind direction is from the south-southwest and south, and associated with low wind speeds. Likely impacts

under these conditions should be to the north and north-northwest of the road and pit. The low wind speeds associated with

the prevailing winds, reduce the likelihood for windblown dust from the open trucks for most of the time. The likelihood exists

for wind erosion to occur from the open trucks when the wind speed exceeds at least 5.4 m/s (US EPA, 2006 and Mian &

Yanful, 2003), and this occurred only for 2% over the three years (2015 -2017). Also, the high wind speeds are mostly

associated with westerly winds (Section 3.2.1). Thus, under these westerly high wind speed conditions, the potential exist for

PM10 and PM2.5 impacts to the east of the plant.



As a screening exercise to determine the maximum distance of likely impacts from the road under windy westerly conditions,

the SCREEN32 model was used. The truck on the road was modelled as an area source (assumed to be a four wheeler tipper

truck with dimensions of 6.9 m long, 3 m wide and 2.9 m high) and an emission rate of 1 g/m²/s. A single neutral stability class

(see Table 8) was used and a wind speed of 5.4 m/s. The aim of the exercise is to show that the ground level concentrations

decrease significantly up to a distance of 250 m from the truck (Figure 12). The boundary is at a minimum distance about 500

m from the road thus off-site impacts are expected to be low with no AQSR within this zone.

Figure 12: Impact distance from the conveyor assuming an emission rate

Tipping of Sinter de-dust into the open pit should not result in significant off-site impacts. The pit depth at the tip-point is about

23 m (Google Earth) and thus the dust generation will be below the surface level allowing for pit retention, likely to result in

low concentrations at the surface.

4.2.2 North-Eastern Topsoil Stockpile

The approved 2005 EMPr makes provision for the storage of topsoil on a topsoil stockpile, but the existing north-eastern

topsoil stockpile located to the east of the north eastern WRD was not included.

The main activity to result in PM is wind erosion from the north-eastern topsoil stockpile, and the clearing of indigenous

vegetation.

Wind erosion is a complex process, including three different phases of particle entrainment, transport and deposition. It is

primarily influenced by atmospheric conditions (e.g. wind, precipitation and temperature), soil properties (e.g. soil texture,

composition and aggregation), land-surface characteristics (e.g. topography, moisture, aerodynamic roughness length,

vegetation and non-erodible elements) and land-use practice (e.g. farming, grazing and mining) (Shao, 2008).

For wind erosion to occur, the wind speed needs to exceed a certain threshold, called the threshold velocity. This relates to

gravity and the inter-particle cohesion that resists removal. Surface properties such as material texture, material moisture and

vegetation cover influence the removal potential. Conversely, the friction velocity, or wind shear at the surface, is related to

atmospheric flow conditions and surface aerodynamic properties. Thus, for particles to become airborne, the wind shear at

2 The South African Regulations on Dispersion Modelling (DEA, 2014) indicates that screening models, such as the US EPA SCREEN3,

are adequate in Level 1 screening assessments which aim to reflect the worst-case air quality impacts. The purpose of these Level 1

assessments is to preliminary identify air quality issues associated with new sources and to determine if more detailed assessments are

needed. SCREEN3, a Gaussian plume model that can provide maximum ground level concentrations for point, area, flare, and volume

sources were used in this assessment (US EPA, 1992).



the surface must exceed the gravitational and cohesive forces acting upon them, called the threshold friction velocity (Shao,

2008).

Estimating the number of windblown particles to be generated from exposed surfaces is not a trivial task and requires detailed

information on the particle size distribution, moisture content, silt content and bulk density. Dust will only be generated under

conditions of high wind speed which is likely to occur when the wind exceeds 5.4 m/s (US EPA, 1995). The US EPA emission

factors apply only to dry, exposed surfaces of mixed size aggregate with limited erosion potential. These emission factors

were based on the highest wind speed event occurring between material disturbances. A uniform particle distribution was

assumed and variations in moisture content, particle density, roughness elements or large surface areas have not been

considered (US-EPA, 1996).

The potential for windblown dust from the exposed surfaces of the north-eastern topsoil stockpile exists when the wind speed

exceeds 5.4 m/s. As indicated under the previous section, wind speeds at Mamatwan only exceed 5.4 m/s for 2% of the time

and is mostly under westerly wind conditions. Similar to wind erosion from the truck, the impacts from windblown topsoil is

likely to impact near the source and reduce rapidly. The significance of the impacts would however depend on the height and

footprint of the exposed area of the north-eastern topsoil stockpile.

Land clearing activities using dozers and scrapers could result in significant dust generation. Again, the significance from

these activities would depend on the duration of scraping and grading as well as the size of the area being cleared.

4.2.3 Cumulative Impacts

When considered cumulatively in the context of the existing MMT operations, the project activities present additional emission

sources that generate dust fallout when considered in the context of existing sources at the MMT. Dust fallout monitoring

results from MMT for the period 2018 to 2019 indicate low dust fallout rates, well below the NDCR limit for residential areas

(600 mg/m²/day) and non-residential areas (1 200 mg/m²/day).

Modelled results from the 2019 AIR indicated very low PM10 concentrations from the Sinter plant operations (Golder Associates

Africa, 2019), but these results excluded the mining sources. Thus, the contribution from the mining operations, both from

MMT and the neighbouring Tshipi Borwa Mine, are likely to result in significant off-site PM10 and PM2.5 concentrations. The

contributions from the various Section 24G activities (windblown dust from the open trucks, dust from tipping of material into

the pit, windblown dust from the north-eastern topsoil stockpile and land clearing activities for the north-eastern topsoil

stockpile) are likely to be concealed by the mining operations contribution. With mitigation in place at these activities, the

contribution is likely to be of a low significance.

4.3 Management and Mitigation Measures

4.3.1 Adams Pit

The following mitigation measures could be applied to the conveyor and at the tipping points:

• Covering the trucks should reduce the potential for windblown dust significantly. Alternatively, the material can be sprayed

on the truck to reduce the potential for windblown dust.

• Mitigation of materials transfer points could be done using water sprays at the tip points – this should result in a 50% CE.

Tipping of the material should be done as far down in the pit as possible, to be below the surface. Furthermore, it is

recommended that material drop heights be minimized.



4.3.2 North-Eastern Topsoil Stockpile

Mitigation of wind erosion from the north-eastern topsoil stockpile could include:

• Water sprays should be used to keep surface material moist and wind breaks installed to reduce wind speeds over the

area. Even though high wind speeds are limited, given that this is a dry environment, wind breaks are advised. A control

efficiency of 50% is anticipated. (NPI, 2012).

• Any binding properties would reduce the potential for wind erosion from the north eastern topsoil stockpile. One of the

most effective measures of minimizing wind erosion emissions is to vegetate the exposed areas, and to re-vegetate when

required to ensure full vegetation cover at all times. The control efficiency of vegetation is given as 40% for non-sustaining

vegetation and 90% for re-vegetation. Secondary rehabilitation would up the control efficiency to 60% for non-sustaining

vegetation (NPI, 2012).



5 CONCLUSION AND RECOMMENDATIONS

5.1 Main Findings

The main findings from the qualitative assessment of the Section 24G activities at MMT are as follow:

• The main pollutant of concern from all the Section 24G activities is PM, with PM10 and PM2.5 concentrations related to

health impacts and dust fallout related to nuisance impacts.

• The disposal of general waste (old and used conveyors and metal) to Adams Pit and the storage of Sinter de-dust to

Adam’s pit is done using trucks. PM from Sinter de-dust may arise from the open trucks under windy conditions and when

the material is tipped into the pit. The likelihood exists for wind erosion to occur during high wind speeds, which are mostly

associated with westerly winds. Under these conditions there is a potential for PM10 and PM2.5 impacts to the east of the

plant but these concentrations are likely to be high close to the source and decrease rapidly up to a distance of 250 m

with no AQSR within this zone.

• Tipping of Sinter de-dust into Adam’s pit is unlikely to result in significant off-site impacts since dust generation from the

tipped material is below surface level (in the pit), allowing for pit retention to dilute the concentrations before reaching the

surface.

• The potential for windblown dust from the exposed surfaces of the north-eastern topsoil stockpile exists under strong

wind conditions. The impacts from windblown topsoil is likely to be high near the north-eastern topsoil stockpile and

reduce significantly further away from the stockpile. The significance of the impacts would however depend on the height

and footprint of the exposed areas of the stockpile.

• Land clearing activities (particularly for the establishment of the north eastern topsoil stockpile) using dozers and scrapers

could have resulted in significant dust generation, but the significance from these activities would have depended on the

duration of scraping and grading as well as the size of the area being cleared.

• Cumulatively, the contributions from the various Section 24G activities (windblown dust from open trucks, dust from

tipping of material into the pit, windblown dust from the north-eastern topsoil stockpile and land clearing activities for the

north eastern topsoil stockpile) are likely to be concealed by the current mining operations, both from MMT and the

neighbouring Tshipi Borwa Mine.

5.2 Conclusion

There is a potential for PM10 and PM2.5 ground level concentrations in excess of the NAAQSs off-site from the Section 24G

activities but with mitigation measures in place, these impacts should be limited to site resulting in a low significance. Measured

dustfall rates, which include the Section 24G activities, are however well below the NDCRs.

5.3 Recommendations

The following mitigation measures are recommended:

• Trucks transporting material: cover the trucks or spray the material to reduce the potential for windblown dust from

the open trucks.

• Adams Pit: Materials transfer points could be managed using water sprays at the tip points – this should result in a

50% CE. Tipping of the material should be done as far down in the pit as possible, to be below the surface. The

drop height of material should be reduced to a minimum.



• North-Eastern Topsoil Stockpile: Water sprays should be used to keep surface material moist and wind breaks

installed to reduce wind speeds over the exposed areas – this should have CE of 50%. The dormant areas should

be vegetation and re-vegetated to ensure full cover at all times – this should have CE of 90%.



6 REFERENCES

CERC. (2004). ADMS Urban Training. Version 2. Unit A.

DEA . (2015). NEMAQA - National Atmospheric Emission Inventory System. Pretoria: Department of Environmental Affairs

(Government Gazette).

DEA. (2014). National Environmental Management: Air Quality Act, 39 of 2004, Regulations regarding Air Dispersion

Modelling. . Pretoria: Government Gazette 37804. Republic of South Africa: 11 July 2014.

Department of National Treasury. (2013). Carbon Tax Policy Paper.

Golder Associates Africa. (2019). Atmospheric Emissions Impact Report for Mamatwan Sinter Plant Application for

Postponement of Compliance timeframes. South32: Hotazel Manganese Mines (Pty) Limited.

Jongikhaya, W. (2015, August 6). Technical Guidelines for Monitoring, Reporting and Verification of Greenhouse Gas

Emissions by Industry.

Krause, N., & Liebenberg-Enslin, H. (2009). Air Quality Impact Assessment for the Proposed Ntsimbintle Manganese Mining.

Metago Engineering Services (Pty) Ltd.

Mian, M., & Yanful, E. (2003). Tailings erosion and resuspension in two mine tailings ponds due to wind waves. Advances in

Environmental Research, 7, 745-765.

NPI. (2012). Emission Estimation Technique Manual for Mining. Version 3.1. Australian Government Department of

Sustainability, Environment, Water, Population and Communities.

Shao, Y. (2008). Physics and Modelling of Wind Erosion. Atmospheric and Oceanographic Science Library, 2nd Revised and

Expanded Edition. Springer Science .

US EPA. (1992). Fugitive Dust Background Document and Technical Information Document for Best Available Control

Measures, EPA-450/2-92-004,. Retrieved from S Environmental Protection Agency: http://www.epa.gov

US EPA. (1995). AP-42, 5th Edition, Volume I, Chapter 13: Miscellaneous Sources, 13.2.3 Heavy Construction Operations.

Retrieved from United States Environmental Protection Agency: http://www.epa.gov/ttn/chief/ap42/

US EPA. (2006, June). Emission Factor Documentation for AP-42 Section 11.12. . Retrieved from Unites Tates Enviroinmental

Protection Agency AP42: http://www.epa.gov/ttnchief/ap42/

US-EPA. (1996). AP42, Fifth Edition, Volume I, Chapter 9: Food and Agricultural Industries, 9.12.1 Malt Beverages. Research

Triangle, North Carolina: United States Environmental Protection Agency.



7 APPENDIX A - SPECIALIST CURRICULUM VITAE

CURRICULUM VITAE HANLIE LIEBENBERG-ENSLIN

FULL CURRICULUM VITAE

Name of Firm Airshed Planning Professionals (Pty) Ltd

Name of Staff Hanlie Liebenberg-Enslin

Profession Managing Director / Air Quality Scientist

Date of Birth 09 January 1971

Years with Firm/ entity 18 years

Nationalities South African

MEMBERSHIP OF PROFESSIONAL SOCIETIES

• International Union of Air Pollution Prevention and Environmental Protection Associations (IUAPPA) – President 2010–

2013, Board member 2013-present

• Member of the National Association for Clean Air (NACA) - President 2008-2010, NACA Council member 2010 –2014

KEY QUALIFICATIONS

Hanlie Liebenberg-Enslin started her professional career in Air Quality Management in 2000 when she joined Environmental

Management Services (EMS) after completing her Master’s Degree at the University of Johannesburg (then Rand Afrikaans

University) in the same field. She is one of the founding members of Airshed Planning Professionals in 2003 where she has

worked as a company Director until May 2013 when she was appointed as Managing Director. She has extensive experience

on the various components of air quality management including emissions quantification for a range of source types,

simulations using a range of dispersion models, impacts assessment and health risk screening assessments. She has worked

all over Africa and has an inclusive knowledge base of international legislation and requirements pertaining to air quality.

She has developed technical and specialist skills in various modelling packages including the industrial source complex

models (ISCST3 and SCREEN3), EPA Regulatory Models (AERMOD and AERMET), UK Gaussian plume model (ADMS),

EPA Regulatory puff-based model (CALPUFF and CALMET), puff-based HAWK model and line based models such as

CALINE. Her experience with emission models includes Tanks 4.0 (for the quantification of tank emissions) and GasSim (for

the quantification of landfill emissions).

Having worked on projects throughout Africa (i.e. South Africa, Mozambique, Botswana, Namibia, Malawi, Kenya, Mali,

Democratic Republic of Congo, Tanzania, Madagascar, Guinea and Mauritania) Hanlie has developed a broad experience

base. She has a good understanding of the laws and regulations associated with ambient air quality and emission limits in

South Africa and various other African countries, as well as the World Bank Guidelines, European Community Limits and

World Health Organisation.

Being an avid student, she received her PhD in 2014, specialising in Aeolian dust transport. Hanlie is also actively involved in

the National Association for Clean Air and is their representative at the International Union of Air Pollution Prevention and

Environmental Protection Associations.



RELEVANT EXPERIENCE

Air Quality Management Plans and Strategies

Vaal Triangle Airshed Priority Area AQMP Review (August 2017 to July 2019); Strategic Environmental Management Plan Air

Quality Management Plan for the Erongo Region Update (May 2016 to February 2019); Provincial Air Quality Management

Plan for the Limpopo Province (March 2013); Mauritius Road Development Agency Proposed Road Decongestion Programme

(July 2013); Transport Air Quality Management Plan for the Gauteng Province (February 2012); Gauteng Green Strategy

(2011); Air Quality and Radiation Assessment for the Erongo Region Namibia as part of a Strategic Environmental Assessment

(June, 2010); Vaal Triangle Airshed Priority Area AQMP (March, 2009); Gauteng Provincial AQMP (January 2009); North

West Province AQMP (2008); City of Tshwane AQMP (April 2006); North West Environment Outlook 2008 (December 2007);

Ambient Monitoring Network for the North West Province (February 2007); Spatial Development Framework Review for the

City of uMhlathuze (August 2006); Ambient Particulate Pollution Management System (Anglo Platinum Rustenburg):

Hanlie has also been the Project Director on all the listed Air Quality Management plan developments.

Mining and Ore Handling

Hanlie has undertaken numerous air quality impact assessments and management plans for coal, platinum, uranium, copper,

cobalt, chromium, fluorspar, bauxite and mineral sands mines. These include air quality impact assessments for: Trekkopje

Uranium Mine near Swakopmund; Bannerman Uranium Project; Langer Heinrich Uranium Mine, Valencia Uranium Mine,

Etango (Husab) Project, Rössing South Uranium Mine (Namibia); Sishen Iron Ore Mine (Kathu); Kolomela Iron Ore Mine

(Postmasburg); Thabazimbi Iron ore Mine (Thabazimbi); UKM Manganese Mine (Hotazel); Everest Platinum Mine

(Steelpoort); Murowa Diamond Mine (Zimbabwe); Jwaneng Diamond Mine (Botswana); Sadiola Gold Mine (Mali); North Mara

Gold Mine (Tanzania); Tselentis Coal mine (Breyeton); Lime Quarries (De Hoek, Dwaalboom, Slurry); Beesting Colliery

(Ogies); Anglo Coal Opencast Coal Mine (Heidelberg); Klippan Colliery (Belfast); Beesting Colliery (Ogies); Xstrata Coal

Tweefontein Mine (Witbank); Xstrata Coal Spitskop Mine (Hendrina); Middelburg Colliery (Middelburg); Klipspruit Project

(Ogies); Rustenburg Platinum Mine (Rustenburg); Impala Platinum (Rustenburg); Buffelsfontein Gold Mine (Stilfontein);

Kroondal Platinum Mine (Kroondal); Lonmin Platinum Mine (Mooinooi); Rhovan Vanadium (Brits); Macauvlei Colliery

(Vereeniging); Voorspoed Gold Mine (Kroonstad); Pilanesberg Platinum Mine (Pilanesberg); Kao Diamond Mine (Lesotho);

Modder East Gold Mine (Brakpan); Modderfontein Mines (Brakpan); Bulyanhulu North Mara Gold Mine (Tanzania); Gold Mine

(Tanzania); Zimbiwa Crusher Plant (Brakpan); RBM Zulti South Titanium mining (Richards Bay); Premier Diamond Mine

(Cullinan).

Metal Recovery

Air quality impact assessments have been carried out for Smelterco Operations (Kitwe, Zimbia); Waterval Smelter (Amplats,

Rustenburg); Hernic Ferrochroime Smelter (Brits); Rhovan Ferrovanadium (Brits); Impala Platinum (Rustenburg); Impala

Platinum (Springs); Transvaal Ferrochrome (now IFM, Mooinooi), Lonmin Platinum (Mooinooi); Xstrata Ferrochrome Project

Lion (Steelpoort); ArcelorMittal South Africa (Vandebijlpark, Vereeniging, Pretoria, Newcastle, Saldanha); Hexavalent Chrome

Xstrata (Rustenburg); Portland Cement Plant (DeHoek, Slurry, Dwaalboom, Hercules, Port Eelizabeth); Vantech Plant

(Steelpoort); Bulyanhulu Gold Smelter (Tanzania), Sadiola Gold Recovery Plant (Mali); RBM Smelter Complex (Richards Bay

); Chibuto Heavy Minerals Smelter (Mozambique); Moma Heavy Minerals Smelter (Mozambique); Boguchansky Aluminium

Plant (Russia); Xstrata Chrome CMI Plant (Lydenburg); SCAW Metals (Germiston).

Chemical Industry

Comprehensive air quality impact assessments have been completed for AECI (Pty) Ltd Operations (Modderfontein); Kynoch

Fertilizer (Potchefstroom), Foskor (Richards Bay) and Omnia (Rustenburg).



Petrochemical Industry

Numerous air quality impact assessments have been completed for SASOL operations (Sasolburg); Sapref Refinery (Durban);

Health risk assessment of Island View Tank Farm (Durban Harbour).

Pulp and Paper Industry

Air quality studies have been undertaken or the expansion of Mondi Richards Bay, Multi-Boiler Project for Mondi Merebank

(Durban), impact assessments for Sappi Stanger, Sappi Enstra (Springs), Sappi Ngodwana (Nelspruit) and Pulp United

(Richards Bay).

Power Generation

Air quality impact assessments have been completed for numerous Eskom coal fired power station studies including the Coal

3 Power Project near Lephalale, Komati Power Station and Lethabo Power Stations. In addition to Eskom’s coal fired power

stations, projects have been completed for the proposed Mmamabula Energy Project (Botswana); Morupule Power Plant

(Botswana); NamPower Van Eck Power Station; NamPower Erongo Power Project (Namibia).

Apart from Eskom projects, heavy fuel oil power station assessments have also been completed in Kenya (Rabai Power

Station) and Namibia (Arandis Power Plant).

Waste Disposal

Air quality impact assessments, including odour and carcinogenic and non-carcinogenic pollutants were undertaken for the

proposed Coega Waste Disposal Facility (Port Elizabeth); Boitshepi Waste Disposal Site (Vanderbijlpak); Umdloti Waste

Water Treatment Plant (Durban).

Cement Manufacturing

Impact assessments for ambient air quality have been completed for the PPC Cement Alternative Fuels Project (which

included the assessment of the cement manufacturing plants in the North West Province, Gauteng and Western). Air Impact

Reporrs and Pollution Prevention Plans for Lafarge Cement in the North West Province.

Vehicle emissions

Platinum Highway (N1 to Zeerust); Gauteng Development Zone (Johannesburg); Gauteng Department of Roads and

Transport (Transport Air Quality Management Plan); Mauritius Road Development Agency (Proposed Road Decongestion

Programme); South African Petroleum Industry Association (Impact Urban Air Quality).

Government Strategy Projects

Hanlie was the project Director on the APPA Registration Certificate Review Project for Department of Environmental Affairs

(DEA); Green Strategy for Gauteng (2011).



EDUCATION

Ph.D Geography University of Johannesburg, RSA (2014)

Title: A functional dependence analysis of wind erosion modelling system

parameters to determine a practical approach for wind erosion assessments

M.Sc Geography and

Environmental Management

University of Johannesburg, RSA (1999)

Title: Air Pollution Population Exposure Evaluation in the Vaal Triangle using GIS

B.Sc Hons. Geography University of Johannesburg, RSA (1995)

GIS & Environmental Management

B.Sc Geography and Geology University of Johannesburg, RSA (1994)

Geography and Geology

ADDITIONAL COURSES AND ACADEMIC REVIEWS

External Examiner

(January 2018) MSc Candidate: Ms B Wernecke

Ambient and Indoor Particulate Matter Concentrations on the Mpumalanga Highveld

Department of Geography and Environmental Management, North-West University

External Examiner

(January 2016) MSc Candidate: Ms M Grobler

Evaluating the costs and benefits associated with the reduction in SO2 emissions

from Industrial activities on the Highveld of South Africa

Department of Chemical Engineering, University of Pretoria

External Examiner MSc Candidate: Ms Seneca Naidoo

(August 2014) Quantification of emissions generated from domestic fuel burning activities from

townships in Johannesburg

Faculty of Science, University of the Witwatersrand

Air Quality Law – Lecturer (2012

-2016)

Environmental Law course: Centre of Environmental Management.

Air Quality law for Mining –

Lecturer (2014)

Environmental Law course: Centre of Environmental Management.

Air Quality Management –

Lecturer (2006 -2012)

Air Quality Management Short Course: NACA and University of Johannesburg,

University of Pretoria and University of the North West

ESRI SA (1999) ARCINFO course at GIMS: Introduction to ARCINFO 7 course

ESRI SA (1998) ARCVIEW course at GIMS: Advanced ARCVIEW 3.1 course



COUNTRIES OF WORK EXPERIENCE

South Africa, Mozambique, Botswana, Namibia, Malawi, Mauritius, Kenya, Mali, Zimbabwe, Democratic Republic of Congo,

Tanzania, Zambia, Madagascar, Guinea, Russia, Mauritania and Saudi Arabia.

EMPLOYMENT RECORD

March 2003 - Present

Airshed Planning Professionals (Pty) Ltd, (previously known as Environmental Management Services cc until March 2003),

Managing Director and Principal Air Quality Scientist, Midrand, South Africa.

January 2000 – February 2003

Environmental Management Services CC, Senior Air Quality Scientist.

May 1998 – December 1999

Independent Broadcasting Authority (IBA), GIS Analyst and Demographer.

February 1997 – April 1998

GIS Business Solutions (PQ Africa), GIS Analyst

January 1996 – December 1996

Annegarn Environmental Research (AER), Student Researcher

LANGUAGES

Speak Read Write

English Excellent Excellent Excellent

Afrikaans Excellent Excellent Excellent

CONFERENCE AND WORKSHOP PRESENTATIONS AND PAPERS

• Understanding the Atmospheric Circulations that lead to high particulate matter concentrations on the west coast of

Namibia. Hanlie Liebenberg-Enslin, Hannes Rauntenbach, Reneé von Gruenewaldt, and Lucian Burger. Clean Air

Journal, 27, 2, 2017, 66-74.

• Cooperation on Air Pollution in Southern Africa: Issues and Opportunities. SLCPs: Regional Actions on Climate and Air

Pollution. Liebenberg-Enslin, H. 17th IUAPPA World Clean Air Congress and 9th CAA Better Air Quality Conference. Clean

Air for Cities - Perspectives and Solutions. 29 August - 2 September 2016, Busan Exhibition and Convention Center,

Busan, South Korea.



• A Best Practice prescription for quantifying wind-blown dust emissions from Gold Mine Tailings Storage Facilities.

Liebenberg-Enslin, H., Annegarn, H.J., and Burger, L.W. VIII International Conference on Aeolian Research, Lanzhou,

China. 21-25 July 2014.

• Quantifying and modelling wind-blown dust emissions from gold mine tailings storage facilities. Liebenberg-Enslin, H.

and Annegarn, H.J. 9th International Conference on Mine Closure, Sandton Convention Centre, 1-3 October 2014.

• Gauteng Transport Air Quality Management Plan. Liebenberg-Enslin, H., Krause,N., Burger, L.W., Fitton, J. and

Modisamongwe, D. National Association for Clean Air Annual Conference, Rustenburg. 31 October to 2 November 2012.

Peer reviewed.

• Developing an Air Quality Management Plan: Lessons from Limpopo. Bird, T.; Liebenberg-Enslin, H., von Gruenewaldt,

R., Modisamongwe, D. National Association for Clean Air Annual Conference, Rustenburg. 31 October to 2 November

2012. Peer reviewed.

• Modelling of wind eroded dust transport in the Erongo Region, Namibia, H. Liebenberg-Enslin, N Krause and H.J.

Annegarn. National Association for Clean Air (NACA) Conference, October 2010. Polokwane.

• The lack of inter-discipline integration into the EIA process-defining environmental specialist synergies. H. Liebenberg-

Enslin and LW Burger. IAIA SA Annual Conference, 21-25 August 2010. Workshop Presentation. Not Peer Reviewed.

• A Critical Evaluation of Air Quality Management in South Africa, H Liebenberg-Enslin. National Association for Clean Air

(NACA) IUAPPA Conference, 1-3 October 2008. Nelspuit.

• Vaal Triangle Priority Area Air Quality Management Plan – Baseline Characterisation, R.G. Thomas, H Liebenberg-

Enslin, N Walton and M van Nierop. National Association for Clean Air (NACA) conference, October 2007, Vanderbijl

Park.

• Air Quality Management plan as a tool to inform spatial development frameworks – City of uMhlathuze, Richards Bay, H

Liebenberg-Enslin and T Jordan. National Association for Clean Air (NACA) conference, 29 – 30 September 2005, Cape

Town.

CERTIFICATION

I, the undersigned, certify that to the best of my knowledge and belief, these data correctly describe me, my qualifications,

and my experience.

26/04/2019

Full name of staff member: Hanlie Liebenberg-Enslin

Mamatwan Mine Environmental Management Plan Amendment: …

Documents

Transcript of Mamatwan Mine Environmental Management Plan Amendment: …