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
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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
Mamatwan Mine Environmental Management Plan Amendment: Air Quality Specialist Opinion as part of the Section 24G Requirements
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
Mamatwan Mine Environmental Management Plan Amendment: Air Quality Specialist Opinion as part of the Section 24G Requirements
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 3.3: Baseline Air Quality
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
Section 3.3: Baseline Air Quality
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
Section 4.2: Qualitative Air Quality Assessment
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.
Section 4.2: Qualitative Air Quality Assessment
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
Mamatwan Mine Environmental Management Plan Amendment: Air Quality Specialist Opinion as part of the Section 24G Requirements
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.
Mamatwan Mine Environmental Management Plan Amendment: Air Quality Specialist Opinion as part of the Section 24G Requirements
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
Mamatwan Mine Environmental Management Plan Amendment: Air Quality Specialist Opinion as part of the Section 24G Requirements
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
Mamatwan Mine Environmental Management Plan Amendment: Air Quality Specialist Opinion as part of the Section 24G Requirements
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.
Mamatwan Mine Environmental Management Plan Amendment: Air Quality Specialist Opinion as part of the Section 24G Requirements
2.1 National Framework ............................................................................................................................................... 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
5 Conclusion and Recommendations................................................................................................................................ 24
5.1 Main Findings ....................................................................................................................................................... 24
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 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 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
Mamatwan Mine Environmental Management Plan Amendment: Air Quality Specialist Opinion as part of the Section 24G Requirements
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.
Mamatwan Mine Environmental Management Plan Amendment: Air Quality Specialist Opinion as part of the Section 24G Requirements
Report No.: 18SLR23 2
Figure 1: Mamatwan Mine mining and processing infrastructure
Mamatwan Mine Environmental Management Plan Amendment: Air Quality Specialist Opinion as part of the Section 24G Requirements
Report No.: 18SLR23 3
Figure 2: Process flow diagram
Mamatwan Mine Environmental Management Plan Amendment: Air Quality Specialist Opinion as part of the Section 24G Requirements
Report No.: 18SLR23 4
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
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
Mamatwan Mine Environmental Management Plan Amendment: Air Quality Specialist Opinion as part of the Section 24G Requirements
Report No.: 18SLR23 5
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
Mamatwan Mine Environmental Management Plan Amendment: Air Quality Specialist Opinion as part of the Section 24G Requirements
Report No.: 18SLR23 6
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.
Mamatwan Mine Environmental Management Plan Amendment: Air Quality Specialist Opinion as part of the Section 24G Requirements
Report No.: 18SLR23 7
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)
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Report No.: 18SLR23 8
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
Mamatwan Mine Environmental Management Plan Amendment: Air Quality Specialist Opinion as part of the Section 24G Requirements
Report No.: 18SLR23 9
Table 4: Applicable Listed Activity for Sinter Plant Operations