A GENERIC ENVIRONMENTAL MANAGEMENT PLAN FOR COAL-FIRED POWER STATIONS
By
ADRIANA BOTHMA
SCRIPTION
Presented in partial fulfillment of the requirements for the Degree
MASTER IN SCIENCE
In
ENVIRONMENTAL MANAGEMENT
In the
FACULTY OF SCIENCE
At the
RAND AFRIKAANS UNIVERSITY
Study leader: Dr. J.M. Meeuwis
May 1998 OPSOMMING
Eskom wek 91 % van Suid-Afrika se elektriese krag op, deur middel van 10 steenkool aangedrewe kragstasies. Ses van hierdie kragstasies is in die Oostelike Haveld van Mpumalanga geled. As gevolg van die konsentrasie van kragstasies in hierdie area, het Eskom reeds etlike jare gelede besluit om die impak wat kragopwekking op die omgewing het, te ondersoek en metodes te vind om impakte te minimaliseer.
Na die identifisering van impakte is Omgewings Bestuursplanne saamgestel om die impakte te bestuur en sodoende te minimaliseer. Huidiglik het al die Eskom kragstasies Omgewings Bestuursplanne in plek. Die formaat en inhoud van die planne verskil egter van stasie tot stasie. Die Kragontwikkeling Omgewings Bestuur Groep het daarom besluit dat 'n Generiese Omgewingsplan opgestel moet word, wat as basis gebruik sal word om al die Omgewings Bestuurs Planne op dieselfde standaard te bring.
Hierdie skripsie dokument het dit dus ten doel om so 'n Generiese Omgewings Bestuurs Plan saam te stel. Literatuur studies het weinig omtrent die inhoud van so 'n bestuurs plan opgelewer en bestaande Omgewings Bestuurs Planne is bestudeer, om `n algemene formaat saam te stel.
Die formaat wat algemeen gebruik word is as volg:
Agtergrond inligting omtrent die projek (kragstasie) Wetgewing van toepassing op die projek (kragstasie) omgewing Geidentifiseerde impakte Bestuursplanne vir impakte Monitering van impakte en bestuursplanne Noodplanne Verantwoordelike persone Ouditering
Meeste van die dokumente sluit ook planne vir kommunikasie, opleiding en bewusmakings programme in, terwyl ander ook die sosiale impakte van 'n projek aanspreek. Hierdie generiese dokument konsentreer egter slegs op die natuurlike impakte van kragontwikkeling, aangesien die skripsie 'n beperking op volume het.
Uit die bestaande Omgewings Bestuursplanne wat bestudeer is, het dit duidelik geword dat die ontwikkeling van elektrisiteit in 4 areas van die natuurlike omgewing, `n invloed het, naamlik:.
Lugbesoedeling Waterbesoedeling Afvalprodusering Grondverval.
Daar is besluit om op hierdie 4 areas te konsentreer in die skripsie. Die Generiese Omgewings Bestuurs Plan wat ontwikkel is, is dus verdeel in 4 afdelings:
Lug Kwaliteit Bestuur Water Kwaliteit Bestuur Afval Bestuur Grond Bestuur.
Vir elk van hierdie afdelings, is 'n lys van generiese impakte saamgestel, met die inligting wat benodig sal word in 'n Omgewings Bestuurs Plan. Die inligting benodig sal insluit: relevante wette en Eskom beleidstukke, wat met die beheer van byvoorbeeld lug kwaliteit te make het. Detail van prosesse, instrumentasie, monitering, noodplanne, verantwoordelike en kontak persone wat beheer moet uitoefen moet in 'n bestuursplan ingesluit word.
Omgewings Bestuurs Planne is huidiglik 'n uitvloeisel van Omgewings Impak Studies wat tydens die beplannings fase van 'n projek uitgevoer word. Die Bestuurs Plan word saamgestel om te verseker dat die impakte wat geidentifiseer is en nie vermy kan word nie, beheer en bestuur word, tydens die konstruksie, operasionele en sluitings fases van die projek. Geen van die Eskom kragstasies huidiglik operasioneel, het egter Omgewings Impak Studies ondergaan nie. Die Omgewings Bestuurs Planne is dus saamgestel op grond van kennis wat deur die jare opgebou is omtrent die impakte. Daar is bewys dat Omgewings Bestuurs Planne met groot sukses in die later fases van projekte saamgestel kan word.
`n Generiese dokument soos hier saamgestel, maak hierdie taak makliker deur 'n standaard te stel en leiding omtrent die tipe impakte wat spesifiek by steenkool bestuur moet word, te gee.
ii SUMMARY
In South Africa, Eskom generates 91 % of all electricity produced. Most of this electricity is generated by 10 coal-fired power stations, 6 of which is situated in the Eastern Highveld region of Mpumalanga. Owing to the concentration of power stations in this region, Eskom decided years ago to investigate the environmental impacts of its generation actions and develop programmes to minimise these impacts.
After the identification of the various impacts Environmental Management Plans were developed to manage and minimise the impacts. Although all the Eskom Power Stations have Environmental Management Plans in place at present, the documents differ in format and content. The Generation Environmental Management Group thus decided that a Generic Environmental Management Plan (EMP) should be developed, to ensure that station plans are developed to the same standard.
The purpose of this scription document is thus to develop such a Generic Environmental Management Plan. Literature studies revealed very little about the content of EMPs, therefore existing management plans were studied to enable the development of a general format.
The format generally used is as follows:
Background on the project (power station) Legislation applicable to the project (power station) Identified impacts Impact Management Plans Monitoring of impacts and management plans Contingency Plans Accountable personnel Auditing.
Most management plans include communication, training and awareness programmes, while others also address the social impacts of a project. This generic document will only concentrate on the impacts on the natural environment.
Studies of the existing documentation on management plans, revealed that power generation have impacts in 4 main areas of the environment, namely:
Air Pollution Water Pollution Waste Production Land Degradation.
It was decided to concentrate on these 4 areas in this scription.
iii The Generic Environmental Plan developed was thus divided into 4 section:
Air Quality Management Water Quality Management Waste management Land Management
Generic impacts, with a list of information needed were listed for each of these impact areas. Information required would include: relevant legislation, Eskom policies and standards that would influence air quality, for instance. Detail of processes, instrumentation, monitoring, contingency plans, accountable personnel and contact people must be included.
Environmental Management Plans are presently developed from impacts identified during the Environmental Impact Studies, which are conducted during the planning phases of projects. The management plan is developed to ensure that all unavoidable impacts will be managed during the construction, operational and decommissioning phases of the project. None of the present Eskom power stations had the benefit of Environmental Impact Studies, and the management Plans were thus compiled from experience gained through the years. Existing Management Plans proved that Environmental Management Plans could be developed in the later phases of a project.
A generic management plan as developed here, makes this task easier, as it sets a standard and provides a guide to the general types of impacts that must be managed at coal-fired power stations.
iv CONTENTS
LIST OF FIGURES LIST OF TABLES
POWER GENERATION IN THE EASTERN HIGHVELD OF MPUMALANGA AND ASSOCIATED ENVIRONMENTAL PROBLEMS
1.1 Introduction 1 1.2 Environmental Problems 3 1.2.1 Air Pollution 3 1.2.2 Water Pollution 6 1.2.3 Waste Production 10 1.2.4 Land Degradation 13
STATEMENT OF THE PROBLEM 14
3 THE DEVELOPMENT OF ENVIRONMENTAL MANAGEMENT PLANS
3.1 Background 16 3.2 Components of an Environmental Management Plan 17 3.3 Generic Environmental Management Plans 19
4 THE STUDY AREA
4.1 Geographic Location 21 4.2 Physical Characteristics of the Study Area 21 4.2.1 Climate 21 4.2.2 Water Supply and Hydrology 25 4.2.3 Geomorphology 27 4.2.4 Geology 28 4.2.5 Soil 28 4.2.6 Flora 29 4.2.7 Fauna 30 4.2.8 Birds 30 4.2.9 Reptiles and Amphibians 31 4.2.10 Spiders and Scorpions 31 4.2.11 Insects 31 4.2.12 Butterflies 31 4.2.13 Fish 31 4.2.14 Alien and Translocated Indigenous Aquatic Animals 32 4.2.15 Archaeology 32
v THE DEVELOPMENT OF A GENERIC ENVIRONMENTAL MANAGEMENT PLAN 33
5.1 Background Information 34
5.2 Air Quality Management 34 5.2.1 Legal Requirements 35 5.2.2 Eskom Requirements 36 5.2.3 Identified Impacts and Mitigation Measures 37 5.2.4 Accountabilities 40 5.2.5 List of Contact Numbers 40 5.2.6 Summary 41
5.3 Water Quality Management 43 5.3.1 Legal Requirements 43 5.3.2 Eskom Requirements 44 5.3.3 Identified Impacts and Mitigation Measures 44 5.3.4 Accountabilities 47 5.3.5 List of Contact Numbers 47 5.3.6 Summary 48
5.4 Waste Management 49 5.4.1 Legal Requirements 49 5.4.2 Eskom Requirements 50 5.4.3 Identified Impacts and Mitigation Measures 50 5.4.4 Accountabilities 54 5.4.5 List of Contact Numbers 54 5.4.6 Summary 54
5.5 Land Management 56 5.5.1 Legal Requirements 56 5.5.2 Eskom Requirements 56 5.5.3 Identified Impacts and Mitigation Measures 57 5.5.4 Accountabilities 60 5.5.5 List of Contact Numbers 60 5.5.6 Summary 60
CONCLUSIONS 62
REFERENCES 65
vi LIST OF FIGURES
Figure 1 Location of Coal-Fired Power Stations in the Mpumalanga 2 Highveld and Associated Coal-fields Figure 2 Particulate Emissions between 1982 to 1996 from Eskom 5 Coal-fired Power Stations Figure 3 Transportation patterns of air parcels from the Eastern 25 Highveld Region, to the Ben MacDhui monitoring station in the Eastern Cape.
LIST OF TABLES
Table 1 Emission Data for Coal-fired Power Generating Power 4 Stations Table 2 Water Utilisation by Coal-fired Power Generating Power 7 Stations Table 3 Waste Products Produced at Coal-fired Power Generation 11 Power Stations during 1996 Table 4 Land areas utilised by Coal-fired Power Generating Power 11 Stations as in 1996 Table 5 Comparison of Air Pollution Exposure Limits. 35 Table 6 Extract from the Accountability Matrix of Lethabo Power 42 Station.
vii 1. POWER GENERATION IN THE EASTERN HIGHVELD OF MPUMALANGA AND ASSOCIATED ENVIRONMENTAL PROBLEMS
`Throughout the world it is accepted that no industry can provide the goods and services that society wants without having some impact on the physical environment. But there is no disagreement that waste, pollution and other environmental challenges are serious and require immediate and continuous attention'. (Eskom, 1995b: Generation Environmental Management - Performance Review, 1)
1.1 Introduction
In South Africa 90 % of all electricity produced in the country, is generated by Eskom, while the total amount of electricity generated in South Africa is also transmitted and distributed by Eskom. This electricity is generated mainly by: Coal-fired power stations - 91 % Hydro electric power stations - 2 % and Koeberg, the Nuclear Power station in the south western Cape - 7 % (Eskom, 1996a) From these percentages it becomes clear that the coal-fired power stations are the main generators of electricity in South Africa. Unfortunately this method of generation exerts negative impacts on the environment as it causes various forms of pollution to occur. It is these coal-fired power stations that will be the focus of this project.
Eskom has 13 coal-fired power stations, nine of which are located in the Mpumalanga Province. Six of these are located in the Eastern Highveld region of Mpumalanga, namely in the vicinity of Witbank and Middelburg (Figure 1). The other three are found in the Standerton, Amersfoort and Ermelo regions.
2 E 30 E
25°S
27' S
Coal Fields
Power Stations 1. Arnot 2. Hendrina 3. Duvha 4. Kendal 5. Kriel 6. Matla 7. Tutuka 8. Majuba 9. Lethabo 10. Grootvlei 11. Camden 12. Komati Matimba not shown in Figure
Figure 1: Location of Coal-Fired Power Stations in the Mpumalanga Highveld and the Associated Coal-fields
2 Only three of the coal-fired power stations are not located in this province; these are Grootvlei near Heidelberg, Lethabo near Sasolburg and Matimba situated at Ellisras. Three of the 13 power stations, namely Camden, Grootvlei and Komati are at present mothballed and are thus not generating any electricity.
1.2 Environmental Problems
The concentration of power stations in the Mpumalanga Highveld region, is a direct result of the abundance of coal reserves found here. Approximately 51 % of the known recoverable coal reserves in South Africa are located in this region (Figure 1), (Doppegieter, et al, 1996). As the transport of coal is expensive, it was found to be more economical to build the power stations adjacent to their supplying coal fields, and to transport the coal via conveyor belt directly into the power station. Because of the availability of coal, many other industries utilising coal as a primary fuel are also located in this region, for example, Highveld Steel, Columbus Steel, SASOL, various brick-works, as well as ferro-alloy and metallurgical plants. These factors have, therefore, conspired to make this region one of the most polluted regions in the country. This has led to the development of several environmental problems, which can be encapsulated under the following headings:
Air Pollution Water Pollution Waste Production Land Degradation
1.2.1 Air Pollution The main atmospheric pollutants causing concern in the region, are particulates (fine ash particles), sulphur oxides (SOx), nitrogen oxides (NOx) and carbon dioxide (CO2) gases (Table 1). These gases, produced when coal is burnt, have been shown to enhance the Greenhouse Effect, which can cause global climate
3 change; deplete the ozone-layer and can, on a local scale, cause acid deposition (Miller, 1994 and Nilsson, 1992). At present there is no legislation in South Africa prescribing the minimisation of gaseous emissions. The technology to do so is available, but it is very expensive, and should any of these technologies be utilised, it will impact on the price of electricity. Eskom is thus not involved in any removal activities at present. The installation of monitors to measure the amounts of SOx and NOx that is emitted, are however, being planned for the next five years. The Technology and Research Investigations division of Eskom, has also started a project to investigate all the available technologies for detoxification of the gaseous emissions. The investigation will also determine the applicability of these technologies to South African conditions and coal types.
Table 1: Emission Data for Coal-fired Power Generating Power Stations (Eskom, 1996a)
Power Particulates SOx NOx CO2 station kilotons thousand tons Thousand tons million tons Arnot 13.7 40628 18069 5 Duvha 8.2 195399 89675 22 Hendrina 46.3 98317 47924 14 Kendal 5.3 190974 84889 20 Kriel 9.7 118806 87550 16 Lethabo 8.3 142567 100381 21 Majuba 0.1 11856 3466 2 Matimba 10.7 204225 58950 21 Matla 6.3 189797 100643 23 Tutuka 3.7 102770 55502 14 TOTAL 112 1295337 647049 159
Eskom is however, utilising the latest technology regarding the removal of particulates from the smoke stack emissions at the power stations. In fact, particulate emissions from Eskom power stations, have decreased from 479 kilotons in 1982 to 112 kilotons in 1996 (Figure 2).
4 4.50 4.00 3.50 0 3.00 Cl, 2.50 2.00 a, 1.50 1.00
0.00 r I f I I I I I 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97
Re 1p e r
Figure 2: Particulate Emissions between 1982 to 1996 from Eskom Coal-fired Power Stations. (Eskom, 1996a)
The particulate emissions in Table 1, indicate that Arnot and Hendrina emitted the most particulates during 1996. Both these power stations are old and thus have ageing precipitators, which cause a great deal of particulates to escape through the smoke stacks. Lethabo's and Matimba's emission figures are influenced by the quality of coal burnt. Low quality coal means that a power station has to burn more coal to generate the same amount of energy, another power station can achieve with less coal of a better quality. Lethabo Power station is, in fact, the power station that burns the lowest quality of coal in the world.
In a study conducted by the Energy Research Institute during 1995 (Dracoulides and Dutkiewicz), data was gathered from 38 power generating plants from all over the world. The following results regarding emissions were given:
Particulates and CO2 emissions: Eskom showed the best average performance of all the power stations studied. However, one of the Eskom power stations, Kriel, has the highest particulate emission per unit of energy sent out, and one of the highest CO 2 emission rates. The reason for this is still being investigated.
5 SOx and NOx emissions: The Eskom power stations compared well with the other power stations studied, with the Lethabo Power station one of the best, owing to the low-sulphur content of the coal being burnt.
Although air pollution is thus the main environmental problem in the region, there are also other allied environmental problems that need to be considered as well. All of these problems tend to have a negative environmental impact.
1.2.2 Water Pollution The main river in the study region is the Olifants River which rises in the Bethal region and meanders through the mining and industrial districts of Middelburg and Witbank. From there it flows through the Drakensberg towards the Lowveld and the Kruger National Park, before it crosses the South African border into Mozambique. Over the years the river has been abused to such an extent that at present it has some form of pollution along its entire length. `Over utilisation and pollution have degraded the riverine habitat by reducing the supply and quality of the water of the river. Salinity and acidity resulting from mining, industrial and urban development in the Highveld region, have increased Encroachment into and the utilisation of wetlands, marshes and sponges by agricultural and other activities, has affected their ability to function as natural water filters. Over-grazing and soil erosion is causing extensive siltation in parts of the river. Utilisation of water for farming, power generation, mining and mineral processing and for household use has depleted the ability of the river to scour and cleanse itself ' (Olifants River Forum, undated)
The Duvha Power station was specifically located and designed to use water from the Witbank Dam. This has, however, never materialised, because of the high sulphate levels of the dam's water, caused by effluent from the surrounding mines. The power station is now supplied with water from the Komati River System (Table 2). The other power stations that receive water
6 from the Komati River System are: Arnot, Hendrina and Komati. The Usutu River System supplies Kendal, Kriel and Camden with water, while Matla and sometimes Kendal receive water from the combined Usutu-Vaal River System. The Vaal River System is responsible for supplying the Kragbron, Lethabo and Grootvlei power stations with water and Majuba Power station's water is brought from the Zaaihoek Dam. It is thus clear that the power stations located in the Mpumalanga Highveld, do not use water from the Olifants River System, but they can, when discharges of water take place from the power stations, cause polluted water to flow into this river and its tributaries (Table 2).
Table 2: Water Utilisation by Coal-fired Power Generating Power Stations (Eskom 1996a)
Power Net Water Water Source Water Discharge Incidents station Usage - Polluted water released Megalitres into the Environment (Megalitres) Arnot 10292.64 Komati System 10.5 (2 incidents) Duvha 43172.45 Komati System 0 Hendrina 25696.91 Komati System 0 Kendal 1852.83 Usutu System 0 Kriel 26636.55 Usutu System 4 (1 incident) Lethabo 36810.31 Vaal System 0 Majuba 1833.658 Zaaihoek Dam 0 Matimba 3044.14 Mokolo Dam 0 Matla 37952.25 Usutu-Vaal 0 System Tutuka 27807.66 Usutu-Vaal 0 System TOTAL 238501.12 14.5
Owing to excellent water management practices during 1996, only a small amount of polluted water was released to the environment. Arnot Power station released 10.5 megaliters of water to the environment. The quality of this water was of acceptable standard, except for SO 4 levels, which was higher than the levels prescribed by DWA&F.
7 At Kriel Power station an ash pipeline burst and ash water flowed into a Maturation Pond, which eventually discharged 4 megalitres of water into the Pampoenspruit.
The main pollution problems experienced by the rivers of the region are; increased salinity, eutrophication and high concentrations of metals. The increase in salinity levels is caused by effluents high in sulphates, calcium, magnesium sodium and chloride, discharged mainly from the coal mines. Eutrophication is caused by the over nourishment of the aquatic ecosystems with nitrates and phosphates from agriculture and industrial plants. The third problem in the Olifants River Catchments' rivers is high concentrations of metals such as iron, manganese and aluminium, also contained in the water released from the mines in the area.
In order to minimise Eskom's contribution to further pollution of the natural waters, Eskom included the philosophy of `Zero-liquid-effluent-discharge' (ZLED) in its Water Management Policy (Eskom, 1996). According to this philosophy, no water from the power stations will be deliberately discharged into the river systems of the region. A system of re-use was developed whereby the effluents from one water using system would be utilised by another system, where lower quality water is acceptable, and so consecutively down to final consumption by evaporation or encapsulation in the ashing systems. The ZLED cascading system however, offers only a limited sink for the encapsulation of effluents, which can cause problems if a power station has large quantities of effluent that have to be disposed of.
Both Matla and Kriel Power Stations, for example, are experiencing problems with excess water. This is caused by the shallow water table in this area and leachate from the open-cast mining areas surrounding the power stations.
8 One way of alleviating this problem is to plant blue gum trees, as these are `water-thirsty trees'. Mature blue gum trees are estimated to absorb 180 - 250 litres* of water per day.
Owing to the increasing awareness that South Africa is a water scarce country, the Department of Water Affairs and Forestry initiated the so-called ' Waste- load-allocation' programme in 1997, whereby the mines and the power stations in the Olifants River Catchment area are allowed to release prescribed quantities of polluted water. This programme runs from the beginning of the rainy season until April and is dependant on the amount of rainfall received in the region. When good rains have fallen and the river is running strongly, the Department allows the mines and power stations to release prescribed quantities and qualities of polluted water. Owing to the quantity of water in the river, the pollutants will be diluted to acceptable amounts. This process makes more usable water available to down-stream users.
Pollution of the groundwater at a power station can occur at several localities; for instance at the coal stockpile, ashing sites and waste sites, where liquids leaching through the coal, ash or wastes can cause pollution of the groundwater. In order to monitor the quality of the groundwater, monitoring systems have been installed at all of Eskom's operating and mothballed power stations. These systems are routinely monitored for compliance with the South African drinking water standards. The analyses of the quality of groundwater, are interpreted by external consultants or by the relevant staff at the power stations.
The creation of a formal centralised database and interpretation of this data by head-office personnel are currently under investigation.
*(Personal communication Melanie Dalton, Matla Power station).
9 A plume flow model (Hodgson et al, 1996), that uses bore-hole data to predict areas of potential pollution of ground water at the power stations, and the path the polluted water will most probably follow over time, has been developed in conjunction with the Institute for Groundwater Research. This model will be installed at all the power stations over the next five years. Information gained from this model will be utilised in identifying and prioritising pollution problems, as well as in assisting in the development of management plans.
Apart from the ZLED philosophy for surface water and the plume flow models installed for groundwater monitoring, Eskom also plays a role in the Olifants River Forum activities. The aim of this Forum, initiated by all the role-players in the region, including industries, non-governmental organisations, nature conservation and various government departments in 1993, is to sponsor projects for the improvement of the water quality of the catchments' main rivers.
1.2.3 Waste Production Various waste products are produced at the power stations (Table 3). The largest waste product of a coal-fired power station, as is evident from Table 3, is the ash that results from the burning of coal during the power generating process. This ash is removed from the power station, and deposited in dumping sites that cover large areas of the surface (Table 4), rendering these land areas useless for other purposes. Apart from covering land, the ashing sites can also cause dust problems when the wind blows the fine ash into the atmosphere. Water leaching through the ash can result in alkaline surface run-off that can pollute streams, as well as the groundwater. It is thus necessary to monitor the area for leachate by drilling bore- holes, to monitor groundwater quality and to prepare trenches to allow polluted surface run-off to be contained.
10 Table 3: Waste Products Produced at Coal-fired Power Generating Power Stations during 1996. (Eskom 1996a)
Power Ash General Metal Paper Hazardous station production wastes Recycled Recycled Waste* kiloton m3 ton kilogram kilogram Arnot 548 2153 1114 497 25 Duvha 398 5300 693 2754 205 Hendrina 1578 32737 2787 7987 297110 Kendal 3506 9631 155 4000 163 Kriel 2006 4636 714 17000 7140 Lethabo 5273 8258 240 24380 48880 Majuba 213 3306 25 280 102 Matimba 4963 20804 24 17920 99 Matla 2710 115 1721 2800 0 Tutuka 1765 11050 291 7320 298933 Simunye 0 6017 1 4280 15091 ** TOTAL 22961 110253 7764 89218.2 667748 Hazardous waste does not include nuclear waste ** Simunye are the mothballed power stations - Camden, Grootvlei and Komati. Waste Figures are rounded.
Table 4: Land areas utilised by Coal-fired Power Generating Power Stations as in 1996. (areas in hectares) (Eskom, 1996a)
Power Total Land Power station Ash Dam and Coal station Area in use Built-Up Area Waste Site Areas Stockyard Arnot 1400 70 120 7 Duvha 1440 150 430 150 Hendrina 1375 530 300 5 Kendal 678 126 207 60 Kriel 1842 110 289 3 Lethabo 460 80 140 109 Majuba 6126 511 590 51 Matimba 1834 634 1200 (634)* Matla 1480 80 490 30 Tutuka 315 219 189 105 TOTAL 16950 2510 3955 520 Coal areas included in power station built up area.
Although numerous research projects have been undertaken by Eskom to turn ash into a resource, it has been relatively unsuccessful and few uses of the ash . have been determined. For example during 1996 only 4.5 % of the ash produced, was sold, mainly to the cement industry*.
(Personal Communication, R. Kruger, Eskom Ash Resources).
11 Sewage, (amounts not recorded) if allowed to enter natural streams or water bodies, can be a major source of pollution. Sewage can be described as a very dilute suspension of human habitation wastes, in water. The pollutants are mainly organic in nature and may be soluble in water. Due to its strong demand for oxygen, sewage can deplete the dissolved oxygen content of a water body to such an extent, that it cannot support life. In addition to this, a build-up of decomposing solids may occur. The solids will settle on the bottom and delay recovery of the water body for many years. A third effect of sewage discharge is eutrophication of the watercourses. Eutrophication was discussed earlier (p7). Sewage is also of particular danger to man, as it contains millions of potentially dangerous pathogenic organisms, which can cause diseases such as typhoid fever, cholera and dysentry. These diseases are also transported through water mediums.
The other smaller volumes of waste produced at power stations (Table 3) include: domestic waste mainly from the offices, kitchen wastes mainly from the canteens and maintenance waste, that includes garden wastes, building rubble and metals.
As much as possible of the above waste products are re-used or recycled, either by the power station itself or by being sold to recycling contractors. Although the amount of waste paper produced is not recorded, the power stations recycle most of this to contractors.
Hazardous wastes products at a power station, include asbestos insulation from the older power stations and oil wastes containing polychlorinated biphenyls (PCB), which are still contained in equipment such as transformers, medical wastes from the medical centres, fluorescent tubing and batteries used in the power station, oils and greases, and
12 - solvents from the chemical laboratories, which may be considered to be of a hazardous nature.
1.2.4 Land Degradation Eskom owns large tracts of land around each power station (Table 4), where land degradation through erosion, as well as a deterioration in the natural fauna and flora can occur if not properly managed. As can be seen in Table 4, the power station buildings use relatively small areas of the total land area. On the other hand the sites utilised for ash dams cover large areas, as these are continuously growing features. The coal stock-pile sites are smaller, because the amount of coal kept in these stock-piles are relatively fixed.
The utilisation of land for power generation has however, over the years proved to have a positive, rather than a negative effect on the environment. The veld surrounding the power station is often improved by the eradication of exotic or invader species of both fauna and flora. Indigenous species are re-introduced, and protected; eroded land is rehabilitated and further erosion prevented, while new habitats are created at the water reservoirs, as well as the dirty and clean water dams of the power station.
The preceding pages prove that coal-fired power generation can have serious negative impacts on the environment, which require management. This was recognised and a host of plans have been devised to ensure that effective management takes place.
13 2. STATEMENT OF THE PROBLEM
From the foregoing it is clear that power generation through the burning of coal, has various impacts on the environment that need to be effectively managed. Although legislation (for example the Atmospheric Pollution Prevention Act No. 45 of 1965; Water Act No. 54 of 1956; and the Environment Conservation Act No. 73 of 1989) in South Africa advocate minimisation of these impacts, very little has been done about enforcing the legislation. Eskom has, however, adopted a self regulatory policy and decided to use compliance to the relevant Acts, as minimum targets. Internal targets, stricter than those set by legislation, where in existence, have been adopted. Each power station has, for example, a certificate issued by the Chief Air Pollution Control Officer (CAPCO) of the Department of Environmental Affairs and Tourism (DEAT), that allows a certain amount of particulates to be emitted. The power stations however, set limits below this allowed level, ensuring compliance with the law. Arnot Power station is for example allowed to emit 3000 tons of particulates per month, as per their CAPCO Certificate. The power station however, strives to emit no more than 2000 tons per month. Thus the legal limit is 3000 tons, while the internal power station limit is 2000 tons. Performance of the power station is judged on this 2000 ton emission limit. Targets such as these, can only be achieved through the development of management plans, which focus on the management of environmental impacts, associated with the whole power generation process.
Management plans were developed for each of the individual power stations, but as no general standards were set, it has become necessary to formulate a generic Environmental Management Plan (EMP), which can be adopted and if necessary adapted for each power station.
The Generation Environmental Management Department of Eskom, acting as an advisory group to the power stations, initiated the compilation of such a generic document in order to assist in the compilation of the power station's individual EMPs. The generic management plan developed here, is thus
14 important in that it will become a guide for the Generation Group when new EMP's are compiled, and existing ones are reviewed.
This document will focus on the management of environmental impacts that will occur during the operational phase of a power station. The aspects investigated will include: Air Quality Control Water Management Waste Management and Land Management.
The general pattern followed by the Environmental Management Plans studied (points 1-8, p18-19), will be followed for the development of the Generic Environmental Management Plan for Coal-fired Power stations.
Owing to the scope of this study, various other facets of importance to environmental management will not be included. These facets include: Social Impacts caused by the generation of power Environmental Communication Environmental Education and Awareness
In order to develop an environmental management plan, the general structure and content of management plans will now be studied.
15 3 THE DEVELOPMENT OF ENVIRONMENTAL MANAGEMENT PLANS
3.1 Background
In 1969, the United States of America passed the National Environmental Policy Act, that proved to be the beginning of Environmental Impact Assessments (EIA) (Riordan, 1976). In 1994 Sadar described an EIA as follows: ' ...an activity which identifies, predicts, interprets and communicates information, and proposes ameliorate measures about impacts of a proposed action or development proposal on human health and the well-being of the ecosystem upon which human survival depends.' (Sadar, 1994:1).
An EIA identifies impacts that a project will have on the environment, and suggests alternatives and mitigatory measures that will lessen or eliminate impacts. Environmental Management Plans (EMP's) are then developed as a follow-up on EIA's. The aim of an EMP is to describe how negative environmental impacts will be managed and monitored, how positive impacts will be maximised and how negative areas will be rehabilitated. "The EMP is there to set out actions to be taken and standards to be met in order to avoid, control, reduce or remediate adverse environmental impacts so as to conform to EIA findings and recommendations, Life-cycle Assessment evaluations, legislation obligations, permit requirements, license conditions and an organisations policies and standards.' (Lucas, 1997:7). EMP's are also called Environmental Impact Management Plans and Environmental Impact Control Programmes (D&B Environmental Consultants; Visser, 1995)
Ideally an EMP should cover all the stages of a development: from the pre- construction phase through to decommissioning of the facility.
Compilation of the EMP should, therefore, be done in the planning phases in consultation with all the role players, including the design team, project team
16 and operational staff However, in the case of Eskom, EMP's were only developed well into the operational phase of the power stations. This has proved successful and it can thus be accepted that EMP's can be developed in the later phases of a project. Mitigation actions in these EMP's will only cover the operational and decommissioning phases, and will concentrate on the identified impacts of the processes. As mentioned before, the existing management plans at the Eskom power stations all differ because no prescribed format was set in the beginning. It was thus decided that such a format will be set, by developing a generic management plan.
Both Environmental Impact Assessments and Environmental Management Plans are elements of Environmental Management, which is defined as: 'those aspects of the overall management function that determine and implement the
environmental policy' (Rawicz, 1992:17). The management function that Environmental Management forms a part of, includes the organisational structure, responsibilities, practices, procedures, processes and resources that makes implementation of environmental management possible. With the rapid growth in environmental awareness since the 1970's, many businesses had adapted from a reactive 'incident management' to a pro-active management- focused 'prevention' approach. During 1993, the International Organisation for Standardisation (ISO), began developing a set of standards (ISO 14000) to assist companies in this management-focused approach. The management system being implemented throughout Eskom at present is based on the ISO 14000 principles. Implementation is such that Eskom can, if so desired, apply for certification to the ISO 14000 programmes in future.
3.2 Components of an Environmental Management Plan
After an intensive literature search, little information on the compilation of EMP's could be found. Most of the literature focused on Management Systems, implementation of these systems or the mitigation factors themselves (Environment Protection Agency, 1995; Little, 1980; Rawicz, 1992; Soutter
17 and Mohr, 1993; and Vaccaro (undated)). The management systems all require EMP's, but none give any details on the contents required.
A number of existing Environmental Management Plans were then studied (Caltex Oil, 1995; Eskom Power station EMP's, (undated); Eskom Subpower station EMP's, (undated); Eskom Transmission Line Management Plans, 1997; Saldanha Steel; Environment Protection Agency, 1995; Fort Beausejour & Fort Gaspareaux National Historic Sites, 1996; Kouchibouguac National Park Management Plan, 1993; Wates, Meiring and Barnard, (undated)), in conjunction with the few documents containing guidelines on the development of an EMP (Eskom Environmental Management Plan Policy, 1996; Visser, 1995). In general the plans consisted of the following:
Background to the project: in short the reasons for the project, the aims and benefits expected. Legislation relevant to the project. The legal aspects that will have a direct effect on the actions of the project. Impacts identified. This would include unavoidable, potential future and social impacts. Mitigatory measures to minimise or control the identified impacts, such as measures to minimise air pollution. Monitoring of pollution prevention and mitigatory measures, documentation of the monitoring results and structures in place to report these results as well as progress made with mitigatory actions to the relevant authorities and company employees. Contingency plans for incident management, to ensure that in the event of, for instance an oil spill, the people on the ground will know how to handle the situation. The contact person(s); where clean-up kits can be found and how these should be utilised. Accountabilities. This would be the responsible person for each of the impact areas, for example the air quality manager or officer, water plant manager, and ash dam manager.
18 8. Audits. The audit cycle, including corporate audits and internal power station audits. At Eskom full corporate audits are conducted every 3 years, with follow-up reviews in-between. Internal audits can be scheduled as the need arises. Both internal and external audit findings, recommendations and the time frames for implementation of the recommendations will be included.
Most EMP's also contain sections on the communication programme, training and awareness requirements and programmes, as well as a section on the social impacts expected from a project. These aspects will not be covered by this document, as the focus will be on the physical impacts of an operating power station.
Using the above format (points 1-8), management plans are then developed for the different phases of the project: Pre-construction Construction Operation Dismantling or decommissioning.
It must once again be emphasised that the generic environmental plan developed in this study, will only be for the operational phase of the Eskom power stations as they have all been in this phase for several years.
3.3 Generic Environmental Management Plans
A generic EMP will contain all the known impacts that are general for a group of similar activities, in this case electricity generation by coal-fired power stations. As discussed before, generating electricity through the burning of coal causes air pollution, water utilised become polluted, waste products are produced and large land areas are utilised. These impacts will thus form the basis of any coal-fired power stations' management plan. As each power
19 station is different from the others, there may be other site specific impacts exclusive to that site. These will then be added to the individual power station EMP by the compilers of the document.
The aspects of environmental management that are generic to the coal-fired power stations will be addressed separately. The sections will cover: Air Quality Control Water Management Waste Management and Land Management.
20
4 THE STUDY AREA
Before the management plan enabling the management of environmental impacts, is developed, some information regarding the study area is needed. This information is important in that it can have an influence on many developmental aspects of a power station, even in the operational phase. As the power stations in this study did not undergo Environmental Impact Assessments, which would have compiled all the necessary background information, it is suggested that this data form part of the EMP.
4.1 Geographic Location The Generic Environmental Management Plan is intended for the coal-fired power stations located in the Mpumalanga Province situated between latitudes 25° and 27° South, and longitudes 28° and 30° East. The power stations include Arnot, Duvha, Hendrina, Kendal, Kriel, Majuba, Matla and Tutuka, as well as the mothballed power stations: Camden, Komati and Grootvlei (Figure 1).
4.2 Physical Characteristics of the Study Area The following physical characteristics of the study area are considered to be important facets that need to be taken into consideration when developing a management plan for power stations.
4.2.1 Climate Climate plays an important role in the planning stages of a power station. Wind direction for instance, will influence the siting of ash dams and in the early stages of planning, the orientation of the power station itself Smoke stack heights are determined by the average levels of the inversion layer.
The general climatic features of the study area are as follows: The area falls within the Eastern Mpumalanga Highveld with temperatures varying from an average maximum of 25.8°C in summer, to an average minimum of 0.0°C
21 during winter nights. Rainfall occurs mainly in the form of thunderstorms from November to January, with an average of between 380 mm to 700 mm. Winds are mostly light to moderate from the north-west during day-time, and from the north-east during night-time. The highest recorded wind speeds are on average 17.6 km/hour, with average wind velocities of 14.5 km/hour, over a one-year period.
As mentioned previously, the concentration of power stations, combined with other coal burning industries in the study area, causes severe air pollution. It is therefore necessary to look in more detail at the weather systems that would influence the movement and dispersal of these pollutants.
Climatic features that influence the dispersal of air pollution: 'Southern Africa is situated in the sub-tropical high pressure belt which causes the general circulation over the subcontinent to be anticyclonic...for most of the time. During the summer months... cyclonic circulations occur when troughs develop over the central plateau of the country. However, it should be noted that the circulation over the eastern parts of the highveld remains under an anticyclonic influence for most of the time. The frequency of anticyclonic circulations and associated atmospheric subsidence reaches a maximum in winter, occurring on more than 65 % of days. This subsidence is conducive to the formation of elevated temperature inversions ...' This occurs during both summer and winter months (Held, et al, 1996:60).
From the foregoing, it is thus evident that two important weather conditions are likely to influence the dispersion of pollutants in the study area. These are:
- the semi-permanent anticyclonic circulation patterns, which result in large scale atmospheric subsidence; and - the formation of elevated temperature inversions.
22 Subsidence of air produces adiabatic warming, drying of the atmosphere, an increase in atmospheric stability, and suppression of precipitation, which leads to dry spells. Subsidence is also highly conducive to the formation of inversions.
During spring, summer and autumn, the atmospheric flow fields are disturbed by westerly and easterly air movements, which are accompanied by strong winds and upward vertical air movements, dispersing accumulated atmospheric pollution. The effect of winter subsidence is that the mean vertical air movement, averaged over a year, is downwards, and pollutants are thus not allowed to disperse. The anticyclonic circulation that dominates during winter, is associated with clear, dry air and light winds, ideal for the formation of inversion layers. In basic terms, an inversion layer is caused by the presence of a warm layer of air in the higher atmosphere (troposphere), which prevents the surface air, with its associated pollution, from rising. This can happen when a large slow-moving high-pressure air mass sweeps warm air in, at high altitude, effectively trapping the lower level with cooler air, beneath it. The typical height of these inversion layers in Mpumalanga, varies from less than 300 meters to more than 1000 meters.
Eskom uses smoke stacks with and average height of 275 meters, to disperse emissions into the inversion layer and to reduce ground-level concentrations. In an international study conducted by Dracoulides and Dutkiewicz (1996), most of the other power stations investigated, had smoke stack heights in the region of 198 meters.
The pollution plumes emitted from the tall smoke stacks used by Eskom, can only reach ground level during daytime convective boundary layer conditions. However, dispersive mixing under these conditions is very effective and ground level concentrations of all pollutants are low. During night time when stable boundary layer conditions develop, the high stack plumes penetrate the inversion layers and have virtually no direct ground level impact.
23 In fact, according to Schakleton et al (1996:137), ' ...a recent analysis of long- term data... in the Mpumalanga Highveld region, has revealed a trend of long- term improvement' Further technical descriptions of the formation of these inversion layers are given in Tyson, et al, 1988 and Held, et al, 1996.
The above atmospheric conditions all combine to influence the dispersal of pollutants originating in the Eastern Highveld of Mpumalanga. Research in the past five years into the fate of these pollutants, has revealed that 'much of the material is distributed over the entire subcontinent, through the re-circulation of material in large circular transports.'(Piketh, et al, 1997:2) The results of the study have shown that air parcels from the Mpumalanga Highveld, most frequently exit the continent off the east coast of South Africa at about 30 °S. This is in contrast to the earlier belief that the pollution caused by power generation gets advected to the east over the Indian Ocean. Piketh et al. (1997), found that other researchers also noted that large amounts of the air parcels, curved back towards the continent.
These observations indicate that the particulates and gases emitted by the power stations in Mpumalanga can effect large parts of the country before they exit to the oceans, and may even circulate back to the area of origin (Figure 3). Planning at the power stations should therefore take these factors into account during the formulation of EMP's.
24 TRANSPORT TO AND FROM BEN MACDHUI TRANSPORT TO AND FROM BEN MACDHUI
am:mum CORetAF0 1104:XWSIG FCAWARO
EASTERLY
1.01totaAU 8.14:07010 FO4WAISO asCrectS10 22 July-19 August 1995 17 August-16 Secternost
Figure 3: Transportation patterns of air parcels from the Eastern Highveld Region, to the Ben MacDhui monitoring station in the Eastern Cape. (Piketh, et al, 1997)
4.2.2 Water Supply and Hydrology The Eskom Power stations in this region fall within the Upper Olifants River Catchment area. This catchment is economically, a highly developed region, containing 50 % of the country's high-production arable land and forestry resources, the majority of coal mines and power stations, and is an important contributor, not only to the regional, but also to the national gross domestic product
of South Africa (Huntley, et al, 1989).
25 Water use in the area comprises 67 % of the total water consumption of the corresponding sector in the Olifants River Basin, while the catchment comprises 13 % of the basin. The water resources of the catchment are not sufficient to cater for the requirements of the various users and more than 200 million m3 of water is imported annually from the Komati, Usutu and Vaal Rivers, specifically for power generation purposes. Even with these imports, water demand is expected to exceed supply in the near future and water shortages are envisaged in the Witbank-Middelburg complex.
The Upper Olifants River is also one of the worst polluted rivers in South Africa. Effluents from the coal mines caused an increase in salinity levels to such an extent that the water has become virtually useless to man and nature in some areas. Industrial development and farming activities have added to the pollution levels in the rivers, causing eutrophication, high metal content and low pH levels.
The Olifants River Forum initiated in 1993 by local industries; including Eskom; nature conservation, as well as the relevant government departments and local interest groups, aim to `... improvement, conservation and sustainable existence of the Olifants River to the benefit of man and the environment,' (Olifants River Forum, undated).
The natural geohydrological conditions in large areas of this region have been greatly disturbed and even destroyed because of open-cast mining activities. Water from the natural aquifers, drains into the open-cast areas, which act as collection systems for much of the groundwater in the area. This disturbed the natural flow direction as well as the flow velocities of the groundwater.
Hydrological conditions are taken into account when water and ash dams, as well as, waste sites and coal stockpiles are planned. These are generally not sited where the natural flow direction of water can cause pollution problems.
26 As mentioned before, the plume flow model developed by Hodgson (1996), in conjunction with the Institute for Groundwater Research, will be implemented at all the power stations in the study area over the next few years.
The model indicates areas where groundwater is at present under threat of pollution. If this pollution is not stopped, the model indicates the path that the underground polluted water will follow. This knowledge enables the environmental practitioners to develop management plans that will combat present problem areas and prevent future pollution.
The chemistry of groundwater is strongly influenced by the media with which it has been in contact as well as the duration of the contact. It is expected that water originating from the granitic rock type in this region, will produce water dominated by sodium, calcium, silica, iron and magnesium concentrations. The Karoo sedimentary rocks are expected to produce groundwater rich in sodium, calcium, potassium and chloride, with localised iron concentrations. Mineralisation of these rocks will produce saline waters. The lava rocks found in the region, will produce higher concentrations of magnesium, iron and possibly sodium and calcium in the water. Information on the natural chemistry of the water in the area, needs to be recorded in order to determine the types of pollution that will be caused in case of an accidental release. For instance an increase in sulphur levels, or a decrease in pH. (Bergh, undated; Duvha Power Station Environmental Management Plan, undated; Hodgson, et al, 1996; Kriel Power Station Environmental Management Plan, undated; Matla Power Station Environmental Management Plan, undated; Van der Merwe, 1989).
4.2.3 Geomorphology The geomorphology of the area is typically that of an old age landscape; gently undulating, with interfluvial areas. The area becomes progressively more dissected from east to west, with drainage generally in a northerly direction. Rehabilitation and eventually the decommissioning of the power station sites is planned around the natural geomorphology of the area as it is Eskom policy to
27 rehabilitate land as close as possible to its natural contours. (Duvha Power Station Environmental Management Plan, undated; Kriel Power Station Environmental Management Plan, undated; Matla Power Station Environmental Management Plan, undated; Van der Merwe, 1989).
4.2.4 Geology The study area of Mpumalanga is underlain by rocks of the Karoo Supergroup, consisting of sandstone, shale and the coal beds of the Ecca Series. These rocks overlie complex intrusive rocks of the Bushveld Igneous Complex which manifests itself as narrow north-west trending ridges. North-westward, quartzites of the Transvaal Supergroup dominate. Post Karoo-age dolerite intrusions strongly influence the geological structure of the area. The chemical make-up and geometry of these sill intrusives are not conducive to groundwater development, except along contact zones where sedimentary strata are often jointed and fractured.
The geology of the area is important as it determines the in-situ soils that will form over time. Porosity and permeability of the soil and underlying rocks influence the infiltration rates of water to the water table and are thus of importance in cases of pollution. (Duvha Power Station Environmental Management Plan, undated; Kriel Power Station Environmental Management Plan, undated; Matla Power Station Environmental Management Plan, undated; Van der Merwe, 1989).
4.2.5 Soil The Mpumalanga Highveld falls into one of the most productive crop production areas in South Africa. The soils of the area are dominated by two groups: A mesotrophic loam, and a sandy to loamy soil form. The soil profile of the area is fairly uniform. Transported soils are of hillwash or mixed origin and vary from silty sand at the surface, to clayey sand deeper down. The sands are free draining and brown to red in colour. A number of burrowing animals live in these soils.
28 Alluvial soils are found in most of the drainage courses and vary from sand to sandy silts to clay. Neither the transported nor the residual soils, display dispersive characteristics such as erosion gullies or discoloured water streams. The soils are, however, moderately erodable; the sandy soils more so than the clayey soils.
Knowledge of the soil types and allied main characteristics on a power station site, assist in the maintenance and rehabilitation of the land, as well as in decisions on flora and fauna to be brought onto the site. (Duvha Power Station Environmental Management Plan, undated; Kriel Power Station Environmental Management Plan, undated; Matla Power Station Environmental Management Plan, undated; Van der Merwe, 1989).
4.2.6 Flora Most of the natural environment in the region has been degraded or destroyed by farming and mining activities. The region falls mainly within the 'Bankenveld' (veld type 61c, Acocks, 1988) and 'Themeda veld' (veld type 52). The Themeda veld is dominated by Themeda triandra (Rooigras), with no other species of great importance. The Bankenveld on the other hand although containing Themeda triandra, also hosts a great variety of other veld-grass and herbaceous species. Some of these occurring in both veld types include: Heteropogon contortus, various Eragrostis species, Brachiaria serrata, Elionurus muticus, Digitaria diagonalis, Eragrostis chloromelas, Michrochloa caffra, and Cymbopogon excavatus. Threatened species in this area include: Cyrtanthus bicolour, Eucomis montana, Gladiolus robertsoniae and Nerine gracilis. None of these species are endemic to the area.
Geigeria aspera, a herbaceous plant found in the Themeda veld, is poisonous to cattle and can become very abundant under heavy grazing. Naturalised invader species in this region include: various Acacia (wattle) species, Eucalyptus (gums) species, Pinus species, Opuntia ficus-indicata, Sesbania punicea and Salix babylonica.
29 Eskom has, in conjunction with the Department of Agriculture, developed a programme to eradicate all black wattle trees from the region. These are so- called invader trees that disturb the ecological balance of the area, which impacts on both the natural fauna and flora, grazing capacities are diminished and the value of property decreases. If successful, the eradication programme will be extended to other invader tree species, such as Eucalyptus and Sesbania. (Duvha Power Station Environmental Management Plan; Kriel Power Station Environmental Management Plan; Matla Power Station Environmental Management Plan, Van der Merwe, 1989).
4.2.7 Fauna As mentioned, most of the natural environment in the region has been degraded or destroyed by farming and mining activities, which destroyed the natural habitat of many of the fauna native to the area. Some of the fauna previously found in abundance in the Highveld, now appear in the Red Data Lists. Rare species that may still be found in the region include: the Aardwolf, African Striped Weasel, Southern African Hedgehog, Brown Hyena and the Serval. There are also several species that are considered vulnerable. (Duvha Power Station Environmental Management Plan; Kriel Power Station Environmental Management Plan; Matla Power Station Environmental Management Plan, Van der Merwe, 1989).
4.2.8 Birds The only bird species found in the area that is considered endangered is the Wattled Crane. Rare species still found include the Pinkbacked Pelican, Peregrine Falcon and the Thickbilled Cuckoo (Brooke, 1988; Duvha Power Station Environmental Management Plan; Kriel Power Station Environmental Management Plan).
30 4.2.9 Reptiles and Amphibians No rare, endangered or vulnerable species are listed for this region. There are however a variety of snakes, lizards, frogs and toads found in the area. Dangerous snakes found include: Cape Cobra, Common Night Adder, Common Puff Adder, Eastern Tiger Snake, Rinkhals and Sundevall's Garter Snake. (Branch, 1988; Duvha Power Station Environmental Management Plan; Kriel Power Station Environmental Management Plan; Matla Power Station Environmental Management Plan, Van der Merwe, 1989).
4.2.10 Spiders, Scorpions No endangered species occur. Dangerous species in the region are the burrowing and thicktail scorpions, and ticks. (Duvha Power Station Environmental Management Plan; Kriel Power station Environmental Management Plan).
4.2.11 Insects No endangered insects are found in the region. (Duvha Power station Environmental Management Plan; Kriel Power station Environmental Management Plan; Matla Power station Environmental Management Plan, Van der Merwe, 1989).
4.2.12 Butterflies Only one species is recognised in the area, namely the Poecilmitus aureus, which is unlikely to occur. (Duvha Power station Environmental Management Plan; Kriel Power Station Environmental Management Plan; Matla Power Station Environmental Management Plan, Van der Merwe, 1989).
4.2.13 Fish No endangered species of fish are known to occur in this region. Alien fish most commonly found in the Eastern Transvaal waters include: Bluegill Sunfish, Small Mouth Bass and Rainbow Trout from North America, Carp from China, Large Mouth Bass from Holland and Brown Trout from England.
31 (Duvha Power Station Environmental Management Plan; Kriel Power Station Environmental Management Plan; Matla Power Station Environmental Management Plan, Van der Merwe, 1989).
4.2.14 Alien and Translocated Indigenous Aquatic Animals The following are all alien to the region and detrimental with a major impact on local animal species: Ich, whitespot disease, Trichodina (fish parasite), Fish tape worm and louse, Physa and Lymnaea snails, Common carp and Small and Large Mouth Bass. Detrimental indigenous species include the rock catfish and mud mullet. (Duvha Power Station Environmental Management Plan; Kriel Power Station Environmental Management Plan; Matla Power Station Environmental Management Plan, Van der Merwe, 1989).
From the previous pages it becomes clear that agricultural and open-cast mining activities have destroyed much of the natural habitats in the Highveld region. To ensure protection of these habitats where possible, any invaders of both Fauna and Flora found on Eskom property, are removed, while natural and rare or vulnerable species found, are protected, or re-introduced to the area.
4.2.15 Archaeology The Olifants River Catchment is rich in both prehistoric and historical sites. No sites of any note have been found on Eskom property to date. If sites such as burial sites are however discovered, the conservation and management of these sites will be included in the environmental management plan, or handed over to the National Monuments Council to manage. (Kendal Power Station Environmental Management Plan; Kriel Power Station Environmental Management Plan; Matla Power Station Environmental Management Plan).
32 5. THE DEVELOPMENT OF A GENERIC ENVIRONMENTAL MANAGEMENT PLAN
After studying existing environmental management plans, the Eskom Generation Environmental Management Section decided that certain information must be included in a coal-fired power station's Environmental Management Plan (EMP).
Background information is needed to gain knowledge on the pre-power station environment, to ensure that all possible impacts are considered in the EMP. For the older power stations in the study area, little is known about the pre- power station environment, and information on the present site and surroundings is therefore gathered as background information. Where available, earlier information will be included. The information in this section will, in all probability, not be used very often, but will be of importance when for example, new ash dams or waste sites have to be developed. When the final rehabilitation of the site, after decommissioning of the power station, is planned, the background data will again be used to ensure that the land will be left as close as possible to its pre-power station condition.
The information in the generic EMP regarding impacts on air, water and land, will only cover the operational phase of the power station life. Operational impacts listed, are the known impacts that occur at the power stations. Any site specific impacts will be included in later revisions of both the power station EMP's and the generic document. The impacts that have been identified through experience need to be listed, with the various mitigation measures, maintenance procedures, as well as monitoring methods. The Environmental Practitioners at the power stations should be able to utilise the EMP as an aide, in the day-to-day management of the power station environment, and the document should also serve as a guide to introduce the power station environment, to any new environmental personnel.
33 5.1 Background Information
This section will be based on the Aide Memoire prepared by the Department of Mineral and Energy Affairs in 1992, to aid prospective mining companies in the drawing up of the required environmental management programmes. Although some of the information may appear to be of little value to a power station, it was decided to adhere to the Aide Memoire format, as it is expected that in the near future this information may be required by the Department of Water Affairs and Forestry (DWA&F), when applying for water permits, and when undertaking Environmental Impact Assessments.
As the background data on the study area in Section 4, was given in the Aide Memoire format, this information will not be repeated here. In the actual EMP's of the power stations, this section will, however, be included. In summary it can be mentioned that maps, or an electronic Geographic Information System (GIS) if available, showing soil types, fauna and flora, land-use, hydrologic information, surface contours, wind directions, etc. should be compiled. (Department of Mineral and Energy Affairs, 1992)
5.2 Air Quality Management
Burning coal to generate energy, produces particulates and gases that enter the air through the smoke stacks. The gaseous emissions include carbon dioxide (CO2), sulphur oxide (SOx) and nitrogen oxide (NOx). Research has shown that all three gaseous emissions are harmful to the atmosphere and eventually to human health (Miller, 1994 and Nilsson, 1992), (Table 5). It is therefore necessary to minimise the amount of these gases allowed to enter the atmosphere.
Owing to the concentration of power stations, and the presence of other coal- burning industries in the study area, minimising and managing the amounts of these pollutants emitted to the atmosphere, are even more important.
34 Table 5: Comparison of Air Pollution Exposure Limits (Held et al, 1996)
Pollutant Air Pollution Exposure Limits USA World Health RSA Organisation Sulphur Dioxide 140 ppb (24-hr ave.) 50 ppb (24-hr ave.) 100 ppb (24 hr ave.) Carbon Monoxide 35 ppm (1-hr ave.) 25 ppm (1-hr aye) 35 ppm (1-hr aye) Ozone 120 ppb (1-hr aye) 60 ppb (24-hr ave.) 120 ppb (1-hr ave.) Nitrogen Dioxide 50 ppb (annual ave.) 75 ppb (8-hr ave.) 50 ppb (annual ave.)
PM10 150 µg.& (24-hr 120 ug.m-3 (24-hr 300 p.g.m-3 (24-hr ave.) ave.) ave.)
The following information should be included in a plan that will facilitate the management of air quality at a power station.
5.2.1 Legal Requirements
There are several laws that have controlling impacts on air polluting activities. Most of these laws consist of several Sections dealing with different aspects of importance to that specific act. That would mean that not all sections of the laws mentioned are applicable to Eskom. The applicable sections are normally highlighted in the internal Eskom Policy and Strategy documents, that would set guidelines on how compliance to the laws are to be ensured.
South African laws containing sections applicable to air pollution include: The South African Atmospheric Pollution Prevention Act, No. 45 of 1965 The South African Environmental Conservation Act, No. 73 of 1989 Occupational Health and Safety Act, No. 85 of 1993 CAPCO Certificate. This certificate is granted by the Chief Air Pollution Control Officer (CAPCO) of the Department of Environmental Affairs and Tourism.
35 The Certificate contains the amount of particulates that CAPCO will allow a power station to emit over any 31-day period. Realistic emission limits are determined by analysing the coal that will be supplied to the power station. Once these are known, the power station and air quality experts negotiate with CAPCO to determine what limits will be allowed. These limits are at present not strictly enforced, as there is little international pressure on South Africa at present. This is however expected to change, as South Africa ratifies international conventions, and international investors and importers of South African products start questioning environmental practices in the country.
5.2.2 Eskom Requirements
Eskom developed policies and strategies that would enable the company to comply with legislation regarding air pollution. A policy is a concise public statement of the company's intentions, eg. 'To ensure that the emissions from Eskom's facilities comply with all legal requirements. To promote continual improvement in air quality management performance in accordance with self imposed guidelines, principles and objectives.' (Eskom, 1994a). These parameters set in the policy, are then translated into objectives and targets, with both long term goals and short term targets, which have defined achievement dates. For example, power stations not complying with CAPCO limits, will develop a plan of action, which CAPCO has to agree upon. In this plan, dates will be stipulated by when maintenance methods will have changed, new technologies introduced, or faulty equipment replaced. Power stations complying with CAPCO limits, will still strive to continually improve, by testing new maintenance methods, technologies and equipment.
Eskom Corporate Documents applicable to management of Air Quality: Eskom Environmental Policy (ESKPBAAD6) The Air Quality Management Policy (ESKPBAAA3) Particulate Stack Emission Policy (ESKADAAL2)
36 Ozone Depletion Compounds Management and Phase-out Policy (ESKPBAAA4) Waste Management Policy (ESKPBAAC4) PCB Management Standard (ESKASAAC2) Occupational Health Practice (EVD1100) Corporate Directive: Environmental Impact Management (ESKADAAA9)
Power station personnel often develop their own policies based on the corporate policies. If this is the case a power station may prefer to keep the Eskom policies separate, and include the power station policies in the EMP.
5.2.3 Identified Impacts and Mitigation Measures
The following are the known sources of air pollution at a coal-fired power station. The list is however general and any site specific pollution sources will be included by each individual power station.
Particulate Emissions As mentioned before, power stations negotiate with CAPCO on the amount of particulates the power station will be allowed to emit over any 31-day period.
This 'allowed' amount would be stipulated in the CAPCO Certificate issued to the power station. This Certificate must be included in the EMP. The measures in place at the power station, to remove particulates from the emissions that leave the smoke stacks, should be described, for example, electrostatic precipitators, fabric filters and sulphur trioxide (SO 3) injection. The type of precipitator or fabric filter used must be described briefly, with specifications. In the case of filter bags, the expected lifetime of the fabric will aid in timeous ordering of replacement bags. Suppliers' should be specified, with contact names and numbers. Opacity meters, installed in the smoke stacks, measure the opacity of the smoke that leaves the stack. The instrument sends a beam of light from the
37 one side of the smoke stack, to a mirror attached on the opposite wall. The amount of light reflected back through the smoke is then measured. This gives an indication of the amount of particulates emitted. The type of opacity meter used, its position(s) in the stack, frequency of readings, the procedure for reading the opacity charts and the frequency of calibrations, must all be stated. If an opacity meter shows that the critical point of allowed opacity is reached, the reasons for this must be investigated and reported to the responsible person(s). The correct process for this investigation must be described. This investigation will supply information on the severity and reasons for the exceedance, as well as the expected duration of the problem. If the problem cannot be solved within the grace period allowed by the CAPCO Certificate, the particular boiler has to take a load loss. This would mean that the power station will generate less energy until the problem has been solved. In cases like this, contact names of the power station people responsible for the energy production programme and maintenance must be available, National Control Room must be informed as this group must then request another power station to supply the lost energy.
Gaseous Emissions At present no legislative measures exist in South Africa that force any industry to measure and minimise the emission of CO 2, SOx and NOx gases. Following international trends, this situation is, however, expected to change soon. South Africa has already signed the following international agreements regarding air quality and pollution: Montreal Protocol for the International Importance of the Ozone layer (1990) and the Convention on Climate Change (1997) (Walmsley and Tosen, 1995). As soon as these agreements are ratified by the Government, legislation follows to enforce the stipulations of the agreements.
As no standards or emission limits of SOx and NOx exist, Eskom is at present not involved in mitigation measures. The power stations do, however, calculate CO2, SOx and NOx emissions, in order to build up a database on the emission levels of these gases. Apart from using low NOx burners in a power station to
38 reduce NOx emissions, there is at present very little that can be done economically, to reduce emissions of these gases. One of the possibilities is a change in the energy mix of electricity generation. This would mean Eskom must generate more electricity at its nuclear and hydro power stations and rely less on the coal-fired power stations. As 91 % of the present electricity is supplied by the coal-fired power stations, a big enough shift in energy mix to realistically reduce gaseous emissions, seems impossible at present.
The formulae used for the calculation of the amount of gases emitted must be included in the Air Quality Management Plan, to ensure that all power stations use the same formula, and so that new personnel will be able to continue to update the database. It is planned to install monitors for SOx and NOx, as well as CO 2 gases at all the power stations during the next five years. When this is done, information regarding the type of monitor, its position, frequency of readings, calculations and reporting of information will be included in the management plan.
Dust Pollution Dust blown from the coal stockyard, conveyors, transporting vehicles and coal discard dumps can pollute the air. Coal in transport should be covered, but if not, canals should be built under the conveyors which will catch any coal spillages and prevent dust blow as well as soil and water pollution. Maps showing the routes the coal will be transported are needed, with areas where spills are likely. The measures implemented to combat pollution by the spilled coal must be stipulated.
Ash from the boilers is transported in a water base to the ash dams or dumps. Wet ash dams have less dust than the dry ash dumps when in operation, but the problem increases as the ash starts to dry out. In most cases ash water is used to dampen the ashing areas to prevent dust problems, until the rehabilitation programme can begin. The source of water, the frequency and method used for dampening the ash must be stipulated.
39 Dust pollution may also occur from the road surfaces on the power station property, as well as non-utilised areas. Measures to prevent and control erosion on these areas must be described.
Chlorofluorocarbons (CFCs) CFCs are organic compounds used in refrigerators, air conditioners and plastics (styrofoam), that can deplete the ozone levels in the atmosphere.
A regular maintenance programme should be in place, to prevent any of these gases escaping from appliances. A programme must be developed to phase in the use of less harmful products in the refrigerators and air conditioners at power stations.
5.2.4 Accountabilities
Detailed breakdowns of the accountable person(s) regarding air quality management are needed. This will include stack emission monitoring, dust control and CFC management. Having this breakdown makes it possible for head office personnel for example, to contact the correct person when information is needed. The power station personnel will also know whom to contact in cases of emergency An example of such a matrix is given in Table 6.
5.2.5 List of Contact Numbers
This list will contain all relevant contact names, with telephone numbers, regarding air quality. This would include: Accountable person(s) at the power station CAPCO contact person Head Office contact people -including Engineering and Generation Environmental Management National Control Room- to ensure the ability to supply demand.
40 5.2.6 Summary
The most important points in the management of air quality are: Compliance to the CAPCO Certificate limits. The general impacts known at present are:
Impact Mitigation Measures in Contingency Plan Place Particulate Emissions Precipitators, filter bags, SO 3 Decrease in energy injections generated Gaseous Emissions Low NOx burners Energy mix change Dust Pollution Keeping soils and ash damp or Covering of problem areas covered or rehabilitate with cloth, or 'soil cement' products
41 Table 6: Extract from the Accountability Matrix of Lethabo Power Station.
Activity Responsible Person Designation Tel. Number EMS E. Lerata Engineering Manager (016) 420-5515 E.M. Tsimba Environmental Officer (016) 420-5008 POLICY E.M. Tsimba Environmental Officer (016) 420-5008 AIR: Dust E.M. Tsimba Environmental Officer (016) 420-5008 Ozone CO2 & SOx D Esterhuizen Boiler Plant Manager (106) 420-5062 NOx WATER: S&G Quantity N.C. Woodhouse Senior Chemist (106) 420-5534 Quality WASTE: Ash Mthombeni Civil Engineer (016) 420-5696 Domestic E.M. Tsimba & Environmental Officer (016) 420-5008 Hazardous Rossouw Ops Dev. (PEA) (016) 420-5634 LAND: Rehabilitation J. Mthombeni Civil Engineer (016) 420-5696 Pesticides G Rapoho Horticulturist (016) 420-5984 ORGANISATION & E. Lerata Engineering Manager (016) 420-5515 HR Z. Dreyer Services (016) 420-5508 J. Hartwig Operating Managers (106) 420-5503 INVESTMENT: Internal P. Steenkamp Power Station Manager (016) 420-5500 External QUANTIFICATION E.M. Tsimba & Environmnetal Officer (016) 420-5008 OF IMPACTS SEAC Members Representatives REGISTER OF E.M. Tsimba Environmental Officer (016) 420-5008 REGULATIONS TARGETS AND E.M. Tsimba Environmental Officer (016) 420-5008 OBJECTIVES MANAGEMENT E.M. Tsimba Environmental Officer (016) 420-5008 MANUAL REPORTING E.M. Tsimba Environmental Officer (016) 420-5008
42 5.3 Water Quality Management
Most of the coal-fired power stations in the study area are wet-cooled. This means that large amounts of water are used to cool the boilers down. Bearing in mind that South Africa is a water scarce country, a reliable supply of water for power generation must be ensured. To this end, reservoirs must be built at the power station to ensure a water supply for several days of power generation. According to the Water Act (Act No. 54 of 1956), once raw water has been used by an industry, it is considered polluted and cannot be released into the environment without treatment. Therefore the power stations also need so- called 'dirty water dams', where the polluted water is stored for re-use, treatment, or is allowed to evaporate.
Eskom developed a philosophy of zero-liquid effluent discharge (ZLED) at all its newer power stations. This implies that within the water management system, a hierarchy of water uses based on quality is established. A system of re-use exists whereby the effluents from one water using system would be utilised by another system, where lower quality water is acceptable, and so consecutively down to final consumption by evaporation or encapsulation in the ashing systems. Water is effectively lost only by evaporation, whilst the accompanying dissolved salts are encapsulated in the coal ash deposits.
Surface as well as groundwater may be polluted from leachates seeping through coal stock yards, coal discard dumps, ash dams, as well as, solid waste sites. Regular monitoring of groundwater at these sites, as well as, downstream, are essential to prevent pollution.
5.3.1 Legal Requirements
South African laws containing sections applicable to water management and pollution include: • Water Act, No. 54 of 1956.
43 Environment Conservation Act, No. 73 of 1989. Water Supply and Sanitation Policy of South Africa 1997.
Permits and Registration Certificates. A copy of the following permits and registration certificates, issued by the Department of Water Affairs and Forestry (DWA&F), allowing the power station to operate these facilities, must be included in the EMP: The Water Permit Any exemptions that allow the power station to release waste water into the environment. Revoked permits should be kept on file. The registration certificates of the Water Treatment Plant. The registration certificate of the power station Sewage Plant where applicable. Registration certificates of the workers in the water laboratories.
5.3.2 Eskom Requirements
Corporate Documents applicable to management of water and water pollution at Eskom power stations: Eskom Environmental Management Policy (ESKPBAAD6) Eskom Water Management Policy (ESKAAPBAAJ4) Procedure: Measurement and Determination of Gross Raw Water Consumption by Power stations and Third-party Users (GGP0460) Eskom Chemistry Standard for Potable Water (NWS1070) Guide to the Considerations for the Preparation of Oil Management Plant and Oil Spill Contingency Plans for Generation Group (GGG0734)
5.3.3 Identified Impacts and Mitigation Measures
Water Supply and Distribution System A complete description of the water system of the power station is needed. In this, the source(s) of water will be given, as well as alternative sources in cases of emergency. The quality of the raw water received is very
44 important, since this will determine whether it will be necessary to treat the water before it can be used in the power station. If treatment is needed, the relevant permits for the water treatment plant, de- mineralisation and desalination plants must be included. Details of the processes should be supplied, as well as the volumes that can be handled, sources of water and destinations of the treated water. Contingency plans for emergency situations must be compiled. These would be situations where untreated polluted water is released due to equipment failures, for example. A plan of the pipeline systems, supplying water to the various users in the power station, and transporting ash to the ash dams, must be included. This will enable the people responsible for water management to identify possible areas where problems or leaks may occur. Contingency plans must be developed to ensure immediate action when water-pipes or ash pipelines burst or have serious leaks. If the cascading system of ZLED is in use, the quality of the water as it reaches the different user levels, must be stipulated. This would prevent water too polluted from entering a certain level. Knowing the quality of water, implies measurement by the different users. A map indicating the sampling positions, as well as the flow meters must be included. Frequency of readings taken and the accepted quality ranges must be stipulated. The allowed water levels in the different dams must be specified - reservoirs, dirty and clean water dams. This would for instance ensure that dams designed to handle excess water are not full during emergencies. Following on from this, the water accounting system used by the power station, or the corporate prescribed system, should be included.
45 Groundwater In order to prevent groundwater pollution the following information must be supplied in the EMP: A map showing monitoring points, normally bore-holes, on the power station property as well as surrounding properties. The frequency of monitoring must be stipulated. A map indicating the groundwater movement is needed, with the position of the different site activities that may pose a pollution threat. These include the ash-dams, dirty water dams, evaporation dams, coal stockyard as well as sewage sludge dams. Monitoring of the waste sites is also necessary. Interpretation of the data gathered has to be done. If the interpretations are done by power station personnel, the procedure for interpretation must be included, as well as the reporting of any possible problems that may be identified. If the interpretations are undertaken by consultants, contact names must be included. The plume flow model to be installed at all the coal-fired power stations needs to be included in the EMP. A procedure regarding the regular updating of this model, must be developed. This enables the environmental practitioners at the power stations, to develop management plans to act on pollution as soon as it is detected.
Sewage Plant Although sewage is seen as a waste product, its impact will be mainly on the water systems at a power station and is therefore discussed under water management. If a power station has a sewage plant, the permit issued by DWA&F must be included in the management plan, with any conditions stipulated, such as special phosphate or sulphur standards imposed on specific catchment areas. A description of the purification method, as well as a diagram of the plant, must be included. The method and location of sludge disposal must be given.
46 Contingency Plans Contingency plans must be developed for the following situations: Ash pipe bursts Heavy rainfalls that may cause overflowing of dams. Oil spills threatening water sources. Spills of chemicals in the laboratories, as well as first aid procedures for contact accidents with the different chemicals used. Sewage spills.
5.3.4 Accountabilities
A detail breakdown of the accountability matrix for water management as well as sewage management is necessary. This would include the Chemical Manager as well as the person(s) responsible for sewerage, groundwater and surface water management, or those responsible for quantity and quality of the water systems at the power station.
5.3.5 List of Contact Numbers
A list containing all relevant contact names, with telephone numbers, regarding water management must be drawn up. This would include: Responsible person(s) at the power station. Responsible medical and safety person(s), in case of chemical accidents. Consultant or power station team leader for oil-spill emergencies. DWA&F - regional and head office. Head Office contact people -including Chemical and Auxiliary Plant Engineering, Hydro & Water Department and Generation Environmental Management. In cases of danger to the public, the local police.
47 5.3.6 Summary
Water Management is dominated by pollution control. Representatives of the Department of Water Affairs and Forestry have made it clear to industry, that any company releasing polluted water will in future be penalised with severe fines (Eskom Hydro & Water Department).
Some of the water related environmental impacts a power station can have is summarised on the next page.
Impact Mitigation Measures in Place Contingency Plan Polluted water Canals, ditches, drains that can Sandbags to divert water away releases divert water back into the from dams, rivers, sensitive power station system areas. Interim dams to catch excess water. Ash disposal Maintenance available Shutting down of ash transport structure failures immediately system Groundwater Monitoring through bore-holes Emergency ditches to catch Pollution Diversion ditches/canals to seepage. catch seepage. Sewage water Diversion channels around Shutting down of sewage plant releases plant to catch releases Overflow of dirty Dam levels must be monitored Emergency dams that will water or other to ensure lowest possible level catch any overflow from dirty dams containing are maintained dams effluent
48 5.4 Waste Management
Waste is a liability to industry, society and the environment. This can be expressed in financial, environmental, social, health or legal terms. An integrated approach is required to minimise and manage waste and associated risk in a cost effective manner.
Although considered a resource in most other countries, coal ash produced from the burning of coal is at present still considered a waste product in South Africa. Large amounts of this ash are produced every month, and transported to ash dams or dumps. These ash dams have to be rehabilitated as soon as possible, to prevent dust problems. The groundwater in the area has to be monitored regularly to detect pollution that may be caused by leaching.
The other wastes produced at a power station include domestic/office waste, building rubble, medical waste, hazardous waste, discarded equipment (metal), liquid effluents and sludge from sewage and water treatment plants. These wastes all have to be disposed of as safely as possible to prevent unnecessary environmental impacts.
5.4.1 Legal Requirements
South African laws containing sections applicable to waste management and pollution include: The Environment Conservation Act, No. 73 of 1989, The Water Act, No 54 of 1965, The Health Act, No. 63 of 1977, Atmospheric Pollution Prevention Act, No. 45 of 1965, The Hazardous Substances Act, No. 15 of 1973, The Minerals Act, No. 50 of 1991,
49 5.4.1. Eskom Requirements
Corporate Documents applicable to management of waste products: ESKOM Environmental Policy (ESKPBAAD6) Waste Management Policy (ESKPBAAC4) Requirement for the Safe Processing, Storing, Removing and Handling of Asbestos or Asbestos Containing Materials (EVP076) Occupational Health Practice (EVD1100) Oil Spill Clean-up and Rehabilitation Guideline (ESKAGAAD7) Minimum Requirements for Waste Management Corporate Directive for the Management of PCBs (ESKADAA02) PCB Management Standard (ESKASAAC2) Considerations for the Preparation of Oil Management Plant and Oil Spill Contingency Plans for Generation Group (GGG0734 Draft)
5.4.3 Identified Impacts and Mitigation Measures
Waste Stream Identification Identification of the waste stream originating from the power station site, is an important part of waste management. This will include office waste, laboratory wastes, garden wastes, building rubble, as well as kitchen wastes, workshop wastes, and the coal-ash. The approximate amounts of the different types of waste should be noted, as well as the removal procedures.
Domestic Waste Site If the power station has its own domestic waste site, the permit granted by DWA&F, for the running of this site must be included in the EMP. Co-ordinates, as well as a layout plan of the waste site must be supplied. Groundwater monitoring points around and inside the site must also be indicated. The measures as well as any contingency plans developed in cases of pollution of the groundwater, must be mentioned or cross- referenced to the water management section of the EMP
50 If waste separation takes place at the waste site, this must be specified, with a description of which wastes can be co-disposed, or where the different wastes are to be dumped. If less hazardous wastes, or sufficiently small amounts of hazardous wastes (such as fluorescent tubing and alkaline batteries) are disposed of on a domestic site, this must be clearly indicated on a map. To prevent general use, or scavenging on the waste site, an indication of the security measures should be supplied. The end-use plan of the waste site must be included in the EMP. This would contain the rehabilitation needed after closure of the site, to obtain a closure permit from DWA&F. Although a closure permit may be granted, the department requires monitoring for possible pollution from a waste site, for 30 years after closure. The frequency and procedures for this monitoring programme must be included.
Recycling Many of the waste products at a power station can be re-used. Procedures for handling and storage of recyclable wastes, must be included.
Metal: The types of metal that can be recycled must be indicated, as well as the minimum amounts that the appointed contractor(s) will remove. The areas used for storage of waste metals must be shown on a map.
Paper: A description of the types of recyclable paper and separation procedures must be available. A list of contractors available, should be compiled. The company collecting paper from a power station is in many cases also prepared to remove glass and tins. If this has proved to be economical, the same steps regarding separation, storage and removal must be followed.
Oil: Power stations use large amounts of various kinds of oil products, such as fuel and lubricating oil. The cleaner waste products of these can be re-used through refining.
51 The types of waste oil with its approximate quantities available on a monthly or quarterly basis, need to be indicated. Storage requirements must be noted. The oil products that the removal company, such as Oilkol can not re-use, is considered a hazardous waste and must be handled as such. The procedures for this can be included either under this section, with the hazardous waste, or under a separate section dealing specifically with oil. Oils containing polychlorinated biphenyls (PCBs) are also classified as hazardous and should be handled as such. PCBs are semi-volatile organic compounds, produced from 1930 to 1977. The substance was widely used in transformers, capacitors, printing inks, paints, pesticides and many other applications, due to its chemical and physical stability and electrical insulating properties. These same properties however prevent PCBs from degradation. They are thus persistent and tend to bio-accumulate. An apparent link to carcinogenesis was also discovered. All these negative effects of the substance led to its regulation by declaring any product containing more than 45 parts per million (ppm) PCBs, as PCB-contaminated. (Eskom, 1993a)
Oil spills are considered serious problems throughout Eskom. Oil spill contingency plans must be developed and included in the Waste Management Plan. This will describe the actions to be taken in cases of an oil spill, where containment equipment is kept, as well as the eventual rehabilitation of any soil polluted through oil spills.
Other re- usable wastes: Garden waste, as well as building rubble, although classified as waste, is often re-used as a stabilising material on the ash dams. The collection points for these products must be indicated. At many power stations, kitchen wastes are used as a food source for animals kept on the power station site, or on nearby properties. The removal and distribution of these wastes must be described.
52 Hazardous Waste Only Tutuka Power station has a registered hazardous waste site at present. Some of the other power stations have waste sites for asbestos disposal, which are also classified as hazardous waste sites. The permits granted by DWA&F, allowing the relevant power stations to operate these sites, must be on display at all times. The detailed layout of the site must be available, with a list of the types of hazardous wastes and its quantities, that will be allowed onto this site. A rehabilitation plan must be developed for areas of the waste dump that have been filled with waste products. A management plan that will include closure procedures and groundwater monitoring for pollution detection, must be developed. The security measures at the hazardous waste site must be given in detail. The power stations that do not have a hazardous waste site, must describe in detail what is classified as hazardous waste as well as, the handling and storage of these products. This will include wastes such as asbestos, medical waste, fluorescent tubes and batteries. It is advisable to obtain a copy of the waste site permit of the contractor(s) that removes these wastes.
Ash Dams/Dumps As mentioned before coal ash produced after combustion of the coal is by far the largest waste product of the coal-fired power stations. The ash dams or dumps, where this ash is disposed of, are possibly the largest single-product waste sites in the country.
In order to manage these sites the following information must be available on maps: Co-ordinate positions of the coal ashing sites. This would include all old, present, as well as possible future ashing sites. A site layout plan, including the planned sequence of ashing. Groundwater monitoring points.
53 To prevent dust-blown problems, the ash dumps are kept damp. The source of water for this purpose must be indicated, as well as the method used for keeping the ash damp.
5.4.4 Accountabilities
A detail accountability matrix of the responsibilities regarding all waste matters has to be compiled. This would include hazardous and non-hazardous waste, as well as recycling accountabilities.
5.4 5 List of Contact Numbers
A list containing contact names, with telephone numbers, of people involved with waste management. This would include: Accountable person(s) at the power station Head Office contact people - including Generation Environmental Management Waste contractors Recycling companies Emergency numbers in cases of oil spillages
5.4.6 Summary
Development of waste sites on any property is subject to a permit from DWA&F. The Department may pose certain conditions, such as lining the site with plastic liners and the size of the site. The most important impact that can be caused by a waste site, is the leaching of organic substances and minerals into the surface and groundwater, as well as into soils. Another impact may be litter accumulation caused by uncontrolled dumping. The possibilities of recycling and re-use of waste products, is a positive impact of waste production.
54 Impact Mitigation Measures in Place Contingency Plan Pollution of water Monitoring bore-holes and ditches Development of ditches and soils through to catch leachates. further away from the site to leachates Lining of waste sites, including catch overflow of existing ash ing site ditches. Uncontrolled Strict control at site Policing of site and dumping prosecution if needed Oil spills Oil bunkers and traps. Availability Emergency teams on stand-by. of containment and clean-up equipment
55 5.5 Land Management
An attempt to develop a land management policy for Eskom was made a few years ago, however, this initial effort was postponed due to the complexity of land management in Eskom. Another effort in developing such a policy will be attempted in 1998. Issues that were identified as potential risk areas, that would need management plans at a power station include: rehabilitation, veld management, land utilisation and security fence management.
5.5.1 Legal Requirements
South African laws containing sections applicable to land management include:
The Environmental Conservation Act, No. 73 of 1989. The Conservation of Agricultural Resources Act, No 43 of 1983. Agricultural Pests Act, No. 36 of 1963. Fencing Act, No. 31 of 1963. Fertilisers, Farm Feeds, Agricultural Remedies and Stock Remedies Act, No. 36 of 1947. Water Act, No. 54 of 1956. Nature Conservation Ordinance of Transvaal, Ordinance 12 of 1983.
5.5.2 Eskom Requirements
Although an Eskom policy has not been developed, the following Eskom documents are applicable to land management: Eskom Environmental Management Policy (ESKPBAAD6) Waste management Policy (ESKPBAAC4) Environmental Impact Assessment Policy (ESKPBAAA9)
Environmental Impact Assessment Procedure (ESKPVAAL7) Herbicide Management Policy (ESKPBAAB4)
56 Guidelines to establish Fire-breaks around Power stations using Herbicides (TRR.S .91/097) Guidelines for Chemical Mowing of 'Species Switch' between Security Fences using Herbicides (TRR/S.92/084) Guide to the Legal Requirements relating to Oil Spills (ESKAGAAD6) Oil Spill Clean-up and Rehabilitation Guideline (ESKAGAAD7) Considerations for the Preparation of Oil Management Plant and Oil Spill Contingency Plans for Generation Group (GGG0734 Draft) The Control of Dust Exposure Within Eskom (EVD 1165) Particular Contract Specifications - Landscape Rehabilitation Revegetation, Monitoring and Rehabilitation of Ash and Solid Waste Disposal Sites.
5.5.3 Identified Impacts and Mitigation Measures
Land Management General management of land, requires regular inspections, especially areas with an erosion potential. Sources of stabilising materials for erosion control must be given. This would for instance include the garden wastes and building rubble that is produced at the power station. The power station property must be kept clean of all invader and exotic plant species. Lists of these plants must be available. Where exotic tree species, such as blue gums are used for water control, these must be indicated on a map. Plans should be developed to control these trees from spreading to adjoining properties. The locations of identified endangered plant species must also be indicated on a map. A management plan must be developed to further protect these species. The same maps and plans should be developed for animal and bird species encountered on the power station property. Flight paths of migrating birds must be indicated and taken into account when the construction of buildings or the development of new ash dams are undertaken.
57 Rehabilitation The main rehabilitation programme at a power station, is that of the ash dams. The areas available for rehabilitation are those that will not be used for ashing any longer. The rehabilitation schedules, with the source of topsoil used for cover, the specific seed mixtures and suppliers thereof should be mentioned. The irrigation frequency of the rehabilitated areas must be stipulated, as well as the source of water. Rehabilitation of waste dumps will follow the same process as that of the ash dams. Initially regular monitoring of the rehabilitated areas is needed to ensure that rehabilitation was successful.
Fire Breaks The making of firebreaks must be well planned and scheduled. All affected parties must be informed beforehand. A list of neighbouring farmers is thus essential, while emergency personnel must be on standby in cases of run away fires occurring.
Herbicide and Pesticide Use Lists of the different herbicides and pesticides in stock and their application procedures must be available. The amounts used, the reason for use, as well as the area of use must be recorded. Contingency plans in cases of spillages must be available, stipulating actions to be taken to contain the spillage, as well as treatment in cases of contact with hazardous substances. If any of the products used poses a danger to the public, clear indications of this must be given. If large amounts are to be used, the local police, as well as neighbouring communities must be informed whenever these products will be in use. The power station must ensure that the safety data sheets of all products used, must be available to the power station chemist. This person can then where possible, recommend alternative, less hazardous products.
58 Wildlife Management Where a power station has wildlife such as zebra and buck, a procedure for management of the veld is needed. This will include maintenance of grazing and watering, and the general condition of the veld. Clear indications of the carrying capacity of the property must be given and the size of herds must be controlled accordingly. Permits granted by the Department of Environmental Affairs and Nature Conservation, allowing the power station to keep wildlife must be kept on file. Regular inspections are needed of the animals to ensure that no sicknesses enter the area that may pose a threat to other animals in the area. Fences must be inspected to prevent animals from entering onto neighbouring properties. Procedures regarding poaching must be developed together with the security department. Contact names and numbers of representatives from Nature Conservation must be available.
Wetlands Wetlands on the property must be indicated on a map, showing inlet and outlet areas. Plans to maintain these areas must be developed, including pollution prevention from the power station water system. Lists of the animals and birds occurring in the wetland areas, must be compiled and diversity checks should be undertaken on a regular basis. Checks such as these can form part of an awareness strategy, where the power station personnel or school groups are involved to help with identification of the various species.
Land Utilisation In cases where parts of the power station property are leased to local farmers, their names and details of the lease agreement, must be available. This would stipulate the name of the contract holder, the type of farming or
59 grazing that will take place, the length of the contract, as well as any specific conditions or responsibilities of either party.
Security Areas and Servitudes The maintenance needed in security areas and servitudes on the property must be described. This would include herbicides used. If security fences are electrified, the voltage must be given. If in lethal mode the fences must be regularly checked, as these often cause animal and bird mortalities, which may attract scavenger species and cause more deaths.
5.5.4 Accountabilities
A detailed breakdown of the various accountabilities regarding land management, such as rehabilitation, herbicide or pesticide usage and wildlife management must be developed.
5.5.5 List of Contact Numbers
A list containing all relevant contact names, with telephone numbers, regarding land management must be available. This would include: Responsible person(s) at the power station in the various sections of land management Emergency numbers - e.g. herbicide and pesticide poisoning Nature Conservation - local, provincial and/or national representatives Head Office: Generation Environmental Management, Farmers renting Eskom land, as well as neighbouring land owners.
5.5.6 Summary
Land Management includes a host of issues to be addressed that may often overlap with other areas of environmental management at a power station. General management of the property will prevent soil erosion, invasion of
60 exotic invader plants and animals, while particular attention should be given to areas such as wetlands and areas that have to be rehabilitated after usage, such as ash dams and waste sites.
Impact Mitigation measures in place Contingency Plan Erosion of soils Regular inspection of property, rehabilitation Uncontrolled Strict control at site Policing of site and dumping prosecution if needed Fire breaks and Fire-fighting teams managing fire Municipal fire-fighting teams veld fires breaks, on stand-by for on stand-by. emergencies. Pollution of soils - Oil containment and clean-up Municipal, regional, national oils spills, chemical equipment available. Teams contacts in serious cases of spills, herbicide trained to handle containment or spills. Police, hospitals on spills clean-up. Medical centre equipped stand-by when public is in to handle chemical spill injuries. danger. Evacuation procedures available and known to all personnel.
61 6. CONCLUSIONS
After studying the various Eskom Power Station Environmental Management Plans already in existence relative to power stations, it became clear that although not in a formal prescribed format, the documents are relatively complete and most contain the information that is required by the Generation Environmental Management Department. It was, therefore, decided to develop a generic plan that could be utilised by all power stations as a guideline in developing or updating the individual power stations' management plans. By using this Generic Environmental Management Plan, the power station EMP's will all be in the same format, and auditors will be able to identify gaps more easily. Where certain of the impacts listed in the generic plan, are not of relevance to a power station, the EMP will state: Not applicable. On the other hand, where a power station has an impact that was not identified in the generic plan, this should be very clearly stated as a site specific impact. This impact should also be made known to other power stations, as it may well occur elsewhere.
Some of the information required in the Generic Plan that was developed, seems to be unnecessary, such as the section on Background Information. It must, however, be kept in mind that although this information may not be used on a day-to-day basis, it is necessary to have the data compiled, as it may be needed for further developments on the power station property. During 1997, the Conservation Act was amended to legislate Environmental Impact Assessments for all projects, including upgrading of existing projects and structures. The kind of data included in the Background Section will be invaluable for these assessments.
The Management Plan developed in this study, was not meant to be a pro- active document, as all the power stations are already in the production phase and impacts
62 are known. The document is meant to be a guideline for the impacts that should be considered in an Environmental Management Plan for these existing structures.
From the documentation studied, it became clear that the main impacts a coal- fired power station has on the environment, are: air pollution, water pollution, waste production and land degradation. These were the main management issues considered in the development of a generic guideline document.
Air Quality Control: The main issues are the emission of particulates and gases, which contribute to pollution of the atmosphere. Different methods of minimising the emission of particulates exist, while minimising gaseous emissions are at present not cost effective in South Africa.
Water Management: Power stations use large volumes of water for the generation of electricity. Most of this water is considered polluted after utilisation and thus has to be contained on the property. Although Eskom has a policy of Zero Liquid Effluent Discharge, the possibility of pollution of surface and groundwater always exist. Therefore, a management plan of the complete water system is necessary to prevent pollution, as well as a procedure that should be followed when unscheduled spillages of water into the environment do take place. Apart from unscheduled water spillages, contingency plans for other emergency situations, such as oil spillages, chemical accidents, as well as heavy rainfall periods must be developed.
Waste Management: The biggest concern regarding waste sites are the potential for pollution. This is true for solid and hazardous waste sites, as well as, ashing sites. Schedules of the amounts and types of wastes dumped are of great importance, as it will assist in managing pollution, if this happens.
63 Re-use, reduce and recycle, are important concepts to be investigated for waste products. Recycling may not be economical in all cases, but re-use and reduce can make a difference in the amount of wastes that have to be dumped.
Land Management: Management of a power station property encompasses diverse issues, from preventing soil erosion, eradicating alien fauna and flora to managing reserve areas and hiking trails. The most important issues are however, the prevention of erosion and the rehabilitation of ashing sites.
All of the above issues, require regular inspections, routine maintenance, as well as, plans for emergency situations. Environmental Management Plans should be regularly updated to include new technologies, products and programmes as these become relevant at a power station.
Although some writers (Lucas, 1997 and Visser, 1995), insist that Management Plans should include time frames for the management of impacts, it is felt that this should rather form part of a power stations' technical plan for a specific year, or the longer term, five-year plans. The Management Plan should rather be used as a document containing information on the measures that will ensure the environment is utilised sustainably, and how to manage pollution incidents when these occur.
If a new power station is considered, and a full EIA has to be undertaken, this generic document may be utilised as a pro-active guide to the possible impacts, mitigation and monitoring measures that will have to be taken into account during the production phase of a power stations' life.
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