PROPOSED WASTEWATER STORAGE AND RECYCLE SYSTEM AT RICHARDS BAY COAL TERMINAL Co (Ltd)

Prepared by

SKP Engineers cc PO Box 326, Westville, 3630 Tel: 031-2668101 Fax: 031-2669001

April 2004

PROPOSED WASTEWATER & RECYCLE SYSTEM AT RBCT

SKP Engineers cc

INDEX

EXECUTIVE SUMMARY......................................................................................................................................... 3 1. 2. 3. BACKGROUND................................................................................................................................................. 5 OBJECTIVE ....................................................................................................................................................... 5 REGULATIONS ................................................................................................................................................ 6 3.1 PREVIOUS WATER ACT .............................................................................................................................. 6 3.2 NATIONAL WATER ACT ............................................................................................................................. 6 3.2.1 Definitions ............................................................................................................................................... 6 3.2.2 Quality / quantity of wastewater discharge ............................................................................................. 7 3.2.3 Capacity requirements of dirty water systems ......................................................................................... 7 3.2.4 Storage of water containing waste for re-use.......................................................................................... 7 3.3 MARINE WATER QUALITY GUIDELINES ................................................................................................ 7 3.4 STATUTORY REQUIREMENTS .................................................................................................................. 7 4. PRESENT SITUATION .................................................................................................................................... 8 4.1 SOURCE OF WASTEWATER ....................................................................................................................... 8 4.2 EXISTING SURFACE WATER MANAGEMENT SYSTEM........................................................................ 8 4.3 QUALITY OF WASTEWATER ..................................................................................................................... 9 4.3.1 Total Suspended Solids............................................................................................................................ 9 4.3.2 Oils, Soaps & Grease ............................................................................................................................ 10 4.3.3 Faecal coli forms................................................................................................................................... 10 4.3.4 Chemical Oxygen Demand .................................................................................................................... 11 4.3.5 Colour ................................................................................................................................................... 11 5. SPECIALIST STUDIES .................................................................................................................................. 11 5.1 CONCLUSIONS............................................................................................................................................ 12 5.2 RECOMMENDATIONS ............................................................................................................................... 12 6. PROPOSED WASTEWATER STORAGE & RECYCLE SYSTEM ......................................................... 13 6.1 TARGET DILUTIONS .................................................................................................................................. 13 6.2 DESIGN DEPTH OF PRECIPITATION ....................................................................................................... 13 6.3 DETERMINATION OF STORAGE VOLUME ............................................................................................ 14 6.4 PROPOSED STORAGE AND RECYCLE SYSTEM ................................................................................... 16 6.4.1 Settling Ponds........................................................................................................................................ 16 6.4.2 Storage/Retention Ponds ....................................................................................................................... 16 6.4.3 Discharge Canal ................................................................................................................................... 17 6.4.4 Recycle Water........................................................................................................................................ 17 6.5 MODIFICATION OF EXISTING STORMWATER OUTLETS .................................................................. 17 6.6 MONITORING PROGRAMME ................................................................................................................... 17 6.6.1 Monitoring at Settling Ponds ................................................................................................................ 17 6.6.2 Monitoring at Storage/Retention Pond Outlet Works ........................................................................... 17 6.6.3 Monitoring of Marine Water ................................................................................................................. 17 6.7 RISK ASSESSMENT .................................................................................................................................... 18 6.7.1 Settling Ponds........................................................................................................................................ 18 6.7.2 Storage/Retention Ponds ....................................................................................................................... 18 7. 8. MITIGATION MEASURES AND ARGUMENTS SUPPORTING PROPOSED SCHEME ................... 18 CONCLUSION ................................................................................................................................................. 19

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EXECUTIVE SUMMARY
The Richards Bay Coal Terminal (RBCT) is involved in receiving, storing and exporting unsized washed coal from Richards Bay Harbour. The Terminal occupies an area of approximately 200ha of which 110ha is allocated to storage of coal in open stockpiles. The main source of the wastewater is stormwater runoff from the coal stockyards and roadways. Although the stockpiles are sprayed twice a day, very little runoff reaches the settling ponds. This is because the amount of water sprayed onto the coal stockpiles is just sufficient to wet the surface of the stockpiles to reduce the generation of airborne dust. Presently surface water runoff is collected in settling ponds designed to contain the first flush volume arising from 20 minutes of runoff from a 1 in 20 year storm event. The capacity of these ponds is insufficient to contain any reasonable rainfall, resulting in frequent overflow into the harbour. Over the past 7 years various improvements have been made to the surface water management system. More recently new settling ponds have been constructed under the wharf conveyors to eliminate the exceptionally high concentrations of suspended solids being discharged from this source. Various specialist studies were commissioned for the Phase 5 Expansion EIA. During the EIA process a Baseline Study was carried out at the request of the DWAF to determine the impact of the current operation on selected aspects of the aquatic ecology in the harbour adjacent to RBCT. Although it is concluded that the stormwater discharge from RBCT has had no measurable impact on the harbour, the specialists recommend that the current surface water management system be improved to reduce the quantity of wastewater discharge and quantity of waste present in the water. Dr. A Connell of the CSIR also recommends that the suspended solids in the stormwater runoff be limited to 50mg/l and that the stormwater be discharged below the surface water level to achieve better dilution. A review of the statutory requirements was carried out to establish regulations dealing with the disposal of wastewater into a marine environment and the storage of wastewater for re-use. It became apparent that no clear statutory requirements exist for the disposal of water containing waste into a harbour, since in terms of the regulations a harbour is not a water resource. Design parameters and limits will therefore need to be approved by DWAF taking into consideration technical, economical, social and environmental aspects of the proposed storage / disposal system. Samples of water taken from the existing settling ponds are tested regularly and compared with the General Limit Values. Typically the concentration of suspended solids exceeds the GLV by an order of magnitude on rain days. However if the water is allowed to stand the concentration of suspended solids has been found to decrease to less than 25mg/l in a 48 hour period. The proposal is to collect all surface water runoff generated during dry weather conditions and for rain events not exceeding the design storm, and to pump this water into storage/retention ponds where the water will be allowed to stand. After the suspended solids have settled out to acceptable levels the clear water will be pumped back to the storage reservoirs on site and recycled. Since the current impact on the harbour is minimal, it is not justified in terms of economic or environmental considerations to design for large storm events. Recognising this, the regional

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office of DWAF agreed in principle to accept 5% non-compliance i.e. not more that 18 discharges a year. Using an upper limit of 5% non-compliance, it was established that the proposed stormwater system should be designed for 60mm daily rainfall and that 80Ml of storage would be required to ensure that neither the settling ponds nor storage/retention ponds overflowed more than 18 times a year. This was done using the historical record for Richards Bay which goes back to 1923. When the design storm is exceeded, the installed pumps will have insufficient capacity to pump the flow into the settling ponds to the storage/retention ponds, and water will overflow into the emergency bypass system. In mitigation this will happen infrequently and at times when the concentrations in the seawater will be elevated. The existing stormwater outlets from the terminal settling ponds will be maintained as emergency bypasses. However, it is proposed that a length of pipe be connected to each of these outlets on the coal quay so that the excess stormwater is discharged below the surface. The proposed scheme will meet the objectives to reduce the quantity of wastewater and waste in the water since: i) ii) iii) iv) v) Under normal weather conditions no wastewater will be discharged from the site. During extreme wet weather conditions the settling ponds and storage/retention ponds are unlikely to overflow more than 10 times/year and 17 times/year respectively. This is significantly less than the present situation and is less than 5% of the time. Overflow from the storage/retention pond during large storms is likely to have a concentration of suspended solids of less than 50mg/l since the incoming water will be diluted by the clear water in the ponds. The proposal to modify the existing stormwater outlets so that the wastewater is discharged below the water surface will reduce the aesthetic impact of the dirty water plume. Rainfall in excess of the design value will overflow into the harbour via the emergency bypass systems. During these events the concentration of suspended solids will exceed ambient level by more than 10%. However the quality of the water in the harbour will also have much higher concentrations of waste emanating from runoff from industries in the area. When the system is overloaded, stormwater will be discharged at points approximately 300m apart along the coal quay, at an outlet opposite SP10 at the southern end of the terminal, and at the canal outfall from the storage/retention pond. The effect of this will be to distribute the discharge over a larger area thereby decreasing the concentrations of waste in the seawater and hence reducing the required number of dilutions to meet the Water Quality Guideline Values for Marine Waters. RBCT will reduce its potable water consumption by approximately 350Ml per annum. RBCT will extend the monitoring programme to include testing samples of seawater taken opposite the stormwater outlets.

vi)

vii) viii)

RBCT is committed to achieve and demonstrate sound environmental performance. They have recently been accredited ISO 14001 certification and have undertaken to implement the proposed scheme at a cost exceeding R30million even if the Phase 5 Expansion does not go ahead. RBCT have been involved in negotiations with the DWAF to licence their stormwater discharge since 1993. Key elements in the imminent Phase 5 Expansion Project are affected by this proposal. It is therefore essential that approval be obtained as a matter of urgency.

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1.

BACKGROUND
Richards Bay Coal Terminal (RBCT) is located in the South Dunes area of Richards Bay Harbour. Its function is to receive, store and export washed unsized coal of nominal size less than 50mm from Berths 301 to 305. RBCT commenced operations in 1976 with a throughput capacity of 12 million tonnes per annum (Mt/a). Increasing demands for steam coal has resulted in four major expansions at the Terminal raising its export capacity to 72 Mt/a. The Terminal occupies an area of approximately 200 ha of which 110 ha is used to stockpile coal. The stockyards are constructed on engineered fill graded to falls. A compacted layer of carpet coal seals the surface and forms the working platform. RBCT is committed to achieve and demonstrate sound environmental performance. Environmental protection and conservation are key aspects in their mission statement. In pursuance of this objective, RBCT initially adopted the BS 7750 management system. In 1993 RBCT was accredited ISO 14001 certification. Since 1993, RBCT has had numerous meetings with officials from the Department of Water Affairs & Forestry (DWAF), and has submitted various applications to DWAF to licence the discharge (water containing coal) from the Terminal. To date no applications have been approved. In 1997 RBCT voluntarily commissioned a programme to reduce wastewater emissions from the Terminal. This entailed inter alia modifying the existing settling ponds to contain the first flush volume arising from 20 minutes of runoff from a 1 in 20 year storm event and more recently installing new settling ponds under the wharf conveyors. Shortcomings in this surface water management system were identified in the proposed Phase 5 Expansion Environmental Impact Assessment. Various specialist studies were carried out to determine the impact of the proposed expansion on the environment and it was recommended that runoff arising from normal rain be collected and recycled. Environmental approval for the Phase 5 Expansion Project was obtained March 1993. In parallel to the Phase 5 Expansion EIA process, DWAF required that a Baseline Study be carried out to determine the impact of the current operation on selected aspects of the aquatic ecology in the harbour adjacent to RBCT. The findings of this and other specialist studies are summaries the report A summary of findings from a series of specialist studies of the impact of Richards Bay Coal Terminal current operations, on the natural environment surrounding the facility in Richards Bay harbour prepared by Dr AD Connell, CSIR.

2.

OBJECTIVE
This objective of this Technical Report is to present a proposal to DWAF in sufficient detail to enable the Department to licence the discharge from RBCT.

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3.

REGULATIONS
Although policy statements relating to marine disposal were provided by the DWAF under the previous Water Act (Act 54 of 1956), the authors are not aware of any policies under the new National Water Act (Act 36 of 1998).

3.1

PREVIOUS WATER ACT Under the previous Water Act (act 54 of 1956), exemptions to discharge to sea were granted under the following conditions: a) b) c) d) e) An official application has been lodged with the DWAF. A full scale EIA based on Integrated Environmental Management principles has been carried out to determine the best disposal option for the effluent. It is neither justified nor practically feasible to treat the effluent sufficiently to return it to its source of origin or to make it available for re-use. The effluent will not result in the deterioration of the marine environment to such an extent that it interferes with the beneficial uses. Public opinion has been taken into consideration.

Upon approval exemption was granted containing specifications on the volume and quality of the effluent and the specific area of discharge. 3.2 NATIONAL WATER ACT The National Water Act (Act 36 of 1998) (NWA) regulates the use, storage and disposal of water into a water resource. The statutory requirements applicable to RBCT are discussed below. 3.2.1 Definitions The Act defines the meaning of the following words or phrases as follows: Commercial activity means those activities identified in the Standard Industrial Classification of All Economic Activities. Domestic wastewater means wastewater arising from domestic and commercial activities and premises, and may contain sewage. Estuary means a partially or fully enclosed body of water which is open to the sea permanently or periodically and within which the sea water can be diluted, to an extent that is measurable, with fresh water drained from land. Waste includes any solid material or material that is suspended, dissolved or transported in water (including sediment) and which is spilled or deposited on land or into a water resource in such volume, composition or manner as to cause, or to be reasonably likely to cause, the water resource to be polluted. Wastewater means water containing waste, or water that has been in contact with waste material. Water resource includes a watercourse, surface water, estuary or aquifer. The definition specifically does not include marine environments.

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3.2.2 Quality / quantity of wastewater discharge Since no major watercourses drain into the Richards Bay Harbour, it is highly improbable that the harbour can be classified as an estuary. This being the case the Richards Bay Harbour is not a water resource and therefore the regulations concerning the quality and quantity of wastewater discharge into the harbour do not apply. 3.2.3 Capacity requirements of dirty water systems Capacity requirements for dirty water systems discharging into a marine environment are not regulated by the Act. The requirements contained in the Regulations on Use of Water for Mining and Related Activities aimed at the Protection of Water Resources do not apply since the harbour is not a water resource. 3.2.4 Storage of water containing waste for re-use In terms of Regulation 4.7 of Section 39 of NWA (General Authorisations), a person may store up to 5000 cubic metres of domestic and/or biodegradable industrial wastewater for the purpose of re-use. However it can be argued that this regulation is intended to limit the storage of water which otherwise could have been used by a downstream user. For the case under consideration, since the source of the water is rain and the point of discharge is the Richards Bay Harbour, the author can see no justification to place a limit on the quantity of water to be stored for re-use. 3.3 MARINE WATER QUALITY GUIDELINES Although not legislated, the South African Water Quality Guidelines for Coastal Marine Waters (DWAF, 1995) provide a reference framework for settling marine quality objectives for the natural environment. These guidelines set target values to be met for coastal marine waters but do not offer any guidance on design parameters to be used for the dirty water system. 3.4 STATUTORY REQUIREMENTS In terms of Schedule 1, Clause 1f of the NWA a person may, subject to the Act, discharge: i) ii) waste or water containing waste; or run-off water, including stormwater from any residential, recreational, commercial or industrial site, into a canal, sea outfall or other conduit controlled by another person authorised to undertake the purification, treatment or disposal of waste or water containing waste, subject to the approval of the person controlling the canal, sea outfall or other conduit.

It is apparent that no clear statutory requirements exist for the disposal of water containing waste into the Richards Bay Harbour, which is permitted in terms of the above regulation. Design parameters and limits will therefore need to be approved by DWAF taking into consideration technical, economical, social and environmental aspects of the proposed storage / disposal system.

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4.

PRESENT SITUATION
The source of the wastewater and operation of the existing first flush system is briefly described below.

4.1

SOURCE OF WASTEWATER The prime source of wastewater is stormwater runoff from the coal stockyards and roadways. Although the stockpiles are sprayed twice a day (currently with potable water), very little runoff reaches the settling ponds. This is because the amount of water sprayed onto the coal stockpiles is just sufficient to wet the surface of the stockpiles to reduce the generation of airborne dust. The other source of wastewater is from cleaning the conveyors and washing of equipment (wash down water). It should be noted that all surface water runoff at RBCT is collected in a single system, with no provision having been made from inception (1975) for the separation of clean (roofs) from dirty (ground surface) runoff. The proposal contained in this document does not change this principle.

4.2

EXISTING SURFACE WATER MANAGEMENT SYSTEM At present all the surface water runoff is collected in settling ponds located around the site. The locations of the main settling ponds are shown in Figure 1. The purpose of these ponds is to capture the first flush volume, which is assumed to carry most of the suspended and transported solids collected from the stockpiles and roadways. When the ponds are full, subsequent flow bypasses the ponds and is discharged directly into the harbour. It should be noted that only settling ponds SP 1, 2, 4, 10, 12A and 13 discharge directly into the harbour. Flow from the other settling ponds pass through SP2, SP10 , SP12A and SP18. After it has rained, the water is allowed to stand for period of 48 hours so that the suspended solids can settle out. It has been established from tests that the Total Suspended Solids (TSS) reduces from 500mg/l to less than 25mg/l in a 48-hour period. After the settling period has elapsed, valves that are connected to floating strainers (Dolphins) are opened to empty the ponds. The clear water is emptied into the stormwater bypass system that ultimately discharges into the harbour. The valves are then closed. Since water is drawn off from just below the surface, any oil that may have found its way into the pond will be left behind for later removal.

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Figure 1 Existing Terminal 4.3 QUALITY OF WASTEWATER Water discharged from RBCT is sampled regularly and the results are submitted to the DWAF Regional Office for their monitoring. The samples are tested against the General Limit Values although the Marine Water Guideline Limits are considered to be more appropriate. Limits that are most often exceeded are: Total Suspended Solids Oils, Soaps & Grease Faecal Coli forms Chemical Oxygen Demand Colour

Each of these will be discussed in more detail below. 4.3.1 Total Suspended Solids Test results for samples of water taken from settling ponds during a storm event lasting more than one day are shown in Table 1. These results show that the TSS present in the settling pond increases with increased rainfall intensity. The concentration of TSS generally exceeds 25mg/l when the settling ponds overflow on rainy days.

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However, during dry weather conditions, the quantity of daily surface water runoff is very small relative to the installed storage capacity of the settling ponds. Under these conditions the settling ponds seldom, if ever, overflow. They are however routinely emptied after the concentration of TSS has decreased to less than 25mg/l. Table 1 TSS measured at settling ponds during rainy periods Date Pond SP 7
20/9/2000

Location Bypass weir Discharge valve Discharge valve Discharge valve Discharge valve Discharge valve Bypass weir Discharge valve Inside pond Bypass weir Inside pond Bypass weir Inside pond Bypass weir Inside pond Bypass weir

Antecedent Rainfall TSS (mg/l) (mm) 109 71 103 221 235 146 313 331 1254 2577 1229 2348 280 241 588 402 405 (over 3 days) 237 (over 2 days) (ponds overflowed on 18/11/2000) 39 (over 2 days) (ponds overflowed on 19/9/2000)

Daily Rainfall (mm) 44

SP 9 SP 12A SP 1 SP 2

20/11/2000

SP 4 SP 12A SP10/14 SP 7 SP 7 SP 8 SP 8 SP 12 SP 12 SP 12A SP 12A

155

21/11/2000

38

4.3.2 Oils, Soaps & Grease Most of the oil spillage occurs at the tipplers. Oily water containing fine coal particles is either pumped or gravitated to an oil trap near each of the tipplers where it is removed by recycling the water through a mechanical oil-separating unit. The treated water is finally discharged into the stormwater system. Oily water that occasionally overflows into the stormwater system when the traps are overloaded during heavy rainfall is trapped in SP2 or SP12A. Localised oil spillage occurring at the conveyor drive stations, diesel-filling points and workshops are dealt with at the source. However, as all of the runoff from site is routed through settling ponds, oil from these sources will ultimately be collected in the ponds where it is removed. 4.3.3 Faecal coli forms Faecal coli form counts over 1000 are occasionally recorded in the settling ponds. RBCT management is aware of the cause of this problem, which is reportedly a result of staff using the open channels as a toilet. Steps have been taken by management to address this source of contamination.

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4.3.4 Chemical Oxygen Demand The Chemical Oxygen Demand is found to exceed the limit when the wastewater has a high concentration of suspended solids. However this limit is not significant for marine waters. 4.3.5 Colour During periods of uncontrolled discharge (i.e. during storm events) the seawater is discoloured in the vicinity of the stormwater outlets. No turbidity tests are carried out on the seawater.

5.

SPECIALIST STUDIES
Numerous specialist studies have been carried out to determine the impact of surface water runoff from a coal terminal in Richards Bay. These include: Luger, S and Taljaard, S and Connell, AD. 1998. South Dunes Coal Terminal EIA: Impact of stormwater discharge on marine water quality in Richards Bay Harbour. CSIR Report ENV/S-C 98079. Van Ballegooyen, R and Luger, S. 2001. Richards Bay Coal Terminal Expansion EIA: Assessment of the Stormwater Discharge and atmospheric fallout from the Richards Bay Coal Terminal on the distribution of coal particles in the marine environment of Richards Bay. CSIR Report ENV-S-C-2001-023. Peralta, D. 2001. Richards Bay Coal Terminal Phase 5 Expansion EIA: Assessment of the potential environmental impact associated with the surface water runoff from the Richards Bay Coal Terminal. SKP Engineers cc. Connell, AD. 2001. The impact of coal spills and stormwater runoff on the benthic fauna in the vicinity of the coal-loading quays at Richards Bay Coal Terminal. CSIR Report ENV-C-D-2001-011. Ward, CJ. 2002. An investigation into possible effects of RBCT-related activities on surrounding vegetation: an illustrated report on findings and suggestions for remediation, where applicable. Lorenz, SA. 2002. An investigation into possible effects of RBCT-related activities on surrounding vegetation. Naidoo, G. 2002. Impact of coal dust on photosynthesis in mangroves at selected sites adjacent to RBCT. Forbes, AT and Demetriades, NT. 2002. An assessment of the ecological impacts of the Richards Bay Coal Terminal operations. Connell, AD. 2002. A summary of findings from a series of specialist Studies of the impact of Richards Bay Coal Terminal current operations, on the natural environment surrounding the facility in Richards Bay harbour. CSIR Report ENV-D-C-2002-082. Field JG. 2003. Review of Richards Bay Coal Terminal assessment reports. Marine Biology Research Institute University of Cape Town.

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Only the CSIR Report ENV-D-C-2002-082 is provided with this document since it summaries the findings of the other specialist studies commissioned. The other reports are available from RBCT should they be required. 5.1 CONCLUSIONS In earlier work for the South Dune Coal Terminal, Luger, Taljaard and Connell (CSIR Report ENV-S-C-1998-079) concluded that: during storm events the SA Water Quality Guidelines for Coastal Marine Waters are likely to be exceeded for a limited period of time in a localised impact zone. Based on the constituents in the stormwater effluent, the predicted duration of exposure and the size of the impact zone, no significant ecological impact is however envisaged as a result of the stormwater discharge. Van Ballegooyen and Luger (CSIR Report ENV-S-C-2001-023) have determined the extent and thickness of accumulation of fine coal particles in the Richards Bay Harbour for various discharge scenarios. They conclude that the main area of accumulation will be in the deep water adjacent to the quay, which will in any event be dredged on a regular basis. Smaller amounts of coal fines were predicted to accumulate in the shallow waters at the southern end of the terminal. Samples from this area have been analysed by Forbes and Demetriades, and are reported on in their work An Assessment Of The Ecological Impacts Of The Richards Bay Coal Terminal Operations. They concluded that: In all these situations, no evidence was found that the coal-dust caused any adverse impact on marine or estuarine benthic communities, in concentrations similar or greater than those found adjacent to RBCT in Richards Bay harbour. For example, in the Severn estuary, 2% coal in sediments was common while at some sites it was as high as 10%, yet neither showed evidence of impacted fauna. The maximum coal-dust in Richards Bay harbour sediments from the current set of studies was about 2%. It can be inferred from these studies that the wastewater discharge from RBCT is currently not detrimental to the environment and that aesthetics (discoloration of the water) is the major impact. 5.2 RECOMMENDATIONS The studies have all emphasised the importance of improved storm-water control at RBCT to minimise the cumulative impact on the harbour, and support the proposal to collect, treat and recycle water from the site. It is also recommended that the suspended solids in the stormwater runoff be limited to 50mg/l and that the stormwater be discharged below the surface water level to achieve better dilution (pers. comm. Dr A Connell, CSIR).

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6.

PROPOSED WASTEWATER STORAGE & RECYCLE SYSTEM

RBCT propose to collect the surface water runoff from the terminal and to pump it to storage ponds situated on a new lease area to the north east of the Terminal or if space permits on the present lease area. The intention is to recycle the water collected in the storage ponds after the suspended solids have settled out to acceptable concentrations. Design parameters to be used to size the pumping stations and storage ponds are proposed below. This is followed by a description of the proposed scheme and operation philosophy.

6.1

TARGET DILUTIONS Studies carried out by the CSIR (see section 5) have determined that 10 dilutions are achievable for stormwater discharging into the harbour, with localised impact zones. The calculations were based on an ambient concentration of suspended solids in the seawater of 25mg/l. This value is considered conservative and is more likely to be much higher. In order to comply with the Water Quality Guidelines for Coastal Marine Waters (WQG), this would require that the concentration of suspended solids in the wastewater should be less than 50mg/l. In terms of toxicity, it is expected that the Minimum Acceptable Toxicant Dilution (MATD) will be less than 10 if the concentration of suspended solids in the wastewater is less than 50mg/l (pers. Comm., Dr A Connell CSIR). Since the suspended solids in the stormwater runoff generally exceeds 50mg/l, a system that will reduce the frequency of discharge and concentration of suspended solids is required.

6.2

DESIGN DEPTH OF PRECIPITATION In Section 4, it was stated that during a storm event the concentration of suspended solids present in the wastewater generally exceeded 25mg/l and is typically around 200mg/l. If the wastewater is given the opportunity to stand, suspended solids in the water will reduce to below 25mg/l after two days. Thus in order to comply with the WQG, the stormwater runoff from the site should be stored for approximately two days before being released into the harbour. The difficulty lies in selecting a storage volume large enough to ensure that the risk of overtopping is acceptable. Since the current impact on the harbour is minimal, it is not justified in terms of economic or environmental considerations to design for large storm events. Recognising this, the regional office of DWAF agreed in principle to accept 5% non-compliance i.e. not more that 18 discharges a year. An analysis of the daily rainfall was undertaken to determine the rainfall event that would satisfy the design risk of up to a maximum of 18 events in a year. This was done using rainfall records for Richards Bay, which exist from 1923. Although there are some missing and questionable records, this database forms a reliable basis on which to establish the design storm. Taking in consideration cumulative rainfall events, it was determined that 60mm of rainfall would be exceeded at most 15 times per year using the historical record. The result of this analysis is shown in Figure 2.

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Frequency Cumulative Rainfall Events Exceeded 60mm Precipitation

16 Frequency Rainfall Exceeded 60mm 14 12 10 8 6 4 2 0

Figure 2 Frequency of cumulative rainfall events exceeding 60mm of rainfall Using conventional hydrological estimating techniques the return period corresponding to 60mm daily precipitation is slightly greater than 1 year. It is proposed that that the storage ponds and pumping systems be designed for 60mm daily rainfall as this represents a risk of excedence of less than 5% of the time. 6.3 DETERMINATION OF STORAGE VOLUME The SCS-SA method was used to calculate the storm flow depth and hence the required storage volume. Essentially this method assesses the potential water retention properties of the soil and uses this index to calculate the storm flow depth. Hardened areas will have a low retention index while sandy areas will have a high index. The method is applicable to catchment areas less than 30km2 and has been shown to be more reliable than other methods used to determine storm flows. It has been determined that approximately 40Ml of storage will be required to contain the design storm, but that 80Ml will be required to ensure that the ponds are stormwater runoff is not discharged more than 18 times a year. The existing settling ponds have the capacity to contain 12Ml of wastewater. It is proposed that an additional 20Ml of on-site storage capacity be provided to attenuate the flow into the pump sumps and hence reduce the pumping rate to the storage ponds.

19 24 19 30 19 34 19 37 19 41 19 44 19 47 19 51 19 55 19 57 19 60 19 64 19 68 19 71 19 75 19 78 19 82 19 86 19 90 19 93 19 97 20 01
Year
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2 x 40ML STORAGE

Figure 3 Proposed Environmental System Upgrade (ESUP)

6.4

PROPOSED STORAGE AND RECYCLE SYSTEM The proposed scheme is shown on Figure 3. A brief description of each element is described below.

6.4.1 Settling Ponds Surface water runoff will be collected in the settling ponds as before. The main difference between the existing system and proposed system is that the wastewater will be pumped from the terminal settling ponds (see Figure 3) to the storage dams. The existing settling ponds will essentially behave as grit traps and pump sumps. The floating Dolphin strainers will be retained in the existing ponds and also installed in the new ponds. This device is effective in skimming off the clean water and will help in preventing any oil that may have accumulated in the ponds from entering the storage dams. The valve connected to the Dolphin should normally be kept open to allow water to drain to the pump sumps at the terminal settling ponds. The emergency bypass system at SP2, SP4, SP12A and SP9/10/14 will be retained; however the level of the overflow weirs will be raised to ensure that overflow only occurs during exceptional rainfall events. This may result in partial flooding of the site for a short period. 6.4.2 Storage/Retention Ponds The wastewater will be pumped to the storage/retention ponds located on a new lease area to the north east of the Terminal. The Department of Agriculture and Environmental Affairs have approved the construction the storage ponds at this location. However RBCT reserve their right to investigate constructing these ponds within the existing lease area. The purpose of the storage/retention ponds is to contain the wastewater and to allow the suspended solids to settle out before the water is pumped back to the two reservoirs on site, where the water will be recycled. The concentration of suspended solids in the water arriving at the dams is unlikely to exceed 500mg/l. From tests carried out by others, the wastewater will require 48 hours of settling time to reduce the TSS to less than 25mg/l. A monitoring programme will be put in place to sample and test the water against the General Limit Values as is currently the case at the settling ponds. The ponds will be approximately equal in size, each having a capacity of 40Ml. The wastewater will arrive at the inlet works where it will be diverted into the storage pond. During large storm events, the storage pond will fill up and overflow into the storm pond. If the design depth of precipitation is exceeded, the storm dam will overflow into the outfall canal and discharge into the Richards Bay harbour. The quality of the overflow under storm conditions is expected to be approximately 50mg/l. It is proposed that the ponds be lined using an impermeable membrane to prevent contamination of the ground water. The ponds will need to be cleaned once every 2 to 5 years depending on the annual rainfall. This would be done manually, with the coal silt being pumped from the outlet works to a silt drying bed (SDB). After drying the collected coal would be removed to the Terminal stockpiles and blended as is the case with coal removed from the settling ponds. A concrete outlet structure will be provided at the northern end of the ponds. Submersible pumps will be installed on floating platforms (one for each pond), and clear water pumped back to the reservoirs on site where it will be recycled.

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A scour pipe will be installed at the outlet structure with a control valve, to allow a controlled release of water from either pond to the outfall canal. A flow recorder and turbidity meter will be installed to monitor the quality and quantity of the discharge. 6.4.3 Discharge Canal The outlet structure at the storage/retention ponds will be connected to an outfall canal that will discharge on the southern bank of the harbour entrance near the position previously investigated by Luger, Taljaard and Connell (CSIR Report ENV-S-C-1998-079). 6.4.4 Recycle Water RBCT currently uses 1.6Ml of potable water a day to suppress dust and to wash down conveyors and equipment. With the implementation of the proposed scheme RBCT would reduce their potable water consumption by approximately 60%. 6.5 MODIFICATION OF EXISTING STORMWATER OUTLETS Better dilution would be achieved it the stormwater is discharged below the water surface in the harbour (pers. comm. Dr A Connell, CSIR). The existing stormwater outlets from the terminal settling ponds will be maintained as emergency bypasses. However it is proposed that a 16m length of pipe be connected to each of these outlets on the coal quay so that the excess stormwater is discharged below the surface. This will assist in reducing the aesthetic impact of the dirty water plume that would otherwise float on the surface. 6.6 MONITORING PROGRAMME

6.6.1 Monitoring at Settling Ponds Since all inflow into the settling ponds arising from runoff from storm events smaller than the design storm will be pumped to the storage dams, no quantity or quality monitoring equipment will be provided at the settling ponds. For larger storm events, wastewater will overflow into the harbour via the existing outlet pipes through the coal quay. It has been determined that the maximum frequency that the settling ponds will overflow is 10 time a year. 6.6.2 Monitoring at Storage/Retention Pond Outlet Works A flow recorder and turbidity meter will be installed on the scour pipe at the storage/retention pond outlet works. The turbidity meter will monitor concentration of suspended solids present in the discharge, and this information will be automatically recorded and analysed. The control valve will close automatically if the suspended solids is found to exceed 50mg/l. As part of the ongoing water quality testing programme, a private company will be commissioned to test water samples taken from the outlet works to establish other constituents in the water so that appropriate action may be taken. 6.6.3 Monitoring of Marine Water It is further proposed that the quality of the seawater opposite the emergency outlets be monitored on a regular basis

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6.7

RISK ASSESSMENT

6.7.1 Settling Ponds The areas of risk at the settling ponds are twofold: a) Pump failure Should any of the pumps fail during the design storm event, overflow will occur via the emergency bypass system into the harbour. It would be uneconomical to install any standby pumps since the duty pumps are expected to run infrequently. b) Design storm is exceeded When the design storm is exceeded, the installed pumps will have insufficient capacity to pump the inflow into the settling ponds to the storage/retention ponds, and overflow will occur as noted above. 6.7.2 Storage/Retention Ponds If the design storm is exceeded and rain continues to fall on consecutive days it is possible that the storage/retention ponds will overflow. The spillway will be designed to pass the flow into the dam for a 1 in 100 year event.

7.

MITIGATION MEASURES AND ARGUMENTS SUPPORTING PROPOSED SCHEME

It has been establish by various specialists that the stormwater discharge from RBCT has no measurable impact on the marine environment in the Richards Bay Harbour. However they recommend that RBCT reduce the quantity of wastewater discharge and concentrations of waste in the water to minimise the cumulative accumulation of fine coal particles in the harbour. The prime areas of concern are the concentration of suspended solids in the water and the aesthetic impact this has in the harbour. By limiting the concentration of suspended solids to less than 50mg/l it is expected that the toxicity will be within acceptable limits. Occasionally the concentration of oils and soaps exceed the Target Values. The source of this contamination is from the Tippler Yard. A Central Oil Treatment Plant is budgeted for in the Phase 5 Expansion Project. It will be designed to collect contaminated water from all of the Tipplers and to mechanically remove the oil from the water before being discharged into the stormwater system.

The proposed scheme will meet the objectives to reduce the quantity of wastewater and waste in the water since: a) b) Under normal weather conditions no wastewater will be discharged from the site. During extreme wet weather conditions the settling ponds and storage/retention ponds are unlikely to overflow more than 10 times/year and 17 times/year respectively. This is significantly less than the present situation and is less than 5% of the time. Overflow from the storage/retention pond during large storms is likely to have a concentration of suspended solids of less than 50mg/l since the incoming water will be diluted by the clear water in the ponds.

c)

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d) e)

f)

g) h)

The proposal to modify the existing stormwater outlets so that the wastewater is discharged below the water surface will reduce the aesthetic impact of the dirty water plume. Rainfall in excess of the design value will overflow into the harbour via the emergency bypass systems. During these events the concentration of suspended solids will exceed ambient level by more than 10%. However the quality of the water in the harbour will also have much higher background concentrations of waste emanating from industries in the area. Although no specific measurements have been taken to quantity the concentration of suspended solids in the harbour during storm events, it is likely to be significantly higher than the ambient level and probably in the same order of magnitude as found in the wastewater from RBCT. When the system is overloaded, stormwater will be discharged at points approximately 300m apart along the coal quay, at an outlet opposite SP10 at the southern end of the terminal, and at the canal outfall from the storage/retention pond. The effect of this will be to distribute the discharge over a larger area thereby decreasing the concentrations of waste in the seawater and hence reducing the required number of dilutions to meet the WQG. RBCT will reduce its potable water consumption by approximately 350Ml per annum. RBCT will extend the monitoring programme to include testing samples of seawater taken opposite the stormwater outlets.

8.

CONCLUSION
RBCT is committed to achieve and demonstrate sound environmental performance. They have undertaken to implement the proposed scheme at a cost exceeding R30million even if the Phase 5 Expansion does not go ahead. RBCT have been involved in negotiations with the DWAF to licence their stormwater discharge since 1993. Key elements in the imminent Phase 5 Expansion Project are affected by this proposal. It is therefore essential that approval be obtained as a matter of urgency.

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