REVIEW OF HUMAN HEALTH RISKS ASSOCIATED WITH AIR EMISSIONS FROM SONAE NOVOBORD, WHITE RIVER. Review Report Sonae Novobord (Pty) Ltd 2015/03/04

Transcription

1 REVIEW OF HUMAN HEALTH RISKS ASSOCIATED WITH AIR EMISSIONS FROM SONAE NOVOBORD, WHITE RIVER Review Report Sonae Novobord (Pty) Ltd 2015/03/04

2 Quality Management Issue/revision Issue 1 Revision 1 Revision 2 Revision 3 Remarks FINAL Date 4 March 2015 Prepared by S. Doel Signature Checked by Signature K. Collett Authorised by Signature S Doel Project number Report number 1 of 1 File reference 46423_Sonae Novobord Health Risk Review FINAL_ docx Project number: Dated: 2015/03/04 Revised:

3 REVIEW OF HUMAN HEALTH RISKS ASSOCIATED WITH AIR EMISSIONS FROM SONAE NOVOBORD, WHITE RIVER Review Report 2015/03/04 Client Sonae Novobord (Pty) Ltd. Rocky Drift, 1 Heidelberg Road, Nelspruit, 1201 Tel: Fax: Consultant WSP Environmental 199 Bryanston Drive Bryanston Durban 2191 South Africa Tel: Registered Address WSP Environment & Energy South Africa 1995/008790/07 WSP House, Bryanston Place, 199 Bryanston Drive, Bryanston, 2191, South Africa WSP Contacts Sean Doel Tel: Sean.Doel@WSPGroup.co.za

4 Table of Contents 1 Introduction Health Risk Review Scope and Approach Principles of Human Health Risk Assessment Site Information Hazard Assessment Identification of Contaminants of Concern Formaldehyde Wood Dust Exposure Assessment Definition of Key Receptors Exposure Parameters Risk Characterisation Formaldehyde Ambient formaldehyde data Discussion Wood Dust Monitoring results Discussion Summary and Recommendations References Project number: Dated: 2015/03/04 Revised:

5 1 Introduction A detailed assessment of human health risks associated with airborne emissions from the Sonae Novobord Plant in White River was undertaken in 2008 by WSP Environment & Energy as part of the Section 24 Rectification Environmental Impact Assessment (EIA) undertaken for authorisation of a new dryer at the Sonae Novobord Plant. One of the conditions of the rectification authorisation for the dryer was that an annual review of the original health risk assessment be undertaken so as to re-assess and validate the original study findings with due consideration of latest monitoring data and toxicological information for the contaminants of concern. This report presents the findings of the fourth annual such review of potential human health risks associated with airborne emissions from the Sonae Novobord Plant in White River. 1.1 Health Risk Review Scope and Approach The objective of this health risk review is to re-assess the potential risk to local communities, residents or workers in the area surrounding the Sonae Novobord Plant from exposure to airborne contaminants, in particular formaldehyde and wood/particulate dust based on latest monitoring data. It is noted that neither the original health risk assessment, nor this review, are intended to be occupational health risk assessments of workers at the Sonae Novobord Plant, and any reference to occupational health related guidelines or studies is for information purposes only. The scope of this study is defined as follows: Review of international literature to identify any significant changes in regulatory guidance on formaldehyde toxicology since the last review; Recalculation of potential receptor exposure levels and definition of health risk profile using latest monitoring data and following comparable methodology as used in the original health risk study; Provide recommendations for any adjustments to air quality monitoring programs, if warranted, based on the findings of the assessed health risk profile for the site; and Advise on risk management or mitigatory measures based on the assessed site health risk profile. This risk assessment has been prepared in accordance with international best practice for human health and environmental risk assessment of contaminated land. Specific guidance that has been followed in this study includes the Environmental Health Risk Assessment Guidelines for Assessing Human Health Risks from Environmental Hazards issued by the Australian Health Council, and the Risk Assessment Guidance for Superfund (RAGS) issued by the USEPA Office of Emergency and Remedial Response. Whilst international best practice has been applied in the preparation of this risk assessment, it is noted that due consideration has been given to local regulatory guidance and practice where applicable.

6 2 Principles of Human Health Risk Assessment The human health risk assessment principles on which this assessment has been undertaken have been detailed in previous reports, and are included for reference in Appendix A. 3 Site Information The confidence with which potential health risk effects can be assessed is critically dependent on the quality of data and state of knowledge regarding contaminant source release and dispersion pathway which gives rise to a receptor exposure for a specific site. While the original health risk study was based on an initial phase of investigative monitoring along with predictive dispersion modelling, there has been on-going monitoring since 2008 and a detailed database of data is now available for assessment purposes. This current report is based on data collected up until the end of Hazard Assessment 4.1 Identification of Contaminants of Concern There have been no changes to Sonae Novobord operations since 2008 that change the suite of identified contaminants of concern in respect of air emissions, namely; Volatile organic compounds (VOCs) specifically formaldehyde, although other aldehydes such as acetaldehyde may also be present; and Particulate matter (wood dust). 4.2 Formaldehyde The assessment of hazards associated with formaldehyde has not changed since the previous review. It is noted that the US EPA has not revised or finalised the Draft IRIS Assessment of Formaldehyde (released during 2010) that was severely criticised by the National Research Council (NRC) in their official review of Since the 2011 review the US EPA convened a state-of-the-science workshop during 2014 that focused on three themes, namely: Evidence pertaining to the influence of formaldehyde that is produced endogenously (by the body during normal biological processes) on the toxicity of inhaled formaldehyde, and implications for the health assessment; Mechanistic evidence relevant to formaldehyde inhalation exposure and lymphohematopoietic cancers (leukemia and lymphomas); and Epidemiological research examining the potential association between formaldehyde exposure and lymphohematopoietic cancers (leukemia and lymphomas). The US EPA has, however, still not finalised the inhalation portion of the IRIS Assessment of Formaldehyde. The same unit inhalation risk estimate from US EPA as per the original health risk study for Sonae Novobord thus remains applicable for this review. Project number: Dated: 2015/03/04 Revised:

7 4.3 Wood Dust It is recorded that the assessment of hazards and regulatory limits as detailed below has not changed since the last review: The inhalable fraction of wood dust is recognised as a human carcinogen (sino-nasal cancer) as well as respiratory irritant linked to inflammatory reactions and increased asthma incidences (IARC, 2012); The primary evidence for adverse health effects from exposure to wood dust is derived from occupational exposure data. The South African occupational limit for wood dust exposure is 5 mg/m 3. This limit is applicable to hardwoods only. No limit has been set for softwoods; Internationally a range of occupational exposure limits have been adopted from 1 to 5 mg/m 3, depending on whether the limit is defined for hard, soft or mixed wood sources; Non-occupational limits have not been defined specifically for community wood dust exposure in South Africa or elsewhere in the world. Rather, wood dust is recognised as a component of ambient particulate matter, the latter being regulated through standards or guidelines for various size fractions, notably total particulates, PM 10 and more recently PM 2.5 ; and The South African National Ambient Air Quality Standards for ambient PM 10 (up until 31 December 2014) were 120 µg/m 3 (24 hour average) and 50 µg/m 3 (annual average), while the PM 2.5 standards are currently 65 µg/m 3 (24 hour average) and 25 µg/m 3 (annual average). The PM 10 standards were reduced to 75 µg/m 3 (24 hour average) and 40 µg/m 3 (annual average) from 1 January These standards are set specifically for protection of public health from exposure to airborne particulate matter and are based on consideration of a range of mineral and non-mineral (e.g. wood dust) components that may be present in airborne particulate matter.

8 5 Exposure Assessment The purpose of an exposure assessment is to estimate the magnitude of actual and/or potential human exposures to one or more contaminants through definition of receptor activity patterns and source-receptor pathways. In this section the key receptors and applicable exposure parameters are defined, as detailed in reviews. The key receptors remain unchanged, however, the meteorological data in terms of receptor exposure frequency has been updated. 5.1 Definition of Key Receptors The closest receptors to the Sonae Novobord Plant include a residential community located on the north-northeastern boundary of the property, and workers in the light industrial areas located immediately to the southeast (Axis Industrial Park) and west-southwest. The closest residential receptors to the south of the plant are situated at Bundu Lodge. Concern has also been raised by Penryn School located approximately 3.5 km to the south-southwest. For the purposes of this study, six receptor locations have been defined for which exposure levels (dosages) have been calculated and the health risks characterized. Key receptor monitoring points are indicated on Figure 1. A summary of receptor locations utilised in the risk assessment calculations is provided in Table 1. Figure 1: Sonae Novobord Key Receptor Monitoring Points Project number: Dated: 2015/03/04 Revised:

9 Table 1: Receptor Locations Receptor Location Receptor Type Distance / Orientation from Sonae Novobord Comment Bundu Lodge Penryn College Residential Area 1 Residential Area 2 Industrial Area 1 (Axis) Residents - Adult and Children Residents - Adult and Children Residents - Adult and Children Residents - Adult and Children Workers Adult 800 m - S Closest residential receptors south of Sonae Novobord m - SSW Closest school to Sonae Novobord. 500 m ENE m NNE 200 m SE Industrial Area 2 Workers Adult 80 m - WSW Closest residential area to Sonae Novobord. Location of air quality monitoring point within residential area to north-east of Sonae Novobord. Industrial area neighbouring Sonae Novobord. Industrial area neighbouring Sonae Novobord. 5.2 Exposure Parameters Exposure parameters define receptor activity patterns and are required to calculate a contaminant dosage. In terms of inhalation exposures, key considerations include the inhalation rate (amount of air breathed over time which is related to physical activity level); how frequently exposure occurs and how long each exposure event last (exposure time); and the amount of time spent indoors compared to outdoors. For the purposes of this study a series of highly conservative exposure parameters are defined against which a decision on potential health risk may be made as follows: Both adults and children in residential areas are considered with the combined child/adult exposure providing an estimate of worst-case lifetime exposure. Unless otherwise stated below, the parameters listed in Table 2 are considered to represent the reasonable maximum exposures (RMEs) for each of the receptors as defined by the US EPA (1997) and subsequent amendments. The RME exposure scenario is based on selection of the percentile values of the probability distributions for individual exposure parameters and thus represents a very conservative exposure estimate that includes the majority of sensitive individuals within the defined receptor population. The exposure parameters applied in this study are provided in Table 2.

10 Table 2: Receptor Exposure Parameters Exposure Parameters Adult (resident) Child (resident) Adult (worker) Body weight, BW (kg) Exposure time, ET (hours/day) 8 hrs (night time exposure) 8 hrs working day 24 hrs (full day exposure) exposure Exposure frequency, EF (days/year) (based on meteorological data - refer discussion below) Exposure Duration, ED (years) Inhalation Rate, IR (m 3 /hr) Lung retention factor, LRF Inhalation absorption factor, IAF Averaging Time, AT (days) 365 x ED (non-carcinogenic effects) 365 x 70 yrs (carcinogenic effects) Ground level air concentration, C (mg/m 3 ) (based on monitoring refer discussion below) Tolerable Daily Intake, TDI (mg/kg/day) Cancer Slope Factor, CSF (mg/kg/day) x x x 10-5 The exposure frequency (days/year) and maximum ground level formaldehyde concentrations at receptor points of exposure are defined based on the meteorological data and formaldehyde monitoring results, respectively. The exposure frequency based on meteorological station data is provided in Table 3. The number of days per year which the wind blows in the direction of a specific receptor was determined based on conservative inclusion of a 45 arc from the wind direction frequency data. For example, the frequency of winds blowing towards Axis Industrial Park, which is located to the southeast of Sonae Novobord, was determined as the sum of wind frequencies blowing from the west-northwest through north-northwest directions. Comparison of the 2014 data with previous years indicates a relative increase in exposure frequency for receptors located south of Sonae Novobord, notably Bundu Lodge, and a relative decrease in exposure frequency for receptors to the west and east. Table 3: Exposure frequency data Receptor Location Exposure Frequency (2010)* Exposure Frequency (2013)** Exposure Frequency (2014) Days/year Days/year Days/year Penryn School SSW Bundu Lodge S Axis Industrial Park SE Industrial Area 2 WSW Residential Area 1 ENE Residential Area 2 NNE * Meteorological data from onsite station. ** Meteorological data from onsite station (Jan to Sept) and SAWS KNP station (Oct to Dec) Project number: Dated: 2015/03/04 Revised:

11 6 Risk Characterisation 6.1 Formaldehyde In previous reviews a re-analysis of exposure and quantitative risk levels in respect of community exposure to formaldehyde was provided following the same methodology as per the original 2008 risk assessment. In this report, the focus is mainly on review of the latest formaldehyde monitoring data below as this data clearly demonstrates the absence of any significant change in ambient levels over the last year and hence consequent absence of any change in the assessment of community health risk. As a matter of record, an updated quantitative analysis of risk using 2014 data is provided as an appendix to this report (Appendix B) Ambient formaldehyde data The average ground-level concentrations of formaldehyde at each receptor location for 2014 are provided in Table 4, along with historic data for comparison. It is noted that the 2008 data reflected in Table 4 is predictive data based on dispersion modelling as no monitoring had been undertaken at that time. Table 4: Ground level formaldehyde concentrations based on monitoring data for 2010 to 2014 compared with the original (2008) health risk assessment modelled data Receptor Location 2008 (modelled data) 2010 (monitoring results) 2011 (monitoring results) 2012 (monitoring results) 2013 (monitoring results) 2014 (monitoring results) 24hr max. Average* Average* Average* Average* Average* ug/m 3 ug/m 3 ug/m 3 ug/m 3 ug/m 3 ug/m 3 Penryn School SSW Bundu Lodge - S Axis Industrial Park - SE Industrial Area 2 - WSW Residential Area 1 - ENE Residential Area 2 - NNE * Average from four sampling sessions Discussion The primary exposure route of concern associated with formaldehyde emitted from the Sonae Novobord Plant is via inhalation of ground level concentrations in outdoor ambient air. In terms of formaldehyde, it is acknowledged that dermal contact with airborne formaldehyde is a potential secondary route of exposure, however, the exposure levels required to induce skin sensitization (allergic contact dermatitis) from airborne exposure are orders of magnitude higher than what would be safe for associated inhalation exposure. Hence, the evaluation of acceptable inhalation exposures necessarily defines acceptable levels of airborne dermal exposures. Comparison of the 2014 formaldehyde monitoring data with historic results indicates that results are comparable to the levels detected during 2012 and 2013, while the results for 2012 through to 2014 are all lower than The quantitative calculations of risk provided in Appendix B confirm the above as would be expected with hazard quotients being well below 1 and cancer risk levels being well below the most conservative

12 internationally accepted risk level of 1 in 1 million (calculated risk levels were all below 1 in 10 million, which is below the incremental lifetime cancer risk levels that the average person will experience from exposure to a range of naturally occurring and anthropogenic sources of chemicals in typical urban and suburban environments). 6.2 Wood Dust In the previous health risk review it was concluded that the ambient particulate levels associated with Sonae Novobord were well below the level at which adverse health effects would be observed based on consideration of potential wood dust health risks. The monitoring data for 2014 in the context of this previous assessment is reviewed below Monitoring results The particulate (PM 10 ) results from the Osiris monitoring station on the western fenceline (Sonae 1, downwind ) of the Sonae Novobord site are shown in Figure 2. Significant peaks in PM 10 were observed during 2009 and up until May 2010, which were considered to be associated with the commissioning of the new (Recalor) dryer. Thereafter, PM 10 was significantly lower, with data during 2011 to 2013 being below the NEM:AQA annual ambient standard of 50 µg/m 3. This trend has continued during 2014, with PM 10 levels being below 50 µg/m 3 throughout This data is summarised in Table 5. Table 5: Sonae 1 Results for 2011 to 2014 Sonae 1 Results: Annual % Data Recovery Annual Average (PM 10) % µg/m % µg/m % µg/m % µg/m 3 The 2014 particulate (PM 10 ) results from the Osiris monitoring station that was relocated to Bundu in 2013 are provided in Figure 3. Project number: Dated: 2015/03/04 Revised:

13 600 Sonae Concentration (ug/m 3 ) Sonae 1 Daily NEM:AQA Standard Figure 2: PM 10 results from the Sonae 1 monitoring station (2008 to 2013) Concentration (ug/m 3 ) Hour PM10 Concentration 24 Hour PM10 NAAQS PM10 Annual Running Average Annual PM10 NAAQS Figure 3: PM 10 results from the Bundu monitoring station (2014)

14 6.2.2 Discussion In the original health risk assessment it was noted that the modelled and monitored data indicated that levels of inhalable particulates at receptor locations would not pose a health risk. However, the available monitoring data at the time demonstrated elevated levels of particulates that significantly exceeded the 24 hour standard of 120 µg/m 3 associated with upset plant conditions. These particulate releases, although apparently of short duration, resulted in a variable period of time ranging from hours to days following the release, when airborne particulate levels posed a significant nuisance impact as well as potential health concern if not rectified. With the implementation of various corrective measures and improvements in operating practices by Sonae Novobord, the short term high level exceedences were rectified, as demonstrated in subsequent monitoring data for 2011 to The data for 2014 demonstrates continued compliance in terms of NEM:AQA ambient particulates standards, and the absence of any significant short term elevated spikes or exceedences in the data. The annual average PM 10 level at Sonae 1 for 2014 remains well below the NEM:AQA standard - a standard which it is noted is specifically intended for protection of public health from particulate exposure. Compliance with this standard, by definition, implies the absence of any potential health concerns. Previous discussions and concerns raised by I&APs as to whether the NEM:AQA ambient standard is protective of dust exposure where the dust is in part or total comprised of wood dust, is noted again here for the record. The standard is considered protective of human health from dust exposures (considering both respiratory irritant and carcinogenic effects), and including where that dust is wood dust. More detailed discussions are provided on this matter from previous reporting in Appendix C for reference purposes. Dust Impacts at Bundu The results of the monitoring data collected at Bundu during 2014 and as reflected in Figure 3, demonstrate PM 10 levels that are compliant with the NEM:AQA standards. The PM 2.5 data recorded for this same station also confirmed levels that were well below the NEM:AQA standard. This data confirms the absence of any health related concerns associated with particulate levels at this location. Project number: Dated: 2015/03/04 Revised:

15 7 Summary and Recommendations On the basis of the monitoring results reported for 2014, which show comparable (PM 10 ) or improved (formaldehyde) ambient levels in the environment, we consider the findings of previous health risk reviews to remain valid and applicable, namely, that: Potential formaldehyde exposure at receptor locations are well below (by at least two orders of magnitude) the level at which concern in respect of adverse health effects would be registered. The assessment is based on consideration of both threshold (cytotoxic effects) and non-threshold (carcinogenic) effects with due consideration of the latest toxicological information and dose-response models for formaldehyde; In terms of potential irritant effects such as nose, throat and eye irritation from exposure to formaldehyde, the levels of formaldehyde beyond the Sonae Novobord fenceline are all below the threshold levels for these responses; and The results for particulates monitoring were compliant with the NEM:AQA daily and annual average standards. These standards are specifically intended for protection of public health from particulate exposure, and compliance therewith implies the absence of any potential health concerns. Further to the above, results of real time particulates monitoring at Bundu confirm that PM 10 and PM 2.5 levels are compliant with NEM:AQA standards and confirms the absence of any health related concerns associated with particulate levels at this location. It is noted that this is a statement in respect of health risk, and in no way infers acceptability or otherwise of nuisance impacts associated with dust. While an annual health risk review was included in the conditions of authorisation for the dryer, we advise that further health risk reviews are unnecessary unless there is a significant (negative) trend in the monitoring data observed.

16 8 References Air Quality Monitoring Reports of Sonae Novobord, White River. WSP Environment & Energy, Benchmarking exposures to wood dust and formaldehyde in selected industries in Australia. Australian Safety and Compensation Council, Community Human Health Risk Assessment, Air emissions associated with Sonae Novobord, White River, Mpumalanga, WSP Environment & Energy, May Draft Toxicological Review of Formaldehyde Inhalation Assessment, Integrated Risk Information System, United States Environmental Protection Agency, June Final Report on Carcinogens: Background document for wood dust, National Toxicology Program, December Health Risk Assessment of Air Emissions from Sonae Novobord, White River, Mpumalanga, WSP Environment & Energy, February IARC Monographs on the evaluation of carcinogenic risks to humans, Vol100C, Wood Dusts, Occupational Exposure to Inhalable Wood Dust in the Member States of the European Union. Kauppinen T, Vincent R, Liukkonen T, Grzebyk M, Kauppinen A, Welling I et al., Ann Occup. Hyg. 2006, 50: Review of the Environmental Protection Agency s Draft IRIS Assessment of Formaldehyde, National Research Council of the National Academies, April Project number: Dated: 2015/03/04 Revised:

17 Appendix A Principles of Human Health Risk Assessment The following section provides a summary of health risk assessment principles for background information purposes. Risk assessment refers to evaluation of the probability, or frequency, of occurrence of a defined risk (for example, exposure to a property of a substance with the potential to cause harm) and the magnitude of the consequences. In terms of risk assessment associated with hazardous substances released into the environment, risk can only exist if a source-pathway-receptor linkage exists as follows: A source of contamination which has the potential to cause harm and to cause pollution of soil, air or water. A pathway is one or more routes or means by, or through which, a receptor may be exposed to, or affected by a contaminant or, could be so exposed or affected by a contaminant. A receptor may be an individual, group of individuals, community or entire population that may be exposed to a specific contaminant via one/or more exposure pathways. Risk assessment involves the definition and evaluation of existing and/or potential future source-pathwayreceptor linkages and typically consists of the steps outlined below. Identification of Chemicals of Concern (COC) This involves the identification of chemicals (contaminants) that are present on the site or emitted by the operations on site at concentrations that may pose a potential health risk and hence require detailed evaluation in the risk assessment. Identification of COCs is typically achieved by comparison of site data with regulatory standards or guidelines. Exposure Assessment The objective of an exposure assessment is to estimate the magnitude of actual and/or potential human exposures, the frequency and duration of these exposures, and the pathways by which humans are potentially exposed. An exposure pathway is defined as the course a chemical or physical agent takes from source to an exposed receptor. An exposure pathway includes a source or release from a source, an exposure point (a location of potential contact between the agent and the organism), and an exposure route, which would normally be a transport medium. A receptor may be an individual, group of individuals, community or entire population that may be exposed to a specific contaminant via one/or more exposure pathways. In terms of airborne exposures, a series of potential receptor groups or populations would typically be defined and evaluated based on spatial location from the source release point and activity patterns e.g. residents, workers etc. A range of exposure scenarios would also be considered with particular emphasis being given to cumulative lifetime exposures as these would represent the greatest potential health risk. Toxicity Assessment The purpose of toxicity assessment is to define the necessary toxicological parameters for the COCs being considered in the risk assessment. This includes (i) the types of adverse health effects associated with chemical exposures, (ii) the relationships between magnitude of exposure and adverse effects, and (iii) related uncertainties such as weight of evidence of a particular chemical s carcinogenicity in humans. Information for toxicity assessment is sourced from international peer-reviewed databases. Risk Characterisation Characterisation of risk is undertaken in terms of cancer and non-cancer health effects. Cancer health effects are calculated and expressed in terms of the incremental probability of an individual developing cancer over a lifetime as a result of exposure to a potential carcinogen. The most stringent risk level applied to environmental exposures would be 1x10-6 (i.e. a risk of 1 out of 1 million exposed individuals being affected). Internationally risk levels in the range of 1x10-6 to 1x10-4 are generally considered acceptable but vary depending on country specific policy decisions, regulatory framework and a number of other political and social considerations. In South Arica there currently is no formal legislated acceptable risk level or other policy guidance. We note,

18 however, that our Water Quality Guidelines are based on risk levels of around 1x10-5, whilst the waste disposal guidance (DWAF Minimum Requirements documentation) is based on 3 x Non-cancer effects are typically evaluated by means of Hazard Quotients. A Hazard Quotient (HQ) is the ratio of exposure to toxicity for an individual pathway and contaminant. HQ values are used to assess risk of noncarcinogenic health effects associated with specific exposure scenarios and receptors. HQ values <1 indicate the absence of adverse health effects and hence acceptable risk. HQ values >1 indicate the potential for health effects and unacceptable risk, and thus indicate the need for further investigation and/or mitigatory action to reduce exposure. Project number: Dated: 2015/03/04 Revised:

19 Appendix B Quantitative analysis of risk associated with airborne formaldehyde exposure Calculation of Exposure Levels (Dosages) Exposure levels (dosages) have been calculated for each receptor scenario using the maximum ground level concentrations of formaldehyde as detailed in this report (refer Sections 5 and 6). The dosages have been calculated using the following equation: Where C = ground level contaminant concentration in ug/m 3 INR = inhalation rate in m 3 /hr CF = conversion from ug/m 3 to mg/m 3 (1 x 10-3 ) IAF = inhalation absorption factor LRF = lung retention factor ET = exposure time in hours/day EF = exposure frequency in days/year ED = exposure duration in years BW = body weight in kg AT = averaging time in days Intake mg/kg C INR CF IAF LRF ET EF ED = day BW AT The calculated dosages are summarized in the table below. Table B.1: Calculated dosages (in mg/kg/day) for inhalation of airborne formaldehyde (threshold approach) Receptor Location Night-time exposure (8hr) Resident Adult Resident - Child Worker - Adult Worst-case (24hr exposure) Night-time exposure (8hr) Worst-case (24hr exposure) Worst-case 8hr exposure Penryn School - SSW 3.23E E E E E-05 Bundu Lodge - S 7.05E E E E E-04 Axis Industrial Park - SE 3.60E E E E E-04 Industrial Area 2 - WSW 4.61E E E E E-04 Residential Area 1 - ENE 8.32E E E E E-05 Residential Area 2 - NNE 2.30E E E E E-05

20 Table B.2: Calculated dosages (in mg/kg/day) for inhalation of airborne formaldehyde (non-threshold response approach) Receptor Location Night-time exposure (8hr) Resident - Adult Resident - Child Worker - Adult Worst-case (24hr exposure) Night-time exposure (8hr) Worst-case (24hr exposure) Worst-case 8hr exposure Penryn School - SSW 3.23E E E E E-05 Bundu Lodge - S 7.05E E E E E-05 Axis Industrial Park - SE 3.60E E E E E-05 Industrial Area 2 - WSW 4.61E E E E E-05 Residential Area 1 - ENE 8.32E E E E E-05 Residential Area 2 - NNE 2.30E E E E E-05 Calculation of Risk Levels Non-cancer risk characterization Hazard quotients (HQ) have been calculated for each of the receptor types at each location using the annual average ground level concentrations of formaldehyde as determined from the 2014 monitoring results. The HQ s have been calculated as follows: Hazard Quotient= Intake Acceptable Daily Intake The HQ s are summarised in the table below. HQ values that are <1 indicate the absence of any potential adverse health effects and hence an acceptable exposure level from a risk perspective. HQ values > 1 indicate the potential for health effects and a potentially unacceptable exposure in terms of risk, and therefore the need for further investigation and/or mitigatory action to reduce exposure. Table B.3: Hazard quotients for residential and worker receptor exposures Resident - Adult Resident - Child Worker - Adult Receptor Location Night-time exposure (8hr) Worst-case (24hr exposure) Night-time exposure (8hr) Worst-case (24hr exposure) Worst-case 8hr exposure Penryn School - SSW 1.62E E E E E-04 Bundu Lodge - S 3.52E E E E E-03 Axis Industrial Park - SE 1.80E E E E E-04 Industrial Area 2 - WSW 2.31E E E E E-04 Residential Area 1 - ENE 4.16E E E E E-04 Residential Area 2 - NNE 1.15E E E E E-04 All HQ s were well below 1. These calculated levels indicate the absence of any concern with respect to potential adverse health effects from airborne formaldehyde exposures to residents or workers in the areas surrounding the Sonae Novobord Plant. Project number: Dated: 2015/03/04 Revised:

21 Cancer risk characterization Cancer risks have been calculated for each of the receptor types at each location using the annual average ground level concentrations of formaldehyde as determined from the 2014 monitoring results. The cancer risks have been calculated as follows: Cancer risk = Intake Slope Factor The cancer risk characterisation is assessed based on an acceptable risk level of 1 in 1 million (1 x 10-6 ). This is the most conservative risk level typically adopted for human health risk evaluation related to environmental exposures and is considered appropriate for this risk assessment study where the primary focus is to identify whether potential worst case exposure scenarios pose a health risk concern or not and hence whether more detailed human health investigations are required. Table B.4: Cancer risk levels for residential and worker receptor exposures Receptor Location Night-time exposure (8hr) Resident - Adult Resident - Child Worker - Adult Worst-case (24hr exposure) Night-time exposure (8hr) Worst-case (24hr exposure) Worst-case 8hr exposure Penryn School - SSW 6.24E E E E E-10 Bundu Lodge - S 1.36E E E E E-09 Axis Industrial Park - SE 6.94E E E E E-10 Industrial Area 2 - WSW 8.90E E E E E-09 Residential Area 1 - ENE 1.61E E E E E-10 Residential Area 2 - NNE 4.43E E E E E-10 Cancer risk levels for residential and worker receptors for all locations considered were found to be well below the most conservative internationally accepted risk level of 1 in 1 million. Calculated risk levels were all below 1 in 10 million. These risk levels are below the incremental lifetime cancer risk levels that the average person will experience from exposure to a range of naturally occurring and anthropogenic sources of chemicals in typical urban and suburban environments.

22 Appendix C Evaluation of Wood Dust Exposure Levels The absence of ambient standards specific to wood dust only has been raised as a concern by I&APs in terms of assessment of health risks. The discussion below is provided by way of context for assessment of dust exposures and potential health risks. The NEM:AQA ambient standards are based on total airborne particulates of varying size fractions, and are protective of human health from all types of community particulate matter exposure, including components such as wood dust. Sonae and ECF members have nevertheless requested guidance as to what levels of community wood dust exposure would trigger a health concern. It is noted that no international regulatory authority has specifically defined such a standard or level that can be presented here. However, the following information can be provided by way of guidance and for context when considering particulate monitoring data. The observational data for statistically proven adverse health effects from wood dust exposure is derived from occupational exposures of workers in manufacturing environments where elevated wood dust levels are routinely experienced as part of the work environment. Examples include forestry, sawmills and wood product manufacturing. A range of comprehensive and complex studies have been undertaken to understand the levels of wood dust exposure of these workers and to quantify the risk levels in terms of adverse health effects (both respiratory irritant and carcinogenic effects) (NTP, 2000; Kauppinen et al, 2006; ASCC, 2008; IARC, 2012). The following key points can be summarised from these studies; A wide range of occupational exposures have been recorded, as would be expected, from <0.5 mg/m 3 to significantly greater than 5 mg/m 3. Severe exposures in excess of 100 mg/m 3 were observed historically but due to improved working conditions have largely been eliminated. Exposure statistics from the European Union indicated that 2% (3.6 million) of the entire EU labour force is exposed to wood dust of which 21% is exposed between 1 2 mg/m 3, 25% between 2 5 mg/m 3, and 16% to > 5 mg/m 3. In terms of adverse health effects, statistical analysis shows greatest confidence and incidences of health impacts at the higher end of the recorded exposure levels, as would be expected. Statistically significant adverse effects on lung function were not observed below 1 mg/m 3. It is on the basis of consideration of the above studies and data that regulatory agencies have defined safe occupational exposure limits for wood dust to be in the range 1 to 5 mg/m 3 depending specifically on how the limit is defined (i.e. hard, soft or a mixed wood source). While it is not possible to directly translate occupational exposure limits to safe community health exposure limits, it is useful to contextualize the levels of exposure at which adverse health effects have been recorded in comparison to the ambient data from Sonae as detailed below. A typical occupational exposure would be defined on the basis of 40 hours/week of exposure (8 hours per day for 5 days per week), whereas residential community type exposure is often continuous i.e. 24 hours a day all days of week (168 hours per week). Other key differences include the inhalation rate of workers which is usually assumed to be higher than for a residential receptor and the period of exposure (which would be up to 30 years for workers compared to 70 years for an adult community receptor). On this basis, the dose of a worker inhaling wood dust at 5 mg/m 3 would be comparable to an adult community receptor exposed at a level of 1.5 mg/m 3 (1500 µg/m 3 ). Similarly, the dose of a worker exposed at 1 mg/m3 would be comparable to an adult community receptor exposed at a level of 0.3 mg/m 3 (300 µg/m 3 ). To put this in context with the data reported by Sonae Novobord, the 2012 annual average for Sonae 1 was µg/m 3. This is an order of magnitude below the 300 µg/m 3 (which is an equivalent dose to the current OHS Act hard wood standard of 1 mg/m 3 ) and two orders of magnitude below 1500 µg/m 3 (which is comparable to an occupational dose of 5 mg/m 3 the level of exposure at which there would concern of adverse health impacts). The levels of particulates recorded at Sonae 1 are thus deemed to be well below the level at which adverse health effects would be observed based on consideration of wood dust health risks. Project number: Dated: 2015/03/04 Revised:

23 WSP Environment & Energy South Africa Block A, 1 on Langford Langford Road, Westville Durban 3629 South Africa Tel: Fax: