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Volumes Consultants Fields

One Archaeology Services Cooperative Cultural Heritage (Terrestrial)

Axiak, Victor Marine Water Bodies

Two Borg, John J Vertebrate Fauna

Borg, Joseph A & Evans, Julian Marine Ecology

Three Calleja, Christian (2 reports) Noise

Cassar, Louis F Land Use and Land Cover

Conrad, Elisabeth Landscape and Visual Assessment

Four Fedra, Kurt (3 reports) Air Dispersion

Formosa, Marvin Social Impact Assessment

Five Gambin, Timothy Marine Archaeology

Lanfranco, Sandro & Cassar, Louis F Terrestrial Ecology

Mamo, Julian & Cauchi, John P Health Impact Assessment

Six Meli, Anthony Agricultural Land

Scerri, Saviour Geology – Geomorphology – Hydrogeology – Hydrology – Soils

Seven Vaccari, Roberto (2 reports) Quantitative Risk Assessment

Report on Marine Archaeology

for the proposed power station at Marsaxlokk Bay, Malta, August 2013

Prepared by:

Dr Timothy Gambin BA MA PhD (Bristol)

Logistic Support:

12, Sir Arthur Borton Street Mosta, MST14

Malta

Telephone: (+356) 2143 1900 Fax: (+356) 21424 137

e-mail: [email protected]

ECOSERV REPORT REFERENCE : 115-13_R

Revised version (16-10-13) of report dated August 2013

mailto:[email protected]

Ecoserv Ltd. Report on Marine Archaeology Marsaxlokk Bay, Malta

Contents 1.0 Introduction .................................................................................................. 3

2.0 Review of the Terms of Reference for the preparation of the Marine Archaeology/Cultural Heritage Assessment ............................................................ 4

3.0 Legislation and Statutory Protection ............................................................... 6

4.0 The Site ......................................................................................................... 7

5.0 Desk-Based Study ........................................................................................ 10

6.0 Diver Survey ................................................................................................ 20

7.0 Analysis of Remote Sensing Data .................................................................. 24

8.0 Summary of Impacts .................................................................................... 27

9.0 Recommendations ....................................................................................... 32

9.1 Monitoring ................................................................................................... 33

10. Bibliography ................................................................................................. 35

Appendix A Strata Box Sub Bottom Profiler Specifications .................................... 39

Appendix B Field report for the Remote Sensing Survey ...................................... 41

Appendix C Sub Bottom Profiler lines .................................................................. 13

Appendix D Sub Bottom Profiler Contacts ........................................................... 14

Appendix E Contents of CD-ROM accompanying this report ................................. 18

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1.0 Introduction

Ecoserv Ltd was commissioned to carry out this study by ERSLI Consultants

in July 2013 and it forms part of a broader Environmental Impact As-

sessment (EIA) being coordinated by ERSLI on behalf of Enemalta. The EIA

will form part of an application aimed at obtaining the necessary permission

for the construction of a new power station in Marsaxlokk together with mooring

facilities for ships that transport and process gas. In order to achieve the objec-

tives listed below, ERSLI contracted the undersigned to undertake a desk-

based study, carry out a remote sensing survey and review the resultant

remote sensing data from Marsxalokk Bay.

The findings contained in this study may be used to guide planning processes

for the proposed project and may also inform any eventual monitoring pro-

gramme.

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2.0 Review of the Terms of Reference for the preparation of the Marine Archaeology/Cultural Heritage Assessment

2.1 Objectives

The Terms of Reference prepared by MEPA and supplied by ERSLI for the Marine Archaeology Study consisted of the following (authors review in italics):

2.2 Area of Study

The area of study for the purpose of this report as indicated by the consultants:

Figure 1. Map showing area of study

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2.3 Statutory Protection

Reference shall be made to local heritage conservation legislation, international

conventions and charters, Structure Plan policies, Local Plans, Scheduling

and other relevant documents related to the protection of cultural heritage.

2.3.1 Description and Assessment of Impacts

All significant impacts and risks posed by the proposed project, both

during construction and during operation, shall be assessed. The impacts may

include:

a) Visual impact on the cultural landscape; and

b) Impact on the heritage assets and archaeological remains (whether

on the surface or buried).

2.3.2 Mitigation Measures

This should include a description of the measures envisaged to prevent,

minimise and where possible offset any significant adverse effects on the

cultural heritage assets and their setting by the project, (including reference

to consideration of alternatives). Such measures could include technological

features; operational management techniques; enhanced site planning and

management; aesthetic measures; conservation measures; reduction of mag-

nitude of project; and health and safety measures.

2.3.3 Monitoring Framework

A long-term monitoring programme of the impacts of the development

on the cultural heritage assets and their setting shall be proposed. This

shall include data gathering on the quality and progress of critical heritage

features identified in the previous section, and spot checks. Therefore the fol-

lowing are required:

a) A monitoring programme during any necessary scientific archaeologi-

cal investigations, provided official written consent is obtained from the Superintendence of Cultural Heritage;

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b) A monitoring programme during construction; and

c) A monitoring programme during operation.

2.3.4 Academic Competence

The survey and report will be undertaken by suitably qualified person/s

holding a degree in Archaeology.

3.0 Legislation and Statutory Protection

Cultural heritage, its management and protection is legally covered by the

Cultural Heritage Act 2002. This act defines any object that is over 50

years old (be it on land and underwater) as cultural heritage (Part 1.3).

Thus any sections of the act referring to the protection and management of

cultural heritage must be taken to also cover underwater cultural heritage.

From an international perspective there are two main conventions that are

relevant to this study:

1) Convention on the Protection of the Underwater Cultural Heritage – 2001.

Although this convention has been ratified by UNESCO, Malta is not yet a

signatory. Despite this, the elements contained within this convention

are to be taken as guidelines for the management and protection of un-

derwater cultural heritage. This is done in numerous European states.

Article 2.5 of this convention states: “The preservation in situ of underwater

cultural heritage shall be considered as the first option before allowing or

engaging in any activities directed at this heritage”.

Also relevant is Article 2.6 that states: 6. Recovered underwater cultural

heritage shall be deposited, conserved and managed in a manner that en-

sures its long-term preservation.

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2) European Convention on the Protection of the Archaeological Heritage (Revised) Valetta, 16.I.1992.

Despite this convention being signed in Valletta, Malta is yet to be in-

cluded as a signatory. Most of this convention is relative in the context

of this study and would prove too lengthy to reproduce here. It can be

downloaded using this link:

http://conventions.coe.int/treaty/en/treaties/html/143.htm

4.0 The Site Marsaxlokk Bay

Situated at the south east of the island this bay is fed by a valley that drains the Marnisi and Ginwi areas. The floodplain is one of the smaller ones on Malta. Today, a small marsh is located at the head of the bay, indicating that the bay may have been larger in the past and gradually silted up since antiquity. The temple at Tas-Silġ that overlooks the harbour of Marsaxlokk attests the importance of this site in antiquity. Although there are no documentary references from the medieval and early modern period to marshes in the area, today a marshy environment survives at the head of the fishing harbour. It is a large natural embayment forming the north-eastern part of the larger harbour complex. Its entrance is oriented to the south, exposing the bay to winds from the south-east to the south-west. Recent sediment deposition has made the bay much shal-lower than it was in ancient times. Vessels of all sizes could have sought shelter here. A sandy beach would have provided a landing place for small boats. A freshwater supply is available from the valley that exists between two of the three hills that dominate this bay to the north-east, north and north-west. Access to the hinterland would have been via this same valley. In its natural state this bay could only have been used as a temporary anchorage but a sea wall would have enabled the area to be used as an all-weather har-bour. In antiquity, its main function would have been to serve agricultural sites in the surrounding area. It may also have enjoyed links with the sanctuary overlooking the bay.

Wied Dalam

At Birżebbuga, two smaller silted bays are situated on either side of a rocky promontory. The Dalam valley feeds one of these whereas both the Qoton and Has-Saptan valleys

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http://conventions.coe.int/treaty/en/treaties/html/143.htm


feed the other (San Ġorġ south). The two small floodplains are clearly visible in the aeri-al photograph. The rocky promontory separating the two was an important location that attracted humans to settle it. Numerous archaeological remains confirm the importance of this site: a Neolithic temple datable to 2500 BC, a Bronze Age fortified village (Trump 2002: 288) and a farm datable to the Punic and Roman periods. In antiquity the bay would have been larger than it is today but sediment deposition has contributed to the gradual silting up of its inner-reaches. Throughout the Middle Ages, stagnant pools in the area were used for the retting of flax, an indication that the siltation process was under-way (Wettinger 2000: 373). By the seventeenth century the bays had become marshy and despite being associated with malaria, retting was still practised (Blouet 1964: 200). Wied Dalam is a small sheltered valley with its entrance oriented to the south-east (Fig. 2). It is sheltered from the prevailing northerly winds but exposed to winds from the south-east to the south-west, although severe gales from the north-east have been known to affect the area. Bordering this bay are a hill to the north and a promontory to the south. Only small- and perhaps medium-sized vessels would have been able to seek shelter here. A beach would have provided a landing place for small boats. Freshwater would have been available for visiting ships from the valley that flows into this bay. Ac-cess to the hinterland would have been via this same valley. Its main functions would have been: as a temporary anchorage; and as an access point for various maritime activ-ities conducted by the inhabitants in the surrounding areas. San Ġorġ (south)

A natural embayment and sheltered valley with its entrance oriented to the south-east and situated to the south of the Kaċċa promontory. In antiquity it would have been larg-er than it is today but sediment deposition has contributed to the gradual silting up of its inner-reaches. It is sheltered from the prevailing northerly winds but exposed to winds from the south-east to the south-west although severe gales from the north-east also affect the area. Only small- and medium-sized vessels would have been able to seek shelter here. A beach and/or marsh would have provided a landing place for small boats. Freshwater would have been available for visiting ships from the valley that flows into this bay. Access to the hinterland would have been via this same valley. Its main func-tion would have been Its main functions would have been: as a temporary anchorage;

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and as an access point for various maritime activities conducted by the inhabitants in the surrounding areas.

Pretty Bay

A natural embayment situated at the south-west part of the Marsaxlokk harbour complex with its entrance oriented to the north-east. It is protected from the prevailing northerly winds but is exposed to winds from the south-east to the south-west, although severe gales from the north-east also affect the area. The bottom is sandy and both small- and medium-sized vessels could have sought shelter here. A beach at the head of the bay would have facilitated landing by small boats and freshwater for visiting ships would have been available from the valley that flows into the bay. This same valley would have provided access to the hinterland. Its main function would have been: as a temporary anchorage; and as an access point for various maritime activities conducted by the in-habitants in the surrounding areas.

Inner Marsaxlokk

A natural embayment at the northwest psrt of Marsaxlokk harbour complex with its en-trance oriented to the south east. It is protected from the prevailing northerly winds but is exposed to winds from the south-east to the south-west, although severe gales from the north-east also affect the area. The bottom is made up of sandy mud and both small- and medium-sized vessels could have sought shelter here. A beach at the head of the bay would have facilitated landing by small boats and freshwater for visiting ships would have been available from the valley that flows into the bay. This same valley would have provided access to the hinterland. Its main function would have been as a harbour serving the temple of Tas-Silg situated at the top of the hill to the north of this site.

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5.0 Desk-Based Study

Given that the development of research in underwater archaeology in Malta has only been a recent and somewhat sporadic event, the current knowledge of submerged archaeological remains is deemed to be quite limited. In the main, the archaeological finds from an underwater context were brought to the surface by amateur sports divers, fishermen and other individuals who were not from the archaeologi-cal/scientific society (Azzopardi and Gambin 2012). Over the past decade, the introduction and enforcement of legislation relating to archaeological impact assessments for marine projects has lead to an increase in surveys, excavations and desk-based stud-ies. This section of the report summarizes the history of the site as well as the main ar-chaeological finds that have been reported within the area of Mellieha Bay. Several sources were consulted in preparation of this report. These were mainly:

1) Documentary 2) Various Archives 3) Cartographic 4) Existing literature referring to the cultural heritage and history of the area 5) Reports of earlier registered discoveries

Amongst the various archives consulted were the:

1) List of scheduled sites and monuments

2) The Superintendence of Cultural Heritage archives

3) The National Archives (Rabat-Malta)

4) The archives of the National Museum of Archaeology, Valletta

5) Various other sources were consulted for any relevant historical infor-mation

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5.1 Desk-based study

Figure 2: Some sites mentioned in the text below: 1) Xrobb L-Ghagin; 2) Tas-Silg; 3) Kavallarizza; 4) Roman Villa; 5) Ta’ Kaccatura; 6) Borg in-Nadur; 7) San Lucian and 8) Fort Delimara

5.1.1 Prehistory

Due to intensive anthropogenic intervention in the immediate area of study it is difficult to establish the exact nature of the original coastal landscape in the ar-ea. Early modern maps show the area around present-day Marsaxlokk Bay as being bereft of any noticeable features such as trees and buildings. However, this is not indicative of the exact nature of the landscape in previous centuries. Recent studies (Mariner et al 2012) show that the environment has gone through numerous and substantial changes over the millennia. It is beyond the scope of this study to go in-to the detail of such changes but one salient feature must be noted. In all probability, the coastline in the inner-reaches of Marsaxlokk Bay stretched further inland than it does in the present day. The Marsaxlokk area is relatively rich in prehistoric remains. On the hill overlooking the area of study one finds the remains of the archaeological site today referred to as Tas-Silg. Although better known for its Phoenician, Punic and Roman remains, the latter

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were actually built over the remains and foundations of a late neolithic temple. This site forms part of a larger cluster of late neolithic sites that are located within the generic ar-ea. Other temples from this cluster are situated at Borg in-Nadur, Hal-Ginwi and Xrobb L-Ghagin (Pace 2004: 98-107).

Recent excavations at Tas-Silg are bringing to light significant parts of the lower levels of the neolithic structure. These discoveries dispel previous theories that the prehistoric levels at Tas-Silg had been seriously comprised.

The presence of numerous late neolithic temples around Marsaxlokk Bay clearly points to intensive use of the area by the prehistoric inhabitants of Malta.

5.1.2 Antiquity

A number important sites from antiquity have been discovered and studied in the Mar-saxlokk area. The remains of a superior Roman edifice, complete with bath complex, were discovered (MAR 1931-32). It was deplete of any industrial remains and its situa-tion in a prominent position overlooking the entrance to Marsaxlokk Bay suggests that it may have been a ‘villa marittima’. Just behind Birzebbuga one finds the remains of a Roman oil producing rural site that was built over earlier remains that date back to Mal-ta’s Carthaginian period (Bonanno 2005). A similar, albeit larger complex was discovered in the 1960s in Zejtun - a discovery that confirms the importance of this area for the production of olive oil on ancient Malta.

However, the most significant site in the Marsaxlokk area is undoubtedly the temple complex at Tas-Silg. Writing in the 1st century AD Cicero describes the famous temple of Juno as containing “a large number of ornaments amongst which was a carefully and supremely crafted ancient ivory statue of Victory”. The presence of such ornaments are a clear indication of the importance of this temple not just locally but also on a pan-Mediterranean scale. Recent studies of the ceramics from Tas-Silg led the researcher to conclude that the sanctuary was used as a centre of exchange for both local and import-ed goods (Bruno 2009: 135). To understand such synergy the sanctuary must always be studied in the context of its position that dominates the harbour of Marsaxlokk. There-fore, the intensive use of the sanctuary by the ancients must also have been mirrored by intensive maritime traffic of the harbour below.

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5.1.3 Middle Ages

Once again, our main body of evidence for terrestrial activity (during the Middle Ages) stems from Tas-Silg. I would seem that the temple maintained some form of ritualistic function. However, there is also strong evidence that some form of settlement must have formed in and/or around the ancient temple. This conclusion was reached on the basis of the numerous ceramic finds that are largely domestic in nature. This may have been a monastic settlement.

In the later Middle Ages, the use of Marsaxlokk as a harbour by medieval seafarers is evidenced by the inclusion of the harbour in medieval portolani. At least three of these medieval sailing instructions dating as far back as the 13th Century mention Marsaxlokk (as marza sinocho, Marsa silocco and marza per sirocho). The Rizo portolan of 1490 gives sailing distances from Marsaxlokk to a variety of pther ports in the Mediterranean including Tunis, Cephalonia and Tripoli in Libya. This is a clear indication of the port’s connectivity with other parts of the medieval MediterraneN (Cassola 1992).

5.1.4 Early Modern

There is little recorded activity in the Early Modern period in and around Marsaxlokk. Due to the numerous attacks by North African corsairs, the Maltese coast was largely bereft of settlements. This does not signify that the harbour fell into disuse. It was utilized by corsairs who conducted large-scale raids on the island. During the largest such raid, known as the Great Siege of 1565, Marsaxlokk was used as the main base until the capture of St Elmo when the fleet was moved to Marsamxett.

Figure 3: Ottoman ships anchored in Marsaxlokk in 1565.

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In order to prevent such landings from enemy vessels the Order of St John embarked on the building of fortified towers in the Marsaxlokk Bay. Fort San Lucjan was built in the first decade of the 17th century by Grand Master Wignacourt. Completed in 1610, it was put to the test four years later when a large Turkish force attempted to land in Marsaxlokk but was repulsed by the guns from the fort (Spiteri 1990: 164). Later in the seventeenth century the Order constructed the ‘Kavallerizza’ in Marsaxlokk - “a wide squattish tower fitted with musketry loopholes” (Spiteri 1009: 171). Other fortifi-cations from this period in the general environs include the gun batteries at Birzebbu-ga and retrenchments in various parts of the harbour complex.

Figure 4: Kavallerizza’ in Marsaxlokk

5.4.1.1 Other functions 1530-1798

Marsaxlokk harbour was very important for the local merchant and corsair fleet espe-cially during the 17th and 18th centuries. The Tower was mostly used in anti smug-gling exercises and also aided private Maltese ships by providing water, wine, salted fish, and dried fruit against a small fee. It seems that the local Torraro made a hand-some profit with such transactions. At times the soldiers of the tower were also used to help row becalmed ship out of harbour. One such example occurred in 1777, when the corsair frigate of Leopoldo Desira was becalmed in port and the tower aided the frigate with its longboats against a fee of 8T ari. (Reference: Notarial Archives, Misc Box: Venditi degli schiavi, Leopoldo Desira 1777)

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5.4.1.2 Blockade 1798-1800

During the Blockade 1798-1800, Marsaxlokk was the most important harbour of Malta for the Maltese revolutionaries along with St. Paul's Bay. Evidence shows that all ship-ping arriving at Malta to aid the National congress had to go through Marsaxlokk. Traffic was so busy that a Port Master was appointed by Michele Cachia Commandant of Zejtun. The Harbour Master was Giuseppe Bugeja. All British, Neopolitan and Por-tugese Ships, allies of the Maltese availed themselves of Marsaxlokk. One account de-scribes how a Maltese Soldiers was accused of throwing Brandy Bottles from British ships into the water so that he would retrieve them later to sell them at a profit. Apart from the mentioned brandy bottles, possibly the most important artifact ever retrieved from Marsaxlokk bay was a cannon pertaining to the 1798-1800 period. A bronze 32 pound Neapolitan cannon was retrieved in the mid- 20th century by the Royal navy. This unique gun cast in Palermo was sent to Malta as war aid by the king of Naples, rightful sovereign of the Islands of Malta. Unfortunately this most needed war material was lost when it was being offloaded by a British warship (HMS Strombolo in Decem-ber 1798). It is preserved at Palace Armoury in Valletta. (Reference: Alfredo Mifsud Sovrantia Inglese 1908, Museum Reports 1905-1950 MMM Library)

5.1.5 Modern

During the British period, Marsaxlokk developed into a small fishing port - a fo rm of mar i t ime satel l i t e enc lave fo r the town o f Zej tun. It was also a place where people from urban centres would take up residence for the summer months (villegatura). Numerous buildings in the area were specifically developed for these purposes. During the 1880s, a large and powerful fort (Fort Delimara) was built to protect the entrance to Marsaxlokk Bay from enemy ships. Today, despite years of neglect this historic fort is still in relatively good condition with four of the original twelve Victorian guns still in place. In the early 20th century, the area known as Kalafrana was developed by the British armed forces as a base for seaplanes. During World War II, the presence of this base exposed Marsaxlokk to bombing raids.

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Figure 5: The Kalafrana seaplane base

Recent studies in the social history of Marsaxlokk point to the area of study being popu-lar with the locals for the harvesting of fish and molluscs. The presence of Posidonia reefs in the area meant that locals could walk out to sea to carry out their harvesting ac-tivities (see Psaila 2003).

This historical overview of Marsaxlokk Bay clearly indicates varying degrees of hu-man/maritime activity within the area of study.

5.2 Disturbances and Discoveries

Before considering the discoveries within the area it is imperative to explore the various site formation processes that may disturb archaeological deposits present in the area. 5.2.1 Disturbance factors in Maltese bays and harbours

1) Dredging References to dredging were recorded in the Museum Annual Reports. Furthermore, dredging activities were also carried during the con-struction of the power station in the late 1980s. Although this activity is known to all Enemalta could not trace any official records related to this phase of the project.

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2) Anchoring

The dynamics of dropping and raising large an2chors in the Bay would have

led to the disturbance of any material found in approximately the first

two metres of the seabed where the top sediments can be very soft.

3) Prop wash

Propeller action in relatively shallow water may disturb the top layers

of the sediment in specific areas of the creek

4) World War II Bombs Bombs exploding on and in the sediment would definitely disturb various

layers of the sediment.

5) Local fishing habits

Fishing for gandofli normally entails the hand fanning of not more than

40cm of sediment meaning that only the topmost layer of the seabed

would be disturbed. Such activities are generally carried out in the proximity

of the quays and shoreline.

5.3 Discoveries

Discoveries from an underwater context within the area of influence (AOI) are summa-rized here. Moreover sites in the immediate vicinity of the AOI are also report-ed. This has been done so as to ensure that the AOI is not considered to exist within a vacuum. Over the past decades a number of archaeological objects have been discovered and raised from the seabed in Marsaxlokk Bay. Some of these objects were reported to the competent authorities, deposited and eventually published in the Museum Annual Re-ports (MAR) issued by the former Museums Department. From these reports one can garner an idea as to the variety of the objects present within the sediments. Some other objects referred to below have been brought to the author’s attention over the past years – mainly through personal contact with persons involved in div-ing operations within the harbor as well as through research in various lesser-known depositories.

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1) One partial amphora – probably late Roman - brought up from seabed in 1998. Exact location of discovery unknown. Object is currently housed in the collection of the St Agatha Museum in Rabat.

Figure 6: STA 06

2) One decorated base of unidentified ceramic object –probably a medieval Ar-ab piece brought up from seabed in 1998. Exact location of discovery un-known. Object is currently housed in the collection of the St Agatha Museum in Rabat.

Figure 7: STA 11

3) Various ceramic fragments as reported in the MAR. 4) A large bronze cannon (see above).

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Figure 8: Cannon brought up from seabed (source: private collection).

5) In 1997, pottery fragments were discovered in 6 meters of water during cleaning of seabed (Source: SCH archives).

6) Ghar L-Ahmar: “Extensive ceramic scatters were reported to be found at a depth of 3m off the Ghar L-Ahmar coast at Marsaxlokk” (Source: SCH ar-chives).

Here one must consider how these objects came to rest on the seabed. All objects

must have been either: a) part of a shipwreck; b) lost overboard accidentally –

such as the loss of the bronze cannon. Objects may also have been disposed of

purposely – such as the jettisoning of objects broken on board or objects caught in

fishing nets and subsequently disposed of. Objects lost over board in a harbor con-

text accumulate over the centuries to form important archaeological layers known

as ‘harbor deposits’. Such deposits contain information that can shed light

on the history of the harbor, on the everyday life on board the vessels that used

the harbor as well as on ‘one-off’ historical events (see section on Great Siege of

1565). The objects listed must not be considered as an exhaustive and definiti ve

list of archaeological material discovered/noted in the Marsaxlokk Bay area.

There have certainly been many more retrievals but these would be unrecord-

ed and are in the hands of private individuals who have dived and/or fished

in the area over the past decades.

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6.0 Diver Survey

6.1 Methodology In order to inspect the seabed within the area of study it was decided to carry out a vis-ual inspection using standard SCUBA equipment. A dive buoy was used to ensure that boat traffic would be aware of operations – at all times the dive team was assisted by an authorized vessel. Dive operations were covered by a Notice to Mariners issued by Transport Malta. During all dives, features of interested where recorded using an under-water camera. A swim line search was carried out by two persons swimming fifteen meters apart. A to-tal of ten lines were covered.

Figure 9: Swim lines carried out for survey.

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Figure 10: The marker buoy at one of the start points.

6.2 The Seabed

The seabed within the area of study is very varied. In the areas close to the shore it is mainly characterized by stretches of sand with sparse stones. Close to the recently re-claimed promontory – the seabed is mainly made up of dumped stones. Towards the outer reaches of the area of study and close to the centre of Marsaxlokk Bay the seabed is mainly made up of a silty sand. Other areas are characterized by the presence of Po-sidonia Oceanica meadows and/or mattes, light growth covering and exposed bedrock.

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Figure 11: A sandy patch adjoining Posidonia mattes.

6.3 Results 1) A small number of archaeological objects were detected on the surface during

these diving operations. 2) The objects consist of the following: 1) a ceramic fragment (non-diagnostic); 2) a

fragment of a ceramic bowl (possibly Roman); 3) some loose ammunition.

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Figure 12: Part of a ceramic bowl on seabed. 3) Within areas covered in Posidonia Oceanica it is hard to discern the presence of

objects on the seabed. However, mattes were inspected closely but these too were archaeologically sterile. Mattes measuring two meters in height were noted close to the main fairway – these were inspected and the sections were found to be sterile.

Figure 13: A typical section of a Posidonia matte in the AOI.

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4) Throughout the AOI modern debris may be observed on the seabed or in a semi-buried state.

Figure 14: Modern debris on seabed.

6.4 Conclusions for diver survey 1) It can be safely ascertained that the there are no significant archaeological de-

posits present ON the seabed in the area of study. 2) The presence of semi-buried modern debris points to the rapid sedimentation

rates present – it is therefore more like that should archaeological deposits be present in the area of study these would be buried..

3) The lack of success by previous expeditions confirms the abovementioned idea. 4) The objects noted during this phase of this survey may be discards from fisher-

men’s nets on their return to their home port.

7.0 Analysis of Remote Sensing Data

The remit for this study also included the analysis of data acquired in the course of this study commissioned by ERSLI. The full technical reports, methodologies and data sets are submitted as Appendix B to this report. Technical specifications are in-cluded as Appendix B. All data and deliverables (geo-tiffs, autocad files, html files etc) are included on CD-Rom submitted with this report.

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7.1 Sub Bottom Survey Targets

The sub bottom profiler was used to map the sediments within the area of study as well as to locate potential targets that may be buried within these same sediments. Dense, hard materials such as steel or iron would be expected to produce the strongest reflections, whilst wood and pottery would produce weaker reflections. Targets with weaker reflecting characteristics may be non- metallic in origin and possibly more significant from the archaeological point of view. The origins of the more scattered individual targets cannot be determined, however, the greater the depth of burial, the older the source of the reflections are likely to be. It should be noted that one exception to this rule may be unexploded ordnance (UXO). An unex-ploded 500 kg bomb can penetrate several meters into soft sediment. The possible presence of UXO should be considered before excavation of any of the targets listed. A total of 9 sub bottom targets were located. These vary in size from 6 meters (smallest) to 20 meters (largest). All the anomalies are situated within the first 2 meters of the sediment deposits. By their very nature, sub bottom targets are very difficult to analyze and identify. The archaeological exploration of sub bottom targets usually coincides with work on a known site. One such example would be the survey of a known ancient shipwreck to investigate how much cultural material exists under the visible objects. However, the situation presented to us here is such that the objects detected in this survey do n o t coincide with any known archaeological sites or objects. However, one must not discount the possibility that some of these targets may consist of cultural material.

7.2 Magnetometer Survey Targets

A magnetometer was used to locate and map objects containing (or made of) non-ferrous metals. Whereas in maritime archaeology magnetometers are generally used to identify relatively modern wrecks with iron cannon or vessels of metal construction – this technol-ogy has also been known to locate deposits of ancient pottery which develop their “ther-mo-remnant magnetic properties” when the “magnetite bearing clay is heated to a rela-

25


tively high temperature and cooled in the presence of the earth’s magnetic field” (Green 2004:63).

There are numerous magnetometer targets. Given that a magnetometer cannot dis-tinguish between an iron cannon and a metal chain it is very hard to classify these targets. The sheer quantity of targets leads one to believe that the magnetometer picked up many pieces of modern debris that are currently lying in the area of study. This debris includes large pieces of a steel vessel that are abandoned on the seabed just off the modern quay.

26


8.0 Summary of Impacts CONSTRUCTION/INSTALLATION WORKS Impact type and Source

Impact type Piling works Specific intervention leading to impact

Planned piling works

Project phase Construction/Installation works

Impact Receptor

Receptor type Potential archaeological deposits

Sensitivity and resilience toward impact

Low/Medium/high sensitivity, due to the unknown nature of the potential archae-ological deposits.

Effect and Scale of Impact

Direct/Indirect Direct and indirect

Cumulative No

Beneficial/Adverse Adverse

Severity Medium

Physical/geographic ex-tent

Localized in areas earmarked for piling. The further away from the coast the high-er the sensitivity – this statement is based on the fact that close to shore the sea-bed has already been disturbed through past dredging works.

Short/Medium/Long Term

Throughout construction/installation phase

Temporary/Permanent if temporary indicate duration

Permanent

Reversible/Irreversible if reversible indicate ease of reversibility

Non-reversible

Probability – Significance – Mitigation – Residual Impacts – Other Requirements

Probability of impact oc-curring (inevitable, likely, re-mote uncertain)

Uncertain - If works are planned around the mapped targets then the possibility of an impact will be remote. The worst case scenario would be represented by a situ-ation whereby undetected archaeological objects are discovered during piling works.

Significance Overall Impact

Low to medium

Proposed Mitigation Measures

Keep planned piles away from SBP targets.

Significance Residual Impact

Medium

Monitoring Monitoring material from piles.

27


Impact type and Source

Impact type Removal of sediments from seabed (should dredging be required 1 )

Specific intervention leading to impact

Dredging


Impact Receptor

Receptor type POTENTIAL archaeological deposits.




Direct/Indirect Direct/Indirect

Cumulative No


Severity Medium


Localized in areas earmarked for dredging. The further away from the coast the higher the sensitivity – this statement is based on the fact that close to shore the seabed has already been disturbed through past dredging works.


Throughout construction/installation phase


Permanent.


Non-Reversible



Uncertain - The worst case scenario would be represented by a situation whereby undetected archaeological objects are discovered during dredging works.


Medium


Investigate SBP targets in areas earmarked for dredging.


medium

Monitoring Monitoring of material raised during dredging works.

1 Although no dredging is planned for the project this proviso is being included to cover the possibility of having to carry out unforeseen dredging works related to the construction phase of the project.

28



Impact type Disturbance from increased vessel traffic


Vessel activity – propwash causing the movement of sediments.


Impact Receptor

Receptor type Potential archaeological deposits.




Direct/Indirect Direct

Cumulative May be cumulative if adverse impacts resulting from a different source/project prevail within the general area, i.e. from outside or within the AoI


Severity Low




Throughout construction/operating phase


Permanent


Non-Reversible


Probability of impact occurring (inevitable, likely, re-mote uncertain)

Remote


Low/medium


Where possible vessels are to keep similar navigational paths.


Low

Monitoring Monitoring of changes in bathymetry

29



Impact type Physical alteration of the seabed


Deployment of temporary structures on the seabed (eg anchors for barges etc)


Impact Receptor





Direct/Indirect Direct

Cumulative May be cumulative if such vessels are repeatedly deployed.


Severity High




Should this happen impact would be long term for places where the seabed has been altered


Permanent


Irreversible for places where the seabed has been impacted by such activity.



Uncertain - The worst case scenario would be represented by a situation whereby undetected archaeological objects are discovered during dredging works.


Medium


Placing anchors etc away from mapped targets. Having set areas for the placement of anchors etc.


Medium

Monitoring Monitoring during the placement of anchors etc.

30



Impact type Changes to the hydrodynamic regime of the area


Construction of jetty/FSU/FRSU and alteration of the shore through land reclamation (should this be required 2)


Impact Receptor



Medium/High, due to the unknown nature of the potential archaeological deposits.


Direct/Indirect Indirect

Cumulative May be cumulative if adverse impacts resulting from a different source/project prevail within the general area, i.e. from outside or within the AoI

Beneficial/Adverse Potentially adverse if deposits are exposed.

Severity The further away from the coast the higher the sensitivity – this statement is based on the fact that close to shore the seabed has already been disturbed through past dredging works.

Physical/geographic extent Localized in areas earmarked for dredging and potentially beyond. The further away from the coast the higher the sensitivity – this statement is based on the fact that close to shore the seabed has already been disturbed through past dredging works.


Throughout construction/operational phases.

Temporary/Permanent if temporary indicate dura-tion

Permanent


Irreversible



Uncertain - depending on whether new jetty changes currents and to what extent. The worst case scenario would be represented by a situation whereby undetected archaeological objects are discovered due to changes to the hydrodynamic regime of the area.


Low


None


Low to medium

Monitoring Monitoring sediment deposition changes for two years after project completion.

2 Although no dredging is planned for the project this proviso is being included to cover the possibility of having to carry out unforeseen dredging works related to the construction phase of the project.

31


9.0 Recommendations Despite the lack of concentrated archaeological evidence on the seabed within the area of study one must not exclude the possible presence of cultural deposits pre-sent within this said area. Given that much of the area is made up of sediment de-posits the presence of buried archaeological objects and/or sites must not be dis-counted. This statement can be corroborated from results acquired during an excavation in Dockyard Creek in 2002. In the course of this excavation over a thousand objects were raised from a trial trench that measured approximately seven cubic meters (Gambin 2003). Other aspects emerging from this study further consoli-date the notion that the archaeological potential in this area is high. These are:

1) The use of the harbour in antiquity.

2) The use of the area by the Ottoman Fleet in 1565. – the hurried na-

ture of the evacuation must have resulted in the loss of some

equipment/objects overboard.

3) The presence of anchored vessels throughout history (including the above-mentioned pirate fleets).

It is safe to state that the intensive maritime use of the area increases the possibility of the presence of objects thrown and/or lost overboard. The recommendations are therefore being suggested to ensure that no potential archae-ological sites are lost.

1) Where possible piling works are to be planned so as to avoid SBP and Mag-

netometer targets.

2) However, should the project engineers determine that the above are not

feasible/possible - refer to the section below on monitoring.

32


9.1 Monitoring

9.1.1 During construction phase

Given the high potential for cultural material to be present within the sediments, all dredging, piling and/or other disturbance of the seabed is to be monitored by professional personnel.

The potential of sediment movement/coastal erosion is also to be studied and moni-tored. Such changes may be brought about by variations of bathymetry through the construction of piles etc. Sediment movement/erosion brought about by these ‘new’ objects on the seabed may expose archaeological objects in the medium to long terms.

Special attention is to be paid to any disturbance of or around sub bottom targets. In order to achieve this, project managers must obtain approved methodologies from the authorities concerned. These may include but are not limited to further studies and underwater inspections by qualified diving archaeologists.

Should any disturbance be planned in the vicinity of magnetometer targets these (the targets) should be verified by qualified diving archaeologists. The latter will ascertain whether the targets correspond to debris or whether there is a potential buried target in the area. Should the possibility of a buried target arise then the same precautions sug-gested for works around a sub bottom target should be implemented. Any material that is recovered during piling (or from dredged material should dredg-ing be required) is to be inspected (in real time) by professional personnel in a man-ner approved by the authorities. All cultural items retrieved in this manner are to be catalogued and put through appropriate conservation processes that will ensure their long-term preservation. Should significant deposits be noted in pile material (or in dredged material should dredging be required), monitors should be empowered to stop construction works until all necessary checks are made and information gathered which will, in turn, con-tribute to a possible way forward.

33


Monitoring terms of reference are to be issued by MEPA in conjunction with the Superin-tendence of Cultural Heritage. Following the submission of the final diagram (Figure 15), it is clear that the main installa-tions are not close to the sub bottom/magnetometer targets. However, due the possible presence of undetected and/or small archaeological deposits in the area the monitoring recommendations for piling works stand.

Figure 15: Overlay of proposed project layout for the jetty and FSU over the map of targets

9.1.2 After the construction phase

The seabed around the newly constructed breakwater is to be inspected so as to study any possible effects of new current patterns and scouring processes on potential archaeological deposits. Terms of reference for this phase of monitoring are to be issued by MEPA in close consultation with the Superintendence of Cultural Heritage.

34


10. Bibliography

Abela, G.F. (1647) Della Descrittione di Malta (Malta).

Ashby, T. (1915) Roman Malta Journal of Roman Studies 5: 23-80.

Atauz, A. D., and McManamon, J., (2001) Underwater survey of Malta: the recon-

naissance season of 2000, in The INA Quarterly, Volume 29, No. 2 (Spring

2001), pp 15-20.

Atauz, A. (2002) Archaeological Survey of the Maltese Archipelago 2001, in The INA Quarterly, Volume 28, No. 1, pp 22-28

Atauz, A. (2008) Eight Thousand Years of Maltese Maritime History – Trade, Piracy and Naval Warfare in the Central Mediterranean (Florida Uni-

versity Press).

Azzopardi, E. (2002) Site Formation Processes and the Archaeological Record

Underwater (undergraduate dissertation submitted to the Department of

Classics and Archaeology at the University of Malta).

Azzopardi, E. (2004) Under the Sea: A history of underwat er archaeology in

Malta in Cortis, T. and Gambin, T. (eds) De Triremibus: A Festschrift in Hon-

our of Joe Muscat (PEG Books).

Azzopardi, E. and Gambin, T. (2012) Archaeology and the Sea in the Maltese Is-

lands (Midsea Books).

Blouet, B. (1964) The Story of Malta (Malta). Bonanno, A. (2005) Malta: Roman, Phoenician, Punic (Midsea Books). Bruno, B. (2009) Roman and Byzantine Malta: Trade and Economy (Midsea Books).

35


Cassola, A. (1992) The Maltese Toponomy in three Ancient Italian Portulans (1296-1490) Al-Masaq Studia Arabo-Islamica Mediterranea International Jour-nal of Arabo- Islamic Mediterranean Studies 5: 47-64.

Frost, H., (1969) The mortar wreck in Mellieha Bay: plans and soundings: a re-port on the 1967 campaign carried out on behalf of the National Museum of Malta, London: Appetron Press Ltd.

Galea, F. (1986) Call-out: a wartime diary of air/sea rescue operations at Malta (Malta).

Gambin, T. (2003) A Window on History from the Seabed Treasures of Mal-ta 10.1: 71-76.

Gambin, T. (2005) Islands of the Middle Sea: an archaeology of a coastline in Proceedings of the international seminar Le contexte physique et territorial des ports anciens et des points d'abordages, Alicante, Spain – No-vember 2003 (Lazio). Green, J. N. (2004) Maritime Archaeology a Technical Handbook. 2nd ed. Else-vier Academic Press, London.

1959, Report on the working of the museum department, Malta: Department of Information 1960, Report on the working of the museum department, Malta: Department of Information 1964, Report on the working of the museum department, Malta: Department of Information 1965, Report on the working of the museum department, Malta: Departme nt of Information 1967, Report on the working of the museum department, Malta: Department of Information

Marriner, N., Gambin, T., Djamali, M., Morhange, C. & Spiteri, M. 2012, " Geoarchaeology of the Burmarrad ria and early Holocene human impacts in western Malta ", Palaeogeography, Palaeoclimatology, Palaeoecology, vol. 339-341, no. 3, pp. 52--65.

36


Pace, A. (2004) The Sites in D. Cilia (ed) Malta Before History (Mirnda Pub-

lications: Malta).

Parker, A. J., (1992) Ancient shipwrecks off the Maltese Islands, in,

Ancient shipwrecks of the Mediterranean & the Roman provinces, Oxford :

B.A.R.

Petriaggi. R. & Davidde, B. (2007) Archeoligia Sott’Acqua – Teoria e Pratica (Fabrizio Serra Editore – Pisa). Psaila, L. (2003) Il-Bahar Rasu iebsa (Midsea Books).

Sagona, C. (2002) The Archaeology of Punic Malta (Ancient Near Eastern Studies Supplement 9) (Belgium: Peeters).

Smyth, W. 1821: (Plan) of the harbours and fortifications of Valetta in the island of Malta Admiralty Chart No: 195 published by the London Hydrograph-ic Office.

Spiteri, S. (1990) The Knights Fortifications – Illustrated Guide (Malta).

Wettinger, G. (2000) Place-names of the Maltese Islands ca.1300-1800 (Mal-ta: PEG).

37


Appendix A

Magnetometer – Geometrics G-882

• Operating Principle: Self-oscillating split-beam Cesium Vapor (non-radioactive) • Operating Range: 20,000 to 100,000 nT • Operating Zones: The earth's field vector should be at an angle greater than 6o

from the sensor's equator and greater than 6o away from the sensor's long axis. Automatic hemisphere switching.

• CM-221 Counter Sensitivity: <0.004 nT/ pHz rms. Typically 0.02 nT P-P at a 0.1 second sample rate or 0.002 nT at 1 second sample rate. Up to 40 samples per second

• Heading Error: <1 nT over entire 360o spin and tumble • Absolute Accuracy: <3 nT throughout range • Output: RS-232 at 1,200 to 19,200 Baud

Mechanical

• Sensor Fish: Body 2.75 in. (7 cm) diameter, 4.5 ft (1.37 m) long with fin assem-bly (11 in. cross width), 40 lbs. (18 kg) Includes Sensor and Electronics and 1 main weight. Additional collar weights are 14lbs (6.4kg) each, total of 5 capable

• Tow Cable: Kevlar Reinforced multiconductor tow cable. Breaking strength 3,600 lbs, 0.48 in OD, 200 ft maximum. Weighs 17 lbs (7.7 kg) with terminations.

• Operating Temperature: -30oF to +122oF (-35oC to +50oC) • Storage Temperature: -48oF to +158oF (-45oC to +70oC) • Altitude: Up to 30,000 ft (9,000 m) • Water Tight: O-Ring sealed for up to 9000 ft (2750 m) depth operation • Power: 24 to 32 VDC, 1.0 amp at turn-on and 0.5 amp thereafter

38


Strata Box Sub Bottom Profiler

SPECIFICATIONS

Units: Feet or Meters

Depth Ranges:

0-15, 0-30, 0-60, 0-120, 0-240, 0-450 Feet. 0- 5, 0-10, 0-20, 0- 40, 0- 80, 0-150 Meters. Millisecond range-scale available in either Feet or Meters. Auto-ranging Modes in all units.

Shift Range: 0-450 feet in 1 foot increments , 0-150 meters in 1 meter increments

Zoom Range: 15, 30, 60, 120, 240 feet 5, 10, 20, 40, 80 meters

Zoom Modes: Bottom Zoom, Bottom Lock, Marker Zoom, GUI Zoom (Playback Only)

Display:

Normal Data, Zoom Data, Navigation, Depth, Com-mand/Status Color Control for Data: 4 selections or Custom (User In-put), Data Invert possible.

Strata Resolution: 6 cm with up to 40 Meters bottom penetration.

Depth Resolution: 0.1 foot, 0.1 meters.

Depth Accuracy: 0.5%

Speed of Sound: 1500 Meters/Second or 4800 Feet/Second.

Geographic Posi-tion

NMEA 0183, GLL, GGA, RMC, VTG, VHW, HDT. Selectable Baud Rate, RS-232. COM2

Data Input: ODEC Stratabox Interface, 57.6Kbaud, RS-422. COM1

Printer Output: Centronics (Parallel Port) interface to TDU Series Thermal Printers.

Shallow Water Op-eration:

< 2.5 meters; bottom type dependant

39


Transmit Rate: Up to 10 Hz, depth and operator mode dependent.

Event Marks: Manual or Periodic (selectable in 1 minute intervals)

Data File Output:

Saves Depth, Navigation, and Graphic Data in ODC for-mat (Proprietary). Normal Data and Zoom Data stored is Pixel Data and can be played back and printed.

Data File Playback: Files played back and printed at Normal or Rapid Advance Speed, with Pause and GUI Zoom available.

Frequency Output: 10 Khz.

Transmit Output Power:

300 Watts (Pulsed), 1000 Watts capable.

Input Power: 10-30 Volts DC, Nominal Power 8 watts, Reverse Polarity and Over Voltage Protected.

Dimensions: 25.4 cm (10") Length, 22.86 cm (9.0") Width, and 6.25 cm ( 2.5") Height. (see below)

Weight: 0.9 kg (2.0 lbs).

Environmental:

-25(C to +60(C Operating Temperature (-55(C to +90(C Storage) Water Resistant to EN60529 IP65 EMC meets EN60945 Emissions ; CE Compliant

40

Appendix B

FIELD REPORT FOR A MAGNETIC AND SHALLOW SEISMIC SURVEY

MARSAXLOKK BAY, MALTA

Prepared by:

Dr Timothy Gambin BA MA PhD (Bristol)

Logistic Support:


Malta

Telephone: (+356) 2143 1900 Fax: (+356) 21424 137


August 2013



TABLE OF CONTENTS

1 SCOPE OF WORKS ................................................................................... 4

1.1 Introduction....................................................................................... 4 1.2 Purpose of the Project ........................................................................ 4

2 scope of works ........................................................................................ 5 2.1 Survey – Scope of Works..................................................................... 5 2.2 Equipment Used ................................................................................. 6

3 field SURVEY ........................................................................................... 7 3.1 Survey .............................................................................................. 7

4 Results and Conclusions ........................................................................... 10

TABLE OF FIGURES Figure 1. Site Location and Survey Lines .......................................................... 5 Figure 2. Recorded Navigation Survey Lines ..................................................... 8 Figure 3. Magnetometer Surveys Lines ............................................................ 9 Figure 4. SBP Survey Lines ............................................................................ 10 Figure 5. Sub Bottom Profiler lines with anomalies ........................................... 11 Figure 6. Magnetometer Lines with Contacts ................................................... 12

2

Ecoserv Ltd. Report on Marine Archaeology August 2013 Marsaxlokk Bay, Malta NON TECHNICAL SUMMARY Ecoserv Ltd was commissioned to carry out this study by ERSLI Con-sultants t o carry out a study of marine magnetic and shallow seismic survey at Marsaxlokk Bay. The pro-gramme of survey was undertaken in advance of construction works associ-ated with a nearby industrial facility in order to locate and possibly identify any potential buried cultural heritage which may be present in the pro-posed development impact zone.

The survey works comprised a marine magnetometer survey with an accom-panying sub bottom profiler survey. Single beam bathymetric data was derived from the first seafloor reflec-tor as recorded by the sub bottom profiler.

The survey was carried out over 2 days, 1st and 8th August 2003. 27 Survey lines of sub bottom profiler data were acquired. These translated into 27814.90 linear metres of sub bottom profiler data. Similarly, 21 lines of marine magnetometer data were acquired. The data acquired was generally of good quality with both

seafloor reflectors and magnetic anomalies noted.

Fewer magnetometer lines were rec-orded than sub bottom profiler as shallow waters to the north of the survey area meant there was greater potential for damage to the magne-tometer. Consequently, the magne-tometer lines planned for this area were not carried out.

Of the 27 sub bottom profiler traces investigated, a total of eight seafloor anomalies were noted. These ranged from small possible substrate features to larger anomalies. The nature and forms of the anomalies were indistin-guishable from the profile trace and so investigation may be warranted. A number of these were close to mag-netic anomalies but none were direct-ly overlapping. There is the possibility that anomalies 5, 6, 7 & 8 do relate to nearby magnetic anomalies. Conse-quently, priority should be given to these.

The marine magnetometer was an ultra high sensitive marine magne-tometer. It recorded a large number

2

Ecoserv Ltd. Report on Marine Archaeology August 2013 Marsaxlokk Bay, Malta of magnetic signatures, a number of these were located close to sub bot-tom profiler anomalies, namely SBP anomalies 5,6,7 & 8.

Due to the passage of nearby vessels and the presence of large metallic ob-jects in and around area of study, the actual magnetometer targets may not be representative of actual non-ferrous metal deposits.

3

Ecoserv Ltd. Report on Marine Archaeology August 2013 Marsaxlokk Bay, Malta

1 SCOPE OF WORKS

1.1 Introduction Ecoserv Ltd was commissioned to carry out this study by ERSLI Consultants t o car-ry out a programme of marine magnetic and shallow seismic survey at Marsaxlokk Bay. The programme of survey was undertaken in advance of construction works associated with a nearby industrial facility in order to locate and possibly identify any potential bur-ied cultural heritage which may be present in the proposed development impact zone.

The survey works comprised a marine magnetometer survey with an accompanying sub bottom profiler survey. Single beam bathymetric data was derived from the first seafloor reflector as recorded by the sub bottom profiler.

The survey was carried out over 2 days, 1st and 8th August 2003. 27 Survey lines of sub bottom profiler data were acquired. These translated into 27814.90 linear metres of sub bottom profiler data. Similarly, 21 lines of marine magnetometer data were acquired. The data acquired was generally of good quality with both seafloor reflectors and mag-netic anomalies noted.

1.2 Purpose of the Project The programme of survey was undertaken as a component of a marine archaeological assessment. The assessment was requested in advance of construction works associated with a nearby industrial facility in order to locate and possibly identify any potential bur-ied cultural heritage which may be present in the proposed development impact zone.

The principle aim of assessment is to anticipate and avoid impacts on the archaeological resource.

Assessment has been described as the overall process of assessing the impact of a de-velopment. It can comprise of mitigatory measures including documentary research, examination of aerial photographs, non-invasive geophysical survey etc. and more intru-sive measures including testing and/or full excavation.

4


Figure 1. Site Location and Survey Lines

2 SCOPE OF WORKS

2.1 Survey – Scope of Works The programme of survey was undertaken in advance of construction works associated with a nearby industrial facility in order to locate and possibly identify any potential bur-ied cultural heritage which may be present in the proposed development impact zone.

The survey works comprised a marine magnetometer survey with an accompanying sub bottom profiler survey. Single beam bathymetric data was subsequently derived from the first seafloor reflector as recorded by the sub bottom profiler.

The survey was carried out over 2 days, 1st and 8th August 2003.

5


2.2 Equipment Used

2.2.1 Positioning

Vessel and equipment positioning was provide by a Trimble 132 AgDGPS. This, survey grade, GPS used EGNOS and WAAS corrections to provide sub metre accuracy at all stages of the survey. A receiver antenna was mounted on the roof of the survey vessel, with a receiver processor being situated in the survey lab. Layback was calculated from the antenna to each of the respective survey components. These calculations were in-putted into the relevant softwares thus providing each unit with a real time position.

2.2.2 Navigation

Vessel navigation was provided by Hypack 2013a. Hypack is the most widely used hy-drographic software package in the world. It enables users to create and follow pre-determined and pre-configured survey lines. It uses GPS input to calculate navigation errors and provides the helmsman with cross track and off track measurements.

2.2.3 Marine Magnetometer

The Geometrics 882 was the marine magnetometer used for this survey. It is a cesium-vapor marine magnetometer which delivers high resolution results in all types of survey applications. The G-882 is a compact system designed for professional surveys in shal-low or deep water.The G-882 magnetometer’s digital output can be recorded with any serial data logger but its full potential is obtained when used with our Mag Log Lite software to log, display and print GPS positioned measurement results.

The G-882 is designed for operation from small vessels for shallow water surveys as well as for large survey vessels for deep tow applications (4,000 psi rating, telemetry over steel coax available to 10Km). It is easily deployed and operated by one person.

All magnetometer data was acquired using Geometrics proprietary Mag Log lite soft-ware. It allowed integration of positional data from the previously mentioned dGPS thereby providing real time locational information.

2.2.4 Sub Bottom Profiler

6


The SyqwestStrata Boxwas the sub bottom profiler used for the survey. It is a portable high- resolution marine sediment imaging instrument capable of delivering 6 cm of ma-rine sediment strata resolution with bottom penetration of up to 40 meters. It is de-signed exclusively for inshore and coastal geophysical marine survey up to 150 meters of water depth.

3 FIELD SURVEY

3.1 Survey The programme of survey was undertaken in advance of construction works associated with a nearby industrial facility in order to locate and possibly identify any potential bur-ied cultural heritage which may be present in the proposed development impact zone.

The survey was carried out over 2 days, 1st and 8th August 2003.

A total of 27 Survey lines of sub bottom profiler data were acquired. These translated into 27814.90 linear metres of sub bottom profiler data. Similarly, 21 lines of marine magnetometer data were acquired. Fewer magnetometer lines were recorded than sub bottom profiler as shallow waters to the north of the survey area meant there was greater potential for damage to the magnetometer. Consequently, the magnetometer lines planned for this area were not carried out.

7


Figure 2. Recorded Navigation Survey Lines 3.2 Equipment Configurations Sub Bottom Profiler The sub bottom profiler survey was carried out using a frequency of 10kHz. The DC gain of 40-45 dB was applied throughout the survey area with changes varying according to the water depth and the substrate type. The data was saved in SEG-Y format on a re-cording PC using Stratabox proprietary software. Magnetometer The marine magnetometer cycled at 1 Hz, there for once per second. This cycle rate is considered optimum for locating small buried materials. The towfish was deployed from the stern of the survey vessel and 50m of towcable was paid out. Accommodation for the 50m towcable length was included in the Mag Log lite recording software. 3.3 Data processing Magnetometer Processing of the magnetometer data was carried out using two distinct software pack-ages and work flows. The first workflow involved importing the raw mag log files into

8


Sonarwiz 5. This software allows interpretation of magnetic data and screen shot captur-ing of specific magnetic spikes. It geo-references the spikes and allows for further re-porting. The second workflow is to import the raw maglog files into Surfer software. This soft-ware allows the user to graphically represent the magnetic c data as a 3d contoured map.

Figure 3. Magnetometer Surveys Lines Sub Bottom Profiler All the recorded SEG-Y files were imported into Sonarwiz. The first seafloor reflector, the seafloor itself, was digitised. Varying levels of time varied gain (TVG) and AVG (Ac-tual Varied Gain) were then applied to the files to enhance trace image and highlight potential anomalies. All subsequent reflectors and anomalies were then digitised and reported on.

9


Figure 4. SBP Survey Lines Navigation All vessel navigation files were exported from Hypack 2013 as xyz files which are com-patible with all GIS and Auto CAD packages. 4 RESULTS AND CONCLUSIONS

A total of 27 Survey lines of sub bottom profiler data were acquired. These translated into 27814.90 linear metres of sub bottom profiler data. Similarly, 21 lines of marine magnetometer data were acquired. Fewer magnetometer lines were recorded than sub bottom profiler as shallow waters to the north of the survey area meant there was greater potential for damage to the magnetometer. Consequently, the magnetometer lines planned for this area were not carried out. Sub Bottom Profiler. Of the 27 sub bottom profiler traces investigated almost all had the same, roughly U shaped profile. The northern and southern ends were shallow with what appeared to be vegetative cover. In the centre, the seafloor then descended c. 20m to a flat seafloor. A number of gas pockets were noted in the shallow area on the sonar traces. These were typified by areas of non acoustic penetration, caused by gas pockets. The size of these

10


gas pockets were not discernible but in such an environmental they would usually be very shallow and would be formed through the decomposition of vegetative matter. . In the deeper areas, a very definite second acoustic reflector was noted throughout the entire deep water sections. This reflector was noted in almost all traces and appeared to be situated 3-4 m below the current seafloor surface. A total of eight seafloor anomalies were noted during the survey, these ranged from small possible substrate features to larger anomalies. The nature and forms of the anomalies were indistinguishable from the profile trace and so investigation may be war-ranted. A number of these were close to magnetic anomalies but none were directly overlapping. There is the possibility that anomalies 5, 6, 7 & 8 do relate to nearby mag-netic anomalies. Consequently, priority should be given to these.

Figure 5. Sub Bottom Profiler lines with anomalies

11


Marine Magnetometer The marine magnetometer was an ultra high sensitive marine magnetometer. It record-ed a large number of magnetic signatures. Some of these were caused by passing ves-sels and others may have been caused by pipelines and other man made features. Magnetic variations can be represented in various forms. If a magnetometer passes close to a large metallic anomaly, it will produce a large spike. If it passes a distance from it the spike is reduced. In this respect, a magnetometer passing close to a small metallic object will produce a similar signature to the magnetometer passing a distance from a larger object. In order to filter excessive variations, a threshold variation of 10 nT was applied to the magnetic readings. Any variation over 10nT would be considered as a potential anomaly. A total of 147 magnetic anomalies were noted during this survey. As previously detailed, a number of these were located close to sub bottom profiler anomalies, namely SBP anomalies 5,6,7& 8. Due to the passage of nearby vessels and the presence of large metallic objects in and around area of study, the actual magnetometer targets may not be representative of actual non-ferrous metal deposits...

Figure 6. Magnetometer Lines with Contacts

12


Appendix C Sub Bottom Profiler lines File N# PingsFile Si Bits/SMapPMinX MinY MaxX MaxY StartTime EndTimeC:\Ma 4686 4.9 16 UTM8 459362 3964575 459777.3 3965375 08/08/2013 10:57 08/08/2013 11:05C:\Ma 4928 5.1 16 UTM8 459321 3964586 459799.3 3965497 08/08/2013 11:07 08/08/2013 11:16C:\Ma 4576 4.8 16 UTM8 459358 3964659 459768.6 3965444 08/08/2013 11:17 08/08/2013 11:25C:\Ma 4320 4.5 16 UTM8 459402 3964686 459817 3965481 08/08/2013 11:26 08/08/2013 11:33C:\Ma 4492 4.7 16 UTM8 459429 3964703 459846.4 3965464 08/08/2013 11:34 08/08/2013 11:42C:\Ma 4139 4.3 16 UTM8 459412 3964796 459828.6 3965584 08/08/2013 11:43 08/08/2013 11:50C:\Ma 4473 4.7 16 UTM8 459424 3964854 459787.5 3965586 08/08/2013 11:50 08/08/2013 11:58C:\Ma 3604 3.8 16 UTM8 459466 3964930 459824.3 3965582 08/08/2013 11:59 08/08/2013 12:05C:\Ma 4299 4.5 16 UTM8 459470 3964919 459833.3 3965619 08/08/2013 12:06 08/08/2013 12:13C:\Ma 4134 4.3 16 UTM8 459492 3964952 459846.1 3965645 08/08/2013 12:14 08/08/2013 12:21C:\Ma 2753 2.9 16 UTM8 459499 3965190 459760.8 3965619 08/08/2013 12:21 08/08/2013 12:26C:\Ma 2326 2.4 16 UTM8 459537 3965229 459739 3965632 08/08/2013 12:26 08/08/2013 12:30C:\Ma 1686 1.8 16 UTM8 459581 3965237 459754.7 3965507 08/08/2013 12:31 08/08/2013 12:34C:\Ma 2254 2.3 16 UTM8 459546 3965263 459766.5 3965644 08/08/2013 12:34 08/08/2013 12:38C:\Us 6492 6.8 16 UTM8 459271 3963939 459936.7 3965220 08/08/2013 08:39 08/08/2013 08:50C:\Us 7916 8.2 16 UTM8 459270 3963953 460001.7 3965342 08/08/2013 09:32 08/08/2013 09:45C:\Us 7319 7.6 16 UTM8 459230 3964019 459965.7 3965407 08/08/2013 09:18 08/08/2013 09:31C:\Us 7280 7.6 16 UTM8 459289 3963972 459966 3965254 08/08/2013 09:04 08/08/2013 09:16C:\Us 6299 6.6 16 UTM8 459229 3963964 459928.3 3965276 08/08/2013 08:27 08/08/2013 08:37C:\Us 6241 6.5 16 UTM8 459252 3963938 459918.9 3965187 08/08/2013 08:14 08/08/2013 08:25C:\Us 5825 6.1 16 UTM8 459192 3964020 459869.2 3965320 08/08/2013 08:03 08/08/2013 08:13C:\Us 6815 7.1 16 UTM8 459284 3964075 459974.6 3965362 08/08/2013 09:47 08/08/2013 09:59C:\Us 7539 7.8 16 UTM8 459299 3963994 460009.7 3965320 08/08/2013 10:00 08/08/2013 10:13C:\Us 7221 7.5 16 UTM8 459294 3964064 460011.3 3965410 08/08/2013 10:15 08/08/2013 10:27C:\Us 7578 7.9 16 UTM8 459326 3964020 460036.9 3965342 08/08/2013 10:29 08/08/2013 10:42

13


Appendix D Sub Bottom Profiler Contacts

Report Malta SBP targets

Generated on 8/14/2013 11:37:08 AM

Target Image Target Info User Entered Info

Contact0000 Dimensions and attributes

● Sonar Time at Target: 8/8/2013 12:10:59

● Target Width: 20 Meters

● Click Position (Lat/Lon Coordinates) ● Target Height: 0 Meters

35.8298949320 14.5537024235

● Target Length: 1 Meters

● Click Position (Projected Coordinates) (X) 459689.93 (Y) 3965173.49

● Target Shadow: 0 Meters

● Mag Anomaly:

● Map Projection: UTM84-33N ● Avoidance Area:

● Acoustic Source File: C:\Malta aug13\20130808130621-1.seg

● Classification1: Unknown

● Classification2: CONF 4

● Ping Number: 2733 ● Area:

● Range to target: 8.19 Meters ● Block:

● Fish Height: 8.02 Meters ● Description: Anomalous feature noted a short distance below the seafloor

● Heading: 0.000 Degrees

● Event Number: 0

● Line Name: 20130808130621-1

● Water Depth: 0.00 Meters

Contact0001 Dimensions and attributes

● Sonar Time at Target: 8/8/2013 11:48:07 AM ● Target Width: 6 Meters

● Click Position (Lat/Lon Coordinates) ● Target Height: 0 Meters

35.8314735855 14.5519137867



● Target Shadow: 0 Meters

● Mag Anomaly:

● Map Projection: UTM84-33N ● Avoidance Area:

● Acoustic Source File: C:\Malta aug13\20130808124314-1.seg

● Classification1: Unknown

● Classification2:

● Ping Number: 2899 ● Area:

● Range to target: 5.81 Meters ● Block:

● Fish Height: 5.05 Meters ● Description: Unknown anomaly

● Heading: 0.000 Degrees

● Event Number: 0

● Line Name: 20130808124314-1


14


Contact0002 Dimensions and attributes ● Sonar Time at Target: 8/8/2013 11:53:26


● Click Position (Lat/Lon Coordinates) ● Target Height: 0 Meters 35.8312900864 14.5521151752



● Target Shadow: 0 Meters ● Mag Anomaly:

● Map Projection: UTM84-33N ● Avoidance Area: ● Acoustic Source File: C:\Malta aug13\20130808125044-1.seg

● Classification1: Possibe substrate horizon ● Classification2: CONF 4

● Ping Number: 1575 ● Area: ● Range to target: 6.92 Meters ● Block:

● Fish Height: 6.29 Meters ● Description: Possible channel substrate hori-zon ● Heading: 0.000 Degrees

● Event Number: 0

● Line Name: 20130808125044-1









● Classification1: Unknown ● Classification2: CONF 4


● Fish Height: 5.00 Meters ● Description: Unknown feature, 0.97m below the surface ● Heading: 0.000 Degrees

● Event Number: 0

● Line Name: 20130808125951-1









● Classification1: Unknown ● Classification2: CONF 4


● Fish Height: 5.05 Meters ● Description: Unknown anomalous feature 0.97m below the surface ● Heading: 0.000 Degrees

● Event Number: 0

● Line Name: 20130808130621-1


15








● Map Projection: UTM84-33N ● Avoidance Area: ● Acoustic Source File: C:\Users\Eoghan\AppData\Local\VirtualStore\20130808100418.seg

● Classification1: Unknown ● Classification2: CONF 4 ● Area:

● Ping Number: 1434 ● Block: ● Range to target: 7.25 Meters ● Description: Unknown feature, possible start of

substrate horizon 0.5m below the current sea-floor surface

● Fish Height: 6.34 Meters ● Heading: 0.000 Degrees

● Event Number: 0

● Line Name: 20130808100418








● Map Projection: UTM84-33N ● Avoidance Area: ● Acoustic Source File: C:\Users\Eoghan\AppData\Local\VirtualStore\20130808110046-1.seg


● Ping Number: 7042 ● Block: ● Range to target: 9.93 Meters ● Description: Small anomalous feature, 0.4 m

below the surface. measuring 10.6m in length ● Fish Height: 9.50 Meters ● Heading: 0.000 Degrees

● Event Number: 0

● Line Name: 20130808110046-1








● Map Projection: UTM84-33N ● Avoidance Area: ● Acoustic Source File: C:\Users\Eoghan\AppData\Local\VirtualStore\20130808111541-1.seg


● Ping Number: 3731 ● Block: ● Range to target: 8.96 Meters ● Description: Unknown anomalous feature

located very claose to the surface and angled into the substrate

● Fish Height: 8.37 Meters ● Heading: 0.000 Degrees

● Event Number: 0

● Line Name: 20130808111541-1


16








● Map Projection: UTM84-33N ● Avoidance Area: ● Acoustic Source File: C:\Users\Eoghan\AppData\Local\VirtualStore\20130808103239.seg


● Ping Number: 4356 ● Block: ● Range to target: 8.62 Meters ● Description: Anomalous target, 0.6m below the

surface ● Fish Height: 7.92 Meters ● Heading: 0.000 Degrees

● Event Number: 0

● Line Name: 20130808103239


Sub Bottom Profiler Contacts TargetName Cl ickLat Cl ickLon Cl ickX Cl ickY

Contact0000 35,829,894,931,979 145,537,024,235,243 459,689,926,299,651 396,517,348,559,358

Contact0001 358,314,735,854,559 145,519,137,867,044 459,529,175,276,431 396,534,931,622,133

Contact0002 358,312,900,864,005 14,552,115,175,181 459,547,271,519,754 396,532,888,061,174

Contact0003 358,321,075,848,782 145,521,373,552,727 459,549,689,739,524 396,541,954,230,752

Contact0004 358,320,763,090,451 145,523,104,749,411 459,565,309,892,441 396,541,600,188,634

Contact0005 358,282,778,916,411 145,508,576,861,575 459,432,161,913,156 396,499,531,089,447

Contact0006 35,820,158,207,606 145,567,474,143,903 459,960,064,773,599 396,409,231,200,082

Contact0007 358,260,677,788,642 145,531,724,309,351 459,640,118,730,832 396,474,922,486,647

Contact0008 358,244,210,104,707 145,535,791,702,611 459,676,024,884,336 396,456,641,011,498

17


Appendix E

Contents of CD-ROM accompanying this report

1) Geo-Tiff Folder – files related to geo-referenced image of remote sensing pro-

ject – files useable on GIS suites such as Mapinfo, ARCGIS etc. 2) Images Folder - files used to illustrate the desk-based study.

3) Mag Folder – files that make up data set of magnetometer survey. 4) SBP Folder – files that make up data set of SBP survey including files for au-

tocad.

18

AN ECOLOGICAL APPRAISAL OF AN AREA AT DELIMARA, MALTA,

PROPOSED FOR THE CONSTRUCTION OF A COMBINED-CYCLE GAS TURBINE AND OF

LIQUEFIED NATURAL GAS FACILITIES: SURVEY OF ECOLOGICAL RESOURCES

Prepared by

Sandro Lanfranco BEd(Hons), MSc(Biol), PhD

and

Louis F Cassar CBiol, MIBiol, p-g Dip Env Mgt, MSc (Env Plan & Mgt), PhD (Reading)

Independent Consultants

Logistic Support:


Malta

Telephone: (+356) 2143 1900 Fax: (+356) 21424 137


ECOSERV REPORT REFERENCE : 109-13_R

Revised version (28 October 2013) of report dated July 2013


Contents 1 Introduction .............................................................................................................................. 4

1.1 General .............................................................................................................................. 4

1.2 Terms of reference ............................................................................................................. 4

1.3 Description of the proposed development ......................................................................... 5

2 Description of the AoS and its environment ............................................................................... 6

2.1 Location ............................................................................................................................. 6

2.2 Geomorphological context of the AoS ................................................................................ 6

2.3 General description of land cover ....................................................................................... 7

3 Methods .................................................................................................................................. 10

3.1 Characterisation of ecological units .................................................................................. 10

3.2 Assessment of plant communities .................................................................................... 10

3.3 Habitats and biota ............................................................................................................ 10

4 Vegetation Assemblages .......................................................................................................... 11

4.1 NW sector of the AoS ....................................................................................................... 13

4.2 Southern sector of the AoS............................................................................................... 13

4.3 Plantation ........................................................................................................................ 14

4.4 Agricultural areas ............................................................................................................. 15

4.5 Rupestral habitats ............................................................................................................ 16

5 General ecological evaluation .................................................................................................. 17

6 Policy context (terrestrial ecological resource) ......................................................................... 17

6.1 General policies................................................................................................................ 17

6.2 Policies concerning species .............................................................................................. 18

6.3 Policies concerning structures within the AoS................................................................... 19

7 Evaluation of potential ecological impact of the proposed development.................................. 21

7.1 General ............................................................................................................................ 21

7.2 Identification of project actions ........................................................................................ 21

7.3 Prediction of probable ecological impact .......................................................................... 21

7.4 Mitigation of environmental impact ................................................................................. 21

7.5 Project actions ................................................................................................................. 22

7.5.1 Relevant project actions during construction phase .................................................. 22

7.5.2 Relevant project actions during operational phase ................................................... 22

7.5.3 Relevant project actions during decommissioning .................................................... 22

7.6 Project action 1: Excavation, Stabilisation and Construction works in the the CCGT site and RGF site ....................................................................................................................................... 22

7.6.1 Predicted impact: obliteration of biological communities ......................................... 22

7.6.2 Predicted impact: disturbance arising from noise and vibration ................................ 23

7.6.3 Predicted impact: effects of windblown limestone dust on habitats and biota .......... 23

7.7 Project action 2a: Storage of excavated material .............................................................. 24

7.7.1 Predicted impact: obliteration of biological communities in possible storage sites .... 24

7.7.2 Predicted impact: redistribution of particulates ........................................................ 25

7.7.3 Predicted impact: proliferation of ruderal species .................................................... 25

7.7.4 Predicted impact: degradation of biological communities due to leakages................ 26

7.8 Project action 2b: Storage of construction materials, waste materials and possible contaminants .............................................................................................................................. 26

7.8.1 Predicted impact: degradation of biological communities due to leakages................ 26

7.9 Project action 3: Site illumination during the night ........................................................... 27

7.9.1 Predicted impact: disturbance of susceptible fauna .................................................. 27

7.10 Project action 4: Emission of primary and secondary pollutants ....................................... 27

7.10.1 Predicted impact: possible damage to vegetation ..................................................... 27

7.11 Project action 5: Storage of fuels and possible contaminants ........................................... 28

7.12 Project Action 6: Release of potential contaminants during dismantling ........................... 28

7.13 Project Action 7: Storage of waste materials and contaminants ....................................... 28

8 References ............................................................................................................................... 28

9 Appendix 1 .............................................................................................................................. 30

9.1.1 Key to Red Data Book categories .............................................................................. 30

9.1.2 Scope of categories .................................................................................................. 30

10 Appendix 2........................................................................................................................... 31

10.1.1 Schedules listed in Legal Notice 200 of 2011: Trees and Woodlands Protection Regulations .............................................................................................................................. 31

11 Appendix 3........................................................................................................................... 32

11.1.1 Schedules listed in Legal Notice 311 of 2006: Flora, Fauna and Natural Habitats Protection Regulations, 2006. .................................................................................................. 32

1 Introduction

1.1 General The present report has been commissioned by ERSLI Consultants and forms part of an Environmental Impact Assessment concerning the proposed construction of a Combined Cycle Gas Turbine (CCGT) associated with facilities for receiving, storing and regasification of Liquefied Natural Gas (LNG). The proposed development will be situated on land adjacent to the existing Delimara Power Station (DPS) facilities, within the boundary of the Power Station Complex.

1.2 Terms of reference The final version of the Terms of Reference (ToR) for this assessment, dated June 2013, was provided to ERSLI Ltd by the Malta Environment and Planning Authority (MEPA) on 10th July 20131. The present report addresses part of the ‘Terrestrial Ecology’ component of the ToR (Section 3.5 of the ToR), part of the ‘Assessment of Environmental Impacts and Environmental Risks’ component (Section 4), and part of the ‘Required measures, Identification of residual impacts, and Monitoring Programme’ component (Section 5). The ToR (Note 10, p.1) stated the following:

“Wherever any baseline studies required by these Terms of Reference are covered by already-existing data, such data should be used in preference to unnecessary duplication of baseline studies, unless the consultants or MEPA or both are of the opinion that the existing data is unavailable, incorrect, outdated, unreliable, insufficient, or otherwise inadequate for the purpose of the EIA.”

The most recent baseline studies in the area were those undertaken by AIS Environmental Ltd (2009) in the general area of the DPS, as part of the Environmental Impact Statement for planning application PA3152-05. Those studies did not include information on the terrestrial ecological resources in the DPS site and its environs, and fresh baseline studies were therefore proposed by Ecoserv to obtain the information required to fulfil the ToR.

The ToR (Section 3.5(1)) also specified that any studies concerning terrestrial ecological resources were to be multi-seasonal. The short timeframe within which this study was to be carried out restricted studies on ecological resources to the dry season. This constraint implies that species that were undetectable during the dry season would have been omitted from the results of this report.

The proposed contribution of Ecoserv to these studies was described in a method statement sent to MEPA on 14th June 2013. This method statement was based on draft ToR published by MEPA in April 2013 (the final version of the ToR was not yet available at the time). The method statement proposed an Area of Study (AoS) within which a dry season survey of terrestrial ecological resources would be carried out (Figure 4). The Method Statement, including the proposed AoS, was approved by MEPA on 16th June 20132.

The ToR that this report is based on may be summarised as follows:

1 Email from Dr Paul Gauci, ERSLI Consultants Ltd, to Ecoserv; dated 11 July 2013.

2 Email from Ecoserv to present consultants; dated 16 June 2013.

1. An investigation of the ecology of the site and its surroundings (represented by the AoS); 2. Reporting on the conservation status and ecological condition of the area and on the state of

health of its habitats, species and ecological features; 3. Reporting of all protected, endangered, rare, unique, endemic, high-quality, keystone,

invasive/deleterious, or otherwise important species, habitats, ecological assemblages, and ecological conditions found in the AoS;

4. Prediction of the magnitude and significance of ecological impact on the habitats and species referred to above;

5. Identification of possible mitigation measures that may reduce the intensity and extent of impact on the habitats and species referred to above;

6. Prediction of any residual impact on the habitats and species referred to above.

1.3 Description of the proposed development The configuration of the proposed development was communicated to the present consultants on 11th October 20133. The proposed development comprises the construction of a CCGT power plant and Regasification Facility, with proposed footprints of 31000m2 and 995m2 respectively, within the area occupied by the DPS Complex (Figure 1). The development will also comprise an offshore Fuel Storage Unit.

3 Email from Dr Paul Gauci, ERSLI Consultants Ltd, to Ecoserv; dated 11 October 2013

Figure 1: Plan of the proposed CCGT power plant, Regasification Facility and offshore Fuel Storage Unit. (Image source: Innovative Architectural Structures)

2 Description of the AoS and its environment

2.1 Location The AoS (Figure 4) comprises land situated along the south-eastern coast of Malta, on the Delimara peninsula (approximate UTM grid reference of centre of area: 4598673965475) along the eastern shore of Marsaxlokk Bay (Figure 2, Figure 3). The longest axes of length and breadth are approximately 1400m and 350m respectively. Much of the AoS is taken up by the DPS complex.

2.2 Geomorphological context of the AoS The following description of the geological and geomorphological features of the AoS draws on the Geological Map of the Maltese Islands (Oil Exploration Directorate, 1993).

The AoS is situated on a west-facing slope, representing the eastern shore of Marsaxlokk Bay (Figure 5). Much of the area occupied by the DPS complex consists of remodelled and reclaimed land that was formed in the early 1990s during the construction phase of the complex. The shoreline fringe of the AoS outcrops on the Middle Globigerina Limestone (MGL) member of the Globigerina Limestone formation, and erodes to give steep coastal cliffs overlooking a boulder beach. A substantial portion of the MGL recorded in the Geological map of the Maltese Islands (Oil Exploration Directorate, 1993) was excavated to accommodate the DPS complex. This excavation has formed a fresh cliff-face

extending along much of the western boundary of the complex and which has undergone natural colonisation by rupestral vegetation. Inland portions of the AoS, including those outside the complex, outcrop on Upper Globigerina Limestone (UGL), which is mostly obscured by a consistent soil cover. A fault striking along the boundary between the MGL and UGL extends throughout the AoS in an approximate north-south direction.

2.3 General description of land cover The central part of the AoS was occupied by the DPS complex. Much of the northern and southern sectors were characterised by agricultural areas, largely under cultivation, whilst the southern sector also comprised a tract of land that may have been subject to rudimentary afforestation attempts in the past, through the practice of mixed plantation, and that was undergoing secondary ecological succession at the time of survey. The uncultivated slopes separating agricultural terraces from other terraces at different elevations were generally colonised by localised shrub formations, broadly characteristic of maritime steppe/garrigue, and, more specifically, by elements of the Maltese Rdum Community. Natural vegetation in the northern part of the AoS mainly comprised herbaceous forms consistent with grass-steppe and ruderal/segetal communities along field margins. A number of trees, presumably representing deliberate introductions along field margins, were also noted. Areas subject to large-amplitude disturbance were noted within the boundary of the DPS complex. Such areas were generally colonised by ruderal species.

Figure 2: Location of the Delimara peninsula in Malta, indicated by the area shaded in yellow. (Base image source: Google Earth, 2013)

Figure 3: The Delimara peninsula, showing the location of the DPS complex, indicated by the yellow border. (Base image source: Google Earth, 2013)

Figure 4: Extent of the Area of Study (AoS) for terrestrial ecological resources as approved by MEPA. The AoS consists of the area enclosed by the yellow outline and by the coastal fringe along the western shore of the Delimara peninsula. (Base image source: Google Earth, 2013)

Figure 5: Portion of the ‘Geological map of the Maltese Islands’ showing surface outcrops in the Delimara peninsula; Mmg indicates Middle Globigerina Limestone and Mug indicates Upper Globigerina Limestone. (Oil Exploration Division, 1993)

3 Methods

3.1 Characterisation of ecological units This study is based on site visits made by the authors during June and July 2013 and is supplemented by material from the literature and the consultants’ previous knowledge of the study area and its environs. Habitats were characterised on the basis of geomorphological features and plant assemblages as outlined in Schembri (1991) and modified by Schembri et al. (1999). Nomenclature of plant communities follows the Palaearctic Habitat Classification system (Devillers & Devillers-Terschuren, 1996).

This report comprises lists of plant species covered by local legislation or by that of the European Union. The designation RDB refers to the Red Data Book status of species recorded (Schembri & Sultana, 1989); the designation LN 311/2006 refers to the status of species recorded in terms of Legal Notice 311 of 2006 and the Schedule or Schedules within which the species are listed. The designation “Trees and Woodlands” refers to the status of the species in the context of Legal Notice 200 of 2011 (Trees and Woodlands Protection Regulations). Descriptions of Red Data Book Categories and the Schedules listed in LN 311/2006 and LN 200/2011 are given in Appendices 1- 3.

3.2 Assessment of plant communities Assessment of the plant communities within the area of study was carried out through a straightforward census of species in a vegetative, flowering or fruiting stage. The species inventory comprises remarks on community affiliation and legislative context for each species listed. This inventory obviously omitted all species that were not at the vegetative, flowering or fruiting stages of their life cycle at the time of survey. The presence of a number of species that were not vegetative at the time of survey was inferred through observation of fruits and withered aerial parts. Identification of vegetation was carried out in the field by the authors. Voucher specimens of forms that were not identified in situ were collected or photographed and compared with descriptions in literature and with reference material.

3.3 Habitats and biota Habitats and biotic assemblages noted during the field surveys were mapped on a base survey sheet. It should be remarked that there is no clear-cut delineation between adjacent habitats or assemblages. The habitats map, although accurate, should therefore be treated as indicative of the extent of the units identified. In the present study, the breadth of ecotones4 should be considered as narrow compared to the extent of the habitat/assemblage.

4 An ecotone is the area between two adjacent and different types of vegetational units, which may share the characteristics of both.

4 Vegetation Assemblages The vegetation assemblages identified in the AoS are described below. The headings describing each assemblage correspond to legend codes in the accompanying biotope/vegetation map (Figure 6).

Figure 6: Biotopes map (to be replaced by digitised version)

4.1 NW sector of the AoS This sector of the AoS is proposed for the construction of the CCGT plant (Figure 1). The perimeter of this site was landscaped and comprised hedges of shrubs and small trees, planted for embellishment purposes. Ruderal species occupied gaps in and around these hedges. A concrete gutter along the perimeter of the area harboured species that were not found in other parts of this area. The hedges in this area mainly comprised Lantana (Lantana camara), Oleander (Nerium oleander) and Shrubby Orache (Atriplex halimus). The eastern perimeter of the area was characterised by a tree border comprising Tamarisk (Tamarix sp.) [Trees & Woodlands: II], White Popinac (Leucaena leucocephala) [Trees & Woodlands: III], Pittosporum (Pittosporum tobira) [Trees & Woodlands: III], Carob (Ceratonia siliqua) [Trees & Woodlands: II] and Olive (Olea europaea s.l.) [Trees & Woodlands: II ]5. Gaps were generally colonised by ruderal species including extensive tracts occupied by Rice Grass (Piptatherum miliaceum), Southern Aster (Aster squamatus), Bermuda Grass (Cynodon dactylon) and Pine Spurge (Euphorbia pinea). A number of species characteristic of the late-pioneer stages of secondary succession, including Fennel (Foeniculum vulgare) and Sticky Fleabane (Dittrichia viscosa) were also recorded from these areas. The concrete gutter, presumably providing a seasonally-wetter habitat than the other parts of this area, was colonised by Smooth-leaved Saltwort (Salsola soda), a possible remnant of the community that occurred in the environs prior to the extensive development of the DPS in the late 1980s.

Species of ‘positive’ or ‘negative’ conservation significance recorded from this area included the following:

Species Vernacular LN

311/2006 Trees &

Woodlands RDB

status

Ceratonia siliqua Carob Schedule II

Leucaena leucocephala White Popinac Schedule III

Olea europaea s.l. Olive Schedule II

Pittosporum tobira Pittosporum Schedule III

Tamarix sp. Tamarisk Schedule II

4.2 Southern sector of the AoS This sector of the AoS is proposed for the construction of the regasification facility (Figure 1). The southern sector of the AoS that was within the boundary of the DPS, was characterised by a mound of largely unconsolidated limestone debris on which a primary ecological succession was proceeding. Much of the vegetation on the mound comprised ruderal species characteristic of the early-pioneer and late-pioneer stages of ecological succession in agricultural and coastal areas. Such species included Rice Grass (Piptatherum miliaceum), Yellow Mustard (Diplotaxis tenuifolia), Boar Thistle

5 Although Olive (Olea europaea) is listed as ‘Rest (MI)?’ in the RDB, these designations only apply to Wild Olive, not to cultivated specimens.

(Galactites tomentosa), Common Golden Thistle (Scolymus hispanicus), Fennel (Foeniculum vulgare), Sticky Fleabane (Dittrichia viscosa), Fat Hen (Chenopodium album), Tree Mallow (Malva dendropomorpha), Sicilian Snapdragon (Antirrhinum siculum) and Yellow Horned-Poppy (Glaucium flavum). Parts of the mound were colonised by slower-growing shrubs characteristic of later seral stages, including Maltese Salt-Tree (Darniella melitensis) [LN 311/2006: Regl.26; RDB: Endemic] and Eastern Phagnalon (Phagnalon graecum subsp. ginzbergeri) [RDB: Rest (MED)]. Larger phanerophytes, including Blue-Leaved Wattle (Acacia cyanophylla) [Trees & Woodlands: III] and Tree Tobacco (Nicotiana glauca) were also noted. The species composition of the assemblage colonising the mound is presumably the result of dispersal of propagules from adjacent agricultural, coastal and rupestral habitats, and also the result of species being introduced into the site when excavated and loose soil was brought into the site to shape the existing mound, forming a hybrid community comprising representatives of the pioneer stages of each of these habitats.

The area surrounding the base of the mound was colonised by an assemblage comprising species characteristic of secondary succession, including Sticky Fleabane (Dittrichia viscosa), associated with scattered patches of plants of coastal areas and of saline marshlands. Such species included Three-horned Stock (Matthiola tricuspidata), Lesser Crystal Plant (Mesembryanthemum nodiflorum), Sea Fennel (Crithmum maritimum), Smooth-leaved Saltwort (Salsola soda) and Prickly Saltwort (Kali soda). This assemblage was presumably formed through a regular influx of propagules from nearby areas, including the saltmarsh at Il-Ballut ta’Marsaxlokk and the rocky coastal areas to the south of the DPS complex.


Species Vernacular name

LN 311/2006

Trees & Woodlands

RDB status

Acacia cyanophylla Blue-Leaved

Wattle

Schedule III

Darniella melitensis Maltese Salt-

Tree Regl.26

Endemic

Phagnalon graecum subsp. ginzbergeri

Eastern Phagnalon

Rest (MED)

4.3 Plantation A portion of the southern sector of the AoS was characterised by a tract of land that was labelled as ‘Woodland, Trees and Shrubs’ in AIS Environmental Ltd (2009). At the time of survey, the area was undergoing secondary ecological succession and was colonised by an assemblage of species derived from various episodes in the recent ecological history of the area. A number of derelict dry stone walls (rubble walls) and consistent soil cover suggest that the area was cultivated in the past. The area has been subject to a rudimentary and piecemeal afforestation, and comprised various species, including Blue-Leaved Wattle (Acacia cyanophylla) [Trees & Woodlands: III], Date Palm (Phoenix

dactylifera) [Trees & Woodlands: II], Oleander (Nerium oleander) and Tamarisk (Tamarix sp.) [Trees & Woodlands: II], that may represent introductions for this purpose. Early-pioneer species characteristic of derelict agricultural areas, including Yellow Mustard (Diplotaxis tenuifolia), Crisped St John’s Wort (Hypericum triquetrifolium), Wild Oats (Avena sterilis) and Galactites tomentosa, were noted throughout the area. These were associated with later colonists of such habitats, including Spiny Asparagus (Asparagus aphyllus), Caper (Capparis orientalis) [LN 311/2006: VIII(b)], Silvery Ragwort (Jacobaea maritima subsp. sicula) [LN 311/2006: Regl.26], Sea Squill (Drimia maritima) [LN 311/2006: VIII(b), X(b); RDB: Rest (MED)], Clustered Carline Thistle (Carlina involucrata) [RDB: Rest (MED)], Fennel (Foeniculum vulgare) and Sticky Fleabane (Dittrichia viscosa). Inclusions from the presumed original maritime community included Maltese Salt-Tree (Darniella melitensis) [LN 311/2006: Regl.26; RDB: Endemic], Golden Samphire (Inula crithmoides), Shrubby Orache (Atriplex halimus), Common Golden Thistle (Scolymus hispanicus), Yellow Horned-Poppy (Glaucium flavum) and Shrubby Seablite (Suaeda vera). The lower parts of the slope, closer to the shore, were colonised by patches of Tree mallow (Lavatera arborea).



LN 311/2006

Trees & Woodlands

RDB status

Acacia cyanophylla Blue-Leaved

Wattle Schedule III

Capparis orientalis Caper Schedule VIII(b)

Carlina involucrata Carline Thistle Rest (MED)


Tree Regl. 26

Endemic

Drimia maritima Sea Squill Schedule VIII (b)

Schedule X (b)

Rest (MED)

Jacobaea maritima subsp. sicula Silvery Ragwort Regl.26

Phoenix dactylifera Date Palm Schedule II

Tamarix sp. Tamarisk Schedule II

4.4 Agricultural areas Much of the land cover within the AoS consisted of agricultural areas most of which were subject to recent cultivation but which were bare at the time of survey. The field margins and field areas were generally colonized by ruderal species, with higher diversity being recorded from agricultural

margins as a consequence of the greater stability of this habitat. Ruderal species colonising the areas utilised for cultivation included Crisped St John’s Wort (Hypericum triquetrifolium), Yellow Mustard (Diplotaxis tenuifolia) and Field Bindweed (Convolvulus arvensis). Assemblages along field margins comprised Rice Grass (Piptatherum miliaceum), Crown Daisy (Glebionis coronaria), Wild Oats (Avena sterilis), Wild Barley (Horedum sp.), Boar Thistle (Galactites tomentosa) and inclusions from adjacent maritime communities including Golden Samphire (Inula crithmoides), Maltese Salt-Tree (Darniella melitensis) [LN 311/2006: Regl.26; RDB: Endemic], Shrubby Orache (Atriplex halimus) and Shrubby Seablite (Suaeda vera). A number of agricultural areas, particularly in the northern sector of the AoS, were bordered by margins of trees, presumably introduced form embellishment or for economic purposes. Such trees included Olive (Olea europaea s.l.) [Trees & Woodlands: II], Eucalypts (Eucalyptus camaldulensis) [Trees & Woodlands: III] and Aleppo Pine (Pinus halepensis) [Trees & Woodlands: II].

Species of ‘positive’ or ‘negative’ conservation significance recorded from these areas included the following:


LN 311/2006

Trees & Woodlands

RDB status


Tree Regl.26

Endemic

Olea europaea s.l. Olive Schedule II Rest (MI)?

Eucalyptus camaldulensis Eucalypt Schedule III

Pinus halepensis Aleppo Pine Schedule II

4.5 Rupestral habitats The coastal fringes in the southern sector of the AoS and the inland perimeter of the DPS complex were characterised by steep cliffs of Middle Globigerina Limestone. The dominant shrub colonising these cliff faces, in terms of biomass and abundance, was Maltese Salt-Tree (Darniella melitensis) [LN 311/2006: Regl.26; RDB: Endemic]. Other plants recorded from these communities included species generally associated with marly slopes (Blue Clay taluses and associated slopes), such as Esparto Grass (Lygeum spartum). Shallower slopes, particularly on the inland cliff faces, were colonised by Rice Grass (Piptatherum miliaceum). Narrow ledges along the cliff face were colonised by Sea Squill (Drimia maritima) [LN 311/2006: VIII(b), X(b); RDB: Rest (MED)], Branched Asphodel (Asphodelus aestivus), Wild Carrot (Daucus carota) and Spiny Asparagus (Asparagus aphyllus).



LN 311/2006

Trees & Woodlands

RDB status


Tree Regl.26 Endemic

Drimia maritima Seaside Squill

Schedule VIII (b)

Schedule X (b)

Rest (MED)

5 General ecological evaluation The AoS comprises three distinct ecological units, all of which represent different stages in the recolonisation of former agricultural areas by natural communities.

(1) The agricultural areas in the AoS have been subject to recent cultivation and, as such, are colonised by herbaceous ruderal species that may generally be considered as ‘weeds’ of agriculture exploiting the recently-released habitat-space. The margins of agricultural land provide corridors for dispersal and have been colonised by species characteristic of greater ecological stability. The presence of rubble wall remnants in the southern portions of the AoS suggests that these areas were also cultivated in the past.

(2) Vertical faces in the AoS were all colonised by a rupestral community dominated by Maltese Salt Tree (Darniella melitensis). The composition of these rupestral assemblages was similar across the AoS and there was little detectable difference in community composition between ‘recent’ and ‘non-recent’ cliff faces. ‘Recent’ cliff faces are defined as those that were exposed following excavation works to accommodate the DPS whilst ‘non-recent’ cliff-faces are those that have been available for colonisation for much longer periods of time. The relatively homogenous community composition across cliff-faces of different ages suggests that the time required to achieve a local climax in these habitats is less than 25 years.

(3) The species composition of the ‘Plantation’ in the southern sector of the AoS suggests a complex ecological history. The area is characterised by remnants of segetal communities from agricultural areas, various trees and large shrubs that were presumably introduced for embellishment, and species characteristic of early-pioneer and late-pioneer stages of secondary ecological succession. The lower parts of the slopes, closer to the shoreline, were characterised by ruderals characteristic of coastal communities.

6 Policy context (terrestrial ecological resource) The ecological significance of the site under investigation has been determined in accordance with the policies of the Structure Plan for the Maltese Islands (Malta Structure Plan, 1992a, Malta Structure Plan, 1992b), the Marsaxlokk Bay Local Plan (MEPA, 1995), henceforth referred to as the MBLP, and relevant legal notices.

6.1 General policies 1. The AoS is not part of a Special Area of Conservation in terms of Malta Government Legal

Notice 859 of 2008 and in accordance with the provisions of the Flora, Fauna and Natural

Habitats Protection Regulations 2006 (Legal Notice 311 of 2006) and is also not part of the Natura 2000 network6.

2. The AoS is not situated within a Special Protection Area in terms of Government Notice 112 of 2007 or subsequent Government Notices, and in accordance with the provisions of Flora, Fauna and Natural Habitats Protection Regulations 20067.

3. Part of the AoS is within the ‘Rdum mid-Dahla ta' San Tumas sa Is-Sarc’ Area of Ecological

Importance (site code: MALT_006) in terms of MBLP policy ME01 and Malta Government Notice 400/96 (Figure 7). The southern sector of the AoS has been designated a Level 2 AEI and the central and northern portions have been designated as a Level 3 AEI.

4. The portion of the AoS that is within an AEI is also a Rural Conservation Area in terms of

MBLP policy ME02.

6.2 Policies concerning species

1. Sea Squill (Drimia maritima =Urginea pancration) and Caper (Capparis orientalis) are listed in Schedule VIII (Animal and plant species of national interest whose taking in the wild and exploitation may be subject to management measures) of the Flora, Fauna and Natural Habitats Protection Regulations, 2006.

2. Any endemic species occurring within the AoS are protected species in terms of Regulation

26 of the Flora, Fauna and Natural Habitats Protection Regulations, 2006 and therefore cannot be deliberately picked, collected, cut, uprooted, destroyed, pursued, taken, damaged, captured, or killed. Note that as defined by these regulations, ‘endemic’ refers not only to those species that occur solely within the Maltese archipelago, but includes all species whose native distribution range is limited to the Central Mediterranean region where ‘Central Mediterranean’ is taken to include Southern Italy (all Italian territory south of Florence), Sardinia, Corsica, Sicily and circum-Sicilian islands (including Pantelleria and the Pelagian Islands), the Maltese Islands, Tunisia and islands off Tunisia. Moreover, ‘endemic species’ also includes possibly endemic species whose taxonomic status or identity requires further analysis. Regulation 26 does not apply to those endemic species listed in Schedule X of the Flora, Fauna and Natural Habitats Protection Regulations, 2006. In practical terms, Regulation 26 applies to most of the species listed as either ‘Endemic’ or ‘Rest (Med)’ in this report, with the exception of Sea Squill (Drimia maritima =Urginea pancration).

3. A number of trees present within the AoS are protected under the Trees and Woodlands Protection Regulations, 20118. Tamarisk (Tamarix spp.), Olive (Olea europaea s.l.) and the

6 Natura 2000 is an ecological network in the territory of the European Union with the ‘Habitats Directive’ and the ‘Birds Directive’ as its basis and is intended to protect the most seriously threatened habitats and species across Europe. The Birds Directive requires the establishment of Special Protection Areas (SPAs) for birds whilst the Habitats Directive requires Special Areas of Conservation (SACs) to be designated for other species, and for habitats. Together, SPAs and SACs make up the Natura 2000 sites. The Natura 2000 network contributes to the "Emerald network" of Areas of Special Conservation Interest (ASCIs) set up under the Bern Convention on the conservation of European wildlife and natural habitats.

7 Legal Notice 311 of 2006

Carob (Ceratonia siliqua) are listed in Schedule II (Trees Protected in Selected Areas). No parts of the AoS are listed as ‘Tree Protection Areas’ in terms of Government Notice 473 of 2011.

4. In addition to the protected species listed above, other species of conservation importance

that occur within the AoS include all the Red Data Book listed species enumerated in this report, even if not threatened (‘threatened’ refers to RDB categories ‘Endangered’ and ‘Vulnerable’).

5. A number fo trees recorded from the AoS are listed in Schedule III (Invasive, Alien or Environmentally-Incompatible Species) of the Trees and Woodlands Protection Regulations, 2011. These included White Popinac (Leucaena leucocephala), Pittosporum (Pittosporum tobira), Blue-Leaved Wattle (Acacia cyanophylla) and Eucalypt (Eucalyptus camaldulensis). .

6.3 Policies concerning structures within the AoS The rubble walls and rural structures present within the AoS are subject to the Rubble Walls and Rural Structures (Conservation and Maintenance) Regulations 19979.

8 Legal Notice 200 of 2011.

9 Legal Notice 160 of 1997.

Figure 7: Designation of Area of Ecological Importance (AEI) at Delimara Peninsula. (Source: Malta Government Notice 400/96).

7 Evaluation of potential ecological impact of the proposed development

7.1 General Evaluation of probable environmental impact of the proposed development involved the following stages:

• Identification of relevant project actions that may potentially impact the ecological resource; • Prediction of probable ecological impact of each project action; • Suggestion of measures for mitigation of such impact.

7.2 Identification of project actions A general description of the works involved in the proposed development was communicated to Ecoserv on 3rd June 2013 in a Project Description Statement (Enemalta Corporation, 2013). Further details concerning procedures envisaged during the construction phase were communicated by ERSLI Consultants to Ecoserv through email on 4th July 2013. The general project actions envisaged during the construction phase of the proposed project were derived from the information in these documents. A document, titled ‘Construction Phase Information’, giving details of the processes involved during the construction phase of the proposed development was subsequently made available to present consultants on 22 July 201310.

7.3 Prediction of probable ecological impact Prediction of the general ecological impact of the proposed development on the ecological resources within the AoS and its environs was carried out by comparing the expected magnitude of the project actions with the known or inferred ecological and physiological tolerances of the ecological receptors that would presumably be influenced by such actions. The assessment of probable ecological impact presented here is general and qualitative. More accurate prediction of environmental impact would necessitate extensive experimental work on the ecological responses of the species concerned and establishment of a mathematical model linking cause with effect. It should be remarked that responses of biota to environmental change are only broadly predictable since they involve the interaction of myriad biotic and abiotic factors, many of which are effectively stochastic on short time scales. The present discussion is therefore based on the consultants’ previous experience of responses of individual species, assemblages and habitats to different stimuli and conditions, and interpretation of the relevant literature.

7.4 Mitigation of environmental impact Measures for the mitigation of predicted environmental impact proposed by the present consultants are based on proposals listed in the Project Description Statement (Enemalta Corporation, 2013) and on the consultants’ previous experience of the application of mitigation measures in comparable contexts.

10 Document communicated to Ecoserv by ERSLI Consultants Ltd through email on 22 July 2013.

7.5 Project actions

7.5.1 Relevant project actions during construction phase The general processes envisaged during the construction phase of the proposed project are the following:

1. Project Action 1: Excavation, Stabilisation and Construction works a. Stabilisation works in the sites proposed for the construction of the CCGT plant

(henceforth referred to as ‘CCGT site’) and of the regasification facility (henceforth referred to as ‘RGF site’);

b. Possible displacement of unconsolidated material in RGF site; c. Construction of the CCGT shed; d. Trenching works;

2. Project Action 2: Storage of materials a. Storage of excavated material; b. Storage of construction materials and possible contaminants;

3. Project Action 3: Site illumination during the night.

7.5.2 Relevant project actions during operational phase 1. Project Action 4: Emission of primary and secondary pollutants; 2. Project Action 5: Storage of fuels and possible contaminants.

7.5.3 Relevant project actions during decommissioning 1. Project Action 6: Release of potential contaminants during dismantling; 2. Project Action 7: Storage of waste materials and contaminants.

7.6 Project action 1: Excavation, Stabilisation and Construction works in the CCGT site and RGF site

7.6.1 Predicted impact: obliteration of biological communities Excavation, stabilisation and construction works in the CCGT site and the RGF site (Figure 1) would be expected to degrade or obliterate all habitats and sessile biota in these areas and lead to the displacement of vagile fauna from the affected areas and their vicinity.

7.6.1.1 Receptors Sensitive biological receptors are the floral and faunal assemblages colonising these parts of the AoS and their immediate environs. These areas represent land that was reclaimed during the construction of the DPS complex. As such, the species in these areas consist of ruderals infiltrating ornamental assemblages in the CCGT site, and ruderals colonising a recently-established and highly disturbed habitat in the RGF site. The plants that will be directly affected by modification of habitat in these areas therefore include introduced species, species associated with disturbed habitats and species representing the pioneer stages of secondary ecological succession. There were no plant species of conservation concern in the CCGT site and its immediate environs whilst the unconsolidated mound adjacent to the RGF site was colonised by two species of positive conservation significance: Maltese Salt-Tree (Darniella melitensis) [RDB: Endemic] and Eastern Phagnalon (Phagnalon graecum subsp. ginzbergeri) [RDB: Rest (MED)]. The RGF site also represents

a potential habitat for reptiles and small mammals (and other animals) and removal or disturbance of the mound will displace or eradicate any such populations.

7.6.1.2 Proposed mitigation measures None.

7.6.2 Predicted impact: disturbance arising from noise and vibration Excavation, stabilisation and construction works are expected to generate considerable ground-borne vibration that will affect a wide area, well beyond the boundaries of the AoS, since vibrations propagate for long distances in a relatively dense medium such as rock. These activities would also be expected to generate considerable noise pollution. Noise and vibration are likely to disturb birds, bats and small mammals and may cause these to relocate from the AoS and from adjacent areas.

7.6.2.1 Receptors All faunal assemblages within the AoS and its immediate environs for noise; all faunal assemblages within the AoS and a considerable radius around it for vibrations.

7.6.2.2 Proposed mitigation measures Use of damping mechanisms to reduce effects of vibrations.

7.6.3 Predicted impact: effects of windblown limestone dust on habitats and biota Excavation and stabilisation works would be expected to generate fine particulates that are subject to transport by wind, by surface runoff following rainfall and by downslope slumping when these activities take place on sloping ground. Fine material stored in stockpiles can be subject to entrainment at wind speeds in excess of about 5 ms-1 (Ministry for the Environment, New Zealand, 2001) which, in the Maltese Islands, are most likely to blow from the northwest or west11. The direction of travel of windborne particulate is dependent on the time of year during which excavation is carried out. Windborne particulate emissions would enter adjacent habitats and may result in increased soil alkalinity. This factor is biologically-significant since pH level influences the solubility of various nutrients and the rate at which they are absorbed by vegetation. Increased fallout of particulates may coat the photosynthetic organs of plants leading to reduced incidence of light on these surfaces, with subsequent reductions in efficiency of photosynthesis, transpiration and thermoregulation (Farmer, 1993, Vardaka et al., 1995). Abrasion of exposed plant surfaces is another impact that may be attributable to fallout of dust. Increased incidence of plant pests and diseases may also be a consequence of heavy dust loading on plants since dust deposits can act as a medium for the growth of fungal diseases (Ministry for the Environment, New Zealand, 2001). Deposits of dust on animals, particularly sedentary and slow-moving species may interfere with their biological functions as well as render their microhabitats unsuitable, depending on how heavy particulate deposition is. Particulates entering the soil may have a very long residence time;

11 Chetcuti et al. (1992) and Galdies (2011) suggest that the prevailing wind in the Maltese Islands, as a whole, is northwesterly.

however, given the high limestone content of local soils, the addition of limestone dust to soil is not expected to exert any significant effects.

7.6.3.1 Receptors Sensitive biological receptors are the floral and faunal assemblages within the AoS and its environs. Assemblages outside the AoS but within range of windborne particulate would also be affected, although to a lesser extent, as clouds of dust would be subject to dispersion with distance and would be expected to have lost coarser fractions through earlier fallout. The direction of travel of windborne particulate is dependent on the time of year during which excavation is carried out. Particulate generated during the wet-season would be expected to be subject to windborne transport in a predominantly south-easterly direction, towards the sea whilst dry-season excavation would generate particulate that may predominantly be transported in a northerly and north-westerly direction towards inland areas. The distribution of windborne particulate will also be modulated by the specific topography of the site, with a flat site of operations backed by high cliff. This may channel particulates into the atmosphere in unpredictable ways. Possible sinks for windborne particulate are the assemblages dominated by Maltese Salt-Tree (Darniella melitensis) [RDB: Endemic] on the slopes surrounding the DPS complex. Such assemblages are already exposed to input of particulates transported from the unconsolidated mound of rubble in the RGF site and are presumably tolerant of such pressures. Waterborne particulate would not be expected to affect terrestrial habitats in the AoS and its environs as the lower elevation of the site of the DPS complex relative to the surroundings suggests that fluid flows from the site would be likely to enter the marine environment, where this may constitute a significant impact.

7.6.3.2 Proposed mitigation measures A number of dust-suppression measures may be considered to minimize wind-blown dispersion. These include collection of fine particulates generated during any on-site working of stone, covering of stored material, and water-spraying of active areas. It should be emphasised that wash-down of particulate may, unless controlled, convert windborne particulate into waterborne particulate which would be subject to further redistribution in surface runoff. In this case, given the topography in the AoS, the sink for such flows may be the sea, where this may constitute a significant impact as indicated in paragraph 7.6.3.1.

7.7 Project action 2a: Storage of excavated material

7.7.1 Predicted impact: obliteration of biological communities in possible storage sites Temporary storage of construction debris, rubble, soil and construction material would obliterate all habitats and biota under the footprint of the stockpiles used for this purpose. It is assumed that any stockpiles will be situated within the boundary of the DPS complex and would therefore not affect biota of positive conservation significance.

7.7.1.1 Receptors Any biota within the footprint of stockpiles.

7.7.1.2 Proposed mitigation measures Stockpiles of excavated materials should either be removed or be underlain with porous bedding and covered with a tarpaulin in order to minimize redistribution by wind and water. Duration of on-site storage of excavated material should be as brief as possible to reduce opportunities for winnowing of sediment. Limiting the height and slope of the stockpiles in order to reduce wind erosion and wet suppression of dust, using sprinklers should also be considered. Wet suppression of dust may however generate fluid flows that, unless contained, may flow into the sea. Siting of stockpiles away from the rupestral habitats characterising the western perimeter of the DPS complex should also be considered.

7.7.2 Predicted impact: redistribution of particulates Temporary storage of construction debris, rubble, soil and construction material on the site may provide opportunities for winnowing and erosion of particulates. Unprotected stockpiles would provide surfaces exposed to redistribution of dust by wind and by surface runoff. The impact of windblown and waterbrone particulate on terrestrial ecological resources in the AoS and its environs has been described in Paragraph 7.6.3. Sediment transported outside the margins of the excavated areas by wind and subsequently deposited on the surface may be subject to further transport and redeposition by stormwater. The effects of such an impact are however likely to attenuate in the longer term as the particulate load would be diluted by further redistribution.. These impacts are expected to operate throughout the excavation and construction phase and would impact areas downwind of the footprint of proposed development.

7.7.2.1 Receptors The most sensitive assemblages are the rupestral assemblages dominated by Maltese Salt-Tree (Darniella melitensis) [RDB: Endemic] on the slopes surrounding the DPS complex. The steep angle of slope of these habitats suggests that large-scale accumulations of transported particulate would be unstable and subject to further downlospe transport through slumping.

7.7.2.2 Proposed mitigation measures Stockpiles should be insulation using a protective covering. The height and slope of the stockpiles should be limited in order to reduce wind erosion. Use of wind breaks around the stockpiles would reduce the frequency of entrainment of particulate by wind.

7.7.3 Predicted impact: proliferation of ruderal species The availability of large quantities of bare construction debris will promote their colonisation by ruderals, and therefore provide a centre from where such ruderals may infiltrate adjacent habitats. Nonetheless, it should be borne in mind that the DPS and its environs are already characterized by numerous reservoirs of ruderal species and it is likely that episodes of infiltration into established communities in the vicinity have already occurred in the past. As such, the presence of any persistent piles of debris within the DPS complex would be expected to modify the magnitude of the impact rather than its nature.

7.7.3.1 Receptors Assemblages in the vicinity of stockpiles and within dispersal range of ruderal species. The most sensitive assemblages are the rupestral assemblages dominated by Maltese Salt-Tree (Darniella

melitensis) [RDB: Endemic] on the slopes surrounding the DPS complex. The high abiotic stress characteristic of such habitats however implies that large-scale and longer-term establishment of relatively unspecialised ruderal assemblages is unlikely.

7.7.3.2 Proposed mitigation measures Insulation of stockpiles in order to minimise dispersal of propagules.

7.7.4 Predicted impact: degradation of biological communities due to leakages Higher volumes of traffic than at present are likely to be attracted to the DPS complex throughout the construction phase. Traffic to and from the site will involve the passage of heavy vehicles generating opportunities for spillages of fuel and transported materials as well as fallout from exhaust streams. Any impacts arising from this source would be dependent on the volume of spillage and on specific weather conditions at the time of spillage. It should be stressed that concentrated discharges of oils and fuels would generally be expected to exert toxic effects on vegetation and other biota along their route of redistribution. Apart from ‘acute’ effects such as the ones described, possible impact may be constituted by ‘chronic’ effects derived from small quantities of operational leakages. If high volumes of vehicular traffic are envisaged, the cumulative ‘chronic’ effects may be significant.

7.7.4.1 Receptors Assemblages directly exposed to such leakages. Any fluid flows arising within the boundary of the DPS complex would not be expected to affect other habitats within the AoS as the direction of flow would be towards the sea. Spillages along Triq Delimara may flow downhill along the roads skirting the AoS but are unlikely to reach the cliff faces colonized by a Maltese Rdum community dominated by Darniella melitensis.

7.7.4.2 Proposed mitigation measures Containment of spillages through secure storage and confinement of loads in vehicles. This should be particularly stringent for loads of oils, solvents and other hazardous chemicals.

7.8 Project action 2b: Storage of construction materials, waste materials and possible contaminants

7.8.1 Predicted impact: degradation of biological communities due to leakages The Project Description Statement (Enemalta Corporation, 2013) suggests that various materials, including hazardous material (such as cement), fuels, solvents, and lubricants may be utilised on-site when construction works are taking place. The storage of such materials generates opportunities for leakage (in the case of fluids) or windborne transport (in the case of gases, aerosols or particulates) into the AoS and its environs during use, during transfer operations, or through misuse or through accident. Other forms of waste, including combustible waste and sanitary waste are also expected to be generated during the construction phase.

7.8.1.1 Receptors Assemblages directly exposed to such leakages. Any impacts arising from this source would be dependent on the materials and chemicals involved, on the volume of leakage and on specific weather conditions at the time of leakage. It should be stressed that concentrated leakages of oils,

other fuels and of solvents would generally be expected to exert toxic effects on vegetation and other biota along their route of redistribution. Impacts also depend on the location of storage sites of such contaminants. Any fluid flows arising within the boundary of the DPS complex would not be expected to affect other habitats within the AoS as the direction of flow would be towards the sea. Depending on the nature of the substratum, significant leakages may permeate through the underlying rock, reaching the sea through discontinuities and other pathways in the rock.

7.8.1.2 Mitigation measures Secure storage of potential pollutants (including oils and cement) with secondary containment and fire-prevention systems. Storage of minimum quantities required and good operational practice will reduce the potential for accidents. A contingency plan to clean up spills, should such occur, should also be established

7.9 Project action 3: Site illumination during the night

7.9.1 Predicted impact: disturbance of susceptible fauna Artificial lighting of the area of construction would cause disturbance of wildlife due to elevated light levels and impacts arising from longer period of illumination of habitat patches. Illumination of the site will serve to attract night-flying insects increasing the opportunity for these to be predated by insectivorous animals (e.g. bats and geckoes) as well as mortality by other means, including trampling by personnel in the area. Lights will disturb any susceptible fauna (including reptiles, birds, bats, hedgehogs and shrews) that may use natural or man-made features in the vicinity as refuges, roosting and nesting sites. It should be emphasised that this impact already exists, as the area occupied by the DPS complex is presently illuminated during the night. Any additional illumination will modify the magnitude of the impact rather than the nature of the impact.

7.9.1.1 Receptors Principal receptors are likely to be birds, bats, other nocturnal mammals, nocturnal reptiles, and nocturnal insects that respond to intense light sources.

7.9.1.2 Mitigation measures Use of downward facing lights, although such lights may still cause light pollution that may negatively influence wildlife. Use of low intensity lighting is recommended where possible.

7.10 Project action 4: Emission of primary and secondary pollutants This assessment of the probable impacts during the operational phase of the DPS complex is general and is limited to effects on biological receptors in the AoS.

7.10.1 Predicted impact: possible damage to vegetation Operation of the DPS would be expected to generate various pollutants including nitrogen oxides (NOx) (Enemalta Corporation, 2013) and their secondary pollutants, including atmospheric acids. Acidic fallout may exert a direct negative impact on vegetation. It should be emphasised that, at present, the DPS already produces such atmospheric pollutants and has been doing so for the duration of its commission. As such, the vegetation assemblages in the AoS and its environs have

already undergone selection for tolerance to this source of stress. The proposed power-generation processes are expected, according to the Project Description Statement (Enemalta Corporation, 2013), to release lower volumes of NOx into the atmosphere, suggesting that impacts (such as possible damage to vegetation) would not be of a higher magnitude than at present.

7.10.1.1 Receptors The relevant biological receptors associated with this source of impact have been described in Paragraph 7.6.3.1

7.10.1.2 Proposed mitigation measures Reduction of NOx emissions may be achieved through the use of appropriate abatement measures, as currently used in the existing DPS and as proposed for the new development (Enemalta Corporation, 2013).

7.11 Project action 5: Storage of fuels and possible contaminants The predicted impact, susceptible receptors within the AoS and proposed mitigation measures for this project action have been described in Paragraph 7.8. These would also apply to temporary storage of the waste stream generated by operation of the DPS, including inert solid waste, toxic waste and organic waste.

7.12 Project Action 6: Release of potential contaminants during dismantling The predicted impact, susceptible receptors within the AoS and proposed mitigation measures for this project action have been described in Paragraph 7.8.

7.13 Project Action 7: Storage of waste materials and contaminants The predicted impact, susceptible receptors within the AoS and proposed mitigation measures for this project action have been described in Paragraph 7.8.

8 References AIS Environmental Ltd (2009). Environmental Impact Statement for the proposed local generating capacity at Delimara Power Station. Devillers P. & Devillers-Terschuren J. (1996). Classification of Palaearctic habitats. Nature and environment, No. 78. Council of Europe. Enemalta Corporation (2013). Project Description Statement: Delimara Gas and Power; Combined Cycle Gas Turbine and Liquefied Natural Gas receiving, storage and regasification facilities. Enemalta Corporation.

Oil Exploration Directorate (1993). Geological map of the Maltese Islands. Sheet I: Malta scale 1:25.000. Oil Exploration Directorate, Office of the Prime Minister, Malta.

Schembri P.J. (1991). Report of survey: natural resources. [Malta Structure Plan Technical Report 5.4] Beltissebh, Malta: Colin Buchanan and Partners/Generale Progetti SpA/Planning Services Division, Government of Malta; viii + 138pp.

Schembri P.J. & Sultana J. (1989). Red Data Book for the Maltese Islands. Valletta, Malta: Department of Information; viii + 142pp.

9 Appendix 1

9.1.1 Key to Red Data Book categories Code Criterion

Endemic Taxon endemic to the Maltese Islands

X Taxon extinct from the Maltese Islands

E Taxon is endangered in the Maltese Islands

R Taxon is rare in the Maltese Islands

RR Taxon is very rare in the Maltese Islands

I Status of taxon in the Maltese Islands is not known

Rest(MI) Taxon has a restricted distribution in the Maltese Islands

Rest(MED) Taxon has a restricted distribution in the Mediterranean region

? Following any other symbol signifies uncertainty in the information given

9.1.2 Scope of categories Category Scope

Endangered Taxon is in danger of extinction due to populations having become severely depleted or due to a drastic reduction in habitat

Vulnerable Taxon is likely to become endangered in the near future if the factors threatening it continue to operate (over-exploitation, extensive destruction of habitat, environmental disturbance)

Rare Taxon is not at present endangered or vulnerable but because of its rarity in the Maltese Islands is at risk

Very rare Taxon is at risk because it is very rare in the Maltese Islands, either because it is restricted to a particular locality or to a habitat type itself rare in the Maltese Islands or because it is thinly scattered

Indeterminate Taxon may or may not be under threat but insufficient information is currently available to evaluate this

10 Appendix 2

10.1.1 Schedules listed in Legal Notice 200 of 2011: Trees and Woodlands Protection Regulations

Schedule Scope

Schedule I Strictly Protected Tree Species

Schedule II Trees Protected in Selected Areas

Schedule III Invasive, Alien or Environmentally-Incompatible Species

11 Appendix 3

11.1.1 Schedules listed in Legal Notice 311 of 2006: Flora, Fauna and Natural Habitats Protection Regulations, 2006.

Schedule Scope

Schedule I Natural habitat types whose conservation requires the designation of Special Areas of Conservation

Schedule II Animal and plant species of community interest whose conservation requires the designation of Special Areas of Conservation

Schedule III Animal and plant species of national interest whose conservation requires the designation of Special Areas of Conservation

Schedule IV Criteria for selecting sites eligible for identification as Sites of National Importance and of International Importance and designation as Special Areas of Conservation

Schedule V Animal and plant species of community interest in need of strict protection

Schedule VI Animal and plant species of national interest in need of strict protection

Schedule VII Animal and plant species of community interest whose taking in the wild and exploitation may be subject to management measures

Schedule VIII Animal and plant species of national interest whose taking in the wild and exploitation may be subject to management measures

Schedule IX Identification and monitoring

Schedule X Endemic species not covered by Regulation 26

Schedule XI Animal species of community interest whose capture and killing and transport are regulated

Schedule XII Prohibited methods and means of capture and killing and modes of transport

Health Impact Assessment Report On the Implementation of a Combined Cycle Gas Turbine power plant and Liquid Natural Gas receiving, storage and regasification facilities at Delimara

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Summary of Impacts


Impact type Health Improvement


Less air pollution Reduction in solid waste Better perceptions on health from nearby residential areas Better long-term impact on economy Cleaner ecology Less wastewater produced

Project phase Construction/Installation works OOperations

Impact Receptor

Receptor type Workers at DPS, Residents of Marsaxlokk, population of Malta


Construction/Installation works Operations

Temporary increase in irritative and allergic conditions (increased dust in air)

Overall reduction in respiratory illness, cardiovascular disease, Skin irritation



Direct/Indirect Direct Direct and Indirect

Cumulative No Yes

Beneficial/Adverse Adverse Beneficial

Severity Minimal Moderate

Physical/geographic extent

SE of Malta All of Malta focusing on Marsaxlokk Bay


SShort term – Improved health, perception of health. MMedium term – further health improvements; slight socioeconomic improvement LLong--term – greater health improvements; improving socio-economic conditions.


Temporary Permanent


Reversible Reversible (eg. Allergies) and Permanent (eg. Cardiovascular disease)



Probability of impact occurring inevitable, likely, remote uncertain

Very likely – esp. workers and closest residents.

Workers at site (at very low risk of negative health impacts) Marsaxlokk residents (positive) General population (positive)


Negative Positive (overall)

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Follow guidelines as per Air quality report, World Bank reports, Water quality report, Social Impact Assessment Report

Follow guidelines as per Air quality report, World Bank reports, Water quality report, Social Impact Assessment Report


Minimal Positive health improvements

Monitoring Importance of monitoring on land, sea and air parameters that bear on health

Objective and routine monitoring on land, sea and air parameters with independent follow-up assessment.

Authorisations Development Permission under the Environment and Development Planning Act (Cap 504)

Development Permission under the Environment and Development Planning Act (Cap 504)

Operations Permit under the Industrial Emissions (Integrated Pollution and Control) Regulations (SL504.54; LN10/03)

Approval of major accident prevention policy document under the Control of Major Accident Hazard Regulations (SL424.19; LN37/03)

Criteria used to describe impacts: Health gains are generally difficult to quantify and characterise because they cannot be directly ascribed to specific hazards.

Beneficial/Adverse

Level Criteria

High

N/A Moderate

Low

Neutral

Severity

Level Criteria

High

N/A Moderate

Low

Neutral

Probability of impact occurring

Level Criteria

High

N/A Moderate

Low

Neutral

Significance: Overall Impact

Level Criteria

High N/A

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Significance: Overall Impact

Level Criteria

Moderate

Low

Neutral

Significance: Residual

Level Criteria

High N/A

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AAbbreviations and Acronyms

CCGT Closed Cycle Gas Turbine

DPS Delimara Power Station

DPS3 Delimara Power Station phase 3 (extension)

EC European Communities

ECE Economic Commission for Europe

EMEP European Monitoring and Evaluation Programme

FWD Air quality framework directive 2008/50/EC

HFO Heavy Fuel Oil

km kilometre

LNG Liquid Natural Gas

MEPA Malta Environment & Planning Authority

MPS Marsa Power Station MTTF Marsa Thermal Treatment Facility

MW Megawatt

NO2 Nitrogen Dioxide

PM10 Particulate matter equal or less than 10 Micrometres ( aerodynamic diameter

PM2.5 Particulate matter equal or less than 2.5 Micrometres ( aerodynamic diameter

TPS Thermal Power Station

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CContents Summary of Impacts ......................................................................................................................... 2

Abbreviations and Acronyms .................................................................................................................. 5

1 Background ..................................................................................................................................... 9

1.1 The Health Impact Assessment ............................................................................................... 9

1.2 The salient developments of the project and their health impacts ..................................... 10

1.2.1 Current situation regarding the link between known environmental hazards and health ............................................................................................................................ 10

1.2.2 Local studies .................................................................................................................. 14

2 Environmental impacts to Health from Power Plants, Liquid Natural Gas Storage and Regasification sites ................................................................................................................................ 15

2.1 Air pollution effects on health .............................................................................................. 15

2.1.1 Sulphur Dioxides ........................................................................................................... 15

2.1.2 Nitrous Oxides (NOx or NO2) ......................................................................................... 16

2.1.3 Particulate Matter - PM 10 and PM 2.5 ................................................................................ 16

2.1.4 Volatile Organic Compounds - VOCs ............................................................................. 17

2.1.5 Ozone (O3) ..................................................................................................................... 17

2.1.6 Carbon Monoxide ......................................................................................................... 17

2.1.7 Carbon Dioxide (CO2) .................................................................................................... 17

2.2 Noise Pollution ...................................................................................................................... 17

2.3 Water Pollution ..................................................................................................................... 18

2.3.1 Thermal water Pollution ............................................................................................... 18

2.4 Waste Removal ..................................................................................................................... 18

2.5 Social Impact ......................................................................................................................... 19

2.6 Natural Disasters ................................................................................................................... 19

2.7 LNG storage and regasification hazards and risks ................................................................ 19

3 Expected change and health impacts of the Project .................................................................... 24

3.1 Air pollution .......................................................................................................................... 24

3.1.1 Nitrous Oxides (including NO2) ..................................................................................... 24

3.1.2 Particulate matter (PM10 and PM2.5) ............................................................................. 25

3.1.3 Sulphur Dioxides ........................................................................................................... 27

3.1.4 Ozone (O3) and Volatile Organic Compounds (VOCs) ................................................... 27

3.1.5 Air Pollution: Conclusion ............................................................................................... 29

3.2 Greenhouse Gas Emissions ................................................................................................... 30

3.2.1 GHGs emissions – long term effects of CO2 and impact on health .............................. 30

3.3 Noise Pollution ...................................................................................................................... 32

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3.3.1 Construction Phase ....................................................................................................... 33

3.3.2 Operational Phase ......................................................................................................... 34

3.4 Water Pollution ..................................................................................................................... 35

3.4.1 Chemical Pollution in Marsaxlokk Bay .......................................................................... 35

3.4.2 Detection of Mercury in Marsaxlokk Bay ...................................................................... 35

3.4.3 Construction Phase ....................................................................................................... 35

3.4.4 Operational Phase ......................................................................................................... 36

3.4.5 Water Effluent Release at - ..................................................................... 37

3.4.6 The Re-gasification Process: Seawater use ................................................................... 38

3.5 Social Impact ......................................................................................................................... 39

3.5.1 Fears expressed regarding the DPS Project .................................................................. 39

3.5.2 Other concerns .............................................................................................................. 40

3.5.3 Employment on site ...................................................................................................... 41

3.5.4 Long-Term benefits from the project ........................................................................... 41

3.5.5 Economic Savings due to use of Natural Gas ................................................................ 41

3.5.6 Land Value: Expansion of Estate ................................................................................... 41

3.6 Waste .................................................................................................................................... 43

3.6.1 Delimara: current waste production. ............................................................................ 43

3.6.2 Waste: Choosing the Site .............................................................................................. 44

3.6.3 Waste expected to be generated during operation phase ........................................... 45

3.6.4 Waste expected to be generated during LNG transport and storage process ............. 48

3.6.5 Waste generated during Construction .......................................................................... 49

3.7 Risk Assessment of LNG operations ...................................................................................... 50

3.7.1 LNG Hazards .................................................................................................................. 50


3.8.1 Earthquakes .................................................................................................................. 52

3.8.2 Tsunamis ....................................................................................................................... 52

3.8.3 Fire ................................................................................................................................ 52

4 Prevention and Mitigation ............................................................................................................ 53

4.1 Positioning of LNG facilities .................................................................................................. 53

4.2 Air quality .............................................................................................................................. 54

4.2.1 Air pollution Mitigation measures ................................................................................ 54

4.2.2 Air pollution Mitigation: Option A ................................................................................ 55

4.3 Noise monitoring including variability under differing circumstances ................................. 56

4.4 Current and future monitoring of marine quality ................................................................. 57

4.4.1 Dredging Activities ........................................................................................................ 57

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4.4.2 Discharges in the bay .................................................................................................... 57

4.4.3 Water Outflow in - .................................................................................. 57

4.4.4 Other recommendations ............................................................................................... 57

4.5 Solid waste ............................................................................................................................ 58

4.5.1 Mitigating solid waste during construction: Option A .................................................. 58

4.5.2 Mitigating solid waste during construction: Options B and C ...................................... 58

4.5.3 Mitigating solid waste during operations ..................................................................... 58

4.5.4 Selection and monitoring of CCGT plant standards ...................................................... 59

4.6 Social impacts ........................................................................................................................ 59

4.6.1 Dealing with the misconceptions regarding the proposed DPS project ....................... 59

4.6.2 Improving the locality ................................................................................................... 60


5 Conclusion ..................................................................................................................................... 61

6 Bibliography .................................................................................................................................. 64

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11 Background

1.1 The Health Impact Assessment

A Health Impact Assessment (HIA) is a method for describing and estimating the effects that a proposed projector policy may have on the health of a population. A more recent and wider description is a process through which evidence of different kinds, interests, values and meanings are brought into dialogue between relevant stakeholders (politicians, professionals and citizens) in order imaginatively to understand and anticipate the effects of change on health and health inequalities in a given population. (Elliot et al 2010).

A HIA may be done prospectively, concurrently or retrospectively. In this case, this will be a prospective HIA with the project yet to be developed as this report is written. The timing is such that it is early enough to be able to influence the design and implementation of the project with full ramifications on the health impacts of these being understood while not too early so as to be clear enough about the proposal’s development, its nature and purpose.

Of the three methods possible for an HIA, the one adopted here is the so called Rapid HIA which takes some weeks and includes a brief description of health impacts based on a literature review of the scientific evidence and the gathering of further evidence and knowledge from experts and stakeholders. This is in contrast to the purely Desktop HIA which may take a few hours or the Comprehensive HIA which can take months to complete and which involves a time intensive, financially costly extensive review and the collection of primary data.

The authors of this HIA are also the very first users of the information submitted from all the other expert contributions to the Environmental Impact Assessment for this project. It was essential that the best available knowledge on the current situation with regards to environmental hazards (under current power plant conditions), and their projections during the construction phase of the new project, as well as their projections (and those of any new hazards) for when the new gas plant was up and running were at hand to be able to make an informed assessment of the health implications of the project.

Such factors which could influence the health of the population as a result of the change in the nature of power generation utilised include the air quality, the noise, the marine water quality, and the social implications ranging from people’s perceptions on health and wellbeing while living in the vicinity of either of the power plants to the value of land and the influences on the local industries.

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1.2 TThe salient developments of the project and their health impacts

The project is a complex one with different health impacts arising from the differing parts of its complexity. Thus, the following phases each have their own health impacts and risks:

Development of new CCGT Setting up of LNG plant for storage and for regasification at the DPS site (on or off shore) Conversion of DPS3 (internal combustion engines) to natural gas Decommissioning of MPS and of DPS steam turbines.

It is fitting that, while the various risks and hazards of each phase may be considered, an overall assessment and conclusion of the complex changes being made globally as part of this project on the overall health and wellbeing of the population at risk be given prominence for the longer term.

With regards to the population influenced by the changes involved in this project, considerations must be given to the health impacts on the local community at Delimara – primarily, the Marsaxlokk residents but also the Birzebbugia residents; to the health of workers involved in the current and future Delimara power plants; that of the workers involved in construction, transport and other phases of the project development itself as well as to the greater impact on the health and wellbeing of the population at large in Malta and Gozo.

A fair assessment of the health implications of such a major project must first include a detailed perspective of the current situation regarding known hazards and their current documented effects on the health of the population. While some regular data has been collected and is reported in the various reports accompanying this HIA as part of the current EIA, it must also be recognised that the frequency and the methodology utilised in monitoring have not always been optimal and that all data has its limitations.

The assessment must also look at new hazards generated during the construction (and decommissioning) of the project – to the local population, to the individuals involved in the works and potentially further afield.

The HIA also must look into benefits and potential hazards following the proposed conversion to a natural gas based power plant. While most effects may be immediate, some others may take a longer time to come to pass.

1.2.1 Current situation regarding the link between known environmental hazards and health

Several illnesses in populations are linked with a number of air pollutants. The air pollutants include Nitrous Oxides NOX and principally, Nitrogen Dioxide - No2, Sulphur Dioxide - So2, benzenes, Carbon Monoxide – CO, Carbon Dioxide – CO2, Volatile Organic Compounds (VOCs) and particulate matter. The illnesses more commonly linked with some of these include lung cancer, asthma, allergic rhinitis and cardiovascular disease. Most notable among these are the established links between asthma and air pollutants. A graphic summary of these can be seen in Figure 1 which shows the link between Hazard ratios for Asthma and a number of pollutants. It is followed by images taken from the historical Harvard Six Cities Study, 1974-2009. This study was able to link Particulate Matter exposure with mortality from all causes/

10

There have also been studies looking more specifically at the link between the proximity of residence to a known environmental hazard such as a power plant with a number of forms of ill health again at population level. The more prominent of these were those linking coal burning power plants with asthma

It is notoriously more difficult to link environmental hazards to disease status in individuals. There are many reasons for this, including methodological and financial ones. Proving any link prospectively (the best available evidence) is both too costly and time-consuming. Other survey methods are possible but remain extremely costly.

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The hallmark of air pollution studies was the Harvard Six-Cities study, conducted in the early 1970s, which followed a cohort in 6 towns in the US with different air pollution levels. This found a clear relationship between Air pollution (particulate matter specifically) and mortality.

Figure 1 Community-specific hazard ratio (HR) of newly diagnosed asthma over 10th–90th percentile range (57.1%) of forced expiratory flow over the mid-range of expiration (FEF25–75%) by average levels of different ambient pollutants. PM2.5, particulate matter with an aerodynamic diameter <2.5 μm; PM10, particulate matter with an aerodynamic diameter <10 μm; NO2, nitrogen dioxide.

From: Thorax. 2007 November; 62(11): 957–963. Published online 2007 May 21. doi: 10.1136/thx.2007.078964.

Effect of different levels of PM 2.5 ug/m3 on survival in long-term cohort follow up

12

The cohort was followed up so that by 2009, a most recent update was put up, focusing on PM 2.5 and various forms of mortality. The two images ton this page attest to this relationship, with all-cause mortality increasing by 14% for every 10/μg/m3. Cardiovascular mortality, in particular, increases by 26% for the same amount.

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11.2.2 Local studies In the local situation, using epidemiological surveys for this purpose in these islands would have the difficulties of small numbers and hence, insufficient statistical power. The other problem is the widespread exposures across the country to hazards such as air pollutants, to the point that it is difficult to obtain sufficient controls unexposed to fine particulate matter and other chemical air pollutants. The problem here is that the limited length of the islands means that exposures tend to get distributed throughout the inhabited areas. There are also a large number of strong confounding influences which could distort the relationship between the environmental hazards and health. The latter include socio-economic class (and associated risk behaviour such as tobacco smoking), the presence of other proximal known hazards, such as the seaport and airport, as well as heavy traffic zones.

The best available epidemiological information locally are ecological studies based on routinely generated information (i.e. not on surveys) and conducted by 2 post-graduate students in Public Health over recent years. While these are extremely interesting, such ecological studies are not considered as the best evidence to establish the environmental hazard - health link, although oftentimes, they are the best there can be.

In the first study, Cuschieri (2002) was able to establish a clear statistical link between congenital anomaly onsets and proximity of residence to the Maghtab dump. The link was only clear within the first 3 kilometres of radius around Maghtab. While this was not spectacular, it was the first ever established link between any environmental hazard and ill health locally. The other, more pertinent to this HIA, was the link established by Calvagna (2005) between the increased frequency of cases registered with Lung Cancer in Malta with decreasing distance of residence from the MPS. It is interesting that both these studies attempted to establish a link between their selected ill health (congenital anomalies and cancer of the lung) with proximity of residence from both the Maghtab dump and the MPS. Both failed to find the other link i.e. Maghtab and lung cancers, MPS and congenital anomalies. It is noteworthy that both these studies, as with all in our islands, are impeded by the small numbers of cases involved for each condition and this also meant that wide confidence intervals (poor power) ensued for both.

The more probable relationship worthy of investigation locally was that of any link between either MPS or even DPS and asthma incidence. However, this link has failed to be established when studied and indeed, while asthma incidence appears high in Malta compared to other European countries, adults residing in the south of Malta appear to have lower rates than the national average. The complexity of studying the problem is typified by the fact that fine particulate matter (known to be linked with Asthma) in Malta may at times be predominantly caused by natural sources (sea spray and desert dust) and spread across a wide area while conversely, a small 2004 study revealed significant differences in asthma rates across a 250 metre distance from the high traffic Zabbar road.

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22 Environmental impacts to Health from Power Plants, Liquid Natural Gas Storage and Regasification sites

The hazards to health from power stations come principally from the following sources:

Air pollution (chemical and PM) Water pollution – through effluents and thermal effects on sea water Noise pollution Solid waste disposal and land pollution Social impacts including via employment, influence on major industry, real estate and perception of health

The list is applicable for both heavy fuel oil and natural gas based plants, with differing levels and considerations for each. Other rare forms of hazard include natural and man-made disasters which put such plants at special risk as typified by the case with the tsunamis which hit the Japanese coast and caused such havoc to the nuclear plants, to people’s health and to the environment. Special considerations for prevention with regard to health impacts must be taken for the specific risk and hazards involved in the construction phase of the new plant and the demolition and removal of old plants, including stacks.

2.1 Air pollution effects on health

Air pollution is a collective term that refers to the introduction of chemicals, biological material or particulates, often through pyrogenic processes, into the atmosphere, that cause discomfort, disease and even death to humans and other organisms in Earth’s biosphere.

It is worthwhile considering that large amounts of air pollution arise from natural causes such as air-borne desert dust, particles from natural wildfires and sea spray particulates, as well as particles resulting from natural chemical atmospheric processes. However, human industrial activity almost inevitably leads to chemicals and particulate matter being released into the atmosphere that can have various effects on health in humans and other organisms.

Most commonly, air pollution refers to the following components:

2.1.1 Sulphur Dioxides These compounds are released due to the combustion of sulphur compounds, commonly found in various forms of fossil fuels, most notably coal. Sulphur dioxide causes a range of harmful effects on the lungs, as recent studies have shown and principally :

Wheezing, shortness of breath and chest tightness and other problems, especially during exercise or physical activity. Continued exposure at high levels increases respiratory symptoms and reduces the ability of the lungs to function. Short exposures to peak levels of SO2 in the air can make it difficult for people with asthma to breathe when they are active outdoors.

15

Rapid breathing during exercise helps SO2 reach the lower respiratory tract, as does breathing through the mouth. Increased risk of hospital admissions or emergency room visits, especially among children, older adults and people with asthma.

Combustion of natural gas emits practically untraceable amounts of Sulphur Oxides compared to considerably higher amounts emitted in the burning of fossil fuels such as coal and HFO, so that one can expect a strong reduction in Sulphur emissions, with overall positive health benefits from the conversion of power plants from HFO to natural gas.

22.1.2 Nitrous Oxides (NOx or NO2) Nitrous oxides, mainly NO2, are gaseous air pollutants composed of nitrogen and oxygen which form when fossil fuels are burnt at high temperatures. This is typically produced by vehicular traffic. NO2 also mixes in outdoor air to form particulate pollution and ozone. It is one of several widespread air pollutants that have national air quality standards to limit them in outdoor air. Nitrous oxides can have quite a range of health effects on the lungs, namely :

Increased inflammation of the airways Worsened coughing and wheezing Deterioration in lung function Increased asthma attacks Increased hospital admissions Increased susceptibility to respiratory infection, such as influenza.

2.1.3 Particulate Matter - PM 10 and PM 2.5

Particulate Matter (PM) affects more people than any other pollutant yet is perhaps among the lesser known industrial air pollutants among the population. The major components of PM are sulphates, nitrates, ammonia, sodium chloride, carbon, mineral dust and water. It consists of a complex mixture of solid and liquid particles of organic and inorganic substances suspended in the air. The particles are identified according to their aerodynamic diameter, as either PM10 (particles with an aerodynamic diameter smaller than 10 μm) or PM2.5 (aerodynamic diameter smaller than 2.5 μm). The latter are more dangerous since, when inhaled, they may reach the peripheral regions of the bronchioles, and interfere with gas exchange inside the lungs, and can even be absorbed into the blood.

The effects of PM on health occur at levels of exposure currently being experienced by most urban and rural populations in both developed and developing countries. They include:

Cardiovascular disease Respiratory diseases Upper Respiratory Tract Infections Asthma Chronic Obstructive Pulmonary Disease (COPD) in very high concentrations Lung cancer among adults

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2.1.4 VVolatile Organic Compounds - VOCs These compounds are usually divided into methane (CH4) and non-methane organic compounds (NMVOCs). Among the NMVOCs are various compounds, such as xylene, benzene and toluene which are suspected to have carcinogenic (cancer-causing) effects. These compounds are released through combustion of fossil fuels and industrial processes.

2.1.5 Ozone (O3) This odourless gas is formed from NOx and VOCs. It has a strong oxidative effect, and therefore affects any organic tissue it comes in contact with. Ozone is a key constituent of the troposphere. It is also an important constituent of certain regions of the stratosphere commonly known as the Ozone layer, which protects life on Earth from harmful UV rays from the sun. Photochemical and chemical reactions involving it drive many of the chemical processes that occur in the atmosphere by day and by night. At abnormally high concentrations brought about by human activities (largely the combustion of fossil fuel), it is a pollutant, and a constituent of smog.

At ground level ozone has a harmful effect on the lungs, and irritates the respiratory system. Exposure to ozone and the pollutants that it produces (due to its oxidative reaction with other chemicals in the atmosphere) has been linked to asthma, bronchitis, heart attacks, premature death and other cardio-respiratory problems.

2.1.6 Carbon Monoxide Carbon Monoxide is the result of incomplete combustion of carbon-containing fuel sources. It is most often a part of vehicular exhaust, especially from older vehicles. It has a highly toxic effect on the human body when exposure is severe and acute as it combines with haemoglobin in the blood forming carboxyhaemoglobin, which limits the body’s ability to absorb oxygen from the lungs, resulting in ischaemic heart disease. It has a negative effect on health through prolonged low dosage in highly polluted areas. While damage has been thought to be neurological including recurrent headaches, it is thought that effects are reversible. The effects of sustained low exposure on the health of the public have been more closely studied over recent decades .

2.1.7 Carbon Dioxide (CO2) This gas does not negatively affect health directly except in high concentrations, which are unlikely to be an issue in the power station context as emissions are emitted from chimneys. However , indirectly the long-term effects of carbon dioxide can affect health through climate change and the greenhouse effect, as well as through oceanic acidification. Malta’s contribution might seem insignificant in the global context but it has its responsibilities to carry for future generations.

2.2 Noise Pollution Although not overwhelmingly loud, most power plants can be heard when in close proximity and this can have a negative health impact on the people living nearby and as well as on workers working in the plant.

This negative health impacts here include:

Sleep Disturbance Cardiovascular disease Hypertension Poor Mental Health

17

Noise annoyance (general)

These and other factors can cause serious concern to the people living nearby.

2.3 WWater Pollution Both air and water cooling mechanisms are possible for power plants. The selected cooling mechanism for Delimara power plants have been water cooling and this continues to be considered for the current project.

Water Pollution can occur due to the discharge of several substances in the effluent waste of any power plant. This discharge varies considerably with time and can have diverse health impacts both direct (eg with substantial heavy metal discharge) or indirect (e.g. by causing thermal changes and thus influencing fish breeding).

Process wastewater may include contaminated wastewater from utility operations, storm water, and sanitary sewage. A number of cleaning agents are used to restore the machinery used in the combustion processes of thermal power plants. Most of these have their own hazard profile at toxic levels.

In the case of the Delimara Power Plant, seawater discharge had been selected mainly to dispose of excessive heat from combustion engines. However, it also removes contaminants discharging from machinery. Chemicals are also added to the effluent periodically, as they are used for the cleaning of machinery parts.

2.3.1 Thermal water Pollution Thermal pollution relates to the fact that the water used for cooling the power plant is released back into the sea at a substantially higher temperature than the water at the release site. This can have an indirect impact on health in that one could expect a possible impact on the biodiversity and bathing quality of the bay.

Algal blooms can occur in warmer waters and this could lead to eutrophication - a process which deoxygenates the seawater beneath the surface. This could have a negative impact on the biodiversity in the area and could present minor health problems to any bathers in the vicinity.

A thermal increases in sea temperature can have an effect on health as it can affect fish physiology , including phases in the life cycle of fish such as spawning, hatching and development, as well as at cellular level. Since the site would also favour more heat-tolerant species as compared to surrounding waters, one could get invasive alien species adapted to living in warmer waters (including jellyfish) which could potentially increase the risk for humans should they approach the area.

2.4 Waste Removal Thermal power plants produce various types and quantities of liquid and solid waste. While these are of high importance to the environment, their relevance here refers to the methods by which these are disposed of in order to avoid occupational and environmental hazards to health. The range of ill health caused by these substances is too vast to describe here. Guidelines on how to dispose of such waste and how to reduce risks for environmental pollution and occupational health

18

and safety are available in a World Bank document and are mentioned briefly in the subsequent section.

2.5 SSocial Impact A number of social impacts arise from the setting up or decommissioning of power plants. These range from the perceptions of residents in terms of their environmental health risks to such issues as impact on local industry, impact on real estate value, employment opportunity, traffic increments, and many others. Ultimately, all of these – whether directly or indirectly, would impact on the health of those at risk. The social impacts may also be very different for different stake holders. Residents in the vicinity are primarily at risk for environmental ill health and hazards and occasionally can stand to gain from economic developments. The population at large is yet another stake holder which generally stands to gain socio-economically from any improvements in energy production and in the potential for greater energy output to render industry more powerful and the country more affluent.

2.6 Natural Disasters Tsunamis, earthquakes and fires are among the less common but potentially most devastating natural disasters that could occur in a Power plant. These are considered in greater detail in the following section and in section 4. The Risk Assessment report has considered carefully the probability of these occurring, going so far as to recommend the placement of the floating LNG storage and regasification units for Options B and C to be situated at a further distance from the power plant and closer to the mouth of the bay. Other mitigating measures must also be taken to lower the probability that such disasters could take place and to ensure that if they did, they would have a lesser damaging effect on the environment and to the health of the population.

2.7 LNG storage and regasification hazards and risks The Risk Assessment report attached to this EIA highlights the prolific safety record that LNG facilities for power plants have been able to boast over the many years in existence. However, there are a number of potential threats to the environment posed by the Storage and regasification of liquid natural gas and a safety record of this calibre is only possible because of rigid standards maintained for the construction and running of such facilities.

These environmental hazards include threats to aquatic and shoreline environments, hazardous material management, LNG transport and others in common with those of power plants like noise, air emissions , wastewater and its management.

A number of health and safety hazards are also known to relate specifically to such facilities. These include fire and explosion due to possible leaks, ‘roll-over’ pressure which can cause structural damage; exposure of personnel to accidental contact with supercooled liquid gas; chemical hazards and accidents associated with confined spaces.

The Environment, Health and Safety Guidelines for liquefied natural gas facilities issued by the World Bank (2007) addresses both environmental as well as health and safety hazards, providing detailed measures to be taken to minimise the possibility of every eventuality. It also produces Performance Indicators and Industry Benchmarks for good international industry practice. These guidelines are mentioned in Section 4 of this report as a means of maintaining standards and preventing accidents through the lessons learnt over the years of constructing and maintaining similar facilities in other countries.

19

Tabl

e 1.

Sum

mar

y of

exp

ecte

d ch

ange

s fro

m th

e pr

ojec

t

N

oise

Ai

r Pol

lutio

n

Traf

fic

NO

x SO

2 PM

10

PM 2

.5

CO2

Befo

re

Curr

ent l

evel

s at

Mar

saxl

okk

are

arou

nd 4

0db.

No

nega

tive

heal

th

impa

cts

Very

low

leve

ls of

Tra

ffic

28 μ

g/m

3 av

erag

e fo

r M

alta

and

Goz

o Cu

rren

t lev

els n

ot

prov

ided

32

.51 μg

/m3

aver

age

for

Mal

ta a

nd G

ozo

Curr

ent l

evel

s not

pr

ovid

ed

Curr

ent e

miss

ions

are

ar

ound

2,5

00 G

g CO

2

Durin

g Sl

ight

incr

ease

due

to

traf

fic a

nd a

t co

nstr

uctio

n sit

es

Incr

ease

due

to

cons

truc

tion

traf

fic

Incr

ease

due

to tr

affic

to

site

(loca

l to

site)

In

crea

se d

ue to

tr

affic

In

crea

se d

ue to

co

nstr

uctio

n w

orks

Incr

ease

at l

ocal

site

, sli

ght i

ncre

ase

in a

reas

cl

ose

to a

rea.

Es

peci

ally

due

to S

ite B

"m

ound

" rem

oval

Incr

ease

due

to tr

affic

to

and

from

site

Afte

r (sh

ort-

term

)

Min

imal

incr

ease

. N

o ne

gativ

e he

alth

im

pact

s Pr

evio

us tr

affic

leve

ls 50

% d

ecre

ase

expe

cted

N

o SO

2 em

issio

ns

50%

- 90

% re

duct

ion

50%

- 90

% re

duct

ion

Decr

ease

due

to sw

itch

to L

NG

Afte

r (lo

ng-

term

)

Min

imal

incr

ease

. N

o ne

gativ

e he

alth

im

pact

s Pr

evio

us tr

affic

leve

ls 50

% d

ecre

ase

expe

cted

N

o SO

2 em

issio

ns

50%

- 90

% re

duct

ion

50%

- 90

% re

duct

ion

Decr

ease

due

to sw

itch

to L

NG

No

chan

ge

Min

imal

Cha

nge

Posit

ive

Heal

th E

ffect

s N

egat

ive

Heal

th E

ffect

s

20

W

ater

So

lid W

aste

Rem

oval

N

atur

al G

as

Ef

fluen

t di

scha

rge

Cool

ing

Wat

er

Mar

sa

Delim

ara

Site

A Si

te B

(if o

ptio

n A

sele

cted

) LN

G Ha

ndlin

g

Befo

re

Bioc

af a

nd

Sulp

huric

aci

d co

mbi

ne to

form

Ch

lorin

e Di

oxid

e.

0.1p

pm re

leas

ed a

t po

int o

f out

flow

. No

know

n ef

fect

on

heal

th a

t tha

t co

ncen

trat

ion

Ther

mal

pol

lutio

n -

cool

ing

outf

low

poi

nt th

an th

e am

bien

t wat

er. R

isk o

f alie

n sp

ecie

s bei

ng in

trod

ucte

d th

at m

ight

cau

se h

arm

.

Curr

ent w

aste

exp

orte

d fo

r tre

atm

ent

Curr

ently

was

te

gene

rate

d fr

om H

FO

plan

t is e

xpor

ted

Empt

y sit

e M

ound

cov

erin

g Si

te B

N

/A

Durin

g N

o ch

ange

N

o ch

ange

Deco

mm

ision

ing

proc

ess -

ne

eds c

aref

ul

man

agem

ent o

f di

sman

tling

of p

ower

pla

nt

to p

reve

nt sp

illag

e of

w

aste

on

site

Land

cle

arin

g w

aste

; Bu

lky

cons

truc

tion

was

te; S

peci

al w

aste

(h

azar

dous

m

ater

ial);

Cons

truc

tion

was

te,

Spec

ial w

aste

due

to

cons

truc

tion

of si

te

Cons

ider

able

co

nstr

uctio

n w

aste

an

d du

st g

ener

ated

by

rem

oval

of m

ound

. Po

ssib

le la

nd

recl

amat

ion

to b

uild

ta

nker

jett

y

N/A

Afte

r (sh

ort-

term

) N

o ch

ange

De

crea

sed

volu

me,

less

th

erm

al p

ollu

tion

NA

N

o so

lid w

aste

ex

pect

ed

No

solid

was

te e

xpec

ted

Stor

age/

Shi

ppin

g ar

ea. P

ossib

le w

aste

pr

oble

ms d

ue to

op

erat

ion

proc

edur

es

Poss

ible

cry

ogen

ic

inju

ry, a

sphy

siatio

n ris

k.

Afte

r (lo

ng-

term

) N

o ch

ange

De

crea

sed

volu

me,

less

th

erm

al p

ollu

tion

NA

No

solid

was

te

expe

cted

N

o so

lid w

aste

exp

ecte

d

Stor

age/

Shi

ppin

g ar

ea. P

ossib

le w

aste

pr

oble

ms d

ue to

op

erat

ion

proc

edur

es

Poss

ible

cry

ogen

ic

inju

ry, a

sphy

siatio

n ris

k.

No

chan

ge

Min

imal

Cha

nge

Posit

ive

Heal

th E

ffect

s N

egat

ive

Heal

th E

ffect

s

21

So

cial

St

orag

e

W

orkf

orce

Pe

rcep

tion

of lo

cals

Econ

omic

Ben

efits

LN

G St

orag

e

Befo

re

NA

Unh

ealth

y, p

ollu

ting

envi

ronm

ent.

Feel

ing

Vict

imise

d.

Expe

nsiv

e - o

il N

A

Durin

g In

crea

sed

Empl

oym

ent -

po

sitiv

e he

alth

impa

ct fo

r th

ose

curr

ently

une

mpl

oyed

Pollu

tion

from

con

stru

ctio

n an

d tr

affic

may

stre

ss lo

cal r

esid

ents

Co

nsid

erab

le in

vest

men

t in

cons

truc

tion/

con

vers

ion

Cons

truc

tion

Afte

r (sh

ort-

term

) M

inim

al C

hang

e Be

tter

env

ironm

ent,

clea

ner a

ir Gr

eate

r ele

ctric

ity c

apac

ity,

clea

ner e

nviro

nmen

t

Ope

ratio

ns n

eed

to b

e ha

ndle

d ca

refu

lly to

av

oid

spill

s, C

ryog

enic

in

jury

Afte

r (lo

ng-

term

) M

inim

al C

hang

e Be

tter

env

ironm

ent,

clea

ner a

ir Gr

eate

r ele

ctric

ity c

apac

ity,

clea

ner e

nviro

nmen

t

Ope

ratio

ns n

eed

to b

e ha

ndle

d ca

refu

lly to

av

oid

spill

s, C

ryog

enic

in

jury

No

chan

ge

Min

imal

Cha

nge

Posit

ive

Heal

th E

ffect

s N

egat

ive

Heal

th E

ffect

s

22

N

atur

al D

isas

ters

Ts

unam

i Ea

rthq

uake

Fi

re

Befo

re

Curr

ent "

Site

B" s

ite is

oc

cupi

ed b

y a

mou

nd th

at

may

pro

tect

the

pow

er p

lant

at

leas

t par

tially

in th

e ev

ent

of a

tsun

ami h

eadi

ng in

from

a

SE d

irect

ion

Eart

hqua

ke P

roof

? De

pend

s on

seve

rity

Fi

re sa

fety

mea

sure

s ava

ilabl

e Ef

fect

iven

ess n

ot m

easu

rabl

e

Durin

g O

ptio

n A

ON

LY: S

ite B

re

mov

ed a

nd p

rote

ctio

n lo

st

Eart

hqua

ke P

roof

? De

pend

s on

seve

rity

Fire

safe

ty m

easu

res a

vaila

ble

Effe

ctiv

enes

s not

mea

sura

ble

Afte

r (sh

ort-

term

) O

ptio

n A

ON

LY: N

o Pr

otec

tion

Opt

ions

B a

nd C

ope

n to

risk

s Ea

rthq

uake

Pro

of?

Depe

nds o

n se

verit

y Fi

re sa

fety

risk

s enh

ance

d

Afte

r (lo

ng-t

erm

) O

ptio

n A

ON

LY: N

o Pr

otec

tion

Opt

ions

B a

nd C

ope

n to

risk

s Ea

rthq

uake

Pro

of?

Depe

nds o

n se

verit

y Fi

re sa

fety

risk

s enh

ance

d

No

chan

ge

Min

imal

Cha

nge

Posit

ive

Heal

th E

ffect

s N

egat

ive

Heal

th E

ffect

s

23

33 Expected change and health impacts of the Project

This section deals with the expected and potential health impacts from the implementation of this project, comparing current baseline levels, when available, with those being modelled by experts in their respective fields (when available). These comparisons are reliant on the accuracy of assumptions upon which these predictions are based.

3.1 Air pollution Overall, the construction of the new CCGT natural gas power plant, the closure of the Marsa power plant and the conversion of the current DPS turbines working on HFO to natural gas should decrease the levels of Air pollutants released, and subsequently, the project should have an overall positive effect on health. Levels of air pollutants, in their majority, have been projected to stay within EU limits, as stipulated by EU directives, should the models be reliable. This is in keeping with the known properties and effects of Natural Gas power plants and the reason for which this is considered a cleaner source of energy.

The Air Quality report attached with this EIA goes on to model projections for various scenarios for the 2015+ scenario, each with its own projected emissions. However, it is safe to say that a significant drop in emissions of Nitrous Oxide (including NO2), Particular Matter (PM10 and PM2.5) and of Sulphur Dioxides are expected, with ultimately positive effects on lung function and on health in general, even if these are difficult to quantify. A small reduction in deaths (as per the Harvard 6 Cities study) would also be expected.

The report uses the assumption that the electricity demand in 2020 does not exceed current levels with an added 25%, and that this level can be met by the Interconnector and the two gas fired units at the DPS, with the OCGT and old CCGT serving only as emergency backup, to predict the following emissions:

Pollutant Target tons Tons/yearNO2 1,850 1,041

PM2.5 0.330 0.315

3.1.1 Nitrous Oxides (including NO2)

On average, in 2008 average NO2 emissions across Malta and Gozo were around 28.7μg/m3, which is lower than the EU Air Quality Standards established in 2010 with a limit of 40μg/m3 over a year. This level is however often exceeded in some locations. Levels three times the maximum EU limit amount have been recorded: the highest level recorded since 2007 was in Floriana, where a level of 129μg/m3 was recorded in August 2008.

Modelling for NOx emissions – main sources being MPS, Freeport and Airport

Modelling foooor rrrr NONONNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNN xxx x xx x xxx eeeemissions – mamaamaaaaininnininininnnn sources being MPMM S,S,SSS,S, FFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFrereeeereeeeerer epepepeppepeppepepepepororoororororororortttttttt and Airport

24

As can be seen in the image to the left, taken from an air dispersion modelling software used for this assessment, one can note that the major sources of NOx emissions, besides traffic, are the Marsa Power Station, the Airport and the Freeport. The following table illustrates the current NOx contributions from Delimara Power Station and the expected value:

ScenarioFor NOx

Average( m3)

annual max ( m3)

Baseline 0.45 8.652015+ 0.15 4.85

A reduction of NOx emissions by an estimated 200g/s (a reduction of around 50% from current baseline levels), with various assumptions upheld in the Air Dispersion modelling report should see a positive health benefit in the local population, especially with the closure of the Marsa Power plant

Should the projected levels play out as predicted, we could expect a slight decrease in respiratory illness and an improvement in lung health in the local population. However, this can be heavily confounded by the rise in vehicular traffic and resulting emissions, as well as through the presence of other air pollutants including natural ones and one may therefore not see any sudden drop in illness in this respect. This is also because several milder forms of respiratory illness would not normally get reported through official channels and thus be missed, except through routine reporting at primary health care level.

33.1.2 Particulate matter (PM10 and PM2.5) According to the Air Dispersion Report (EIA, August 2013) in the local scenario, it is important to note that, at times, a very high proportion of PM (up to 85%) in the air is actually originating from natural sources, namely desert and other dust and sea spray particulates. The former is due to the construction industry, the semi-arid landscape of the Maltese islands with an increased likelihood of dust becoming airborne, and also due to the close proximity of Malta to the Sahara Desert south of Malta. This was clearly seen during a recent high-pressure system over Malta in May 2013 (Times of Malta, May 2013) that led to a large amount of dust in the atmosphere coming from a dust storm in North Africa that drastically reduced visibility and led to an increased number of people with health complaints at hospital.

It is predicted, through modelling, that we could see a reduction of 130g/s in levels of particulate matter

currently being emitted by power generation activities in Malta in the 2015+ scenario compared to the present. This translates into a reduction of 90% from current baseline levels.

This projection assumes minimal use of the gasoil generators as backup and maximal use of natural gas facilities and the interconnector. The gasoil units (OCGT, old CCGT units) would contribute significantly to particulate matter, whereas the planned CCGT plant

Modelling for PM10 emissions shows the Grand Harbour area (MPS included) and the freeport being main sources of particulate matter

25

would contribute no particulate matter to the local scenario.

Pollutant Target tons Tons/yearNO2 1,850 1,041

PM2.5 0.330 0.315 The above table assumes the best case scenario, where energy demands by 2020 are not expected to be more than 25% from current levels, and that the use of the 2 gas plants at DPS and interconnector would be sufficient to meet electricity demand. One can note that PM2.5 particularly is emitted in very low amounts.

33.1.2.1 PM 2.5 and association with negative health outcomes

PM 2.5 is nowadays considered to be the more dangerous category of PM as it is ultrafine, and can be absorbed in the bloodstream. A study conducted in 2013 had found that there is a strong association between mortality from both respiratory and cardiovascular causes in the Mediterranean region. The following table illustrates such a relationship, and we have highlighted the two parameters for which we have clear data for this study. (Associations between Fine and Coarse Particles and Mortality in

Mediterranean Cities: Results from the MED-PARTICLES Project, Samoli et. al, 2013).

3.1.2.2 The 2015+ emissions scenario

The 2015+ scenario, considering every point stack at DPS, can therefore be summed up as follows, in g/s.:

source capacity MW avg load% NO2 PM2.5DPS OCGT 74 20 15.0 0.14DPS CCGT 110 11 11.6 0.12DPS3 149 30 11.5 0new CCGT 200 73 10.1 0

total emissions, energy sector 2015+ 48.2 0.26

Percent increase (95% CI) in mortality associated with 10- m3 increase in fine and coarse particles for selected lag periods.a

Primary pollutant Second pollutant All-cause mortality (lag 0–1) Cardiovascular mortality (lag 0–5) Respiratory mortality (lag 0–5)PM2.5

None 0.55 (0.27, 0.84) 0.86 (0.15, 1.57) 1.91 (0.71, 3.12)+SO2 0.33 (–0.37, 1.03) 0.56 (–0.60, 1.74) 1.98 (–0.01, 4.01)+NO2 0.28 (–0.12,0.68) 0.64 (–0.30, 1.60) 2.15 (0.40, 3.94)

+O3 0.46 (0.16, 0.76) 0.94 (0.16, 1.73) 2.45 (0.94, 3.97)+PM2.5–10 0.59 (0.00, 1.18)* 1.35 (0.44, 2.26) 3.44 (1.63, 5.29)

PM2.5–10None 0.30 (–0.10, 0.69) 0.33 (–0.78, 1.46) 0.76 (–0.70, 2.25)+SO2 0.13 (–0.40, 0.66) –0.09 (–1.30, 1.13) –1.01 (–4.30, 2.38)+NO2 0.06 (–0.53, 0.66) –0.17 (–1.27, 0.95) –0.25 (–2.91, 2.45)

+O3 0.22 (–0.50, 0.95) 0.21 (–1.11, 1.55) –0.19 (–2.60, 2.29)+PM2.5 –0.05 (–0.84, 0.75) –0.28 (–1.36, 0.81) –0.85 (–2.81, 1.15)

aResults from second-stage random-effects models pooling estimates from city-specific 2-pollutant Poisson models adjusted for seasonality, temperature, day of the week, holidays, influenza, and summer population decrease. *Statistically significant heterogeneity as indicated by p < 0.10 from Cochran’s Q and I 2 > 50%.

26

With this considerable reduction we can expect again a decrease in respiratory illnesses – both mild , such as allergic rhinitis, and severe such as asthma and bronchitis, as well as a reduction in cardiovascular illness . However, a parallel rise in vehicular traffic and the continuing activities of the construction industry can also potentially confound the positive effects that can be expected from this decrease in emissions. It is also important to note that at times, a significant proportion of PM in Malta remains that from natural background sources (dust and sea spray particulates) which cannot, at least at the present time, be mitigated.

33.1.3 Sulphur Dioxides Sulphur Dioxide emissions are expected to drop significantly. Natural Gas, as opposed to Heavy Fuel Oil, is not contaminated with sulphates when it is at the delivery stage, and we can therefore expect a positive health outcome as regards the negative health impacts of sulphur dioxides outlined in Section 2 above.

Although current and projected levels of sulphur dioxide have been requested in order to fully quantify their potential impacts on health, as befits a comprehensive HIA, these have not been forthcoming and as such we are unable to discuss their health impacts. We are therefore assuming that the World Bank data in the table on the next page hold true, and that Natural gas would be free of Sulphur compounds.

3.1.4 Ozone (O3) and Volatile Organic Compounds (VOCs)

As stipulated in Section 2 above, both Ozone and VOCs warrant a detailed mention and assessment in a Health Impact Assessment in relation to such a project. Both are known to have significant effects on health, especially via tropospheric ozone, which has well documented negative respiratory health impacts.

However, no baseline levels or projected emissions were provided for these two categories of pollutants. We therefore are not able to discuss their health impacts at this stage, and would recommend studies (and the implementation of any available mitigation measures) be carried out in due course in order to address any potential future impact from these significant pollutants.

27

Tabl

e ob

tain

ed fr

om: E

nviro

nmen

tal,

Heal

th, a

nd S

afet

y Gu

idel

ines

: THE

RMAL

PO

WER

PLA

NTS

, Wor

ld B

ank,

200

8.

Ta

ble6

(B)-

Emiss

ionsG

uideli

nes(

inmg

/Nm3

or a

s ind

icated

)for

Com

busti

onTu

rbine

Note:

-Gu

idelin

esar

eapp

licab

lefo

rnew

facil

ities.

-EA

may

justify

mor

estr

ingen

torl

ess

string

entl

imits

due

toam

bient

envir

onm

ent,

techn

icala

ndec

onom

icco

nside

ratio

nspr

ovide

dth

ere

isco

mpli

ance

with

appli

cable

ambie

ntair

quali

tysta

ndar

dsan

dinc

rem

ental

impa

ctsar

emini

mize

d.-

Forp

rojec

tsto

reha

bilita

teex

isting

facil

ities,

case

-by-c

ase

emiss

ionre

quire

men

tssh

ould

bees

tablis

hed

bythe

EAco

nside

ring

(i)th

eex

isting

emiss

ionlev

elsan

d im

pacts

onthe

envir

onm

enta

ndco

mmu

nityh

ealth

,and

(ii)co

stan

dtec

hnica

lfeas

ibility

ofbr

inging

theex

isting

emiss

ionlev

elsto

mee

tthes

enew

facilit

ieslim

its.

-EA

shou

ldde

mons

trate

that

emiss

ionsd

ono

tcon

tribut

ea

signif

icant

portio

nto

the

attain

men

tofr

eleva

ntam

bient

airqu

ality

guide

lines

orsta

ndar

ds,a

ndm

ore

string

entli

mits

mayb

ereq

uired

.Co

mbu

stion

Tech

nolog

y/Fu

elPa

rticula

teMa

tter(

PM)

Sulfu

rDiox

ide(S

O 2)

Nitro

genO

xides

(NOx

)Dr

yGas

,Exc

ess

O 2Co

ntent

(%)

Com

busti

onTu

rbine

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28

33.1.5 Air Pollution: Conclusion

It is important to note that it is impossible to fully quantify the effects that a reduction of any particular air pollutant would have on the health of the population. This is due to the lack of local data in Malta regarding the correlation of air pollution and health impacts, the methodological difficulties in directly linking air pollutants with levels of illness in individuals, and the lack of baseline levels of several among the different pollutants,. One cannot, for example, with the data given, safely state that a reduction of 50% in NOx levels, for example, would lead to 50% less cases of asthma per year. This holds true because we are unable to say how many current day asthma cases can be ascribed to NO2.

This is further compounded by the fact that Malta, being such a small island with a high population density, there exist too many confounding variables for us to safely make such a statement. Additionally, Malta’s population is too small for any differences in levels to achieve sufficient statistical power to confidently give expected quantifiable results.

Despite these limitations, we can still attest that, should projections prove to be valid, one would expect the stated positive effects on health and reduced respiratory illness (and even mortality) due to air pollution, especially when considering the energy sector as an individual contributor to air pollution in Malta.

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3.2 GGreenhouse Gas Emissions

There is, with almost absolute certainty, ample evidence that anthropogenic Greenhouse Gas Emissions (GHGs) are contributing to the current global warming and subsequent climate change. The main gas responsible for such warming is Carbon Dioxide, CO2, which is emitted on combustion of fossil fuels, on which our modern global economy relies to a large extent.

3.2.1 GHGs emissions – long term effects of CO2 and impact on health

3.2.1.1 Climate Change Effects on health Climate Change is expected to affect different areas of the globe in different ways. In the case of the Mediterranean region, one can expect a more intense precipitation period, followed by longer dry seasons that can severely impact on food production and water scarcity. In Malta, already having the highest water scarcity in Europe, this is particularly alarming. From a health perspective, this is particularly important as adequate supplies of water are crucial to the health of a population. Experience shows that we can rely on desalination for our water to a large extent. However, this could entail increased energy consumption and costs.

The shifting temperatures over the Mediterranean could also lead to new disease vectors being introduced in Malta (a phenomenon recently heralded by the arrival of the Asian tiger mosquito) which would re-establish diseases that have been eradicated, such as Malaria, and potentially introduce new tropical diseases which would have an impact on the local population’s health.

Sea water levels are also set to rise in the coming decades. These can have an indeterminate impact Malta’s economy, which relies heavily on maritime traffic and infrastructure. This could also ultimately impact on the health of the population, both because of increased water scarcity.

It is therefore important that we strive to mitigate GHG emissions and play our part to help prevent the dire consequences of climate change from happening.

3.2.1.2 Malta and GHG emissions Malta has long been reliant on fossil fuels for its power generation. Although there has been an increase over the past decade in domestic renewable power generation, mainly in the form of solar PV panels applied in the domestic setting (thanks also to government subsidies), these are very far from contributing significantly to Malta’s power generation at this point in time and to helping the country achieve its targets for reliance on alternative energy sources.

“Malta emits around 2,500 Gg of CO2, less than 0.01% of the global total .” Eurostat news release on Carbon Dioxide Emissions. 2013, Eurostat Press Office.

It can be argued that Malta’s current negative contribution to climate change is so insignificant that it can be deemed negligible. However, one cannot use this argument as an excuse not to play its own part in reducing GHG, especially in an atmosphere that has no boundaries. Our own contribution to climate change and mitigation should be of concern to everyone, regardless of how significant our current contribution is on an international scale.

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33.2.1.3 The proposed DPS project and GHG emissions

The conversion project at Delimara is a step in the right direction in this regard, since Natural Gas is considered a cleaner and less carbon-intensive fuel than more traditional fuels such as gasoil, or heavy fuel oil. Carbon dioxide emissions are expected to decrease significantly with this development, which will not only help meet EU targets for lower GHG emissions, but also help satisfy our moral responsibility. In our view, this is desirable, especially since Malta stands to suffer particularly from climate change impacts, given its small insular size and dependence on favourable weather conditions. It will also have a likely longer term positive effect on the help of future Maltese populations.

The table here shows a comparison of g of CO2 produced per different category of thermal power plant.

As one can note, the CO2 per KwH of a Gas CCGT system is not only more efficient than an HFO system (highlighted orange), but is also less carbon intensive. This translates into less CO2 per KWh produced.

It is hoped that an eventual consideration of non-fossil fuel alternative energy sources as per our EU responsibilities would be the next step in the environmentally correct direction, which would also prove to be of maximum health benefit to Malta’s future generations.

The interconnector project with Sicily is also expected to contribute significantly to Malta’s energy mix. It is desirable, in our view, that the source for this electricity comes from

renewable sources – otherwise we would be simply exporting our challenge to reduce carbon dioxide emissions to another country.

3.2.1.4 Natural Gas: Methane as a GHG. One of the main components of Natural Gas, (in this case, LNG) is methane. Methane (CH4) is 30 times more effective as a GHG as carbon dioxide, the traditional nemesis of climate change. It is therefore very important that any leaks in delivery and use of this gas be identified and tackled

Typical CO2 Emissions Performance of New Thermal Power Plants

Fuel Efficiency CO2 (gCO2 /kWh – Gross)

Efficiency (% Net, HHV)Coal (*1, Ultra-Supercritical (*1):

676-795*2) 37.6 – 42.7Supercritical:35.9-38.3 (*1) 756-83639.1 (w/o CCS) (*2) 76324.9 (with CCS) (*2) 95Subcritical:33.1-35.9 (*1) 807-90736.8 (w/o CCS) (*2) 80824.9 (with CCS) (*2) 102IGCC:39.2-41.8 (*1) 654-71938.2–41.1 (w/o CCS) (*2) 640 – 66231.7–32.5 (with CCS) (*2) 68 – 86

Gas (*2) Advanced CCGT (*2):35550.8 (w/o CCS)

43.7 (with CCS) 39Efficiency (% Net, LHV)Coal (*3) 42 (Ultra-Supercritical) 811

40 (Supercritical) 85130 – 38 (Subcritical) 896-1,05046 (IGCC) 76038 (IGCC+CCS) 134

Coal andLignite (*4, *7)

(*4) 43-47 (Coal-PC)>41(Coal-FBC)42-45 (Lignite-PC)>40 (Lignite-FBC)

(*6) 725-792 (Net)<831 (Net)

808-866 (Net)<909 (Net)

Gas (*4, (*4) 36–40 (Simple Cycle GT) (*6) 505-561 (Net)*7) 38-45 (Gas Engine) 531-449 (Net)

40-42 (Boiler) 481-505 (Net)54-58 (CCGT) 348-374 (Net)

Oil (*4,*7)

(*4) 40 – 45 (HFO/LFOReciprocating Engine)

(*6) 449-505 (Net)Efficiency (% Gross, LHV)Coal (*5, (*5) 47 (Ultra-supercritical) (*6) 725*7) 44 (Supercritical) 774

41-42 (Subcritical) 811-83147-48 (IGCC) 710-725

Oil (*5, (*5) 43 (Reciprocating Engine) (*6) 648*7) 41 (Boiler) 680Gas (*5) (*5) 34 (Simple Cycle GT) (*6) 594

51 (CCGT) 396Source: (*1) US EPA 2006, (*2) US DOE/NETL 2007, (*3) World Bank,April 2006, (*4) European Commission 2006, (*5) World Bank Group, Sep2006, (*6) World Bank Group estimates

Table obtained from: Environmental, Health, and SafetyGuidelines: THERMAL POWER PLANTS, World Bank, 2008.

31

immediately, not solely out of direct health and safety concerns, but also from a climate change perspective.

33.2.1.5 Other GHGs: Ozone In addition to its effect causing respiratory irritation, tropospheric Ozone is also a GHG. This pollutant is oftentimes produced by the reaction of Volatile Organic compounds (VOCs) with NOx, such as NO2. Mitigation of emissions of Ozone and VOCs should therefore tackle the emissions of these additional GHGs.

3.2.1.6 Conclusion: Greenhouse Gases With climate change being such an important factor in assuring a safer and healthier environment, its mitigation is the most logical and straightforward manner in addressing the problems it poses.

The move towards a cleaner source of fuel is therefore an encouraging step in the right direction, as natural gas is less carbon intensive than the heavy fuel oil and gasoil it will replace.

It should be the ultimate aim, however, to move next towards a carbon-free electricity generation infrastructure for Malta. This is extremely challenging in the local context, given the costs it would involve and the very limited local natural resources land area. However, with an ever more innovative and fast-evolving market, future decades could provide the answer in terms of alternative energy power to meet Malta’s energy needs in a sustainable manner. This would not only be of environmental benefit but also of health benefit to the local population

3.3 Noise Pollution Noise pollution has been found to have considerable effects on health. This includes not just the mental health aspect, due to increased stress, insomnia and irritation, but also it as an effect on the physical health of the person. Studies have found a relationship between noise pollution and cardiac illness – this is probably due to the link between mental health and the actual physical effect that has on the body (stress does increase the heart rate and also blood pressure, for example). Hearing loss also is another serious result of frequent exposure to high noise levels.

In view of this, noise pollution needs to be taken seriously. Noise pollution studies, however have shown that there will be a negligible increase of noise pollution levels in the surrounding areas. Currently around 40-50 metres away from the plant, noise levels stand at around 40-50 db, which is well within recognised safe EU health limits. In the 2015+ scenario, noise levels are not expected to increase significantly. This of course depends on which options (from A, B or C) are chosen for the siting of the storage and regasification of natural gas. Should the mixed or totally offshore options be considered, one can see the reported projection of a higher level of noise at the mooring site. However, it is unlikely that this will have an effect on the majority of the local population of Marsaxlokk as the noise levels, besides being low, will be too far away to cause any disturbance to the local population.

There is also expected to be a minimal increase of employment on the site, without significant increase in vehicular traffic. Thus, one can expect a negligible (if not entirely absent) increase to noise pollution on the routes to the Delimara power plant, and this will in turn most likely not affect the health of the population in any way.

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33.3.1 Construction Phase During Construction of the Site one can expected elevated noise levels that could annoy the local residents of Marsaxlokk. However, noise levels are not expected to be excessive and would mostly affect neighbouring residents in the immediate vicinity.

In the Noise pollution report received as part of this EIA, a worst case scenario was envisaged. For Option A, the scenario where most noise is generated was assumed, with work being done on all three sites of the project at the same time, during a 12 hour day period. Traffic noise generated in this scenario was also modelled and is visually displayed below.

This image shows that in inhabited areas the noise level is expected to be in the 40-50 Db range, corresponding to the sounds of a quiet street, which is within the safety limits recommended by the WHO Europe during the day. During the night this is expected to be lower as less work will be done at that time. This translates into safe noise levels as discussed in the WHO Europe report on Night noise published in 2009. The noise at the sites of construction is expected to be much higher, however, so appropriate mitigation measures should be provided to the workers on site.

We therefore anticipate no negative health impacts on the population of Marsaxlokk during construction, and such sufficient mitigation tools be provided to workers on the site, minimal health impacts on workers at the site of construction.

Construction Phase: Expected noise level in worst case scenario

33

33.3.2 Operational Phase

This noise levels during operation of the DPS plant depends mostly on the Option selected from Options A, B, and C. Noise pollution modelling has been carried out to estimate the difference in

levels of noise from the current situation as opposed to the different scenarios being presented:

Option A

This option has the least noise increase for all three scenarios. However one should not that any increases in noise in residential areas are minimal – indeed a decrease in noise levels is to be expected for Marsaxlokk village.

Option B

Option B is slightly noisier than option A. Again, however, for most of Marsaxlokk Village noise coming from the DPS is expected to decline slightly. Some noise increase is deflected towards Fort Delimara, which could become a tourist attraction should rehabilitation of the site occur, potentially affecting tourists. However the noise increase is minimal (4-8 db more).

Option C

This option offers the largest noise increase from all three scenarios, mainly around the offshore platform in the outer part of Marsaxlokk bay. It should be noted however that most of the noise is deflected onto the bay facing south, so that, again, Marsaxlokk village should experience a decrease in noise levels coming from the DPS.

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3.4 WWater Pollution Water Pollution has to be considered on two levels:

3.4.1 Chemical Pollution in Marsaxlokk Bay

The sea water at Marsaxlokk Bay is set to have a minimal chemical pollution increase as a result of this project, as only six (6) additional vessels a year are expected to enter the harbour (in addition to the circa 2000 vessels entering the harbour every year). Thus, one can expect only a minor increase in chemical and hydrocarbon pollution in the waters of the bay.

It is important to note, however, that aromatic and petroleum hydrocarbons, which are carcinogenic, are currently already found to be measurable at elevated levels in the bay. This is to be expected due to the harbour activities occurring on a daily basis in the location. As a mitigation effort, following information gathered from this assessment, efforts should be made to notify any prospective swimmers on the polluted nature of the bay and advise them to swim elsewhere as a precaution.

Copper was also found inside Marsaxlokk Bay to be at levels just above detection limits. The health effects of long-term exposure to copper can cause irritation of the nose, mouth and eyes. It also causes headaches, stomach aches, dizziness, vomiting and diarrhoea. Intentionally high uptakes of copper may cause liver and kidney damage and even death. Whether copper is carcinogenic has not been determined yet. Being found at such low levels (although exceeding the recommended amount), health effects of this level of copper are uncertain.

Heavy metals such as cadmium and chromium have also been found in the superficial marine sediments at the bottom of the bay. These chemicals have carcinogenic effects upon long-term exposure, along with other effects associated with heavy metal deposition such as liver disease. However it should also be noted that being at levels below various guidelines and the EQS (except for cadmium), these shouldn’t be of concern to health.

In the case of cadmium, elevated levels were found that seem to point to the DPS activities being the primary source. However this could also be due to other important sources at the site (similar levels have also been found at the Grand Harbour and Marsamxett Harbour), and warrants further investigation.

3.4.2 Detection of Mercury in Marsaxlokk Bay During investigations that were conducted for the Water Quality Assessment, mercury levels well exceeding the maximum amount allowed by AA-EQS water quality guidelines were detected in over 12 out of 18 samples. This assessment was carried out over 9 months, so this is not a one-off scenario.

Mercury is highly toxic, especially as it accumulates in the filter-feeding fauna of the bay, and ultimately bioaccumulates higher up in the food chain. Any elevated levels should be taken very seriously. For both environmental and health concerns, this detection of Mercury should be investigated, and any sources discovered ought to be dealt with as soon as possible.

3.4.3 Construction Phase During the Construction phase one can expect an increase in turbidity of the water due to activities occurring next to the DPS, including the projected dredging activities for a possible new quay. This is expected to cause minimal danger to human health. However, it may affect the ecology of the bay

35

(especially the Posedonia meadows relatively close to the DPS) which might in turn affect the fish stocks of surrounding waters.

33.4.3.1 Option A – Site B removal Should Option A be opted for, this would require the removal of the mound currently occupying Site B so that four cryogenic LNG tanks could be placed on the site. The volume required to be removed is estimated at 45,000 m3, which would need to be deposited or placed elsewhere.

The removal of this level of debris would lead to large volumes of dust being generated which could negatively affect the health of neighbouring Marsaxlokk residents and workers on the site.

3.4.3.2 Jetty Construction The surface area of potential land reclamation so as to accommodate a jetty for the LNG tankers may be up to 8400 m2. This will probably be all along Area B, extending it approximately 30 m into the sea, according to the Water Quality Assessment report. The amount of material required to fill in this area for land reclamation, may be roughly estimated to be 20,000m3 (assuming a water depth of 2 to 3m).

This should not negatively impact the health of the population, in spite of the damage done to the ecology of the bay. However the dust generated through land reclamation activities could negatively affect people in the vicinity, as mentioned above.

It is important that any excavation material that is generated from coastal works at Area B be disposed of safely, so that in the event that it may be contaminated, negative health impacts would be mitigated.

3.4.3.3 Dredging Activities in Marsaxlokk Bay It is likely that some level of dredging will be carried out in the bay so as to accommodate the activities that will be required for the DPS to operate effectively. This would involve the disturbance of surface marine sediments which have mostly low levels of contamination with heavy metals. These however could have negative effects on the health of individuals exposed to such sediments, such as bathers or water sports enthusiasts.

3.4.3.4 Spills and Chemical Pollution during Construction Additionally, any spills or chemical pollution of the bay during this phase needs to be taken into account. People still fish from the quay next to the bay, and this should be strictly prohibited, especially since there have been elevated levels of Mercury reported immediately in front of the DPS.

The increased turbidity in the water generated during this phase should have no health effect on swimmers in the area. Should Options B and C be selected, this risk would be eliminated as no landscaping will occur, and the construction of the jetty isn’t expected to cause any significant pollution.

3.4.4 Operational Phase During normal operations in the bay, it is expected that there will be very little effect, if at all, on the pollution in the bay. There might be a slight improvement in the longer term water quality as air pollutants currently being released from the power station will drop significantly, leading to less settling of particulate matter and other chemicals into the water surrounding the DPS.

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33.4.5 Water Effluent Release at -

This seawater is later released back into the sea on the Hofra z-Zghira side of the Delimara Peninsula

pollution. The average volume of water used for cooling currently is around 43,000 cu.m/hr.

The release of water effluent is expected to ultimately decrease in volume once the new natural gas plant is in operation., One can also expect a drop in the thermal pollution of the same affected bay. The water quality of the bay, as confirmed by both the marine ecology assessment and the water quality assessment in this comprehensive EIA, is currently in a very good state, although there appear to be periods of temporary worse water quality effluents at times in the current set up, possibly when cooling machinery is being cleaned chemically. It is expected to remain this way or improve further when the new NG plant is running.

The cooling water released into the Hofra z-Zghira bay is treated by additives/chemicals – Biocaf and Sulphuric Acid . The sulphuric acid and Biocaf are combined so that chlorine dioxide is produced, which acts as an effective biocide agent that serves to maintain the operational efficiency of the plant.

The concentration of chlorine dioxide at the outflow site of the plant is minimal – around 0.1ppm. This residual chlorine dioxide naturally breaks down into oxygen and chlorine, which are absorbed by the sea water. With an increase in local power generation, one can expect larger amounts of both sulphuric acid and biocaf to be used, however the resulting chlorine dioxide is in such a small amount that health impacts are virtually negligible, if any.

Any other effluents that could be released

from the cooling water outflow would warrant further investigation from a health perspective. However there is no more information available on any further effluents released.

The effluent is currently treated with chlorine dioxide (ClO2), and this is expected to remain the same when the new plant comes into action. This should cause minimal changes on water quality, as the substance breaks down on exposure to

The Water Effluent on the day of our site visit

37

sunlight into its components (chlorine and oxygen), which are harmless to humans at such a dilute level.

For a number of parameters, levels of contaminants are present both at the inlet and outlet sites for the thermal outflow. This indicates that the particular contaminant has not necessarily been released by the direct operations of DPS. This therefore points to a source which has yet to be identified, and dealt with not only for environmental reasons, but also for the health of the general population.

The monitoring of the site, however, also pointed to some traces of metals being released. These include Zinc, Cadmium, Copper and Arsenic, which were higher in the bay outflow site than at the inlet. Suspended solids were also found to be released into the bay. These were mostly just above the detectable level, and are in very small amounts. The difference from the inflow and outflow sites indicated that the DPS may indeed be the source of these contaminants.

It should be noted, however, that taking into account the very large volumes of water being discharged into the - (around 43,000 m3 per hour), daily releases of these contiminants are minimal on a daily level – amounting to not more than 0.5kg of suspended solids, 0.5g of Zinc, 0.1g of copper and arsenic . These, coupled to the high water circulation levels in the outflow, amount to a minimal effect on water quality, and we are unable to ascertain any attributable hazard to bathers in the area.

33.4.6 The Re-gasification Process: Seawater use During the regasification process, seawater will be used to warm up the LNG. The same biocides that are currently used for the cooling waters (Chlorine Dioxide) will be used for this process.

The water being used will be discharged at a temperature below ambient near the current inlet for the cooling water of the DPS. At a temperature approximately around -5°C compared to ambient temperature, this should make the process of cooling of the DPS more efficient.

Since no bathers are expected to be in the vicinity of the inlet, this should not endanger the health of the population. Additionally, no contaminants, such as methane of LNG constituents are expected to contaminate this waste stream.

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3.5 SSocial Impact

The perception of the residents of Marsaxlokk, being closest to the DPS site, is very important not only for obvious economic, political and environmental reasons, but also from a health perspective. Often, should one perceive a project to be negative, the additional stress of knowing that one is living proximal to an “undesired” site can lead to negative health impacts. On the other hand, a positively perceived intervention could go a long way to addressing the current situation and improve it for the better.

Although highly subjective in nature, these views should not be viewed as irrational and unimportant, especially because they are provided by people living at the locality, who have day-to-day experience of living with the site in plain view. Their experience should substantiate the assessment of the project – ultimately, they stand to experience first-hand what to most people in Malta is somebody else’s problem.

3.5.1 Fears expressed regarding the DPS Project The social impact assessment carried out for this project involved the interviewing of stakeholders from the villages of Marsaxlokk and neighbouring Birzebbugia. It is important to note that these two populations are not representative of the general local population – however, being the people living permanently in proximity to the site, the importance of this qualitative work should not be underestimated. It should also be noted that the study was not a quantitative one and the sample cannot be taken as representative of the resident population

The assessment conducted has found that some of the residents of both villages, especially those of Marsaxlokk, are very much concerned about anything that happens in their locality which they deem would have an impact on their health and environment. The interviews with local residents clearly showed a concern especially as regards the current situation, with many residents pointing to the DPS as a source of “Black dust” that occasionally falls on the area and found to cover the rooftops and clothes put out to dry – many blame various health ailments on this pollutant.

These views should be taken seriously, especially because most residents in the area feel they have been unfairly treated when the Delimara Power Station was constructed at the site in the early 1990s. Many residents interviewed expressed concern that they have seen a decline in health since that time, and most blame the power station as being the cause.

The main areas of concern identified for this DPS project are i) Noise; ii) Dust levels; iii) Environmental impact during dredging and construction works and iv) large-scale hazards such as “gas fireballs” and other events. These fears should be addressed, and local resident be accurately informed in detail on the project, and reassured accordingly that all measures necessary be taken to minimise impacts on their daily life.

Additionally, the removal of the 150m chimney currently in place is strongly desired (although ironically created to disperse emissions further afield than the locality itself). The options where regasification and storage is offshore are also preferable to the local residents. The residents also expressed a preference that these be located outside the port should that option be feasible, so that the visual impact would be reduced, and also so as not to disturb the path of fishing vessels leaving the bay.

In view of all this, with air pollution set to drop significantly once the new plant is operational, one should expect a better perception of the site and of its health implications. The removal of the 150

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metre chimney in particular, being a constant very visible reminder of the site, should signal an improvement to the local residents.

33.5.2 Other concerns The following modified table illustrates the results from the Social Impact Assessment as regards perceptions on multiple issues of social interest:

Impact M’Xlokk B’Buga Comments

Well-being Positive Positive The project will have a positive effect on improving the health of residents.

Recreation Positive Positive As the result of a cleaner environment, the project will have a positive effect on the residents’ ways of relaxation.

Personal rights Positive Positive As the result of a cleaner environment, the project will have a positive effect on residents’ citizenship rights.

Property rights Positive Positive As the result of a cleaner environment, one expects that - at least - property values will not fall.

Tourism Positive Positive

As the result of a cleaner environment, and the eventual removal of the chimney in Marsaxlokk, one expects that the tourist impact will improve.

Road traffic Negative

(short-term) None

Whilst Marsaxlokk residents expects road traffic to increase during the construction phase, it was generally accepted that once this stage is completed, vehicular traffic become normal once again.

Maritime traffic Inconclusive None

Many residents in perceived that the construction of a jetty and the presence of the storage tanker in Marsaxlokk Bay has the potential to hinder the coming and going of fisher vessels. However, it is noteworthy that a number of interviewed fishermen did nor corroborate such a perception.

In this table we have included those factors where a change - negative or positive, was perceived by the community to be expected as regards the project.

As one can see most people perceive effects of this project to be positive. This should translate, on a mental level, on feeling less “victimised”, and therefore less stressed, mentally, than with the current situation. Most stakeholders commented on the fact that they expect a cleaner

Table modified from Social Impact Assessment, Marvin Formosa, 2013

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environment, and hence a healthier one. This perception is borne out by the available literature and could translate into a real positive health outcome.

33.5.3 Employment on site During the construction phase of the CCGT power plant extension and conversion of the current HFO plant to Gas, one can expect an increase in the number of people being employed. This would have a positive health impact on society in general due to decrease in unemployment. Unemployment has been a well-studied factor that contributes to elevated stress levels in society in general, and unemployed people tend to be worse off, in health as amongst other things, than employed people. This however is most probably a temporary effect – during operations phase there will only be minimal increase in employment. It is expected that the offshore instalments should employ a few more people, to carefully manage the transfer of LNG from tankers onto onshore storage/ operations.

3.5.4 Long-Term benefits from the project The current power plants in Delimara and Marsa have a nominal gross supply capacity of 620 MW. With the closure of the Marsa power station, the new CCGT plant at Delimara and the Interconnector project with Sicily, the total gross supply capacity is expected to increase to around 733 MW. This means that the local economy could support more energy-intensive industries which could employ more people. Should this come to pass, it would further reduce unemployment in Malta in the long-term, with resulting improvements in socioeconomic status and health.

3.5.5 Economic Savings due to use of Natural Gas

Currently, Natural Gas is cheaper than Oil. This means that the shift to natural gas, should theoretically lead to lower energy prices, although the cost of shipping and storage is not included in this assumption. However it can be assumed that even after shipping and storage costs, overall prices of natural gas should be lower, should the markets remain stable. As a result of lower prices, one can assume that this would lead to lower energy prices so that the general population could afford to purchase more appliances such as air-conditioning units. This could lead to a net positive impact on the health of the population.

3.5.6 Land Value: Expansion of Estate

There currently are places of habitation in the vicinity of the power station well within a 500 m radius. These, however, are a few villas which were there before the construction of Delimara power station in the 1990s. The part of Marsaxlokk village proper which is closest to the power station is around 650m away from the site.

As can be expected due to the noise and air pollution in the air, and the eyesore of the Delimara Chimney that is a 150m tall, land prices in this area are likely below average for such properties. This

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probably has a negative health impact on the people living in the area as it could cause undue stress, and can lead to poor health (even when one excludes the negative health impact of being exposed to pollution, etc.).

Agricultural land in the area was described in the year 2000 as being “agriculture with significant areas of natural vegetation” by MEPA .The site is surrounded by terrestrial environmental designations as per MEPA web site and as described in the PDS of this project. These sites include terrestrial habitats (salt marsh, woodland, trees and shrubs, and maritime garrigue).

With an expected decline in airborne pollution and hazard waste, the value of the land is expected to rise, though the very knowledge of being close to a power station will probably limit land value price increase. One can also expect the agricultural produce of the area to be safer, due to less air pollution in the area, which could have a tiny, but positive effect on health.

3.5.6.1 LLand Imprint for DPSThe sites designated for instruction (Sites A and B) are both within the existing premises of Delimara Power station – this effectively means that no land outside of the existing power station boundary will be occupied. Site B could be cleared to make way for gas storage (should option A be selected) and regasification. A small part of land will be reclaimed adjacent to Site B to facilitate the construction of a jetty.

There can be no expected health impacts outside of the activities associated with construction, since no additional land will be taken up by the project.

3.5.6.2 Expansion of Estate It is very unlikely that further housing areas will be allowed to develop close to the power station. Should this occur in the future, one can expect a negative health impact due to noise pollution very close to the site. In our view, expansion of residential areas in vicinity of DPS should not be allowed, as in the very unlikely event of an accident on the site the residents’ lives could be in danger.

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3.6 WWaste

3.6.1 Delimara: current waste production. The following is a list of waste products currently being produced at the Delimara Power Station.

OPERATIONAL WASTE STREAMS

Waste Type EWC Code Nature Quantity p.a. Disposal routeFlue Gas DesulphurizationChemical Composition:- 78% Sodium Sulphate Na2SO4

- 17% Sodium Carbonate Na2CO3- 5% Fuel Ash

10 01 18* SolidHazardousWaste

9, 880t Exported forfinal treatment

Spent Catalyst 16 08 02* SolidHazardousWaste

5.5t Exported forfinal treatment

Sea water cooling systemoxidants and disinfectingagents

10 01 26 Effluenttreated toDirective2006/11/EC

10.8tLiquidtreatment toDirective2006/11/ECrequirementsprior todischarge backto sea

Oil Sludge 13 05 02* LiquidHazardousWaste

993tIncineratedlocally or sentto haz. landfillor exported

Oily Water 13 05 07* Effluenttreated toDirective76/464/EEC

9,933tTreated to<5ppm andwhich then canbe dischargedto the sea inaccordancewith Directive76/464/EEC.

Boiler Wash Down Sludge 10 01 22*Semi-solidHazardousWaste

8m3 HazardousLandfill

Sanitary Waste Water (sewage) 16 10 02 Liquid waste 2,300litres/day

Sent to publicsewers

Flue Gas Desulphurisation: EWC 10 01 18

This flue gas is solid hazardous waste, and the fuel ash in it is usually contaminated with various heavy metals such as cadmium, copper and arsenic. These can be highly carcinogenic, and therefore this waste has to be treated safely.

Flue Gas emissions have been linked to neurological defects in foetuses, mostly because mercury is a common contaminant of this waste.

This type of waste is therefore very hazardous, and its treatment process is expensive.

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Spent Catalyst: EWC 16 08 02

This catalyst is classified as “solid hazardous waste” – its contents haven’t been specified, so we could not comment on any specific health hazards it may have.

Sea water cooling system oxidants and disinfecting agents: EWC 10 01 26

The oxidant and disinfecting agent currently being used is Chlorine Dioxide (produced by a reaction of biocaf and sulphuric acid). When it is released together with effluent, the level is very dilute so that no negative health effects should be registered.

Oil Sludge: EWC 13 05 02

This sludge is classified as liquid hazardous waste, and its components are highly carcinogenic. Currently this waste is either incinerated locally, sent to a hazardous landfill site or exported.

Oily Water: EWC 13 05 07

Currently this waste is treated to have a <5ppm concentration level and then discharged into the sea. Although dilute, the oily contents of this waste might be carcinogenic, and may enter the food chain in the bay, ultimately exposing the local population to toxins.

Boiler Wash Down Sludge: EWC 10 01 22

This semi-hazardous waste is disposed of in a hazardous landfill. The components of this sludge haven’t been disclosed, and we are therefore unable to comment on the health impact.

The Delimara HFO plants (Delimara 1-ST and Delimara 3) will cease to operate on HFO fuel. Delimara 1-ST generators will be decommissioned, whilst the Delimara 3 plant will be converted to operate on Natural Gas. This will have a net positive health benefit since:

It reduces the risk of a toxic waste spill, which is the current situation due to the large amount of hazardous waste produced from the HFO plants. Natural gas is a much cleaner fuel for a plant to operate on, which is expected to generate no solid waste due to the gaseous nature of the fuel.

We can therefore expect a drastic reduction in the amount of toxic waste generated, which will positively impact the health of both the local population and the workers on site.

33.6.2 Waste: Choosing the Site

Option A, as shown in the Project Development Scheme, envisages the procedures of regasification and storage of liquefied natural gas occurring Onshore on an area designated as “Site B”, currently occupied by a mound of debris.

Should this option be opted for, construction of the LNG plant onshore would generate large amounts of dust and waste, mainly construction waste, due to the site being occupied by a mound which would need to be removed. This waste needs to be safely disposed of – we have not been informed of where this large volume of waste will be deposited should option A be opted for.

This would therefore pose a temporary health hazard to people on site and in the surrounding area, namely because very large amounts of inhalable particulate matter that is

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expected to be generated which would negatively impact the respiratory health of the people in the area.

33.6.3 Waste expected to be generated during operation phase

Upon construction of the site, one could expect the following activities to occur on this site:

Gasoil storageOil/water separatorGasoil transportChemical storageLube and hydraulic oil storage

These activities need to be carefully managed so that waste generated would be carefully collected and deposited/treated safely, so as to minimise any health risks. Some of the waste products from these activities are described below.

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The following are a list of water waste products that are to be expected during the operational phase of the plant:

Emissions to water

type of waste water

EWC catalogue number

amount composition discharge point

Cooling water 10 01 26 16,000 m³/h

Sea water with maximum:

0.2mg/L Chloride

bay of Il- ofra - g ira

Drain HRSG 10 01 221.5 -2.0 m³/h Concentrated boiler

water with phosphate and Ammonia

bay of Il- ofra - g iraOnce a year 65 m³

Cleaning GT’s 10 01 99 4 times a year water and cleansing agent

trucks to authorized processing company

Scrub and wash water 10 01 99

0.2 m³/h (average)

Possible polluted wash water

Oil separator, cleaned before discharge to sea

Sanitary water 10 01 99 0.2 m³/h (average) sanitary to DPS system

Rainwater 10 01 99 not known Uncontaminated rainwater bay of Marsaxlokk

Cooling Water: EWC 10 01 26

This is expected to cause no damage to health, as thermal pollution is expected to be minimal. With a temperature increase of a few degrees celcius, any bathers in the warmer water are not expected to experience any negative health impacts.

The Chlorine Dioxide, at 0.2mg/L is not expected to cause any negative health effect.

Drain HRSG: EWC 10 01 22

Ammonia produced from the cleaning process of boilers in water can form ammonium hydroxide. At high concentrations this can cause negative health effects and damages the cells of the body upon

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contact. It can cause irritation to the repiratory tract if inhaled in vapor form. Similarily Phosphate salts cause irritation to skin and can cause eye damage if in sufficiently high concentrations.

The thermal outflow of volume 16,000m3 per hour will contain 1.5-2.0 m3 of this waste water per hour – at such low concentrations no negative health effects are expedcted to occur.

Cleaning GT’s: EWC 10 01 99

We have not been provided details as to what cleaning GT agents are expected to be used. Therefore we cannot comment about what effects they could have on health. It is encouraging however to note that this waste will be discharged into trucks for processing – therefore careful and safe management of this water and adequate processing should lead to no negative health impact occurring.

Scrub and wash water: EWC 10 01 99

This water has the possibility of being polluted, and will be treated using an oil separator and cleaned before being discharged in the sea. If the cleaning process and treatment is assured, one can expect that no negative health impact would occur. It is imperative, however, that the oil separator be functioning so as to ensure that no toxic contaminants are accidentally discharged into the sea.

Sanitary Water: EWC 10 01 99

Sanitary water will enter gthe DPS sanitation system. Therefore no negative health impacts are expected to occur.

Rainwater: EWC 10 01 99

Uncontaiminated rainwater should be perfectly safe to discharge into the bay. However one should ensure that the area occupied by the DPS be cleaned adequately so that no toxic chemicals or contaminants are washed out in the rainwater to pollute the bay.

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33.6.4 Waste expected to be generated during LNG transport and storage process

Emissions to water

type of technology

EWC catalogue Number

What & amount composition discharge point

Direct Ambient Air Vaporizers

Cooling of the moist ambient air results in condensation of a large amount of water vapour from the atmosphere. Some of this condensed water collects as frost and/or ice on the tubes of each unit.

This water is expected to have minor or nocontamination and may be treated prior to disposal or used within the Import Terminal.

Typically, the ice from the surface of each unit melts and drains to a collection basin during the de-icing cycle.

05 07 99

Indirect Ambient Air Vaporizers

05 07 99Water produced from condensation of water vapor from the surrounding air.

For Reverse Cooling Tower systems, the circulating water stream is likely to require chemical treatment and the blow down needs to be appropriately handled.

The water must be continuously discharged and safely discarded.

Submerged Combustion Vaporizers

05 07 99 Waste water

The pH of the water bath is monitored and controlled byintroducing alkaline chemicals such as caustic soda or sodium carbonate.

Drain and water treatment system

Open-rack vaporizers

05 07 99

Seawater from the ORVs is routed to the water outfall and returned to the sea. The ORV effluent is approximately5° below ambient water temperature and could potentially affect the local environment.

To prevent bio-fouling of the seawatersystem, significant quantities of chlorinemust be added. Industries, typically in the effluent 0,1 –0,2 mg/l.

The water outfall

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During the transport and transfer of LNG, wastewater may be generated, as listed above. Most of these are formed as a result of LNG being transported at - which causes ice to form. This can be of danger to workers at the site, but should adequate health and safety precautions be taken no negative health effects should be expected.

Direct Ambient Air Vaporizers: EWC 05 07 99

This is expected to cause no health impacts if the workers at the site are at an adequate distance from the formation of these vapors. Safety gear and adequate protection should be ensured at all times so as to avoid cyrogenic injury.

Indirect Ambient Air Vaporizers: EWC 05 07 99

Similar to the above, no negative health impacts are expected. Should other chemicals (unspecified) condense due to the extreme cold temperatures involved, adequate safety measures should be taken.

Submerged Combustion Vaporizers: EWC 05 07 99

Due to varying pH levels (predicted level not provided) adequate protection must be necessary for the workers dealing with this type of wastewater. One should also ensure that any caustic soda or sodium carbonate instroduced to deal with the waste should be added in adequate amounts, and that all necessary precautions be taken.

Open-rack vaporisers: EWC 05 07 99

of the thermal cooling water. This will not pose any danger to the health of any people at the site or bathers at the outflow bay, and indeed will be used to more efficiently lower the temperature of the CCGT plant during operation.

33.6.5 Waste generated during Construction During the construction phase of the project, one can expect the generation of hazardous waste which would warrant special caution, especially due to the site being a coastal area. Extra caution should be taken to ensure no spillage on – or offshore of hazardous toxic material would take place, which could be a danger not only to the workers on the site but to the people living in the Village of Marsaxlokk.

The waste expected to be generated during Construction phase is mostly construction material. However this material has been in contact with oil products, and therefore the necessary precautions should be taken to ensure that these substances, many of which are carcinogenic in nature, should be disposed of safely.

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3.7 RRisk Assessment of LNG operations LNG operations, due to the nature of the substance and its behaviour should be taken seriously, especially from a health perspective. Quoting from page 21 of the Risk Assessment provided:

“LNG terminals have exhibited an exceptionally high safety record when compared to refineries and other (petro) chemical plants. Small LNG vapour releases, and minor fires and explosions have been reported, but their effect was limited to the plant itself and the hazard was promptly handled by plant personnel. During the past sixty years of LNG operations, not a single general public fatality has occurred anywhere in the world because of LNG operations.

Also, LNG tankers are among the safest transportation mode. In the last three decades, after more than 40,000 voyages by sea worldwide, there has not been a single reported LNG release from a ship’s cargo tank. LNG tankers have experienced groundings and collisions during this period, but none has resulted in a major spill. This is partly due to the double-hulled design of LNG tankers which offers significant protection to the double walled LNG containers. However, LNG and methane hazards must be seriously considered in the QRA, due to the nature of the substance and its behaviour.”

This report is therefore a very encouraging statement as regards the safety record of LNG transport and regasification procedures. There are, however, dangers associated with working with LNG which need to be taken into account:

3.7.1 LNG Hazards

The following list below will outline what we identified as the hazards that plant personnel could face during day to day operations. However it is very important to note that, following the Risk Assessment prepared for this project, one has to look at the orders of magnitude of probability of incidents occuring. For all of the possible accidents that could occur on site, the risk of a fatality is less than 1 in 10,000 over a year (10-5) and in most the risk is less than 1 in 100,000 (10-6). This therefore makes the following potential hazards very unlikely.

3.7.1.1 Cryogenic Burns Since the liquified natural gas is cryogenic, being transported at temperatures around -can cause burns to personnel if it comes in contact with skin. Breathing cold vapours as a result of LNG evaporation and boiling is also very dangerous as it causes damage to the lungs and respiratory tract, with severity of damage related to severity of exposure. In effect, the exceedlingly cold temeprature of the vapour can cause “frosting” of the lungs, which can be fatal.

3.7.1.2 Asphyxiation This can occur due to methane being colourless and odourless, so that if a leak occurs personnel nearby may not be aware that they are being exposed to high amounts of gas. This will only occur, however, when there is a high amount of gas in the air, typically only close to an accidental release of LNG.

3.7.1.3 Explosions and Spills risk LNG in liquid form does not explode. This means that an accidental spill of LNG would not lead to the entire energy content of the spill to be released instantly as happens with explosives. LNG is also stored at atmospheric pressure – this prevents a rapidly expanding vapour explosion from occuring. On contact with much warmer sea water, LNG would undergo rapid-phase transitions that could

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form a pressure wave, which is typically not as strong as a chemical explosion. This could physically harm any personnel next to the accident.

33.7.1.4 Leakage, and Gas Cloud risk In the unlikely event of an accident, one of the greatest risks is the spread of a gas cloud that could be ignited thourgh various “ignition point” in the DPS site. This could, theoretically, cause a large explosion to occur and would invariably cause fatalities at the site.

Though the risk of such an event occuring should never be understimated, adequate precautions and technological adaptations could be provided to minimise the risk as much as possible. For option B, this gas cloud proceeds from a pool of LNG spilled onto the water due to the failure of the unloading arm connecting the FSU to the onshore RU, while for option C, the gas cloud proceeds from the leaking unloading arm delivering the regasified natural gas from the FSRU. Option A, on the other hand (with the storage tanks onshore) there is the highest individual risk to the scattered residential homes around Delimara Power station.

According to the qualitative risk assessment provided, Option C seems to be the better option minimise risk to the local population of Marsaxlokk Bay. In the case of Option B, the regasification unit should be placed as far as possible from the Power Station and as close as possible to the unloading sites to minimise risk.

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3.8 NNatural Disasters

It is important to be prepared for any eventuality, however remote or unlikely it may be. This section will address the risks associated with natural disasters, such as Earthquakes, Tsunamis and Fires – which have occured in the past, and may occur again.

3.8.1 Earthquakes In the event of an Earthquake, landslides from the surrounding cliffs may occur which can cause great damage to the site. Fortunately, the DPS is designed to withstand such an event to not only minimise damage to such a crucial piece of infrastructure in Malta, but also to minimise injury and/or loss of life.

In the event of a large earthquake (such as the 1693 Earthquake that devastated many parts of Malta) electricity infrastructure should be a top priority, especially with public health infrastructure being so totally reliant on such a source of power. Mater Dei hospital, fortunately, is also earthquake-proof, and therefore these building adaptations, in the event of an earthquake, would prove to be of great importance.

In view of this rare but very real risk, plant personnel should be trained in how to react in such an event, and how to ensure that the necessary infrastructure be brought up and running as quickly as possible without endangering their health, or that of people in residential aras nearby.

3.8.2 Tsunamis Tsunamis in the Mediterranean, although relatively rare, have occured in the past, and could truly impact our capacity to generate electricity should such a wave occur from a South-Westerly direction. Although the likelihood of such a disaster is low, they often occur with devastating effect.

Fortunately tsunamis in the Mediterranean originate far from the Maltese Islands. Should such an event be reported, the plant personnel (and indeed all residents in the coastal regions at risk) should be notified to evacuate immediately.

If Option A is selected, this would entail the removal of Site B, which at this point proves to offer some protection from such an event for the Delimara Power station. This removal would lead to great infrastructural damage to the DPS that could severely hamper the effectiveness of an adequate public health response in Malta.

3.8.3 Fire As described in Section 3.6 above, the likelihood of such an event occuring in the presence of adequate safety protocols is very low. However it can occur, and therefore safe zones and adequate fire safety equipment should be put in place to avoid such a hazard from occuring or spreading. Personnel at the site should be adequately trained on how to avoid injury, and how to help fellow plant personnel in the event of a fire.

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44 Prevention and Mitigation

Mitigation is a broad term and we would like to outline some of the different aspects that need to be considered here. Careful recommendations have been made for prevention, early routine monitoring and hazard prevention in each of the EIA experts’ reports and we feel that these should be followed to the letter. We do not suggest that these measures can be any way shortened or summarised although we wish to highlight the various categories of measures here.

The International Finance Corporation of the World Bank Group has collaborated to issue a number of pertinent guidelines related to the power generation industry. Two of them are directly related to the current project – the Environmental Health and Safety Guidelines for Thermal Power Plants (2008) and the Environmental Health and Safety Guidelines for Liquefied Natural Gas (LNG) Facilities (2007). These documents will be referred to in this section as they offer a comprehensive and detailed guide on mitigation and prevention of hazards.

The former document carefully lists and appraises the hazards linked with the diverse thermal power plants (including those running on heavy fuel oils and those on LNG) while citing expected ranges for the various emissions.

The following is the URL link for the document on Thermal Power plants.

http://www.ifc.org/wps/wcm/connect/dfb6a60048855a21852cd76a6515bb18/FINAL_Thermal%2BPower.pdf?MOD=AJPERES&id=1323162579734

4.1 Positioning of LNG facilities

As advised in the Risk Assessment report submitted as part of this EIA, Options C or B would be preferable in order to minimise the risks caused by possible flash fires to the population and to the power plant with the actual positioning of the facilities as recommended in the same report towards the south, closer to the mouth of the bay. This would, however, require further assessments of nautical and harbour risks.

“The ultimate conclusion is that a FSRU (Option C) or a FSU plus a RU (Option B), if located in the recommended zone (shown in drawing #13), is the preferred choice in order to minimize the individual risk for the populations as well as to minimize the damages to the Delimara Power Station in case of flash-fire. However, the client has to take into account that the suggested position may be not suitable if analysed from the nautical point of view: In fact the FSRU or FSU would be located closer to the mouth of the harbour, increasing the probabilities for a collision with a manoeuvring ship or for a damage in the FSRU or FSU itself due to high waves, storms and other atmospheric phenomena, against which the tanker would not be protected. In order to define the optimum location in the harbour, balancing (1) the facilities inherent risk, (2) the nautical collision risk and (3) the meteorological risk, is highly recommended to perform a nautical risk assessment (for #2) as well as a harbour risk assessment (for #3).

Project for a new LNG regasification facility to be located in the Marsaxlokk Bay - QRA PRELIMINARY REPORTRef: 02-901-188098-12141-rev0Page 66 of 69

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4.2 AAir quality Based on the air dispersion model report submitted with this EIA, there will be considerable improvements in air quality once the new natural gas power plants are up and running. However, these improvements are dependent on a number of conditions and these must be satisfied in order to achieve such improvements (mitigation and prevention).

Thus, a stack height of 105 metres as proposed in the consultation document; the ensuring of the availability of the interconnector and the various modifications as planned are all essential to acquire the improvements in air quality being proposed. (Fedra K. 2013 Report on Air Dispersion Modelling Delimara CCGT & LNG EIA Ecoserv Ltd & ESS GmbH)

4.2.1 Air pollution Mitigation measures

Although the NOx and PM emissions are to decline dramatically in the 2015+ scenario, one should still explore possible recommendations to further mitigate and reduce the release of pollutants into the air.

4.2.1.1 NOx emissions mitigation

The following tables have been obtained from a World Bank Group Document titled “Environmental, Health, and Safety Guidelines for Thermal Power Plants” (2008).

The table to the left highlights the suggested NOx reduction systems that would reduce the amount of NOx release. In the case of the CCGT plant, an additional 1-2% cost would be expected. This increased capital cost could pay off in the long term due to health benefits gained from NOx emissions reduction.

Performance / Characteristics of Secondary NOx Reduction Systems

Type Characteristics Plant Capital CostIncrease

SCR - NOx emission reduction rate of 80 –95%

- Use 0.5% of electricity generated- Use ammonia or urea as reagent.- Ammonia slip increases with increasing

NH3/NOx ratio may cause a problem (e.g., too high ammonia in the fly ash). Larger catalyst volume / improving the mixing of NH3 and NOx in the flue gas may be needed to avoid this problem.

- Catalysts may contain heavy metals. Proper handling and disposal / recycle of spent catalysts is needed.

- Life of catalysts has been 6-10 years (coal-fired), 8-12 years (oil-fired) andmore than 10 years (gas-fired).

4-9% (coal-fired boiler)

1-2% (gas-fired combined cycle gasturbine)

20-30%(reciprocating engines)

SNCR - NOx emission reduction rate of 30 –50%- Use 0.1-0.3% of electricity generated- Use ammonia or urea as reagent.- Cannot be used on gas turbines or gas

engines.- Operates without using catalysts.

1-2%

Source: EC (2006), World Bank Group

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44.2.1.2 Particulate Matter release mitigation

As already described previously, natural gas combustion produces no solid waste, and hence no particulate matter is expected to be emitted from the CCGT plants. However, the gasoil plants will be used as a backup system should demand exceed the capacity of both the interconnector and the CCGT plants. We are therefore recommending the following measures to be adapted into the current gasoil units so as to limit PM 10 and PM 2.5 emissions, which, as already described, cause negative health impacts.

The three different systems suggested in this table (“Environmental, Health, and Safety Guidelines for Thermal Power Plants”, World Bank Group, 2008), could be adapted into the gasoil units so that in the event of their use as backup, or as regular sources of power, Particular Matter emissions would be greatly reduced. It is important, in the case of the Wet Scrubber, that the wastewater produced be treated effectively so that one wouldn’t simply shift the problem from the air into the sea around DPS.

4.2.2 Air pollution Mitigation: Option A

Should option A be opted for, one can expect a very large amount of dust to be generated since it entails the removal of Site B, which is currently occupied by a mound of construction debris.

One could perhaps attempt to mitigate this problem by stopping the clearance of the site during days with winds from a Southerly direction, which would avoid large amounts of dust from reaching the village of Marsaxlokk, which would not only be a nuisance to the people in the locality but could also pose a significant health risk.

Performance / Characteristics of Dust Removal Systems

Type Performance / CharacteristicsESP - Removal efficiency of >96.5% (<1 m), >99.95%

(>10 m)- 0.1-1.8% of electricity generated is used- It might not work on particulates with very high

electrical resistivity. In these cases, flue gas conditioning (FGC) may improve ESP performance.

- Can handle very large gas volume with lowpressure drops

Fabric Filter - Removal efficiency of >99.6% (<1 m), >99.95%(>10 m). Removes smaller particles than ESPs.

- 0.2-3% of electricity generated is used- Filter life decreases as coal S content increases- Operating costs go up considerably as the fabric

filter becomes dense to remove more particles- If ash is particularly reactive, it can weaken the

fabric and eventually it disintegrates.Wet Scrubber • Removal efficiency of >98.5% (<1 m), >99.9%

(>10 m)• Up to 3% of electricity generated is used.• As a secondary effect, can remove and absorb

gaseous heavy metals• Wastewater needs to be treated

Sources: EC (2006) and World Bank Group.

55

4.3 NNoise monitoring including variability under differing circumstances

Noise pollution, as described in Section 3.3.2, is set to be minimal in the vicinity of Marsaxlokk village. However noise levels will increase in the site itself, especially around the CCGT plant and the offshore platform (should options B or C be selected).

It is therefore recommended that measures be taken at the site to limit the noise emitted by the machinery, so as to avoid damage to the hearing and mental well-being of the plant personnel.

Noise impacts, control measures, and recommended ambient noise levels are presented in Section 1.7 of the General EHS Guidelines. Additional recommended measures to prevent, minimize, and control noise from thermal power plants include:

(e.g., residential receptors, schools, hospitals, religious places) to the extent possible. If the local land use is not controlled through zoning or is not effectively enforced, examine whether residential receptors could come outside the acquired plant boundary. In some cases, it could be more cost effective to acquire additional land as buffer zone than relying on technical noise control measures, where possible;

structures according to their noise isolation effect to envelop the building; using mufflers or silencers in intake and exhaust channels; using sound absorptive materials in walls and ceilings; using vibration isolators and flexible connections (e.g., helical steel springs and rubber elements); applying a carefully detailed design to prevent possible noise leakage through openings or to minimize pressure variations in piping;

vegetation to limit ambient noise at plant property lines, especially where sensitive noise receptors may be present.

“Environmental, Health, and Safety Guidelines for Thermal Power Plants”, World Bank Group, 2008

We would also suggest noise pollution monitoring stations to be set up in the vicinity of the site, so that should changes in activities lead to an elevated noise level, necessary mitigation measures should be provided.

Additionally, as is mentioned in the General EHS guidelines prepared by the World Bank, we would recommend noise-protection equipment to be provided to personnel working with noisy machinery, and that they be instructed as necessary in their use.

56

4.4 CCurrent and future monitoring of marine quality

Marsaxlokk Bay, has long been a centre of harbour activities throughout the history of Malta. Unfortunately, its waters are more contaminated than other waters around Malta – sediments on the seabed attest to the many and various vessels that enter the harbour, with cadmium, mercury, arsenic, copper and various other heavy metals found at low levels.

4.4.1 Dredging Activities Although not directly hazardous to bathers, the dredging activity that will inevitably occur in the bay needs to be carefully managed so that the sediment disturbed would not be at such levels to endanger the health of the local population. Additionally fishing in the area close to DPS should be strictly forbidden, as any toxic spills or contaminants during the construction phase may find their way into the food chain and bioaccumulate, which could pose a danger to health.

Additionally, swimmers should be advised to avoid swimming in the areas directly adjacent to the DPS during this phase or further in along the same bay to avoid any dangerous exposure to toxins in surface waters.

4.4.2 Discharges in the bay Following the findings in Marsaxlokk Bay, where various contaminants have been found both in surface waters and in bottom sediments, measures must be taken to ensure that any discharges are strictly forbidden as they could endanger the health of local residents.

Measures should be taken to set standards for marine vessels entering the bay, advising and enforcing strict standards for discharges to air and sea. Fiscal penalties should be considered for vessels found to break such standards after the requisite warnings are issued.

4.4.3 Water Outflow in - Following reports of foamy water, and our first-hand experience at seeing this occurrence, we would recommend that regular monitoring of the site be maintained so that, in the eventuality of this happening again, the foamy substance would be sampled and tested. One should note that this inlet is frequented by swimmers, and that exposure to these substances might be harmful.

Both thermal and chemical monitoring at the site should be conducted to ensure that the waters of the inlet remain of a very good standard. The only way that this monitoring and resultant action can be effective is if an appropriate independent body be set up to undertake this task. This body should remain independent of political and industrial influences so that population health is not compromised.

4.4.4 Other recommendations The document titled “Environmental, Health, and Safety Guidelines for Thermal Power Plants”, World Bank Group, 2008” should be consulted as it offers advice on international standards to ensure the best water quality for such a project.

Additionally, due to very low risk of accidental spills or hazards related to handling LNG, the document titled “Environmental, Health, and Safety Guidelines LNG liquefied natural gas facilities” by the World Bank Group should also be consulted. All technological adaptations necessary should be taken so as to ensure that maximum safety of both the workers and the residents of Marsaxlokk.

57

4.5 SSolid waste

4.5.1 Mitigating solid waste during construction: Option A

As already described above, the solid waste generated should option A be opted for would be considerably large, due to the landscaping of site B, which currently is occupied by a mound of debris. No information has been provided as to where this waste can be deposited.

It is therefore our view that, should option A be opted for, a proper assessment is done of the debris on the site and an informed decision should be as to where the debris will be deposited, safely and at the last possible annoyance to the population in general.

4.5.2 Mitigating solid waste during construction: Options B and C

Options B and C would entail some the Regasification and Storage of LNG to occur on an floating offshore platform, either entirely (both activities occurring offshore) or partially (regasification occurring on the jetty).

During construction, the waste generated would be less than that of Option A as these options do not necessitate the removal of the mound on Site B. However the construction and placing of the floating platform could generate considerable amounts of waste which could spill into the sea, and necessary precautions have to be taken to avoid this risk to marine life and subsequently, human health.

Once constructed, activities would be the same as detailed above. However, with these activities occurring partially or entirely offshore, one has to take the necessary precautions to avoid waste being spilt into the sea. This would be especially challenging in adverse weather that occasionally affects Malta, where choppy waters or stormy seas could pose a danger to the floating platform and could lead to waste spillage into the sea, with potentially very negative effects not only on the environment of the area but also to the health of the people in the region.

It is therefore very important that the recommendations detailed in the section on Water Quality (Section 4.4) and referral to the “Environmental, Health, and Safety Guidelines for Thermal Power Plants”, World Bank Group, 2008” should be followed to minimise health risk to residents and plant personnel alike.

4.5.3 Mitigating solid waste during operations There is very little solid waste that is expected to be generated from the 2015+ scenario for the DPS. The little solid waste, other than that from the day to day running of the facility (eg. paper waste, machinery maintenance materials, drainage, etc.) would likely come from the gasoil power units, should they be put to use as backup.

It is very important that any such waste be collected safely and transported and treated effectively so as to minimise any danger it poses to human health and to the environment. Additionally all plant personnel should be provided with the necessary protection equipment so as to avoid unwarranted exposure to potentially hazardous material.

58

4.5.4 Selection and monitoring of CCGT plant standards The International Finance Corporation World Bank Environmental Health and Safety Guidelines for Liquefied Natural Gas (LNG) Facilities (2007) document deals more carefully with the hazards of LNG facilities, subsequently suggesting mitigating and preventive action to reduce risks.

http://www.ifc.org/wps/wcm/connect/87e7a48048855295ac04fe6a6515bb18/Final%2B-%2BLNG.pdf?MOD=AJPERES&id=1323161924903

4.5.4.1 Safety measures for workers on site As the workers on the site will be working with potentially hazardous materials, it is of great importance that all the necessary equipment be provided both for protection and for mitigation should an accident occur.

Additionally training of personnel in using equipment should be a great priority, so that in the unlikely event of an accident personnel would follow the best safety protocols.

We recommend the protocols available on the website below, which details the necessary equipment necessary to maintain a high safety standard.

http://www.ifc.org/wps/wcm/connect/Topics_Ext_Content/IFC_External_Corporate_Site/IFC+Sustainability/Sustainability+Framework/Environmental,+Health,+and+Safety+Guidelines/

4.6 SSocial impacts

The social impacts of the project have been described in great detail in the Social Impact Assessment conducted by Dr Formosa for this project. It is clear that the DPS is of great concern to the Maltese people, especially the residents of the village of Marsaxlokk who live closest to the site.

4.6.1 Dealing with the misconceptions regarding the proposed DPS project There are many misconceptions regarding the project and its dangers, and it is important that these are addressed adequately and promptly so as to assure the residents nearby of the nature of the plant, and that it is a mature technology with a very good safety record. The benefits to health that will arise from this project should be particularly stressed, since the residents have long complained of adverse health effects that they squarely blame the DPS for, and perhaps they are right in doing so.

One such misconception is that on the area an unlikely gas cloud would encompass, with various forms of media reporting huge clouds that would engulf the entire village into a fireball. These exaggerations should not be taken lightly, as there is a lot of misinformation on the nature of Gas technology. It is important that this fear should be addressed and allayed, and that all assessments and consultations be made public to assure the residents that all the necessary assessments has been carried out, and that this is in the best interest of the Maltese population.

We therefore would recommend that a proper and honest information campaign be set up for both the local residents and general population of Malta, ideally by an independent group or NGO without any bias, so that any misconceptions on the project will be addressed appropriately and in an informed manner.

59

44.6.2 Improving the locality The residents of Marsaxlokk have long felt “victimised” as they have had to bear the brunt of a polluting Power plant for the past two decades. They have often expressed, as is attested in the Social Impact Assessment (SIA), that they have been “abandoned” by the government and that they have no voice in decisions that are of great concern to them as regards the DPS site.

It is therefore important that, besides involving the community, enhancement project be carried out in the area to enhance the quality of life of its residents. A restoration of Delimara fort and the placement of a heritage trail in the area would enhance tourism in the locality, which would provide and economic boost to the local residents. It would also enhance the environment around the DPS, and improve the quality of life of residents.

These and other suggestions mentioned in the SIA would improve the socioeconomic status of the residents in the area. An improvement in socioeconomic status, by itself, would improve health in the area. Many studies have found a strong link between health and socioeconomic status; this link has not yet been fully understood, but the studies hold true in many countries and cities around the world.

4.7 Natural Disasters The risks of an earthquake, tsunami or fire at the site should be taken very seriously. In the highly unlikely event that such a disaster would happen during the operational phase of this project, the plant personnel should be well-trained so that they would know how to react in a safe and efficient manner.

For this reason we would suggest that evacuation points should be set up in the area, especially when one notes that there is only one access road to the site, and that an uncoordinated response could cause more harm than good.

Additionally we suggest that a study be conducted specifically on the risk that these disasters would occur – and that if they did, what could be done in response. It is therefore suggested that a framework be set up so that it would be available when or if such an event occurs.

60

55 Conclusion This complex HIA has involved an extensive review of the literature on a number of different aspects of power plants and NG storage and regasification facilities. It has also benefitted from information derived from the various expert drafts on the present and projected (2015+) situation regarding Risk Assessment, Air quality, Marine Impacts, Solid waste, Noise and Social Impacts.

There are various assumptions that have been taken in order to predict the 2015+ situation. Obviously, these have their limitations. Additionally, various scenarios have been used to predict the outcome of environmental hazards under different conditions. This renders the ability to make a frank statement about the overall impacts to health all the more difficult and tentative.

However, an in-depth review of the various expert reviews together with an understanding of this HIA will allow some broad statements regarding possible health outcomes.

To initiate this, a broad reflection on which of the Enemalta PDS options proposed would guarantee a safer outcome. The conclusion, based on the Risk Assessment and SIA mostly, is that Option C renders both the hazards from flash fires of spreading less harmful and allays the perceptions of residents regarding both their risk as well as the permanence of such structures in their precincts.

Having taken this stand, an overall balance sheet of impacts and health repercussions can now be made with Option C as the selected site and with most assumptions taken as valid.

61

Balance sheet of Health impacts

Positive Negative better air quality (Delimara, all of Malta) high initial capital cost (diminished socio-

economic status) less solid waste some land reclamation needed, disturbing sea

quality less greenhouse gases temporary decrease in air and water quality

during dredging and construction works eventually lower electricity bills (improved socio-economic status)

minimally heightened noise, especially to immediate neighbours

less likely EU environmental standard offence fines

generation of substantial building waste

less thermal heating of effluent possible disturbance of heavy metals in local sediment

better perceived health projected air quality improvements not completely within EU limits unless interconnector available

recovered urban land mass for rehabilitation (Marsa plant) (improved socio-economic status -

no need for high stack (also boost to perceived health)

overall better health (asthma and other respiratory illness, cardiovascular disease, deaths)

Transference of all power production air waste to least impact site in view of prevailing winds (diminished hazards, improved health)

62

66 Acknowledgments

The authors wish to thank all their colleagues the various experts who submitted timely and illuminating reports for this EIA and who offered further advice and cooperation towards a better understanding of the available information and its limitations. Thanks also to the Engineering staff at Enemalta and the MEPA staff who attended meetings and gave their contributions to a better understanding of the current and projected situation in the power plants.

They also wish to thank the mayor of Marsaxlokk, Architect Edric Micallef for his time and dedication in an informative meeting and for giving his views on the project and the perceptions among residents.

They also wish to thank Dr. Pierre Chircop, former deputy mayor of Birzebbugia, for his kind cooperation and contribution.

They are especially grateful to Paul Gauci, coordinator of this EIA for his continuing efficient support and for making cross exchanges so much easier.

John Paul Cauchi Julian Mamo

63

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68

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In the HIA handed in to Enemalta in August, 2013, we commented that, based on the models provided by the virtual power plant model used by environmental consultants, a chimney of height 105m was desired over that of 75m so as to disperse any pollutants and allow acceptable parameter levels at ground level. However, through information provided by the bidder, it has been shown that their plant will have 3 chimneys operating at high pressure. This means that a height of 75m is sufficient, as the virtual height, due to emissions being under high pressure, will in fact be far higher. Therefore a height of 75m for each chimney is now acceptable under this scenario.

The CCGT plant will now, under the most updated scenario, be host to 3 turbines and 3 chimneys, not 1 large turbine. This is considered a more efficient option, as during lower power demand, one can have the option of switching off one turbine to conserve power. This therefore allows not only less pollution release and less fuel consumption, but also gives a high efficiency for the plant, which would be able reach a potential of 58% efficiency(1), and even up to 60% in some scenarios.

The health results from this could be that less fuel is consumed, and therefore less air pollutants will be emitted overall.

3. OptionsB–selected,andslightlymodified

The HIA submitted commented on 3 options – Options A, B and C with various scenarios on how the plant could be constructed. Option A envisaged the plant and storage to be fully onshore; option B a hybrid onshore‐offshore option, with Regasification plant onshore and Storage offshore, and Option C with both regasification plant and storage units offshore.

The bidder, Electrogas, has submitted a proposal mostly based on Option B, with a few modifications. The main modification is that the Regasification plants will be located not on the Jetty, as was envisaged originally, but onshore, next to Site B. It is important therefore, with this modification, that appropriate measure be taken to ensure that all safety precautions be taken to ensure that the regasification site be operated under strict health and safety recommendations, as shown in the guidelines offered by the World Bank in the document titled “Environmental, Health, and Safety Guidelines for Liquefied Natural Gas (LNG) Facilities.”(2)

4. RiskAssessment

Given that LNG is a highly volatile substance, a quantitative risk assessment (QRA) has been undertaken to attempt to quantify the level of risk at the site.(3) In the Individual Risks section of this report, the risk of a fatality is less than 1 in 10,0000 over a year (10‐5) for the Inner Zoneand around 1 in 1,000,000 (10‐6) for the Middle Zone. This therefore confirms our previous assessment, based on international figures, and makes the potential hazards listed in our HIA, Section 3.7, as very unlikely.

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hose can therefore also be seen as an appropriate adaptive measure. Its use should reduce the risk that could increase due to sea‐level risewhen a loading arm is being used as a main fuel un/loading mechanism.

References

1. Integrated Pollution Prevention and Control Reference Document on Best Available Techniques for Large Combustion Plants. European Commission, July 2006. 2. Environmental, Health, and Safety Guidelines for LNG facilities, World Bank. 2007. 3. Vaccari R. Draft: Project for a new LN regasification facility to be located in the Marsaxlokk Bay. Malta: 2013.

Documents

Delimara Gas and Power - Welcome DPS_EIS_App02v_E… · Delima iq il-Powe NTA vironme Gas ed Cycle and efied Nat, and re-ra Powe r Station L IM ntal Su Appendix T Volume F ... marsh