chapter 8fred.csir.co.za/project/cip_eia/pages/ess_ch8.pdf · chapter 8 the protection of...

CHAPTER 8:

IMPACT ASSESSMENT OF MATERIALS

HANDLING AND CHEMICAL AND SOLID WASTE MANAGEMENT

IMPACT ASSESSMENT OF MATERIALS HANDLING

CHAPTER 8

CONTENTS 8. IMPACT ASSESSMENT OF MATERIALS HANDLING AND

CHEMICAL AND SOLID WASTE MANAGEMENT ___________ 8-1

8.1 Approach to Materials Handling and Chemical and Solid Waste Management study __________________________________________8-1

8.1.1 Terms of Reference ____________________________________________8-1 8.1.2 Information sources ____________________________________________8-2 8.1.3 Specific assumptions and limitations _______________________________8-2

8.2 Description of chemical and solid materials used and waste generated by the project _____________________________________8-2

8.2.1 Chemical and solid materials _____________________________________8-2 8.2.2 Chemical and solid waste________________________________________8-3

8.3 Description of the local waste management infrastructure _________8-3 8.4 Identification of applicable policies, legislation, guidelines or

standards__________________________________________________8-4 8.4.1 National legislation and policies ___________________________________8-4 8.4.2 Conditions of the Port of Ngqura Record of Decision ___________________8-6 8.4.3 Minimum Requirements for the Handling, Classification and Disposal of

Hazardous Waste ______________________________________________8-6 8.4.4 Permit requirements ____________________________________________8-9

8.5 Description of materials handling and chemical and solid waste management issues____________________________________8-9

8.6 Scenarios to be considered in the Materials Handling and Chemical and Solid Waste Management study __________________8-11

8.7 Project alternatives_________________________________________8-11 8.8 Impact assessment_________________________________________8-11

8.8.1 Construction phase____________________________________________8-11 8.8.2 Operations phase _____________________________________________8-12 8.8.3 Decommissioning phase________________________________________8-12

8.9 Specification of environmental thresholds _____________________8-14 8.10 Recommendations for project planning and design______________8-14

8.10.1 Materials handling_____________________________________________8-14 8.10.2 Waste management ___________________________________________8-14

8.11 Recommendations for baseline monitoring and more detailed studies ___________________________________________________8-15

Coega Integrated Power Project: Environmental Screening Study

Final Report, February 2004 - Confidential

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CHAPTER 8

TABLES Table 8.1: Classification system for waste disposal sites......................................................8-7 Table 8.2: Landfill size classes..............................................................................................8-7 Table 8.3: Minimum Requirements for waste handling, storage and transportation .............8-8 Table 8.4: List of permits and registrations required relating to material handling and waste

management........................................................................................................8-9 Table 8.5: Construction, operations and decommissioning phase issues associated with

materials handling and chemical and solid waste management........................8-10 Table 8.6: Construction and operation phase impacts associated with materials handling and

chemical and solid waste management.............................................................8-13



page ii


CHAPTER 8

8. IMPACT ASSESSMENT OF MATERIALS HANDLING AND CHEMICAL AND SOLID WASTE MANAGEMENT

8.1 Approach to Materials Handling and Chemical and Solid Waste

Management study This chapter deals with the identification of issues and the assessment of potential impacts related to chemical and solid materials handling and chemical and solid waste generated during construction, operation and decommissioning of the Coega Integrated Power Project (CIPP). It is based on a synthesis of information from the Aluminium Pechiney EIA Specialist Study on Materials Handling and Waste Management (Raghubir et al., 2002). 8.1.1 Terms of Reference The following Terms of Reference applied to this study: Materials handling

Identification of key issues associated with materials handling and assessment of the potential impacts thereof.

Waste

Identification, quantification and classification of all chemical and solid by-products or waste outputs; as well as the source of the waste, temporary storage requirements and final destination.

Description of the waste management facilities, infrastructure requirements or processes that will be required for each of the major waste streams.

Based on the waste classification, an identification of the class of waste site required for that component of waste that will require disposal. The existence and location of such waste sites within the region and their capacity to handle the extra waste generated from this project will be determined and evaluated.

Identification of key issues of concern associated with chemical and solid waste and assess the potential impacts thereof.

Identification of potential constraints (e.g. legislative, environmental or practical) associated with waste management. This must take into consideration relevant international, as well as national or local, protocols or requirements.

Identification of the opportunities for minimisation, re-use and recycling of waste that should be taken into consideration during the further project planning and design. This should include an identification of the potential opportunities for using this waste



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as inputs to other industries or other users, and a comment on whether such users are known to exist within the region.

Identification of principles that should be incorporated into the further project planning and design in order to promote cleaner production and eco-efficiency1.

8.1.2 Information sources Information on the materials handling, chemical and solid waste generated by the CIPP was requested from the project proponents. This assessment is largely based on the Materials Handling and Waste Management specialist study undertaken for the Aluminium Pechiney EIA (Raghubir et al., 2002). 8.1.3 Specific assumptions and limitations It is assumed that a local competent and legally compliant waste management company will be contracted to collect and transport waste to permitted landfill sites or appropriate recycling facilities, depending on the nature of the solid waste. This investigation and ability to meet the Terms of Reference was constrained by the limited information which was available on the types and quantities of chemical and solid materials required and waste generated by the CIPP.

8.2 Description of chemical and solid materials used and waste generated by the project

8.2.1 Chemical and solid materials LNG terminal The LNG terminal will use typical construction materials during the construction phase. At this stage the amount of construction material used is unknown, but it will be dependant on the physical size of the terminal. CCGT power plant Based on the information provided by Eskom, the following chemicals have been identified as being required by the CCGT power plant during operation:

Glycol (pipeline from LNG berth to CCGT power plant)

Lubricating oils and seal oils (industrial turbine units and compressors)

Silicone fluids (transformers)



page 8-2

1 By “eco-efficiency” we imply the approach of producing more goods and services with less use of resources and less generation of waste and pollution.


CHAPTER 8

Sodium hypochlorite (electrochlorination plant)

Sodium phosphate (heat recovery steam generator blowdown)

Ammonia (cooling circuit)

Diesel (back-up power system) Information on the quantities of these materials has not been provided.

8.2.2 Chemical and solid waste LNG terminal No information is currently available on the cut/fill balance for the LNG terminal during construction, however some construction waste (building rubble) can be expected. Therefore no assessment can be made of impacts of material waste that may be produced. Based on the information provided by Shell, no by-products are produced by the LNG terminal operations and minimal wastes are produced. No information was provided on the type of chemical and solid waste, which could be expected, however it is expected that the majority of the waste generated will be domestic or general waste. Some sludge may be generated during the shutdown of the Terminal for annual maintenance operations. CCGT power plant No information is currently available on the cut/fill balance for the CCGT power plant during construction, however some construction waste (building rubble) can be expected. Therefore no assessment can be made of impacts of material waste that may be produced. Based on information provided by Eskom, solid wastes include concentrated sludge from the wastewater treatment plant and demineralization plant. No further information was provided, however other expected waste streams include domestic or general waste, scrap metals, used oil, recyclable material (e.g. paper, plastic, cardboard, glass) and other industrial waste. 8.3 Description of the local waste management infrastructure The general waste disposal sites that will be used by tenants within the Coega IDZ are the Arlington General Landfill and Koedoeskloof Low Hazardous and General Landfill, which are both permitted by DWAF and operated by the Municipality (Raghubir et al., 2002). It is expected that the currently operational Aloes High Hazardous landfill will be closed in the near future and that a regional hazardous waste management facility will be developed to cater for the Nelson Mandela Metropolitan Municipality (NMMM) and the Coega IDZ. A site selection study has been undertaken to identify possible sites for a new regional general and hazardous waste processing facility and the EIA for this facility is underway. The Scoping



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process identified three possible sites on properties outside the Coega IDZ, that will be assessed in more detail during the EIA phase. Currently the Scoping Report has been approved by the authorities and the Plan of Study is being compiled by the environmental consultants, Bohlweki Environmental. The NMMM’s Integrated Waste Management Plan (IWMP) is currently being developed and seeks to encourage waste separation and recycling. The intention, expressed in the draft IWMP, is to reduce the amount of general waste disposed of at landfills by 90% by 2015. This would be achieved mainly through composting of organic material, and implementing a Materials Recovery Facility that will support an Eco-industrial Park. There is, therefore, the potential for industrial developments such as the CIPP to send a larger component of waste for recycling. 8.4 Identification of applicable policies, legislation, guidelines or standards 8.4.1 National legislation and policies There are various Acts and regulations that regulate waste and hazardous chemical management in South Africa, as well as different by-laws that regulate industrial activity. The following are the key Acts which need to be taken into account in planning and designing for materials handling, storage and waste management systems:

• National Environmental Management Act (NEMA), (Act 107 of 1998)

This Act forms the overarching framework for environmental management in South Africa and incorporates, amongst others, the principles embodied in the White Paper on Integrated Pollution and Waste Management for South Africa (January 2000), and the National Waste Management Strategy documents (October 1999). The key principles include moving away from the “end-of-pipe” treatment approach towards the prevention of pollution and waste and avoiding environmental degradation.

• Environmental Conservation Act, (Act 73 of 1989)

Section 20 of this Act indicates that waste can only be disposed of at a waste disposal facility that has a permit issued by the Minister of Water Affairs and Forestry. Such a waste disposal facility must be in accordance with the Department’s Waste Management Series, “Minimum Requirements” documents (DWAF, 1998). Regulations in terms of Section 24-28 stipulate the requirement for a permit from DWAF for temporary onsite storage of hazardous waste.

• National Water Act, (Act 36 of 1998)

This Act includes strict measures to protect water resources. The Act provides for

Coega Integrated Power Project: Environmental Screening Study Final Report, February 2004 - Confidential

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CHAPTER 8

the protection of groundwater resources and has implications for waste storage, disposal and effluent discharge.

• Occupational Health and Safety Act, (Act 85 of 1993)

The following regulations are based on this Act. The first two are particularly relevant to the chemical, petrochemical and gas industries:

Hazardous Chemical Substances Regulations (R1179, 25 August 1995), which identify hazardous chemicals, and how they should be controlled so as to ensure safe working conditions for employees.

Major Hazard Installation Regulations (R6077, 16 January 1998), which sets out the responsibilities for the control of facilities that have, either permanently or temporarily, an installation or a quantity of a substance which can pose a significant risk of resulting in a major incident that could affect the health and safety of persons outside the premises, including the public. A risk assessment is required in order to determine whether or not the different components of the CIPP are to be classified as Major Hazardous Installations. Construction Regulations (R1010, 18 July 2003), which focuses on the health and safety requirements of construction contractors, but also stipulates that all construction waste and debris is removed and disposed of from the site in accordance with the applicable legislation.

• National Road Traffic Act, (Act 83 of 1996)

The following regulations apply to the transportation of dangerous goods and substances by road:

National Road Traffic Regulations (GN R225, 17 March 2000). These regulations incorporate standard specifications developed by the South African Bureau of Standards (SABS) for transportation of dangerous goods and substances by road.

Specific South African legislation on waste management is still undergoing revision. While the Government’s key waste management objectives, (i.e. moving away from fragmented and uncoordinated waste management to integrated waste management in order to reduce both the generation and the environmental impact of waste), are included in legislation such as the National Environmental Management Act (Act 107 of 1998) and Environmental Conservation Act (Act 73 of 1988), the following are currently being written:



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• A Draft Bill on Waste Management is being drawn up by the Department of Environmental Affairs and Tourism (DEAT)

This Bill includes among many other provisions substantial fines (as high as R5 million) for pollution offences. Potential new developments within the Bill include the use of Best Available Technology Not Entailing Excessive Cost (BATNEEC) instead of Best Practicable Environmental Option (BPEO); a requirement for Industry Waste Management Plans; a requirement for the company to have an Environmental Compliance Certificate and requirements for Import/Export of wastes via the Basel Convention.

• Revisions of the current Minimum Requirements Series of documents

developed by DWAF.

In addition to the revisions a new document is being drafted that will cover auditing of waste facilities, staff minimum qualifications and training requirements.

The Polokwane Declaration refers to reduction targets agreed upon by Government, business and labour as long-term goals. Waste generation and waste disposal must be reduced by 50% and 25% respectively by 2012; and zero waste disposal by 2020. 8.4.2 Conditions of the Port of Ngqura Record of Decision The following condition of the Record of Decision for the Port of Ngqura (DEAT, 2002) is applicable to the CIPP project: 2.37 As part of the Environmental Management System (EMS), during each stage of

development, from site preparation to final construction and operation, adequate measures to collect, remove and safely dispose of waste must be instituted for the port, back-of-port and the rest of the IDZ area.

8.4.3 Minimum Requirements for the Handling, Classification and Disposal of

Hazardous Waste In terms of the South African Minimum Requirements for the Handling, Classification and Disposal of Hazardous Waste issued by the Department of Water Affairs and Forestry (DWAF, 1998), hazardous wastes are grouped into four hazard ratings: extreme risk, high risk, moderate risk and low risk. The hazard rating indicates the class of the waste disposal site to which the waste must be disposed (Table 8.1).



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Table 8.1: Classification system for waste disposal sites

HAZARD RATING DISPOSAL SITE CLASS HR1 – Extreme Hazard H:H

HR2 – High Hazard H:H

HR3 – Moderate Hazard* H:h

HR4 – Low Hazard* H:h

General waste** G * Can also be disposed of at a Class H:H disposal site ** Can also be disposal of at Class H:h and Class H:H disposal sites

General waste landfills are further divided into four size categories (Table 8.2):

Table 8.2: Landfill size classes

LANDFILL SIZE CLASS MAX. RATE OF DEPOSITION (MRD) (tones per day)

Communal C < 25

Small S >25 <150

Medium M >150 <500

Large L >500 The potential for significant leachate generation and the need for leachate management is also determined for General Waste sites.

B- : indicates sporadic leachate generation B+ : indicates significant leachate generation

Thus the above abbreviations can be used to describe waste disposal sites. An example of this is:

A landfill with the classification G:M:B+ implies that it is a general waste disposal site with MRD between 150 and 500 tonnes per day, and requiring a leachate management system.



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Table 8.3 presents the minimum requirements for waste handling, storage and transportation.

Table 8.3: Minimum Requirements for waste handling, storage and transportation

SUBJECT MINIMUM REQUIREMENTS

Qualification as disposal site

If a waste is held at a storage site for a period exceeding three months, the site automatically qualifies as a Waste Disposal Site, and must be registered as such and meet all the requirements of a disposal site.

Temporary storage area

A temporary storage area must have a firm, waterproof base and drainage system. It must be so designed and managed that there is no escape of contaminants into the environment.

Identification of waste

The transporter must be provided with accurate information about the nature and properties of the load.

Documentation The transport operator must be provided with the relevant transportation documentation for the consignment.

Security of load The load must be properly loaded and secured on site. Hazchem placard The transport operator must be supplied with the appropriate Hazchem placards.

Hazchem placard The transport operator must ensure that the Hazchem placards are properly fitted to the vehicle.

Vehicle Roadworthiness

The Responsible Person must ensure that before the vehicle leaves the consignor’s premises it is not overloaded or showing any obvious defect that would affect its safety.

Escape of hazardous spillage at site

The Department of Water Affairs and Forestry and the Local Authority must be advised immediately, should it prove impossible to contain spillage of a Hazardous Waste on a site.

Protection against effect of accident

The Generator – or his representative, i.e. transporter – must ensure that adequate steps are taken to minimize the effect an incident or incident may have on the public and on the environment.

Spillage on site The Generator must initiate remedial action to clean up any spillage remaining on a site after an accident,

Notification All road accidents must be reported to the Department of Transport on the prescribed documentation.

Notification In case of an accident, a full report, containing all the information listed in 10.8.2 must be sent to the Department.



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8.4.4 Permit requirements The following table (Table 8.4) identifies the permits and registrations that may be required by the project relating to materials handling and waste management.

Table 8.4: List of permits and registrations required relating to material handling and waste management

No. Permit required Details Government

department

Legislation & Section in the

Act

1 Waste Disposal Site permit

If a waste is held at an onsite storage site for a period exceeding three months, the site automatically qualifies as a Waste Disposal Site, and must be registered as such and meet all the requirements of a disposal site. A permit or an exemption is required.

Department of Water Affairs and Forestry

Environment Conservation Act (Act 73 of 1989), Section 20

2

Major Hazard Installation (MHI)

Permission to construct and operate any installation which may be a major hazard installation is required. A risk assessment, as outlined in the MHI regulations, must be completed by the project proponents in order to determine whether the proposed facility is an MHI. This assessment must be reviewed by a certified inspection authority registered with the Department of Labour prior to submission to the department.

Department of Labour

Occupational Health and Safety Act (Act 85 of 1993), Section 43

3

Waste Information System (WIS) Registration

The LNG terminal and CCGT power plant may need to register as waste generators according to the local IWMP and/or national WIS

Department of Environmental Affairs and Tourism (provincial and/or national)

Potential NEMA Regulation

8.5 Description of materials handling and chemical and solid waste

management issues During all phases of the project (construction, operation and decommissioning) the issues associated with materials handling and waste management are:

The generation of construction waste and its subsequent management in terms of interim storage, transportation and disposal.

The potential contamination of soil and water resulting from accidental leakage or spillage of chemical and solid materials during materials handling (including storage).

The potential reduction in spare landfill and waste processing capacity for both general and hazardous wastes.

These issues are summarized in Table 8.5.



page 8-9

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page

8-1

0


CHAPTER 8

8.6 Scenarios to be considered in the Materials Handling and Chemical and

Solid Waste Management study No scenarios were considered in the Materials Handling and Chemical and Solid Waste Management study. 8.7 Project alternatives No project alternatives were considered in the Materials Handling and Chemical and Solid Waste Management study. It should be noted that the World Bank Pollution Prevention and Abatement Handbook states that for new power plants, combined cycle plants burning natural gas currently have a decisive advantage over other technologies and fuels in terms of their capital costs, thermal efficiency, and environmental performance. Natural gas is also the preferred fuel for minimizing greenhouse gas emissions because it produces lower carbon dioxide emissions per unit of energy and enhances energy efficiency. 8.8 Impact assessment 8.8.1 Construction phase Accidental leakage or spillage of hazardous materials (e.g fuel, oil) may lead to localized contamination of soil or water (e.g. through contamination of stormwater runoff) if not properly managed and cleaned-up immediately. The magnitude of the impact is assessed to be low, however, this largely depends on the volume of pollutant released to the soil or water environment, and the location of the leak or spill relative to sensitive receptors. The industrial, general, and hazardous waste generated during the construction phase of the CIPP will be disposed of at the respective, permitted waste disposal sites. The amounts of these waste types are not expected to be significant and are, therefore, not expected to lead to a significant reduction in spare landfill capacity. Some waste streams may have recycling potential (e.g. scrap metal). The largest waste stream is expected to be construction waste. The largest component of construction waste is expected to be the moved earth and rubble generated by the initial earthworks required to create the necessary terrace for the LNG terminal and CCGT power plant. As the terrace is to be constructed in an area already modified as a result of the current port construction activities (i.e. concrete batching plant and dolos yard) the environmental impacts of the earthworks is assessed to be low. There is currently insufficient information regarding the end destination of surplus earthworks material to assess the impacts associated with its disposal. A summary of potential construction phase impacts is provided in Table 8.5.



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CHAPTER 8

8.8.2 Operations phase Accidental leakage or spillage of hazardous materials (e.g. fuel, oil) may lead to localized contamination of soil or water (e.g. through contamination of stormwater runoff) if not properly managed and cleaned-up immediately. The significance of the impact is assessed to be low, however, this largely depends on the volume of pollutant released to the soil or water environment, and the location of the leak or spill relative to sensitive receptors. According to the draft Integrated Waste Management Plan (IWMP) for the NMMM, there is sufficient airspace (disposal capacity) at the Arlington disposal site (approx. 65 years) and Koedoeskloof disposal site (approx. 25 years). Therefore, the industrial solid waste generated by the CIPP is not expected to impact on the life on these landfill sites significantly. The proposed regional general and hazardous waste processing facility is being designed to cater for the waste disposal needs of the region in the future (next 100 years) and it is likely that this facility will be designed to accommodate the hazardous waste from development options within the Coega IDZ and Port Elizabeth Region (Raghubir et al., 2002). Therefore, the small amount of hazardous waste generated by the CIPP is not expected to have a significant impact on the life of this facility. A summary of potential operations phase impacts is provided in Table 8.5. 8.8.3 Decommissioning phase The decommissioning of the LNG terminal and the CCGT power plant will result in the generation of large amounts of construction waste (building rubble and scrap metal), which will require transportation off the site. Insufficient information is available at this stage to assess the impacts of decommissioning, however it is envisaged that the bulk of the generated waste will be recycled and/or reused.



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Ta

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8.6:

Con

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8-1

3


CHAPTER 8

8.9 Specification of environmental thresholds Due to the limited information on the type and quantities of waste produced during construction and operation of the CIPP no environmental thresholds have been established.

8.10 Recommendations for project planning and design A general recommendation for the project planning, and design stage is the conceptualisation and establishment of a Materials Handing and Waste Management System for the project. Such a system should consider the use of a life cycle assessment approach where the environmental impacts of materials used and waste generated are considered:

throughout the life cycle of the project; and throughout the life cycle of the material used or waste generated.

The project planning and design stage should also consider the application of cleaner production principles and the use of environmentally acceptable materials (e.g. less energy intensive materials, materials that can be recycled) for construction and operations.

8.10.1 Materials handling The following recommendations are pertinent to the further project planning and engineering design:

All materials handling areas (loading and unloading areas) should be designed with compartmentalisation and proper bunding to ensure containment of spillages.

As far as possible loading and unloading should occur in bunded areas to contain any spillage which may occur.

Oil feed piping should be run within the lube-oil reservoir drain line, or drain channels to avoid oil being lost in the event of a pipeline leakage.

Materials to be handled in such a manner so as to minimize the generation of airborne dust (e.g. loading and unloading to occur in covered, wind still areas).

8.10.2 Waste management The following waste management hierarchy should be adopted for both the construction and operations phase to mitigate environmental impacts:

minimise the generation of waste

re-use the waste

re-use or recycle waste streams by other users at other locations

dispose unusable waste streams at permitted waste disposal facilities



page 8-14


CHAPTER 8

The project should be serviced by a competent and legally compliant waste management contracting company that will be responsible for the off-site removal of waste streams to the final destinations (e.g. permitted waste disposal sites, recycling centres). During both construction and operation it is recommended that re-useable and recyclable waste (e.g. scrap metal, used oil) should be sent to recycling centres within the NMMM, or – if unavailable – to recycling centers in other parts of the country. It must be noted that even though the waste contracting company is responsible for the transportation of the waste, the respective project proponents will still remain responsible for the environmentally acceptable recycling and disposal of the waste. As stipulated by the Minimum Requirements for Waste Disposal (DWAF, 1998), all landfill waste must be disposed of at a permitted waste disposal site. It is, therefore, the project proponent’s responsibility to ensure that the waste is transported and disposed of at permitted waste disposal sites. 8.11 Recommendations for baseline monitoring and more detailed studies In order to assess impacts associated with different waste streams during the EIA process, the typical solid and chemical wastes associated with existing LNG terminals and CCGT power plants of similar size and characteristics should be sourced, recorded and characterised in terms of the following:

Waste description

Waste source

Quantities generated

Waste composition

Waste classification

Disposal options

Behaviour when leaked, spilt or not properly disposed of

The objective of collating this information is to plan for and promote the separation of waste streams at the source in order to ensure that wastes are correctly disposed of, or alternatively recycled or reused. An associated benefit is the minimization of costs associated with unnecessary landfilling. The disposal of waste at H:h and H:H Class landfill sites is more expensive than disposal at an Industrial waste disposal site (Class G). This is mainly due to the additional measures taken at the H:h and H:H Class sites to reduce the environmental impacts (e.g. leachate management systems). It would, therefore, be in the project proponent’s interest to assemble this information at an early stage to correctly classify the expected waste streams.



page 8-15


CHAPTER 8



page 8-16

Project proponents should clarify plans for disposing of earthworks material prior to the start of the EIA process in order for a proper assessment to be made of the associated impacts. It is recommended that investigations into the reuse or recycling of the different wastes be initiated so that measures for promoting reuse and recycling can be implemented when the project is operational. It is recommended that an overall waste stream inventory is compiled for the proposed project, including solid waste, liquid effluents and gaseous emissions. This will serve as a basis for other EIA specialist studies, as well as a starting point for the Environmental Management System that is expected to be instituted. A review of the technology is also recommended/proposed to benchmark the proposed CCGT technology as Best Available Technology (BAT) in terms of

process efficiency,

overall environmental acceptance, and

sustainable development.

The potential of generating carbon credits through the Kyoto Protocol CDM initiative can also be evaluated. The EIA should include Route Risk Assessments as per the regulation governing the transportation of hazardous waste (as per GN R 225 part of the National Road Traffic Regulations, 2000)

chapter 8fred.csir.co.za/project/cip_eia/pages/ess_ch8.pdf · chapter 8 the protection of...

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