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PROPOSED POWER GENERATION
PLANT THROUGH THE PYROLYSIS
OF ABATTOIR WASTE,
KROONSTAD, FREE STATE
DRAFT ENVIRONMENTAL IMPACT
ASSESSMENT (EIA) REPORT
DEA waste licence Ref No: 12/9/11/L1391/2
July 2014
ESCIENCE
ASSOCIATES
(PTY) LTD
POSTAL
ADDRESS:
PO Box 29Saxonwold
2132
PHYSICAL
ADDRESS:
9 Victoria Street
Oaklands
Johannesburg
2192
TEL:
+27 (0)11 728 2683
FAX:
086 512 5681
WEBSITE:
www.escience.co.za
E-MAIL:
DRAFT EIA REPORT
PROPOSED POWER GENERATION PLANT THROUGH THE PYROLYSIS OF ABATTOIR WASTE, KROONSTAD
EScience Associates (Pty) Ltd Page i
ENVIRONMENTAL IMPACT ASSESSMENT REPORT: PROPOSED POWER GENERATION PLANT THROUGH THE PYROLYSIS OF
ABATTOIR WASTE, KROONSTAD, FREE STATE
COMPILED BY EAP:
EScience Associates (Pty) Ltd.
PO Box 2950
Saxonwold
2132
Tel: (011) 728 2683
Fax: 086 610 6703
E-mail: [email protected]
ON BEHALF OF APPLICANT:
Square Root Trading Seven (Pty) Ltd
T/A Country Meat Abattoir
PO Box 1932
Kroonstad
9500
Tel: (056) 631 0120
Fax: (056) 631 0120
E-mail: [email protected]
PREPARED FOR REVIEW BY COMPETENT AUTHORITY:
National Department of Environment Affairs (DEA)
2nd Floor, North Tower
Fedsure Forum Building
315 Pretorius Street
c/o Pretorious and van der Walt Streets
Pretoria
0001
Tel: (012) 310 3920
Fax: (012) 310 3753
July 2014
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PROJECT INFORMATION SHEET
Project:
PROPOSED POWER GENERATION PLANT THROUGH THE PYROLYSIS OF ABATTOIR WASTE,
KROONSTAD
Project Applicant:
Square Root Trading Seven (Pty) Ltd T/A Country Meat Abattoir
Postal Address: PO Box 1932, Kroonstad, 9500
Tel: (056) 631 0120
Fax: (056) 631 0120
E-mail: [email protected]
Environmental Assessment Practitioner:
EScience Associates (Pty) Ltd.
Postal Address: PO Box 2950, Saxonwold, 2132
Contact: Tel: (011) 718 6380
Fax: 086 610 6703
E-mail: [email protected]
Project Leader: Theo Fischer
Competent Authority:
National Department of Environment Affairs (DEA)
Postal Address: 2nd Floor, North Tower, Fedsure Forum Building
315 Pretorius Street, Pretoria, 0001
Contact: Malepo Phoshoko
Tel: (012) 310 3741
Fax: (012) 310 3753
Report history and details:
Report Name and Status: Draft EIA
Draft report issued for public review: July 2014
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EXECUTIVE SUMMARY
Square Root Trading Seven (Pty) Ltd. (hereafter referred to as SRTS) has appointed
EScience Associates (Pty) Ltd. (hereafter referred to as ‘ESA’), as independent
Environmental Assessment Practitioner (EAP), to undertake an Environmental Impact
Assessment (EIA) to assess the environmental feasibility of the proposed establishment
of a power generation plant through the pyrolysis of abattoir waste in Kroonstad, Free
State. ESA was appointed to facilitate the application for obtaining a Waste
Management License and an Atmospheric Emissions Licence for the proposed facility.
The aforementioned application was submitted to the National Department of
Environmental Affairs (DEA) on 14th November 2013, and acknowledged by the DEA
on 22nd November 2013. The application was assigned the reference number
12/9/11/L1391/2. The final scoping report, after having undergone public review, was
submitted to the DEA on 29th May 2014. The DEA accepted the scoping report on 4th
July 2014 and a letter stating the acceptance of the Scoping Report was received by
the EAP on 7th July 2014
The process of pyrolysis involves heating organic materials to greater than 600°C in the
absence of oxygen. The SRTS project will use dewatered abattoir waste that would
otherwise be disposed to landfill. Resulting products are renewable electricity and bio-
char/ pyrolysis ash. Reprocessing /recovery is ranked third out of seven waste
management options in the internationally recognised waste management hierarchy,
after reuse but above recycling. As it is not feasible to reuse abattoir waste, recovery of
energy and other products is most likely to qualify as the Best Practicable
Environmental Option.
The existing abattoir site will be used to house the facility and the waste generated
from the abattoir which is, at present, transported off site to be disposed of at a landfill
disposal site will be fed into the pyrolysis plant so as to produce syngas which will be
utilised in the generation of electricity by means of internal combustion engines. There
will be provisions made for the storage of 40m3 of the dewatered waste on site for
utilisation over weekends. The proposed facility’s primary activities would be as follows:
The separation of water from the abattoir waste through a screw press or similar
mechanical means, thereby separating a large percentage of water from the
waste;
Short term storage of dewatered abattoir waste for processing and generation
of electricity when abattoir is not operational;
The pyrolysis of the abattoir waste for the generation of syngas (heating organic
materials to greater than 600°C in the absence of oxygen); and
Generation of electricity to be used by abattoir through the combustion of
syngas in an internal combustion engine.
The proposed project requires SRTS to undertake several so-called ‘listed’ waste
management activities, which may not commence prior to obtaining a Waste
Management Licence, in terms of Section 20(b) of the National Environmental
Management: Waste Act, 2008 (Act No. 59 of 2008)[NEM:WA]; where Schedule 1 under
NEM:WA (GN. R. 921 of November 2013) provides an inclusionary list of waste
management activities for which licencing is required.
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Due to the nature and/or scale of the activities that would be associated with the
subject waste license application, the NEM:WA requires that the potential
environmental impacts must be considered, investigated, assessed and reported on to
the competent authorities through a Scoping and detailed Environmental Impact
Assessment (EIA) process, as per the relevant provisions of GN. R. 543 of June 2010 as
amended by GN.R 1159 of December 2010 (the so called 2010 NEMA EIA Regulations),
promulgated in terms of Section 24(5) of NEMA. The application was submitted whilst
the waste management activities were listed under GN.R 718 of 2009 which has since
been replaced by GN. R.921 of 29 November 2013.
Waste management activities that will be triggered according to Categories A and B
of Schedule 1 (GN. R.921 of 29 November 2013) to the NEM:WA, are as follows:
Applicable ‘Category A’ (Basic Assessment) Activities:
Category A -
Activity No. 3
(12)
The construction of a facility for a waste management activity listed in
Category A of this schedule (not in isolation to associated waste
management activity).
REASON: The establishment of the facility will require the construction
of structures and infrastructure supporting of the proposed waste
management activities identified above.
Applicable ‘Category B’ (Scoping and EIA) Activities
Category B -
Activity (3)
The recovery of waste including the refining, utilisation, or co-
processing of the waste at a facility that processes in excess of 100
tons of general waste per day or in excess of 1 ton of hazardous waste
per day, excluding recovery that takes place as an integral part of an
internal manufacturing process within the same premises.
REASON: the proposed facility would have the capacity to recover 10
tons of hazardous waste per day in order to generate electricity.
Category B -
Activity (4)
The treatment of hazardous waste in excess of 1 ton per day
calculated as a monthly average; using any form of treatment
excluding the treatment of effluent, wastewater or sewage.
REASON: The pyrolysis of waste is considered treatment.
Category B -
Activity (10)
The construction of facilities for a waste management activity listed in
Category B of this schedule (not in isolation to associated activity).
REASON: The establishment of the facility will require the construction
of structures and infrastructure supporting of the proposed waste
management activities identified above.
A scoping report was completed in order to identify and discuss issues of potential
environmental significance, and where possible, indicate the significance of those
impacts, so as to inform the scope of the Environmental Impact Assessment (EIA)
phase. The initial identification and assessment of environmental impacts revealed the
following potentially significant environmental aspects which required further detailed
assessment:
Emissions, air quality and odour impact, and
Waste management handling and disposal
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Environmental Impact Assessment aims to ensure effective compliance and
governance concerning the sustainable use of environmental resources, while
simultaneously focusing on key issues such as stakeholder empowerment, providing
access to relevant and concise information to enable informed decision-making. This
EIA Report was compiled through the execution of a methodology set out to produce
a report in compliance with the requirements of Section 31 of GN. R.543 as amended
by GN.R 1159 of December 2010, in terms of Chapter 5 of the National Environmental
Management Act,1998 (Act No. 107 of 1998, as amended)[NEMA].
It is the professional opinion of the EAP that the EIA process undertaken for the project
to date has been procedurally correct, in terms of, inter alia, the requirements outlined
in Government Notice No. 543-546 of June 2010 as amended by GN.R 1159 of
December 2010. The EAP, furthermore, believes that the significant issues that may
potentially be realised through the possible authorisation of the project by the
Competent Authority have indeed been identified to the greatest extent possible /
practical. The EAP also believes that the information provided in this EIA Report was
sufficient /substantive for IAPs to have contributed meaningfully to the EIA process thus
far (as required by Government Notice 543 as amended by GN.R 1159 of December
2010) and for the competent authority (CA) to make an informed decision as to
whether, or not activity should be authorised. It is, therefore, the EAPs recommendation
that the CA approve this activity based on the substantive content provided in the
report itself.
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TABLE OF CONTENTS
EXECUTIVE SUMMARY III
1. INTRODUCTION 1
1.1 BACKGROUND 1 1.2 WHAT IS AN EIA? 5
1.2.1 Scoping and Scoping Report 6 1.2.2 Plan of Study for EIA 8
1.3 DETAILS OF ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP) 9 1.4 RELEVANT AUTHORITIES 9 1.5 CONSULTATION WITH THE COMPETENT AUTHORITY 10
2. OVERVIEW OF CURRENT OPERATIONS 11
2.1 SURFACE INFRASTRUCTURE 11 2.2 CURRENT SITE WATER MANAGEMENT AND SUPPLY 11
2.2.1 water supply 11
3. PROJECT DESCRIPTION 12
3.1 PROPOSED WASTE MANAGEMENT ACTIVITIES 12 3.1.1 Hazardous waste Storage 13 3.1.2 General Waste Storage 13 3.1.3 Treatment and disposal of water seperated from waste 13 3.1.4 Pyrolysis of waste for generation of Syngas 13
3.2 PROPOSED ELECTRICITY GENERATION 14 3.2.1 .Gas clean-up system 14
3.3 THE USE OF ASH AS FERTILISER & SOIL ADDITIVE 14
4. ALTERNATIVES 16
4.1 SITE ALTERNATIVES 16 4.2 PROCESS/TECHNOLOGY ALTERNATIVES 17
4.2.1 Non-Thermal WTE Alternatives 17 4.2.2 Thermal WTE alternatives 18
4.3 LAYOUT, DESIGN OR SCALE ALTERNATIVES 22 4.4 OPERATION AND SCHEDULING ALTERNATIVES 22 4.5 NO-GO ALTERNATIVE 22
5. LEGAL AND POLICY FRAMEWORK 23
5.1 NATIONAL ENVIRONMENTAL MANAGEMENT ACT (NEMA) 23 5.1.1 Duty of Care 24
5.2 WASTE MANAGEMENT AND LICENSING 25 5.2.1 Definition of Waste 25 5.2.2 WASTE MANAGEMENT LICENSING 26
5.3 WASTE CLASSIFICATION 30 5.4 AIR QUALITY AND LICENSING 32 5.5 OTHER RELEVANT LEGISLATION TO BE CONSIDERED 38
5.5.1 National Water Act 38 5.5.2 OCCUPATIONAL HEALTH AND SAFETY 38 5.5.3 The Noise Control Regulations 39 5.5.4 National Heritage Resources Act 39 5.5.5 Access to information 39
6. PUBLIC PARTICIPATION 41
6.1 PUBLIC PARTICIPATION PROCESS FOR SCOPING PHASE 41 6.1.1 Participation Process 41
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6.1.2 Comments and issues 42 6.2 PUBLIC PARTICIPATION PROCESS FOR EIA PHASE 42
6.2.1 Participation Process 42 6.2.2 Key dates 42
7. DESCRIPTION OF THE RECEIVING ENVIRONMENT 43
7.1 LOCATION, LAND-USE AND ZONING 43 7.2 CLIMATE 44
7.2.1 Temperature 44 7.2.2 Rainfall 44 7.2.3 Wind 45
7.3 TOPOGRAPHY 46 7.4 GEOLOGY AND SOILS 46 7.5 FAUNA AND FLORA 46 7.6 SURFACE WATER 47
7.6.1 Surface water quality 47 7.7 GROUNDWATER 49
7.7.1 Aquifer characterisation 49 7.8 GROUNDWATER QUALITY 50 7.9 AMBIENT AIR QUALITY 50
8. IMPACT ASSESSMENT METHODOLOGY 52
8.1 INTRODUCTION 52 8.2 TYPE OF IMPACTS 54 8.3 DETERMINING SIGNIFICANCE 55
8.3.1 Nature 55 8.3.2 Extent 55 8.3.3 Duration 55 8.3.4 Intensity 56 8.3.5 Probability 56 8.3.6 Mitigation or Enhancement 56 8.3.7 Reversibility 58
8.4 CALCULATING IMPACT SIGNIFICANCE 58 8.5 UNDERSTANDING IMPACT SIGNIFICANCE 59
9. IMPACT SIGNIFICANCE ASSESSMENT/ANALYSIS 61
9.1 INDICATORS OF POTENTIAL IMPACT SIGNIFICANCE 61 9.2 CONSTRUCTION PHASE 62
9.2.1 Noise 63 9.2.2 Biodiversity 65 9.2.3 Construction and installation waste generation (contribution to landfill) 65 9.2.4 Groundwater and Surface water quality 67 9.2.5 Air quality 68
9.3 OPERATIONAL PHASE 70 9.3.1 Noise 70 9.3.2 Groundwater Pollution 72 9.3.3 Air quality 74 9.3.4 Socio Economic 79
10. ASSESSMENTS OF CUMULATIVE IMPACTS 80
11. CONCLUSIONS AND EAP RECOMMENDATIONS 81
11.1 IN SUMMARY 81 11.2 CONCLUSIONS 81
11.2.1 Construction 81 11.2.2 Operation 81
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12. REFERENCES 83
APPENDIX 1: AUTHORITY CORRESPONDENCE 84
APPENDIX 2: WASTE MANAGEMENT LICENSE APPLICATION FORM 85
APPENDIX 3: LAYOUT PLAN FOR PROPOSED STRUCTURES AND INFRASTRUCTURE 86
APPENDIX 4: PUBLIC PARTICIPATION DOCUMENTATION 87
APPENDIX 5: SCOPING REPORT 88
APPENDIX 6: EAP CV’S 89
APPENDIX 7: AIR QUALITY IMPACT ASSESSMENT 90
APPENDIX 8: WASTE ASSESSMENT 91
APPENDIX 9: ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT 92
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LIST OF FIGURES
Figure 1-1: Regional Locality ....................................................................................................... 3 Figure 1-2: Satellite Image of the SRTS abattoir and surrounding land-use ......................... 4 Figure 1-3: Fezile Dabi District Municipality ............................................................................... 5 Figure 1-4: Generic Scoping and EIA Process Flow Diagram ................................................ 7 Figure 3-1: Overview of proposed operations ....................................................................... 15 Figure 4-1: Anaerobic Digestion WTE Plant ............................................................................. 17 Figure 4-2: Incineration .............................................................................................................. 18 Figure 4-3: Plasma arc gasification WTE plant ....................................................................... 19 Figure 4-4: Thermal Depolymerisation (TDP) plant (adapted from Cutting Edge, 2006) . 20 Figure 4-5: Gasification WTE Plant ............................................................................................ 21 Figure 5-1: Scoping and EIA Process for Waste Licensing .................................................... 29 Figure 5-2: Interrelationship between the EIA and AEL Processes....................................... 37 Figure 7-1: Annual Wind Rose Kroonstad SAWS station from 2005-2008. ........................... 45 Figure 7-2: Topographical map ............................................................................................... 46 Figure 7-3 Middle Vaal Water Management Area ............................................................... 48 Figure 7-4: Highveld and Vaal Triangle Priority Areas ........................................................... 51 Figure 9-1: Predicted PM10 maximum 24-Hour average ambient concentration for the
Proposed Waste to Energy Project .................................................................................. 75 Figure 9-2: Predicted SO2 maximum hourly average ambient concentration for the
Proposed Waste to Energy Project .................................................................................. 76 Figure 9-3: Predicted NOx hourly maximum ambient concentration for the Proposed
Waste to Energy Project .................................................................................................... 77 Figure 9-4: Predicted CO hourly maximum ambient concentration for the Proposed
Waste to Energy Project .................................................................................................... 78
LIST OF TABLES
Table 1-1: Details of the EAPs ..................................................................................................... 9 Table 1-2: Authority Consultation ............................................................................................. 10 Table 5-1: EIA Activities .............................................................................................................. 24 Table 5-2: NEMWA Listed Waste Management Activities at the time of Application,
listed under GN R.718 ......................................................................................................... 27 Table 5-3: NEMWA Listed Waste Management Activities listed under GN R.921 ............. 28 Table 5-4: Waste type classification of waste according to concentration thresholds
from the national norms and standards (23 August 2013) ........................................... 30 Table 5-5: Landfill requirements based on waste type from the national norms and
standards (23 August 2013) ............................................................................................... 30 Table 5-6: Category 8: Thermal Treatment of Hazardous and General Waste................. 33 Table 6-1: Key Dates in EIA Phase ............................................................................................ 42 Table 7-1 Aerial over view of Square Root Trading Seven (Pty) Ltd (Google) .................. 43 Table 7-2 Average monthly rainfall (mm) for Kroonstad ...................................................... 44 Table 8-1: Selected Definitions of Significance ...................................................................... 53 Table 8-2: Scoring for Significance Criteria............................................................................. 58 Table 8-3: Final Significance Scoring ....................................................................................... 59 Table 9-1: Impacts on Ambient Noise Levels (Construction) ............................................... 64 Table 9-2: Impacts on biodiversity (Construction) ................................................................. 65 Table 9-3: Impacts of Construction Waste Generation (Construction)............................. 66 Table 9-4: Impacts on Water Resource Quality (Construction) ........................................... 67 Table 9-5: Impacts on Air Quality (Construction) .................................................................. 69
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Table 9-6: Impacts on Ambient Noise Levels (Operation) ................................................... 71 Table 9-7: Impacts on Water Resource Quality (operation) ................................................ 72
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ABBREVIATIONS
AQIA Air Quality Impact Assessment
DEA Department of Environmental Affairs
DWA Department of Water Affairs
ECA Environment Conservation Act, Act No. 73 of 1989
EIA Environmental Impact Assessment
EIR Environmental Impact Report
EMP Environmental Management Plan
IAPs Interested and Affected Parties
IDP Integrated Development Plan
IPWM Integrated Pollution and Waste Management
NEMA National Environmental Management Act, Act No. 107 of 1998
NEMA EIA
Regulations Regulations GN R.543, R.5444, 545 and R.546 (18 June 2010), as amended
by GN.R 1159 of December 2010, promulgated in terms of Section 24(5) read with
Section 44, and Sections 24 and 24D of the National Environmental Management Act,
1998
NEMAQA National Environment Management: Air Quality Act, Act No. 39 of 2004
NEMWA National Environmental Management: Waste Act, Act No. 59 of 2008
NWA National Water Act, Act No. 36 of 1998
POSEIA Plan of Study for EIA
SR Scoping Report
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DEFINITIONS Alternative - A possible course of action, in place of another, that would meet the same
purpose and need defined by the development proposal. Alternatives considered in the
EIA process can include location and/or routing alternatives, layout alternatives, process
and/or design alternatives, scheduling alternatives or input alternatives.
Aspect – Element of an organisation’s activities, products or services that can interact with
the environment.
Auditing - A systematic, documented, periodic and objective evaluation of how well the
environmental management plan is being implemented and is performing with the aim of
helping to safeguard the environment by: facilitating management control which would
include meeting regulatory requirements. Results of the audit help the organisation to
improve its environmental policies and management systems.
Contamination - Polluting or making something impure.
Corrective (or remedial) action - Response required to address an environmental problem
that is in conflict with the requirements of the EMP. The need for corrective action may be
determined through monitoring, audits or management review.
Degradation - The lowering of the quality of the environment through human activities, e.g.
river degradation, soil degradation.
Environment - Our surroundings, including living and non-living elements, e.g. land, soil,
plants, animals, air, water and humans. The environment also refers to our social and
economic surroundings, and our effect on our surroundings.
Environmental Impact Assessment (EIA) - An Environmental Impact Assessment (EIA) refers
to the process of identifying, predicting and assessing the potential positive and negative
social, economic and biophysical impacts of a proposed development. The EIA includes
an evaluation of alternatives; recommendations for appropriate management actions for
minimising or avoiding negative impacts and for enhancing positive impacts; as well as
proposed monitoring measures.
Environmental Management System (EMS) - Environmental Management Systems (EMS)
provide guidance on how to manage the environmental impacts of activities, products
and services. They detail the organisational structure, responsibilities, practices,
procedures, processes and resources for environmental management. The ISO14001 EMS
standard has been developed by the International Standards Organisation.
Environmental policy - Statement of intent and principles in relation to overall
environmental performance, providing a framework for the setting of objectives and
targets.
Hazardous waste – Waste, even in small amounts, that can cause damage to plants,
animals, their habitat and the well-being of human beings, e.g. waste from factories,
detergents, pesticides, hydrocarbons, etc.
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Impact - A description of the potential effect or consequence of an aspect of the
development on a specified component of the biophysical, social or economic
environment within a defined time and space.
Infrastructure - The network of facilities and services that are needed for economic
activities, e.g. roads, electricity, water, sewerage.
Integrated Environmental Management (IEM) - A way of managing the environment by
including environmental factors in all stages of development. This includes thinking about
physical, social, cultural and economic factors and consulting with all the people affected
by the proposed developments. Also called "IEM".
Mitigation - Measures designed to avoid, reduce or remedy adverse impacts on the
environment.
Proponent – Entity which applies for environmental approval and is ultimately accountable
for compliance to conditions stipulated in the Environmental authorisation (EA) and
requirements of the EMP.
Resources - Parts of our natural environment that we use and protect, e.g. land, forests,
water, wildlife, and minerals.
IAPS / Stakeholders - A sub-group of the public whose interests may be positively or
negatively affected by a proposal or activity and/or who are concerned with a proposal
or activity and its consequences. The term includes the proponent, authorities and all
interested and affected parties.
Waste Management – Classifying, recycling, treatment and disposal of waste generated
during construction, operation and decommissioning activities.
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1. INTRODUCTION
1.1 BACKGROUND Square Root Trading Seven (Pty) Ltd. (hereafter referred to as SRTS) has appointed
EScience Associates (Pty) Ltd. (hereafter referred to as ‘ESA’), as independent
Environmental Assessment Practitioner (EAP), to undertake an Environmental Impact
Assessment (EIA) to assess the environmental feasibility of the proposed establishment of a
power generation plant through the pyrolysis of abattoir waste in Kroonstad, Free State.
ESA was appointed as independent EAP to conduct the scientific investigations of the EIA,
and to facilitate the associated legal and administrative processes required to obtain the
necessary Environmental Authorisations (namely a Waste Management Licence, and an
Atmospheric Emissions Licence) for the proposed facility.
The aforementioned application was submitted to the National Department of
Environmental Affairs (DEA) on 14th November 2013, and acknowledged by the DEA on
22nd November 2013. The application was assigned the reference number
12/9/11/L1391/2. The final scoping report, after having undergone public review, was
submitted to the DEA on 29th May 2014. The DEA accepted the scoping report on 4th July
2014 and a letter stating the acceptance of the Scoping Report was received by the EAP
on 7th July 2014
SRTS presently operates an abattoir on 22 11th Avenue, Kroonstad, Free State and intends
to establish the pyrolysis plant on this site. The site lies on the outskirts of Kroonstad Industria.
Refer to Figure 1-1 to Figure 1-3.
• The site currently hosts the Country Meat abattoir capable of slaughtering 200
animals per day.
• The abattoir buys feedlot cattle on a daily basis for slaughter from various farmers
and feedlots in and around Kroonstad.
• The property is approximately 2.4 ha in extent, and the total existing infrastructure
coverage (buildings, offices, workshops etc.) on-site occupies approximately 50% of
the site.
• The area on which the proposed facility is to be constructed is roughly 60m2.
High cost of energy and the potential to recover energy through improved waste
management coupled to this is the high cost of transporting the abattoir waste to suitable
landfills has led to SRTS exploring alternative, more sustainable means of dealing with the
abattoir waste it generates as part of it operations.
The proposed development, if implemented, would act towards solving some significant
issues currently facing South Africa; such as the current power crisis, the retrieval of
material and energy value from waste, reduction of waste to landfill, reducing of
hazardousness of waste before disposal.
The existing abattoir site will be utilised for the waste to energy facility and the waste
generated from the abattoir which is, at present, transported off site to be disposed of will
be fed into the pyrolysis plant. The pyrolysis technology will utilise abattoir waste to
produce synthetic gas (syngas) for use in a gas engine for power generation (guaranteed
0.12 MW). Pyrolysis involves heating organic materials to temperatures greater than 350 °C
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in the absence of oxygen. Under these conditions, the abattoir waste is decomposed and
a large portion of the dry mass is volatilised to produce syngas with the remaining solids
converted into a char product. The syngas generated in the pyrolysis phase will then be
sent to a generator for electricity generation. Additionally provision will be made for
storage of 40m3 of abattoir waste on site. The proposed facility’s primary activities would
be as follows:
• Storage of abattoir waste;
• The drying of abattoir waste in a centrifuge, thereby separating a large
percentage of water from the waste;
• The generation of syngas through the pyrolysis of the abattoir waste; and
• Generation of electricity from the syngas which is to be used by abattoir
The proposed project concerns renewable energy generation and will be bid in terms of
the Department of Energy Small Renewables Bid programme.
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Figure 1-1: Regional Locality
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Figure 1-2: Satellite Image of the SRTS abattoir and surrounding land-use
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Figure 1-3: Fezile Dabi District Municipality
1.2 WHAT IS AN EIA?
The International Association for Impact Assessment (IAIA) defines an environmental
impact assessment as "the process of identifying, predicting, evaluating and mitigating
the biophysical, social, and other relevant effects of development proposals prior to major
decisions being taken and commitments made.” Environmental Impact Assessment (EIA)
in South Africa is predominantly undertaken in response to, and within the bounds of, a
well-defined and robust legal framework. A myriad of ‘environmental’ Acts, Regulations,
Policies and Guidelines have relevance in this regard (Section 5 refers), all of which aim at
giving effect to the fundamental environmental rights enshrined upon all South African
Citizens within section 24 of the constitution, 1996 (Act No. 108 of 1996).
An EIA is a methodical and systematic process to identify potential positive and negative
impacts on the bio-physical, socio-economic and /or cultural environment that may result
from an activity (i.e. opencast mining operations in this instance). The minimum
requirements for EIA practice in South Africa are largely prescribed in Regulations (GN. R.
543 of June 2010 as amended by GN.R 1159 of December 2010) under the National
Environmental Management Act (Act N0. 107 of 1998) [NEMA]. The NEMA EIA Regulations
lay out clear enviro-legal administrative requirements for EIA process, public participation
(stakeholder engagement) and reporting alike.
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The EIA aims to ensure effective compliance and governance concerning the sustainable
use of environmental resources, while simultaneously focusing on key issues such as
stakeholder empowerment, and providing access to relevant and concise information to
enable informed decision-making by competent authorities exercising a regulatory role in
any aspect of the project proposal.
The EIA process is also used to examine alternatives and management measures to
minimise negative- and optimise positive impacts resulting from a project, or activity. The
ultimate objectives of the EIA process are to prevent significant detrimental impact on the
environment and to ensure sustainable development into the future. An EIA should not
aim to stop, hinder or obstruct development, but should rather act as a ‘green-filter’ to
development proposals, that seeks to ensure that developments / activities proceed in an
environmentally acceptable and sustainable manner (unless of course significant impact
may result from an activity that truly renders the undertaking of that activity ‘fatally
flawed’).
The EIA has to consider the different perspectives and requirements of all role players, who
derive different benefits from participating in the EIA process. These include the following:
Decision-making Authorities:
Enables informed decision making
Ensuring protection of environmental quality
Supporting the management, monitoring and sustainable utilisation of resources
Understanding demands on bulk services, waste disposal sites, etc.
Project proponents:
Pro-actively considering environmentally sustainable design and management
principles in all that they undertake
Investigating natural resource opportunities and constraints
Identifying the risks and opportunities associated with environmental and
operational aspects
Evaluating the potential for pollution and the prevention thereof
Optimising energy, water and other resource use
Interested and affected parties (IAPs):
Providing an opportunity to be informed and give comment/express concerns
Protecting environmental rights
Utilising local and indigenous knowledge
Increasing knowledge and environmental awareness
Informing the decision-making process
1.2.1 SCOPING AND SCOPING REPORT
The ‘Scoping and EIA’ process prescribed in the 2010 NEMA EIA Regulations (GN. R. 543 of
June 2010 as amended by GN.R 1159 of December 2010), as the name suggests, is
divided into two main phases. These are the initial ‘scoping’ and the subsequent ‘EIA
phase’ (Figure 1-4). The scoping phase of this environmental assessment sought to identify
the key issues and potential impacts, from the project proposal that warranted further
detailed investigation during the EIA phase of the process.
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Figure 1-4: Generic Scoping and EIA Process Flow Diagram
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The preceding scoping report thus resulted in the establishment of the technical terms of
reference (ToR), in the form of a Plan of Study for EIA (PoSEIA,) for this EIA phase.
1.2.2 PLAN OF STUDY FOR EIA
A methodology for specialist study has been developed; this is referred to as a plan of
study for EIA. This has been formulated to meet the requirements for a Plan of Study for
Environmental Impact Assessment (EIA) as set out in regulation 29.1(i) of GN R.385,
promulgated in terms of chapter 5 of the National Environmental Management Act (Act
No. 107 of 1998) (Full Plan of Study for EIA can be found in Appendix 5: Scoping Report.
The following key aspects were identified be informed by specialist study (and are
addressed in respective specialist studies):
Air quality impact assessment: to study criteria pollutants emitted by various
sections of the proposed site operations with focus on pyrolysis plant, so as to allow
specification of emissions abatement technology and plant parameters (e.g. stack
height) and ensure that no odour impacts result, based on the DEA Guideline to Air
Dispersion Modelling for Air Quality Management; and
Waste treatment and disposal process assessment: to investigate requirements for
waste handling, storage, treatment and disposal.
Also it was determined during the Scoping phase that operational control and
monitoring of the facility will be required to ensure that impacts are minimised as
follows (and is addressed in Appendix 9: Environmental Management Programme
Report)
The identification and initial assessment of environmental aspects revealed the following
potentially significant environmental aspects are assessed in further detail in this EIA-
phase:
Operational and Environmental Management and Monitoring: to assess the
adequacy of operational plans and developing environmental management and
monitoring plans adequate to ensure potentially significant impacts do not realise
from the site.
The PoSEIA was used as the basis for defining the nature and extent of the investigations
and specialist assessments undertaken as part of the EIA phase. This impact significance
assessment thus involves the execution of those ToR; where it aims to assess in detail, and
quantify as far as possible, the significance (in respect of the nature, duration, extent,
intensity and probability of occurrence thereof) of the identified environmental impacts
posed by the proposed project.
One needs to, however, bear in mind that the natural environment is the most threatened
and irreplaceable resource upon which all the other human aspects depend. The analysis
of impact significance for potential project impacts, furthermore, needs to consider
impacts that may be realised through all project phases, as follows:
Construction/establishment
Operation
Decommissioning and closure
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Impact analysis is, in a sense, the core of the EIA process. It is the phase where all relevant
project information that has been gathered is manipulated and distilled – it is the
Environmental Impact Assessment. The impact analysis has two major goals, starting with
listing and describing all possible environmental impacts and then proceeding to give
some perspective on the relative significance of the various impacts. The predicted
effects of mitigation measures also need to be factored into the impact analysis.
1.3 DETAILS OF ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP)
The EIA for this application was undertaken by EScience Associates (Pty) Ltd., as
independent Environmental Assessment Practitioners (EAP). The study team was led by Mr.
T. Fischer, senior environmental scientists with more than 10 years’ experience in
environmental management (see Appendix 6: EAP CV’s). Brief details of the key
consultants are shown in the table below.
Table 1-1: Details of the EAPs
Name Qualification
Theo Fischer BSc Natural Science
Sam Leyde BSc (Mechanical Engineering)
1.4 RELEVANT AUTHORITIES
The site is located within the jurisdiction of the Moqhaka Local Municipality within the Free
State Province. Authorities with jurisdiction in the application are as follows:
• NEMWA: Due to application concerning the processing of hazardous waste, the
competent authority in terms of this waste license application is the national
Department of Environmental Affairs (DEA).
• NEMAQA: The atmospheric emissions licensing authority resides with the Fezile Dabi
District Municipality.
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1.5 CONSULTATION WITH THE COMPETENT AUTHORITY
Table 1-2: Authority Consultation
Process Phase Details Date
Application Lodge application and declaration of
interest
14th November 2013
Receive confirmation of application 22nd November 2013
Scoping Lodge Scoping Report (Including Plan of
Study for EIA)
29th May 2014
Consideration of Scoping Report and
PoS for Environmental Impact
Assessment
May, June, July 2014
Receive confirmation of acceptance of
Scoping Report and PoSEIA
7th July 2014
EIR Lodge Environmental Impact
Assessment Report
Not yet completed
Receive confirmation of acceptance of
EIR
Not yet completed
Decision on application Not yet completed
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2. OVERVIEW OF CURRENT OPERATIONS
The site is located at 22 11th Avenue, Kroonstad, Free State in an industrial area named
Kroonstad Industria.
The site currently hosts the Country Meat abattoir capable of slaughtering 200
animals per day.
The abattoir buys feedlot cattle on a daily basis for slaughter from various farmers
and feedlots in and around Kroonstad.
The property is approximately 2.4 ha in extent, and the total existing infrastructure
coverage (buildings, offices, workshops etc.) on-site occupies approximately 50%
of the site.
The area on which the proposed facility is to be constructed is roughly 60m2.
2.1 SURFACE INFRASTRUCTURE The total existing infrastructure on site including concrete slabs, roofed warehouses/sheds,
storm water management infrastructure, administrative buildings, access and internal
road network, etc. occupies approximately 1.2 ha of the 2.4 ha site. The proposed Waste
to Energy (WTE) facility to be constructed is roughly 60m2.
2.2 CURRENT SITE WATER MANAGEMENT AND SUPPLY
2.2.1 WATER SUPPLY
Water is released from Serfontein Dam to the Vals River, where it is pumped to Bloemhoek
Dam which supplies water to Kroonstad. 30 % of the total water utilised by the abattoir
originates from this water source.
Municipal water (30%) and borehole water (70%) supply is used for all operations and
processes. The abattoir currently uses 400 000 L of water per day, a large portion of this is
for the cleaning of abattoir floors.
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3. PROJECT DESCRIPTION
The proposed facility will utilise the waste products from the abattoir to generate
electricity. Waste streams, which will predominantly be comprised of blood and paunch
contents but also include condemned carcasses, will be processed though dewatering
and then either fed directly into the pyrolysis plant or stored in a dedicated cold room
prior to being fed into the pyrolysis plant.
The waste will be dewatered down to a 10% moisture content through the use of a screw
press and then pyrolysed to form syngas. The syngas will then be combusted in an internal
combustion engine to generate electricity to be used by the facility itself. Figure 3-1 shows
an overview of the proposed operations. The following sections provide an overview of
the proposed activities envisaged at the site.
3.1 PROPOSED WASTE MANAGEMENT ACTIVITIES
Waste management activities that will be triggered according to Categories A and B of
Schedule 1 (GN. R.921 of 29 November 2013) to the NEM:WA, are as follows:
Applicable ‘Category A’ (Basic Assessment) Activities:
Category A -
Activity No. 3
(12)
The construction of a facility for a waste management activity listed in
Category A of this schedule (not in isolation to associated waste
management activity).
REASON: The establishment of the facility will require the construction of
structures and infrastructure supporting of the proposed waste
management activities identified above.
Applicable ‘Category B’ (Scoping and EIA) Activities
Category B -
Activity (3)
The recovery of waste including the refining, utilisation, or co-processing
of the waste at a facility that processes in excess of 100 tons of general
waste per day or in excess of 1 ton of hazardous waste per day,
excluding recovery that takes place as an integral part of an internal
manufacturing process within the same premises.
REASON: the proposed facility would have the capacity to recover 10
tons of hazardous waste per day in order to generate electricity.
Category B -
Activity (4)
The treatment of hazardous waste in excess of 1 ton per day calculated
as a monthly average; using any form of treatment excluding the
treatment of effluent, wastewater or sewage.
REASON: The pyrolysis of waste is considered treatment.
Category B -
Activity (10)
The construction of facilities for a waste management activity listed in
Category B of this schedule (not in isolation to associated activity).
REASON: The establishment of the facility will require the construction of
structures and infrastructure supporting of the proposed waste
management activities identified above.
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3.1.1 HAZARDOUS WASTE STORAGE
The pyrolysis plant is to be run continuously while the abattoir is only operational from
Monday to Friday. In order for the pyrolysis plant to be run over weekends and public
holidays a stockpile of the abattoir waste will need to be to be created. This stockpile of
abattoir waste will be stored on site in a dedicated cold room. The proposed facility
would thus act as a temporary storage facility for this hazardous waste prior to the
recovery thereof. The system will be designed in a “first in, first out” manner so that no
waste is left in storage for too long a period.
3.1.2 GENERAL WASTE STORAGE
Ash will be generated during the pyrolysis process. This will be stored on site until such time
that it has accumulated to a point that is economically feasible to be transported away
from site and disposed of at a licensed disposal facility.
3.1.3 TREATMENT AND DISPOSAL OF WATER SEPERATED FROM WASTE
The abattoir waste will need to be dewatered down to a moisture content of roughly 10%.
This will be achieved by means of a screw press. This water will then be treated to an
acceptable quality before being discharged to the sewer. Output will be approximately
4440 litres per day or 1620 cubic metres per year.
3.1.4 PYROLYSIS OF WASTE FOR GENERATION OF SYNGAS
The abattoir waste will go through a process called pyrolysis. Pyrolysis involves the thermal
conversion of carbonaceous material into solid, liquid and gaseous fuels in the absence of
oxygen at temperatures above 220 degrees Celsius. Biomass materials (including abattoir
waste) are typical pyrolysis feed materials, others include other waste streams including
plastics and rubbers each resulting in different products.
There are two types of pyrolysis technologies namely, fast pyrolysis and slow pyrolysis. Fast
pyrolysis takes place at moderate temperatures (450°C – 550°C) and requires feedstock
with a moisture content of less than 10% as well as smaller feedstock particle sizes. In slow
pyrolysis feedstock is converted into primarily char under low temperatures and over long
residence times. Unlike, fast pyrolysis, the feedstock does not require drying or size
reduction prior to pyrolysis.
The products of pyrolysis include syngas and a solid residue called char. Syngas is a
mixture of gases with high proportion of carbon monoxide, hydrogen and methane. This
also contains condensable oils, waxes and tars. Syngas has a high calorific value allowing
it to be used directly in an internal combustion engine for electric power generation as
described previously.
Thermal treatment of waste requires an Atmospheric Emission Licence. The required air
emission standards set in terms of the NEMAQA S21 Minimum Emission Standards published
in Notice No. 893 in Government Gazette 37054 of 22 November 2013 will have to be met
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3.2 PROPOSED ELECTRICITY GENERATION
The gas produced from pyrolysis is to be fed into an internal combustion engine where it is
combusted. This engine will in turn power a generator that is to generate 0.13MW
electricity which will be utilised by the plant itself. The proposed project will be bid in terms
of the Department of Energy Small Renewables Bid programme.
3.2.1 .GAS CLEAN-UP SYSTEM
Before the gas is combusted in the turbine it is required to be cleaned, to remove
substances such as sub-micron particulate matter, tars, ammonia and acid gases, as
these substances will have a detrimental effect on the operation of the turbine. The gas is
to be cleaned in a scrubber as well as tar and oil condensers. The removed substances
are then to be returned to the pyrolyser, while the removed ash is to be stored and
subsequently disposed of at a licensed disposal facility
3.3 THE USE OF ASH AS FERTILISER & SOIL ADDITIVE
The bio-char/ pyrolysis ash is high in fertiliser and carbon as well as other micronutrients
derived from blood, bone and other abattoir waste materials. The -char/ pyrolysis ash will
likely qualify as an “organic fertiliser” in terms of Fertilizers, Farm Feeds, Agricultural
Remedies and Stock Remedies Act No. 36 of 1947 ) FFARSRA ) and Regulation 75 of 8
February 2013 (Regulations relating to the production and registration of fertilizers).
The first issue of the scoping report for public review (Date: 14 March 2014) indicated the
intent to utilise char/ pyrolysis ash for use as a soil conditioner/ fertiliser and included
proposed methodology for comprehensive bio-char/ pyrolysis ash analyses and green
house plant potting trials to determine whether the material meets the requirements of a
fertiliser in terms of.
Note that due to a lack of adequate volumes of bio-char/ pyrolysis ash as well as
compositional differences in the bio-char/ pyrolysis ash produced by pilot plant and that
which is expected from the full plant, this component of the study has been removed. The
investigation into the suitability of the into the suitability of the ash in terms of FFARSRA
Regulations will now be undertaken once the plant is operational and producing
representative bio-char/ pyrolysis ash for evaluation.
In the case that the ash is not used a fertiliser it will be considered a waste and the
bio-char/ pyrolysis ash to be disposed of will need to be assessed before disposal as
is regulated in terms of:
o GN 635:2013 – National Norms and Standards for the Assessment of Waste for
Landfill Disposal; and
o GN 636:2013 – National Norms and Standards for Disposal of Waste to Landfill
If the bio-char/ pyrolysis ash is shown to meet the requirements of a fertiliser then in
terms of FFARSRA it will be considered a product and not a waste.
If the bio-char/ pyrolysis ash does not meet the requirements for a fertiliser in terms
of FFARSRA but is demonstrated to be beneficial in application to land, then DEA
will be approached with respect to licensing requirements.
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Figure 3-1: Overview of proposed operations
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4. ALTERNATIVES
The requirement for consideration of development alternatives were introduced into
South Africa’s ‘environmental’ legislation to encourage developers, ‘industry’ and
‘mining’ to consider different ways of doing things that would have different
environmental impacts, whilst still achieving the development goal. The ultimate goal
of consideration of alternatives is to both reduce negative environmental impacts and
to increase or introduce positive environmental impacts.
Typical factors assessed for evaluating alternatives include:
financial feasibility
environmental impact
socio-economic impact
land use planning
future expansion of the operations
logistical constraints – power, water, raw materials, labour, market, etc.
Alternatives can take the form of relatively small adjustments to an operation, in which
case they blur into mitigation, or totally different activities, depending on how widely
the development goal has been stated. Generally, whatever the scale of the
alternative, they are grouped into various types, including the following main groups
(after DEAT, 2004):
location or routing alternatives
activity or process alternatives
layout, design or scale alternatives
operational or scheduling alternatives
no-go alternative
The role of assessing alternatives in the EIA process is to reach the most desirable
outcome for all parties involved in and affected by the proposed project. Having
alternatives allows the comparison and selection of the best option, considering the
pro’s, con’s and costs of each of those alternatives. Ultimately, the alternative that
minimises negative impacts and maximises benefits should be the chosen one
(provided that the chosen alternative is economically feasible).
4.1 SITE ALTERNATIVES
For practical purposes, the proposed project must be undertaken within proposed
existing SRTS site. The abattoir already exists on the site and the space required for the
proposed facility is available on the site.
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4.2 PROCESS/TECHNOLOGY ALTERNATIVES
There are various process alternatives which may be considered for waste to energy.
4.2.1 NON-THERMAL WTE ALTERNATIVES
Non-Thermal WTE involves the conversion of waste into combustible gases such as
methane, methanol or synthetic fuel which can be used to generate electricity.
Technically feasible technologies for this type of application include:
Anaerobic digestion
Mechanical Biological Treatment (MBT)
Anaerobic Digestion
Anaerobic digestion is a biological decomposition of biodegradable waste in the
absence of oxygen. The products of this process include biogas which contains high
proportions of methane with much of the remainder being carbon dioxide and
digestate which contains fibre and liquor. The biogas can be used directly in engines
for combined heat and power (CHP) generation or treated to remove CO2 and then
be used as a fuel in gas turbines or be combusted to generate heat. The digestate
which may contain valuable nutrients such as nitrogen and potassium can be used as
a renewable fertilizer or a soil conditioner. Figure 4-1 shows a typical anaerobic digester
WTE plant.
Figure 4-1: Anaerobic Digestion WTE Plant
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4.2.2 THERMAL WTE ALTERNATIVES
Thermal WTE involves the conversion of waste into electricity or heat by combustion or
heating the waste without the presence of oxygen. Technically feasible technologies
for this type of application include:
Incineration
Plasma arc gasification
Thermal Depolymerisation (TDP)
Gasification
Pyrolysis
Incineration
Incineration involves the combustion of un-sorted waste using excess air at
temperatures exceeding 850oC. In this process waste is converted into primarily ash
and flue gas which contains a wide variety of gases depending on the waste.
Incineration is an attractive option for waste reduction mostly because it can reduce
the volume of waste by 80% to 95% thereby decreasing demand for landfill space. This
process also releases more of the available energy relative to pyrolysis and gasification.
This energy can be used to generate electricity through a steam turbine as depicted in
Figure 4-2. Various other thermal electricity cycles may also be used e.g. organic
rankine cycle, open or combined cycle gas turbines etc. The main disadvantages of
waste incineration are the high capital and operational costs. It is estimated that 35%
of the cost is attributed to mitigating emissions (Rand, Haukohl, and Mauxen, 2000).
Figure 4-2: Incineration
Plasma arc gasification
Plasma arc gasification involves the use of plasma torches to convert waste into syngas
which can be used as a fuel to generate electricity through a gas turbine. In this
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process waste is converted into syngas and slag at extremely high temperatures
(2800oC – 4400oC).
Plasma gasification accepts different feedstock such as biomass, tires, hazardous
waste, MSW etc.
Plasma gasification provides a number of key benefits:
Superior energy output - It unlocks the greatest amount of energy from waste
relative to the other technologies considered herein
Feed material flexibility - Feedstock can be mixed, such as municipal solid
waste, biomass, tires, hazardous waste, and auto shredder waste
Valuable slag - Metals resulting from plasma pyrolysis can be recovered from
the slag
It produces syngas, which can be combusted in a gas turbine or
reciprocating to produce electricity or further processed into chemicals,
fertilizers, or transportation fuels—thereby reducing the need for virgin
materials to produce these products
High reaction temperatures and efficiency reduce the potential for
formation of toxic gaseous by products (e.g. dioxins, furans etc.)
Figure 4-3: Plasma arc gasification WTE plant
Thermal Depolymerisation (TDP)
TDP is a thermal process which mimics the natural geological process thought to be
responsible for fossil fuel production. In this process waste is converted into crude oil
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products under high temperatures and pressures. Waste used in TDP include: wood,
leaves, grass, food, paper, plastic, paint, cotton, synthetic fabrics, sludge from sewage
and animal matter.
Figure 4-4 shows a typical TDP plant, the process begins with waste being crushed and
mixed with water to create slurry. The slurry is fed into a pressurized reactor operating at
a temperature in the order of 300°C depending on the composition of the waste. The
mixture is then released into a low pressure environment where the water immediately
boils off creating steam which is recycled back into the grinder to save energy. The
minerals and metals settle out and are collected to be sold. The carbon containing
material that remains is sent to a second reactor where long carbon chains are broken
into simple hydrocarbons at temperatures in the order of 500°C. These simple
hydrocarbons are separated using distillation columns into heavy oils, petrols and light
oils which can then be stored in their respective storage tanks (Cutting Edge, 2006).
Figure 4-4: Thermal Depolymerisation (TDP) plant (adapted from Cutting Edge, 2006)
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Gasification
Gasification involves the combustion of a substance using insufficient oxygen to promote
incomplete combustion. This occurs at temperatures above 650°C and the products
include syngas and ash which contains small amounts of carbon. The syngas typically
contains CO, H2 and to some extent CH4 and can thus be used as a fuel to generate
electricity in a gas turbine. Figure 4-5 shows a typical MWS WTE gasification plant.
Waste heat from the gas turbine can be recovered in a heat recovery steam generator
(HRSG) to produce high pressure steam which can be used to in a steam turbine to
generate additional electricity; this system is called the Integrated Gasification Combined
System (IGCC).
Figure 4-5: Gasification WTE Plant
Pyrolysis
Refer to Section 0 for a discussion on pyrolysis as well as a graphical representation of a
conventional WTE pyrolysis plant.
Pyrolysis involves the thermal conversion of carbonaceous material into solid, liquid and
gaseous fuels, in the absence of oxygen, at temperatures above 220 degrees Celsius.
Biomass, abattoir waste and municipal solid waste (MSW) are typical pyrolysis feed
materials, each resulting in different products. The products of pyrolysis include syngas and
a solid residue called char. Syngas is a mixture of gases with high proportion of carbon
monoxide, hydrogen and methane, it has a high calorific value allowing it to be used
directly in a gas turbine for electric power generation.
The advantages of pyrolysis
Pyrolysis can be performed at relatively small scale and at remote locations
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It is efficient and relatively low on cost
Reduce transport and handling costs of waste.
It also provides an opportunity for the processing of waste into clean energy
The disadvantages of pyrolysis were also considered and they include:
High start-up cost
Need for oil management
Emissions to the environment
Not mobile
4.3 LAYOUT, DESIGN OR SCALE ALTERNATIVES
Due to the layout of existing operations and the fact that it is only practical to have the
plant on the existing SRTS site it was the most viable option to place the pyrolysis plant as
graphically shown in Appendix 3: Layout plan for proposed structures and infrastructure,
and thus no alternatives were considered.
4.4 OPERATION AND SCHEDULING ALTERNATIVES
Seeing that the pyrolysis plant will result in energy supply to the abattoir it would not be
feasible to shut down the plant or adopt an operation schedule.
4.5 NO-GO ALTERNATIVE
The no-go option refers to the alternative of the proposed development not going ahead
at all. The baseline status quo is maintained in this case. This alternative will avoid
potentially positive and negative impacts on the environment. In this case, the no-go
option would mean that:
All waste continues to be disposed of to landfill
Excess costs continue to be incurred in the transport of waste to landfill
The abattoir continues to draw all its electricity requirements from the national grid.
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5. LEGAL AND POLICY FRAMEWORK
The Constitution of the Republic of South Africa (Act No. 108 of 1996) has significant
implications for environmental management. The main effects are the protection of
environmental and property rights, the drastic change brought about by the sections
dealing with administrative law such as access to information, just administrative action
and broadening of the locus standi of litigants.
These aspects provide general and overarching support and are of major assistance in
the effective implementation of the environmental management principles and structures
of the NEM:WA and NEMA. Section 24 in the Bill of Rights of the Constitution specifically
states:
"Everyone has the right - to an environment that is not harmful to their health or
well-being”;
“To have the environment protected, for the benefit of present and future
generations, through reasonable legislative and other measures that -
Prevent pollution and ecological degradation;
Promote conservation”; and
Secure ecologically sustainable development and use of natural
resources while promoting justifiable economic and social
development."
5.1 NATIONAL ENVIRONMENTAL MANAGEMENT ACT (NEMA)
The National Environmental Management Act (NEMA), 1998 (Act 107 of 1998, as
amended) is South Africa’s overarching environmental legislation, and contains a
comprehensive legal framework to give effect to the environmental rights contained in
section 24 of The Constitution. Section 2 of NEMA contains environmental principles that
form the legal foundation for sustainable environmental management in South Africa.
NEMA introduces the principle of integrated environmental management that is achieved
through the environmental assessment process in Section 24, which stipulates that certain
identified activities may not commence without an Environmental Authorisation from the
competent authority. Section 24(1) of NEMA requires applicants to consider, investigate,
assess and report the potential environmental impact of these activities. The requirements
for the investigation, assessment and communication of potential environmental impacts
are contained in the so-called 2010 amendment EIA Regulations (GN R.543, R.544, R.545
and R.546; June 2010 as amended by GN.R 1159 of December 2010).
The assessment required (Figure 1-4) is, therefore, comprehensive and detailed where
appropriate, and is a systematic process to identify potential positive and negative
impacts on the environment (biophysical, socio-economic, and cultural) associated with
proposed, as well as existing, activities, which aims to:
Examine alternatives / management measures to minimise negative and optimise
positive consequences;
Prevent substantial detrimental impact to the environment;
Improve the environmental design of the proposal;
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Ensure that resources are used efficiently; and
Identify appropriate management measures for mitigation and the monitoring
thereof.
Importantly, the licensing process for the subject waste management activities, and the
supporting information required is the same as for activities listed in GN R.544, GN R.545
and R.546 that require an Environmental Authorisation in terms of the NEMA. In order to
avoid duplication by requiring two approvals for the same activity, waste activities listed in
the EIA Regulations were removed by means of General Notice No: 719 on 3 July 2009,
which means that currently, waste activities only require a Licence in terms of NEM:WA,
and not an Environmental Authorisation in terms of NEMA too. The proposed activities are
thus only subject to an application for waste management licencing, as detailed in the
Waste Management and Licensing section that follows, and not subject to an application
for environmental authorisation as well.
The activities that would be associated with the proposed SRTS facility are listed below in
Table 5-1.
Table 5-1: EIA Activities
GN R.545 Scoping and EIA activities (June 2010)
Activity No. 5: The construction of facilities or infrastructure for any process or activity
which requires a permit or licence in terms of national or provincial legislation governing
the generation or release of emissions, pollution or effluent and which is not identified in
Notice No. 544 of 2010 or included in the list of waste management activities published in
terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No.
59 of 2008) in which case that Act will apply.
REASON: The proposed pyrolosis plant waste to energy plant will require an Air Emission
Licence in terms of the NEM: Air Quality Act (2004).
Activity No. 26: Commencing of an activity, which requires an atmospheric emission
licence in terms of section 21 of the National Environmental Management: Air Quality Act,
2004 (Act No. 39 of 2004), except where Activity 28 in Notice No. R. 544 of 2010 applies.
REASON: pyrolosis of waste is deemed to be an incineration activity and accordingly
require an Air Emission Licence in terms of the NEM: Air Quality Act (2004).
5.1.1 DUTY OF CARE
The National Environmental Management Act, Act 107 of 1998, (NEMA) places a duty to
care on all persons who may cause significant pollution or degradation of the
environment. Specifically, Section 28 of the Act states:
“28 (1) Every person who causes, has caused or may cause significant pollution or
degradation of the environment must take reasonable measures to prevent such pollution
or degradation from occurring, continuing or recurring, or, in so far as such harm to the
environment is authorised by law or cannot reasonably be avoided or stopped, to
minimise and rectify such pollution or degradation of the environment.
(2) Without limiting the generality of the duty in subsection (1), the persons on whom
subsection (1) imposes an obligation to take reasonable measures, include an owner of
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land or premises, a person in control of land or premises or a person who has a right to use
the land or premises on which or in which-
(a) any activity or process is or was performed or undertaken; or
(b) any other situation exists, which causes, has caused or is likely to cause
significant pollution or degradation of the environment.
(3) The measures required in terms of subsection (1) may include measures to-
(a) investigate, assess and evaluate the impact on the environment;
(b) inform and educate employees about the environmental risks of their work
and the manner in which their tasks must be performed in order to avoid
causing significant pollution or degradation of the environment;
(c) cease, modify or control any act, activity or process causing the pollution or
degradation;
(d) contain or prevent the movement of pollutants or the causant of
degradation;
(e) eliminate any source of the pollution or degradation; or
(f) remedy the effects of the pollution or degradation.”
Consequently, in the context of this assessment, SRTS must take “reasonable steps” to
prevent pollution or degradation of the environment which may result from the proposed
activities. These reasonable steps include the investigation and evaluation of the potential
impact and identification of means to prevent an unacceptable impact on the
environment, and to contain or minimise potential impacts where they cannot be
eliminated.
5.2 WASTE MANAGEMENT AND LICENSING
In the past, waste management activities were regulated under the Environment
Conservation Act (ECA), 1989 (Act 73 of 1989), specifically Section 20(1), which states that
“no person shall establish, provide or operate any disposal site without a permit issued by
the Minister of Water Affairs”. Based on strict interpretation applied by authorities, any
waste handling facility, including waste storage and treatment, also required permitting
(or at least exemption) in terms of Section 20(1). These requirements have however been
replaced by the National Environmental Management: Waste Act (Act 59 of 2008)
(NEMWA), which was enacted on 10 March 2009 and came into force on 01 July 2009.
NEMWA was published in 2008 to, amongst other objectives, to:
reform the law regulating waste management in order to protect health and the
environment by providing reasonable measures for the prevention of pollution and
ecological degradation and for securing ecologically sustainable development;
provide for national norms and standards for regulating the management of waste
by all spheres of government; and
provide for specific waste management measures.
5.2.1 DEFINITION OF WASTE
The NEMWA defines ‘Waste’ as “any substance, whether or not that substance can be
reduced, re-used, recycled and recovered -
(a) that is surplus, unwanted, rejected, discarded, abandoned or disposed of
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(b) which the generator has no further use of for the purposes of production
(c) that must be treated or disposed of
(d) that is identified as a waste by the Minister by notice in the Gazette, and includes
waste generated by the mining, medical or other sector, but- (i) a by-product is not
considered waste; and (ii) any portion of waste, once re-used, recycled and recovered,
ceases to be waste”.
Other key definitions in NEMWA are:
Hazardous Waste: Any waste that contains organic or inorganic elements or
compounds that may, owing to the inherent physical, chemical or toxicological
characteristics of that waste, have a detrimental impact on health and the
environment;
General Waste: Waste that does not pose an immediate hazard or threat to
health or to the environment, and includes (a) domestic waste; (b) building and
demolition waste; (c) business waste; and (d) inert waste; and
Inert Waste: Waste that (a) does not undergo any significant physical, chemical
or biological transformation after disposal; (b) does not burn, react physically or
chemically biodegrade or otherwise adversely affect any other matter or
environment with which it may come into contact; and (c) does not impact
negatively on the environment, because of its pollutant content and because
the toxicity of its leachate is insignificant.
5.2.2 WASTE MANAGEMENT LICENSING
According to Section 19(1) and 19(3) of the Act, the Minister may publish a list of waste
management activities that have, or are likely to have, a detrimental effect on the
environment, and must specify whether a waste management licence is required to
conduct these activities. Under these provisions, a list of ‘Category A’ and ‘Category B’
waste management activities, which require a Waste Management Licence in terms of
Section 20(b) of NEMWA, were published via Government Notice No: 718 on 3 July 2009 as
Schedule 1 to NEMWA. On 29 November 2013 the minister amended the list through the
publishing of Government Notice No. 921.
The activities now fall under Categories A, B and C. In terms of this notice, a person who
wishes to commence, undertake or conduct any of these listed activities must, as part of
the Waste Management Licence application, conduct either a Basic Assessment process
(for Category A activities), or a Scoping and EIA (for Category B) as stipulated in the EIA
Regulations (GN R.543 as amended by GN.R 1159 of December 2010). For Category C
activities a person wishing to undertake such activities must comply with relevant
standards specified by the minister and listed in GN No. 921.
The licencing process for waste management activities and the supporting information
required is therefore the same as for activities listed in GN R.544, GN R.545 and R.546 that
require an Environmental Authorisation. In order to avoid duplication by requiring two
approvals for the same activity, waste activities listed in the EIA Regulations were removed
by means of General Notice No: 719 on 3 July 2009, which means that currently, waste
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activities only require a Licence in terms of NEMWA, and not an Environmental
Authorisation in terms of NEMA in addition thereto.
In terms of Section 43(1)(a) of NEMWA, the Minister (i.e. national DEA) is the licensing
authority where the waste management activity involves the establishment, operation,
cessation or decommissioning of a facility at which hazardous waste has been, or is to be,
stored, treated or disposed of. The waste management activities that are listed in
Schedule 1 to NEMWA, which are likely to form part of the project and that may require a
licence (but subject to interpretation of the definition of waste, the classification and final
management, which would all be assessed during the EIA), are listed below. It is to be
noted that at the time of application the activities listed under GN R.718 were in place.
Table 5-2: NEMWA Listed Waste Management Activities at the time of Application, listed
under GN R.718
Applicable ‘Category A’ (Basic Assessment) Activities:
Category A -
Activity No. 3
(2)
The storage including the temporary storage of hazardous waste at a
facility that has the capacity to store in excess of 35m3 of hazardous
waste at any one time, excluding the storage of hazardous waste in
lagoons.
REASON: The site store waste in a cold room or freezer if pyrolysis plant is
not running, as well as to build up a stock pile for when the abattoir is not
running.
Category A -
Activity No. 3
(8)
The recovery of waste including the refining, utilisation, or co-processing
of the waste at a facility that has the capacity to process in excess of
three tons of general waste or less than 500kg of hazardous waste per
day, excluding recovery that takes place as an integral part of an
internal manufacturing process within the same premises.
REASON: The proposed facility would have the capacity to recover
energy from waste (general and hazardous).
Category A -
Activity No. 3
(18)
The construction of facilities for activities listed in Category A of this
schedule (not in isolation to associated activity).
REASON: The establishment of the facility will require the construction of
structures and infrastructure supporting of the proposed waste
management activities identified above.
Category A -
Activity No. 3
(19)
The expansion of facilities of or changes to existing facilities for any
process or activity, which requires an amendment of an existing permit or
license or a new permit or license in terms of legislation governing the
release of pollution, effluent or waste.
REASON: The establishment of the facility will require a new waste
management license.
Applicable ‘Category B’ (Scoping and EIA) Activities
Category B -
Activity No. 4
(3)
The recovery of hazardous waste including the refining, utilisation or co-
processing of waste at a facility with a capacity to process more than
500kg of hazardous waste per day excluding recovery that takes place
as an integral part of an internal manufacturing process within the same
premises or unless the Minister has approved re-use guidelines for the
specific waste stream.
REASON: The proposed facility would have the capacity to recover
energy from waste (general and hazardous).
Category B - The biological, physical or physico-chemical treatment of hazardous
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Activity No. 4
(4)
waste at a facility that has the capacity to receive in excess of 500 kg of
hazardous waste per day.
REASON: The pyrolysis of waste is considered physico-chemical
treatment.
Category B -
Activity No. 4
(5)
The treatment of hazardous waste using any form of treatment regardless
of the size or capacity of such a facility to treat such waste.
REASON: The pyrolysis of waste is considered physic-chemical treatment.
Category B -
Activity No. 4
(8)
Incineration of waste regardless of the capacity of such a facility
REASON: The waste will undergo pyrolysis which is considered
incineration.
Category B -
Activity No. 4
(11)
The construction of facilities for activities listed in Category B of this
schedule (not in isolation to associated activity).
REASON: The establishment of the facility will require the construction of
structures and infrastructure supporting of the proposed waste
management activities identified above.
Table 5-3 below lists the corresponding activities now listed under GN.R 921.
Table 5-3: NEMWA Listed Waste Management Activities listed under GN R.921
Applicable ‘Category A’ (Basic Assessment) Activities:
Category A -
Activity No. 3
(12)
The construction of a facility for a waste management activity listed in
Category A of this schedule (not in isolation to associated waste
management activity).
REASON: The establishment of the facility will require the construction of
structures and infrastructure supporting of the proposed waste
management activities identified above.
Applicable ‘Category B’ (Scoping and EIA) Activities
Category B -
Activity (3)
The recovery of waste including the refining, utilisation, or co-processing
of the waste at a facility that processes in excess of 100 tons of general
waste per day or in excess of 1 ton of hazardous waste per day,
excluding recovery that takes place as an integral part of an internal
manufacturing process within the same premises.
REASON: the proposed facility would have the capacity to recover 10
tons of hazardous waste per day in order to generate electricity.
Category B -
Activity (4)
The treatment of hazardous waste in excess of 1 ton per day calculated
as a monthly average; using any form of treatment excluding the
treatment of effluent, wastewater or sewage.
REASON: The pyrolysis of waste is considered treatment.
Category B -
Activity (10)
The construction of facilities for a waste management activity listed in
Category B of this schedule (not in isolation to associated activity).
REASON: The establishment of the facility will require the construction of
structures and infrastructure supporting of the proposed waste
management activities identified above.
With the activities being listed in both Category A and B of the aforementioned
Government Notice (GN.R 921, 29 November 2013), the process of applying for
Environmental Authorisation includes a requirement to conduct an initial Scoping phase,
followed by a detailed Environmental Impact Assessment as part of the application, in
terms of Government Notice R.543 (the so called NEMA EIA Regulations as amended by
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GN.R 1159 of December 2010) promulgated in terms of Section 24(5) of the National
Environmental Management Act (NEMA), 1998 (Act 107 of 1998, as amended). The
assessment process required (Figure 4-1) is, therefore, comprehensive and detailed where
appropriate, and is a systematic process to identify potential positive and negative
impacts on the environment (biophysical, socio-economic, cultural) associated with
proposed activity, which aims to:
Examine alternatives/management measures to minimise the negative and
optimise the positive consequences of the proposed operation;
Prevent substantial detrimental impact to the environment
Improve the environmental design of the proposal
Ensure that resources are used efficiently
Identify appropriate management measures for mitigation and the monitoring
Figure 5-1: Scoping and EIA Process for Waste Licensing
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5.3 WASTE CLASSIFICATION
The recently promulgated “National norms and standards for the assessment of waste for
landfill disposal” was published on the 23rd August 2013 in the government gazette
(GN635:2013). These require that all wastes that are to be disposed of in landfills be
assessed in terms of its composition and its leaching properties. These values are then
compared to threshold values to determine the classification of the waste.
If any of the concentrations (total or leach) of the compounds are higher than a given
threshold, the waste is given a specific rating; the lowest waste type in the waste will be
used. Type 4 wastes are the least hazardous while Type 0 is the most hazardous.
Table 5-4: Waste type classification of waste according to concentration
thresholds from the national norms and standards (23 August 2013)
Leachable
Concentration Total Concentration Waste Type
LC ≤ LCT0 TC ≤ TCT0 Type 4#
LCT0 < LC ≤ LCT1 TC ≤ TCT1 Type 3
LCT1 < LC ≤ LCT2 TC ≤ TCT1 Type 2
LCT2 < LC ≤ LCT3 TCT1 < TC ≤ TCT2 Type 1
LCT3 < LC TCT2 < TC Type 0 # Waste Type 4 has additional concentration limits that should not be exceeded
The waste types relate to specific landfill requirements as stated in the “National Norms
and Standards for Disposal of Waste to Landfill” (23 August 2013) (Table 5-5).
Table 5-5: Landfill requirements based on waste type from the national norms and
standards (23 August 2013)
Waste
type Landfill requirements
Type 0 The disposal of Type 0 waste to landfill is not allowed. The waste must be treated and re-assessed in terms of the Norms and Standards for Assessment of Waste for Landfill Disposal.
Type 1
Type 1 waste may only be disposed of at a Class A landfill designed in accordance with section 3(1) and (2) of these Norms and Standards, or, subject to section 3(4) of these Norms and Standards, may be disposed of at a landfill site designed in accordance with the requirements for a Hh/HH landfill as specified in the Minimum Requirements for Waste Disposal by Landfill (2nd Ed., Department of Water Affairs and Forestry, 1998).
Type 2
Type 2 waste may only be disposed of at a Class B landfill designed in accordance with section 3(1) and (2) of these Norms and Standards, or, subject to section 3(4) of these Norms and Standards, may be disposed of at a landfill site designed in accordance with the requirements for a GLB+ landfill as specified in the Minimum Requirements for Waste Disposal by Landfill (2nd Ed., DWAF, 1998).
Type 3
Type 3 waste may only be disposed of at a Class C landfill designed in accordance with section 3(1) and (2) of these Norms and Standards, or, subject to section 3(4) of these Norms and Standards, may be disposed of at a landfill site designed in accordance with the requirements for a GLB+ landfill as specified in the Minimum Requirements for Waste Disposal by Landfill (2nd Ed., DWAF, 1998).
Type 4 Type 4 waste may only be disposed of at a Class D landfill designed in accordance with section 3(1) and (2) of these Norms and Standards, or, subject to section 3(4) of these Norms
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Table 5-5: Landfill requirements based on waste type from the national norms and
standards (23 August 2013)
Waste
type Landfill requirements and Standards, may be disposed of at a landfill site designed in accordance with the requirements for a GLB landfill as specified in the Minimum Requirements for Waste Disposal by Landfill (2nd Ed., DWAF, 1998).
Waste obtained from the pyrolysis will consist primarily of bone ash, as almost all of the
other tissue would likely have been converted to syngas. This waste assessment focused
on reviewing the bone ash produced and discussed its use as a fertilizer and it’s
classification in terms of the SANS 10234 as required by the National Environmental
Management: Waste Act (NEMWA, 2008) Waste Classification and Management
Regulations (GN.R 634, 2013). A Literature review conducted on bone ash confirms it to be
non-hazardous. Refer to Appendix 8: Waste Assessment for the results.
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5.4 AIR QUALITY AND LICENSING
The National Environmental Management: Air Quality Act (NEMAQA), 2004 (Act 39 of
2004) regulates air quality in general, as well as, activities that may have an impact on
ambient air quality. All sections of the NEMAQA have been enacted and have replaced
the Atmospheric Pollution Prevention Act of 1965 (APPA).
According to S21 of NEMAQA, the Minister must publish, by notice in the Government
Gazette, a list of activities, which result in atmospheric emissions and which the Minister
reasonably believes have or may have a significant detrimental effect on the
environment.
Furthermore, such a notice must establish minimum emission standards for substances
resulting from a listed activity, including the permissible amount or concentration of
substances being emitted, as well as, the manner in which measurements of such
emissions must be carried out. The notice may also contain transitional and other special
arrangements in respect of activities which are carried out at the time of their listing.
The DEA has given effect to Section 21 through the Listed Activities and Minimum Emission
Standards (March 2010), which include air emission standards for new plants such as
boilers and waste to energy plants, and would accordingly require an Air Emission Licence
(Figure 4-3). In Accordance with the Air Quality Act (NEMAQA), 2004 (Act 39 of 2004) a list
of activities which result in atmospheric emissions which have or may have a significant
detrimental effect on the environment, including health, social conditions, economic
conditions, ecological conditions or cultural heritage has been published. The list was
published on the 31st of March 2010 (Government Gazette No. 33064) and has since been
amended in Government Gazette No. 37054 published on 22 November 2013. The
minimum emissions applicable to the proposed waste management facility are given in
Table 5-6 below
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Table 5-6: Category 8: Thermal Treatment of Hazardous and General Waste
Subcategory 8.1: Thermal Treatment of General and Hazardous Waste
Description: Facilities where general and hazardous waste are treated by the application of heat.
Application: All installations treating 10 Kg or more per day of waste.
Substance or mixture of substances Plant status
mg /Nm3 under normal
conditions of 273 Kelvin
and 101.3 kPa.
Common name Chemical symbol
Particulate matter N/A New 10
Existing 25
Carbon monoxide CO New 50
Existing 75
Sulphur dioxide S02 New 50
Existing 50
Oxides of nitrogen NOx expressed as NO2 New 200
Existing 200
Hydrogen chloride HCI New 10
Existing 10
Hydrogen fluoride HF New 1
Existing 1
Sum of Lead, arsenic, antimony, chromium, cobalt, copper, manganese, nickel, vanadium
Pb As+ Sb+ Cr + Co+ Cu + Mn+ Ni V
New 0.5
Existing 0.5
Mercury Hg New 0.05
Existing 0.05
Cadmium Thallium Cd + TI New 0.05
Existing 0.05
Total organic compounds TOC New 10
Existing 10
Ammonia NH3 New 10
Existing 10
ng I-TEQ/Nm3 under normal conditions of 10% 02 , 273
Kelvin and 101 3 kPa.
Dioxins and furans PCDD/PCDF New 0.1
Existing 0.1
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The following special arrangements shall apply:
1. For pyrolysis, reference oxygen content does not apply.
2. The facility shall be designed, equipped, built and operated in such a way so as to
prevent the emissions into the air giving rise to significant ground-level air pollution
(i.e. leading to the exceedance of an accepted ambient air quality threshold
standard).
3. Monitoring equipment shall be installed and acceptable techniques used in order
to accurately monitor the parameters, conditions and mass concentrations
relevant to the co-processing of AFR and incineration of waste.
4. All continuous, on-line emission monitoring results must be reported as a Daily
Average concentration expressed as mg/Nm3, and at 'normalised' conditions of
10% 02, 101.3 kPa, 273 K / 0 °C, dry gas.
5. Discontinuous (periodic) emission monitoring results must be expressed as mg/Nm3,
or ng/Nm3 I-TEQ for PCDD/PCDF, and at 'normalised' conditions of 10% 02, 101.3
kPa, 273 K / 0 °C, dry gas.
6. Exit gas temperatures must be maintained below 200 °C.
7. Pollution control devices (exhaust gas cooling and bag filter or ESP) must have a
daily availability of 98% (i.e. maximum downtime of 2% or 30 minutes per running 24
hours). The cumulative annual downtime (total downtime over a one year period)
may however not exceed 60 hours (0.685 % per annum).
8. Continuous, on-line measurement of the following emissions and operating
parameters is required:
Particulate matter (total particulate);
O2;
CO;
NOx;
SO2;
HCI;
HF;
VOC/TOC;
Emission exhaust volume (e.g. Nm3/hr) and flow rate (e.g. m/s);
Water vapour content of exhaust gas (humidity);
Exhaust gas temperature;
Internal process temperature/s;
Pressure; and
Availability of air pollution control equipment (including exit gas cooling).
9. Appropriate installation and functioning of automated, continuous monitoring
equipment for emissions to air, which are subject to quality control and to an
annual surveillance test. Independent accredited calibration must be undertaken
by means of parallel measurements with the reference methods, at a frequency as
per the requirements of the equipment, but as a minimum every 3 years.
10. Periodic measurements of heavy metals and dioxin and furan emissions must be
undertaken, using national (if available) or internationally acceptable methods, by
independent/external, accredited specialists twice during the first 12 months of
waste incineration / AFR co-processing, and annually thereafter.
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11. Average emission values for heavy metals are to be measured over a minimum
sample period of 60 minutes to obtain a representative sample, and a maximum of
8 hours, and the average values for dioxins and furans (expressed as I-TEQ) over a
sample period of a minimum of 60 minutes and maximum of 8 hours.
12. Periodic measurements of heavy metals and dioxins and furans are to be carried
out representatively to provide accurate and scientifically correct emission data
and results, and sampling and analysis must be carried out by independent,
accredited laboratories.
13. To ensure valid monitoring results are obtained, no more than five half-hourly
average values in any day, and no more than ten daily average values per year,
may be discarded due to malfunction or maintenance of the continuous
measurement system.
14. All measurement results must be recorded, processed and presented in an
appropriate manner in a Quarterly Emissions Monitoring Report in order to enable
verification of compliance with permitted operating conditions and air emission
standards. Quarterly Emission Monitoring Reports must include, amongst others:
Daily average results of all continuous, on-line emission monitoring
parameters, reported on line graphs that include individual, daily
average data points, and indicating the relevant air emission limit if
applicable;
Results of all continuous, on-line operational monitoring parameters,
reported on line graphs that correspond in scale with the emission
monitoring results;
Results of periodic emission measurements of heavy metals, and dioxins
and furans;
Confirmation of residence times and temperatures of specific wastes
coprocessed as determined by the specific feed points, plant dimensions
and material and gas flow rates;
Discussion on availability or air pollution control equipment, together with
reasons for and management of downtime;
All relevant results must be compared with baseline measurements taken
prior to the co-processing of AFR or hazardous waste; and
Detailed evaluation and discussion of any non-compliance during the
reporting period.
15. Treatment of High Level POPs Containing Waste (as defined by the Stockholm and
Basel Conventions) are to be preceded by an independently monitored
Performance Verification Test to determine the Destruction Efficiency (DE) and
Destruction and Removal Efficiency (DRE) of principal organic hazardous
compounds (POHC) using a suitable verification compound (e.g. trichloroethane).
16. A plan for conducting a Performance Verification Test must be submitted to the
relevant Government Department/s at least 3 months prior to the commencement
of such a test, and must include, amongst others, the following:
Motivation for why the plant should be used for treatment of High Level
POPs;
A feasibility study showing that the plant is technically qualified;
Planned date for commencement of the test and expected duration;
Details on the waste to be co-processed during the test, including
source, volume, composition etc.;
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Motivation for the particular choice of waste and its suitability in
providing an accurate and representative indication of the plant's DE
and DRE, and therefore suitability to treat High Level POPs Containing
Waste;
Extension of monitoring regime to include Chlorobenzenes, HCB, PCBs,
Benzene, Toluene, Xylenes, PAHs, and NH3;
Monitoring and analysis to be conducted, the associated methodologies
and independent parties responsible for monitoring.
17. A detailed, independent report documenting and interpreting the results of the
Performance Verification Test must be compiled. As a minimum, a DE/DRE of
99.9999% would be required, as well as compliance with Air Emission Standards.
18. An Air Quality Improvement Plan for achieving emission limits over time must be
developed if transitional arrangements apply to compliance with emission
standards.
19. Compliance time frames for health care risk waste incineration will be as specified
in paragraphs (8); (9); and (10) unless specific compliance time frames for health
care risk waste incineration have been set under health care risk waste regulations,
in which case, the specific compliance time frames for health care risk waste
incineration set under health care risk waste regulations shall apply.
20. Continuous emission monitoring for Health Care Risk Incinerators shall be complied
with by 31 March 2014.
21. Combustion of solid, liquid and gaseous waste materials in installations primarily
used for steam for steam raising or electricity generation must comply with the
emission standards of this sub- category.
NEMAQA also makes provisions for the establishment of national standards for ambient
concentrations of specified substances or mixtures of substances in ambient air, which
through ambient concentrations, bioaccumulation, deposition or in any other way,
present a threat to health, well-being or the environment or which are reasonably
believed to present a threat.
The Minister of Water and Environmental Affairs has accordingly published national
ambient air quality standards referring to various pollutants. In addition, criteria and limits
for dust deposition and regulations on the management of dust pollution have also been
set.
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Figure 5-2: Interrelationship between the EIA and AEL Processes
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5.5 OTHER RELEVANT LEGISLATION TO BE CONSIDERED
The following list of legislation was considered during the Scoping and EIA process for the
proposed SRTS development:
5.5.1 NATIONAL WATER ACT
The National Water Act (NWA), 1998 (Act 36 of 1998), aims to manage national water
resources in order to achieve sustainable use of water for the benefit of all water users.
This requires that the quality of water resources is protected, and integrated management
of water resources takes place. In terms of the National Water Act, a water use licence
application (WULA) is required for:
(a) taking water from a water resource;
(b) storing water;
(c) impeding or diverting the flow of water in a watercourse;
(d) engaging in a stream flow reduction activity contemplated in section 36;
(e) engaging in a controlled activity identified as such in section 37 (1) or declared
under section 38 (1) ;
(f) discharging waste or water containing waste into a water resource through a pipe,
canal, sewer, sea outfall or other conduit;
(g) disposing of waste in a manner which may detrimentally impact on a water
resource;
(h) disposing in any manner of water which contains waste from, or which has been
heated in, any industrial or power generation process;
(i) altering the bed, banks, course or characteristics of a watercourse;
(j) removing, discharging or disposing of water found underground if it is necessary for
the efficient continuation of an activity or for the safety of people; and
(k) using water for recreational purposes.
5.5.2 OCCUPATIONAL HEALTH AND SAFETY
The Occupational Health and Safety Act (OHSA) 1993 (Act 85 of 1993) regulations include
Regulation 1179 (Hazardous Chemical Substances) and Regulation 7122 (Major Hazard
Installations).
A “hazardous chemical substance” is defined in Government Notice R.1179 Hazardous
Chemical Substances Regulations (1995) as any toxic, harmful, corrosive, irritant or
asphyxiant substance, or a mixture of such substances for which (a) an occupational
exposure limit is prescribed, or (b) an occupational exposure limit is not prescribed; but
which creates a hazard to health.
A ‘major hazard installation’ means an installation:
(a) where more than the prescribed quantity of any substance is or may be kept,
whether permanently or temporarily; or
(b) where any substance is produced, used, handled or stored in such a form and
quantity that it has the potential to cause a major incident.”
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The proposed project, nor any of the existing structures subject to this application, will
require the storage of substances in more than prescribed quantities required in terms of
the relevant OHSA Regulations. No element of the proposed project is thus deemed to fall
within the definition of a MHI.
5.5.3 THE NOISE CONTROL REGULATIONS
The Noise Control Regulations (R 154 GG 13717 of 10 January 1992), promulgated in terms
of ECA, defines:
nuisance noise as, “any sound which disturbs or impairs or may disturb or impair
the convenience or peace of any person”;
disturbing noise as, “any noise level which exceeds the zone sound level or, if no
zone sound level has been designated, a noise level which exceeds the
ambient sound level at the same measuring point by 7 dBA or more”.
Regulation 4 states, “No person shall make, produce or cause a disturbing noise, or allow it
to be made, produced or caused by any person, machine, device or apparatus or any
combination thereof”. The operation of the propose plant is not anticipated to generate
noise on the existing industrial site that could be regarded as nuisance or disturbing noise
(as defined in the Noise Regulations).
5.5.4 NATIONAL HERITAGE RESOURCES ACT
The National Heritage Resources Act, 1999 (Act 25 of 1999) legislates the necessity for
cultural and heritage impact assessment in areas earmarked for development, which
exceed 0.5 hectares (ha) and where linear developments (including pipelines) exceed
300 metres in length. The Act makes provision for the potential destruction to existing sites,
pending the archaeologist’s recommendations through permitting procedures. Permits
are administered by the South African Heritage Resources Agency (SAHRA).
Given that the site at which the proposed activity is proposed is a “brown-fields” site (that
is to say that the site already subject to disturbance through previous ‘industrial’ activities),
the above Act is not deemed to be of any relevance to this particular project.
5.5.5 ACCESS TO INFORMATION
The Promotion of Access to Information Act (Act 2 of 2000) [PAIA] recognises that
everyone has a Constitutional right of access to any information held by the state and by
another person when that information is required to exercise or protect any rights. The
purpose of the Act is to foster a culture of transparency and accountability in public and
private bodies and to promote a society in which people have access to information that
enables them to exercise and protect their rights.
The EIA process undertaken, and particularly the Public Participation component thereof,
are aligned with the PAIA in the sense that all registered stakeholders in the EIA process
will be provided a fair opportunity to review and comment on any reports (Scoping
Report, Plan of Study for EIA, EIA Report and Environmental Management Plan) submitted
to the Competent Authority for decision making.
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The public participation component of this report is outlined in Section 6.
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6. PUBLIC PARTICIPATION
Public participation provides the opportunity for IAPs (interested or affected parties) to
participate on an informed basis, and to ensure that their needs and concerns are
considered during the impact assessment process. In so doing, a sense of ownership of
the project is vested in both the project proponent and interested or affected parties. The
Public Participation Process is aimed at achieving the following:
Provide opportunities for IAPs and the authorities to obtain clear, accurate and
understandable information about the expected environmental and socio-
economic impacts of the proposed development.
Establish a formal platform for the public with the opportunity to voice their
concerns and to raise questions regarding the project.
Utilise the opportunity to formulate ways for reducing or mitigating any negative
impacts of the project, and for enhancing its benefits.
Enable project proponent to consider the needs, preferences and values of
IAPs in their decisions.
Clear up any misunderstandings about technical issues, resolving disputes and
reconciling conflicting interests.
Provide a proactive indication of issues which may inhibit project progress
resulting in delays, or which may result in enhanced and shared benefits.
Ensure transparency and accountability in decision-making.
The public participation process to the end of the Scoping phase is outlined below. Refer
to Appendix 4: Public Participation Documentation for further detail, which includes:
Newspaper advertisements and site notices.
I&AP’s list
Proof of notification of I&AP’s
Proof of distribution of scoping report to I&AP’s and DEA
Proof of communication with Fezile Dabi District Municipality
6.1 PUBLIC PARTICIPATION PROCESS FOR SCOPING PHASE
6.1.1 PARTICIPATION PROCESS
The public and stakeholder participation process to date have entailed the following:
Pre-identification of interested and affected parties (IAPs).
Advertising the proposed project and associated EIA process in “Kroonnuus” on
the 3rd December 2013. The advertisements indicated where written comments
may be directed to and who to contact in order to be registered on the IAP list.
A2-size site notices were erected at the site’s entrance gate.
A draft Scoping report was made available for public comment between 25th
April 2014 and 10th May 2014.
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6.1.2 COMMENTS AND ISSUES
No comments were received from I&APs in the scoping phase.
6.2 PUBLIC PARTICIPATION PROCESS FOR EIA PHASE
6.2.1 PARTICIPATION PROCESS
The proposed public participation process for the Environmental Impact Assessment will
consist of:
Presenting registered Interested and Affected Parties and stakeholders with the
opportunity to read and comment on environmental impact assessment report
including specialist reports;
Presenting registered Interested and Affected Parties and stakeholders with the
opportunity to read and comment on draft environmental management plans
compiled in terms of regulation;
Presenting registered Interested and Affected Parties and stakeholders with the
opportunity to read and comment on the final reports submitted to the National
Department of Environment Affairs: Waste Permitting.
6.2.2 KEY DATES
Table 6-1: Key Dates in EIA Phase
Draft EIA and EMP report issued to IAP’s for comment 09 July 2014
Comment period closed, EIA updated to Final and submitted
to DEA 19 August 2014
Authority decision-making August, September,
October 2014
Appeal period (Chapter 7 – 2010 NEMA EIA Regulations) November/December
2014
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7. DESCRIPTION OF THE RECEIVING ENVIRONMENT
7.1 LOCATION, LAND-USE AND ZONING
The proposed pyrolysis and power generation facility is located at 22 11th Avenue,
Kroonstad, 9499. The site falls within the jurisdiction of the Moqhaka Local Municipality and
the Fezile Dabi District Municipality The site is currently zoned ‘Industrial’.
The closest residential area is approximately 300m away to the north east of the site.
Table 7-1 Aerial over view of Square Root Trading Seven (Pty) Ltd (Google)
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7.2 CLIMATE
7.2.1 TEMPERATURE
The average midday temperatures for Kroonstad range from 17°C in June to 28.7°C in
January. The region is the coldest during June when the temperature drops to 0°C on
average during the night
7.2.2 RAINFALL
The site is located in a summer rainfall region and therefore receives most of its rainfall
from December to January. While gentle soaking rains do occur, the rainfall in the area is
often characterised by intense thunderstorms, which occur mainly in the late afternoon.
The annual average rainfall is 560 mm (Mucina and Rutherford, 2006).
Table 7-2 Average monthly rainfall (mm) for Kroonstad
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7.2.3 WIND
Figure 7-1: Annual Wind Rose Kroonstad SAWS station from 2005-2008.
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7.3 TOPOGRAPHY
Kroonstad occurs at an altitude of 1300-1640m (Mucina and Rutherford, 2006). Refer to
Figure 7-2 for topographical map of the area in which Square Root Trading Seven (Pty) Ltd
operates.
Figure 7-2: Topographical map
7.4 GEOLOGY AND SOILS
Kroonstad Sedimentary mudstones and sandstone mainly of the Adelaide Subgroup
(Beauford Group, Karoo Supergroup) as well as those of the Ecca Group (Karoo
Supergroup) underlie the area. This gives rise to vertic, melanic and red soils. Less common
intrusive dolerites of the Jurassic Karoo Dolerite Suite support dry clayey soils is also typical
of the landscape type (Mucina and Rutherford, 2006).
7.5 FAUNA AND FLORA
Koonstad occurs within the Central Free State Grasslands. This biome is characterised by
undulating plains supporting short grassland, in natural conditions Themeda triandra
dominates while Eragrostis curvula and E. chloromelas become dominant in degraded
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areas. Dwarf karoo bushes establish in severely degraded clayey bottomlands.
Overgrazed and trampled low-lying areas with heavy clayey soils are prone to Acacia
karroo encroachment (Mucina and Rutherford, 2006).
7.6 SURFACE WATER
The SRTS site is located within the Middle Vaal water management area which is situated
in the central part of South Africa, in the Free State and North West Provinces. The Middle
Vaal water management area is situated between the Upper Vaal and Lower Vaal water
management areas and also borders on the Crocodile (West) and Marico as well as the
Upper Orange water management areas. The Vaal River is the only main river in the water
management area. It flows in a westerly direction from the Upper Vaal water
management area, to be joined by the Skoonspruit, Rhenoster, Vals and Vet Rivers as
main tributaries from the Middle Vaal water management area, before flowing into the
Lower Vaal water management area and then into the Orange River.
Kroonstad falls within the Rhenoster-Vals Sub-area which was again sub divided into the
Vals sub-catchment.C60D.Serfontein Dam (capacity of 25 million m3) supports town.
Historic yield analysis indicated significant shortages in supply which can be confirmed by
the water use restrictions on Kroonstad.
7.6.1 SURFACE WATER QUALITY
Naturally the quality of surface water in the water management area is good, but can be
of high turbidity. Wash-off and return flows from urban areas in the proximity of the Vaal
River and main tributes, such as at Klerksdorp, also impact on the areas water quality.
Water which enters the Middle Vaal water management area along the Vaal River
contains a large proportion of urban and industrial return flows from the Johannesburg
area with part of the water having been through more than one cycle of use. As a
consequence, salinity levels can be very high and need to be managed through
blending with fresh water in the Upper Vaal water management area, so as not to
exceed certain target concentrations. High nutrient concentrations also occur as a result
of the large domestic component of return flows which, together with the low turbidity of
the return flows, stimulates excessive algal growth. See Figure 7-3 for the graphical
representation of the Middle Vaal water management area.
The water quality in Rhenoster Vals Sub-area (specifically) is good with some localised
problems associated with the management and maintenance of the sanitation system in
Kroonstad, having a local impact on the water quality of the Vals River.
Correct water and waste management needs to occur on side to prevent any negative
impact of the abattoir and proposed waste-to-electricity plant on the areas water
sources.
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Figure 7-3 Middle Vaal Water Management Area
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7.7 GROUNDWATER
Although water restrictions have been effected in Kroonstad, there appears to be
adequate groundwater resources in this area (2–5 l/s per borehole according to
National Groundwater maps). Limited groundwater monitoring is being undertaken in the
area to assess groundwater quality trends. It was identified that in order to utilise these
groundwater resources, further monitoring and assessments need to be undertaken. The
intention is to focus these activities near the towns where groundwater can be utilised.
Correct water and waste management needs to occur on side to prevent any negative
impact of the abattoir and proposed waste-to-electricity plant on the areas water
sources.
7.7.1 AQUIFER CHARACTERISATION
Nearly the entire area covered by the Kroonstad Hydrogeological Map is situated in the
north-eastern part of the Central Karoo Basin. The thickness of the Karoo sediments
increases gradually from the pre-Karoo bedrock outcropping at the Vredefort and in the
northwest map corner towards south and close to the Lesotho border reaches over 2000
m. The age of the sediments decreases in the southerly direction.
Although groundwater is not the main source of water supply to many larger users in that
area, it can always be considered as an optional supplement to surface water in a
drought situation. Occurrences of the four recognised different types of aquifer in the
area covered by the sheet Kroonstad are to be discussed in this section.
Intergranular aquifers
This aquifer is weakly represented in the map area. The unconsolidated, water saturated
alluvium occurs sporadically along the Vaal, Wilge, Klip, Sand, Vet, Modder and Vals
Rivers. The thickness of the alluvial sediments that consist mainly of clay, sand and gravel
at the bottom is limited to a few metres. Two larger alluvial areas along the lower Vet and
Klip rivers are indicated on the map as Q. The alluvial aquifers there are thin and not
directly tapped by boreholes that usually bypass them. The two areas are therefore
characterised as “intergranular and fractured” type of aquifer that ignores the alluvium
reflecting only the water bearing character of the bedrock.
Fractured aquifers
The tectonic forces and to a lesser degree the weathering processes have produced a
network of fractures in the highly competent mainly quartzitic rock formations of Randian
age. Little, or no decomposition of the rock mass took place due to their predominantly
arenaceous and rudaceous nature. The storage volume of groundwater stored in this type
of aquifer is therefore limited, much lower than in other aquifer types. The groundwater
pumped from the Free State Goldfields mines is considered to be stored in the network of
interconnected fissures and fractures in the rocks of both the Witwatersrand and
Ventersdorp Supergroups. It is isolated form the shallow, subsurface Karoo rock aquifer by
the impermeable shales of the Ecca Group.
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Karstic aquifers
Karstic aquifers are formed by dissolution of a carbonate rock by circulating groundwater
containing carbonic acid. The process is taking place along the faults, fractures and joint
planes resulting in their enlargement. Channels, caves and other cavities are formed
which are often partially filled by permeable residual products of chert rubble, iron and
manganese oxides and hydroxides. Karstic aquifers are often characterized by high
storage and high yielding of boreholes, should the dissolved rock sections be penetrated.
Intergranular and Fractured aquifers
This aquifer system occurs practically in the entire map area. The action of tectonic forces
together with the subsequent processes of weathering, created two hydraulically
interconnected different zones that occur in a vertical profile namely:
A shallower, weathered zone, where the original rock structure has been changed
to a mass of more or less loose rock fragments, in a matrix of fine products of
weathering, mostly sand, silt and clay.
A fractured zone, down to a depth where the rock is becoming solid and fresh in
appearance. The transition to this deeper zone is usually gradual. The lateral
movement of groundwater in the top zone is very slow and boreholes tapping it
are weak.
Exploitable aquifers are found in four major Geological Supergroups: The Karoo
Supergroup, Transvaal Supergroup, Ventersdorp Supergroup and the Witwatersrand
Supergroup. There are also limited aquifers found in alluvial deposits along streams and
rivers. Karoo sediments of the Ecca and Beaufort Groups, which consist of mainly
sandstones, mudstones and shales, cover a large portion of the WMA. The aquifers are
secondary aquifers with water associated with fracturing of the porous medium.
Groundwater is often associated with dolerite intrusions and the yields are very variable
between 0.1 – 10l/s depending on the type and fracturing of the sediments
7.8 GROUNDWATER QUALITY
In Renoster/Vals catchment the only definite problem that was identified was the
localized groundwater pollution from food manufacturing factories however, the issues
relating to urban and agricultural activities may also apply here. Limited groundwater
monitoring is being done in the area to assess groundwater quality trends and the largest
gap on data for groundwater use and resources is in the Renoster/Vals sub-catchments.
There is little mining or industrial development in these catchments and the only data
available is from the WARMS database. No studies targeted at groundwater have been
initiated in this area. Correct water and waste management needs to occur on side to
prevent any negative impact of the abattoir and proposed waste-to-electricity plant on
the areas water sources
7.9 AMBIENT AIR QUALITY
The plant lies well away from the Highveld Priority Area and Vaal Triangle Priority Area
(VTPA). The Highveld area in South Africa is associated with poor air quality. Elevated
concentrations of criteria pollutants occur due to the high density of source emitters
including both industrial and non-industrial source operations. As a result, the Highveld
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Priority Area (HPA) was declared a priority area by the Minister on 23 November 2007
under NEMAQA.
Figure 7-4: Highveld and Vaal Triangle Priority Areas
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8. IMPACT ASSESSMENT METHODOLOGY
8.1 INTRODUCTION
Once a list of potential impacts has been developed (i.e. through the preceding scoping
process), the second major goal of the EIA process is to rate, rank and quantify, the many
impacts, so that the significant ones are emphasised in decision-making. There are many
techniques for doing this, but it must always be remembered that the technique should suit
the project.
There are very few cases where all potential impacts can be precisely quantified,
especially considering that the impacts cover such varying topics as employment effects
and groundwater quality, but a list of impacts with no indication of their ‘relative
significance’ would make decisions very difficult to reach and informed conclusions very
hard to make. In almost all situations, impact significance is done using semi-quantitative
methods. At this stage a few definitions are deemed necessary.
Significance: The concept of significance is at the core of impact identification, prediction,
evaluation and decision-making and the focus of EIA always narrows down to a decision
about whether the project is likely to cause significant/unacceptable adverse
environmental effects. Despite this, the concept remains largely undefined and there is no
international consensus on a single definition. Some examples of definitions or
interpretations from various authors are provided in Table 8-1 that follows:
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Table 8-1: Selected Definitions of Significance
Source Definition or interpretation
Haug et al.
(1984)
Determining significance is ultimately a judgement call. The
significance of a particular issue is determined by a threshold of
concern, a priority of that concern, and a probability that a
potential environmental impact may cross the threshold of concern.
Canter and
Canty (1993)
Significance can be considered on three levels: (1) significant and
not mitigatable, (2) significant but mitigatable, and (3) insignificant.
Significance is sometimes based on professional judgement,
executive authority, the importance of the project/issue, sensitivity
of the project/issue, and context, or by the controversy raised.
US
Environmental
Protection
Agency (1993)
Determination of significance requires predicting change. These
impact predictions are along with societal values, the major input to
significance determination. Ideally, change should be compared
against thresholds of concern, some of which may be legally
mandated and others, which may be levels or states of valued
components determined by the public, authorities or the EIA team.
Sadler (1996) The evaluation of significance is subjective, contingent upon values,
and dependent upon the environmental and community context.
Scientific disciplinary and professional perspectives frame
evaluations of significance. Scientists therefore evaluate
significance differently from one another and from local
communities.
Sippe (1999) Environmental significance is an anthropocentric concept, which
uses judgement and values to the same or greater extent than
science-based criteria and standards. The degree of significance
depends upon the nature (i.e. type, magnitude, intensity, etc.) of
impacts and the importance communities place on them.
Importantly, the NEMA EIA Regulations of 2010 (GN. R. 543 as amended by GN.R 1159 of
December 2010) states:
A “significant impact” means an impact that by its magnitude, duration, intensity or
probability of occurrence may have a notable effect on one or more aspects of the
environment;
Regulation 31(2)(l) states that an Environmental Impact Report must include:
“an assessment of each identified potentially significant impact, including—
(i) cumulative impacts
(ii) the nature of the impact
(iii) the extent and duration of the impact
(iv) the probability of the impact occurring
(v) the degree to which the impact can be reversed
(vi) the degree to which the impact may cause irreplaceable loss of resources
(vii) the degree to which the impact can be mitigated
Qualitative Methods/Assessment: This is done using statements, pictures or illustrations to
compare the impact of an activity versus the initial state of the receiving environment. For
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example, a social impact assessment makes use of interviews to find out how residents in
an area feel about a project proposal, whilst the visual assessment uses photomontage to
show how the views in the area will change.
Qualitative methods are typically used where the variables describing an impact are not
tangible and difficult to quantify. This method has the disadvantage of sometimes being
vague and is inherently based on the judgment of the assessor. However, these value-
based opinions are an important component of any EIA process and the challenge in the
EIA process is to balance value based input with scientific/technical information.
Quantitative Methods/Assessment: This is done using numerical methods where data is
directly comparable. However, scientific/technical information cannot always be
quantified – in many instances, ecological impacts are difficult to quantify. So, although
there is a component that can be precisely quantified, the more important biological
impacts will have to be semi-quantitative at best. Quantitative assessment is typically
applied for noise, air and other forms of pollution, where the direct physical changes may
be easily quantified and compared against regulatory limits, yet the indirect impacts
thereof on humans, plants and animals is not so easily calculated. It is important to note
that where quantitative models are used, they must as far as possible take into account the
existing environmental loading for the environmental aspect being assessed.
Semi-quantitative Methods/Assessment: This covers a range of methods that slot in-
between the two methods above. On the more qualitative side, an ordinal system can be
used where impacts are assigned a significance that is relative, but not precise, such as:
negligible, minor, major, severe, etc.
Baselines: Environmental impacts are measured against a baseline (i.e. the existing
conditions prior to the proposed development).
Thresholds: A threshold represents that point at which potential environmental effects are
considered significant. Thresholds are an analytical tool for judging significance. They can
be defined as a quantitative or qualitative standard or set of criteria against which the
significance of a given environmental effect may be determined. A threshold may be
based on aspects relating to:
Health-based standards, such as air pollutant emission standards, water pollutant
discharge standards, noise levels etc.
Service capacity standards, such as transportation service, water supply capacity or
waste treatment plant capacity
Ecological tolerance standards such as physical carrying capacity, impacts on
threatened or endangered species
8.2 TYPE OF IMPACTS Potential environmental impacts may either have a positive or negative effect on the
environment, and can in general be categorised as follows:
a) Direct/Primary Impacts
Primary impacts are caused directly due to the activity and generally occur at the same
time and at the place of the activity.
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b) Indirect/Secondary Impacts
Secondary impacts induce changes that may occur as a result of the activity. These types
of impacts include all the potential impacts that do not manifest immediately when the
activity is undertaken.
c) Cumulative Impacts
Cumulative impacts are those that result from the incremental impact of the proposed
activity on common resources when added to the impacts of the other past, present or
reasonably foreseeable future activities. Cumulative impacts can occur from the collective
impacts of individual minor actions over a period of time, and can include both direct and
indirect impacts.
8.3 DETERMINING SIGNIFICANCE
Impact significance assessment has been quantified to the greatest extent possible
throughout this EIA, with qualitative methods having been employed, together with
professional/specialist judgement, to assess the less tangible of the identified impacts.
The following criteria/method has also been used to, semi-quantitatively determine the
relative significance of the identified impacts, such that can at some level be
ranked/compared, so that the significant impacts are emphasised.
The scores associated with each of the levels within each criterion are indicated in brackets
after each description [like this].
8.3.1 NATURE
Nature (N) considers whether the impact is:
positive [- ¼ ]
negative [+1].
8.3.2 EXTENT
Extent (E) considers whether the impact will occur:
on site [1]
locally: within the vicinity of the site [2]
regionally: within the local municipality [3]
provincially: across the province [4]
nationally or internationally [5].
8.3.3 DURATION
Duration (D) considers whether the impact will be:
very short term: a matter of days or less [1]
short term: a matter of weeks to months [2]
medium term: up to a year or two [3]
long term: up to 10 years [4]
very long term, or permanent: 10 years or longer [5].
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8.3.4 INTENSITY
Intensity (I) considers whether the impact will be:
negligible: there is an impact on the environment, but it is negligible, having no
discernable effect [1]
minor: the impact alters the environment in such a way that the natural processes or
functions are hardly affected; the system does however, become more sensitive to
other impacts [2]
moderate: the environment is altered, but function and process continue, albeit in a
modified way; the system is stressed but manages to continue, although not with the
same strength as before [3]
major: the disturbance to the environment is enough to disrupt functions or
processes, resulting in reduced diversity; the system has been damaged and is no
longer what it used to be, but there are still remaining functions; the system will
probably decline further without positive intervention [4]
severe: the disturbance to the environment destroys certain aspects and damages
all others; the system is totally out of balance and will collapse without major
intervention or rehabilitation [5].
8.3.5 PROBABILITY
Probability (P) considers whether the impact will be:
unlikely: the possibility of the impact occurring is very low, due either to the
circumstances, design or experience [1]
likely: there is a possibility that the impact will occur, to the extent that provisions
must be made for it [2]
very likely: the impact will probably occur, but it is not certain [3]
definite: the impact will occur regardless of any prevention plans, and only
mitigation can be used to manage the impact [4].
8.3.6 MITIGATION OR ENHANCEMENT
Mitigation (M) is about eliminating, minimising or compensating for negative impacts,
whereas enhancement (H) magnifies project benefits. This factor considers whether –
A negative impact can be mitigated:
unmitigated: no mitigation is possible or planned [1]
slightly mitigated: a small reduction in the impact is likely [2]
moderately mitigated: the impact can be substantially mitigated, but the residual
impact is still noticeable or significant (relative to the original impact) [3]
well mitigated: the impact can be mostly mitigated and the residual impact is
negligible or minor [4]
A positive impact can be enhanced:
un-enhanced: no enhancement is possible or planned [1]
slightly enhanced: a small enhancement in the benefit is possible [2]
moderately enhanced: a noticeable enhancement is possible, which will increase
the quantity or quality of the benefit in a significant way [3]
well enhanced: the benefit can be substantially enhanced to reach a far greater
number of receptors or recipients and/or be of a much higher quality than the
original benefit [4].
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8.3.7 REVERSIBILITY
Reversibility (R) considers whether an impact is:
irreversible: no amount of time or money will allow the impact to be substantially
reversed [1]
slightly reversible: the impact is not easy to reverse and will require much effort,
taken immediately after the impact, and even then, the final result will not match
the original environment prior to the impact [2]
moderately reversible: much of the impact can be reversed, but action will have to
be taken within a certain time and the amount of effort will be significant in order to
achieve a fair degree of rehabilitation [3]
mostly reversible: the impact can mostly be reversed, although if the duration of the
impact is too long, it may make the rehabilitation less successful, but otherwise a
satisfactory degree of rehabilitation can generally be achieved quite easily [4].
8.4 CALCULATING IMPACT SIGNIFICANCE Significance is determined through the integration of impact characteristics in terms of the
above-mentioned variables, resulting in a rating of high, medium or low significance.
Impact significance is assigned both with and without mitigation, and the measures or
outcome of mitigation or optimisation of impacts highlighted. The table below summarises
the scoring for all the criteria.
Table 8-2: Scoring for Significance Criteria CRITERION SCORES
- ¼ 1 2 3 4 5
N-nature positive negative - - - -
E-extent - site local regional provinci
al
national
D-duration - very short short moderate long very long
I-intensity - negligible minor moderate major severe
P-probability - very unlikely unlikely likely very
likely
-
M-mitigation - none slight moderate good -
H-enhancement - none slight moderate good -
R-reversibility - none slight moderate good -
Impact significance is a net result of all the above criteria. The formula proposed to
calculate impact significance (S) is:
For a negative impact: S = N x (E+D) x I x P ÷ ½(M+R); and
For a positive impact: S = N x (E+D) x I x P x (H).
Negative impacts score from 2 to 200. Positive impacts score from – ½ to -200.
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8.5 UNDERSTANDING IMPACT SIGNIFICANCE The following is a guide to interpreting the final scores of an impact (for negative impacts):
Table 8-3: Final Significance Scoring Final score (S) Impact significance
0 – 10 negligible the impact should cause no real damage to the
environment, except where it has the opportunity to
contribute to cumulative impacts
10 – 20 Low the impact will be noticeable but should be localized or
occur over a limited time period and not cause
permanent or unacceptable changes; it should be
addressed in an EMP and managed appropriately
20 – 50 moderate the impact is significant and will affect the integrity of the
environment; effort must be made to mitigate and reverse
this impact; in addition the project benefits must be shown
to outweigh the impact
50 – 100 High the impact will affect the environment to such an extent
that permanent damage is likely and recovery will be slow
and difficult; the impact is unacceptable without real
mitigation or reversal plans; project benefits must be
proven to be very substantial; the approval of the project
will be in jeopardy if this impact cannot be addressed
100 – 200 severe the impact will result in large, permanent and severe
impacts, such as, local species extinctions, minor human
migrations or local economic collapses; even projects with
major benefits may not go ahead with this level of impact;
project alternatives that are substantially different should
be looked at, otherwise the project should not be
approved
Two examples will help illustrate this system:
SCENARIO 1 – An industrial facility proposes discharging effluent containing a high salt
content into a nearby stream. These salts will cause temporary problems for the ecosystem,
but are washed downstream, diluted and will have no long term effects. The short term
damage to the stream can be reversed fairly easily, but only if the ecosystem has not been
seriously damaged by the salts over a long time. A mitigation measure is also proposed
whereby during low flow periods (dry season) a pulse of clean water is discharged into the
stream after the saline effluent, diluting the salts and pushing them downstream faster, so
that the salts become so dilute as to have little or no effect.
From this scenario, the criteria are:
nature = negative = 1
extent = local = 2
duration = medium = 3
intensity = moderate = 3
probability = very likely = 4
mitigation = moderate = 3
reversibility = moderate = 3,
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and therefore impact significance is:
S = N x (E+D) x I x P ÷ ½(M+R)
= 1 x (2+3) x 3 x 4 ÷ ½(3+3)
= 60 ÷ 3
= 20.
Note that the impact prior to mitigation is major, but that due to the mitigation and the fact
that the ecosystem can recover easily from the effects of salt (high reversibility), the residual
impact becomes minor/moderate.
SCENARIO 2 – The above scenario applies, except that the effluent contains metals. These
metals become adsorbed onto clay and organic matter in the stream bed and are
accumulative toxins within the ecosystem, getting into the food chain and concentrating
upwards into predator species. Fresh water flushing will only very slightly mitigate this and
ecosystem recovery will not be easy or fast.
From this scenario, the criteria are:
nature = negative = 1
extent = local = 2
duration = very long = 5
intensity = moderate = 3
probability = very likely = 4
mitigation = slight = 2
reversibility = slight = 2,
and therefore impact significance is:
S = N x (E+D) x I x P ÷ ½(M+R)
= 1 x (2+5) x 3 x 4 ÷ ½(2+2)
= 84 ÷ 2
= 42.
Note that in this case, the original impact (of the metals) is more serious than the salt, but it
is the limited mitigation and reversibility that also act on the residual score and result in this
score being moderate.
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9. IMPACT SIGNIFICANCE ASSESSMENT/ANALYSIS
Impact analysis is, in a sense, the core of the EIA process. It is the phase where all relevant
project information that has been gathered is manipulated and distilled – it is the
‘Environmental Impact Assessment’. The impact analysis has two major goals, starting with
listing and describing all possible environmental impacts and then proceeding to give
some perspective on the relative significance of the various impacts. The predicted effects
of mitigation measures also need to be factored into the impact analysis.
Environmental impact analysis needs to take cognisance of the following issues that all fall
under the definition of the ‘environment’:
Physical natural environment: water, land, air
Biological natural environment: flora, fauna, ecosystems
Resources: land/space, minerals, water, rights of use
Economic: cost, profit, distribution of income, jobs, skills, permanence
Human health: occupational, environmental health, pollution, safety
Human cultural: religion, tradition, aesthetics, heritage, recreation
One needs to, however, bear in mind that the natural environment is the most threatened
and irreplaceable resource upon which all the other human aspects depend. The analysis
of impact significance assessment for potential project impacts furthermore needs to
consider impacts that may be realised through all project phases, as follows:
Construction/establishment
Operation
Decommissioning, closure and rehabilitation
Relative impact significance is semi-quantitatively assessed (Section 7.2) for relevant
aspects (e.g. water, air, biodiversity, noise, visual character, heritage resources, etc.) for
each respective phase of the project referred to above. Impact significance is however
also, to the greatest extent possible, quantified through comparison against legislated
thresholds (e.g. ambient air quality limits under NEM:AQA), or other applicable legal
limits/standards.
In addition, a brief description of mitigation to be implemented in order to minimise the
significance of the potential impacts is provided. The details of inter alia required
mitigation, monitoring and reporting are put forward in Appendix 9: Environmental
Management Programme Report
9.1 INDICATORS OF POTENTIAL IMPACT SIGNIFICANCE Some generic characteristics of impacts that point strongly towards significance include:
(EPA, 1998) -
violation of national laws or international protocols and norms
opportunity to contribute to cumulative impacts
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chance of irreversible damage occurring
amount of contradictory opinion or controversy
degree of uncertainty or number of unknowns
possibility of setting a precedent
More specific impact characteristics that will probably be included as significant are those
which (Adapted from DEA, 2002) -
conflict with environmental plans and frameworks
interfere with the movement of migratory wildlife
destroy wildlife habitat
exceed published environmental standards and limits e.g. water and air quality
standards
expose sensitive receptors to pollution
breach standards for transport, storage and handling of waste or hazardous goods
contaminate a public water supply
result in loss of prime agricultural land
terminate or substantially alter existing land uses
deface or devalue a cultural or heritage resource
cause changes in community or population dynamics
generate traffic beyond the design capacity of existing infrastructure
require resettlement of people
create a public health hazard
interfere with emergency response plans
As can be seen from the above lists, the determination of significance is far from being a
set method. In most cases, there is more than one aspect that will influence how significant
a particular impact is.
9.2 CONSTRUCTION PHASE
This phase of the project involves all those activities related to preparation of the site and
subsequent construction/establishment of the various project structures and associated
surface infrastructure thereon (earthworks/levelling/excavations/foundations, building
construction and engineering services installation, etc.). It is envisaged that the
construction period will last for approximately 3 months
Below is an assessment of environmental aspects and their associated impacts relating to
the proposed project. Differentiation is made between significance of impact and priority
for the management of an impact, which is determined by impact significance, and
existence of applicable legislation.
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9.2.1 NOISE
Introduction
The proponent must comply with the provisions of the Occupational Health and Safety Act,
1993 (Act No. 85 of 1993), as well as any other national norms and standards regarding
noise management. Predominant construction related noise impacts are anticipated from
the following sources:
Heavy vehicle movement and operation associated with ground works and
building activities (i.e. dump trucks, excavators, TLBs, cranes, graders, earth
compacters, etc.); and
Drilling (e.g. structural works).
The SRTS site is primarily surrounded by industrial areas. The nearest residential area to the
site is located approximately 1 km to the north-west of the SRTS plant, while the central
business district of Kroonstad is located approximately 1 km to the north-east of the SRTS
plant.
The Noise Control Regulations (R 154 GG 13717 of 10 January 1992) promulgated in terms
of ECA, defines:
Nuisance noise, as “any sound which disturbs or impairs or may disturb or impair
the convenience or peace of any person”; and
Disturbing noise, as “any noise level which exceeds the zone sound level or, if no
zone sound level has been designated, a noise level which exceeds the ambient
sound level at the same measuring point by 7 dBA or more”.
Regulation 4 states ‘No person shall make, produce or cause a disturbing noise, or allow it
to be made, produced or caused by any person, machine, device or apparatus or any
combination thereof.’ In addition, Section 28 of NEMA imposes a ‘duty of care’ on every
person who may cause significant pollution to prevent such pollution or degradation from
occurring, continuing or recurring, or, in so far as such harm to the environment is
authorised by law or cannot reasonably be avoided or stopped, to minimise and rectify
such pollution or degradation of the environment. An increase of 7dB above current
ambient noise levels would thus be unacceptable, and the proponent would need to take
appropriate noise reduction measures to avoid creating ‘ disturbing noise’ during the
construction period; where construction phase noise monitoring may be required if
complaints arise from around noise during the construction phase.
Impact discussion and significance assessment
Two aspects are important when considering the potential noise impacts of a project and
these are as follows:
The anticipated increase in the ambient noise level; and
The overall ambient noise level produced.
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Table 9-1: Impacts on Ambient Noise Levels (Construction)
Nature (N) Negative impacts of construction related noise on
sensitive receptors 1
Extent (E) Locally: Within the vicinity of the site 2
Duration (D) Short term: Construction phase (bulk of work
conservatively anticipated for a matter of months) 2
Intensity (I) Moderate: Ambient noise levels would likely be
increased over the short-term, but function and
process would continue, albeit in a modified way. 2
Probability (P) Likely: There is a possibility that the impact will occur,
to the extent that provisions must be made for it. 3
Mitigation (M) Slightly mitigated: Limited avoidance and
minimisation techniques available 2
Enhancement (H) N/A -
Reversibility (R) Reversible with the cessation of the activity 4
Significance Rating
with Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R)
negligible 8
Significance Rating
without Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R)
Low 12
Significance Rating
-Positive Impact (S)
N x (E+D) x I x P x (H). -
Mitigation Management
The following measures must be considered by the Proponent prior to the acquisition of
earthmoving equipment:
Enclosure of engine bays;
Modification of radiator fan design and materials;
Installation of louvers on radiator and hydraulic cooling fans; and
Re-engineering of exhaust systems.
The following are the Environmental, Health and Safety Guidelines of the IFC of the World
Bank, which should be taken into consideration during the construction phases of the
project:
Selecting equipment with lower sound power levels;
Installing suitable mufflers on engine exhausts and compressor components;
Installing vibration isolation for mechanical equipment; and
Develop a mechanism to record and respond to complaints.
The proponent must also restrict construction activities to within 7:00am and 5:00pm on
weekdays, and 8:00am to 13:00pm on Saturdays.
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9.2.2 BIODIVERSITY
Impact Discussion and Significance Assessment
The proposed WTE plant will be on an already existing site therefore no biodiversity loss in
anticipated.
Mitigation/management
There can be very little to no mitigation of biodiversity loss, due to the fact that the
development area is completely transformed.
9.2.3 CONSTRUCTION AND INSTALLATION WASTE GENERATION (CONTRIBUTION TO
LANDFILL)
Introduction
Nominal volumes of construction and installation waste will be generated during the
construction of the proposed WTE plant. The waste would predominantly comprise of
building rubble, packaging and fabrication waste/s. Steel and electric cabling waste, and
packaging waste is also expected from installation. It is likely that most, if not all, of the
waste generated would be non-hazardous/general waste. The generation of such waste
could indirectly impact on the operational lifespan of the Disposal Facility, through the
permanent occupation of remaining available airspace at this facility. The same principle
Table 9-2: Impacts on biodiversity (Construction)
Nature (N) Negative: Indirect negative effect on biodiversity
occurring within the perimeter of the site. 1
Extent (E) Site: Fauna and flora occurring within the perimeter
of the site might be affected.
1
Duration (D) Very long: The fauna and flora will be affected for
the life of the plant and evaporation ponds. 5
Intensity (I) Negligible: The effect of fauna and flora will be
negligible due to the area already having been
completely disturbed therefore the status quo should
be maintained in terms of biodiversity.
1
Probability (P) Good: The probability of fauna and flora occurring
directly where construction activities take place is
very likely.
2
Mitigation (M) No mitigation is planned. 1
Enhancement (H) N/A -
Reversibility (R) Slight: The chance of creating a habitable
environment for indiginous fauna and flora is slight. 4
Significance Rating
with Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R)
negligible 4.8
Significance Rating
without Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R)
negligible 6
Significance Rating
-Positive Impact (S)
N x (E+D) x I x P x (H). -
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would apply to the applicable hazardous landfill facility/ies to which hazardous waste
generated during construction will be taken for disposal.
Impact Discussion and Significance Assessment
The intensity of the impact will be low relative to cumulative National and regional waste
generation volumes (general and hazardous waste generation).
Table 9-3: Impacts of Construction Waste Generation (Construction)
Nature (N) Indirect negative impact on landfill airspace
availability. 1
Extent (E) Provincial: Use of landfill in the province 4
Duration (D) Short term: Construction phase (bulk of work
conservatively anticipated for a matter of months) 2
Intensity (I) Negligible: The anticipated impact will be negligible,
with no discernable effect on relative airspace
availability.
1
Probability (P) Definite: The generated of waste during the
construction phase is largely unavoidable (the
amount generated can, however, be managed)
4
Mitigation (M) Slightly: A small reduction in the volumes of waste
generated can likely be effected during construction 2
Enhancement (H) N/A -
Reversibility (R) Moderately reversible through reuse, recovery and/or
recycling initiatives: Where the impact relates to
contribution to landfill, any measure implemented to
reuse, recover, or recycle such waste would
constitute the reversal of the impact
3
Significance Rating
with Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R)
negligible 9.6
Significance Rating
without Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R)
Low 16
Significance Rating
-Positive Impact (S)
N x (E+D) x I x P x (H). -
Mitigation/Management
All construction and installation waste will be stored temporarily in a way that protects
surface- and groundwater, and appropriately disposed of at a suitable,
permitted/licensed, disposal site (i.e. where the waste in question is classified as general
waste), or stored temporarily prior to collection by a suitably licensed waste disposal
contractor in the event that hazardous waste is generated. Temporary waste storage areas
will be sited under the guidance of site environmental personnel prior to the start of
construction activities. Construction personnel will be trained in their correct use and the
sites will be regularly inspected to ensure that they are being appropriately managed.
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9.2.4 GROUNDWATER AND SURFACE WATER QUALITY
Introduction
The inappropriate storage, management and handling of fuel, oil and other potentially
hazardous chemicals and substances during the construction period could result in
potentially negative impacts on surface- and ground water quality; where spillages of such
could enter the groundwater environment in particular, through the infiltration of
contaminated surface run-off into the groundwater environment. Contamination of this
nature, associated with the construction phase of a project of this magnitude, would
typically be hydrocarbon based (i.e. petrol, diesel and oil leaks and spillages to bare soil
surfaces). Temporary concrete batching plants can also impact negatively on ground- and
surface water resource quality if poorly managed.
Groundwater contamination would generally be restricted to the confines of the site, or in
severe cases the immediate surrounds of the site. In the absence of a significant,
continuous, point source of pollution, a groundwater pollution plume would likely develop
and extend (i.e. in terms of lateral geographic extent) slowly within the underlying alluvial
aquifer.
In addition, during construction, temporary stockpiles of building material, excavated soil,
overburden and rock, as well as waste, will be produced. It is important that these
stockpiles are located in a centralised area where temporary measures such as berms will
prevent sediment run-off, specifically during heavy rainfall episodes. These particular waste
streams are, however, not expected to be hazardous, or pose a significant contamination
risk to groundwater.
Impact Discussion and Significance Assessment
Table 9-4: Impacts on Water Resource Quality (Construction)
Nature (N) Negative impact on water resource quality 1
Extent (E) Locally: Localised to the site and immediate
surrounds
2
Duration (D) Long term: Only if a plume enters groundwater will it
be a long process to remediate contaminated
groundwater.
5
Intensity (I) Minor: The quantity of contaminants that have a
possibility of entering groundwater are small
2
Probability (P) Unlikely: The probability of a spill taking place during
construction is low
2
Mitigation (M) Good: There are many measures that can be
implemented in order to prevent water
contamination.
4
Enhancement (H) N/A -
Reversibility (R) Slight: Groundwater remediation is possible but is a
lengthy and costly process.
2
Significance Rating
with Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R)
Negligible 9.3
Significance Rating N x (E+D) x I x P ÷ ½(M+R) Low 18.6
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Table 9-4: Impacts on Water Resource Quality (Construction)
without Mitigation -
Negative Impact (S)
Significance Rating
-Positive Impact (S)
N x (E+D) x I x P x (H). -
Mitigation/Management
The remediation of contaminated groundwater is a long, arduous and costly process. Any
such remediation efforts may also likely leave significant residual contamination, despite
any such remediation attempts (dependant on the nature and extent of the
contamination itself). As such, the proponent’s management actions should focus on the
prevention of any such potential hydrocarbon contamination, rather than post impact
remediation thereof. A comprehensive range of effective, proven, mitigation measures will
be implemented in this regard, which are in principle as follows:
All hazardous substances to be stored within appropriately sized,
impermeable, bund walls;
Storm water control measures to be implemented that prevent the free
movement of ‘clean’ storm water run-off through the aforementioned
storage areas, as well as any service yards and wash bays;
Hazardous substances spill kits to be readily available at all points where
hazardous substances will be stored and/or transferred (e.g. refuelling points);
Vehicle and plant servicing to only take place in dedicated service yards on
impermeable surfaces coupled with appropriate ‘dirty’ water containment
systems/sumps and oil/water separators; and
Drip trays to be appropriately placed under vehicles and plant that over-
night on bare soil surfaces.
Contractors will also be required to provide a method statement in respect of how they
propose to manage fuel storage, concrete batching- and workshop areas to minimise the
potential for groundwater pollution. Such method statements would need to be signed off
by competent site environmental personnel / environmental control officer (ECO), prior to
the start of construction activities.
9.2.5 AIR QUALITY
Introduction
During construction, the undertaking of ground- and civil works would lead to the
generation of vehicle and wind entrained dust. Although the impact is likely to be localised
to the site, dust suppression techniques such as wetting roads, or application of dust
palliatives, would be required. Other emissions, such as construction vehicle and machinery
exhausts are not anticipated to be significant.
The nearest residential receptors to the development site are located approximately 1km
to the north-west of the SRTS plant. It must be noted that that the proponent would need to
ensure that dust fallout during construction does not exceed the limit for industrial land use
specified in SANS1929:2005 (i.e. < 600mg/m2/day – 30 day average).
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Impact Discussion and Significance Assessment
The impact will be of a low intensity and isolated to the site and its immediate surrounds.
Effective mitigation, in the form of accepted dust suppression techniques, can be applied,
but will not likely mitigate the potential occurrence of the impact in its entirety (i.e. residual
impacts may be noticeable, but will be negligible relative to the original impact). The
residual impacts will occur up until the point at which construction activities cease and
when concurrent rehabilitation of applicable affected areas has been completed.
Table 9-5: Impacts on Air Quality (Construction)
Nature (N) Negative impact on ambient air quality. 1
Extent (E) Locally: Localised to the site and immediate
surrounds
2
Duration (D) Short Term: Construction phase (conservatively
anticipated for a matter of months) 2
Intensity (I) Minor: Natural processes or functions will hardly be
affected 2
Probability (P) Likely: Impact will likely occur, to the extent that
provisions must be made for the mitigation thereof 2
Mitigation (M) Well mitigated: Effective dust suppression methods
readily available 4
Enhancement (H) N/A -
Reversibility (R) Irreversible: Not practical to reverse the impact once
it has occurred 1
Significance
Rating with
Mitigation -
Negative Impact
(S)
N x (E+D) x I x P ÷ ½(M+R)
Negligible 6.4
Significance
Rating without
Mitigation -
Negative Impact
(S)
N x (E+D) x I x P ÷ ½(M+R)
Moderate 32
Significance
Rating -Positive
Impact (S)
N x (E+D) x I x P x (H).
-
Mitigation/Management
The Proponent will institute effective dust suppression measures on all un-surfaced access
and haul roads for the duration of the construction phase. Compliance thereto will be
measures against draft dust control standards (SANS1929:2005 – ‘industrial’) and associated
thresholds.
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9.3 OPERATIONAL PHASE The operational phase of the project encompasses all those aspects associated with the
actual treatment of waste at the sites, as well as those activities associated with the
management of secondary waste streams from that treatment processes .
All of the operational activities aforementioned in Section 3.1 have the potential to impact
on one, or more, environmental parameters, as evaluated and described in the following
sections.
9.3.1 NOISE
Introduction
The proponent must comply with the provisions of the Occupational Health and Safety Act,
1993 (Act No. 85 of 1993), as well as any other national norms and standards regarding
noise management. Noise impacts during operation are anticipated from the following
sources:
Combustions fans for the pyrolysis unit
The gas engine exhaust
The SRTS site is primarily surrounded by industrial areas. The nearest residential area to the
site is located approximately 1 km to the north-west of the SRTS plant, while the central
business district of Kroonstad is located approximately 1 km to the north-east of the SRTS
plant.
The Noise Control Regulations (R 154 GG 13717 of 10 January 1992) promulgated in terms
of ECA, defines:
Nuisance noise, as “any sound which disturbs or impairs or may disturb or impair
the convenience or peace of any person”; and
Disturbing noise, as “any noise level which exceeds the zone sound level or, if no
zone sound level has been designated, a noise level which exceeds the ambient
sound level at the same measuring point by 7 dBA or more”.
Regulation 4 states ‘No person shall make, produce or cause a disturbing noise, or allow it
to be made, produced or caused by any person, machine, device or apparatus or any
combination thereof.’ In addition, Section 28 of NEMA imposes a ‘duty of care’ on every
person who may cause significant pollution to prevent such pollution or degradation from
occurring, continuing or recurring, or, in so far as such harm to the environment is
authorised by law or cannot reasonably be avoided or stopped, to minimise and rectify
such pollution or degradation of the environment. An increase of 7dB above current
ambient noise levels would thus be unacceptable, and the proponent would need to take
appropriate noise reduction measures to avoid creating ‘ disturbing noise’ during the
construction period; where construction phase noise monitoring may be required if
complaints arise from around noise during the construction phase.
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Impact discussion and significance assessment
Two aspects are important when considering the potential noise impacts of a project and
these are as follows:
The anticipated increase in the ambient noise level; and
The overall ambient noise level produced.
Table 9-6: Impacts on Ambient Noise Levels (Operation)
Nature (N) Negative impacts of construction related noise on
sensitive receptors 1
Extent (E) Locally: Within the vicinity of the site 2
Duration (D) Short term: Construction phase (bulk of work
conservatively anticipated for a matter of months) 5
Intensity (I) Moderate: Ambient noise levels would likely be
increased. 2
Probability (P) Likely: There is a possibility that the impact will occur,
to the extent that provisions must be made for it. 2
Mitigation (M) moderately mitigated: Viable avoidance and
minimisation techniques available 3
Enhancement (H) N/A -
Reversibility (R) Reversible with the cessation of the activity 4
Significance Rating
with Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R)
negligible 8
Significance Rating
without Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R)
Low 14
Significance Rating
-Positive Impact (S)
N x (E+D) x I x P x (H). -
Mitigation Management
The following are the Environmental, Health and Safety Guidelines of the IFC of the World
Bank, which should be taken into consideration:
Selecting equipment with lower sound power levels;
Installing suitable mufflers on engine exhausts and compressor components;
Installing vibration isolation for mechanical equipment; and
Develop a mechanism to record and respond to complaints.
Appropriate acoustic silencers need to be installed if the ambient noise levels are found to
be above the levels stipulated in The Noise Control Regulations (R 154 GG 13717 of 10
January 1992)
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9.3.2 GROUNDWATER POLLUTION
Introduction
The inappropriate storage, management and handling of fuel, oil and other potentially
hazardous chemicals and substances during the operational phase could result in
potentially negative impacts on surface and ground water quality; where spillages of such
could enter the groundwater environment in particular, through the infiltration of
contaminated surface run-off into the groundwater environment. Contamination of this
nature, associated with a project of this magnitude, would typically be hydrocarbon based
(i.e. petrol, diesel and oil leaks and spillages to bare soil surfaces). Temporary concrete
batching plants can also impact negatively on ground- and surface water resource quality
if poorly managed.
Groundwater contamination would generally be restricted to the confines of the site, or in
severe cases the immediate surrounds of the site. In the absence of a significant,
continuous, point source of pollution, a groundwater pollution plume would likely develop
and extend (i.e. in terms of lateral geographic extent) slowly within the underlying alluvial
aquifer.
Impact Discussion and Significance Assessment
The intensity of the impact will be low.
Table 9-7: Impacts on Water Resource Quality (operation)
Nature (N) Negative impact on water resource quality 1
Extent (E) Locally: Localised to the site and immediate
surrounds
2
Duration (D) Long term: Only if a plume enters groundwater will it
be a long process to remediate contaminated
groundwater.
5
Intensity (I) Minor: The quantity of contaminants that have a
possibility of entering groundwater are small
2
Probability (P) Unlikely: The probability of a spill taking place during
operation is low
2
Mitigation (M) Good: There are many measures that can be
implemented in order to prevent water
contamination.
4
Enhancement (H) N/A -
Reversibility (R) Slight: Groundwater remediation is possible but is a
lengthy and costly process.
2
Significance Rating
with Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R)
Negligible 9.3
Significance Rating
without Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R)
Low 18.6
Significance Rating
-Positive Impact (S)
N x (E+D) x I x P x (H). -
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Mitigation/Management
Since it is possible that the waste water will impact on the receiving hydrogeological
regime, mitigation/management measures will have to be put in place to negate any
potential contamination that may result. The following measures will have to be put in
place:
Store all potential sources in secure facilities with appropriate storm water
management, ensuring contaminants are not released into the environment.
Implement the EMP’s of other environmental related aspects, including
pollution prevention and impact minimisation.
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9.3.3 AIR QUALITY
Introduction
The proposed operations will produce emissions from the pyrolysis process as well as the
internal combustion engine. An emission inventory for operations was formulated based on
emission limits as stipulated in GN 893. Only sources of potential significance were
modelled. Emissions information was provided by the technology provider, based on the
guarantee that the emissions limits will be met. The proposed operations will have a single
stack combining all emissions.
Impact Discussion and Significance Assessment
The emission from the proposed SRTS site was modelled to show the impacts the waste to
energy operations would have on the local ambient air quality. As there are no significant
industrial background contributors to ambient emissions only the proposed operations were
modelled as a part of the Air Quality Impact Assessment (AQIA). The findings of the AQIA
are set out below, for more detail refer to Appendix 7: Air Quality Impact Assessment.
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Predicted concentrations for PM10 & PM2.5
Predicted maximum daily-averaged ambient concentrations of PM10 resulting from both
the site and the cumulative scenario are well within the NAAQS (75 µg/m3). As the total
PM10 ambient concentrations are below that of the PM2.5 ambient limits (25 µg/m3), the
PM2.5 ambient concentrations will automatically be met.
Figure 9-1: Predicted PM10 maximum 24-Hour average ambient concentration for the
Proposed Waste to Energy Project
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Predicted concentrations for SO2
Only the maximum hourly SO2 results are presented here. The impact from the proposed
operations as well as background emitters is well within the national ambient air quality
standards for all regulated averaging periods.
Figure 9-2: Predicted SO2 maximum hourly average ambient concentration for the
Proposed Waste to Energy Project
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Predicted Ambient NO2
Only the maximum hourly NO2 results are presented here. The impact from the proposed
operations is well within the national ambient air quality standards for all regulated
averaging periods.
Figure 9-3: Predicted NOx hourly maximum ambient concentration for the Proposed Waste
to Energy Project
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Predicted Concentrations AMBIENT CO
There is no predicted exceedance of the hourly CO ambient limit due to emissions from
the proposed waste to energy project.
Figure 9-4: Predicted CO hourly maximum ambient concentration for the Proposed
Waste to Energy Project
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Conclusion
The AQIA report shows that the impact on ambient air quality resulting from proposed
waste to energy process point sources is well within the ambient limits. Thus the impact
significance is considered to be low.
Mitigation/Management
The technology provider has ensured that the emissions limits utilised for the emissions
modelling will be met. In order to ensure this a regenerative thermal oxidiser is proposed
as an abatement measure.
9.3.4 SOCIO ECONOMIC
Introduction
The proposed project would result in the employment of three technical operators. The
socio-economic impact of this is therefore not deemed to be of high significance
Impact Discussion and Significance Assessment
The proposed project will have a positive socio-economic impact.
Mitigation/Management
N/A
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10. ASSESSMENTS OF CUMULATIVE IMPACTS
The NEMA 2010 Regulations states that a ‘cumulative impact’, in relation to an activity,
means the impact of an activity that in itself may not be significant but may become
significant when added to the existing and potential impacts eventuating from similar
or diverse activities or undertakings in the area. The outputs of a cumulative impact
assessment can be -
1. the identified sources of cumulative impacts;
2. the sequence of events from source to effect; or
3. the resultant effects.
Cumulative impact assessment methods are evolving and there is no single accepted
state of global practice. Key is to consider cumulative impacts as integral to the
assessment of impacts and that activity induced impacts not be seen in isolation but
considered using a wider systems based approach to consider both the assimilative
capacity to absorb cumulative impacts. This impact assessment considers all impacts in
a cumulative sense throughout. See list below for further details.
Potential cumulative impacts have been identified for the proposed project, as follows,
and have been intrinsically assessed in specialist studies utilising state of the art
modelling and also as part of the EIA itself and relevant supporting specialist
assessments:
The specialist air quality impact assessment undertaken in support of the EIA took
due consideration of the potential existence of other potentially significant
emission sources in the area (i.e. that may contribute toward cumulative
impacts on ambient air quality, together with the proposed plant’s emissions).
No such source was identified.
The air quality impact assessment further considered the cumulative impacts of
criteria pollutant emissions on ambient air quality resulting from all relevant onsite
sources.
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11. CONCLUSIONS AND EAP RECOMMENDATIONS
11.1 IN SUMMARY In light of high cost of disposal and long distances of material transport to a licensed
disposal facility associated with the current disposal of the SRTS abattoir’s waste to landfill
a better solution was sought for to deal with the waste from the SRTS abattoir. EScience
Associates (ESA) was appointed by SRTS, as the independent Environmental Assessment
Practitioner (EAP), to facilitate the application for obtaining a Waste Management
License for a proposed power generation plant through pyrolysis of abattoir waste. The
aforementioned application was submitted to the National Department of Environmental
Affairs (DEA) on 14th November 2013, and acknowledged by the DEA on 22nd November
2013. The application was assigned the reference number 12/9/11/L1391/2. The final
scoping report, after having undergone public review, was submitted to the DEA on 29th
May 2014. The DEA accepted the scoping report on 4th July 2014 and a letter stating the
acceptance of the Scoping Report was received by the EAP on 7th July 2014
The main objective of this report was to identify and discuss issues of potential
environmental significance, and where possible, indicate the significance of those
impacts. The identification and assessment of environmental impacts, for every project
phase, revealed that there are some potential impacts. However the problems that have
been highlighted can be addressed through stringent and rigorous mitigation measures.
The need for the pyrolysis plant is strong and it will greatly reduce the amount of waste to
landfill, as well as the high cost associated with the transport of this waste. It is therefore
the opinion of the EAP that the project should go ahead as long as a strict EMPr is
formulated and adhered to from the construction all the way to decommissioning phase.
11.2 CONCLUSIONS
11.2.1 CONSTRUCTION
Potential construction phase impacts of significance include noise, dust, traffic and soil
and ground water contamination. With sufficient mitigation these impacts will be easily
managed and kept within legal limits.
No identified construction phase impacts are identified to pose a fatal flaw to the project,
provided that the mitigation put forward in this EIA and the attached EMPR are complied
with by the proponent during construction.
11.2.2 OPERATION
The operational phase too has the potential to result in impacts such as ground water
contamination, air emissions and noise. Provided sufficient containment infrastructure is in
place where storage of hazardous substances occurs the contamination of groundwater
can be prevented. The air emissions are to be within stipulated legal limits shown in Table
5-6.
Appendix 7: Air Quality Impact Assessment shows that the impact on ambient air quality
resulting from proposed waste to energy process point sources is well within the ambient
limits.
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No fatal flaws have been identified for the project during the operational phase thereof,
provided that the full range of mitigation and monitoring requirements put forward in this
EIA and the attached EMPR are complied with by the proponent during operation.
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12. REFERENCES
Department of Labour (2005), Explanatory Notes on the Major Hazard Installation
Regulations by Chief Directorate of Occupational Health and Safety in the Department of
Labour. April 2005.
DWAF (1998), Department of Water Affairs and Forestry Minimum Requirements for the
Handling, Classification and Disposal of Hazardous Waste, Edition 2 1998.
South African Weather Services: www.weathersa.co.za
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APPENDIX 1: AUTHORITY CORRESPONDENCE
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APPENDIX 2: WASTE MANAGEMENT LICENSE APPLICATION
FORM
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APPENDIX 3: LAYOUT PLAN FOR PROPOSED STRUCTURES AND
INFRASTRUCTURE
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APPENDIX 4: PUBLIC PARTICIPATION DOCUMENTATION
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APPENDIX 5: SCOPING REPORT
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APPENDIX 6: EAP CV’S
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APPENDIX 7: AIR QUALITY IMPACT ASSESSMENT
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APPENDIX 8: WASTE ASSESSMENT
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APPENDIX 9: ENVIRONMENTAL MANAGEMENT PROGRAMME
REPORT