Post on 24-Apr-2023
PROPOSED WASTE PYROLYSIS
FACILITY, INDUSTRIAL GREEN ENERGY
SOLUTIONS (PTY) LTD, CENTURION,
GAUTENG
DRAFT BASIC ASSESSMENT REPORT
DEFF REFERENCE:
12/9/11/L200812122133/3/N
August 2020
ESCIENCE
ASSOCIATES
(PTY) LTD
POSTAL
ADDRESS:
PO Box 2950
Saxonwold
2132
PHYSICAL
ADDRESS:
9 Victoria Street
Oaklands
Johannesburg
2192
TEL:
+27 11 728 2683
FAX:
086 512 5681
WEBSITE:
www.escience.co.za
E-MAIL:
info@escience.co.za
ESCIENCE
DRAFT BASIC ASSESSMENT REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page i
PROJECT INFORMATION SHEET
PROJECT:
PROPOSED WASTE PYROLYSIS FACILITY, INDUSTRIAL GREEN ENERGY SOLUTIONS (PTY) LTD,
CENTURION, GAUTENG
APPLICANT:
Industrial Green Energy Solutions (Pty) Ltd
Postal Address: 8 Summit Road, Knoppieslaagte 385, Centurion, , 0157
Contact: Cell: 083 222 5222
Tel: 071 877 7610
E-mail: barry.gonin@industrialgreenenergy.com
Contact Person: Barry Gonin
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: info@escience.co.za
Project Leader: Abdul Ebrahim
COMPETENT AUTHORITY:
NATIONAL DEPARTMENT OF ENVIRONMENT, FORESTRY AND FISHERIES
Postal Address: Private Bag X447, Pretoria, 0001, South Africa
Contact: Tel: (086) 111 2468
REPORT HISTORY AND DETAILS:
Draft Basic Assessment Report for distribution to Interested and Affected Parties
DRAFT BASIC ASSESSMENT REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page ii
EXECUTIVE SUMMARY
BACKGROUND
Industrial Green Energy Solutions (Pty) Ltd (hereinafter referred to as IGE) has appointed
EScience Associates (Pty) Ltd. (hereinafter referred to as EScience), as an independent
Environmental Assessment Practitioner (EAP), to undertake an Environmental Impact
Assessment (EIA) in support of an application for a Waste Management Licence (WML)
for the proposed establishment of a waste pyrolysis facility at the Limeroc Business Park,
Knoppieslaagte 385-Jr, Centurion, Gauteng.
The proposed facility will recover lighter hydrocarbons through thermal treatment of non-
hazardous wastes such as recovered waxes, non-hazardous oils and lubricants and
plastics, in order to produce various organic compounds and fuel blends including but
not limited to naphtha, petrol, diesel, and heavy fuel oil.
The proposed site is located within the City of Tshwane Metropolitan Municipality and is
immediately surrounded by residential and commercial activities as well as
grassland/shrubland. It forms [art of ward 106 of the City of Tshwane Metropolitan
Municipality.
WASTE MANAGEMENT LICENCING
According to section 19(1) and 19(3) of the NEMWA, 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’
and subsequently ‘Category C’ waste management activities were first published, in GN
718 of 3 July 2009, with subsequent amendments, including General Notice No: 921 on
29 November 2013, and subsequent amendments thereto as well. The latest amendment
being GN 1094 at the time of submission of this application. Category A and B activities
require a Waste Management Licence in terms of section 20(b) of NEMWA, whereas
Category C activities require that the person conducting these activities complies with
the relevant requirements or standards as stated in GN. R.921, as amended.
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. Activities listed under category
C do not require a Basic Assessment or Scoping and EIA. The licensing process for waste
management activities and the supporting information required is therefore the same as
for activities listed in the EIA listing notices that require an Environmental Authorisation.
The table below shows the NEMWA Listed Waste Management Activities listed under GN
R.921, as amended, that are applicable to the proposed facility.
NEM:WA Listed Waste Management Activities as per GN 921:2013
Applicable ‘Category A’ (Basic Assessment) Activities
Category A
– Activity (3)
The recycling of general waste at a facility that has an operational area
in excess of 500m2, excluding recycling that takes place as an integral
part of an internal manufacturing process within the same premises.
DRAFT BASIC ASSESSMENT REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page iii
NEM:WA Listed Waste Management Activities as per GN 921:2013
Reason: Recycling of up to 40 tons/day general waste (wax and plastics)
to produce fuels
Category A -
Activity (5)
The recovery of waste including the refining, utilisation, or co- processing
of waste in excess of 10 tons but less than 100 tons of general waste per
day or in excess of 500kg but less than 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: Recovery of up to 40 tons/day general waste (wax and plastics)
to produce fuels
Category A
– Activity (6) The treatment of general waste using any form of treatment at a facility
that has the capacity to process in excess of 10 tons but less than 100
tons.
Reason: Treatment of up to 40 tons/day general waste (wax and plastics)
to produce fuels
Category A
– Activity
(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).
With the activities being listed in Category A, the process of applying for a WML requires
the conduct Basic Assessment as per the EIA Regulations. The competent authority in this
respect is the Department of Environment, Forestry and Fisheries (DEFF) due to the fact
that this is a waste to energy project.
PUBLIC PARTICIPATION
The public and stakeholder participation process to date has entailed the following:
• Advertising of the proposed project and associated BA process in The Star and
The Pretoria News newspapers on the 16th of July 2020 and the Fourways Review
on 28th July 2020. (Refer to Appendix 1.1: Newspaper Advertisements)
• Placement of site notices at the main entrance as well as the sidewalk to the main
entrance to the site on the 14th of July 2020 (Refer to Appendix 1.2: Site Notices)
• Pre-identification of Interested and Affected Parties based on the existing list
registered IAPs including neighbouring landowners and occupiers, the ward
councillor, the municipality, the provincial environmental authority, and other
stakeholders. (Refer to Appendix 1.3 for the list of IAPS)
The following is to be conducted through the distribution of the Draft Basic Assessment
Report to registered interested and affected parties:
• Notification of Interested and Affected Parties, including neighbouring
landowners and occupiers, the ward councillor, the municipality, the provincial
environmental authority, and other stakeholders.
• Distribution of draft BAR to IAPs for comment.
• Focus group meetings with relevant stakeholders if required.
DRAFT BASIC ASSESSMENT REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page iv
SUMMARY OF IMPACTS
Impact Summary
Impact
( - / +)
Impact significance without
mitigation
Impact significance with
mitigation
Construction phase:
Potential impacts on soil and groundwater quality
during construction - Low Negligible
Noise generation during construction activities. - Low Negligible
Waste generation during construction of infrastructure. - Low Negligible
Dust generation during construction activities. - Negligible Negligible
Archaeological and cultural impacts - No impact (refer to section 0)
Operational phase:
Potential impacts on groundwater quality during
operations - Moderate Negligible
Potential impacts on soil during operations - Negligible Negligible
Noise - Low Negligible
Air Quality Low to negligible (refer to section 9.1)
Reduction of waste to landfill + Positive (Negligible)
Socio-Economic - Job creation + Positive (Moderate)
Decommissioning Phase
Potential impacts on surface and groundwater quality
during construction - Low Negligible
Noise generation during decommissioning activities. - Low Negligible
Waste generation during decommissioning of
infrastructure. - Low Negligible
Dust generation during decommissioning activities. - Negligible Negligible
DRAFT BASIC ASSESSMENT REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page v
CONCLUSION
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 revealed that the
potential impacts can be adequately addressed through appropriate management
measures.
It is the professional opinion of the EAP that the process undertaken for the application
to date has been procedurally correct, in terms of, inter alia, the requirements outlined
in the National Environmental Management Act, 1998 (Act No. 107 of 1998) (“NEMA”)
and the EIA Regulations, 2014 (as amended).
The EAP, furthermore, believes that any significant impacts that may be caused by the
facility have indeed been identified to the extent possible / practical and to a large
extent these impacts can be well mitigated through adequate environmental
management.
The EAP also believes that the information provided in this Basic Assessment Report is
sufficient / substantive for IAPs to contribute meaningfully to the process 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.
It must be noted that the proposed location for the site is zoned for industrial use.
Therefore, the refusal of this application would most likely result in the site being used by
another industrial activity in the future (whether or not by this proponent) due to its
location, zoning and access to established industrial services such as water supply, roads,
electrical supply, sewage and other infrastructure. The environmental impact of this
future activity cannot be predicted.
DRAFT BASIC ASSESSMENT REPORT
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TABLE OF CONTENTS
EXECUTIVE SUMMARY .................................................................................................................. II
BACKGROUND .....................................................................................................................................II WASTE MANAGEMENT LICENCING ......................................................................................................II PUBLIC PARTICIPATION ......................................................................................................................III SUMMARY OF IMPACTS ..................................................................................................................... IV CONCLUSION ...................................................................................................................................... V
1. INTRODUCTION ......................................................................................................................... 1
1.1 PROJECT SUMMARY ................................................................................................................. 1 1.2 PURPOSE OF BASIC ASSESSMENT ............................................................................................. 2 1.3 LOCATION AND SITE DESCRIPTION .......................................................................................... 2 1.4 ADMINISTRATIVE INFORMATION .............................................................................................. 6 1.5 EXISTING AUTHORISATIONS .................................................................................................... 7
1.5.1 Existing Environmental Authorisation For Preferred Location ......................................... 7 1.5.2 Existing Environmental Authorisation For Alternative Location ....................................... 9
2. DESCRIPTION OF PROPOSED ACTIVITIES ....................................................................... 11
2.1 PROPOSED FACILITY OPERATIONS ......................................................................................... 11 2.1.1 Introduction ................................................................................................................... 11 2.1.2 Feedstock preparation ................................................................................................... 14 2.1.3 Pyrolysis ........................................................................................................................ 14 2.1.4 Fuel recovery ................................................................................................................. 14 2.1.5 Energy Use .................................................................................................................... 15
2.2 CONSIDERATION OF ALTERNATIVES ...................................................................................... 15 2.2.1 Location Alternatives ..................................................................................................... 16 2.2.2 Process/Technology Alternatives .................................................................................... 17 2.2.3 No-Go Alternative .......................................................................................................... 20 2.2.4 Concluding statement on Selection of Alternatives .......................................................... 20
3. PROJECT NEED AND DESIRABILITY .................................................................................. 21
3.1 WASTE HIERARCHY ............................................................................................................... 21 3.2 ALIGNMENT WITH MUNICIPAL, PROVINCIAL AND NATIONAL DEVELOPMENT STRATEGIES ..... 21
3.2.1 Gauteng Provincial Environmental Management Framework......................................... 21 3.2.2 Gauteng Spatial Development Framework ..................................................................... 22 3.2.3 National Waste Management Strategy ............................................................................ 22 3.2.4 National Development Plan ........................................................................................... 22
3.3 NEED AND DESIRABILITY OF THE ACTIVITY IN THE CONTEXT OF THE PREFERRED LOCATION ... 22
4. LEGAL AND POLICY FRAMEWORK ................................................................................... 23
4.1 CONSTITUTION OF SOUTH AFRICA ......................................................................................... 23 4.2 NATIONAL ENVIRONMENTAL MANAGEMENT ACT (NEMA) ................................................... 23
4.2.1 Duty of Care .................................................................................................................. 23 4.2.2 EIA & Environmental Authorisation ............................................................................... 24
4.3 NATIONAL ENVIRONMENTAL MANAGEMENT: WASTE ACT (ACT 59 OF 2008), AS
AMENDED [NEM:WA] ...................................................................................................................... 25 4.3.1 Definition of Waste ........................................................................................................ 25 4.3.2 Waste Management Licencing ........................................................................................ 25 4.3.3 Waste Classification ....................................................................................................... 28 4.3.4 Waste prohibited from landfill disposal .......................................................................... 29 4.3.5 Norms and Standards for Storage of Waste, 2013 ........................................................... 31 4.3.6 National Norms and Standards for the Sorting, Shredding, Grinding, Crushing, Screening,
Chipping or Baling of General Waste, 2017 .................................................................................. 31 4.3.7 National Waste Information Regulations, 2012............................................................... 31 4.3.8 National Policy on Thermal Treatment of General and Hazardous Waste ....................... 31 4.4.3 National Regulations Regarding Dispersion Modelling GN.R 533 of 2014 ..................... 35
DRAFT BASIC ASSESSMENT REPORT
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EScience Associates (Pty) Ltd Page vii
4.5 NATIONAL WATER ACT (ACT 36 OF 1998) {NWA} ........................................................ 36 4.6 THE NOISE CONTROL REGULATIONS ...................................................................................... 36 4.7 NATIONAL HERITAGE RESOURCES ACT ................................................................................. 37
5. PUBLIC PARTICIPATION ....................................................................................................... 38
5.1 INTRODUCTION ...................................................................................................................... 38 5.2 STAKEHOLDER NOTIFICATION ............................................................................................... 38 5.3 SUMMARY OF ISSUES RAISED BY IAP’S ................................................................................ 38
6. CORRESPONDENCE WITH COMPETENT AUTHORITY .................................................. 39
7. DESCRIPTION OF THE ENVIRONMENT AND POTENTIAL IMPACTS .......................... 40
7.1 LOCATION, LAND-USE AND ZONING ...................................................................................... 40 7.2 BIOPHYSICAL ENVIRONMENT................................................................................................. 43
7.2.1 Climate .......................................................................................................................... 43 7.2.2 Topography ................................................................................................................... 47 7.2.3 Fauna & Flora............................................................................................................... 47
7.3 SITE PHOTOGRAPHS ............................................................................................................... 48 7.3.1 Preferred location .......................................................................................................... 48 7.3.2 Alternative location ........................................................................................................ 51
7.4 SOCIO-ECONOMIC ENVIRONMENT.......................................................................................... 53 7.5 ARCHAEOLOGY, HERITAGE & CULTURE ................................................................................ 53
8. DEFF ONLINE SCREENING TOOL ........................................................................................ 54
8.1 MOTIVATION FOR THE EXCLUSION OF SPECIALIST STUDIES IDENTIFIED BY THE DEFF SCREENING
TOOL 55 8.1.1 Agricultural Impact Assessment ..................................................................................... 55 8.1.2 Landscape/Visual Impact Assessment ............................................................................. 55 8.1.3 Palaeontology Impact Assessment .................................................................................. 55 8.1.4 Terrestrial Biodiversity Impact Assessment .................................................................... 56 8.1.5 Aquatic Biodiversity Impact Assessment ......................................................................... 56 8.1.6 Hydrological Assessment ............................................................................................... 56 8.1.7 Noise Impact Assessment................................................................................................ 56 8.1.8 Traffic Impact Assessment .............................................................................................. 56 8.1.9 Health Impact Assessment .............................................................................................. 57 8.1.10 Socio-Economic Assessment ........................................................................................... 57 8.1.11 Plant Species Assessment ............................................................................................... 57 8.1.12 Animal Species Assessment ............................................................................................ 57
9. SPECIALIST STUDIES ............................................................................................................. 58
9.1 AIR QUALITY IMPACT ASSESSMENT ....................................................................................... 58 9.2 ARCHAEOLOGICAL IMPACT ASSESSMENT .............................................................................. 58
10. METHODOLOGY USED TO DETERMINE IMPACTS ..................................................... 59
10.1 TYPE / NATURE OF IMPACTS ................................................................................................... 59 10.2 DETERMINING SIGNIFICANCE ............................................................................................ 59
10.2.1 Nature............................................................................................................................ 59 10.2.2 Extent ............................................................................................................................ 59 10.2.3 Duration ........................................................................................................................ 59 10.2.4 Intensity ......................................................................................................................... 60 10.2.5 Probability ..................................................................................................................... 60 10.2.6 Mitigation or Enhancement ............................................................................................ 60 10.2.7 REVERSIBILITY ............................................................................................................ 61
10.3 CALCULATING IMPACT SIGNIFICANCE ................................................................................... 61 10.4 UNDERSTANDING IMPACT SIGNIFICANCE ............................................................................... 62
11.1.5 ARCHAEOLOGICAL Impact ......................................................................................... 66 11.2.3 Air Quality ..................................................................................................................... 74 11.3.4 AIR QUALITY – DUST GENERATION .......................................................................... 96
DRAFT BASIC ASSESSMENT REPORT
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EScience Associates (Pty) Ltd Page viii
12. CONCLUSION ........................................................................................................................ 98
12.1 SUMMARY OF ENVIRONMENTAL IMPACTS .............................................................................. 98 12.2 IMPACT MANAGEMENT MEASURES FROM SPECIALIST STUDIES............................................ 100
12.2.1 Air Quality Impact Assessment ..................................................................................... 100 12.2.2 Archaeological Impact Assessment ............................................................................... 100
12.3 CONDITIONAL FINDINGS TO BE INCLUDED AS CONDITIONS OF AUTHORISATION ................. 100 12.4 DESCRIPTION OF ASSUMPTIONS, UNCERTAINTIES AND GAPS IN KNOWLEDGE ........................ 100 12.5 EAP RECOMMENDATION ..................................................................................................... 100
13. DECLARATION BY EAP .................................................................................................... 102
APPENDIX 1: PUBLIC PARTICIPATION DOCUMENTATION ............................................... 103
APPENDIX 1.1 PROOF OF ADVERTISEMENTS .................................................................................... 103 APPENDIX 1.2 PROOF OF SITE NOTICES ........................................................................................... 107 APPENDIX 1.3 INTERESTED AND AFFECTED PARTIES LIST ................................................................ 112 APPENDIX 1.4 PROOF OF DISTRIBUTION OF DRAFT BASIC ASSESSMENT REPORT TO INTERESTED AND
AFFECTED PARTIES ......................................................................................................................... 114 APPENDIX 1.5 COMMENTS FROM I&APS ......................................................................................... 115
APPENDIX 2: CV’S OF EAP.......................................................................................................... 116
APPENDIX 3: AUTHORITY CORRESPONDENCE ................................................................... 117
APPENDIX 3.1: SUMMARY OF PRE-APPLICATION MEETING WITH DEFF ........................................... 118 APPENDIX 3.2: DEFF ACKNOWLEDGEMENT OF RECEIPT OF APPLICATION ....................................... 119
APPENDIX 4: SPECIALIST STUDIES .......................................................................................... 120
APPENDIX 4.1: AIR QUALITY IMPACT ASSESSMENT ......................................................................... 121 APPENDIX 4.2: ARCHAEOLOGICAL AND CULTURAL HERITAGE SCREENING ASSESSMENT ................ 122
APPENDIX 5: ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT...................... 123
DRAFT BASIC ASSESSMENT REPORT
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LIST OF FIGURES Figure 1-1: Proposed site locality ....................................................................................................4 Figure 1-2: Proposed site locality - Zoomed .................................................................................5 Figure 2-1: Process Flow Diagram ................................................................................................ 12 Figure 2-2: Proposed Site Layout.................................................................................................. 13 Figure 2-3: Proposed pyrolysis facility locations ........................................................................ 17 Figure 4-1: Basic Assessment Process .......................................................................................... 27 Figure 7-1 Land cover at the site and surrounding areas ...................................................... 41 Figure 7-2: Surrounding Land Use ................................................................................................ 42 Figure 7-3: Average monthly temperatures and rainfall from Diepsloot AAQM station from
2017 – 2019. .............................................................................................................................. 43 Figure 7-4: Average Wind Roses from 2017-2018 for Diepsloot AAQM station - Annual .. 44 Figure 7-5: Average Wind Roses from 2017-2018 for Diepsloot AAQM station - Summer 45 Figure 7-6: Average Wind Roses from 2017-2018 for Diepsloot AAQM station - Autumn 45 Figure 7-7: Average Wind Roses from 2017-2018 for Diepsloot AAQM station - Winter ... 46 Figure 7-8: Average Wind Roses from 2017-2018 for Diepsloot AAQM station - Spring .... 46 Figure 7-9: Topographical Map .................................................................................................. 47 Figure 7-10: Critical Biodiversity Areas (CBAs) or Ecological Support Areas (ESAs) as per
the Gauteng Conservation Plan 2014 ................................................................................ 48 Figure 7-11: Photograph 1 of preferred location ..................................................................... 49 Figure 7-12: Photograph 2 of preferred location ..................................................................... 49 Figure 7-13: Photograph 3 of preferred location ..................................................................... 50 Figure 7-14: Photograph 4 of preferred location ..................................................................... 50 Figure 7-15: Photograph 1 of alternative location ................................................................... 51 Figure 7-16: Photograph 2 of alternative location ................................................................... 51 Figure 7-17: Photograph 3 of alternative location ................................................................... 52 Figure 7-18: Photograph 4 of alternative location ................................................................... 52 Figure 8-1: Palaeontological sensitivity Map (https://sahris.sahra.org.za/map/palaeo)
.................................................................................................................................................... 56 Figure 10-1: Survey tracklog indicated in red while the green polygons demarcate the
development ........................................................................................................................... 68 Figure 10-2: Various images of the preferred location ........................................................... 69 Figure 10-3: Various images of the alternative development location............................... 70 Figure 10-4: Scenario 1 Predicted PM10 24-Hour maximum modelled ambient
concentration. ......................................................................................................................... 78 Figure 10-5: Scenario 1 Predicted PM2.5 24-Hour maximum modelled ambient
concentration. ......................................................................................................................... 79 Figure 10-6: Scenario 1 Predicted SO2 1-Hour maximum modelled ambient
concentration. ......................................................................................................................... 80 Figure 10-7: Scenario 1 Predicted NO2 1-Hour maximum modelled ambient
concentration. ......................................................................................................................... 81 Figure 10-8: Scenario 1 Predicted Cr(VI) lifetime carcinogenic risk with WHO RfC. ......... 82 Figure 10-9: Scenario 2 Predicted PM10 24-Hour maximum modelled ambient
concentration. ......................................................................................................................... 85 Figure 10-10: Scenario 2 Predicted PM2.5 24-Hour maximum modelled ambient
concentration. ......................................................................................................................... 86 Figure 10-11: Scenario 2 Predicted SO2 1-Hour maximum modelled ambient
concentration. ......................................................................................................................... 87 Figure 10-12: Scenario 2 Predicted NO2 1-Hour maximum modelled ambient
concentration. ......................................................................................................................... 88 Figure 10-13: Scenario 2 Predicted Cr(VI) lifetime carcinogenic risk with WHO RfC. ....... 89
DRAFT BASIC ASSESSMENT REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page x
LIST OF TABLES
Table 1-1: NEM:WA Listed Waste Management Activities as per GN 921:2013....................1 Table 1-2: Property Description .......................................................................................................3 Table 1-3: Name and Address of Applicant ................................................................................6 Table 1-4: Name and Address of Property Owner ......................................................................6 Table 1-5: Details of EAP ...................................................................................................................6 Table 1-6: Details of the EAP Study Team .....................................................................................6 Table 1-7: Details of the Competent Authority ............................................................................6 Table 1-8:Authorised activities for preferred location (ref GAUT 002/ 17-18/E0184) ............7 Table 1-9: Authorised activities for alternative location (ref GAUT 002/ 17-18/E0184) ........9 Table 2-1: Comparison of Emissions Abatement Technology Alternatives......................... 19 Table 4-1: NEMA listed activities (none applicable) ................................................................ 24 Table 4-2: NEM:WA Listed Waste Management Activities as per GN 921:2013................. 26 Table 4-3: Hazard Classes of the SANS 10234 (GHS) Classification System. ........................ 29 Table 4-4: Waste prohibited from landfill disposal (GN 636 of 2013) .................................... 30 Table 4-5: National Ambient Air Quality Standards - GN 1210:2009 .................................... 32 Table 4-6: National Ambient Air Quality Standards for PM2.5 - GN 486:2012 ...................... 33 Table 4-7: GN 893:2013 Subcategory 3.1: Combustion Installations .................................... 34 Table 4-8: GN 893:2013 Subcategory 3.4: Char, Charcoal and Carbon Black
Production ............................................................................................................................... 34 Table 4-9: GN 893:2013 Subcategory 8.1: Thermal Treatment of Hazardous and
General Waste ....................................................................................................................... 34 Table 6-1: Authority Consultation ................................................................................................ 39 Table 7-1: Land use surrounding the site in 500m increments ............................................... 40 Table 7-2: Data availability for AAQM station. ......................................................................... 44 Table 7-3: Wind speed comparison for the Diepsloot AAQM station. ................................. 44 Table 8-1: Environmental sensitivities identified by DEFF Online Screening Tool ................ 54 Table 10-1: Scoring for Significance Criteria ............................................................................. 61 Table 10-2: Final Significance Scoring ........................................................................................ 62 Table 10-3: Impacts on soil and groundwater quality (Construction) ................................. 63 Table 10-4: Noise impacts (Construction) .................................................................................. 64 Table 10-5: Waste generation impact (Construction) ............................................................ 65 Table 10-6: Air Quality – Dust Generation (Construction)....................................................... 66 Table 10-7: Impacts on Groundwater Quality – Waste Storage and Handling (Operation)
.................................................................................................................................................... 71 Table 10-8: Impacts on Soil Quality- – Waste Storage and Handling (Operation) ............ 72 Table 10-9: Noise impacts (Operation) ...................................................................................... 73 Table 10-10: Parameters for Point Sources ................................................................................ 75 Table 10-11: Point Source Maximum Emission Rates (normal operating conditions) ....... 76 Table 10-12: Metals and other pollutants .................................................................................. 84 Table 10-13: Metals and other pollutants .................................................................................. 91 Table 10-14: Waste reduction impact (Operation) ................................................................. 92 Table 10-15: Impacts on Socio-economics (Operation) ........................................................ 92 Table 10-16: Impacts on soil and groundwater quality (Decommissioning) ...................... 93 Table 10-17: Noise impacts (Decommissioning) ....................................................................... 94 Table 10-18: Waste generation impact (Decommissioning) ................................................. 95 Table 10-19: Air Quality – Dust Generation (decommissioning) ............................................ 96 Table 12-1: Impact Summary ....................................................................................................... 99
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ABBREVIATIONS
BAR Basic Assessment Report
CBA Critical Biodiversity Area
CoT City of Tshwane Metropolitan Municipality
DEA Department of Environmental Affairs
DWS Department of Water and Sanitation
EAP Environmental Assessment Practitioner
EIA Environmental Impact Assessment
EIR Environmental Impact Report
EMF Environmental Management Framework
EMPr Environmental Management Programme Report
GHS Globally Harmonised System for the Classification and Labelling of
chemicals
IAPs Interested and Affected Parties
IDP Integrated Development Plan
IPWM Integrated Pollution and Waste Management
MHI Major Hazard Installation
NEMA National Environmental Management Act, Act No. 107 of 1998, as
amended
EIA
Regulations
GN R.982, R.983, 984 and R.985 (4 December 2014), as amended,
promulgated in terms of Section 24(5) read with Section 44, and Sections
24 and 24D of the National Environmental Management Act, 1998
NDP National Development Plan
NEMAQA National Environment Management: Air Quality Act, Act No. 39 of 2004
NEMWA National Environmental Management: Waste Act, Act No. 59 of 2008, as
amended
Nm3 Normal Cubic Metre
NWA National Water Act, Act No. 36 of 1998
NWMS National Waste Management Strategy 2011
OHSA Occupational Health and Safety Act 1993 (Act 85 of 1993)
South African Heritage Resources Agency
SAWIS South African Waste Information system
SDS Safety Data Sheet
DRAFT BASIC ASSESSMENT REPORT
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1. INTRODUCTION
1.1 PROJECT SUMMARY
Industrial Green Energy Solutions (Pty) Ltd (hereinafter referred to as IGE) has appointed
EScience Associates (Pty) Ltd. (hereinafter referred to as EScience), as an independent
Environmental Assessment Practitioner (EAP), to undertake an Environmental Impact
Assessment (EIA) in support of an application for a Waste Management Licence (WML) for
the proposed establishment of a waste pyrolysis facility at the Limeroc Business Park,
Knoppieslaagte 385-Jr, Centurion, Gauteng.
The proposed facility will recover lighter hydrocarbons through thermal treatment of non-
hazardous wastes such as recovered waxes, non-hazardous oils and lubricants and plastics,
in order to produce various organic compounds and fuel blends including but not limited
to naphtha, petrol, diesel, and heavy fuel oil.
Table 1-1 shows the NEMWA Listed Waste Management Activities listed under GN R.921, as
amended, that are applicable to the proposed facility.
Table 1-1: NEM:WA Listed Waste Management Activities as per GN 921:2013
Applicable ‘Category A’ (Basic Assessment) Activities
Category A
– Activity (3)
The recycling of general waste at a facility that has an operational area
in excess of 500m2, excluding recycling that takes place as an integral
part of an internal manufacturing process within the same premises.
Reason: Recycling of up to 40 tons/day general waste (wax and plastics)
to produce fuels
Category A -
Activity (5)
The recovery of waste including the refining, utilisation, or co- processing
of waste in excess of 10 tons but less than 100 tons of general waste per
day or in excess of 500kg but less than 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: Recovery of up to 40 tons/day general waste (wax and plastics)
to produce fuels
Category A
– Activity (6)
The storage of general waste at a facility that has the capacity to store
in excess of 100m3 of general waste at any one time, excluding the
storage of waste in lagoons or temporary storage of such waste.
Reason: Potential for waste to be stored longer than 90 days.
Category A
– Activity
(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).
With the activities being listed in Category A, the process of applying for a WML requires the
conduct Basic Assessment as per the EIA Regulations. The competent authority in this
respect is the Department of Environment, Forestry and Fisheries (DEFF).
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1.2 PURPOSE OF BASIC ASSESSMENT
The operation of the proposed activity 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 59 of 2008, as amended) {NEMWA}, as well as an
Atmospheric Emissions Licence in terms of the National Environmental Air Quality Act
(NEMAQA) {Act 39 of 2004, as amended}. As a result, a Basic Assessment process must be
undertaken to inform the application for these licences. These and other environmental
legal requirements are detailed in section 0 of this report.
The objective of the environmental impact assessment process is to, through a consultative
process—
a) determine the policy and legislative context within which the activity is located and
document how the proposed activity complies with and responds to the policy and
legislative context;
b) describe the need and desirability of the proposed activity, including the need and
desirability of the activity in the context of the development footprint on the
approved site;
c) identify the location of the development footprint based on an impact and risk
assessment process inclusive of cumulative impacts and a ranking process of all the
identified development footprint alternatives focusing on the geographical,
physical, biological, social, economic, heritage and cultural aspects of the
environment;
d) determine the—
a. nature, significance, consequence, extent, duration and probability of the
impacts occurring to inform identified preferred alternatives; and
b. degree to which these impacts—
i. can be reversed;
ii. may cause irreplaceable loss of resources, and
iii. can be avoided, managed or mitigated;
e) identify the most ideal location for the activity based on the lowest level of
environmental sensitivity identified during the assessment;
f) identify, assess, and rank the impacts the activity will have through the life of the
activity;
g) identify suitable measures to avoid, manage or mitigate identified impacts; and
h) identify residual risks that need to be managed and monitored
1.3 LOCATION AND SITE DESCRIPTION
The proposed facility will be located in the Limeroc Business Park, Knoppieslaagte 385-Jr,
Centurion within the City of Tshwane Metropolitan Municipality. The business park is
accessed from the R114 and is immediately surrounded by residential and commercial
activities as well as grassland/shrubland. The closest residential area is an informal
settlement located 10m west of the property boundary. Refer to Figure 1-1 and Figure 1-2
for maps showing the location of the facility.
The site falls within Ward 106 of the City of Tshwane Metropolitan Municipality.
Two locations within the Limeroc Business Park are being considered:
• Preferred Alternative:
o Portion 111 of Farm No. 385 Knopjeslaagte
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• Alternative Location:
o Portion 109 of Farm No. 385 Knopjeslaagte
o Portion 331 of Farm No. 385 Knopjeslaagte
Refer to Table 1-2 for details on the properties.
Table 1-2: Property Description
Province Municipality Ward
No.
Erf Number SG 21 Key
Preferred Location
Gauteng
City of
Tshwane
Metropolitan
Municipality
106
Portion 111 of Farm No.
385 Knopjeslaagte
T0JR00000000038500111
Alternative Location
Portion 109 of Farm No.
385 Knopjeslaagte
T0JR00000000038500109
Portion 331 of Farm No.
385 Knopjeslaagte
T0JR00000000038500331
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Figure 1-1: Proposed site locality
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Figure 1-2: Proposed site locality - Zoomed
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1.4 ADMINISTRATIVE INFORMATION
The following section and associated set of tables, provides pertinent administrative
information pertaining to Transnet, as well as the environmental assessment practitioner
who developed the Basic Assessment report (Table 1-3 to Table 1-6).
Table 1-3: Name and Address of Applicant
Applicant Industrial Green Energy Solutions (Pty) Ltd
Physical Address 8 Summit Road, Timsrand, Centurion, 2196
Telephone 012 940 3471
Table 1-4: Name and Address of Property Owner
Applicant NAPAJ Property Investment and Development (Pty) Ltd
Physical Address Icon Industrial Park, Baralong Street, Sunderland Ridge,
Pretoria
Telephone 021 161 0888
Table 1-5: Details of EAP
Name of Company EScience Associates (Pty) Ltd.
Lead EAP Mr. Abdul Ebrahim
Contact Person Mr. Sam Leyde
Postal Address PO Box 2950, Saxonwold, Johannesburg, South Africa
2132
Physical Address 9 Victoria Street, Oaklands, Johannesburg, South Africa,
2192
Telephone +27 11 718 6380
Fax 0866 106 703
Email sam@escience.co.za
Qualifications BSc Honours Mechanical Engineering
Curriculum Vitae Refer Appendix 2
The study team is led by Mr. A. Ebrahim, senior environmental engineer with more than
20 years’ experience in environmental management. Brief details of the key consultants
are shown in Table 1-6. Detailed curricula vitae are attached as Appendix 2.
Table 1-6: Details of the EAP Study Team
Name Qualifications and Professional Affiliations Experience
Abdul Ebrahim
BEng (Hons) Environmental Engineering
Certified EAP
Member of the Engineering Council of South Africa
20 years
Sam Leyde BSc (Hons) Mechanical Engineering 7 Years
Tiffany Seema BSc (Hons) Archaeology
BSc Geography and Geology
4 Years
Table 1-7: Details of the Competent Authority
Name National Department of Environment, Forestry and Fisheries
Physical Address 473, Steve Biko Rd & Soutpansberg Rd, Arcadia, Pretoria, 0083
Postal Address Private Bag X447, Pretoria, 0001, South Africa
Telephone 086 111 2468
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1.5 EXISTING AUTHORISATIONS
There are two existing environmental authorisations (EAs) each covering part of the
Limeroc Business Park that were obtained prior to the development of the business park
as detailed in the following sections. The EAs were issued by the Gauteng Department
of Agriculture and Rural Development.
1.5.1 EXISTING ENVIRONMENTAL AUTHORISATION FOR PREFERRED LOCATION
EA with reference number GAUT 002/ 17-18/E0184, obtained on 3rd May 2018, applicable
to portion 111 of the farm Knopjeslaagte 385 JR to undertake the activities shown in Table
1-8.
Table 1-8:Authorised activities for preferred location (ref GAUT 002/ 17-18/E0184)
Activity
number Activity Description
Geographical areas
based on
environmental
attributes
Listing Notice 1
9
The development of infrastructure exceeding 1 000 metres in
length for the bulk transportation of water or storm water—
(i) with an internal diameter of 0,36 metres or more; or
(ii) with a peak throughput of 120 litres per second or more;
N/A
10
The development and related operation of infrastructure
exceeding 1 000 metres in length for the bulk transportation of
sewage, effluent, process water, waste water, return water,
industrial discharge or slimes –
(i) with an internal diameter of 0,36 metres or more; or
(ii) with a peak throughput of 120 litres per second or more;
N/A
11
The development of facilities or infrastructure for the
transmission and distribution of electricity—
(i) outside urban areas or industrial complexes with a capacity
of more than 33 but less than 275 kilovolts; or
(ii) inside urban areas or industrial complexes with a capacity of
275 kilovolts or more;
N/A
12
The development of—
(i) dams or weirs, where the dam or weir, including infrastructure
and water surface area, exceeds 100 square metres; or
(ii) infrastructure or structures with a physical footprint of 100
square metres or more;
where such development occurs—
(a) within a watercourse;
(b) …
excluding—
(aa) …
(bb) …
(cc) activities listed in activity 14 in Listing Notice 2 of 2014 or
activity 14 in Listing Notice 3 of 2014, in which case that activity
applies;
(dd) where such development occurs within an urban area;
N/A
19
The infilling or depositing of any material of more than 10 cubic
metres into, or the dredging, excavation, removal or moving of
soil, sand, shells, shell grit, pebbles or rock of more than 10 cubic
metres from a watercourse;
N/A
27
The clearance of an area of 1 hectares or more, but less than
20 hectares of indigenous vegetation, except where such
clearance of indigenous vegetation is required for…
N/A
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Table 1-8:Authorised activities for preferred location (ref GAUT 002/ 17-18/E0184)
Activity
number Activity Description
Geographical areas
based on
environmental
attributes
28
Residential, mixed, retail, commercial, industrial or institutional
developments where such land was used for agriculture, game
farming, equestrian purposes or afforestation on or after 01 April
1998 and where such development:
(i) will occur inside an urban area, where the total land to be
developed is bigger than 5 hectares; or
(ii) will occur outside an urban area, where the total land to be
developed is bigger than 1 hectare;
excluding where such land has already been developed for
residential, mixed, retail, commercial, industrial or institutional
purposes.
N/A
Listing Notice 3
3.
The development of masts or towers of any material or type
used for telecommunication broadcasting or radio transmission
purposes where the mast or tower—
(a) is to be placed on a site not previously used for this purpose;
and (b) will exceed 15metres in height— but excluding
attachments to existing buildings and masts on rooftops.
c. Gauteng
ii. National Protected
Area Expansion
Strategy Focus Areas;
12.
The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of
indigenous vegetation is required for maintenance purposes
undertaken in accordance with a Maintenance management
plan.
c. Gauteng
ii. Within Critical
Biodiversity Areas or
Ecological Support
Areas identified in the
Gauteng
Conservation Plan or
bioregional plans; or
14.
The development of -
(ii) channels exceeding 10 square metres in size;
c. Gauteng
iv. Sites identified as
Critical Biodiversity
Areas (CBAs) or
Ecological Support
Areas (ESAs) in the
Gauteng
Conservation Plan or
in bioregional plans;
The specialist studies that were undertaken as part of this application for Environmental
Authorisation included:
• Fauna Habitat Assessment
• Vegetation Survey
• Addendum to the Ecological Habitat Assessment
• Geotechnical Report
• Wetland Assessment
• Heritage Impact Assessment
• Service Report
• Traffic Impact Study
• Storm Water Management Report
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1.5.2 EXISTING ENVIRONMENTAL AUTHORISATION FOR ALTERNATIVE LOCATION
EA with reference number GAUT 002/16-17/E0218, obtained on 7th July 2017, applicable
to portions 105, 109 and 331 of the farm Knopjeslaagte 385 JR to undertake the activities
shown in Table 1-9
Table 1-9: Authorised activities for alternative location (ref GAUT 002/ 17-18/E0184)
Activity
number Activity Description
Geographical areas
based on
environmental
attributes
Listing Notice 1
9
The development of infrastructure exceeding 1 000 metres in
length for the bulk transportation of water or storm water—
(i) with an internal diameter of 0,36 metres or more; or
(ii) with a peak throughput of 120 litres per second or more;
N/A
10
The development and related operation of infrastructure
exceeding 1 000 metres in length for the bulk transportation of
sewage, effluent, process water, waste water, return water,
industrial discharge or slimes –
(i) with an internal diameter of 0,36 metres or more; or
(ii) with a peak throughput of 120 litres per second or more;
N/A
27
The clearance of an area of 1 hectares or more, but less than
20 hectares of indigenous vegetation, except where such
clearance of indigenous vegetation is required for…
N/A
28
Residential, mixed, retail, commercial, industrial or institutional
developments where such land was used for agriculture,
game farming, equestrian purposes or afforestation on or after
01 April 1998 and where such development:
(i) will occur inside an urban area, where the total land to be
developed is bigger than 5 hectares; or
(ii) will occur outside an urban area, where the total land to
be developed is bigger than 1 hectare;
excluding where such land has already been developed for
residential, mixed, retail, commercial, industrial or institutional
purposes.
N/A
Listing Notice 3
4
The development of a road wider than 4 metres with a reserve
less than 13, 5 metres.
c. Gauteng
iv. Sites identified as
Critical Biodiversity
Areas (CBAs) or
Ecological Support
Areas (ESAs) in the
Gauteng
Conservation Plan or
in bioregional plans;
12.
The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of
indigenous vegetation is required for maintenance purposes
undertaken in accordance with a Maintenance
management plan.
c. Gauteng
ii. Within Critical
Biodiversity Areas or
Ecological Support
Areas identified in the
Gauteng
Conservation Plan or
bioregional plans; or
The specialist studies that were undertaken as part of this application for Environmental
Authorisation included:
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• Fauna and Flora Habitat Assessment
• Geotechnical Report
• Services Report
• Traffic impact Study
• Heritage Impact Assessment
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2. DESCRIPTION OF PROPOSED ACTIVITIES
2.1 PROPOSED FACILITY OPERATIONS
2.1.1 INTRODUCTION
The primary intent of the proposed plant is to recover lighter hydrocarbons through
thermal treatment of non-hazardous wastes such as recovered waxes, non-hazardous
oils and lubricants and plastics, in order to produce various organic compounds and fuel
blends including but not limited to naphtha, petrol, diesel, and heavy fuel oil.
Objectives
The main targets of this project are to:
• Reduce waste to landfill to extend the landfill site air space life.
• Divert solid waste from landfill to productive utilization.
• Reduce fossil fuel dependency through the production of waste derived fuel
and energy.
Refer to Refer to Figure 2-1 for a process flow diagram and Figure 2-2 for the proposed
site layout.
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Figure 2-1: Process Flow Diagram
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Figure 2-2: Proposed Site Layout
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2.1.2 FEEDSTOCK PREPARATION
A combination of hydrocarbons, waxes and plastic waste (feedstock) will be delivered to
site via road and stored onsite prior to preparation and processing. The waste will be
received in bags if solid or in flow bins if liquid.
The solid feedstock is to be fed into a mill where the size of the feedstock will be reduced
to below 5mm average particle diameter. It is anticipated that there may be blending
and/or homogenisation of the material to optimise further processing and products.
2.1.3 PYROLYSIS
2.1.3.1 Pyrolysis feeding arrangement
The pyrolysis process requires an atmosphere devoid of oxygen. The feed material is to be
introduced into the pyrolysis unit by means of two isolation valves where one of the two
valves is always closed to preserve the oxygen free atmosphere. A continuous nitrogen
purge between the valves further reduces the likelihood of oxygen entering the system.
Liquid feed will be fed with a slurry pump into the pyrolysis reactor.
2.1.3.2 Pyrolysis unit
A single pyrolysis reactor (a horizontal kiln)will be installed. It will convert the feed material
through various thermochemical reactions into a vapour product containing liquid (oil) and
gas (syngas) fractions, and a solid product (residue/char). The pyrolizer is heated externally
by combustion of LPG, syngas or solid residue from the pyrolysis process. The actual
conversion takes place inside the reactor, in the absence of oxygen, thus preventing
combustion of the feed material from taking place and allowing for production of higher
calorific value gas at the exit. The vapour exhaust temperature is between 500°C and
700°C.
The vapour discharge is separated from the residue product (char) in a dropout box and a
settling chamber.
2.1.3.3 Pyrolysis char combustion/Vitrification furnace
The solid products of pyrolysis as well as any waste oils are to be sent to a
combustion/vitrification furnace where energy is recovered through combustion to provide
energy to the pyrolysis unit. The unit is run at a high temperature (~1300°C) whereby the
oxidised char will fuse to form a slag which can then be quenched into a glass like
substance in a process called vitrification. Alternatively, the furnace is operated at a lower
temperature such that the oxidised char remains as a free flowing solid. Any excess
combustion gases not used by the pyrolysis unit, as well as the exhaust gases from the
pyrolysis unit heating chamber are sent to the waste heat recovery boiler.
2.1.4 FUEL RECOVERY
2.1.4.1 Exhaust gas cooler
The superheated vapour product from the pyrolysis unit will pass through a heat exchanger
which cools the vapour to 350°C which prepares it for condensing in the diesel condenser.
The cooling medium used is atmospheric air, whereby the heat exchanger is used as a
preheater for this air before it is used for combustion to provide heat to the pyrolysis reactor,
thus improving efficiency.
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2.1.4.2 Diesel condensing tower
The vapour enters the diesel condenser tower at 350°C and is cooled down to 120°C on the
outlet by circulating the condensed and cooled diesel to the top of the tower. The diesel is
then filtered and cooled before sending it to the intermediate storage tanks for quality
control.
2.1.4.3 Naphtha/water condensing tower
The lower boiling point hydrocarbons, as well as any water, are then cooled down to
approximately 40°C in a second scrubbing tower utilising the cooled condensed naphtha
stream as scrubbing liquid. Water and naphtha are separated in a gravity settler and any
water recovered is used as cooling medium of the solid waste.
2.1.4.4 Gas handling
The remaining non-condensable portion of the pyrolysis gas is transferred to a gas bladder
by using a booster fan. The gas bladder allows for the gas to homogenise and allows for
minor process upsets which result in changes in gas production. A booster fan on the outlet
of the gas bladder is used to convey the gas to the burners on the pyrolysis unit.
2.1.4.5 Electricity Generation
Steam generated by the waste heat recovery boiler and combustion of excess cleaned
gas may be used to drive a turbine or organic Rankine cycle process to produce electricity.
If conducted this will be less than 10MW and thus will not require Environmental
Authorisation.
2.1.5 ENERGY USE
All feedstock is to be processed in an enclosed and sealed reactor allowing contaminants
to be efficiently captured and disposed of in ash collectors or through water scrubbing
processes. Pollutants are not to be released into the atmosphere in this process, as they
would be in a combustion-centric process.
Water used in the process will be supplied from municipal services and no industrial effluent
of significance is anticipated.
Measures within buildings and with other associated machinery to reduce energy usage
include:
• Machinery will be started sequentially and ramped up to minimise peak demand at
start up.
• Variable speed drives will be used wherever practical for controlling feed and flow
rates.
• Use of natural lighting will be optimized where practical.
• Low energy lighting will be used.
• Electricity and fuel usage will be monitored and discussed at management meetings
to ensure that energy usage is optimized and reduced where practical.
2.2 CONSIDERATION OF ALTERNATIVES
The requirement for consideration of development alternatives were introduced into South
Africa’s environmental legislation to encourage developers 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
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negative environmental impacts and to increase or introduce positive environmental
impacts.
According to the EIA regulations, alternatives in relation to a proposed activity, means
different means of meeting the general purpose and requirements of the activity, which
may include alternatives to the:
a) property on which or location where the activity is proposed to be undertaken;
b) type of activity to be undertaken;
c) design or layout of the activity;
d) technology to be used in the activity; or
e) operational aspects of the activity;
and includes the option of not implementing the activity;
Typical factors to be considered in deriving and evaluating alternatives include:
• environmental impact
• technical feasibility
• financial feasibility
• socio-economic impact
• land use planning
• future expansion of the operations
• logistical constraints – power, water, raw materials, labour, market, etc.
The EIA process must contain a range of alternatives developed to fulfil the purpose and
goal/s of the proposed project. Accordingly, all feasible alternatives, particularly as it relates
to different treatment, recycling, and recovery technologies relevant to the proposed
activities, have been subject to a detailed process of detailed impact analysis.
2.2.1 LOCATION ALTERNATIVES
The proposed facility will be located within the already established Limeroc Business Park.
There are two main location alternatives being considered within the existing business park
as illustrated in Figure 2-3 below.
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Figure 2-3: Proposed pyrolysis facility locations
Both the alternatives are zoned Industrial 1 in terms of the Tshwane town-planning scheme.
The preferred location was selected due to the following factors:
• It is located further from the residential area on the west of the Limreoc Business Park
• The available footprint for development is larger than that of the alternative location.
2.2.2 PROCESS/TECHNOLOGY ALTERNATIVES
2.2.2.1 Thermal Waste to Energy Alternatives
Other waste to energy technologies for this type of application include:
• Incineration
• Plasma arc gasification
• Gasification
However, these technologies have not been considered further as they are not applicable
to the primary purpose of the proposed facility which is the recovery of liquid fuels from the
waste.
2.2.2.2 Emissions Abatement Technology Alternatives
Alternative mitigation measures to mitigate potential emissions that will occur from the
pyrolysis process that were considered include a scrubber, bag filters and electrostatic
precipitators.
In order to assess the feasibility of each emissions abatement technology a selection matrix
(Table 2-1) was produced based on:
1. Design and operating constraints
2. Capital and running cost considerations
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3. Environmental impacts
The signs in the adjacent columns, for each alternative, indicate whether the outcome is
positive or negative for each aspect/criterion considered:
+ indicates a net benefit or significant advantage over the other alternatives
- indicates a net deterioration or significant disadvantage relative to the other
alternatives
… No sign implies neutrality.
A cumulative sum at the bottom of the table indicates the net outcome of all
considerations.
As shown in Table 2-1 the outcome of the emissions abatement technology selection matrix
is that a wet scrubber is the most desirable technology.
This is mainly due to the following:
• A wet scrubber comes at a lower capital and operational cost than the bag filter
and electrostatic precipitator;
• The wet scrubber provides soluble gas abatement and particulate removal whereas
the bag filter and electrostatic precipitator only provide particulate removal.
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Table 2-1: Comparison of Emissions Abatement Technology Alternatives
ITEM Bag Filter Electrostatic Precipitator Wet Scrubber
Design & Operation Constraints
Maintenance requirements High - High - High -
Specialist Skills – Operation and
maintenance
Skilled - Skilled - Skilled -
Construction time 3 to 6 months 3 to 6 months 3 to 6 months
-2 -2 -2
Capital & Running Cost Considerations
Capital Costs High - High - Medium
Operational Costs Medium Medium Low +
-1 -1 +1
Environmental Aspects
Particulate Collection Efficiency High + High + High +
Soluble gas abatement none - none - High +
Waste Generated Fly Ash - Fly Ash - Scrubber Sludge -
Water use None + None + Medium
Pollutant emissions Emissions Limits must be
met
Emissions Limits must be
met
Emissions Limits must be
met
0 0 +1
Outcome -3 -3 0
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2.2.3 NO-GO ALTERNATIVE
The no-go option refers to the alternative of the proposed project not going ahead at all.
The baseline status quo would be maintained in this case, which would result the continued
disposal of waste to landfill, as well as perpetuate continued reliance on fossil fuels.
The proposed facility aims to remove waste from municipal waste streams, and
subsequently from landfills, through thermally converting waste to fuel and energy. Plastic
waste is not biodegradable thus leading to overflowing landfills and the increased chance
of plastic litter in drains and water bodies. In this respect the no-go alternative would
contribute more to city and marine litter than the alternative of the facility being
established.
Considering that the negative impacts of the proposed facility are low and negligible, and
there are some positive impacts the no-go alternative is deemed an undesirable
alternative.
It must be noted that the proposed location for the site is zoned for industrial use. Therefore,
the refusal of this application would most likely result in the site being used by another
industrial activity in the future (whether or not by this proponent) due to its location, zoning
and access to established industrial services such as water supply, roads, electrical supply,
sewage and other infrastructure. The environmental impact of this future activity cannot be
predicted.
2.2.4 CONCLUDING STATEMENT ON SELECTION OF ALTERNATIVES
The preferred location of the proposed activities was selected due to its size and distance
from the nearest residential areas.
As shown in Table 2-1 the outcome of the emissions abatement technology selection matrix
is that a wet scrubber is the most desirable technology.
This is mainly due to the following:
• A wet scrubber comes at a lower capital and operational cost than the bag filter
and electrostatic precipitator;
• The wet scrubber provides soluble gas abatement and particulate removal whereas
the bag filter and electrostatic precipitator only provide particulate removal.
The no-go alternative is undesirable as it would:
• Perpetuate continued reliance on virgin fossil fuels
• Result in the continued disposal of waste to landfill rather than the recovery of fuel
from said waste
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3. PROJECT NEED AND DESIRABILITY
The primary intent of the proposed plant is to recover lighter hydrocarbons through thermal
treatment of non-hazardous wastes such as recovered waxes, non-hazardous oils and
lubricants and plastics, in order to produce various organic compounds and fuel blends
including but not limited to naphtha, petrol, diesel, and heavy fuel oil.
The main targets of this project are to:
• Reduce waste to landfill to extend the landfill site air space life.
• Divert solid waste from landfill to productive utilization.
• Reduce fossil fuel dependency through the production of waste derived fuel and
energy.
3.1 WASTE HIERARCHY
The proposed project is in line with the national waste management strategy and the
promotion of the waste hierarchy through the recovery of waste and subsequent reduction
of waste being disposed of to landfill. The establishment of the pyrolysis plant will effectively
result in:
• Recovery of waste where such materials might otherwise be disposed of
• Recovery lighter hydrocarbons from non-hazardous wastes through thermal
treatment of non-hazardous wastes
• Reduction of solid waste being disposed of to landfill
The Project is aligned with Goal 1 of the National Waste Management Strategy:
• Goal 1: to Promote waste minimisation, reuse, recycling, and recovery of waste.
3.2 ALIGNMENT WITH MUNICIPAL, PROVINCIAL AND NATIONAL
DEVELOPMENT STRATEGIES
3.2.1 GAUTENG PROVINCIAL ENVIRONMENTAL MANAGEMENT FRAMEWORK
The Gauteng Provincial Environmental Management Framework is a legal instrument in
terms of the Environmental Management Framework Regulations, 2010. The regulations are
designed to assist environmental impact management including EIA processes, spatial
planning and sustainable development.
The proposed site is located within Gauteng Environmental Management Framework Zone
1 (Urban development zone) and is therefore aligned with the desired development type
for the area.
The objectives of the policy that are in alignment with the proposed project include:
• To facilitate the optimal use of current industrial, mining land and other suitable
derelict land for the development of non-polluting industrial and large commercial
developments.
• To protect Critical Biodiversity Areas (CBAs) within urban and rural environments.
• To focus on the sustainability of development through the implementation of
initiatives such as:
o Waste minimisation, reuse and recycling
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3.2.2 GAUTENG SPATIAL DEVELOPMENT FRAMEWORK
According to the Gauteng Spatial Development Framework, Gauteng generates
approximately 42% of the countries waste and as the majority of landfills in the City of
Johannesburg and City of Tshwane have less than ten years lifespans, alternate measures
to increase this lifespan are encouraged.
Although this project on its own will not make a significant impact to the lifespan of landfills
in the city, it still serves as a sustainable waste-to-energy facility with a low emissions footprint
that allows for flexible feedstock specifications.
3.2.3 NATIONAL WASTE MANAGEMENT STRATEGY
The National Waste Management Strategy 2011(NWMS), is a legislative requirement of the
National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) as amended.
The purpose of the NWMS is to achieve the objects of the Waste Act. Organs of state and
affected persons are obliged to give effect to the NWMS.
The project is aligned with goal 1 of the National Waste Management Strategy:
• Goal 1: to Promote waste minimisation, reuse, recycling and recovery of waste.
3.2.4 NATIONAL DEVELOPMENT PLAN
Primary objectives of the NDP include building environmental sustainability and resilience
and relevant to this proposed project is the reduction of greenhouse gas emissions and
improvement of energy efficiency. Chapter 5 of the NDP, Environmental Sustainability and
Resilience, includes the following objectives which are supported by this project:
• Achieve the peak, plateau and decline trajectory for greenhouse gas emissions, with
the peak being reached around 2025.
• Absolute reductions in the total volume of waste disposed to landfill each year.
3.3 NEED AND DESIRABILITY OF THE ACTIVITY IN THE CONTEXT OF THE
PREFERRED LOCATION
The preferred location on which the proposed facility is to be located is zoned Industrial 1
in terms of the Tshwane town-planning scheme. Rezoning of the property would therefore
not be required as the proposed site location and facility is aligned with the desired
development type for the area.
The proposed site is located within Gauteng Environmental Management Framework Zone
1 (Urban development zone) and is therefore aligned with the desired development type
for the area.
As detailed in section 1.5, the Limeroc Business Park owners have obtained the necessary
environmental authorisations from the Gauteng Department of Agriculture and Rural
Development for the clearance of this land, amongst other activities detailed in Table 1-8
and Table 1-9.
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4. LEGAL AND POLICY FRAMEWORK
The following section is intended to provide an overview of legislation and associated
regulatory requirements that are applicable to this Basic Assessment process.
4.1 CONSTITUTION OF SOUTH AFRICA
Section 24 of the Constitution provides the following rights:
“Everyone has the right -
a. to an environment that is not harmful to their health or well-being; and
b. to have the environment protected, for the benefit of present and future
generations, through reasonable legislative and other measures that -
i. prevent pollution and ecological degradation;
ii. promote conservation; and
secure ecologically sustainable development and use of natural resources while
promoting justifiable economic and social development.”
Accordingly, legislative measures as summarised in ensuing sections have been
promulgated.
4.2 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.
4.2.1 DUTY OF CARE
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 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;
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(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, City of Johannesburg Metropolitan
Municipality 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.
4.2.2 EIA & ENVIRONMENTAL AUTHORISATION
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 (EA) 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 EIA Regulations (GN R.982, GN R. 983, GN R. 984 and GN R.
985; 4 December 2014, as amended by GN R.324, GN .R325, GN R.326 and GN R.327 of 2017
respectively). Based on the potential significance of impacts, the Regulations identify
specific activities that are either subject to a Basic Assessment process or Scoping and EIA
process.
Based on the potential significance of impacts, the Regulations identify specific activities
that are either subject to a Basic Assessment process, or Scoping and EIA process. The
proposed project does not include any of these listings. Notably the need for an
atmospheric emissions license would trigger Activity 6 of Listing Notice 2 as detailed in Table
4-1 below, but this specifically excludes activities where a Waste Management Licence is
required.
Table 4-1: NEMA listed activities (none applicable)
GN R.984 – Listing Notice 2
Activity No.6 The development of facilities or infrastructure for any process or activity
which requires a permit or licence or an amended permit or licence in
terms of national or provincial legislation governing the generation or
release of emissions, pollution or effluent, excluding—
(i) activities which are identified and included in Listing Notice 1 of
2014;
(ii) activities which are 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 the National Environmental Management:
Waste Act, 2008 applies;
(iii) the development of facilities or infrastructure for the treatment of
effluent, polluted water, wastewater or sewage where such
facilities have a daily throughput capacity of 2 000 cubic metres
or less; or
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Table 4-1: NEMA listed activities (none applicable)
GN R.984 – Listing Notice 2
(iv) where the development is directly related to aquaculture
facilities or infrastructure where the wastewater discharge
capacity will not exceed 50 cubic metres per day.
Not applicable - Reason: The proposed activities will require an
Atmospheric Emissions Licence, however this activity is excluded due to
the requirement for a Waste Management Licence for the proposed
development.
4.3 NATIONAL ENVIRONMENTAL MANAGEMENT: WASTE ACT (ACT 59 OF
2008), AS AMENDED [NEM:WA]
The NEM:WA 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.
4.3.1 DEFINITION OF WASTE
NEM:WA defines ‘waste’ as:
a) any substance, material or object, that is unwanted, rejected, abandoned,
discarded or disposed of, or that is intended or required to be discarded or disposed
of, by the holder of that substance, material or object, whether or not such
substance, material or object can be re-used, recycled or recovered and includes
all wastes as defined in Schedule 3 to this Act; or
b) any other substance, material or object that is not included in Schedule 3 that may
be defined as a waste by the Minister by notice in the Gazette,
but any waste or portion of waste, referred to in paragraphs (a) and (b), ceases to be a
waste-
i. once an application for its re-use, recycling or recovery has been approved or,
after such approval, once it is, or has been re-used, recycled or recovered;
ii. where approval is not required, once a waste is, or has been re-used, recycled
or recovered;
iii. where the Minister has, in terms of section 74, exempted any waste or a portion
of waste generated by a particular process from the definition of waste; or
iv. where the Minister has, in the prescribed manner, excluded any waste stream or
a portion of a waste stream from the definition of waste.
4.3.2 WASTE MANAGEMENT LICENCING
According to section 19(1) and 19(3) of the NEMWA, 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
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conduct these activities. Under these provisions, a list of ‘Category A’, and ‘Category B’
and subsequently ‘Category C’ waste management activities were first published, in GN
718 of 3 July 2009, with subsequent amendments, including General Notice No: 921 on 29
November 2013, and subsequent amendments thereto as well. The latest amendment
being GN 1094 at the time of submission of this application. Category A and B activities
require a Waste Management Licence in terms of section 20(b) of NEMWA, whereas
Category C activities require that the person conducting these activities complies with the
relevant requirements or standards as stated in GN. R.921, as amended.
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. Activities listed under category C do not
require a Basic Assessment or Scoping and EIA. The licensing process for waste
management activities and the supporting information required is therefore the same as for
activities listed in the EIA listing notices that require an Environmental Authorisation.
Table 4-2 shows the NEMWA Listed Waste Management Activities listed under GN R.921, as
amended, that are applicable to the proposed facility.
Table 4-2: NEM:WA Listed Waste Management Activities as per GN 921:2013
Applicable ‘Category A’ (Basic Assessment) Activities
Category A
– Activity (3)
The recycling of general waste at a facility that has an operational area
in excess of 500m2, excluding recycling that takes place as an integral
part of an internal manufacturing process within the same premises.
Reason: Recycling of up to 40 tons/day general waste to produce fuels
Category A -
Activity (5)
The recovery of waste including the refining, utilisation, or co- processing
of waste in excess of 10 tons but less than 100 tons of general waste per
day or in excess of 500kg but less than 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: Recovery of up to 40 tons/day general waste to produce fuels
Category A
– Activity (6)
The treatment of general waste using any form of treatment at a facility
that has the capacity to process in excess of 10 tons but less than 100
tons.
Reason: Treatment of up to 40 tons/day general waste to produce fuels
Category A
– Activity
(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).
With the activities being listed in Category A, the process of applying for a WML requires the
conduct Basic Assessment as per the EIA Regulations. The competent authority in this
respect is the National Department of Environment, Forestry and Fisheries (DEFF) due to the
fact that this is a waste to energy project.
Figure 4-1 gives a diagrammatic representation of the Basic Assessment process.
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Figure 4-1: Basic Assessment Process
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4.3.3 WASTE CLASSIFICATION
Waste must be classified, in order to determine the risk associated with its handling and
disposal, such that these may be appropriately managed. In terms of NEMWA Waste
Classification and Management Regulations GN 634:2013:
• 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 and includes hazardous substances, materials or objects within business
waste, residue deposits and residue stockpiles…”;
• 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 and which include (a) discarded concrete,
bricks, tiles and ceramics; (b) discarded glass; (c) discarded soil, stones and dredging
spoil”.
In order to determine whether waste is hazardous, general or inert waste it must be
classified.
The NEMWA Waste Classification and Management Regulations GN 634:2013 were
promulgated on 23 August 2013 promulgated on 23 August 2013. The regulations:
• Regulate the classification and management of waste
• Prescribe requirements for the disposal of waste to land
• Prescribe requirements and timeframes for the management of certain wastes
• Prescribe general duties of waste generators, transporters, and managers.
• Establish a mechanism and procedure for the listing of waste management
activities that do not require a Waste Management Licence
Regulation 4 (2) requires that waste be classified according to the provisions of SANS 10234
(GHS – Globally Harmonised System for the Classification and Labelling of chemicals) within
180 days of the generation thereof. This excludes pre-classified wastes specified under
Annexure 1 thereto. Regulation 4(4) requires that waste be reclassified every 5 years, or
within 30 days of a significant change to the processes or raw materials used to generate
the waste.
SANS 10234 sets out a comprehensive classification system to determine whether a waste is
hazardous based on the nature of its physical, health and environmental hazardous
properties.
The SANS 10234 standard covers the harmonized criteria for the classification of hazardous
substances and mixtures, including waste, for their safe transport, use at the workplace or
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in the home, according to their health, environmental and physical hazards. It also
stipulates the harmonized communication elements for labelling and Safety Data Sheets
(SDS). The standard accordingly provides detail on classification criteria (including tests
methods, often with reference to SANS 10228, labelling, hazard identification symbols
(pictograms), packaging and the minimum information required for a Safety Data Sheet
(SDS).
Classification in terms of SANS 10234 means establishing whether a waste is hazardous
based on the nature of its intrinsic physical, health and environmental hazardous properties
(Hazard Classes; Table 4-3), as well as Hazard Categories, which are sub-divisions within
each hazard class with specific criteria that determine the degree or severity of the hazard.
Table 4-3: Hazard Classes of the SANS 10234 (GHS) Classification System.
Physical Hazards Health Hazards Hazards to the Aquatic
Environment
▪ Explosives
▪ Flammable gases
▪ Flammable aerosols
▪ Oxidizing gases
▪ Gases under pressure
▪ Flammable liquids
▪ Flammable solids
▪ Self-reactive
substances / mixtures
▪ Pyrophoric substances
▪ Self-heating
substances / mixtures
▪ Substances / mixtures
that on contact with
water, emit
flammable gases
▪ Oxidizing substances /
mixtures
▪ Organic peroxides
▪ Corrosive to metals
▪ Acute toxicity
▪ Skin corrosion & skin
irritation
▪ Serious eye damage
& eye irritation `
▪ Respiratory
sensitization & skin
sensitization
▪ Germ cell
mutagenicity
▪ Carcinogenicity
▪ Reproductive toxicity
▪ Specific target organ
toxicity: single
exposure
▪ Specific target organ
toxicity: repeated
exposure
▪ Aspiration hazards
▪ Acute aquatic
toxicity
▪ Chronic aquatic
toxicity
Importantly, the classification of a waste has no bearing on the disposal / management
requirements thereof, but is used predominantly to inform:
i. appropriate handling and storage of hazardous waste; as well as,
ii. the development of an associated Safety Data Sheet (SDS) for hazardous waste in
terms of SANS10234, as required in terms of Regulation 5 (1).
4.3.4 WASTE PROHIBITED FROM LANDFILL DISPOSAL
It is notable that the National Norms and Standards for Disposal of Waste to Landfill,
published 23 August 2013 in GN 636, cover requirements and restrictions for landfill disposal.
Noteworthy is the regulatory restriction on waste streams which is aimed at forcing these
streams into alternative treatment/ recovery /disposal methods. To the extent that these
regulations will be adhered to by the regulated community and enforced by authorities
these regulations will create a requirement for alternatives to landfill. The list of waste
streams is shown in Table 4-4.
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Table 4-4: Waste prohibited from landfill disposal (GN 636 of 2013)
Waste Prohibited or Restricted in terms of Disposal Timeframe from 23
August 2013
(a) Waste which, in the conditions of a landfill, is explosive,
corrosive, oxidizing (according to SANS 10234 or SANS10228). Immediate
(b) Waste with a pH value of <6 or >12. Immediate
(c) Flammable waste with a closed cup flashpoint lower than 61°
Celsius. Immediate
(d) Reactive waste that may react with water, air, acids or
components of the waste, or that could generate unacceptable
amounts of toxic gases within the landfill.
Immediate
(e) Waste compressed gases (according to SANS 10234 or SANS
10228). Immediate
(f) Untreated Healthcare Risk Waste (HCRW). Immediate
(g) (i) POPs pesticides listed under the Stockholm Convention. Eight (8) years
(ii) Other waste pesticides. Four (4) years
(h) Lead acid batteries. Immediate Immediate
(i) Other batteries. Eight (8) years
(j) Re-usable, recoverable or recyclable used lubricating mineral
oils, as well as oil filters, but excluding other oil containing wastes. Four (4) years
(k) Re-usable, recoverable or recyclable used or spent solvents. Five (5) Years
(I) PCB containing wastes (>50 mg/kg or 50 ppm). Five (5) Years
(m) Hazardous Waste Electric and Electronic Equipment (WEEE)
Lamps. Three (3) Years
(n) Hazardous Waste Electric and Electronic Equipment (WEEE)
Other. Eight (8) years
(o) Waste tyres: Whole. Immediate
(p) Waste tyres: Quartered. Five (5) Years
(q) Liquid waste
(i) Waste which has an angle of repose of less than 5 degrees, or
becomes free-flowing at or below 60 °C or when it is transported,
or is not generally capable of being picked up by a spade or
shovel; or
Six (6) years
(ii) Waste with a moisture content of >40% or that liberates moisture
under pressure in landfill conditions, and which has not been
stabilised by treatment.
Six (6) years
(r) Hazardous waste with a calorific value of:
(i) > 25 MJ/kg. Four (4) years
(ii) > 20 MJ/kg. Six (6) years
(iii) > 10 MJ/kg. Twelve (12) years
(iv) > 6% TOC. Fifteen (15) years
(s) Brine or waste with a high salt content (TDS > 5%), and a
leachable concentration for TDS of more than 100 000 mg/I. Eight (8) years
(t) Disposal of garden waste:
(i) 25% diversion from the baseline at a particular landfill of
separated garden waste. Five (5) years
(ii) 50% diversion from the baseline at a particular landfill of
separated garden waste Ten (10) years
(u) Infectious animal carcasses and animal waste. Immediate
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4.3.5 NORMS AND STANDARDS FOR STORAGE OF WASTE, 2013
The following activities listed under GN R.921, as amended, is proposed to be undertaken
at the facility:
• Category C – Activity (1) The storage of general waste at a facility that has the
capacity to store in excess of 100m3 of general waste at any one time, excluding
the storage of waste in lagoons or temporary storage of such waste.
GN R.921, as amended, requires that a person undertaking these activities must comply
with the Norms and Standards For Storage Of Waste, GN 926 of 2013.
4.3.6 NATIONAL NORMS AND STANDARDS FOR THE SORTING, SHREDDING,
GRINDING, CRUSHING, SCREENING, CHIPPING OR BALING OF GENERAL
WASTE, 2017
The following activity listed under GN R.921, as amended, is proposed to be undertaken at
the facility:
• Category C – Activity (6) The sorting, shredding, grinding, crushing, screening or
baling of general waste at a waste facility that has an operational area that is
1000m2 and more
GN R.921, as amended, requires that a person undertaking this activity must comply with
the National Norms and Standards for the Sorting, Shredding, Grinding, Crushing, Screening,
Chipping or Baling of General Waste, GN 1093 of 2017.
4.3.7 NATIONAL WASTE INFORMATION REGULATIONS, 2012.
The purpose of these Regulations is to regulate the collection of data and information to
fulfil the objectives of the national waste information system as set out in section 61 of the
NEMWA.
The regulations require any person conducting a listed waste management activity to
apply to the Department of Environment, Forestry and Fisheries to be registered on the South
African Waste Information system (SAWIS). The registered person must then submit the
required information on SAWIS quarterly.
4.3.8 NATIONAL POLICY ON THERMAL TREATMENT OF GENERAL AND HAZARDOUS
WASTE
The policy will apply to the proposed activities. This policy was established to, inter alia:
• Promote waste management options that allow for the recovery of energy and
raw materials from waste together with the effective treatment thereof, in order to
reduce the pressure on certain non-renewable resources.
• Accept and advance the implementation of an integrated waste management
system for South Africa in line with the waste management hierarchy, by facilitating
the move away from single waste management solutions towards the integration
of thermal waste treatment technologies, including incineration and cement kiln
co-processing.
• Provide minimum environmental requirements for the development and
implementation of waste incineration and co-processing technologies, in line with
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international best available techniques (BAT) and best environmental practice
(BEP).
4.4 AIR QUALITY LEGISLATION IN SOUTH AFRICA
The Air Quality Management in South Africa has undergone significant changes with regard
to amendments in Air Quality legislation. With the introduction of the National Environmental
Air Quality Act (NEMAQA) (Act 39 of 2004), there has been a shift in Air Quality Management
from a sourced based and best practicable means (BPM) approach under the Air Pollution
Prevention Act (APPA), Act 45 of 1965) to an ambient air quality management approach
whereby responsibilities for air quality management have been devolved down from the
national level to the local authority level (district and metropolitan municipalities).
Further to the “duty of care” previously discussed in terms of NEMA, NEMAQA defines air
pollution as:
““air pollution” means any change in the composition of the air caused by smoke, soot,
dust (including fly-ash), cinders, solid particles of any kind, gases, fumes, aerosols and
odorous substances;”
NEMAQA is effects-based legislation, with the result that activities that result in atmospheric
emissions are to be managed through the setting of environmental health based ambient
air quality standards. Facilities with potential impacts on air quality should ideally be
assessed not only in terms of its individual contribution, but in terms of its additive
contribution to baseline ambient air quality i.e. cumulative effects must be considered.
4.4.1 NATIONAL AMBIENT AIR QUALITY STANDARDS
According to S9 of NEMAQA:
“(1) The Minister, by notice in the Gazette-
(a) must identify 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 the Minister reasonably
believes present such a threat; and
(b) must, in respect of each of those substances or mixtures of substances, establish
national standards for ambient air quality, including the permissible amount or
concentration of each such substance or mixture of substances in ambient air; …”
The Minister of Water and Environmental Affairs published limits for ambient air quality in
Government Notice No 1210 of 24 December 2009, in terms of S9(1) of NEMAQA, as shown
in Table 4-5.
Table 4-5: National Ambient Air Quality Standards - GN 1210:2009
Pollutant Averaging period Conc. µg/m3 FOE* Compliance date
PM10 24-hours 75 4 1 January 2015
Annual 40 0 1 January 2015
NO2 1-hour 200 88 Immediate
Annual 40 0 Immediate
SO2
10-min (running) 500 526 Immediate
1-hour 350 88 Immediate
24-hours 125 4 Immediate
Annual 50 0 Immediate
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Table 4-5: National Ambient Air Quality Standards - GN 1210:2009
Pollutant Averaging period Conc. µg/m3 FOE* Compliance date
CO 1-hour 30 88 Immediate
8-hours (running)^ 10 11 Immediate
* FOE – Permitted Frequency of Exceedance in occurrences per year ^ Calculated on 1-Hourly averages.
The Ministry of Water and Environmental Affairs further published limits for PM2.5 on the 29th
June 2012, in terms of S9(1) of NEMAQA, as shown in Table 4-6.
Table 4-6: National Ambient Air Quality Standards for PM2.5 - GN 486:2012
Pollutant Averaging period Conc. µg/m3 FOE* Compliance date
PM2.5
24-hours
60 4 immediate
40 4 01 January 2016
25 4 01 January 2030
Annual
25 0 immediate
20 0 01 January 2016
15 0 01 January 2030
* FOE – Permitted Frequency of Exceedance in occurrences per year
4.4.2 LISTED ACTIVITIES AND ATMOSPHERIC EMISSIONS LICENSING
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.
S22 of NEMAQA states that no person may, without a provisional atmospheric emission
licence or an atmospheric emission licence, conduct a listed activity. A list of activities was
published in GN 248 of 2010. This list was superseded by GN 893 of 2013 and subsequently
by GN 551 on 12 June 2015 in accordance with S21 of NEMAQA.
The required air emission standards, set in terms of the NEMAQA S21 Minimum Emission
Standards, applicable to the proposed facility are given in Table 4-7 to Table 4-9 below.
The processes must comply with the ‘new plant’ minimum emission standards during the
operation of the plant, unless otherwise stipulated in an Atmospheric Emissions Licence.
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Table 4-7: GN 893:2013 Subcategory 3.1: Combustion Installations
Description Combustion installations not used primarily for steam raising or
electricity generation.
Application All combustion installations (except test or experimental
installations).
Substance or Mixtures of Substances
Common Name Chemical
Symbol
Plant
Status
mg/Nm3 under
normal conditions
of 273 Kelvin, 101.3
kPa
Particulate Matter N/A New 50
Existing 100
Oxides of nitrogen
NOx
expressed as
NO2
New 700
Existing 2000
Total organic compounds
(from non-coke oven
operations)
N/A
New 40
Existing 90
Table 4-8: GN 893:2013 Subcategory 3.4: Char, Charcoal and Carbon Black
Production
Description Production of char, charcoal and the production and use of
carbon black.
Application All installations producing more than 20 tons of char or charcoal
per month. Installations consuming more than 20 tons per month
of carbon black in any
processes.
Substance or Mixtures of Substances
Common Name Chemical
Symbol
Plant
Status
mg/Nm3 under
normal conditions
of 273 Kelvin, 101.3
kPa
Particulate Matter N/A New 50
Existing 100
Poly Aromatic Hydrocarbons PAH New 0.1
Existing 0.5
Table 4-9: GN 893:2013 Subcategory 8.1: Thermal Treatment of Hazardous and
General 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 Mixtures of Substances
Common Name Chemical
Symbol
Plant
Status
mg/Nm3 under
normal conditions
of 273 Kelvin, 101.3
kPa
Particulate matter N/A New 10
Existing 25
Carbon monoxide CO New 50
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Table 4-9: GN 893:2013 Subcategory 8.1: Thermal Treatment of Hazardous and
General 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 Mixtures of Substances
Common Name Chemical
Symbol
Plant
Status
mg/Nm3 under
normal conditions
of 273 Kelvin, 101.3
kPa
Existing 75
Sulphur dioxide SO2 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 0.5
Existing 0.5
Sum of Lead, arsenic,
antimony, chromium, cobalt,
copper, manganese, nickel,
vanadium
Pb, As, Sb, Cr,
Co, Cu, Mn,
Ni, V
New 0.05
Existing 0.05
Mercury Hg New 0.05
Existing 0.05
Cadmium Thallium Cd + TI New 10
Existing 10
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
4.4.3 NATIONAL REGULATIONS REGARDING DISPERSION MODELLING GN.R 533 OF
2014
The National Regulations Regarding Dispersion Modelling, GN.R 533 of 2014, was
promulgated in terms of NEMAQA in order to regulate air dispersion modelling that is
undertaken:
• in the development of an air quality management plan, as contemplated in Chapter
3 of NEMAQA;
• in the development of a priority area air quality management plan, as
contemplated in Section 19 of NEMAQA;
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• in the development of an atmospheric impact report, as contemplated in Section
30 of NEMAQA; and
• in the development of a specialist air quality impact assessment study, as
contemplated in Section 37(2)(b) of NEMAQA.
4.5 NATIONAL WATER ACT (ACT 36 OF 1998) {NWA}
The National Water Act, (Act 36 of 1998) {NWA}, 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, Act No. 36 of 1998 (NWA) a water use licence 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.
The facility will not trigger any water uses and thus does not require a Water Use Licence.
4.6 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”.
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The proposed activities are not expected to significantly alter the noise profile of the area.
4.7 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).
The proposed development’s footprint will exceed 0.5ha. An Archaeological Impact
Assessment was conducted and a summary of the results can be found under section 0.
The full report is attached as Appendix 4.2.
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5. PUBLIC PARTICIPATION
5.1 INTRODUCTION
Public participation provides the opportunity for interested and affected parties (IAPs) to
participate in the Environmental Impact Assessment process on an informed basis, and to
ensure that their concerns are considered during the environmental 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 to obtain information about the expected
environmental impacts of the proposed development.
• Establish a formal platform for IAPs to raise queries and give input regarding the
environmental impact of the project.
• Utilise the opportunity to formulate ways for reducing or mitigating any negative
environmental impacts of the project, and for enhancing its benefits.
• Enable the applicant to consider the needs, preferences and values of IAPs in their
decisions.
• Ensure transparency and accountability in decision-making.
5.2 STAKEHOLDER NOTIFICATION
The public and stakeholder participation process to date has entailed the following:
• Advertising of the proposed project and associated BA process in The Star and The
Pretoria News newspapers on the 16th of July 2020 and the Fourways Review on 28th
July 2020 (Refer to Appendix 1.1: Newspaper Advertisements)
• Placement of site notices at the main entrance as well as the sidewalk to the main
entrance to the site on the 14th of July 2020 (Refer to Appendix 1.2: Site Notices)
• Pre-identification of Interested and Affected Parties based on the existing list
registered IAPs including neighbouring landowners and occupiers, the ward
councillor, the municipality, the provincial environmental authority, and other
stakeholders. (Refer to Appendix 1.3 for the list of IAPS)
• Notification of Interested and Affected Parties, including neighbouring landowners
and occupiers, the ward councillor (including neighbouring wards), the local
municipality, the district municipality, the provincial environmental authority, and
other stakeholders.
The following is to be conducted through the distribution of the Draft Basic Assessment
Report to registered interested and affected parties:
• Distribution of draft BAR to IAPs for comment.
• Focus group meetings with relevant stakeholders if required.
5.3 SUMMARY OF ISSUES RAISED BY IAP’S
This report constitutes the draft report as distributed to IAPs for comment, thus no comments
have been received as of yet. Details of the public participation process undertaken and
a comments and responses report will be included in the Final Basic Assessment Report.
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6. CORRESPONDENCE WITH COMPETENT AUTHORITY
Proposed consultation with the Competent Authority is detailed in Table 6-1
Table 6-1: Authority Consultation
Process Phase Details
Pre-Application Pre-application meeting held with DEFF – 4th August 2020
Application Lodge application - 5th August 2020
Receive acknowledgement of application - 13th August 2020
Basic Assessment Distribute draft Basic Assessment to IAPs for comment - CURRENT
Submit Final Basic Assessment Report
Receive confirmation of acceptance of BAR
Receive Decision on application
This report constitutes the draft report as distributed to IAPs and the competent authority for
comment, therefore proof of submission of application and draft BAR to the DEFF will be
provided in the final report.
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7. DESCRIPTION OF THE ENVIRONMENT AND POTENTIAL
IMPACTS
7.1 LOCATION, LAND-USE AND ZONING
The proposed site is located within the City of Tshwane Metropolitan Municipality in the
Province of Gauteng. The site will be accessed off the R114 and is immediately surrounded
by residential and commercial activities as well as grassland/shrubland. The nearest
residential area is Laezonia AH, approximately 0.5 km West of the proposed site. There is
also an informal settlement located approximately 10m from the boundary of the Limeroc
Business Park. Refer to Figure 1-1 for an overview of the location of the facility.
Both the preferred and alternative location are zoned Industrial 1.
The following land uses are present within 1km from the Limeroc Business Park site boundary
(See Figure 7-2):
1. Vacant land (grassland/shrubland)
2. Cultivated Land
3. Informal residential
4. Low density residential
5. Commercial & warehousing
6. Light industrial
7. Regional road
8. National Road
9. Mining
10. Waterbody/Wetland/River
11. Mining
Table 7-1 give a spatial representation of the respective land uses listed above surrounding
the site with each block in the table representing a 500m x 500m area.
Table 7-1: Land use surrounding the site in 500m increments
North
4 4 / 8 1/2 1/2 8 / 10 / 11
4 4/5/7 1/7 2 1/2
West 4 1/3/4 SITE 1/10 1/9 East
4 1/7 1/4/8 1/2/8 1/2
1/5 1/8 1/4 1/4 4
South
Figure 7-1 illustrates the Land use types surrounding the Limeroc Business Park.
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Figure 7-1 Land cover at the site and surrounding areas
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Figure 7-2: Surrounding Land Use
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7.2 BIOPHYSICAL ENVIRONMENT
7.2.1 CLIMATE
7.2.1.1 GENERAL DESCRIPTION OF CLIMATOLOGY AND METEOROLOGY
The proposed facility is located in the City of Tshwane. This is a summer rainfall region that
is defined by a mid-latitude steppe/semi-arid cool climate and is situated near the
subtropical dry forest biome.
7.2.1.2 RAINFALL AND TEMPERATURE
The City of Tshwane has a subtropical climate resulting in short winters (June, July, and
August). Temperatures in winter can fall below freezing with frosty mornings, the minimum
recorded temperature over the period is 0°C. The average maximum temperature that
is reached in the winter months is 18.8°C for the period of 2017 - 2019. Rainfall occurs in
the summer months (December, January, and February), predominantly in December
and January with July being the lowest rainfall month (Figure 7-3).
7.2.1.3 WIND
Observed wind direction and wind speed at the nearest ambient air quality monitoring
(AAQM) station is shown as wind roses (for 2017 through to 2018) in Figure 7-4 to Figure
7-8. The length of the colour-coded line is proportional to the frequency of occurrence
of wind blowing from that direction. Wind speed classes are also colour coded and the
length of each class/category is proportional to the frequency of occurrence of wind
speed. Figure 7-4 to Figure 7-8 shows the wind rose developed for data obtained from
the Diepsloot AAQM Station situated approximately 1.8 km south west of Limeroc
Business Park. Data was not available for 2016 and data availability for 2018 is poor (see
Table 7-2). The combined data over the 2017 – 2018 period is poor (less than 65%).
Figure 7-3: Average monthly temperatures and rainfall from Diepsloot AAQM station
from 2017 – 2019.
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Table 7-2: Data availability for AAQM station.
Station Data Availability
2016 2017 2018 Combined
Diepsloot, City of
Johannesburg 0.00% 16.30% 90.23% 53.26%
Table 7-3: Wind speed comparison for the Diepsloot AAQM station.
Station
Wind speed (m/s)
2016 2017 2018 Combined
(2017 – 2018)
Measured - 2.80 2.74 2.75
Figure 7-4: Average Wind Roses from 2017-2018 for Diepsloot AAQM station - Annual
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Figure 7-5: Average Wind Roses from 2017-2018 for Diepsloot AAQM station - Summer
Figure 7-6: Average Wind Roses from 2017-2018 for Diepsloot AAQM station - Autumn
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Figure 7-7: Average Wind Roses from 2017-2018 for Diepsloot AAQM station - Winter
Figure 7-8: Average Wind Roses from 2017-2018 for Diepsloot AAQM station - Spring
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7.2.2 TOPOGRAPHY
The terrain surrounding the site is not complex. There is higher terrain to the east of the site (
Figure 7-9: Topographical Map
7.2.3 FAUNA & FLORA
The site on which the proposed facility is to be located is currently vacant. It is largely made
up of thicket, grasses. There are no natural habitats of significance within the site. The
surrounding land has largely been disturbed by commercial and residential activities as
shown in Figure 7-1.
As shown in Figure 7-10, the preferred site is located within an area deemed to be an
Ecological Support Area (and partly within a Critical Biodiversity Area), and the alternative
site is located within an area deemed to be a Critical Biodiversity Area, according to the
Gauteng Conservation Plan 2014.
It is important to note, as detailed in section 1.5, that the Limeroc Business Park owners have
obtained the necessary environmental authorisations from the Gauteng Department of
Agriculture and Rural Development for the clearance of this land, amongst other activities
detailed in Table 1-8 and Table 1-9.
The following specialist studies were undertaken on each of the sites:
Preferred location:
• Fauna Habitat Assessment
• Vegetation Survey
• Addendum to the Ecological Habitat Assessment
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• Geotechnical Report
• Wetland Assessment
• Heritage Impact Assessment
• Service Report
• Traffic Impact Study
• Storm Water Management Report
Alternative Location:
• Fauna and Flora Habitat Assessment
• Geotechnical Report
• Services Report
• Traffic impact Study
• Heritage Impact Assessment
Figure 7-10: Critical Biodiversity Areas (CBAs) or Ecological Support Areas (ESAs) as per the
Gauteng Conservation Plan 2014
7.3 SITE PHOTOGRAPHS
7.3.1 PREFERRED LOCATION
Photographs of the preferred location are shown in Figure 7-11 to Figure 7-14. As discussed
in section 1.5, the land clearance activities that can be seen have been conducted by the
landowner under an existing valid environmental authorisation. As shown in the
photographs the land is completely disturbed.
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Figure 7-11: Photograph 1 of preferred location
Figure 7-12: Photograph 2 of preferred location
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Figure 7-13: Photograph 3 of preferred location
Figure 7-14: Photograph 4 of preferred location
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7.3.2 ALTERNATIVE LOCATION
Photographs of the alternative location are shown in Figure 7-15 to Figure 7-18. As discussed
in section 1.5, the land owner has obtained an environmental authorisation for the
clearance of the vegetation. As shown in the photographs the land contains a significant
amount of alien vegetation.
Figure 7-15: Photograph 1 of alternative location
Figure 7-16: Photograph 2 of alternative location
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Figure 7-17: Photograph 3 of alternative location
Figure 7-18: Photograph 4 of alternative location
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7.4 SOCIO-ECONOMIC ENVIRONMENT
According to Statistics SA Census 2011, the then population of the City of Tshwane was 2.92
million with Centurion in particular having a population of 236 580. The City of Tshwane
continues to fight high unemployment. Overall, the City’s unemployment in 2011 was 24.2%
(Statistics SA Census, 2011).
Centurion falls into Region 4 of the City of Tshwane Metropolitan Municipality. According to
the city, this region falls into the economic core of Gauteng.
According to the City of Tshwane, Region 4 25% of the population in the region is regarded
as being within the low-income group although the region is described as being more
affluent.
The proposed project is not expected to have any negative socio-economic impact as it
constitutes the construction of a waste pyrolysis plant and supporting infrastructure. It will
however contribute to the minimisation of plastic and hydrocarbon waste in across the
municipality by removing waste that could be disposed of here thus ensuring that these
sites can extend their operational lifespans.
7.5 ARCHAEOLOGY, HERITAGE & CULTURE
An Archaeological Impact Assessment of the proposed site was conducted. A summary of
the findings of the report are given under section 0. The full report is attached as Appendix
4.2. The development within the limits of the proposed impact areas are not anticipated to
have any impact on cultural heritage. In addition, given the sparseness of archaeological
sites and material within the immediate area, based on a review of relevant heritage reports
on SAHRIS, it is unlikely that the proposed development will have any significant impact on
cultural heritage.
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8. DEFF ONLINE SCREENING TOOL
The National Department of Environment Forestry and Fisheries (DEFF) has developed a
national screening tool that identifies potentially environmentally sensitive areas in and
around the proposed site. The screening tool is available for the entirety of South Africa and
is available at the following link:
https://screening.environment.gov.za/screeningtool/index.html#/pages/welcome
It is now a requirement that any application for environmental authorisation is
accompanied by such a screening report. Table 8-1 shows the environmental sensitivities
identified by the DEFF Online Screening Tool within the vicinity of the proposed
development footprint.
Table 8-1: Environmental sensitivities identified by DEFF Online Screening Tool
Theme Very High
sensitivity
High
sensitivity
Medium
sensitivity
Low
sensitivity
Agriculture Theme X
Animal Species Theme X
Aquatic Biodiversity
Theme X
Archaeological and
Cultural Heritage Theme X
Civil Aviation Theme X
Plant Species Theme X
Defence Theme X
Terrestrial Biodiversity
Theme X
The screening tool identified the following specialist studies that may be applicable to the
proposed facility based on the site’s classification, and the identified environmental
sensitivities of the proposed development footprint:
• Agricultural Impact Assessment
• Landscape/Visual Impact Assessment
• Archaeological and Cultural Heritage Impact Assessment
• Palaeontology Impact Assessment
• Terrestrial Biodiversity Impact Assessment
• Aquatic Biodiversity Impact Assessment
• Hydrological Assessment
• Noise Impact Assessment
• Traffic Impact Assessment
• Health Impact Assessment
• Socio-Economic Assessment
• Ambient Air Quality Impact Assessment
• Air Quality Impact Assessment
• Plant Species Assessment
• Animal Species Assessment
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It is the professional opinion of EScience Associates that the above listed studies are not all
relevant based on the disturbed and developed nature of the site, the surrounding land
uses, and the nature of proposed activities. The specialist studies that are deemed to be
required are as follows:
• Air Quality Impact Assessment in support of an Atmospheric Emission Licence (AEL)
application as well in cognisance that emissions to atmosphere are likely to the
environmental concern of most significance.
• Archaeological Impact Assessment. This will be required due to the fact that
excavation may be required during construction, together with the fact that the
area is deemed to be of high Archaeological and Cultural Heritage sensitivity.
8.1 MOTIVATION FOR THE EXCLUSION OF SPECIALIST STUDIES IDENTIFIED BY
THE DEFF SCREENING TOOL
8.1.1 AGRICULTURAL IMPACT ASSESSMENT
The proposed activities will be undertaken wholly within the disturbed footprint of the
Limeroc Business Park. Consequently, there will be no impact on agriculture nor any
sterilisation of arable land. An Agricultural Impact Assessment is therefore deemed
unnecessary.
8.1.2 LANDSCAPE/VISUAL IMPACT ASSESSMENT
The proposed activities will be undertaken wholly within the disturbed footprint of the
Limeroc Business Park. The park is zoned for industrial use. There will thus be no changes to
the sense of place and a Visual Impact Assessment is deemed unnecessary.
8.1.3 PALAEONTOLOGY IMPACT ASSESSMENT
The South African Heritage Resources Information System (SAHRIS) Palaeontological
sensitivity map (https://sahris.sahra.org.za/map/palaeo) shows that the site falls within an
area of “insignificant / zero” sensitivity which in turn does not require any Palaeontological
studies.
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Figure 8-1: Palaeontological sensitivity Map (https://sahris.sahra.org.za/map/palaeo)
8.1.4 TERRESTRIAL BIODIVERSITY IMPACT ASSESSMENT
The proposed activities will be undertaken wholly within the disturbed footprint of the
Limeroc Business Park. There will be no clearance of indigenous vegetation. Consequently,
the potential for terrestrial biodiversity impacts is negligible. A Terrestrial Biodiversity Impact
Assessment is therefore deemed unnecessary.
8.1.5 AQUATIC BIODIVERSITY IMPACT ASSESSMENT
The proposed activities will be undertaken wholly within the disturbed footprint of the
Limeroc Business Park. The facility will be constructed within the storm water management
infrastructure of the business park and no polluted rainfall runoff is expected to leave the
site. Consequently, the potential for aquatic biodiversity impacts is negligible. An Aquatic
Biodiversity Impact Assessment is therefore deemed unnecessary.
8.1.6 HYDROLOGICAL ASSESSMENT
The proposed activities will be undertaken wholly within the disturbed footprint of the
Limeroc Business Park. The facility will not cause hydrological impacts. Consequently, a
Hydrological Impact Assessment is deemed unnecessary.
8.1.7 NOISE IMPACT ASSESSMENT
The proposed activities will be undertaken at the Limeroc Business Park within the
boundaries of the industrial complex and will be surrounded by other industrial activities.
The noise profile of the industrial complex is not expected to change to a significant extent.
A Noise Impact Assessment is therefore deemed unnecessary.
8.1.8 TRAFFIC IMPACT ASSESSMENT
The activity will result in additional road traffic through the delivery of raw materials to the
facility and transport of products away from the facility. However, considering the proximity
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to major urban roads (N14 and R511) there is expected to be a negligible impact on traffic.
A Traffic Impact Assessment is therefore not deemed necessary.
8.1.9 HEALTH IMPACT ASSESSMENT
The only anticipated potential health impacts will be air quality related. These impacts are
assessed within the Air Quality Impact Assessment.
8.1.10 SOCIO-ECONOMIC ASSESSMENT
The proposed expansion is not expected to result in a significant number of additional jobs,
nor is it expected to have a negative socio-economic impact. The socio-economic impact
is not expected to be significant and thus a Socio-Economic Assessment is deemed
unnecessary.
8.1.11 PLANT SPECIES ASSESSMENT
The proposed activities will be undertaken wholly within the disturbed footprint of the
Limeroc Business Park. There will be no clearance of vegetation. A Plant Species Assessment
is therefore deemed unnecessary.
8.1.12 ANIMAL SPECIES ASSESSMENT
The proposed activities will be undertaken wholly within the disturbed footprint of the
Limeroc Business Park. There will be no clearance of vegetation nor any disturbance of
existing biodiversity habitat. An Animal Species Assessment is therefore deemed
unnecessary.
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9. SPECIALIST STUDIES
9.1 AIR QUALITY IMPACT ASSESSMENT
A specialist air quality impact assessment was undertaken by Escience Associates (Pty) Ltd.
The following emissions from the proposed plant were identified and assessed as potentially
significant in terms of the possible effect on ambient air quality:
o Oxides of Nitrogen (NOx)
o Particulate matter (PM),
o Sulphur dioxide (SO2) and other acid gases (e.g. HCl) depending on the composition
of the fuels.
o Metals within the particulate matter.
o Hexavalent Chromium
o Polycyclic Aromatic Hydrocarbons
o Potential dioxins and furans from post combustion de-novo synthesis depending on
the composition of the materials combusted and post combustion conditions to
which off-gases are exposed.
A summary of the assessment is provided under section 11.2.3. The full Air Quality Impact
Assessment can be found as Appendix 4.1 hereto.
9.2 ARCHAEOLOGICAL IMPACT ASSESSMENT
A Phase 1 Archaeological Impact Assessment was conducted by Dr Matt Lotter and Dr Tim
Forssman. Both are members of the Association of Southern African Professional
Archaeologists, with Cultural Resource Management accreditation.
The relevant portions of land were investigated on foot for any surface traces of cultural
heritage. Where excavations had taken place on the property, these and their spoil heaps
were also examined for any heritage traces. All finds or sites were recorded following
standard archaeological procedures. A specially designed site recording form was used to
notate any observable traits, including cultural heritage types, deposit information and
assemblage or site context, and this was graded following a set rating criteria. All survey
routes were GPS recorded and every find was photographed along with the landscape.
A summary of the assessment is provided under section 11.1.5, the full assessment can be
found as Appendix 4.2 hereto.
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10. METHODOLOGY USED TO DETERMINE IMPACTS
The following criteria and methodology were utilised to determine the significance of
environmental impacts that may result from the facility.
10.1 TYPE / NATURE 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.
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 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.
10.2 DETERMINING SIGNIFICANCE
The following criteria were used to determine the significance of an impact. The scores
associated with each of the levels within each criterion are indicated in brackets after each
description [like this].
10.2.1 NATURE
Nature (N) considers whether the impact is:
• Positive [- ¼]
• Negative [+1].
10.2.2 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].
10.2.3 DURATION
Duration (D) considers whether the impact will be:
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• 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: 10 years or longer [5].
10.2.4 INTENSITY
Intensity (I) considers whether the impact will be:
• negligible: there is an impact on the environment, but it is negligible, having no
discernible 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].
10.2.5 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].
10.2.6 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:
• unenhanced: no enhancement is possible or planned [1]
• slightly enhanced: a small enhancement in the benefit is possible [2]
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• 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].
10.2.7 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].
10.3 CALCULATING IMPACT SIGNIFICANCE
The table below summarises the scoring for all the criteria.
Table 10-1: Scoring for Significance Criteria
CRITERION SCORES
- ¼ 1 2 3 4 5
N-nature positive negative - - - -
E-extent - site local municipal provincial national
D-duration - very short short moderate long very long
I-intensity - negligible minor moderate major severe
P-probability - unlikely likely Very likely definite -
M-mitigation - none slight moderate good -
H-enhancement - none slight moderate good -
R-reversibility - none slight moderate mostly -
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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10.4 UNDERSTANDING IMPACT SIGNIFICANCE
The following is a guide to interpreting the final scores of an impact (for negative impacts):
Table 10-2: Final Significance Scoring
Final
score (S)
Impact significance
0 – 10 Negligible The impact should result in no appreciable 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,
sterilising of essential environmental resources, local species extinctions,
eco-system collapse; project alternatives that are substantially different
should be considered, otherwise the project should not be approved.
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11. IMPACT ASSESSMENT
11.1 POTENTIAL IMPACTS – CONSTRUCTION PHASE
11.1.1 SOIL AND GROUNDWATER QUALITY
11.1.1.1 Introduction
Spills or inappropriate storage, management and handling of fuels and other potentially
dangerous substances could result in negative impacts on soil and groundwater quality;
where spillages of such substances could enter the soil and / or groundwater environment
through the infiltration of contaminated surface run-off.
11.1.1.2 Impact Discussion & Significance Assessment
Table 10-3: Impacts on soil and groundwater quality (Construction)
Nature (N) Negative impact on groundwater 1
Extent (E) Locally: groundwater can be affected outside of the
site boundary 2
Duration (D) Medium term: If contaminant does enter groundwater
it could be present for 1-2 years. 3
Intensity (I) Moderate: If contaminant enters the groundwater, the
environment is altered. 3
Probability (P) Unlikely: The probability of contaminant entering soil or
even groundwater is low as fuel is to be stored in a
bunded area.
1
Mitigation (M) Impact can be mostly mitigated e.g. by placing drip
trays under vehicles and storing fuel in bunded areas. 4
Reversibility (R) Slight: Groundwater remediation is possible but is a very
costly and lengthy process 2
Significance Rating
without Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R)
Low 15
Significance Rating
with Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R)
Negligible 5
11.1.1.3 Mitigation / Management
The following measures should be put in place to prevent groundwater pollution:
• Ensure that storage of dangerous goods takes place over an impermeable surface
within a bunded area.
• If vehicle and / or construction machinery maintenance is to occur onsite, a suitable
leak proof container for the storage of oiled equipment (filters, drip tray contents and
oil changes etc.) must be established.
• Hazardous substances such as fuel and oil must be stored within appropriately sized,
impermeable, bund walls, with the appropriate warning signage.
• Spill kits to be readily available at all points where hazardous substances will be
stored and / or transferred (e.g. refuelling points);
• In the instance that a spill occurs, this should be dealt with in line with the EMPr.
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• All vehicles, equipment, fuel and petroleum services and tanks must be maintained
in a condition that prevents leakage and possible contamination of soil or water.
Refuelling areas must be bunded and secured to prevent soil and water
contamination.
• Where possible building materials are to be prepared at the batching plant, to
enable the effects of cement and other substances, and the resulting effluent to be
more easily managed.
11.1.2 NOISE
11.1.2.1 Introduction
Significant noise generation from the construction itself is not expected. The construction is
expected to occur within normal working hours, the noise generation is not expected to
have any significant impact and is expected to be in accordance with the locally
applicable by-laws.
11.1.2.2 Impact Discussion & Significance Assessment
Noise during construction activities of proposed infrastructure and equipment is expected
to have no significant impact outside of the site provided that the recommended
mitigatory measures are implemented.
Table 10-4: Noise impacts (Construction)
Nature (N) Negative impact - Construction related activities to
be limited to normal working hours, in accordance
with locally applicable by-laws.
1
Extent (E) Locally: Localised to the site and immediate
surrounds
2
Duration (D) Short term: The construction period is expected to be
less than 6 months.
2
Intensity (I) Minor: The facility is within a built-up urban area
zoned for industrial use. Noise generation is expected
to be minimal.
2
Probability (P) Very Likely: It is very likely that noise will be generated
to an extent that mitigation measures should be
considered
4
Mitigation (M) Well mitigated: To be limited to normal working hours,
in accordance with locally applicable by-laws. 4
Reversibility (R) Mostly Reversible: The status quo will return to the
previous status quo upon completion. 4
Significance Rating
without Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R) Low 16
Significance Rating
with Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R) Negligible 8
11.1.2.3 Mitigation / Management
• Use of construction vehicles, and activities, which may create a disturbing noise
must be undertaken during typical business hours in accordance with locally
applicable by-laws during the week. These activities must be avoided as far as is
practical during night-time and weekends.
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• A complaints register shall be maintained and kept at reception in order to record
complaints of noise and / or odour.
11.1.3 WASTE GENERATION, HANDLING AND DISPOSAL
11.1.3.1 Introduction
Construction waste will largely consist of non-hazardous / general waste. The generation of
such waste could indirectly impact on the operational lifespan of a waste disposal facility,
through the permanent occupation of remaining available airspace at such a facility.
Recyclable materials such as steel should be separated and recycled.
11.1.3.2 Impact Discussion & Significance Assessment
Table 10-5: Waste generation impact (Construction)
Nature (N) Negative impact resulting from waste generation 1
Extent (E) Municipal: Use of airspace that would otherwise be
available to other uses in the municipality. 3
Duration (D) Very Long term: Waste generated will be disposed of
at a landfill. 5
Intensity (I) Negligible: Construction activities are expected to
produce negligible amounts of waste. 1
Probability (P) Definite: Waste will be produced. 4
Mitigation (M) Moderately mitigated through re-use and recycling 3
Reversibility (R) Reversible: The status quo will return upon completion
of the construction. 4
Significance Rating
without Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R) Low 16
Significance Rating
with Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R) Negligible 9
11.1.3.3 Mitigation / Management
• Recyclable materials such as steel should be separated and recycled.
• Adequate Bins and / or skips must be provided on the site to provide for general
waste. Waste sorting must be done at source or within a dedicated area.
Undesired or non-recyclable waste must be collected by an appropriate waste
management service provider.
• All waste must be stored in compliance with the Norms and Standards set out in
GN926 National Environmental Management: Waste Act (59 / 2008): National
norms and standards for the storage of waste.
• Waste management practices must adhere to the regulations set out in GN.R634
National Environmental Management: Waste Act (59 / 2008): Waste Classification
and Management Regulations.
• All waste and storage areas must be clearly demarcated and maintained.
11.1.4 AIR QUALITY – DUST GENERATION
11.1.4.1 Introduction
During construction, the undertaking of ground preparation and civil works may lead to the
generation of vehicle and wind entrained dust. Although the impact is likely to be localised
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to the site due the size of the area to be worked, dust suppression techniques such as
wetting roads, or application of dust palliatives, may be required. Other emissions during
construction, such as construction vehicle and machinery exhausts are not anticipated to
be significant.
11.1.4.2 Impact Discussion & Significance Assessment
Table 10-6: Air Quality – Dust Generation (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 up to 6 months 2
Intensity (I) Minor: Natural processes or functions will hardly be
affected 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) Well mitigated: Effective dust suppression methods
readily available 4
Reversibility (R) Reversible: The status quo will return upon completion
of the construction 4
Significance Rating
without Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R) Negligible 8
Significance Rating
with Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R) Negligible 4
11.1.4.3 Mitigation / Management
The Proponent is to institute effective dust suppression measures on all un-surfaced access
roads for the duration of the construction phase.
11.1.5 ARCHAEOLOGICAL IMPACT
A Phase 1 Archaeological Impact Assessment was conducted by Dr Matt Lotter and Dr Tim
Forssman. Both are members of the Association of Southern African Professional
Archaeologists, with Cultural Resource Management accreditation.
A summary of the assessment is provided herein, the full assessment can be found as
Appendix 4.2 hereto.
11.1.5.1 Introduction
Drs Matt Lotter and Tim Forssman were then appointed by EScience Associates to perform
an Archaeological Impact Assessment on Erf numbers 1807 and 1824, within the Limeroc
Business Park in Centurion, for the development of warehouses by IGE Solutions.
11.1.5.2 Methods
The relevant portions of land were investigated on foot for any surface traces of cultural
heritage. Where excavations had taken place on the property, these and their spoil heaps
were also examined for any heritage traces. All finds or sites were recorded following
standard archaeological procedures. A specially designed site recording form was used to
notate any observable traits, including cultural heritage types, deposit information and
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assemblage or site context, and this was graded following a set rating criteria. All survey
routes were GPS recorded and every find was photographed along with the landscape.
11.1.5.3 Constraints and limitations
Several factors have contributed to the potential disturbance of archaeological remains,
namely: surface clearings, sporadic soil stockpiling and vehicle traffic. The gravel road and
stockpiled sediments in the alternative development area may also have had a negative
impact on the preservation and context of archaeological remains, although on inspecting
these no cultural material was identified.
Furthermore, as with all archaeological surveys, the primary goal is to identify cultural
material exposed on the surface. From this, one is able to make inferences about what may
also lie below the surface. However, without actual test trenches or geotrenches, it is not
possible to be certain what is represented underground. Moreover, underground heritage
remains may not be represented on the surface making their identification impossible. This
serves as a considerable limitation. Should any cultural heritage be identified when the
development begins, a specialist must be consulted to examine the finds.
11.1.5.4 Results
The entire portion of both the preferred and alternative development areas was surveyed
as shown in Figure 10-1. Therefore, from the survey, an accurate and inclusive assessment
was possible and the results apply to the entirety of each location. Since the survey was
restricted to these areas only, the findings cannot be applied to any area outside of the
development impact areas within the confines of the Limeroc Business Park.
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Figure 10-1: Survey tracklog indicated in red while the green polygons demarcate the
development
Both the preferred and alternative development areas are highly disturbed. For example,
in the preferred area to the east, historic imagery in Google Earth indicates that it was
largely vegetated and undisturbed in early 2018, but thereafter and until early to mid-2019
there have been considerable changes to the landscape. Currently, the area receives
heavy traffic from construction vehicles (Figure 10-2). As a result of this largely modified
landscape, it is currently not possible to determine what impact these activities have had
on preserved heritage in the area (if any, given its current complete absence). Part of the
alternative development area appears to have been agricultural fields within the last 10
years (Figure 10-3)
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Figure 10-2: Various images of the preferred location
looking southwest(A), east (B), southeast (C) and south (D). All the images show the impact of surface clearing and vehicle traffic (save
for D), which may have impacted tangible cultural material if it was present.
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Figure 10-3: Various images of the alternative development location.
This flat parcel of land has a gravel road and stockpiled sediment along its northwestern boundary (A). Natural quartz geofacts (chucks)
are frequently found at the surface (B; scale=10cm). General views of this location (C and D) and evidence excavation spoil stockpiles
for backfilling (E) are also indicated.
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No cultural heritage was located on the surface in either the preferred or alternative
development areas. The stockpiled sediment in the alternative area provided a potential
view for what may lie below the surface, in conjunction with the associated shallow
diggings adjacent to the gravel road, but no tangible cultural material was noted within
these deposits (Figure 10-3A). Sporadic natural geofacts were also located, comprising
quartz chunks and fragments, but these are non-artefactual and non-archaeological
(Figure 10-3B).
Although there are certain limitations that may have inhibited identification (section
11.1.5.3), it is highly unlikely that any surface archaeology was not identified.
11.1.5.5 Conclusions
Impact Discussion & Significance Assessment
The development within the limits of the proposed impact areas are not anticipated to
have any impact on cultural heritage. In addition, given the sparseness of archaeological
sites and material within the immediate area, based on a review of relevant heritage reports
on SAHRIS, it is unlikely that the proposed development will have any significant impact on
cultural heritage.
Recommendations
No heritage finds of any significance were identified in the impact footprint of the
development. Therefore, regarding the visible cultural heritage, there are no
recommendations put forward.
However, developers should be cognisant of the possibility that once development
commences, cultural heritage buried underground may be exposed. Should this occur, the
development in the vicinity of the find should be halted and a specialist must be consulted
to examine the finds.
11.2 POTENTIAL IMPACTS – OPERATIONAL PHASE
11.2.1 SOIL AND GROUNDWATER QUALITY – WASTE STORAGE AND HANDLING
11.2.1.1 Introduction
The inappropriate handling and storage, of waste may result in negative impacts on soil
and groundwater quality; where spillages of such substances could enter the groundwater
environment through the infiltration of contaminated surface run-off. The storage areas will
be constructed in accordance with the National Norms and Standards for Storage of Waste
GN 926 of 2013.
Storage of waste is to take place under roof on an impermeable surface and within a
bunded area, thus the potential for seepage to groundwater or contamination of soil and
rainwater runoff is limited.
11.2.1.2 Impact Discussion & Significance Assessment
Table 10-7: Impacts on Groundwater Quality – Waste Storage and Handling
(Operation)
Nature (N) Negative impact 1
Extent (E) Locally: Localised to the site and immediate surrounds 2
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Table 10-7: Impacts on Groundwater Quality – Waste Storage and Handling
(Operation)
Duration (D) Medium term: If a plume does enter groundwater it
could be present for 1-2 years 3
Intensity (I) Major: Without the required management measures in
place, if a plume enters the groundwater, the
groundwater surrounding the plant would potentially
be significantly impacted on.
4
Probability (P) Unlikely: The probability of contaminant entering
groundwater is low as waste is to be stored in a bunded
area.
1
Mitigation (M) Well mitigated: Impact can be prevented by
construction of an impermeable bunded facility. 4
Reversibility (R) Slight: Groundwater remediation is possible but is a very
costly and lengthy process 2
Significance Rating
without Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R)
Moderate 20
Significance Rating
with Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R)
Negligible 7
Table 10-8: Impacts on Soil Quality- – Waste Storage and Handling (Operation)
Nature (N) Negative 1
Extent (E) On site 1
Duration (D) Short term: Potential impact can be addressed
immediately
2
Intensity (I) Minor: Natural processes or functions are not expected
to be appreciably affected 2
Probability (P) Unlikely: The probability of contaminant entering soil is
low as waste is to be stored in a bunded area. 1
Mitigation (M) Impact can be mostly mitigated: Impact can be
prevented by placing drip trays under vehicles. 4
Reversibility (R) Mostly reversible: The contaminated soil can be
removed and treated 4
Significance Rating
without Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R)
Negligible 3
Significance Rating
with Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R)
Negligible 2
11.2.1.3 Mitigation / Management
The following measures should be put in place to prevent soil and groundwater pollution:
• Adequate Bins and / or skips must be provided on the site to provide for storage of
waste.
• Storage of waste is to take place under roof on an impermeable surface and within
a bunded area.
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• All waste must be stored in compliance with the Norms and Standards set out in
GN926 National Environmental Management: Waste Act (59 / 2008): National
norms and standards for the storage of waste.
• Waste management practices must adhere to the regulations set out in GN.R634
National Environmental Management: Waste Act (59 / 2008): Waste Classification
and Management Regulations.
• All waste and storage areas must be clearly demarcated and maintained.
• Transport of handling of waste must be conducted in such a manner that leachate
does not leak onto roads or parking areas.
11.2.2 NOISE
11.2.2.1 Introduction
Significant noise generation from the facility itself is not expected. Noise is expected to be
generated from waste delivery vehicles and waste processing. Considering that the waste
deliveries and waste processing activities will take place during normal working hours, the
noise generation is not expected to have any significant impact and is expected to be in
accordance with the applicable by-laws.
11.2.2.2 Impact Discussion & Significance Assessment
Noise during operational activities of proposed infrastructure and equipment is expected
to have no significant impact outside of the site provided that the recommended
mitigatory measures are implemented.
Table 10-9: Noise impacts (Operation)
Nature (N) Negative impact 1
Extent (E) Locally: Localised to the site and immediate surrounds 2
Duration (D) Very long term: Operations are expected to last longer
than 10 years 5
Intensity (I) Negligible: The proposed site location is zoned for
industrial use, noise levels are expected to be within the
acceptable limits in accordance with the applicable
by-laws.
1
Probability (P) Definite: Noise will be generated. 4
Mitigation (M) Well mitigated: To be limited to normal working hours, in
accordance with locally applicable by-laws. 4
Reversibility (R) Mostly Reversible: The status quo will return to the
previous status quo upon completion. 4
Significance Rating
without Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R) Low 14
Significance Rating
with Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R) Negligible 7
11.2.2.3 Mitigation / Management
• Noise generating activities should be limited to normal working hours, in accordance
with locally applicable by-laws.
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• A complaints register should be implemented to record any complaints from
surrounding land owners / users. If any noise complaints are received the root cause
of the compliant must be investigated and resolved.
11.2.3 AIR QUALITY
A specialist air quality impact assessment was undertaken by Escience Associates (Pty) Ltd.
A summary of the assessment is provided herein. The full Air Quality Impact Assessment can
be found as Appendix 4.1 hereto.
11.2.3.1 PROPOSED EMISSIONS
The parameters for the point source for the proposed facility are presented in Table 10-10.
A recommended stack height of 12m has been determined based on screening results and
the Guideline for Determination of Good Engineering Practice Stack Height (USEPA, 1985).
The maximum emission rates for the point sources under normal operating conditions are
presented in Table 10-11.
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Table 10-10: Parameters for Point Sources
Point
Source
Code
Source Name
Latitude
(decimal
degrees)
Longitude
(decimal
degrees)
Height of
Release
Above
Ground (m)
Height
Above
Nearby
Building
(m)
Diameter at
Stack Tip /
Vent Exit
(m)
Actual Gas
Exit
Temperatur
e (°C)
Actual Gas
Volumetric
Flow (m³/hr)
Actual
Gas Exit
Velocity
(m/s)
Emission
Hours
Type of
Emission
(Continuous
/ Batch) South East
SS1 Scrubber
Stack 1 -25.90386 28.37975 12.00 4.00 0.15 60 501.94 11.30 24 Hours Continuous
SS2 Scrubber
Stack 2 -25.90386 28.37975 12.00 4.00 0.15 60 501.94 11.30 24 Hours Continuous
SS3 Scrubber
Stack 3 -25.90386 28.37975 12.00 4.00 0.15 60 501.94 11.30 24 Hours Continuous
SS4 Scrubber
Stack 4 -25.90386 28.37975 12.00 4.00 0.15 60 501.94 11.30 24 Hours Continuous
AS1
Alternative
Scrubber
Stack 1
-25.90612 28.03001 12.00 4.00 0.15 60 501.94 11.30 24 Hours Continuous
AS2
Alternative
Scrubber
Stack 2
-25.90612 28.03001 12.00 4.00 0.15 60 501.94 11.30 24 Hours Continuous
AS3
Alternative
Scrubber
Stack 3
-25.90612 28.03001 12.00 4.00 0.15 60 501.94 11.30 24 Hours Continuous
AS4
Alternative
Scrubber
Stack 4
-25.90612 28.03001 12.00 4.00 0.15 60 501.94 11.30 24 Hours Continuous
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Table 10-11: Point Source Maximum Emission Rates (normal operating conditions)
Point Source
Code Pollutant Name Chemical Symbol
Maximum Release Rate
Duration of
Emissions (mg/Nm³)
Date to be
Achieved By
Average
Period
SS1 – SS4,
AS1 – AS4
Particulate matter PM 10 Immediate 24 Hours Continuous
Carbon monoxide CO 50 Immediate 24 Hours Continuous
Sulphur dioxide SO2 50 Immediate 24 Hours Continuous
Oxides of Nitrogen NOx as NO2 200 Immediate 24 Hours Continuous
Hydrogen chloride HCl 10 Immediate 24 Hours Continuous
Hydrogen fluoride HF 0.5 Immediate 24 Hours Continuous
Sum of Lead, arsenic, antimony,
chromium, cobalt, copper,
manganese, nickel, vanadium
Pb +As+ Sb + Cr +
Co + Cu + Mn+ Ni
+ V
0.05 Immediate 24 Hours Continuous
Mercury Hg 0.05 Immediate 24 Hours Continuous
Cadmium Thallium Cd TI 0.05* Immediate 24 Hours Continuous
Total organic compounds TOC 10 Immediate 24 Hours Continuous
Ammonia NH3 10 Immediate 24 Hours Continuous
Poly Aromatic Hydrocarbons PAH 0.1 Immediate 24 Hours Continuous
Dioxins and furans PCDD/PCDF ng I-TEQ /Nm3
Immediate 24 Hours Continuous 0.1
* Although the limit for Cadmium and Thallium is listed as 10 mg/Nm3 under this activity in GN 893 of 2013 as amended, all other waste
related activities within GN893 of 2013 as amended list the limit as 0.05 mg/Nm3. It was assumed that the applicable limit for Cadmium
and Thallium is 0.05 mg/Nm3.
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The emissions quantification and subsequent prediction of ambient impact have been
undertaken with conservativeness, with the effect that the modelled outcomes relating
to emissions from the site are expected to be over-predictions. The modelling further
does not account for wet deposition of the pollutants, thus further over-predicting
atmospheric concentrations.
Two scenarios were modelled:
i. Scenario 1 – All proposed sources modelled at the preferred site location
minimum emission standards for the applicable regulated emissions per source
as stipulated by Subcategory 3.4 and Subcategory 8.1 in GN893:2013, as
amended; and,
ii. Scenario 2 - All proposed sources modelled at the alternative site location
minimum emission standards for the applicable regulated emissions per source
as stipulated by Subcategory 3.4 and Subcategory 8.1 in GN893:2013, as
amended.
11.2.3.2 IMPACT DISCUSSION & SIGNIFICANCE ASSESSMENT - SCENARIO 1:
PREFERRED LOCATION EMISSIONS
It is important to note that this scenario evaluates the potential impact of Industrial Green
Energy Solutions operating all its’ proposed sources at the maximum allowable emissions
rates on a continuous basis of 24h a day for 365 a year. This is in fact an exaggeration of
the actual impact of operating at the maximum allowable emission rates the sources do
not have 100% uptime, and actual emissions vary. However, it demonstrates the worst
case permitted emissions scenario and gives insight into the worst case impact that
would occur if the site operated at the very limit of compliance with the emissions
regulations.
PARTICULATE MATTER PM10 - 24 HOUR
The predicted impact from the operations is well within the NAAQS limit of 75 µg/m3 for
the 24-hour averaging interval (Figure 10-4).
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Figure 10-4: Scenario 1 Predicted PM10 24-Hour maximum modelled ambient
concentration.
PM10 - ANNUAL
Predicted maximum ambient concentrations of PM10 from the proposed operations are
well within the annual ambient air quality limit, 40 µg/m³.
PM2.5 - 24 HOUR
The predicted impact from the operations is well within the NAAQS limit of 40 µg/m3 for
the 24-hour averaging interval (Figure 10-5).
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Figure 10-5: Scenario 1 Predicted PM2.5 24-Hour maximum modelled ambient
concentration.
PM2.5 - ANNUAL
Predicted maximum ambient concentrations of PM2.5 from the proposed operations are
well within the annual ambient air quality limit, 20 µg/m³.
SULPHUR DIOXIDE 1-HOUR
The predicted impact from the operations is well within the NAAQS limit of 350 µg/m3 for
the 1-hour averaging interval (Figure 10-6).
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Figure 10-6: Scenario 1 Predicted SO2 1-Hour maximum modelled ambient
concentration.
24-HOUR
Predicted maximum ambient concentrations of SO2 from the proposed operations are
within the 24-hour limit, 125 µg/m³.
ANNUAL
Predicted maximum ambient concentrations of SO2 from the proposed operations are
within the annual limit, 50 µg/m³.
NITROGEN DIOXIDE 1-HOUR
The predicted impact from the operations is within the NAAQS limit of 200 µg/m3 for the
1-hour averaging interval (Figure 10-7).
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Figure 10-7: Scenario 1 Predicted NO2 1-Hour maximum modelled ambient
concentration.
ANNUAL
Predicted maximum ambient concentrations of NO2 from the proposed operations are
within the annual limit, 40 µg/m³.
HEXAVALENT CHROMIUM 1-HOUR
The maximum predicted 1-hour ambient concentrations from the operations are within
the Alberta state and Manitoba state 1-hour limits of 1 µg/m3 and 4.5 µg/m3, respectively.
PREDICTED LIFETIME CARCINOGENIC RISK USING THE WHO RFC
Figure 10-8 shows the predicted excess lifetime carcinogenic risk resulting from the
maximum anticipated emissions from the plant, based on the WHO recommendations
for linear dose-response relationships between exposure to Cr(VI) compounds and lung
cancer.
As noted in the Air Quality Impact Assessment Report life time exposure risk ratings have
been adopted in this study with 1 in 10 000 as the maximum tolerable risk to the public
and any lesser risk being deemed to be within the de minimis range.
The predicted lifetime carcinogenic risk factor for a small area within the Limeroc Business
Park and Centurion Flight Academy is 1 in 330 000. Extending over the immediate
surrounds of the site there is a lifetime carcinogenic risk in the order of 1 in 500 000. No
residential areas are predicted to be exposed to a risk greater than 1 in 1 000 000.
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Figure 10-8: Scenario 1 Predicted Cr(VI) lifetime carcinogenic risk with WHO RfC.
The cancer risk range that is deemed acceptable in various parts of the world is from 1
in 10 000 to 1 in 1 000 000. This risk range reflects a de minimis lifetime risk that is so trivial
that any action to reduce risk is not warranted (Kocher and Hoffman, 1994).
To put this into context for South Africa, it must be noted that the overall (background)
cancer risk for South Africans in 2009 was 1 in 8 for men and 1 in 9 for women.
PREDICTED LIFETIME CARCINOGENIC RISK USING THE US EPA RFC
The predicted lifetime carcinogenic risk resulting from the maximum anticipated
emissions from the plant, based on the US EPA recommendations for linear dose-
response relationships between exposure to Cr(VI) compounds and lung cancer, within
the proximity of the Limeroc Business Park and the immediate surrounds of the site is in
the order of 1 in 1 000 000.
The cancer risk range that is deemed acceptable in various parts of the world is from 1
in 10 000 to 1 in 1 000 000. This risk range reflects a de minimis lifetime risk that is so trivial
that any action to reduce risk is not warranted (Kocher and Hoffman, 1994).
To put this into context for South Africa, it must be noted that the overall (background)
cancer risk for South Africans in 2009 was 1 in 8 for men and 1 in 9 for women.
POLYCYCLIC AROMATIC HYDROCARBONS PREDICTED LIFETIME CARCINOGENIC RISK
The maximum predicted lifetime exposure carcinogenic risk from cumulative PAH
emissions for scenario 1 is estimated to be 1 in 1 025 299.
A risk of 1 in 1 000 000 or lower is defined as an ‘acceptable risk’ at which no further
improvements in safety need to be made.
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To put this into context for South Africa, it must be noted that the overall (background)
cancer risk for South Africans in 2009 was 1 in 8 for men and 1 in 9 for women.
METALS AND OTHER POLLUTANTS
Apart from lead (Pb) and Carbon Monoxide (CO) no ambient air quality standards have
been set in South Africa for the metals and other pollutants with emission limits for
Subcategory 8.1. Therefore, international guidelines have been used to assess the
impact of the predicted concentrations on ambient air quality. The predicted ambient
concentrations for all relevant pollutants are well within international standards as shown
in Table 10-12
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Table 10-12: Metals and other pollutants
Name Symbol Modelled Emission
Limits (mg/Nm³)
Ambient Air Quality
Limit (μg/m³)
Predicted Maximum Ambient
Concentration (μg/m³)
Averagin
g time
Country /
agency
Thallium Tl 0.05 0.1 0.0002 Annual Michigan
Cadmium Cd 0.05 0.025 0.0017 24 h Ontario
0.005 0.0002 Annual Ontario
Carbon Monoxide CO 50 30 000 7.4892 1 h SA
10 000 2.9957 8 hr SA
Ammonia NH3 10
350 1.4978 1 h Michigan
100 0.3319 24 h Ontario
8 0.0608 Annual New Zealand
Antimony Sb 0.05 25 0.0017 24 h Ontario
Arsenic As 0.05 0.3 0.0017 24 h Ontario
Chromium Cr 0.05 0.5 0.0017 24 h Ontario
0.11 0.0017 Annual New Zealand
Cobalt Co 0.05 0.1 0.0017 24 h Ontario
Copper Cu 0.05 50 0.0017 24 h Ontario
Lead Pb 0.05 0.5 0.0002 Annual SA
Manganese Mn 0.05 2.5 0.0017 24h Ontario
0.15 0.0002 Annual WHO
Nickel Ni 0.05 0.2 0.0017 24 h Ontario
0.04 0.0002 Annual Ontario
Vanadium V 0.05 1 0.0017 24 h WHO
Mercury Hg 10 2 0.0017 24 h Ontario
1 0.0002 Annual WHO
Hydrochloric acid HCl 10 75 1.4964 1 h UK
20 0.3315 24 h Ontario
Hydrofluoric acid HF 10 16 0.0749 1 h UK
0.86 0.0166 24 h Ontario
Dioxins/furans PCCD/
PCDF
ng I-TEQ/Nm³ pg I-TEQ/Nm³
0.1 0.1 0.000003 24h Ontario
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11.2.3.3 IMPACT DISCUSSION & SIGNIFICANCE ASSESSMENT - SCENARIO 2:
ALTERNATIVE LOCATION EMISSIONS
It is important to note that this scenario evaluates the potential impact of Industrial Green
Energy Solutions operating all its’ proposed sources at the maximum allowable emissions
rates on a continuous basis of 24h a day for 365 a year. This is in fact an exaggeration of
the actual impact of operating at the maximum allowable emission rates the sources do
not have 100% uptime, and actual emissions vary. However, it demonstrates the worst
case permitted emissions scenario and gives insight into the worst case impact that
would occur if the site operated at the very limit of compliance with the emissions
regulations.
PARTICULATE MATTER PM10 - 24 HOUR
The predicted impact from the operations is well within the NAAQS limit of 75 µg/m3 for
the 24-hour averaging interval (Figure 10-9).
Figure 10-9: Scenario 2 Predicted PM10 24-Hour maximum modelled ambient
concentration.
PM10 - ANNUAL
Predicted maximum ambient concentrations of PM10 from the proposed operations are
well within the annual ambient air quality limit, 40 µg/m³.
PM2.5 - 24 HOUR
The predicted impact from the operations is well within the NAAQS limit of 40 µg/m3 for
the 24-hour averaging interval (Figure 10-10).
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Figure 10-10: Scenario 2 Predicted PM2.5 24-Hour maximum modelled ambient
concentration.
PM2.5 - ANNUAL
Predicted maximum ambient concentrations of PM2.5 from the proposed operations are
well within the annual ambient air quality limit, 20 µg/m³.
SULPHUR DIOXIDE 1-HOUR
The predicted impact from the operations is well within the NAAQS limit of 350 µg/m3 for
the 1-hour averaging interval (Figure 10-11).
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Figure 10-11: Scenario 2 Predicted SO2 1-Hour maximum modelled ambient
concentration.
24-HOUR
Predicted maximum ambient concentrations of SO2 from the proposed operations are
within the 24-hour limit, 125 µg/m³.
ANNUAL
Predicted maximum ambient concentrations of SO2 from the proposed operations are
within the annual limit, 50 µg/m³.
NITROGEN DIOXIDE 1-HOUR
The predicted impact from the operations is within the NAAQS limit of 200 µg/m3 for the
1-hour averaging interval (Figure 10-12).
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Figure 10-12: Scenario 2 Predicted NO2 1-Hour maximum modelled ambient
concentration.
ANNUAL
Predicted maximum ambient concentrations of NO2 from the proposed operations are
within the annual limit, 40 µg/m³.
HEXAVALENT CHROMIUM 1-HOUR
The maximum predicted impact from the operations are within the Alberta state and
Manitoba state 1-hour limits of 1 µg/m3 and 4.5 µg/m3, respectively.
PREDICTED LIFETIME CARCINOGENIC RISK USING THE WHO RFC
Figure 10-13 shows the predicted excess lifetime carcinogenic risk resulting from the
maximum anticipated emissions from the plant, based on the WHO recommendations
for linear dose-response relationships between exposure to Cr(VI) compounds and lung
cancer.
As noted in the Air Quality Impact Assessment Report life time exposure risk ratings have
been adopted in this study with 1 in 10 000 as the maximum tolerable risk to the public
and any lesser risk being deemed to be within the de minimis range.
The predicted lifetime carcinogenic risk factor for a small area within the Limeroc Business
Park is 1 in 1 000 000. Extending over the immediate surrounds of the site there is a lifetime
carcinogenic risk in the order of 1 in 1 000 000. No residential areas are predicted to be
exposed to a risk greater than 1 in 1 000 000.
To put this into context for South Africa, it must be noted that the overall (background)
cancer risk for South Africans in 2009 was 1 in 8 for men and 1 in 9 for women.
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Figure 10-13: Scenario 2 Predicted Cr(VI) lifetime carcinogenic risk with WHO RfC.
PREDICTED LIFETIME CARCINOGENIC RISK USING THE US EPA RFC
The predicted lifetime carcinogenic risk resulting from the maximum anticipated
emissions from the plant, based on the US EPA recommendations for linear dose-
response relationships between exposure to Cr(VI) compounds and lung cancer, within
the proximity of the Limeroc Business Park and the immediate surrounds of the site is in
the order of 1 in 1 000 000.
The cancer risk range that is deemed acceptable in various parts of the world is from 1
in 10 000 to 1 in 1 000 000. This risk range reflects a de minimis lifetime risk that is so trivial
that any action to reduce risk is not warranted (Kocher and Hoffman, 1994).
To put this into context for South Africa, it must be noted that the overall (background)
cancer risk for South Africans in 2009 was 1 in 8 for men and 1 in 9 for women.
POLYCYCLIC AROMATIC HYDROCARBONS PREDICTED LIFETIME CARCINOGENIC RISK
The maximum predicted lifetime exposure carcinogenic risk from cumulative PAH
emissions for scenario 2 is estimated to be 1 in 4 166 587.
A risk of 1 in 1 000 000 or lower is defined as an ‘acceptable risk’ at which no further
improvements in safety need to be made.
To put this into context for South Africa, it must be noted that the overall (background)
cancer risk for South Africans in 2009 was 1 in 8 for men and 1 in 9 for women.
METALS AND OTHER POLLUTANTS
Apart from lead (Pb) and Carbon Monoxide (CO) no ambient air quality standards have
been set in South Africa for the metals and other pollutants with emission limits for
Subcategory 8.1. Therefore, international guidelines have been used to assess the
impact of the predicted concentrations on ambient air quality. The predicted ambient
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concentrations for all relevant pollutants are well within international standards as shown
in Table 10-13
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Table 10-13: Metals and other pollutants
Name Symbol Modelled Emission
Limits (mg/Nm³)
Ambient Air Quality
Limit (μg/m³)
Predicted Maximum Ambient
Concentration (μg/m³)
Averagin
g time
Country /
agency
Thallium Tl 0.05 0.1 0.0002 Annual Michigan
Cadmium Cd 0.05 0.025 0.0017 24 h Ontario
0.005 0.0002 Annual Ontario
Carbon Monoxide CO 50 30 000 7.4892 1 h SA
10 000 2.9957 8 hr SA
Ammonia NH3 10
350 1.4978 1 h Michigan
100 0.3319 24 h Ontario
8 0.0608 Annual New Zealand
Antimony Sb 0.05 25 0.0017 24 h Ontario
Arsenic As 0.05 0.3 0.0017 24 h Ontario
Chromium Cr 0.05 0.5 0.0017 24 h Ontario
0.11 0.0017 Annual New Zealand
Cobalt Co 0.05 0.1 0.0017 24 h Ontario
Copper Cu 0.05 50 0.0017 24 h Ontario
Lead Pb 0.05 0.5 0.0002 Annual SA
Manganese Mn 0.05 2.5 0.0017 24h Ontario
0.15 0.0002 Annual WHO
Nickel Ni 0.05 0.2 0.0017 24 h Ontario
0.04 0.0002 Annual Ontario
Vanadium V 0.05 1 0.0017 24 h WHO
Mercury Hg 10 2 0.0017 24 h Ontario
1 0.0002 Annual WHO
Hydrochloric acid HCl 10 75 1.4964 1 h UK
20 0.3315 24 h Ontario
Hydrofluoric acid HF 10 16 0.0749 1 h UK
0.86 0.0166 24 h Ontario
Dioxins/furans PCCD/
PCDF
ng I-TEQ/Nm³ pg I-TEQ/Nm³
0.1 0.1 0.000003 24h Ontario
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11.2.3.4 RECOMMENDATIONS
Based on the results above, and in cognisance of both the limitations and conservative
over-predictions, it is concluded that environmental authorisation and related Atmospheric
Emissions Licence be granted for the operations. The emissions limits listed in the Minimum
Emission Standards as stipulated in GN 893:2013 must be met.
11.2.4 REDUCTION IN WASTE DISPOSAL TO LANDFILL
11.2.4.1 Introduction
Plastic and other municipal solid waste that is currently being disposed of to landfill will be
utilised as the primary material for the gasification process. The impacts that are assessed
here are those that arise from a reduction in the waste being disposed of at municipal
landfills and waste management facilities.
11.2.4.2 Impact Discussion & Significance Assessment
Table 10-14: Waste reduction impact (Operation)
Nature (N) Positive impact -0.25
Extent (E) Municipal: operations will reduce waste disposed to
municipal landfills 3
Duration (D)
Very Long Term: Waste diverted from landfill will be
permanently diverted from landfill. Operations are
expected to last longer than 10 years
5
Intensity (I)
Negligible: Activities are expected to process negligible
amounts of waste (50 tons per day) in comparison to the
amount waste processed on a municipal level.
1
Probability (P) Definite: General waste will be processed. 4
Enhancement (H) None 1
Significance Rating
-Positive Impact (S) N x (E+D) x I x P x (H). Positive (Negligible) -8
11.2.4.3 Enhancement
None.
11.2.5 SOCIO-ECONOMIC – PROVISION OF EMPLOYMENT
11.2.5.1 Introduction
It is envisaged that the plant will employ approximately 11 people during operations.
11.2.5.2 Impact Discussion & Significance Assessment
The impact will be of a minor intensity and will have a municipal extent. Although new
employment will be created, a minimal amount of unskilled labour will be required. Effective
enhancement, in the form of the proponent making a concerted effort to employ workers
from the surrounding areas, can be applied.
Table 10-15: Impacts on Socio-economics (Operation)
Nature (N) Positive – operation of the site and the continuation of other
existing economic activity and employment -0.25
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Table 10-15: Impacts on Socio-economics (Operation)
Extent (E) Municipality: Expected to have an impact at a municipal
extent 3
Duration (D) Very long term: Operations are expected to last longer than
10 years 5
Intensity (I) Minor: Although employment will be created this will not
significantly alter the employment situation of the
surrounding environment
2
Probability (P) Definite: Proposed development will require new staff 4
Enhancement (H) Slight enhancement, in the form of the proponent making a
concerted effort to employ workers from the surrounding
areas, can be applied
2
Significance
Rating -Positive
Impact (S)
N x (E+D) x I x P x (H).
Positive (Moderate) -32
11.3 POTENTIAL IMPACTS – DECOMMISSIONING PHASE
Due to the plant being located in an area zoned for industrial use, it is not anticipated that
the site will require rehabilitation in order to restore an undisturbed state. The
decommissioning of the plant is expected to entail the dismantling and / or demolishing of
the plant infrastructure, the potential impacts of which are assessed below.
If decommissioning were to take place it would entail dismantling of the infrastructure for
sale and / or recycling as well as the potential demolition of the existing buildings. If
decommissioning were to occur it is envisaged that the decommissioning period would last
no longer than 3 months, due to the relatively small size of the facility and small amount of
infrastructure to be removed. The potential impacts of these activities are therefore
considered to be similar to that of the construction phase.
11.3.1 SOIL AND GROUNDWATER QUALITY
11.3.1.1 Introduction
Spills or inappropriate storage, management and handling of fuels and other potentially
dangerous substances could result in negative impacts on soil and groundwater quality;
where spillages of such substances could enter the soil and / or groundwater environment
through the infiltration of contaminated surface run-off.
11.3.1.2 Impact Discussion & Significance Assessment
Table 10-16: Impacts on soil and groundwater quality (Decommissioning)
Nature (N) Negative impact on groundwater 1
Extent (E) Locally: groundwater can be affected outside of the
site boundary 2
Duration (D) Medium term: If contaminant does enter groundwater
it could be present for 1-2 years. 3
Intensity (I) Moderate: If contaminant enters the groundwater, the
environment is altered. 3
Probability (P) Unlikely: The probability of contaminant entering soil or
even groundwater is low as fuel is to be stored in a
bunded area.
1
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Table 10-16: Impacts on soil and groundwater quality (Decommissioning)
Mitigation (M) Impact can be mostly mitigated e.g. by placing drip
trays under vehicles and storing fuel in bunded areas. 4
Reversibility (R) Slight: Groundwater remediation is possible but is a very
costly and lengthy process 2
Significance Rating
without Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R)
Low 15
Significance Rating
with Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R)
Negligible 5
11.3.1.3 Mitigation / Management
The following measures should be put in place to prevent groundwater pollution:
• Ensure that storage of dangerous goods takes place over an impermeable surface
within a bunded area.
• If vehicle and / or construction machinery maintenance is to occur onsite, a suitable
leak proof container for the storage of oiled equipment (filters, drip tray contents and
oil changes etc.) must be established.
• Hazardous substances such as fuel and oil must be stored within appropriately sized,
impermeable, bund walls, with the appropriate warning signage.
• Spill kits to be readily available at all points where hazardous substances will be
stored and / or transferred (e.g. refuelling points);
• In the instance that a spill occurs, this should be dealt with in line with the EMPr.
• All vehicles, equipment, fuel and petroleum services and tanks must be maintained
in a condition that prevents leakage and possible contamination of soil or water.
Refuelling areas must be bunded and secured to prevent soil and water
contamination.
• Where possible building materials are to be prepared at the batching plant, to
enable the effects of cement and other substances, and the resulting effluent to be
more easily managed.
11.3.2 NOISE
11.3.2.1 Introduction
Significant noise generation from the decommissioning is not expected. Decommissioning
is expected to occur within normal working hours, the noise generation is not expected to
have any significant impact and is expected to be in accordance with the locally
applicable by-laws.
11.3.2.2 Impact Discussion & Significance Assessment
Noise during decommissioning activities of proposed infrastructure and equipment is
expected to have no significant impact outside of the site provided that the recommended
mitigatory measures are implemented.
Table 10-17: Noise impacts (Decommissioning)
Nature (N) Negative impact: Decommissioning related activities
to be limited to normal working hours, in accordance
with locally applicable by-laws.
1
Extent (E) Locally: Localised to the site and immediate
surrounds
2
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Table 10-17: Noise impacts (Decommissioning)
Duration (D) Short term: Decommissioning activities not expected
to take longer than 3 months
2
Intensity (I) Minor: The facility is within a built-up urban area. Noise
generation is expected to be minimal. 2
Probability (P) Very Likely: It is very likely that noise will be generated
to an extent that mitigation measures should be
considered
4
Mitigation (M) Well mitigated: To be limited to normal working hours,
in accordance with locally applicable by-laws. 4
Reversibility (R) Mostly Reversible: The status quo will return to the
previous status quo upon completion. 4
Significance Rating
without Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R) Low 16
Significance Rating
with Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R) Negligible 8
11.3.2.3 Mitigation / Management
• Use of construction vehicles, and activities, which may create a disturbing noise
must be undertaken during typical business hours in accordance with locally
applicable by-laws during the week. These activities must be avoided as far as is
practical during night-time and weekends.
• A complaints register shall be maintained and kept at reception in order to record
complaints of noise and / or odour.
11.3.3 WASTE GENERATION, HANDLING AND DISPOSAL
11.3.3.1 Introduction
Construction waste will largely consist of non-hazardous / general waste, it is expected 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 a waste
disposal facility, through the permanent occupation of remaining available airspace at
such a facility. Recyclable materials such as steel should be separated and recycled.
11.3.3.2 Impact Discussion & Significance Assessment
Table 10-18: Waste generation impact (Decommissioning)
Nature (N) Indirect negative impact on landfill airspace
availability. 1
Extent (E) Municipal: Use of airspace that would otherwise be
available to other uses in the municipality. 3
Duration (D) Very Long term: Waste generated will be disposed of
at a landfill. 5
Intensity (I) Negligible: The anticipated impact will be negligible,
with a very little effect on relative airspace
availability.
1
Probability (P) Definite: Waste will be produced. 4
Mitigation (M) Moderately mitigated through re-use and recycling 3
Reversibility (R) Reversible: The status quo will return upon completion
of the construction. 4
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Table 10-18: Waste generation impact (Decommissioning)
Significance Rating
without Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R) Low 16
Significance Rating
with Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R) Negligible 9
11.3.3.3 Mitigation / Management
• Recyclable materials such as steel should be separated and recycled.
• Adequate Bins and / or skips must be provided on the site to provide for general
waste. Waste sorting must be done at source or within a dedicated area.
Undesired or non-recyclable waste must be collected by an appropriate waste
management service provider.
• All waste must be stored in compliance with the Norms and Standards set out in
GN926 National Environmental Management: Waste Act (59 / 2008): National
norms and standards for the storage of waste.
• Waste management practices must adhere to the regulations set out in GN.R634
National Environmental Management: Waste Act (59 / 2008): Waste Classification
and Management Regulations.
• All waste and storage areas must be clearly demarcated and maintained.
11.3.4 AIR QUALITY – DUST GENERATION
11.3.4.1 Introduction
During decommissioning, it is not anticipated that rehabilitation will be required. Dust
generation would potentially come from the potential demolition of buildings.
11.3.4.2 Impact Discussion & Significance Assessment
Table 10-19: Air Quality – Dust Generation (decommissioning)
Nature (N) Negative impact on ambient air quality. 1
Extent (E) Locally: Localised to the site and immediate
surrounds
2
Duration (D) Short Term: decommissioning phase is not
anticipated to be more than 6 months 2
Intensity (I) Minor: Natural processes or functions will hardly be
affected 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) Well mitigated: Effective dust suppression methods
readily available 4
Reversibility (R) Reversible: The status quo will return upon completion
of the decommissioning phase 4
Significance Rating
without Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R) Negligible 8
Significance Rating
with Mitigation -
Negative Impact (S)
N x (E+D) x I x P ÷ ½(M+R) Negligible 4
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11.3.4.3 Mitigation / Management
The Proponent is to institute effective dust suppression measures on all un-surfaced access
roads for the duration of the decommissioning phase.
11.4 NO-GO ALTERNATIVE
The no-go option refers to the alternative of the proposed project not going ahead at all.
The baseline status quo would be maintained in this case, which would result the continued
disposal of waste to landfill, as well as perpetuate continued reliance on fossil fuels.
Considering that the negative impacts of the proposed facility are low and negligible, and
there are some positive impacts the no-go alternative is deemed an undesirable
alternative.
It must be noted that the site is an existing site in an established industrial park, thus the
refusal of this application would most likely result in the site being used by another industrial
activity in the future (whether or not by this proponent) due to its location, zoning and
access to established industrial services such as water supply, roads, electrical supply,
sewage and other infrastructure. The environmental impact of this future activity cannot be
predicted.
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12. CONCLUSION
12.1 SUMMARY OF ENVIRONMENTAL IMPACTS
A summary of the impact assessment is presented in Table 12-1. The impacts of the proposed
facility, with mitigation are all anticipated to be negligible or acceptable.
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Table 12-1: Impact Summary
Impact
( - / +)
Impact significance without
mitigation
Impact significance with
mitigation
Construction phase:
Potential impacts on soil and groundwater quality
during construction - Low Negligible
Noise generation during construction activities. - Low Negligible
Waste generation during construction of infrastructure. - Low Negligible
Dust generation during construction activities. - Negligible Negligible
Archaeological and cultural impacts - No impact (refer to section 0)
Operational phase:
Potential impacts on groundwater quality during
operations - Moderate Negligible
Potential impacts on soil during operations - Negligible Negligible
Noise - Low Negligible
Air Quality Low to negligible (refer to section 9.1)
Reduction of waste to landfill + Positive (Negligible)
Socio-Economic - Job creation + Positive (Moderate)
Decommissioning Phase
Potential impacts on surface and groundwater quality
during construction - Low Negligible
Noise generation during decommissioning activities. - Low Negligible
Waste generation during decommissioning of
infrastructure. - Low Negligible
Dust generation during decommissioning activities. - Negligible Negligible
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12.2 IMPACT MANAGEMENT MEASURES FROM SPECIALIST STUDIES
12.2.1 AIR QUALITY IMPACT ASSESSMENT
The emissions limits listed in the Minimum Emission Standards as stipulated in GN 893:2013
must be met.
Stack monitoring must be undertaken as per the conditions of the atmospheric emissions
licence.
12.2.2 ARCHAEOLOGICAL IMPACT ASSESSMENT
No heritage finds of any significance were identified in the impact footprint of the
development. Therefore, regarding the visible cultural heritage, there are no
recommendations put forward.
However, developers should be cognisant of the possibility that once development
commences, cultural heritage buried underground may be exposed. Should this occur, the
development in the vicinity of the find should be halted and a specialist must be consulted
to examine the finds.
12.3 CONDITIONAL FINDINGS TO BE INCLUDED AS CONDITIONS OF
AUTHORISATION
The conditional findings that are recommended to be included as conditions of the
authorisation include:
• Comply with the conditions set out as part of the EMPr (Appendix 5).
• The emissions limits listed in the Minimum Emission Standards as stipulated in GN
893:2013 must be met.
• Stack monitoring must be undertaken as per the conditions of the atmospheric
emissions licence.
12.4 DESCRIPTION OF ASSUMPTIONS, UNCERTAINTIES AND GAPS IN
KNOWLEDGE
Given the nature and scale of the project, there are no significant gaps in knowledge or
major assumptions that have been made and the conclusions of this basic assessment are
based on the information reported within this Basic Assessment Report.
12.5 EAP RECOMMENDATION
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 revealed that the potential
impacts can be adequately addressed through appropriate management measures.
It is the professional opinion of the EAP that the process undertaken for the application to
date has been procedurally correct, in terms of, inter alia, the requirements outlined in
the National Environmental Management Act, 1998 (Act No. 107 of 1998) (“NEMA”) and
the EIA Regulations, 2014 (as amended).
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The EAP, furthermore, believes that any significant impacts that may be caused by the
facility have indeed been identified to the extent possible / practical and to a large extent
these impacts can be well mitigated through adequate environmental management.
The EAP also believes that the information provided in this Basic Assessment Report is
sufficient / substantive for IAPs to contribute meaningfully to the process 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.
It must be noted that the proposed location for the site is zoned for industrial use. Therefore,
the refusal of this application would most likely result in the site being used by another
industrial activity in the future (whether or not by this proponent) due to its location, zoning
and access to established industrial services such as water supply, roads, electrical supply,
sewage and other infrastructure. The environmental impact of this future activity cannot be
predicted.
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13. DECLARATION BY EAP
[Declaration to be signed in final report]
EScience Associates (Pty) Ltd, as the Environmental Assessment Practitioner, led by Abdul
Ebrahim hereby affirms that:
• The information herein is true and correct to the best of our knowledge;
• The EAP has kept a register of all interested and affected parties that participated in
a public participation process;
• The EAP has ensured that information containing all relevant facts in respect of the
application is distributed or made available to interested and affected parties and
the public and that participation by interested and affected parties has been
facilitated in such a manner that all interested and affected parties have been
provided with a reasonable opportunity to participate and to provide comments on
documents that are produced to support the application;
• The EAP has included all comments and inputs made by stakeholders and interested
and affected parties as well as the competent authority. Responses to comments
are appended to this Environmental Impact Report.
________________________________________
NAME OF EAP
________________________________________ _________________
SIGNATURE OF EAP DATE
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APPENDIX 1: PUBLIC PARTICIPATION DOCUMENTATION
APPENDIX 1.1 PROOF OF ADVERTISEMENTS
Advert and site notice wording
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Proof of Advert – The Star 16 July 2020
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Proof of Advert – Pretoria News 16 July 2020
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Proof of Advert – Fourways Review 31 July 2020
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APPENDIX 1.2 PROOF OF SITE NOTICES
Site notice put up at main security entrance to Limeroc business Park
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Site notice put up at main security entrance to Limeroc business Park
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Site notice put up on fence of preferred site
DRAFT BASIC ASSESSMENT REPORT
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EScience Associates (Pty) Ltd Page 110
Site notice put up on fence of preferred site
DRAFT BASIC ASSESSMENT REPORT
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EScience Associates (Pty) Ltd Page 111
Site notice put up on fence of preferred site
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APPENDIX 1.3 INTERESTED AND AFFECTED PARTIES LIST
Note that some IAP contact details are hidden for public distribution of this document
Surname Name or Initials Organisation / Capacity Email Telephone
Ward Councillors
Applicable Ward
Maas Shane Ward Councillor - Ward 106 (Tshwane) ShaneM@tshwane.gov.za 0829354287
Brink Cilliers Constituency Head (106, 48, 77) cilliers.brink@me.com 0674079701
Surrounding Wards
Wakelin Kingsley Neighbouring Ward Councillor - Ward 48 (Tshwane) ward48.da@gmail.com 0824984356
Cox Sean Neighbouring Ward Councillor - Ward 77 (Tshwane) seanandos@gmail.com 0729290243
Kreusch Sean Neighbouring Ward Councillor - Ward 113 (COJ) sean@kreusch.co.za 0823020315
Kreusch Sean Neighbouring Ward Councillor - Ward 95 (COJ) (Diepsloot)
sean@kreusch.co.za
0823020315
Foley David Neighbouring Ward Councillor - Ward 94 (COJ) david.foley@bcx.co.za 0829025003
Mackenzie Cameron Constituency Head (113, 94, 95) mackenzie@sentinel360.co.za 0836944510
Authorities
Mahlangu Lucas Department of Environment, Forestry and Fisheries: Waste
LMahlangu@environment.gov.za 012 399 9791
Ramaila Pertunia Department of Environment, Forestry and Fisheries: Waste
mpramaila@environment.gov.za 012 399 9910
Baloyi Tiyani Department of Environment, Forestry and Fisheries: Waste
TiBaloyi@environment.gov.za 012 399 9491
Patric City of Tshwane: Environmental Management Service
Patricmp@tshwane.gov.za 082 499 2445 / 012 358 2347
Moatshe Elizabeth City of Tshwane: Air Quality Officer elizabethmoa@tshwane.gov.za 012 358 8714
Mzondi Sanelisiwe City of Tshwane: Air Quality Officer sanelisiwem@tshwane.gov.za 012 358 6777
Ramogotswa William City of Tshwane WilliamRa@tshwane.gov.za
Matlou Marcus City of Tshwane MarcusMa@tshwane.gov.za
Moseta Mmapula City of Tshwane Emergency services:Fire MmapulaM@tshwane.gov.za
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Surname Name or Initials Organisation / Capacity Email Telephone
Godobedzha Tshifhiwa City of Tshwane TshifhiwaG@tshwane.gov.za
072 050 6633/012 358 5599
Mukheli Rudzani City of Tshwane RudzaniM@tshwane.gov.za
079 958 0360/012 358 8731
Ngati Mosili City of Tshwane mosidin@tshwane.gov.za
084 836 1921/012 358 0277
Mthembu Sibusisio Department of Water and Sanitation Mthembusi@dws.gov.za 082 615 4730/012 392 1300
Khwinana Phillimon Department of Water and Sanitation khwinap@dws.gov.za 012 392 1356
National Office Department of Water and Sanitation centralp@dws.gov.za
Baloyi Alice Gauteng Department of Agriculture and Rural Development
Alice.Baloyi@gauteng.gov.za
Malaza Phindy Gauteng Department of Agriculture and Rural Development
Phindy.Malaza@gauteng.gov.za
Mathibeli Palesa Gauteng Department of Agriculture and Rural Development
<PALESA.MATHIBELI@gauteng.gov.za>
Kolisa Mthobeli City of Tshwane: Environment Strategic Executive Director/Infrastructure and community services
MthobeliK@tshwane.gov.za
Neighbouring Property Owners
- - Centurion Flight Academy
Contact details are hidden for public distribution of this
document
- - NAPAJ Property Investment and Development (Limeroc Owner)
- - Bilt Worx - 7158 Hollan Road, Open space 33, Pretoria
Khourie Russel Anthony 7090 Holland Road, Open space 33, Pretoria
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APPENDIX 1.4 PROOF OF DISTRIBUTION OF DRAFT BASIC ASSESSMENT
REPORT TO INTERESTED AND AFFECTED PARTIES
This report constitutes the draft report as distributed to IAPs for comment, proof of distribution
of this report to IAPs for comment will be included in the Final Basic Assessment Report.
DRAFT BASIC ASSESSMENT REPORT
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APPENDIX 1.5 COMMENTS FROM I&APS
This report constitutes the draft report as distributed to IAPs for comment, thus no comments
have been received as of yet. Details of the public participation process undertaken and
a comments and responses report will be included in the Final Basic Assessment Report.
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APPENDIX 2: CV’S OF EAP
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
Surname: Abdul Ebrahim
Date of birth: 07 December 1977
Country of Residency: Republic of South Africa
Position: Director
Key Qualifications: BEng (Hons) Environmental, BEng (Hons) Mechanical
Registrations: ECSA, EAPASA
Contact details
: 011 7186380
: 072 268 1119
: abdul@escience.co.za
Abstract
Abdul Ebrahim is a director of EScience Associates, an environmental consultancy specialising in waste and waste recovery, effluent, atmospheric emissions and air quality, as well as cleaner and renewable energy. EScience Associates caters for a diversity of industries and economic sectors and has forged strong relationships with other specialists, and specialist agencies, allowing the company to deal with complex and contentious environmental problems. Abdul Ebrahim holds a BEng (Hons) in both Mechanical and Environmental Engineering disciplines. He specialises in air quality management, hazardous waste management and cleaner production, as well as their related environmental authorisation and licensing processes. His work experience includes numerous environmental impact assessments, cleaner production, waste recover-recuse-recycling, hazardous waste management assessments, and air quality impact management projects in power generation, manufacturing, minerals processing, and mining industries. His interests range from atmospheric modelling and wind energy, to the beneficial use of industrial wastes and effluents. He is a certified Environmental Assessment Practioner (EAP) and member of amongst other professional organisations: Engineering Council of South Africa (ECSA), and the National Association of Clean Air (NACA). Abdul has provided Honours level lecturing at the University of Pretoria, UNISA, Cape Town University of Technology and various private training institutions in the fields of Environmental Compliance Enforcement, Environmental Impact Assessment, Cleaner Production and Air Quality Management since 2005. His work experience includes:
• Environmental strategic, legal, and technical compliance advisory services
• Environmental Permitting - Environmental Authorisation, Waste Management Licensing, Atmospheric Emissions Licensing, Mine Environmental Management Programme development, and their relating environmental impact assessment and stakeholder engagement processes.
• Air quality management and Air Quality Management Plan development – Emissions quantification; meteorological and air quality modelling and impact assessment; development of emissions abatement and management strategies;
• Waste management consulting - classification, landfill assessment, mine residue liner risk assessments, development of waste minimisation treatment & recycling strategies;
• Development of specialist training courses (including EIA Administration and Review, Environmental Enforcement, Environmental Compliance Achievement for Industry).
• Environmental Due Diligence – due diligence assessment to inform purchase or ownership transfer of existing going concerns or proposed new establishments.
Abdul has 20 years post graduate experience of which four years are in industry, and the remainder in consulting.
Education
BEng (Hons) Mechanical Engineering
BEng (Hons) Environmental Engineering
Languages
English (excellent speaking and writing) Limited French and Portuguese
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
Experience
Personal work experience includes:
• Cleaner and renewable energy strategy development, plan and project development;
• Technical and environmental due diligence – industrial and energy projects
• Waste management (classification, handling, storage, and disposal requirements;
• Development of waste minimisation treatment & recycling strategies);
• Air quality management and emissions inventorying¸ development of abatement and management strategies;
• Environmental Impact Assessment and Permitting
• Development and dissemination of specialist training for government and the private sector at NQF level 7 (honours degree).
Abdul’s work experience in a wide diversity of economic sectors and industries and provides him with a good understanding of both small scale and large scale impacts of waste and pollution, as well as keeping up to date with various management alternatives available and their individual advantages and disadvantages, both locally and internationally implemented and pilot scale. Various waste streams have been dealt with to determine the most applicable disposal methods and impacts on the environment, from various industries:
• Metallurgical processes
• Power generation
• Food processing
• Waste recovery, reuse, and recycling and waste to energy
• Mining
• Cement manufacturing
• General Commercial – General waste management from various industries
Professional Registration
Environmental Assessment Practioner (EAP) Engineering Council of South Africa (ECSA
Hourly Rate
Nature of expertise offered
• Ability to interpret and analyse technical material on wide range of subjects
• Engineering expertise in energy, waste, air quality and multi-disciplinary subjects
• Ability to undertake technology feasibility studies, technical and financial due diligence
• Understanding of the green economy and technologies, ICT and agricultural and agro-processing sectors
• Ability to undertake a market research and investigation into the industry
• Proposal evaluation expertise
Experience and relevant projects
1. AIR QUALITY MANAGEMENT:
1.1 Government & Regulatory
o Vaal Triangle Air-shed Priority Area - Air Quality Management Plan review, development of emissions inventory and Ambient Air Quality Impact Assessment.
o Highveld Priority Area Air Quality Management Plan – development of emissions inventory, and mitigation strategies.
▪ Reference: Dr Thulile Mdluli
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
▪ Tel: 012 310 3436
▪ Email : tmdluli@environment.gov.za
o Ekurhuleni Metropolitan Municipality - Development of an Air Quality Management Plan (AQMP)
▪ Reference: Mr Edmund van Wyk
▪ Tel: 011 999 2470
▪ Email: Edmund.vWyk@ekurhuleni.gov.za
o Nkangala District Municipality - Development of an Air Quality Management Plan (AQMP) ▪ Reference: Mr Vusi Mahlangu
▪ Tel: 013 249 2164
▪ Email: Mahlangumv@nkangaladm.gov.za
o North West Province - development of provincial emissions inventory (PM, NOx, SO2 etc)
o Development of National Air Quality Officers Companion Guide for the Republic of South Africa
o Development of the atmospheric emissions licensing department for Nkangala District Municipality
o EThekwini Municipality (Durban) - Greenhouse gas emissions quantification
o Newcastle Local Municipality - Development of an Air Quality Management Plan (AQMP) ▪ Reference: Mr Phelelani Ntshingila
▪ Tel: 034 328 3300
▪ Phelelani.Ntshingila@newcastle.gov.za
1.2 Industrial and Mining
o A large variety of major industrial and mining operation across the Highveld and Vaal Triangle as part of Highveld Priority Area and Vaal Triangle Air-shed Priority Area AQMP projects.
o Lanxess CISA Chrome Chemicals Plant Expansion, CO2 generation, Power Generation and hazardous waste treatment and recovery
o Samancor Chrome Proposed Chrome Chemicals plant
o Karbochem (Synthetic Rubber Manufacture) proposed Power Generation Plant
o PPC Cement Slurry Cement Plant Expansion
o PPC Cement Jupiter Cement Plant Expansion
o PPC Cement PE Cement Plant Expansion
o PPC Cement Dwaalboom waste heat recovery
o PPC Cement De Hoek, PE, Slurry, and Dwaalboom postponement applications
o Afrisam Cement - Dudfield Environmental Management Programme update.
o ClinX Medical Waste Incineration plant expansion
o Goedemoed organic waste incineration
o AWPP pyrolysis of organic waste
o Interwaste Waste Recovery, Waste to Energy and Waste Incineration plant
o Eskom power generation emissions off-setting
o Hayes Lemmerz SA Aluminium Wheel Manufacturing
o Evraz Highveld Steel and Vanadium proposed Powered Generation - Furnace Off-Gases
o Assmang Ferrochrome and Ferromanganese plants Powered Generation - Furnace Off-Gases
o Resource Generation Proposed Boikarabelo Power Station – coal fired
o Weir Minerals Africa (Isando, Alrode and Heavy Bay Foundries)
o Goedemoed Prison proposed Waste incineration and Landfill
o Consolidated Wire Industries Expansion
o Sylvania Proposed Open Cast PGE Mine and Processing Plant
o Assmang Black Rock proposed manganese mine expansion and sinter plant
o Assmang machadodorp proposed smelter plant expansion and cross-over to manganese
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
o Dwarsrivier Chrome Mine
o Nkwe proposed Platinum Mine
o Agricultural Research Commission hazardous and infectious waste incineration
o Sephaku Aganang proposed use of AFR’s in cement manufacture
o Idwala Phalaborwa atmospheric emission licence for magnetite drying
o Mandini Wealth (Pty) Ltd tyre pyrolysis air quality health risk assessment
o Johnson Tiles a Division of Norcros Sa (Pty) Ltd Air quality health risk assessment
o Lanxess CISA (Pty) Ltd Air quality health risk assessment
o Namakwa Sands, South Africa – Tronox
o Devon Valley Landfill expansion
o Groblersdal limestone mine
2. WASTE CLASSIFICATION, HAZARD RISK ASSESSMENT AND MANAGEMENT
o Weir Minerals Africa
o Heavy Bay foundry Port Elizabeth
o Lafarge Gypsum
o Consolidated Wire Industries
o BPB Gypsum
o PG Bison melamine plant
o ABBW Electrical manufacturing plant
o CBI copper and fibre optical cable manufacture
o Holcim Cement
o Lanxess Chrome Chemicals
o Assmang Chrome
o Assmang Manganese
o Hayes Lemmerz SA Aluminium Wheel Manufacturing
o Auto industrial group (Pty) Ltd
o CBI Electrical
o Various mining residues
3. ENVIRONMENTAL IMPACT ASSESSMENT:
o Assmang Black Rock Mine expansions, tailings facilities, water treatment facilities
o Highveld Steel furnace off-gas power generation
o Lanxess CISA chrome chemicals plant expansion and hazardous waste landfilling
o Samancor chrome chemicals plant development
o Hernic Ferrochrome power generation from furnace off-gases
o Kanhym Biogas project
o Alumicor secondary aluminium recovery rotary salt furnaces
o Hays Lemmerz Aluminium smelters, furnace and alloy die casting
o Agricultural Research Commission hazardous waste incineration plant
o Darkling Metal Industries
o Idwala Lime Danielskuil asbestos waste disposal
o Plettenburg Polo Estates
o PG Bison Decorative Panels
o British Aerospace Land Based OMC Systems
o BPB Gypsum phosphogypsum plant
o Extrupet HPDE and PET recycling plants
o Assmang BRMO
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
o Assmang Machadodorp
o Interwaste waste recovery and waste to energy plants
o PPC Cement expansions, electricity generation, use of alternative fuels and resources
o Sephaku cement use of alternative fuels and resources
o ClinX Healthcare Risk Waste Management
o Turfontein Race Course night racing
4. ENVIRONMENTAL LEGAL COMPLIANCE ASSESSMENT & RECTIFICATION PLANNING:
o SASOL Synfuels
o NATCOS Petrochem
o Dwarsrivier Chrome Mine
o Angloplatinum Base Metals Recovery
o Samancor Hotazel Manganese Mines
o PG Bison (Pty) Ltd MDF manufacturing
o Samancor Manganese Division Samancor Metalloys Meyerton
o Holcim SA (Pty) Ltd Cement Plants: ▪ DUDFIELD ▪ ULCO ▪ ROODEPOORT
o Natal Portland Cement Plants: ▪ NEWCASTLE
o Consolidated Wire Industries
o South African Airways (Pty) Ltd Technical Division
o TWK forestry strategic environmental legal compliance assessment
o Inergy Automotive Systems(Pty) Ltd
o Consolidated Wire Industries
o Mittal Steel Vereeninging and Dunswart plants – specialist assistance to DEAT environmental management inspectors
o Assmang Black Rock Mining Operations
o ClinX Medical Waste Management
o Extrupet PET and HDEP recycling plants
o Scaw Metals High Chromium Ball Plant
o Unilever waste recovery, recycling, and zero waste-to-landfill
o Numerous waste recycling facilities
o Oilflow
o The Smart Company
o Darkling Industrial Metals CC
o Unilever waste recovery, recycling, and zero waste-to-landfill
o Central Waste
o AT Packaging
o EWaste Africa
o Mpact Recycling
o Wasteplan
o Fine Metals
o Living Earth
o Industrial Plastic Recyclers
o SA Paper Mills
o Interwaste
o Matchem
o TGS
o Verigreen
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
o SB Boxes
o Drumpal
o Oscars Meat
o FOSECO South Africa (Pty) Ltd
o
5. GREENHOUSE GAS QUANTIFICATIONS AND ASSESSMENTS
o PPC Riebeeck
o Lafarge Licthenburg
o Ilangabi Investments coal mining
o Lanxess CISA (Pty) Ltd
o Consolidated Wire Industries
o ClinX Waste Management
o ArcelorMittal Newcastle
o Development of emission factors for ferrochrome smelting
6. CLEANER PRODUCTION AUDITS, WASTE TO ENERGY, ENERGY RECOVERY, WASTE RECOVERY AND
RELATED PROJECTS:
o Tuffy Plastics
o Proplas plastics
o WHS Distribution
o Premier Foods Pretoria Wheat Mill
o Alfred Nzou municipality
o Lanxess chrome chemicals residue recovery
o Karbochem power generation ash to bricks project
o Cement kilns alternative fuels and raw materials assessment for South Africa
o Kanhym Estates Biogas Generation from piggery effluent
o British American Tobacco:
o Tobacco Processors Zimbabwe
o Souza Cruz Brazil
7. ENVIRONMENTAL MANAGEMENT SYSTEM DEVELOPMENT & IMPLEMENTATION: ▪ British American Tobacco (full system development from scratch – ISO 14001 and ISO 9001)
o Weir Minerals Aspects Identification, Rating, Assessment and Development of EMPs
o Lafarge Gypsum Aspects Identification, Rating, Assessment and Development of EMPs
o Environmental Aspects Identification, rating and formulation of EMPs for Samancor Metalloys Meyerton
o Environmental Aspects Identification, rating and formulation of EMPs for DMS Powders.
o Holcim Slagment development & implementation of EMS components including waste and air quality management
o Holcim Roodepoort development & implementation of EMS components including waste and air quality management
o Consolidated Wire Industries Environmental Aspects Identification, rating and formulation of EMPs and operational control procedures.
o Samancor Metalloys Ferro Silicon Manganese and FerroSilicon production
o DMS FeSi dense media prodcution
8. ISO14001 AUDITING:
o Debswana Orapa and Letlhakane Mines
o Ingwe Colliery
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
o Arnot Colliery
o FOSECO South Africa (Pty) Ltd
o Lafarge Gypsum
o CWI
9. SPECIALIST TRAINING COURSE DEVELOPMENT & PRESENTATION
o 2011 Training of Atmospheric Emissions Licensing Authorities – air quality management, emissions quantification, regulation and enforcement.
o 2007-2015 Training of Authorities for EIA review and permiting
Responsible for development of NEMA EIA Review Course and Administrators EIA Review Manual, theoretical and
practical training material, and training of Government Officials responsible for EIA Review - responsible for the whole
manual other than Law applicable to EIA Review. As at May 2013 approximately 1000 officials from National,
Provincial and Local Government.
o 2005&6 Bridging Training for Environmental Management Inspectors and Enforcement
ESA was part of a consortium selected to develop and conduct the EMI Training. More than 2000 officials and
university students have completed the training.
o University Of Pretoria Specialist Lecturer
- Environmental Legal Compliance inspections and investigations (RSA)
- Environmental Legal Compliance achievement (RSA)
- Environmental Legal Compliance inspections and investigations (Africa)
o University Of South Africa Specialist Lecturer
- Environmental Legal Compliance inspections and investigations (RSA)
o Training for industry and mining
Development and presentation of training material for environmental impact identification and management in terms
of South African environmental law for the SABS and other training institutions.
10. SOIL AND GROUNDWATER CONTAMINATION ASSESSMENT:
o Weir Heavy Bay Foundry
o Lafarge Gypsum
o Kanhym Estates
o SABAT (Pty) Ltd Johannesburg – investigation of heavy metal contamination of soils and groundwater
o Chemiphos SA (Pty) Ltd – investigation of phosphate and heavy metal contamination of soils and groundwater
o Castrol Lubricants Zimbabwe
11. ENVIRONMENTAL DUE DILIGENCE AUDITS, INCLUDING ASSESSMENT OF ENVIRONMENTAL AND CLOSURE LIABILITY:
o Determination and quantification of financial provision for the environmental rehabilitation and closure requirements of smelting operations for Highveld Steel & Vanadium operations:
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
▪ HIGHVELD IRON AND STEEL WORKS ▪ VANCHEM ▪ TRANSALLOYS ▪ RAND CARBIDE ▪ MAPOCHS MINE
o Determination and quantification of financial provision for the environmental rehabilitation and closure requirements of smelting operations for TransAlloys
o Determination and quantification of financial provision for the environmental rehabilitation and closure requirements of mining operations for Samancor Chrome:
▪ MIDDELBURG FERROCHROME ▪ FERROMETALS ▪ TUBATSE FERROCHROME ▪ WESTERN CHROME MINES ▪ EASTERN CHROME MINES
o Determination of critical environmental liability associated with the purchase of Xmeco Foundry by Weir Minerals Africa, and subsequent legal compliance achievement programme
12.
Possible timelines to commit to the assignment
• Available for assignments over the next two years
• Not available during the December holiday period - from 15 December until 3 January – due to company’s closure for the festive season
Page 1 of 2
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Sam Leyde
Surname: Leyde
Name: Sam
Date of birth: 25 November 1985
Nationality: RSA
Position: Environmental Consultant
Key Qualifications: BSc(hons) Mechanical Engineering
Contact details
: 011 7186380
: sam@escience.co.za
Abstract
Sam Leyde is an employee of EScience Associates, an environmental consultancy specialising in waste and waste recovery, effluent, atmospheric emissions and air quality, as well as cleaner and renewable energy. EScience Associates caters for a diversity of industries and economic sectors and has forged strong relationships with other specialists, and specialist agencies, allowing the company to deal with complex and contentious environmental problems. Sam Leyde holds a BSc (Hons) in Mechanical Engineering. He specialises environmental authorisation and licensing processes. His work experience includes numerous environmental impact assessments, , waste recover-recuse-recycling, waste disposal and classification assessments, and air quality impact management projects in the manufacturing sector. Sam has 8 years post graduate experience of which 7 years are in industry, and the remainder in engineering.
Education
BSc (Hons) Mechanical Engineering
Languages
English (excellent speaking and writing)
Experience
Personal work experience includes:
• Environmental Authorisation, Waste Management Licensing, Atmospheric Emissions Licensing, Environmental Management Programme development, and their relating environmental impact assessment and stakeholder engagement processes.
• Waste management (classification, handling, storage, and disposal requirements, development of waste minimisation treatment & recycling strategies);
• Air Quality Impact Assessments;
• External Environmental Auditing – due diligence assessment to inform purchase or ownership transfer of existing going concerns or proposed new establishments.
Experience and relevant projects
1. ENVIRONMENTAL IMPACT ASSESSMENT:
o EIA for Sephaku Aganang proposed use of AFR’s in cement manufacture
o EIA for PPC Cement Slurry Cement Plant Expansion
o Extrupet HPDE and PET recycling plants
o Assmang Machadodorp Reverse Osmosis Plant and Stormwater Upgrades;
o Interwaste Waste Recovery and Waste to Energy Plant
o ClinX Healthcare Risk Waste Management
Page 2 of 2
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Sam Leyde
Experience and relevant projects
o EIA for proposed Refuse Derived Fuel Energy Recovery Facility, Athlone, Cape Town;
o EIA for proposed pyrolysis of organic/abattoir waste – Square Root Trading Seven, Kroonstad;
o EIA for Interwaste proposed Waste to Energy and Waste Incineration plant;
o EIA Sylvania Proposed Open Cast PGE Mine and Processing Plant;
o EIA for Assmang Machadodorp proposed water treatment plant;
o Basic Assessment for Assmang Machadodorp Storm Water management upgrades;
o Water Use License Application for Assmang Machadodorp Storm Water management upgrades and water treatment facility;
o Water Use Licence for SA Dorper Leather Tannery;
o Oilflow oil blending facility
o The Smart Company Copper melting facility
o Darkling Industrial Metals CC – Scrap Metal Recovery Facility
2. ENVIRONMENTAL LEGAL COMPLIANCE AUDITING & RECTIFICATION PLANNING:
o FFS Refiners, Storage facility Evander 2013 and 2019
o Assmang Black Rock Mining Operations
o ClinX Medical Waste Management
o Extrupet PET and HDEP recycling plants
o Scaw Metals High Chromium Ball Plant
o Oilflow oil blending facility
o The Smart Company Copper melting facility
o Darkling Industrial Metals CC – Scrap Metal Recovery Facility
3. AIR QUALITY MANAGEMENT:
o AQIA for Sephaku Aganang proposed use of AFR’s in cement manufacture
o AQIA for PPC Cement Slurry Cement Plant Expansion
o Lanxess CISA Chrome Chemicals Plant Expansion, CO2 generation, Power Generation and hazardous waste treatment and recovery
o ClinX Medical Waste Incineration plant expansion
o Interwaste Waste Recovery, Waste to Energy and Waste Incineration plant
o Weir Minerals Africa (Isando, Alrode and Heavy Bay Foundries)
o Sylvania Proposed Open Cast PGE Mine and Processing Plant
o Agricultural Research Commission hazardous and infectious waste incineration
o Johnson Tiles a Division of Norcros Sa (Pty) Ltd Air quality health risk assessment
o Proposed pyrolysis of organic/abattoir waste – Square Root Trading Seven, Kroonstad;
4. WASTE CLASSIFICATION, HAZARD RISK ASSESSMENT AND MANAGEMENT
o Weir Minerals Africa
o Wispeco Aluminium
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Tiffany Seema
Name: Tiffany Seema
Date of birth: 03 September 1993
Residency: RSA
Position: Junior Environmental Management Scientist
Key Qualifications: BSc (Hons) Geology, BSc. Geology and Geography
Contact details
: 011 718 6380/ 076 689 4978
: tiffany@escience.co.za
Education
BSc. (Hons) Geology
University of the Witwatersrand: 2015
Thesis Title:
Detrital zircon geochronology and heavy mineral study of the basal conglomerates of the Umkondo Group,
eastern Zimbabwe, with implications for the origin of the Marange diamonds.
Bachelor of Science
University of the Witwatersrand : 2012-2014
Majors: Geology and Geography
Minors: Economics and Energy Resources
Languages
English (Speaking and writing - Excellent) IsiZulu (Speaking and writing - Good)
Sepedi (Speaking - Excellent, Writing – Good)
Work Experience
Junior Environmental Management Consultant (July 2016 – current)
EScience Associates (Pty) Ltd Key experience:
• Data Capturing
• Data input into the National Atmospheric Emissions Inventory System
• Emission Inventories and Calculations
• Compliance Audits (External) and compiling Audit Reports
• Technical and Scientific Report Writing
• Compiling Environmental Licensing and Authorisation applications
• Heading up Public Participation Processes
• Presenter/Speaker at Public Engagements
• Liaison with Authorities
• Basic ArcGIS mapping
• Developing process diagrams
• General administration and project management Intern – Environmental Science (February 2016 – July 2016)
EScience Associates Key tasks: Same as current duties Tutor
University of the Witwatersrand Assisting first years with:
• Rock and mineral identification
• Interpreting geological processes
• Map work
• Report writing
DRAFT BASIC ASSESSMENT REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 117
APPENDIX 3: AUTHORITY CORRESPONDENCE
DRAFT BASIC ASSESSMENT REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 118
APPENDIX 3.1: SUMMARY OF PRE-APPLICATION MEETING WITH DEFF
EScience Associates (Pty) Ltd
Summary of pre-application meeting – Proposed Waste Pyrolysis Facility, Industrial Green Energy
Solutions (Pty) Ltd, Centurion, Gauteng
Purpose Pre-application Meeting - Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
Meeting No. N/A
Venue/Platform
Microsoft Teams Next Meeting N/A
Meeting date 04 August 2020 Start time 15:30 Finish time 16:15
Recorded by Sam Leyde Telephone 011 718 6380 E Mail sam@escience.co.za
Name Initials Representing
In Attendance
Lucas Mahlangu LM Department of Environment Forestry and Fisheries
Abdul Ebrahim AE EScience Associates (Pty) Ltd , Environmental Assessment Practitioner
Sam Leyde SL EScience Associates (Pty) Ltd , Environmental Assessment Practitioner
Apologies None
Absent None
Pre-amble The summary is not necessarily presented in the exact order of discussion, but rather so that topics of discussion are grouped together for ease of reference/review.
EScience Associates (Pty) Ltd
Summary of pre-application meeting – Proposed Waste Pyrolysis Facility, Industrial Green Energy
Solutions (Pty) Ltd, Centurion, Gauteng
Discussion Key Next Steps / Actions / Decision Log
• AE explained project description and asked about applicable listed activities
• LM confirmed that treatment, recovery and recycling are applicable, therefore activities 3, 5, 6 and 12 of Category A are applicable
o Recovery applicable due to the fact that energy will be recovered o Recycling applicable due to the fact that a product will be produced
Activities 3, 5, 6 and 12 of Category A are applicable
• LM asked if any hazardous waste is to be processed. o AE indicated that only non-hazardous waste is to be fed into process; the char to be produced is not
expected to be hazardous.
• LM confirmed that DEFF is the Competent Authority for Waste to Energy Projects
• LM indicated that City of Tshwane must be consulted regarding the designation of a competent authority for the AEL, as it may also be the minister, due to the fact that minister is CA for the WML
EAP to contact City of Tshwane regarding designation of AEL Competent Authority
• AE goes through the specialist studies identified by the DEFF online screening tool, providing motivation for why certain studies have been excluded
• LM indicated that heritage is very important even at late stages of development (such as graves) o AE indicated that specialist have been appointed to assess this
• Public participation Plan was discussed and presented as follows: o Provincial / National Newspaper Advert: The Star 16 July 2020 o Local Newspaper Adverts:
▪ The Pretoria News newspapers on the 16 July 2020 ▪ Fourways Review on 28 July 2020
o Site notices at the main entrance as well as the sidewalk to the main entrance 14 July 2020 o Notification of IAPs, including neighbouring landowners and occupiers, the ward councillor (including
neighbouring wards), the local municipality, the district municipality, the provincial environmental authority, and other stakeholders (such as SAHRA).
o Distribution of draft BAR to IAPs for 30-day comment Period. o Focus group meetings with relevant stakeholders if required, although not anticipated as it is within
an industrial park.
• LM asked if provision will be made for neighbours that may not be able to read? o AE indicated that although the immediate neighbours will be other industries within the industrial park,
we normally work with ward councillors to ensure notification and inclusion of community members.
• LM approved the public participation plan and indicated that when submitting application a note must be included regarding the fact that the PPP Plan was discussed with Lucas Mahlangu and approved.
Public Participation Plan Agreed to by DEFF
• LM indicated that although the gazette of 5 June 2020 gives provision for extension of timeframes due to Covid-19, at this point the timeframes as per the EIA regulations should be adequate
Review timeframes as per EAI Regulations to apply
• It was indicated that application should be emailed to wmlapplication@environment.gov.za, reports to be uploaded to sfiler.
application to be emailed to wmlapplication@environment.gov.za
EScience Associates (Pty) Ltd
Summary of pre-application meeting – Proposed Waste Pyrolysis Facility, Industrial Green Energy
Solutions (Pty) Ltd, Centurion, Gauteng APPENDIX 1: Process Flow Diagram and Locality Map
EScience Associates (Pty) Ltd
Summary of pre-application meeting – Proposed Waste Pyrolysis Facility, Industrial Green Energy
Solutions (Pty) Ltd, Centurion, Gauteng
DRAFT BASIC ASSESSMENT REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 119
APPENDIX 3.2: DEFF ACKNOWLEDGEMENT OF RECEIPT OF APPLICATION
DRAFT BASIC ASSESSMENT REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 120
APPENDIX 4: SPECIALIST STUDIES
DRAFT BASIC ASSESSMENT REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 121
APPENDIX 4.1: AIR QUALITY IMPACT ASSESSMENT
AIR QUALITY IMPACT ASSESSMENT
REPORT:
PROPOSED WASTE PYROLYSIS FACILITY,
INDUSTRIAL GREEN ENERGY SOLUTIONS
(PTY) LTD, CENTURION, GAUTENG
August 2020
ESCIENCE
ASSOCIATES
(PTY) LTD
POSTAL
ADDRESS:
PO Box 2950,
Saxonwold,
2132
Johannesburg
PHYSICAL
ADDRESS:
09 Victoria Street
Oaklands
2192
Johannesburg
TEL:
+27 11 718 6380
FAX:
+27 866 106 703
WEBSITE:
www.escience.co.za
E-MAIL:
info@escience.co.za
Air Quality Impact Assessment
Industrial Green Energy Solutions (Pty) Ltd Waste Pyrolysis Plant, Centurion, Gauteng
EScience Associates (Pty) Ltd Page i
AIR QUALITY IMPACT ASSESSMENT REPORT
PROPOSED WASTE PYROLYSIS FACILITY,
INDUSTRIAL GREEN ENERGY SOLUTIONS (PTY) LTD, CENTURION,
GAUTENG
COMPILED BY:
EScience Associates (Pty) Ltd.
PO Box 2950,
Saxonwold, 2132
9 Victoria Street,
Oaklands, Johannesburg, 2192
Tel: (011) 718 6380
Fax: 086 610 6703
E-mail: info@escience.co.za
ON BEHALF OF APPLICANT:
Industrial Green Energy Solutions (Pty) Ltd
8 Summit Road
Knoppieslaagte 385
Centurion
2196
Tel: (012) 940 3471
August 2020
Air Quality Impact Assessment
Industrial Green Energy Solutions (Pty) Ltd Waste Pyrolysis Plant, Centurion, Gauteng
EScience Associates (Pty) Ltd Page ii
GLOSSARY Glossary of Key Terms adapted from NEMA, NEMAQA and the USEPA
(http://www.epa.gov/ttn/atw/nata/gloss1.html )
Ambient air:
In this assessment, ambient air refers to the air surrounding a person through which
pollutants can be carried.
Background concentrations:
Background concentrations to mean the contributions to outdoor air toxics
concentrations resulting from sources other than the plant of concern, persistence in
the environment of past years' emissions and long-range transport from distant
sources. To accurately estimate outdoor concentrations, it is necessary to account for
the background concentrations by adding them to the modelled concentrations
Dispersion model:
A dispersion model is a computerised set of mathematical equations that uses
emissions and meteorological information to simulate the behaviour and movement
of air pollutants in the atmosphere. The results of a dispersion model are estimated
outdoor concentrations of individual air pollutants at specified locations.
Emission:
“atmospheric emission” or “emission” means any emission or entrainment process
emanating from a point, non-point or mobile source that results in air pollution;
Frequency of Exceedance (FoE)
"frequency of exceedance" means a frequency (number/time) related to a limit
value representing the tolerated exceedance of that limit value at a specific
monitoring station, i.e. if exceedances of limit value are within the tolerances, then
there is still compliance with the standard. This exceedance is applicable to a
calendar year.
Inhalation:
Breathing. Once inhaled, contaminants can be deposited in the lungs, taken into the
blood, or both.
The Inhalation Unit Risk (IUR):
The Inhalation Unit Risk (IUR) is the upper-bound excess lifetime cancer risk estimated
to result from continuous exposure to an agent at a concentration of 1 µg/m³ in air.
The interpretation of inhalation unit risk would be as follows: if unit risk = 2 × 10⁻⁶ per
µg/m³, 2 excess cancer cases (upper bound estimate) are expected to develop per
1,000,000 people if exposed daily for a lifetime to 1 µg of the chemical per m³ of air.
Limit Value or Ambient Air Quality Limit
Limit value" means a level fixed on the basis of scientific knowledge, with the aim of
reducing harmful effects on human health (or the environment (or both)), to be
attained within a given compliance period and not to be exceeded once attained.
Air Quality Impact Assessment
Industrial Green Energy Solutions (Pty) Ltd Waste Pyrolysis Plant, Centurion, Gauteng
EScience Associates (Pty) Ltd Page iii
ABBREVIATIONS & ACRONYMS
°C Degrees Celsius
µg Microgram
AAQM Ambient Air Quality Monitoring
AH Agricultural Holdings
AEL Atmospheric Emission Licence
AIR Atmospheric Impact Report
As Arsenic
AQIA Air Quality Impact Assessment
BaP Benzo(a)pyrene
CALPUFF California Puff Model
Cd Cadmium
Co Cobalt
CO Carbon monoxide
CO2 Carbon dioxide
Cr Chromium
Cu Copper
EAP Environmental Assessment Practitioner
EScience EScience Associates (Pty) Ltd
EIA Environmental Impact Assessment
FoE Frequency of Exceedance
GN Government Notice
GN.R Government Notice Regulations
HCl Hydrogen Chloride
HF Hydrogen Fluoride
HFO Heavy Fuel Oil
Hg Mercury
IGE Industrial Green Energy Solutions (Pty) Ltd
IOA Index Of Agreement
IUR The Inhalation Unit Risk
LC50 Lethal Concentration 50%
LPG Liquid Petroleum Gas
LULC Land use and land cover
m Metre
mg Milligram
mm Millimetre
Mn Manganese
NAAQS National Ambient Air Quality Standards
NEMA National Environmental Management Act, No 107 OF 1998
NEMAQA National Environment Management: Air Quality Act, No 39 Of 2004
Air Quality Impact Assessment
Industrial Green Energy Solutions (Pty) Ltd Waste Pyrolysis Plant, Centurion, Gauteng
EScience Associates (Pty) Ltd Page iv
ng Nanogram
NH3 Ammonia
Ni Nickel
NLC National Land Cover
NO Nitric oxide
NO2 Nitrogen dioxide
NOx Oxides of Nitrogen
O3 Ozone
PAEL Provisional Atmospheric Emission Licence
PAH Polycyclic Aromatic Hydrocarbons
Pb Lead
PCDD/F Poly-chlorinated dioxins and/or furans
PM Particulate Matter
PM10 Particulate matter of aerodynamic diameter 10µm or less
PM2.5 Particulate matter of aerodynamic diameter 2.5µm or less
RfC Reference Concentration
SAAQIS South African Air Quality Information System
Sb Antimony
SO2 Sulphur Dioxide
TEQ Toxicity Equivalent
Tl Thallium
TOC Total Organic Compounds
TSP Total Suspended Particles
US EPA United States Environmental Protection Agency
V Vanadium
WHO World Health Organization
WRF Weather Research and Forecasting Model
Air Quality Impact Assessment
Industrial Green Energy Solutions (Pty) Ltd Waste Pyrolysis Plant, Centurion, Gauteng
EScience Associates (Pty) Ltd Page v
TABLE OF CONTENTS
1 INTRODUCTION................................................................................................................................ 1
2 ENTERPRISE DETAILS .................................................................................................................... 2
2.1 ENTERPRISE DETAILS ............................................................................................................... 2
2.2 LOCATION AND EXTENT OF THE PLANT ............................................................................... 3
2.2.1 DESCRIPTION OF SURROUNDING LAND USE (WITHIN 5KM RADIUS) ........................... 3
2.3 ATMOSPHERIC EMISSION LICENCE AND OTHER AUTHORISATIONS ............................... 3
3 NATURE OF THE PROCESS ............................................................................................................ 6
3.1 LISTED ACTIVITY OR ACTIVITIES ........................................................................................... 6
3.2 PROCESS DESCRIPTION ............................................................................................................ 6
3.2.1 FEEDSTOCK PREPARATION ............................................................................................... 6
3.2.2 PYROLYSIS ............................................................................................................................ 7
3.2.3 FUEL RECOVERY ................................................................................................................. 7
3.2.4 UNIT PROCESSES ................................................................................................................10
4 TECHNICAL INFORMATION .........................................................................................................11
4.1 RAW MATERIALS USED ...........................................................................................................11
4.2 APPLIANCES AND ABATEMENT EQUIPMENT CONTROL TECHNOLOGY.........................11
5 ATMOSPHERIC EMISSIONS ..........................................................................................................12
5.1 POINT SOURCE PARAMETERS ................................................................................................12
5.2 POINT SOURCE MAXIMUM EMISSION RATES (NORMAL OPERATING CONDITIONS) ....13
5.3 POINT SOURCE MAXIMUM EMISSION RATES (START UP, SHUT-DOWN, UPSET AND
MAINTENANCE CONDITIONS)............................................................................................................14
5.4 FUGITIVE EMISSIONS (AREA AND/OR LINE SOURCES) ......................................................15
5.4.1 FUGITIVE EMISSIONS (AREA AND/OR LINE SOURCES) PARAMETERS ..........................15
5.4.2 FUGITIVE EMISSIONS (AREA AND/OR LINE SOURCES) MANAGEMENT AND
MITIGATION MEASURES ...................................................................................................................15
5.5 EMERGENCY INCIDENTS .........................................................................................................15
6 APPLICABLE LEGISLATION .........................................................................................................16
6.1 SECTION 24 ENVIRONMENTAL RIGHT ..................................................................................16
6.2 NEMA AND DUTY OF CARE .....................................................................................................16
6.3 AIR QUALITY LEGISLATION IN SOUTH AFRICA ..................................................................17
6.3.1 NATIONAL AMBIENT AIR QUALITY STANDARDS .............................................................17
6.3.2 LISTED ACTIVITIES AND ATMOSPHERIC EMISSIONS LICENSING .................................19
6.4 AMBIENT AIR QUALITY STANDARDS FOR ATMOSPHERIC POLLUTANTS OF POTENTIAL
CONCERN ...............................................................................................................................................21
6.4.1 AIR QUALITY STANDARDS AND GUIDELINES FOR PM10 .................................................21
6.4.2 AIR QUALITY STANDARDS AND GUIDELINES FOR PM2.5 ................................................23
6.4.3 AIR QUALITY STANDARDS AND GUIDELINES FOR DUSTFALL AND DUST CONTROL
REGULATIONS ....................................................................................................................................23
6.4.4 AIR QUALITY STANDARDS AND GUIDELINES FOR SULPHUR DIOXIDE .......................23
6.4.5 AIR QUALITY STANDARDS AND GUIDELINES FOR OXIDES OF NITROGEN ..................24
6.4.6 AIR QUALITY STANDARDS AND GUIDELINES CARBON MONOXIDE .............................25
6.4.7 AIR QUALITY STANDARDS AND GUIDELINES ARSENIC ..................................................26
6.4.8 AIR QUALITY STANDARDS AND GUIDELINES ANTIMONY ..............................................27
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6.4.9 AIR QUALITY STANDARDS AND GUIDELINES CADMIUM ...............................................27
6.4.10 AIR QUALITY STANDARDS AND GUIDELINES COBALT ...................................................27
6.4.11 AIR QUALITY IMPACT, STANDARDS & GUIDELINES FOR CHROMIUM COMPOUNDS 28
6.4.12 AIR QUALITY STANDARDS AND GUIDELINES COPPER ..................................................39
6.4.13 AIR QUALITY STANDARDS AND GUIDELINES LEAD .......................................................39
6.4.14 AIR QUALITY STANDARDS AND GUIDELINES FOR MANGANESE ..................................40
6.4.15 AIR QUALITY STANDARDS AND GUIDELINES FOR NICKEL ...........................................43
6.4.16 AIR QUALITY STANDARDS AND GUIDELINES FOR VANADIUM .....................................43
6.4.17 AIR QUALITY STANDARDS AND GUIDELINES FOR AMMONIA .......................................44
6.4.18 AIR QUALITY STANDARDS AND GUIDELINES FOR MERCURY .......................................45
6.4.19 AIR QUALITY STANDARDS AND GUIDELINES FOR HCL AND HF...................................46
6.4.20 AIR QUALITY STANDARDS AND GUIDELINES FOR DIOXINS AND FURANS (A.K.A.
PCDD’S): .............................................................................................................................................47
6.4.21 AIR QUALITY STANDARDS AND GUIDELINES FOR POLYCYCLIC AROMATIC
HYDROCARBONS ................................................................................................................................48
7 BACKGROUND LEVELS OF AMBIENT AIR POLLUTION ........................................................54
8 EMISSIONS QUANTIFICATION.....................................................................................................60
8.1 SITE EMISSIONS INVENTORY .................................................................................................61
9 METEOROLOGY ..............................................................................................................................62
9.1 GENERAL DESCRIPTION OF CLIMATOLOGY AND METEOROLOGY .................................62
9.2 RAINFALL AND TEMPERATURE .............................................................................................62
9.3 WIND – MEASURED AND MODELLED ....................................................................................62
9.4 DISPERSION POTENTIAL ..........................................................................................................65
9.4.1 ATMOSPHERIC STABILITY .................................................................................................66
9.4.2 MIXING HEIGHTS ................................................................................................................66
10 DISPERSION MODELLING .........................................................................................................68
10.1 DESCRIPTION OF THE DISPERSION MODEL ..........................................................................68
10.1.1 CALPUFF SUITE OF MODELS ............................................................................................68
10.1.2 CALPUFF / CALMET CHARACTERISTICS ..........................................................................68
10.1.3 MODEL INPUT DATA ..........................................................................................................69
10.1.4 GEOPHYSICAL DATA INPUT AND GENERAL DESCRIPTION OF THE AREA ..................69
10.2 TOPOGRAPHY ............................................................................................................................70
10.3 LAND USE/ LAND COVER .........................................................................................................70
10.4 MODEL VERIFICATION ............................................................................................................73
10.5 ASSUMPTIONS AND LIMITATIONS.........................................................................................76
11 IMPACT OF ENTERPRISE ON THE RECEIVING ENVIRONMENT .....................................78
11.1 ANALYSIS OF EMISSION’S IMPACT ON HUMAN HEALTH ..................................................78
11.1.1 PREAMBLE...........................................................................................................................78
11.1.2 SCENARIO 1: PREFERRED LOCATION ..............................................................................80
11.1.3 SCENARIO 2: ALTERNATIVE LOCATION ...........................................................................90
11.2 ANALYSIS OF EMISSIONS’ IMPACT ON THE ENVIRONMENT ............................................99
12 CURRENT OR PLANNED AIR QUALITY MANAGEMENT INTERVENTIONS ................. 100
13 EMERGENCY INCIDENTS ........................................................................................................ 101
14 COMPLIANCE AND ENFORCEMENT HISTORY .................................................................. 101
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15 COMPLAINTS ............................................................................................................................. 101
16 CONCLUSIONS AND RECOMMENDATIONS ........................................................................ 102
16.1 SCENARIO 1: PREFERRED LOCATION EMISSIONS ............................................................. 102
16.1.1 PARTICULATE MATTER .................................................................................................... 102
16.1.2 SULPHUR DIOXIDE .......................................................................................................... 103
16.1.3 NITROGEN DIOXIDE ......................................................................................................... 103
16.1.4 HEXAVALENT CHROMIUM ............................................................................................... 103
16.1.5 POLYCYCLIC AROMATIC HYDROCARBONS ................................................................... 104
16.1.6 METALS AND OTHER POLLUTANTS ................................................................................ 104
16.2 SCENARIO 2: ALTERNATIVE LOCATION EMISSIONS ........................................................ 104
16.2.1 PARTICULATE MATTER .................................................................................................... 104
16.2.2 SULPHUR DIOXIDE .......................................................................................................... 105
16.2.3 NITROGEN DIOXIDE ......................................................................................................... 105
16.2.4 HEXAVALENT CHROMIUM ............................................................................................... 105
16.2.5 POLYCYCLIC AROMATIC HYDROCARBONS ................................................................... 106
16.2.6 METALS AND OTHER POLLUTANTS ................................................................................ 106
16.3 RECOMMENDATIONS ............................................................................................................. 107
17 DETAILS OF THE SPECIALIST................................................................................................ 108
17.1 SPECIALISTS COMPILING THE REPORT............................................................................... 108
17.2 DECLARATION OF INTEREST ................................................................................................ 108
18 FORMAL DECLARATION ......................................................................................................... 109
18.1 DECLARATION OF ACCURACY OF INFORMATION-APPLICANT ..................................... 109
18.2 DECLARATION OF INDEPENDENCE – PRACTITIONER ...................................................... 110
19 REFERENCES .............................................................................................................................. 111
APPENDIX 1: RECLASSIFICATION OF SA LULC CODES INTO CALMET LULC CODES ........ 115
APPENDIX 2: CV’S OF TEAM MEMBERS .......................................................................................... 125
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INDEX OF FIGURES
FIGURE 2-1: SITE LOCATION ..................................................................................................................................................4 FIGURE 2-2: SITE LOCATION & SURROUNDING LAND USE .............................................................................................................5 FIGURE 3-1: SITE PROCESS FLOW DIAGRAM ..............................................................................................................................9 FIGURE 6-1: GENERAL STRUCTURE FOR DIOXINS (A) AND FURANS (B) ........................................................................................... 47 FIGURE 7-1: REGIONAL METEOROLOGICAL AND AMBIENT AIR QUALITY MONITORING STATIONS ......................................................... 54 FIGURE 7-2: SO2 HOURLY AVERAGE AMBIENT AIR QUALITY DATA FROM THE DIEPSLOOT AAQM STATION. .............................................. 56 FIGURE 7-3: SO2 DAILY AVERAGE AMBIENT AIR QUALITY DATA FROM THE DIEPSLOOT AAQM STATION. ................................................. 57 FIGURE 7-4: PM10 DAILY AVERAGE AMBIENT AIR QUALITY DATA FROM THE DIEPSLOOT AAQM STATION. ............................................... 58 FIGURE 7-5: O3 8-HOUR AVERAGE AMBIENT AIR QUALITY DATA FROM DIEPSLOOT AAQM STATION. ..................................................... 59 FIGURE 9-1: AVERAGE MONTHLY TEMPERATURES AND RAINFALL FROM DIEPSLOOT AAQM STATION FROM 2017 – 2019. ........................ 62 FIGURE 9-2: AVERAGE WIND ROSES FROM 2017-2018 FOR DIEPSLOOT AAQM STATION ................................................................. 64 FIGURE 9-3: AVERAGE CALMET MODELLED MIXING HEIGHTS AT INDUSTRIAL GREEN ENERGY SOLUTIONS PREFERRED SITE. ...................... 67 FIGURE 10-1: THE 2-DIMENSIONAL TERRAIN WITHIN THE MODELLING DOMAIN ................................................................................ 70 FIGURE 10-2: CALMET LAND USE TYPES WITHIN THE MODELLING DOMAIN .................................................................................... 71 FIGURE 10-3: THE 2017 DIEPSLOOT AMBIENT MONITORING STATION WIND SPEED (TOP) AND WIND DIRECTION (BOTTOM) ........................ 74 FIGURE 10-4: THE 2018 DIEPSLOOT AMBIENT MONITORING STATION WIND SPEED (TOP) AND WIND DIRECTION (BOTTOM) ........................ 75 FIGURE 11-1: SCENARIO 1 PREDICTED PM10 24-HOUR MAXIMUM MODELLED AMBIENT CONCENTRATION. ............................................ 80 FIGURE 11-2: SCENARIO 1 PREDICTED PM2.5 24-HOUR MAXIMUM MODELLED AMBIENT CONCENTRATION. ............................................ 81 FIGURE 11-3: SCENARIO 1 PREDICTED SO2 1-HOUR MAXIMUM MODELLED AMBIENT CONCENTRATION. ................................................ 82 FIGURE 11-4: SCENARIO 1 PREDICTED NO2 1-HOUR MAXIMUM MODELLED AMBIENT CONCENTRATION. ................................................ 83 FIGURE 11-5: SCENARIO 1 PREDICTED CR(VI) 1-HOUR MAXIMUM MODELLED AMBIENT CONCENTRATION. ............................................. 84 FIGURE 11-6: SCENARIO 1 PREDICTED CR(VI) LIFETIME CARCINOGENIC RISK WITH WHO RFC. ............................................................ 85 FIGURE 11-7: SCENARIO 2 PREDICTED PM10 24-HOUR MAXIMUM MODELLED AMBIENT CONCENTRATION. ............................................ 90 FIGURE 11-8: SCENARIO 2 PREDICTED PM2.5 24-HOUR MAXIMUM MODELLED AMBIENT CONCENTRATION. ............................................ 91 FIGURE 11-9: SCENARIO 2 PREDICTED SO2 1-HOUR MAXIMUM MODELLED AMBIENT CONCENTRATION. ................................................ 92 FIGURE 11-10: SCENARIO 2 PREDICTED NO2 1-HOUR MAXIMUM MODELLED AMBIENT CONCENTRATION. .............................................. 93 FIGURE 11-11: SCENARIO 2 PREDICTED CR(VI) 1-HOUR MAXIMUM MODELLED AMBIENT CONCENTRATION. ........................................... 94 FIGURE 11-12: SCENARIO 2 PREDICTED CR(VI) LIFETIME CARCINOGENIC RISK WITH WHO RFC. .......................................................... 95
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INDEX OF TABLES TABLE 2-1: ENTERPRISE DETAILS FOR THE SITE ...........................................................................................................................2 TABLE 2-2: LOCATION AND EXTENT OF THE SITE .........................................................................................................................3 TABLE 3-1: LISTED ACTIVITIES AT THE SITE ................................................................................................................................6 TABLE 3-2: PROPOSED OPERATIONAL UNIT PROCESSES.............................................................................................................. 10 TABLE 4-1: RAW MATERIALS USED ON SITE............................................................................................................................. 11 TABLE 4-2: APPLIANCES AND ABATEMENT EQUIPMENT CONTROL TECHNOLOGY USED ON SITE .............................................................. 11 TABLE 5-1: PARAMETERS FOR POINT SOURCES ........................................................................................................................ 12 TABLE 5-2: POINT SOURCE MAXIMUM EMISSION RATES (NORMAL OPERATING CONDITIONS) .............................................................. 13 TABLE 5-3: POINT SOURCE MAXIMUM EMISSION RATES (START UP, SHUT-DOWN, UPSET AND MAINTENANCE CONDITIONS) ....................... 14 TABLE 6-1: NATIONAL AMBIENT AIR QUALITY STANDARDS - GN 1210:2009 ................................................................................. 17 TABLE 6-2: NATIONAL AMBIENT AIR QUALITY STANDARDS FOR PM2.5 - GN 486:2012 .................................................................... 18 TABLE 6-3: GN 893:2013 SUBCATEGORY 3.1: COMBUSTION INSTALLATIONS ................................................................................ 20 TABLE 6-4: GN 893:2013 SUBCATEGORY 3.4: CHAR, CHARCOAL AND CARBON BLACK PRODUCTION .................................................. 20 TABLE 6-5: GN 893:2013 SUBCATEGORY 8.1: THERMAL TREATMENT OF GENERAL AND HAZARDOUS WASTE ....................................... 21 TABLE 6-5: AIR QUALITY STANDARD FOR INHALABLE PARTICULATES (PM10) ............................................................................ 22 TABLE 6-6 : AIR QUALITY STANDARDS FOR INHALABLE PARTICULATES (PM2.5) ................................................................................ 23 TABLE 6-7: GN827:2013 ACCEPTABLE DUSTFALL RATES ........................................................................................................... 23 TABLE 6-8: AIR QUALITY STANDARD FOR SULPHUR DIOXIDE (SO2) .......................................................................................... 24 TABLE 6-9: AIR QUALITY STANDARDS FOR NITROGEN DIOXIDE (NO2) ..................................................................................... 25 TABLE 6-10: AIR QUALITY STANDARDS FOR CARBON MONOXIDE (CO) .......................................................................................... 25 TABLE 6-11: SUMMARY OF EXISTING AIR QUALITY GUIDELINES FOR CHROMIUM (CR) ....................................................................... 31 TABLE 6-12: RISK EXPRESSED AS A PROBABILITY OF OCCURRING .................................................................................................... 38 TABLE 6-13: AIR QUALITY STANDARDS FOR LEAD (PB) .............................................................................................................. 40 TABLE 6-14: ANNUAL AVERAGE STANDARDS AND GUIDELINES FOR MANGANESE (MN) ...................................................................... 41 TABLE 6-15: 24-HOUR AVERAGE STANDARDS AND GUIDELINES FOR MANGANESE (MN) .................................................................... 41 TABLE 6-16: 8 HOUR AND 1 HOUR AVERAGE STANDARDS AND GUIDELINES FOR MANGANESE (MN) ..................................................... 42 TABLE 6-17: AIR QUALITY STANDARDS FOR AMMONIA (NH3) ..................................................................................................... 44 TABLE 6-18: AIR QUALITY STANDARDS FOR MERCURY (HG) ....................................................................................................... 45 TABLE 6-19: INTERNATIONAL AMBIENT STANDARDS AND GUIDELINES FOR VARIOUS POLLUTANTS .......................................................... 47 TABLE 6-20: INTERNATIONAL AMBIENT STANDARDS AND GUIDELINES FOR DIOXINS AND FURANS ........................................................... 48 TABLE 6-21: INTERNATIONAL AMBIENT AIR QUALITY STANDARDS FOR PAHS .................................................................................. 49 TABLE 6-22: PAH EMISSIONS FROM THE COMBUSTION OF PLASTICS (LI, ZHUANG, HSIEH, LEE, & TSAO, 2001) ....................................... 50 TABLE 6-23: CLASSIFICATION OF CARCINOGENS BY DIFFERENT HEALTH ORGANISATIONS ...................................................................... 51 TABLE 6-24: CARCINOGENIC PAHS EXPECTED FROM THE COMBUSTION OF PLASTICS .......................................................................... 51 TABLE 6-25: RISK EXPRESSED AS A PROBABILITY OF OCCURRING .................................................................................................... 52 TABLE 7-1: AMBIENT AIR QUALITY DATA AVAILABILITY .............................................................................................................. 55 TABLE 8-1: POINT SOURCE EMISSION RATES ............................................................................................................................ 61 TABLE 9-1: DATA AVAILABILITY FOR AAQM STATION. ............................................................................................................... 63 TABLE 9-2: WIND SPEED COMPARISON FOR THE DIEPSLOOT AAQM STATION. ................................................................................. 63 TABLE 10-1: DEFAULT CALMET LAND USE CATEGORIES AND ASSOCIATED GEOPHYSICAL PARAMETERS. ............................................... 71 TABLE 10-2: LAND USE CODES AND CATEGORIES USED IN THE MODEL ............................................................................................ 72 TABLE 11-1: PREDICTED AMBIENT CONCENTRATIONS – COLOUR CODING ...................................................................................... 78 TABLE 11-2: PREDICTED FREQUENCY OF EXCEEDANCES – COLOUR CODING .................................................................................... 79 TABLE 11-3: PREDICTED CHROMIUM (VI) LIFETIME CARCINOGENIC RISK – COLOUR CODING .............................................................. 79 TABLE 11-4: CALCULATED CANCER RISK OF PAHS EXPECTED FROM THE COMBUSTION OF PLASTICS – SCENARIO 1 .................................... 86 TABLE 11-5: METALS AND OTHER POLLUTANTS ........................................................................................................................ 88 TABLE 11-6: CALCULATED CANCER RISK OF PAHS EXPECTED FROM THE COMBUSTION OF PLASTICS – SCENARIO 2 .................................... 96 TABLE 11-7: METALS AND OTHER POLLUTANTS ........................................................................................................................ 97 TABLE 12-1: APPLIANCES AND ABATEMENT EQUIPMENT CONTROL TECHNOLOGY USED ON SITE .......................................................... 100 TABLE 17-1: DETAILS OF THE SPECIALISTS ............................................................................................................................. 108 TABLE 0-1: SOUTH AFRICAN LAND USE LAND COVER (LULC) CODES RECLASSIFIED ACCORDING TO CALMET LULC CODES....................... 115
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1 INTRODUCTION
EScience Associates (Pty) Ltd (hereafter referred to as EScience), was appointed by
Industrial Green Energy Solutions (Pty) Ltd, hereby referred to as IGE, to undertake an Air
Quality Impact Assessment (AQIA) to inform an environmental impact assessment
process for a proposed facility for the thermal processing of high boiling point
hydrocarbons/waxes and plastic waste to produce various hydrocarbons and other
products.
The proposed facility will be located in the Limeroc Business Park, Knoppieslaagte 385-Jr,
Centurion within the City of Tshwane Metropolitan Municipality. The primary intent of the
proposed plant is to recover lighter hydrocarbons through thermal treatment of non-
hazardous wastes such as recovered waxes, non-hazardous oils and lubricants and
plastics, in order to produce various organic compounds and fuel blends including but
not limited to naphtha, petrol, diesel, and heavy fuel oil. A carbonaceous residue (char)
will also be produced. The lighter non-condensable fractions will be combusted to
sustain the pyrolysis process.
The AQIA will determine the impact of emissions from the proposed facility in relation to
gazetted ambient air quality limits and acceptable air quality limits where relevant and
to facilitate the associated legal and administrative processes required to obtain the
necessary environmental authorisations.
GN 893:2013 gazetted in terms of Section 21 of the National Environmental
Management: Air Quality Act (Act 39 of 2004), is 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. A Provisional Atmospheric Emissions Licence (PAEL), or
Atmospheric Emissions Licence (AEL), is required to conduct these activities. The
operations trigger two of the activities listed in GN551:2015, namely:
• Subcategory 3.4: Char, Charcoal and Carbon Black Production
• Subcategory 8.1: Thermal Treatment of General and Hazardous Waste
The objective of this AQIA is to assess the potential impact of the proposed facility on
ambient air quality, and thus inform the Atmospheric Emissions Licence (AEL) application
process.
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2 ENTERPRISE DETAILS
2.1 ENTERPRISE DETAILS
Table 2-1: Enterprise Details for the Site
Enterprise Name Industrial Green Energy Solutions (Pty)
Ltd
Trading As Industrial Green Energy Solutions (Pty)
Ltd
Type of Enterprise, e.g.
Company/Close Corporation/Trust
Company
Company/Close Corporation/Trust
Registration Number (Registration
Numbers of Joint Venture)
2017/432540/07
Registered Address 8 Summit Road, Knoppieslaagte 385,
Centurion, South Africa
Postal Address 8 Summit Road, Knoppieslaagte 385,
Centurion, South Africa
Telephone Number (General) 071 877 7610
Fax Number (General) -
Industry Type/Nature of Trade Waste Pyrolysis
Land Use Zoning as per Town Planning
Scheme
Industrial
Land Use Rights if outside Town
Planning Scheme
Not Applicable
Responsible Person Mr Barry Gonin
Emission Control Officer Mr Barry Gonin
Telephone Number 071 877 7610
Cell Phone Number 083 222 5222
Fax Number -
E-mail Address barry.gonin@industrialgreenenergy.com
After hours Contact Details 083 222 5222
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2.2 LOCATION AND EXTENT OF THE PLANT
Table 2-2: Location and Extent of the site
Physical Address of the Plant Limeroc Business Park, Knoppieslaagte
385-Jr, Centurion
Description of Site (Where No Street
Address)
Not Applicable
Coordinates of Approximate Centre of
Operations
North-south: 25°54'20.14"S
East-west: 28°02'02.96"E
Extent (km2) 0.5
Elevation Above Mean Sea Level (m) 1 490m
Province Gauteng
Metropolitan/District Municipality City of Tshwane Metropolitan
Municipality.
Local Municipality Not Applicable
Designated Priority Area (if applicable) None
2.2.1 DESCRIPTION OF SURROUNDING LAND USE (WITHIN 5KM RADIUS)
The proposed facility will be located within the Limeroc Business Park in Centurion,
Gauteng. The business park is immediately surrounded by residential, mining, and
commercial activities as well as grassland/shrubland.
Laezonia Agricultural Holdings (AH) and Timsrand AH are the closest residential areas
approximately 0.5 km west and south of the Limeroc Business Park boundary,
respectively. An informal settlement is located across Fig road approximately 10m west
from the Limeroc Business Park boundary. The suburb of Diepsloot West is approximately
1km south west, Copperleaf Golf and Country Estate is approximately 2km north, Mnandi
AH is approximately 2km north east and Saddlebrook Estate approximately 4.5km south
of the Limeroc Business Park boundary.
Centurion Flight Academy boarders the south east of the Limeroc Business Park
boundary. The Ingwe Airfield and Aero 57 Airstrip are approximately 1.5km and 4.5km
east of the proposed facility, respectively. The area to the north is mostly cultivated land,
with small holdings located across the R114 road, approximately 10m from the Limeroc
Business Park boundary. Mining activities include Kilo Sand present at approximately
0.5km to the east of the facility and Gomes Sand Construction Company located
approximately 2km west of the Limeroc Business Park boundary.
The closest hospital is located 1.5km south west of the Limeroc Business Park Boundary.
The location and land-use surrounding the site is shown in Figure 2-1and Figure 2-2,
respectively.
2.3 ATMOSPHERIC EMISSION LICENCE AND OTHER AUTHORISATIONS
The site currently does not hold an Atmospheric Emissions Licence (AEL).
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Figure 2-1: Site Location
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Figure 2-2: Site Location & Surrounding Land use
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3 NATURE OF THE PROCESS
3.1 LISTED ACTIVITY OR ACTIVITIES
The list of all Listed Activities, as published in terms of Section 21 of the NEMAQA, that
apply to the proposed facility are given in Table 3-1 below.
Table 3-1: Listed Activities at the Site
Listed
Activity
Number
Category of
Listed Activity
Sub-
category
of the
Listed
Activity
Listed Activity
Name
Description of the Listed
Activity
3 Carbonization
and Coal
Gasification
3.1 Combustion
Installations
Combustion installations
not used primarily for steam
raising or electricity
generation.
3 Carbonization
and Coal
Gasification
3.4 Char,
Charcoal
and Carbon
Black
Production
Production of char,
charcoal and the
production and use of
carbon black.
8 Thermal
Treatment of
Hazardous
and General
Waste
8.1 Thermal
Treatment of
General and
Hazardous
Waste
Facilities where general
and hazardous waste are
treated by the application
of heat.
3.2 PROCESS DESCRIPTION
Figure 3-1 depicts a summary of the proposed unit processes. The proposed facility will
produce various organic compounds and fuel blends including, but not limited to,
naphtha, petrol, diesel, and HFO. Water used in the process will be supplied from
municipal services and no industrial effluent of significance is anticipated.
3.2.1 FEEDSTOCK PREPARATION
A combination of hydrocarbons, waxes, and plastic waste (feedstock) will be
delivered to site via road and stored onsite prior to preparation and processing. The
waste will be received in bags if solid or in waste skips if liquid.
The solid feedstock is to be fed into a shredder where the size of the feedstock will
be reduced to below 5mm average particle diameter. It is anticipated that there
may be blending and/or homogenisation of the material to optimise further
processing and products.
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3.2.2 PYROLYSIS
3.2.2.1 PYROLYSIS FEEDING ARRANGEMENT
The pyrolysis process requires an atmosphere devoid of oxygen. The feed material
is to be introduced into the pyrolysis unit by means of two isolation valves where
one of the two valves is always closed to preserve the oxygen free atmosphere. A
continuous nitrogen purge between the valves further reduces the likelihood of
oxygen entering the system. Liquid feed will be fed with a slurry pump into the
pyrolysis.
3.2.2.2 PYROLYSIS UNIT
A single pyrolysis reactor (a horizontal kiln)will be installed. It will convert the feed
material through various thermochemical reactions into a vapour product
containing liquid (oil) and gas (syngas) fractions, and a solid product
(residue/char). The pyrolizer is heated externally by combustion of LPG, syngas, or
solid residue from the pyrolysis process. The actual conversion takes place inside
the reactor, in the absence of oxygen, thus preventing combustion of the feed
material from taking place and allowing for production of higher calorific value gas
at the exit. The vapour exhaust temperature is between 500°C and 700°C.
The vapour discharge is separated from the residue product (char) in a dropout
box and a settling chamber.
3.2.2.3 PYROLYSIS CHAR COMBUSTION/VITRIFICATION FURNACE
The solid products of pyrolysis as well as any waste oils are to be sent to a
combustion/vitrification furnace where energy is recovered through combustion to
provide energy to the pyrolysis unit. The unit is run at a high temperature (~1300°C)
whereby the oxidised char will fuse to form a slag which can then be quenched into a
glass like substance in a process called vitrification. Alternatively, the furnace is operated
at a lower temperature such that the oxidised char remains as a free flowing solid. Any
excess combustion gases not used by the pyrolysis unit, as well as the exhaust gases from
the pyrolysis unit heating chamber are sent to the waste heat recovery boiler.
3.2.3 FUEL RECOVERY
3.2.3.1 EXHAUST GAS COOLER
The superheated vapour product from the pyrolysis unit will pass through a heat
exchanger which cools the vapour to 350°C which prepares it for condensing in the
diesel condenser. The cooling medium used is atmospheric air, whereby the heat
exchanger is used as a preheater for this air before it is used for combustion to provide
heat to the pyrolysis reactor, thus improving efficiency.
3.2.3.2 DIESEL CONDENSING TOWER
The vapour enters the tower at 350°C and is cooled down to 120°C on the outlet by
circulating the condensed and cooled diesel to the top of the tower. The diesel is then
filtered and cooled before sending it to the intermediate storage tanks for quality
control.
3.2.3.3 NAPHTHA/WATER CONDENSING TOWER
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The lower boiling point hydrocarbons, as well as any water, are then cooled down
to approximately 40°C in a second scrubbing tower utilising the cooled condensed
naphtha stream as scrubbing liquid. Water and naphtha are separated in a gravity
settler and any water recovered is used as cooling medium of the solid waste.
3.2.3.4 GAS HANDLING
The cleaned pyrolysis gas is transferred to a gas bladder by using a booster fan. The
gas bladder allows for the gas to homogenise and allows for minor process upsets
which result in changes in gas production. A booster fan on the outlet of the gas
bladder is used to convey the gas to the burners on the pyrolysis unit as well the
power generation unit.
3.2.3.5 ELECTRICITY GENERATION
Steam generated by the waste heat recovery boiler and combustion of excess cleaned
gas may be used to drive a turbine or organic Rankine cycle process to produce
electricity. If conducted this will be less than 10MW and thus will not require
Environmental Authorisation.
Figure 3-1 below shows the overall processes of the site.
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Figure 3-1: Site Process Flow Diagram
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3.2.4 UNIT PROCESSES
The unit processes operational at the site are presented in Table 3-2.
Table 3-2: Proposed Operational Unit Processes
Name of the Unit
Process Unit Process Function
Batch or
Continuous
Process
Receiving Feedstock received by truck, off-loaded,
and stored in the yard in skips or bags.
Batch
Milling/Shredding Feedstock fed into shredder where the size
of the feedstock is reduced.
Batch
Pyrolysis Reactor Shredded feedstock fed to pyrolysis reactor
and converted to gas, diesel, liquid
hydrocarbons, and char.
Continuous
Vitrification
furnace
The solid products of pyrolysis as well as any
waste oils are to be sent to a
combustion/vitrification furnace whereby
the oxidised char will fuse to form a slag
which can then be quenched into a glass
like substance in a process called
vitrification.
Continuous
Exhaust Gas
Cooler
Heat exchanger used to cools the vapour
from pyrolysis reactor to 350°C
Continuous
Diesel Condensing
Tower
Diesel condenser cools vapour down to
120°C to condense diesel fraction
Continuous
Naptha/water
condensing Tower
scrubbing tower to condense lower boiling
point hydrocarbons, as well as any water.
Continuous
Water/Naptha
Separator
Water and naphtha are separated in a
gravity settler
Continuous
Gas Bladder Remaining non-condensable gases
transferred to a gas bladder. A booster fan
on the outlet of the gas bladder is used to
convey the gas to the burners on the
pyrolysis unit
Continuous
Waste heat
recovery boiler Waste heat to be used to produce steam. Continuous
Turbine and
Generator unit Steam generated used to drive a turbine or
organic rankine cycle process to produce
electricity.
Continuous
Storage and
shipping Products stored in tanks, skips, and bunkers. Batch
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4 TECHNICAL INFORMATION
4.1 RAW MATERIALS USED
Raw materials used at the plant are presented in Table 4-1.
* Regulated raw materials refers to those materials when increased or decreased may result in
the change of air emissions output.
** Non-regulated raw materials refer to those materials when increased or decreased may not
result in any change of air emissions output.
4.2 APPLIANCES AND ABATEMENT EQUIPMENT CONTROL TECHNOLOGY
The appliances and abatement equipment control technology that will be used on site
are presented in Table 4-2.
Table 4-2: Appliances and Abatement equipment control technology used on site
Appliance Name Appliance
Type/Description
Appliance
Function/Purpose
Scrubber Stack Scrubber Removal of soluble
gases
Table 4-1: Raw Materials used on Site
Regulated Raw Materials*
Raw Material Type Design Consumption Rate
(Quantity) Units (quantity/period)
Waxes 5 000 Ton/annum
Non-hazardous oils and
lubricants 5 000 Ton/annum
Plastic 5 250 m3/annum
Non-regulated Raw Materials**
Raw Material Type Design Consumption Rate
(Quantity) Units (quantity/period)
Municipal water Not Applicable Not Applicable
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5 ATMOSPHERIC EMISSIONS
5.1 POINT SOURCE PARAMETERS
The parameters for the point source for the proposed facility are presented in Table 5-1. A recommended stack height of 12m has been
determined based on screening results and the Guideline for Determination of Good Engineering Practice Stack Height (USEPA, 1985).
Table 5-1: Parameters for Point Sources
Point
Source
Code Source Name
Latitude
(decimal
degrees)
Longitude
(decimal
degrees)
Height of
Release
Above
Ground (m)
Height
Above
Nearby
Building
(m)
Diameter at
Stack Tip /
Vent Exit
(m)
Actual Gas
Exit
Temperatur
e (°C)
Actual Gas
Volumetric
Flow (m³/hr)
Actual
Gas Exit
Velocity
(m/s)
Emission
Hours
Type of
Emission
(Continuous
/ Batch) South East
SS1 Scrubber
Stack 1 -25.90386 28.37975 12.00 4.00 0.15 60 501.94 11.30 24 Hours Continuous
SS2 Scrubber
Stack 2 -25.90386 28.37975 12.00 4.00 0.15 60 501.94 11.30 24 Hours Continuous
SS3 Scrubber
Stack 3 -25.90386 28.37975 12.00 4.00 0.15 60 501.94 11.30 24 Hours Continuous
SS4 Scrubber
Stack 4 -25.90386 28.37975 12.00 4.00 0.15 60 501.94 11.30 24 Hours Continuous
AS1
Alternative
Scrubber
Stack 1
-25.90612 28.03001 12.00 4.00 0.15 60 501.94 11.30 24 Hours Continuous
AS2
Alternative
Scrubber
Stack 2
-25.90612 28.03001 12.00 4.00 0.15 60 501.94 11.30 24 Hours Continuous
AS3
Alternative
Scrubber
Stack 3
-25.90612 28.03001 12.00 4.00 0.15 60 501.94 11.30 24 Hours Continuous
AS4
Alternative
Scrubber
Stack 4
-25.90612 28.03001 12.00 4.00 0.15 60 501.94 11.30 24 Hours Continuous
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5.2 POINT SOURCE MAXIMUM EMISSION RATES (NORMAL OPERATING CONDITIONS)
The maximum emission rates for the point sources under normal operating conditions are presented in Table 5-2.
Table 5-2: Point Source Maximum Emission Rates (normal operating conditions)
Point Source
Code Pollutant Name Chemical Symbol
Maximum Release Rate Duration of
Emissions (mg/Nm³) Date to be
Achieved By
Average
Period
SS1 – SS4,
AS1 – AS4
Particulate matter PM 10 Immediate 24 Hours Continuous
Carbon monoxide CO 50 Immediate 24 Hours Continuous
Sulphur dioxide SO2 50 Immediate 24 Hours Continuous
Oxides of Nitrogen NOx as NO2 200 Immediate 24 Hours Continuous
Hydrogen chloride HCl 10 Immediate 24 Hours Continuous
Hydrogen fluoride HF 0.5 Immediate 24 Hours Continuous
Sum of Lead, arsenic,
antimony, chromium, cobalt,
copper, manganese, nickel,
vanadium
Pb +As+ Sb + Cr +
Co + Cu + Mn+ Ni
+ V
0.05 Immediate 24 Hours Continuous
Mercury Hg 0.05 Immediate 24 Hours Continuous
Cadmium Thallium Cd TI 10 Immediate 24 Hours Continuous
Total organic compounds TOC 10 Immediate 24 Hours Continuous
Ammonia NH3 10 Immediate 24 Hours Continuous
Dioxins and furans PCDD/PCDF ng I-TEQ /Nm3
Immediate 24 Hours Continuous
0.1
Poly Aromatic Hydrocarbons PAH 0.1 Immediate 24 Hours Continuous
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5.3 POINT SOURCE MAXIMUM EMISSION RATES (START UP, SHUT-DOWN, UPSET AND MAINTENANCE CONDITIONS)
The maximum emission rates for the point sources under start up, shut-down, upset and maintenance conditions are presented in Table
5-3.
Table 5-3: Point Source Maximum Emission Rates (Start up, shut-down, upset and maintenance conditions)
Point Source
Code Pollutant Name Chemical Symbol
Maximum Release Rate Duration of
Emissions (mg/Nm³) Date to be
Achieved By
Average
Period
SS1 – SS4,
AS1 – AS4
Particulate matter PM 10 Immediate 24 Hours Continuous
Carbon monoxide CO 50 Immediate 24 Hours Continuous
Sulphur dioxide SO2 50 Immediate 24 Hours Continuous
Oxides of Nitrogen NOx as NO2 200 Immediate 24 Hours Continuous
Hydrogen chloride HCl 10 Immediate 24 Hours Continuous
Hydrogen fluoride HF 0.5 Immediate 24 Hours Continuous
Sum of Lead, arsenic,
antimony, chromium, cobalt,
copper, manganese, nickel,
vanadium
Pb +As+ Sb + Cr +
Co + Cu + Mn+ Ni +
V
0.05 Immediate 24 Hours Continuous
Mercury Hg 0.05 Immediate 24 Hours Continuous
Cadmium Thallium Cd TI 10 Immediate 24 Hours Continuous
Total organic compounds TOC 10 Immediate 24 Hours Continuous
Ammonia NH3 10 Immediate 24 Hours Continuous
Dioxins and furans PCDD/PCDF ng I-TEQ /Nm3
Immediate 24 Hours Continuous 0.1
Poly Aromatic Hydrocarbons PAH 0.1 Immediate 24 Hours Continuous
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5.4 FUGITIVE EMISSIONS (AREA AND/OR LINE SOURCES)
5.4.1 FUGITIVE EMISSIONS (AREA AND/OR LINE SOURCES) PARAMETERS
No Significant area and/or line sources found are expected.
5.4.2 FUGITIVE EMISSIONS (AREA AND/OR LINE SOURCES) MANAGEMENT AND
MITIGATION MEASURES
No Significant area and/or line sources found are expected.
5.5 EMERGENCY INCIDENTS
Not Applicable.
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6 APPLICABLE LEGISLATION
6.1 SECTION 24 ENVIRONMENTAL RIGHT
Section 24 of the Constitution provides the following:
“Everyone has the right -
a. to an environment that is not harmful to their health or well-being; and
b. to have the environment protected, for the benefit of present and future
generations, through reasonable legislative and other measures that -
i. prevent pollution and ecological degradation;
ii. promote conservation; and
iii. secure ecologically sustainable development and use of natural resources
while promoting justifiable economic and social development.”
6.2 NEMA AND DUTY OF CARE
NEMA constitutes the primary law in terms of which integrated environmental
management and environmental impact assessment is carried out and applied in South
Africa in pursuance of the abovementioned environmental right.
NEMA places a duty of 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 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-
investigate, assess and evaluate the impact on the environment; 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; cease, modify or control any act, activity or process causing the
pollution or degradation; contain or prevent the movement of pollutants or the
causant of degradation; eliminate any source of the pollution or degradation; or
remedy the effects of the pollution or degradation.”
In the context of this Air Quality Impact Assessment (AQIA), the impact of Industrial Green
Energy Solutions (Pty) Ltd has been assessed and evaluated to determine the
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significance of the factory’s impact on air quality and subsequently inform decisions with
respect to air quality management.
6.3 AIR QUALITY LEGISLATION IN SOUTH AFRICA
The National Environmental Air Quality Act (NEMAQA) (Act 39 of 2004), provides the
environmental legal basis for management of air quality in South Africa. in the Act
focuses on Air Quality Management from an ambient air quality management
approach.
Further to the “duty of care” previously discussed in terms of NEMA, NEMAQA defines air
pollution as:
““air pollution” means any change in the composition of the air caused by smoke, soot,
dust (including fly-ash), cinders, solid particles of any kind, gases, fumes, aerosols and
odorous substances;”
NEMAQA is effects-based legislation, with the result that activities that result in
atmospheric emissions are to be managed through the setting of environmental health
based ambient air quality standards. Facilities with potential impacts on air quality should
ideally be assessed not only in terms of its individual contribution, but in terms of its
additive contribution to baseline ambient air quality i.e. cumulative effects must be
considered.
6.3.1 NATIONAL AMBIENT AIR QUALITY STANDARDS
According to S9 of NEMAQA:
“(1) The Minister, by notice in the Gazette-
(a) must identify 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 the
Minister reasonably believes present such a threat; and
(b) must, in respect of each of those substances or mixtures of substances,
establish national standards for ambient air quality, including the permissible
amount or concentration of each such substance or mixture of substances in
ambient air; …”
The Minister of Water and Environmental Affairs published limits for ambient air
quality in Government Notice No 1210 of 24 December 2009, in terms of S9(1) of
NEMAQA, as shown in Table 6-1.
Table 6-1: National Ambient Air Quality Standards - GN 1210:2009
Pollutant Averaging period Conc. µg/m3 FOE* Compliance date
PM10 24-hours 75 4 Immediate
Annual 40 0 Immediate
NO2 1-hour 200 88 Immediate
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Table 6-1: National Ambient Air Quality Standards - GN 1210:2009
Pollutant Averaging period Conc. µg/m3 FOE* Compliance date
Annual 40 0 Immediate
SO2
10-min (running) 500 526 Immediate
1-hour 350 88 Immediate
24-hours 125 4 Immediate
Annual 50 0 Immediate
CO 1-hour 30 88 Immediate
8-hours (running)^ 10 11 Immediate
* FOE – Permitted Frequency of Exceedance in occurrences per year
^ Calculated on 1-Hourly averages.
The Ministry of Water and Environmental Affairs further published limits for PM2.5 on the
29th June 2012, in terms of S9(1) of NEMAQA, as shown in Table 6-2.
Table 6-2: National Ambient Air Quality Standards for PM2.5 - GN 486:2012
Pollutant Averaging period Conc. µg/m3 FOE* Compliance date
PM2.5
24-hours 40 4 Immediate
25 4 01 January 2030
Annual 20 0 Immediate
15 0 01 January 2030
* FOE – Permitted Frequency of Exceedance in occurrences per year
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6.3.2 LISTED ACTIVITIES AND ATMOSPHERIC EMISSIONS LICENSING
S21 of NEMAQA provides for the minister (or MEC) to:
“…publish a list of activities which result in atmospheric emissions and which the Minister
or MEC reasonably believes have or may have a significant detrimental effect on the
environment, including health, social conditions, economic conditions, ecological
conditions or cultural heritage;...”
S22 of NEMAQA states that no person may, without a provisional atmospheric emission
licence or an atmospheric emission licence, conduct a listed activity.
Accordingly, the minister published the "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". The list of activities was published in GN 248 of 2010,
and subsequently superseded by GN 893 on 22 November 2013, and subsequently
amended by GN 551 in 2015, in accordance with S21 of NEMAQA. The following apply
to the proposed expansion:
• Category 3: Carbonization and Coal Gasification; Subcategory 3.1: Combustion
Installations,
• Category 3: Carbonization and Coal Gasification; Subcategory 3.4: Char,
Charcoal and Carbon Black Production, and
• Category 8: Thermal Treatment of Hazardous and General Waste; Subcategory
8.1: Thermal Treatment of General and Hazardous Waste.
These subcategories of GN 893:2013, as amended are reproduced in Table 6-3, Table 6-4
and Table 6-5. These processes thus require an Atmospheric Emissions Licence for the
continuance of operations.
The required air emission standards, set in terms of the NEMAQA S21 Minimum Emission
Standards, applicable to the proposed facility are given in Table 6-3, Table 6-4 and Table
6-5. The standards for “new plant” will apply.
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Table 6-3: GN 893:2013 Subcategory 3.1: Combustion Installations
Description Combustion installations not used primarily for steam raising or
electricity generation.
Application All combustion installations (except test or experimental
installations).
Substance or Mixtures of Substances
Common Name Chemical
Symbol
Plant
Status
mg/Nm3 under
normal conditions
of 273 Kelvin, 101.3
kPa
Particulate Matter N/A New 50
Existing 100
Oxides of nitrogen
NOx
expressed as
NO2
New 700
Existing 2000
Total organic compounds
(from non-coke oven
operations)
N/A
New 40
Existing 90
Table 6-4: GN 893:2013 Subcategory 3.4: Char, Charcoal and Carbon Black
Production
Description Production of char, charcoal and the production and use of
carbon black.
Application All installations producing more than 20 tons of char or charcoal
per month. Installations consuming more than 20 tons per month
of carbon black in any
processes.
Substance or Mixtures of Substances
Plant
Status
mg/Nm3 under
normal conditions
of 273 Kelvin, 101.3
kPa Common Name
Chemical
Symbol
Particulate Matter N/A
New 50
Existing 100
Poly Aromatic Hydrocarbons1 PAH
New 0.1
Existing 0.5
1 Assumed to be Polycyclic Aromatic Hydrocarbons
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Table 6-5: GN 893:2013 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 Mixtures of Substances
Plant
Status
mg/Nm3 under
normal conditions
of 273 Kelvin, 101.3
kPa Common Name
Chemical
Symbol
Particulate matter N/A New 10
Existing 25
Carbon monoxide CO New 50
Existing 75
Sulphur dioxide SO2 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 0.5
Existing 0.5
Sum of Lead, arsenic,
antimony, chromium, cobalt,
copper, manganese, nickel,
vanadium
Pb, As, Sb, Cr,
Co, Cu, Mn,
Ni, V
New 0.05
Existing 0.05
Mercury Hg New 0.05
Existing 0.05
Cadmium Thallium Cd + TI New 10*
Existing 10*
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
*Although the limit for Cadmium and Thallium is listed as 10 mg/Nm3 under this activity in
GN 893 of 2013 as amended, all other waste related activities within GN893 of 2013 as
amended list the limit as 0.05 mg/Nm3.
6.4 AMBIENT AIR QUALITY STANDARDS FOR ATMOSPHERIC POLLUTANTS OF
POTENTIAL CONCERN
6.4.1 AIR QUALITY STANDARDS AND GUIDELINES FOR PM10
The impact of particles on human health is largely depended on (i) particle
characteristics, particularly particle size and chemical composition, and (ii) the duration,
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frequency and magnitude of exposure. The potential of particles to be inhaled and
deposited in the lung is a function of the aerodynamic characteristics of particles in flow
streams. The aerodynamic properties of particles are related to their size, shape, and
density.
The nasal openings permit very large dust particles to enter the nasal region, along with
much finer airborne particulates. Larger particles are deposited in the nasal region by
impaction on the hairs of the nose or at the bends of the nasal passages. Smaller particles
pass through the nasal region and are deposited in the tracheobronchial and pulmonary
regions. Particles are removed by impacting the wall of the bronchi when they are
unable to follow the gaseous streamline flow through subsequent bifurcations of the
bronchial tree. As the airflow decreases near the terminal bronchi, the smallest particles
are removed by Brownian motion, which pushes them to the alveolar membrane
(CEPA/FPAC Working Group, 1998; Dockery and Pope, 1994).
Air quality guidelines for particulates are given for various particle size fractions, including
total suspended particulates (TSP), inhalable particulates or PM10 (i.e. particulates with
an aerodynamic diameter of less than 10 µg/m3), and respirable particulates or PM2.5
(i.e. particulates with an aerodynamic diameter of less than 2.5 µg/m³). Although TSP is
defined as all particulates with an aerodynamic diameter of less than 100 µg/m³, an
effective upper limit of 30 µg/m³ aerodynamic diameter is frequently assigned. PM10 and
PM2.5 are of concern due to their health impact potentials. As indicated previously, such
fine particles can be deposited in, and can be damaging to, the lower airways and gas-
exchanging portions of the respiratory system.
PM10 limits and standards issued nationally and abroad are documented in Table 6-6.
Table 6-6: Air Quality Standard for Inhalable Particulates (PM10)
Authority
Maximum 24-
hour
Concentration
Annual Average
Concentration
µg/m³ µg/m³
RSA (NEMAQA) 75(a) 40
Australian Standards(b) 50 -
European Community(c) 50 40
United Kingdom(d) 50 40
United States EPA(e) 150 -
World Health Organisation(f) 20 50
Notes:
(a). Not to be exceeded more than four times in one year.
(b). Australian Ambient Air Quality Standards. (http://www.deh.gov.au/atrnosphere/airaualitv/standards.htrnl). Not to be
exceeded more than 5 days per year. Compliance by 2008.
(c). European Commission EU Air Quality Directive (2008/50/EC), WHO, 2006, Air quality guidelines: Global update 2005.
https://www.eea.europa.eu/themes/air/air-quality-standards (d). UK Air Quality Objectives.
https://uk-air.defra.gov.uk/assets/documents/Air_Quality_Objectives_Update.pdf. (e). US National Ambient Air Quality Standards (www.ena.gov/air/Criteria.htrnl). Not to be exceeded more than once per year
on average over 3 years. (f). WHO Ambient (outdoor) Air Quality and Health Guideline values. https://www.who.int/news-room/fact-
sheets/detail/ambient-(outdoor)-air-quality-and-health, 2 May 2018.
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6.4.2 AIR QUALITY STANDARDS AND GUIDELINES FOR PM2.5
The health effects of the finer particulates are significant. International and South African
recognition is held for the importance of guidelines for this pollutant. International and
South African guidelines are as documented in Table 6-7.
Table 6-7 : Air Quality Standards for Inhalable Particulates (PM2.5)
Authority
Maximum 24-hour
Concentration
Annual Average
Concentration
µg/m³ µg/m³
RSA (NEMAQA) 40(a) 20
Australian Standards (b) 25 8
European Community (c) - 25
United Kingdom(d) 25 10
United States EPA(e) 35 15
World Health Organisation (f) 25 10 Notes:
(a). Not to be exceeded more than four times in one year.
(b). Australian Ambient Air Quality Standards. (http://www.deh.gov.au/atrnosphere/airaualitv/standards.htrnl). (c). European Commission EU Air Quality Directive (2008/50/EC), WHO, 2006, Air quality guidelines: Global update 2005.
https://www.eea.europa.eu/themes/air/air-quality-standards.
(d). UK Air Quality Objectives. https://uk-air.defra.gov.uk/assets/documents/Air_Quality_Objectives_Update.pdf.
(e). US National Ambient Air Quality Standards (www.ena.gov/air/Criteria.htrnl).
(f). WHO Ambient (outdoor) Air Quality and Health Guideline values. https://www.who.int/news-room/fact-
sheets/detail/ambient-(outdoor)-air-quality-and-health 2 May 2018.
6.4.3 AIR QUALITY STANDARDS AND GUIDELINES FOR DUSTFALL AND DUST
CONTROL REGULATIONS
The National Dust Control Regulations GN 827:2013, prescribe general measures for the
control of dust in all areas. Dustfall standards for acceptable dustfall rates are given in
Table 6-8 for residential and non-residential areas. The regulations also provide a method
to be used for measuring dustfall rate and guideline for locating sampling points, the
method to be used is AST D1739:1970, or equivalent method approved by any
internationally recognised body.
Table 6-8: GN827:2013 Acceptable dustfall rates
Restriction Areas
Dustfall rate (D)
(mg/m2/day, 30-
days average)
Permitted frequency of exceeding
fall rate
Residential area D <600 Two within a year, not sequential
months
Non-residential area 600< D <1200 Two within a year, not sequential
months
6.4.4 AIR QUALITY STANDARDS AND GUIDELINES FOR SULPHUR DIOXIDE
Ambient air quality guidelines and standards issued for various countries and
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organisations for Sulphur dioxide (SO2) are given in Table 6-9. Although the South
African limits are in line with most of the international limits shown, it is important to
note that the WHO air quality guidelines (WHO AQGs) published in 2000 for SO 2
have been revised (WHO, 2005). Although the 10-minute AQG of 500 µg/m³ has
remained unchanged, the previously published daily guideline has been
significantly reduced from 125 µg/m³ to 20 µg/m³. The previous daily guideline was
based on epidemiological studies. WHO (2005) refers to more recent evidence
which suggests the occurrence of health risks at lower concentrations. Although
WHO (2005) acknowledges the considerable uncertainty as to whether SO 2 is the
pollutant responsible for the observed adverse effects (as it may be due to ultra-
fine particles or other correlated substances), it took the decision to publish a
stringent daily guideline in line with the precautionary principle. WHO (2005)
stipulates an annual guideline is not needed for the protection of human health,
since compliance with the 24-Hour level will assure sufficiently low levels for the
annual average.
Table 6-9: Air quality standard for Sulphur dioxide (SO2)
Authority
Maximum
10-minute
Average
Maximum
1-hour
Average
Maximum
24-hour
Average
Annual
Average
µg/m³ µg/m³ µg/m³ µg/m³
RSA (NEMAQA)(a) 500 350 125 50
Australian Standards*(b) 530 210 53
European Community(c) 350 125
United Kingdom(d) 350 125
United States EPA*(e) 200
World Health Organisation(f) 500 20
Notes:
(a). Not to be exceeded more than the allowable number of exceedances.
(b). Australian Ambient Air Quality Standards. (http://www.deh.gov.au/atrnosphere/airaualitv/standards.htrnl). (c). European Commission EU Air Quality Directive (2008/50/EC), WHO, 2006, Air quality guidelines: Global update 2005.
https://www.eea.europa.eu/themes/air/air-quality-standards
(d). UK Air Quality Objectives. https://uk-air.defra.gov.uk/assets/documents/Air_Quality_Objectives_Update.pdf.
(e). US National Ambient Air Quality Standards (www.ena.gov/air/Criteria.htrnl).
(f). WHO Ambient (outdoor) Air Quality and Health Guideline values. https://www.who.int/news-room/fact-
sheets/detail/ambient-(outdoor)-air-quality-and-health 2 May 2018.
*Values calculated using European commission conversion factor. https://uk-
air.defra.gov.uk/assets/documents/reports/cat06/0502160851_Conversion_Factors_Between_ppb_and.pdf
6.4.5 AIR QUALITY STANDARDS AND GUIDELINES FOR OXIDES OF NITROGEN
Ambient air quality guidelines and standards issued for various countries and
organisations for nitrogen dioxide are given in Table 6-10. The South African limit
threshold is in line with other international limits, but the 1-hr frequency of exceedances
allowed is less stringent.
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Table 6-10: Air Quality Standards for Nitrogen Dioxide (NO2)
Authority
Maximum
1-hour Concentration
Annual
Concentration
µg/m³ µg/m³
RSA (NEMAQA)(a) 200 40
Australian Standards*(b) 230 57
European Community(c) 200 40
United Kingdom(d) 200 40
United States EPA*(e) 192 101
World Health Organisation(f) 200 40
Notes:
(a). Not to be exceeded more than the allowable number of exceedances.
(b). Australian Ambient Air Quality Standards. (http://www.deh.gov.au/atrnosphere/airaualitv/standards.htrnl). (c). European Commission EU Air Quality Directive (2008/50/EC), WHO, 2006, Air quality guidelines: Global update 2005. No t to
be exceeded more than 35 times a year. https://www.eea.europa.eu/themes/air/air-quality-standards
(d). UK Air Quality Objectives. Not to be exceeded more than 18 times a year. https://uk-
air.defra.gov.uk/assets/documents/Air_Quality_Objectives_Update.pdf.
(e). US National Ambient Air Quality Standards (www.ena.gov/air/Criteria.htrnl).
(f). WHO Ambient (outdoor) Air Quality and Health Guideline values. https://www.who.int/news-room/fact-
sheets/detail/ambient-(outdoor)-air-quality-and-health 2 May 2018.
*Value calculated using European commission conversion factor. https://uk-
air.defra.gov.uk/assets/documents/reports/cat06/0502160851_Conversion_Factors_Between_ppb_and.pdf.
6.4.6 AIR QUALITY STANDARDS AND GUIDELINES CARBON MONOXIDE
During combustion, carbon in the fuel is oxidized through a series of reactions to form first
carbon monoxide (CO) and then carbon dioxide (CO2). The extent, or completion, of
the combustion process is measured by the extent of carbon transformation to carbon
monoxide and the following depletion of carbon monoxide to form carbon dioxide in
the flue gas. High levels of carbon monoxide output are due to incomplete combustion,
likely due to incorrect air-to-fuel ratio, poor burner design or poor operation and
maintenance (Cleaver Brooks, 1998).
CO and hydrocarbons are formed by incomplete combustion of the carbon content of
the fuel. Control is accomplished by air-staging (Miller & Miller, 2008: 299). Proper burner
maintenance, inspections, operation, or utilizing an oxygen control package are
additional methods for the control of carbon monoxide formation (Cleaver Brooks, 1998).
Table 6-11: Air Quality Standards for Carbon Monoxide (CO)
Authority
(all in µg/m³ unless
specified otherwise)
Maximum
15-min
Concentration
Maximum 1-
hour
Concentration
Maximum
8-hour
Concentration
Maximum 24-
hour
Concentration µg/m³ µg/m³ µg/m³ µg/m³
RSA (NEMAQA)(a) 30 000 10 000
Alberta, Canada(b) 15 000 6 000
SANS limits (SANS
1929:2005)(c) 30 10
Australia(d) - 9000
Ontario, Canada(e) 36 200 15 700
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Canada(f) 15 000 –
35 000
6 000 –
20 000
New Zealand(g) 30 000 10 000
Texas, USA(h) 35.50 ppm 9.50 ppm
European
Community(i) - 10
Japan(j) 10 ppm 20 ppm
South Korea(k) ≤ 25 ppm ≤ 9 ppm
United Kingdom(l) - 10
US EPA(m) 35 ppm 9 ppm
Vermont, USA(n) 2 000 500
World Health
Organisation(o) 100 000 30 10 7 000
Notes:
a) RSA, National Environmental Management: Air Quality Act, National Ambient Air Quality Standards (GN1210: 2009)
b) Alberta, 2009, Alberta Ambient Air Quality Objectives and Guidelines
c) SANS 1929:2005, 2011, South African National Standard. Ambient Air Quality – list of common pollutants, as amended.
d) Australia, 2016, Department of the Environment. Ambient Air Quality Standards.
e) Ontario’s Ambient Air Quality Criteria, 2012, Standards Development Branch Ontario Ministry of the Environment
f) Canadian Environmental Quality Guidelines, Summary of Existing Canadian Environmental Quality Guidelines, Canada, 2003
g) New Zealand, 2002, Ambient Air Quality Guidelines, 2002 Update
h) Texas Natural Resource Conservation Commission (TNRCC) 2001. Toxicology & Risk Assessment (TARA)
i) EC First Daughter Directive, 1999/30/EC (http://eurona.eu.int/comm/environment/air/ambient.htm). Limit to protect health, to
be complied with by 1 January 2005 (not to be exceeded more than 4 times per calendar year).
j) Japan, 1997, Environmental Quality Standards in Japan, https://www.env.go.jp/en/air/aq/aq.html
k) South Korea, 2010, Environmental Pollution Prevention Act (1963)
l) UK Air Quality Objectives. http://uk-air.defra.gov.uk/documents/National_air_quality_objectives.pdf
m) US EPA, National Ambient Air Quality Standards (NAAQS). https://www.epa.gov/criteria-air-pollutants/naaqs-table
n) State of Vermont, 2007, Air Pollution Control Regulations
o) World Health Organization (WHO). 2000. Air Quality Guidelines for Europe, 2nd Edition. WHO Regional Publications, European
Series, No. 91. WHO Regional Office for Europe, Copenhagen
6.4.7 AIR QUALITY STANDARDS AND GUIDELINES ARSENIC
Inorganic arsenic is usually found combined with other elements such as oxygen,
chlorine, and sulphur. Arsenic combined with elements such as oxygen, chlorine, and
sulphur forms inorganic arsenic with compounds including arsenic pentoxide, arsenic
trioxide, and arsenic acid. Arsenic combined with carbon and hydrogen forms organic
arsenic; organic arsenic compounds include arsenic acid, arsenobetaine, and
dimethylarsinic acid. These compounds are likely to form under combustion conditions
during thermal treatments on an industrial scale.
Acute (short-term) high-level inhalation exposure to arsenic dust or fumes has resulted in
gastrointestinal effects (nausea, diarrhoea, abdominal pain); central and peripheral
nervous system disorders have occurred in workers acutely exposed to inorganic arsenic.
Chronic (long-term) inhalation exposure to inorganic arsenic of humans is associated
with irritation of the skin and mucous membranes and effects in the brain and nervous
system. Chronic oral exposure to elevated levels of inorganic arsenic has resulted in
gastrointestinal effects, anaemia, peripheral neuropathy, skin lesions,
hyperpigmentation, and liver or kidney damage in humans. Inorganic arsenic exposure
of humans, by the inhalation route, has been shown to be strongly associated with lung
cancer, while ingestion of inorganic arsenic by humans has been linked to a form of skin
cancer and also to bladder, liver, and lung cancer. The United States Environmental
Protection Agency (US EPA) has classified inorganic arsenic as a human carcinogen.
(EPA 107-02-8).
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The maximum daily Canada Ontario Limit of 0.3 µg/m3 is adopted herein as a guideline
limit in the absence of a national ambient standard.
6.4.8 AIR QUALITY STANDARDS AND GUIDELINES ANTIMONY
Antimony is found at very low levels throughout the environment (ATSDR 1992) and its
concentration in ambient air ranges from less than 1 ng/m3 to about 170 ng/m3. Acute
(short-term) exposure to antimony by inhalation in humans results in effects on the skin
and eyes. Skin effects consist of a condition known as antimony spots, which is a rash
consisting of pustules around sweat and sebaceous glands, while effects on the eye
include ocular conjunctivitis. Oral exposure to antimony in humans has resulted in
gastrointestinal effects. (ATSDR 1992, NTIP 1993) Respiratory effects, such as inflammation
of the lungs, chronic bronchitis, and chronic emphysema, are the primary effects noted
from chronic (long-term) exposure to antimony in humans via inhalation. Human studies
are inconclusive regarding antimony exposure and cancer, while animal studies have
reported lung tumours in rats exposed to antimony trioxide via inhalation (US EPA, 2014).
The maximum daily Canada Ontario Limit of 25 µg/m3 is adopted herein as a guideline
limit in the absence of a national ambient standard.
6.4.9 AIR QUALITY STANDARDS AND GUIDELINES CADMIUM
Cadmium is a natural metal generally found bound to other elements such as chlorine,
oxygen, and sulphur within the earth’s crust. Cadmium can is found in soils, rocks,
fertilizers, and coal. Due to the low corrosivity of Cadmium, it is generally used in the
production of batteries, metal coatings and plastics. The common exposure to Cadmium
occurs through the food industry where fertilizers are utilized in crop production. Acute
inhalation of air with very high values of Cadmium can result in severe damage to the
lungs and may cause death. Chronic inhalation of low levels of Cadmium may cause
build-up within the kidneys resulting in kidney disease and damage (ATSDR, 2011).
The maximum daily and annual Canada Ontario Limit of 0.025 µg/m3 and 0.005 µg/m3,
respectively, are adopted herein as a guideline limit in the absence of a national
ambient standard.
6.4.10 AIR QUALITY STANDARDS AND GUIDELINES COBALT
Acute (short-term) exposure to high levels of cobalt by inhalation in humans and animals
results in respiratory effects, such as a significant decrease in ventilatory function,
congestion, oedema, and haemorrhage of the lung. Respiratory effects are also the
major effects noted from chronic (long-term) exposure to cobalt by inhalation, with
respiratory irritation, wheezing, asthma, pneumonia, and fibrosis noted. Cardiac effects,
congestion of the liver, kidneys, and conjunctiva, and immunological effects have also
been noted in chronically-exposed humans (EPA 2000)
The maximum daily Canada Ontario Limit of 0.1 µg/m3 is adopted herein as a guideline
limit in the absence of a national ambient standard.
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6.4.11 AIR QUALITY IMPACT, STANDARDS & GUIDELINES FOR CHROMIUM
COMPOUNDS
Elemental chromium (Cr) does not occur in nature, but is present in ores, primarily
chromite (FeCr2O4). The proposed processes will produce trivalent chromium products.
Only two of the several oxidation states of chromium, Cr(III) and Cr(VI), are reviewed
herein based on the anticipated emissions from the site and the stability of these
oxidation states in the ambient environment.
Chromium(III) is poorly absorbed, regardless of the route of exposure, whereas
chromium(VI) is more readily absorbed . Animal studies show that Cr(VI) is generally more
toxic than Cr(III), but neither oxidation state is very toxic by the oral route (RAIS, 1992). In
cognisance of this, and in cognisance of emissions to atmosphere with subsequent
dispersion to potential receptors being the pathway of most likely significance, this
assessment focuses of environmental exposure via inhalation.
According to Ontario Ministry of Environment, studies in rats have examined the lethality
of hexavalent chromium compounds, including chromium trioxide, sodium chromate
and potassium chromate. The 4-hour LC501 values ranged from 29 mg/m3 in females
exposed to potassium chromate up to 137 mg/m3 in males exposed to chromium trioxide
(Ontario 2004).
According to the U.S. Department of Energy (DOE), Office of Environmental
Management, estimated acute exposure Cr(VI) LC50 values for humans range from 5
mg/m3 for zinc chromate to 94 mg/m3 for potassium dichromate. The inhalation of
chromium can cause nasal ulcers and perforation of the nasal septum. The perforation
lesions do not disappear when exposure ceases. Nasal irritation has been observed
following short-term exposure to chromium levels of <0.01 mg/m3 (RAIS, 1992).
In respect of animals’ acute exposure the estimated LC50 values in the Sprague Dawley
rat (males and females combined) exposed to Cr(VI) compounds are: 158 mg/m3 for
ammonium dichromate, 104 mg/m3 for sodium chromate, and 94 mg/m3 for potassium
dichromate. Clinical signs of toxicity include respiratory distress and irritation and body
weight loss. Lethality data were not found for Cr(III) compounds (RAIS, 1992).
These exposure levels are orders of magnitude higher than those anticipated for ambient
exposure due to IGE’s emissions and thus chronic exposure is the focus of the assessment.
Results of occupational epidemiologic studies of chromium-exposed workers are
consistent across investigators and study populations. Dose response relationships have
been established for chromium exposure and lung cancer. Chromium-exposed workers
are exposed to both chromium III and chromium VI compounds. However, because only
chromium VI has been found to be carcinogenic in animals’ studies, it was concluded
that only chromium(VI) should be classified as a human carcinogen" (U.S. EPA, 1991)
1 LC50 is the mean concentration resulting in 50% lethality of an exposed population and is a
measure of toxicity.
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6.4.11.1 TOXICOLOGY OF CR(VI)
The following toxicological review of chromium is focused primarily on the inhalation
route of exposure.
The key criterion for assessing the risk of inhalation exposure to Cr(VI) compounds is their
carcinogenic potential. Cr (VI) is known to be carcinogenic in humans by the inhalation
route of exposure. The International Agency for Research on Cancer (IARC, 1990)
concluded that there is sufficient evidence in humans for the carcinogenicity of
hexavalent chromium compounds as encountered in chromate production, chromate
pigment production and chromium plating industries (where inhalation is the primary
route of exposure).
As the bronchial tree is the major target organ for carcinogenic effects of chromium(VI)
compounds, and cancer primarily occurs following inhalation exposure, uptake in the
respiratory organs is of great significance in respect of the subsequent risk of cancer in
humans. IARC has stated that for chromium and certain chromium compounds there is
sufficient evidence of carcinogenicity in humans (WHO, 2000).
Following oral exposure, absorption of chromium in the gastrointestinal tract is low, at an
estimated 5% or less. Studies on the uptake of chromium(VI) compounds in the
gastrointestinal tract indicate that the rate of uptake is to a great extent governed by
the water solubility of the compounds. Results from in vitro studies indicate that
gastrointestinal juices are capable of reducing Cr(VI) to chromium(III); however, data
from in vivo studies are insufficient to demonstrate whether this reduction process has
the capacity to eliminate any differences in absorption between ingested chromium(VI)
and chromium(III) compounds. Pulmonary cells have been shown in vitro to have some
capacity to reduce hexavalent chromium; however, this capacity is low compared to
that of liver cells (WHO, 2000).
According to WHO (2000), chrome ulcers, corrosive reactions on the nasal septum, acute
irritative dermatitis and allergic eczematous dermatitis have also been recorded among
subjects exposed to Cr(VI) compounds.
6.4.11.2 RISK ASSESSMENT UNIT RISK COEFFICIENTS AS BASIS FOR STANDARDS
The World Health Organisation (WHO) and some countries, most notably the US, have
based air quality standard setting on quantitative risk assessment methods. This
approach seeks to extrapolate occupational data to lower concentrations and
therefore to quantify the additional risk of cancer at concentrations likely to occur in the
environment. There are many ways in which this extrapolation can be made depending
upon the assumed mechanism of carcinogenesis. It should be noted that quantitative
risk estimates should not be regarded as being equivalent to the true cancer risk but
represent plausible upper bounds which may vary widely according to the assumptions
on which they are based (WHO, 2000). Quantitative risk assessment gives a unit risk factor
which can be used to calculate the concentrations of an airborne pollutant associated
with a particular level of excess lifetime risk.
In this respect the WHO (2000) calculates that if it assumed that a linear dose–response
relationship between exposure to Cr(VI) compounds and lung cancer exists, that no safe
level of Cr(VI) can be recommended; however, the WHO does not adequately
differentiate between species of Cr(VI) compounds and extrapolates to estimate them.
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At an air concentration of Cr(VI) of 1 µg/m³, the lifetime risk for lung cancer is estimated
to be 4 × 10-2 (derived by averaging the results of studies of four cohorts of chromate
production workers (WHO, 2000).
The RfC for non-cancer effects arising from exposure to Cr(VI), in the form of chromic
acid mists and dissolved Cr(VI) aerosols, is 8 ng/m3 based on nasal septum atrophy in
exposed workers. This is an estimate of an airborne concentration that is likely to be
without an appreciable risk of deleterious effects during a lifetime. The RfC for non-
cancer effects arising from exposure to Cr(VI) as particulate is 100 ng/m3 based on the
results of a 90 day study in rats. The confidence of the USEPA in their RfCs for chromic
acid mists and Cr(VI) dusts are low and medium, respectively. The same agency has
estimated the unit risk factor for lifetime (lung) cancer risk arising from exposure to Cr(VI)
to be 1.2x10-2 per µg/m3 in air (USEPA, 1998).
Care should be taken when deriving air quality standards from unit risk coefficients such
as those proposed by the WHO and US EPA because of the inherent uncertainty involved
in extrapolating from observed effects at high levels of exposure to responses at the
much lower concentrations commonly associated with environmental exposure.
In the context of this assessment the intent is to undertake a predictive risk assessment.
Therefore, the RFC values and international ambient air quality standards are used to
determine the potential risk associated with lifetime exposure to ambient concentrations
of Cr(VI) resulting from IGE’s predicted emissions.
6.4.11.3 EXISTING AIR QUALITY GUIDELINES FOR CHROMIUM COMPOUNDS
Internationally, there is an increasing trend towards the specification of air quality limits
for certain metals and various international standards for chromium compounds have
been set by various environmental authorities including various US States and EU
Countries. Notably neither the federal US government nor the EU governing council have
set standards for chromium and its compounds. The German Technical Instructions on
Air Quality Control (TA Luft) are in place to protect the environmental and human health
from harmful effects of air pollution (TA Luft, 2002). The technical instructions identify
Cr(VI) as a carcinogenic substance, hence the ambient air concentration of waste gas
of a new installation may not exceed 0.05 mg/m3.
It is notable from Table 6-12 below that there are numerous international ambient air
quality standards which exist for Cr(VI) and that these vary significantly in magnitude and
are based on varying methodologies and source data. A sound scientific basis for
selecting a single ambient standard for chronic exposure assessment is not possible within
the scope of this study. However it is notable that both WHO and US EPA reference
concentrations for risk assessment exist, and therefore a risk assessment approach based
on lifetime exposure provides a sound basis for chronic exposure assessment. Notably,
given that there is one ambient air quality standard for acute exposure (hourly), that
standard will accordingly be used to assess acute exposure risk.
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Table 6-12: Summary of Existing Air Quality Guidelines for Chromium (Cr)
Agency Guideline Value1 Basis of Guideline2 Date Comments
Canada
(CEPA)
0.66 μg/m3
(TC05)
For hexavalent chromium
Lung cancer in
chromate production
plant workers
(Mancuso, 1975)
1993 A Tumorigenic Concentration (TC05) is
the concentration generally in air
associated with a 5% increase in
incidence or mortality due to tumours.
The TC05 of 0.66 μg/m3 corresponds to
a concentration of 1.32x10-5
μg/m3 of
chromium (VI) in air for an increased
cancer risk of 1x10-6
.
4.6 μg/m3
(TC05)
For total chromium
Lung cancer in
chromate production
plant workers
(Mancuso, 1975)
1993 The TC05 of 4.6 μg/m3 corresponds to a
concentration of 0.011μg/m3 of
chromium (total) in air for an
increased cancer risk of 1x10-6
.
Alberta 1.0 μg/m3
(1-hour average)
Based on Texas’ short-
term ESL for chromium
(metal)
2000 Ambient Air Quality Guideline.
Manitoba 4.5 μg/m3 (1-hour average) Basis is unknown
1985 Maximum Acceptable Level
Concentration.
Ontario (MOE)
5 μg/m3 (½-hour average, POI)
For di-, tri- and hexavalent forms
1.5 μg/m3 (24-hour AAQC)
For di-, tri- and hexavalent forms
Health considerations
1982 Half-hour Point of Impingement
standard.
1-Hour Ambient Air Quality Criterion
(AAQC).
Ontario 3.5x10-4 μg/m3
(24-hour average)
Ambient Air Quality
Criteria
2012 Ambient Air Quality Guideline.
1 Guidelines in this table can refer to: guidelines, risk-specific concentrations based on cancer potencies, and non-cancer-based reference concentrations.
2 Date here refers to when the health-based guideline background report or original legislative initiative was issued. The sources were the respective agency
documents. For the US EPA, date refers to when the latest review of the RfC was conducted, if applicable, or the date the IRIS database was accessed, in the case
where no RfC has been developed
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Table 6-12: Summary of Existing Air Quality Guidelines for Chromium (Cr)
Agency Guideline Value1 Basis of Guideline2 Date Comments
For hexavalent chromium
7x10-5 μg/m3
(Annual average)
For hexavalent chromium
2012 Ambient Air Quality Guideline.
Quebec
(MENV)
8.0x10-5 μg/m3
(Annual average)
For hexavalent chromium
Based on the US EPA’s
inhalation unit cancer
risk of 1.2x10-2 (μg/m3)-1
1998 Air Quality Criteria – the criteria value
is the concentration of chromium (VI)
in air associated with an increased
cancer risk of 1x10-6.
4x10-3 μg/m3
(Annual average)
For hexavalent chromium
Basis is unknown 2014 Ambient Air Quality Guideline.
US EPA (IRIS)
8x10-3 μg/m3 (RfC)
For chromic acid mists and dissolved
Cr(VI)aerosols
Observed nasal septum
atrophy
(Hedenstierna, 1983)
1998 Reference Concentration for
inhalation (RfC).
0.1 μg/m3 (RfC)
For hexavalent chromium particulates
Lactate
dehydrogenase in
bronchioalveolar
lavage fluid
(Glaser et al., 1990;
Malsch et al., 1994)
1998
8x10-5 (μg/m3)-1
For hexavalent chromium
Increased incidence of
lung cancer in exposed
workers (Mancuso,
1975)
1998 1x10-6 additional cancer risk based on
a unit risk of 1.2x10-2 (μg/m3)-1.
California
(OEHHA)
0.2 μg/m3
(Chronic REL for hexavalent chromium
compounds)
Bronchoalveolar
hyperplasia in rats
(Glaser et al., 1990)
2001 Chronic Reference Exposure Level for
hexavalent chromium compounds.
0.002 μg/m3
(Chronic REL for chromium trioxide as
chromic acid mist)
Nasal atrophy, nasal
mucosal ulcerations,
nasal septal
perforations, transient
2001 Chronic Reference Exposure Level for
chromium trioxide as chromic acid
mist.
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Table 6-12: Summary of Existing Air Quality Guidelines for Chromium (Cr)
Agency Guideline Value1 Basis of Guideline2 Date Comments
pulmonary function
changes in humans
(Lindberg and
Hedenstierna, 1983)
7.0x10-6 μg/m3
(Cancer effect for chromium
compounds)
Lung cancer deaths
among employees of a
chromate plant
(Mancuso, 1975)
1986 1x10-6 additional cancer risk based on
a unit risk of 1.5x10-1 (μg/m3)-1.
Louisiana (DEP)
0.01 μg/m3
(annual)
TLV-TWA from ACGIH 1997 Ambient air standard.
Massachusetts
(DEP)
0.003 μg/m3 (24-hour, TEL)
1.0x10-4 μg/m3 (annual, AAL)
For chromic acid
Based on NIOSH’s TWA-
REL of 1.0 μg/m3
1995 Threshold Effects Exposure Limit (TEL).
Allowable Ambient Limit (AAL).
1.36 μg/m3
(24-hour, TEL)
0.68 μg/m3 (annual, AAL)
For chromium (metal)
Based on the ACGIH’s
TLV-TWA of 500 μg/m3
0.003 μg/m3 (24-hour, TEL)
1.0x10-4 μg/m3 (annual, AAL)
For hexavalent chromium compounds
Based on NIOSH’s TWA-
REL of 1.0 μg/m3
Michigan
(DEQ)
0.5 μg/m3
(24-hour average ITSL)
For chromic (+3) oxide and chromium
(+3) hydroxide
Based on respiratory
tract effects observed in
exposed rats (Derelanko
et al. 1999)
2000 Initial Threshold Screening Level. Used
for permitting.
0.008 μg/m3 (24-hour ITSL)
8.3x10-5 μg/ m3 (annual IRSL)
8.3x10-4 μg/ m3 (annual SRSL)
These values were derived for hexavalent
chromium mist
Based on the US EPA’s
RfC
Based on the US EPA’s
inhalation unit risk
Based on the US EPA’s
inhalation unit risk
1998 Initial Threshold Screening Level. Used
for permitting.
Initial Risk Screening Level (IRSL).
Secondary Risk Screening Level (SRSL).
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Table 6-12: Summary of Existing Air Quality Guidelines for Chromium (Cr)
Agency Guideline Value1 Basis of Guideline2 Date Comments
0.1 μg/m3 (24-hour ITSL)
8.3x10-5 μg/ m3 (annual IRSL)
8.3x10-4 μg/ m3 (annual SRSL)
These values were derived for hexavalent
chromium particulate
Based on the US EPA’s
RfC
Based on the US EPA’s
inhalation unit risk
Based on the US EPA’s
inhalation unit risk
1998 Initial Threshold Screening Level. Used
for permitting.
Initial Risk Screening Level (IRSL).
Secondary Risk Screening Level (SRSL).
5 μg/ m3 (8-hour ITSL)
For trivalent chromium
Based on the ACGH’s
TLV-TWA
1995 Initial Threshold Screening Level. Used
for permitting.
0.1 μg/m3
(Annual average)
For hexavalent chromium
Basis is unknown 2017 Ambient Air Quality Guideline.
New Jersey
(DEP)
8.0x10-3 μg/ m3 (RfC)
For chromic acid mists (Cr VI) and
dissolved hexavalent chromium aerosols
Based on the US EPA’s
RfC
2003 Reference Concentration for
Inhalation.
0.1 μg/m3
For hexavalent chromium particulates
Based on the US EPA’s
RfC
2003
2.0x10-3 μg/m3
For total chromium
Based on the US EPA’s
HEAST (1997)
2003
8x10-5 μg/m3
For hexavalent chromium
Based on the US EPA’s
inhalation unit risk value
2003 1x10-6 additional cancer risk based on
a unit risk of 1.2x10-2 (μg/m3)-1.
New York
(DEC)
4.2x10-5 – 6.3x10-5 μg/m3
(annual, AGCs)
For various chromic acid compounds
Based on the chronic
REL of the OEHHA for
chromium trioxide as
chromic acid mist
2003 The values for the individual
compounds were adjusted based on
the ratio of the molecular weights.
1.2 μg/m3
(annual, AGC)
For chromium (elemental)
Based on the ACGIH’s
TLV-TWA
2003 Ambient Guideline Concentration.
Used for permitting.
4.5x10-5 – 0.59 μg/m3
(annual, AGCs)
For various chromium compounds
Based on the ACGIH’s
TLV-TWA
2003 The values for the individual
compounds were adjusted based on
the ratio of the molecular weights.
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Table 6-12: Summary of Existing Air Quality Guidelines for Chromium (Cr)
Agency Guideline Value1 Basis of Guideline2 Date Comments
0.1 μg/m3
(annual, AGC)
For trivalent chromium
Based on the ACGIH’s
TLV-TWA
2003 Ambient Guideline Concentration.
Used for permitting.
2.0x10-5 μg/m3
(annual, AGC)
For hexavalent chromium
Based on the chronic
REL of the OEHHA for
chromium trioxide as
chromic acid mist
2003 Ambient Guideline Concentration.
Used for permitting.
North Carolina
(DENR)
0.62 μg/m3
(24-hour, AAL)
For soluble chromate compounds, as
hexavalent chromium equivalent
Basis is unknown.
1987 Acceptable ambient level (AAL).
Used for permitting.
8.3x10-5 μg/m3
For bioavailable chromate pigments and
non-specific hexavalent chromium
compounds, as hexavalent chromium
equivalent
Based on the US EPA’s
inhalation unit risk
1987 1x10-6 additional cancer risk based on
a unit risk of 1.2x10-2 (μg/m3)-1.
Texas (TCEQ)
1.0 μg/m3 (1-hour ESL)
0.1 μg/m3 (annual ESL)
For chromium metal and chromium (II)
and (III) compounds
TLV from ACGIH
Not
stated
Short-term Effects Screening Level.
Long-term Effects Screening Level.
Used for permitting.
0.1 μg/m3 (1-hour ESL)
0.01 μg/m3 (annual ESL)
For chromium trioxide, chromic acid,
chromate, and hexavalent chromium
compounds
4.3x10-3 μg/m3
(Annual average)
For Hexavalent chromium
Based on an inhalation
unit risk factor (URF) of
2.3x10-3 per μg/m3 and
a no significant risk level
of 1 in 100 000 excess
cancer risk, and
2014 Ambient Air Quality Guidelines.
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Table 6-12: Summary of Existing Air Quality Guidelines for Chromium (Cr)
Agency Guideline Value1 Basis of Guideline2 Date Comments
applicable to all forms
of Cr(VI) compounds.
Vermont 8.3x10-5 μg/m3
(Annual average)
For hexavalent chromium
Air Pollution Control
Regulations
2007 Ambient Air Quality Guidelines.
The
Netherlands
(RIVM)
2.5x10-5 μg/m3 (annual, target value)
2.5x10-3 μg/m3 (annual, MPC)
Based on the WHO
inhalation unit risk for
hexavalent chromium
1999 Maximum Permissible Concentration
(MPC). The MPC is used for emissions
permitting purposes. The target value
represents a long-term air quality
goal.
New Zealand 1.1x10-3 μg/m3
(Annual average)
For hexavalent chromium
Top end of WHO values
but lower than the US
EPA’s carcinogen value.
2002 Ambient Air Quality Guideline.
European
Union (EU)
21 μg/m3
(HT25)
Based on the US EPA’s
inhalation unit risk of
1.2x10-2 (μg/m3)-1
2002 The HT25 is human dose equivalent of
the chronic daily dose rate which will
give 25% of the animals’ tumours at a
specific tissue (Sanner et al., 2002).
WHO (Europe)
2.5x10-5 μg/m3
For hexavalent chromium
Increased incidence of
cancer in exposed
chromate workers. The
inhalation unit risk value
was derived by
calculating the
geometric mean of the
accepted study lifetime
risks identified by the
WHO [range of risk
estimates from 0.13-
0.011 (μg/m3)-1]
2000 Ambient air guideline value.
1x10-6 additional cancer risk based on
a derived unit risk of 4x10-2 (μg/m3)-1.
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Table 6-12: Summary of Existing Air Quality Guidelines for Chromium (Cr)
Agency Guideline Value1 Basis of Guideline2 Date Comments
1 Guidelines in this table can refer to: guidelines, risk-specific concentrations based on cancer potencies, and non-cancer-based
reference concentrations. 2 Date here refers to when the health-based guideline background report or original legislative initiative was issued. The sources were
the respective agency documents. For the US EPA, date refers to when the latest review of the RfC was conducted, if applicable, or
the date the IRIS database was accessed, in the case where no RfC has been developed
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6.4.11.4 DEFINING ACCEPTABLE RISK
The notion that there is some level of risk that everyone will find acceptable is a difficult
idea to reconcile and yet, without such a baseline, it may never be possible to set
guideline values and standards, given that life can never be risk free.
One definition of acceptable risk that has been widely accepted in environmental
regulation, is if lifetime exposure to a substance increases a person’s chance of
developing cancer by one chance in a million or less. This level, which has come to be
taken as ‘essentially zero’, was apparently derived in the US in the 1960s during the
development of guidelines for safety testing in animal studies. A figure, for the purposes
of discussion, of 1 chance in 100 million (or 10-7) of developing cancer was put forward
as safe. This figure was adopted by the Food and Drug Administration in 1973 but
amended to one in a million in 1977. This level of 10–6 has been seen as something of a
gold standard ever since. The US Environmental Protection Agency (EPA) typically uses
a target reference risk range of 1 in 10 000 to 1 in 1 000 000 (or 10–4 to 10–6) for carcinogens
in drinking water, which is in line with World Health organization (WHO) guidelines for
drinking water quality which, where practical, base guideline values for genotoxic
carcinogens on the upper bound estimate of an excess lifetime cancer risk of 1 in 100 000
(or 10–5) (Adapted from WHO 2001).
Similar approaches have been adopted elsewhere and for other risks. In the UK, for
example, the Health and Safety Executive (HSE) adopted the following levels of risk, in
terms of the probability of an individual dying in any one year:
• 1 in 1000 as the ‘just about tolerable risk’ for any substantial category of workers
for any large part of a working life.
• 1 in 10,000 as the ‘maximum tolerable risk’ for members of the public from any
single non-nuclear plant.
• 1 in 100,000 as the ‘maximum tolerable risk’ for members of the public from any
new nuclear power station.
• 1 in 1,000,000 as the level of ‘acceptable risk’ at which no further improvements
in safety need to be made.
These probabilities may alternatively be represented as a percentage probability of
occurring as illustrated in Table 6-13.
Table 6-13: Risk expressed as a probability of occurring
Percentage
likelihood Fraction Risk description
0.1% to 0.01% 1 in 1 000 to 1 in 10 000
‘just about tolerable risk’ for any
substantial category of workers for
any large part of a working life
0.01% to 0.001% 1 in 10 000 to 1 in 100 000
maximum tolerable risk’ for
members of the public from any
single non-nuclear plant
0.001% to 0.0001% 1 in 100 000 to 1 in 1 000 000
maximum tolerable risk’ for
members of the public from any
new nuclear power station
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Table 6-13: Risk expressed as a probability of occurring
Percentage
likelihood Fraction Risk description
Less than 0.0001% Less than 1 in 1 000 000
‘acceptable risk’ at which no
further improvements in safety
need to be made
In general, regulatory agencies tend to use default approaches for carcinogens. For risks
calculated to be linear at low doses, agencies use acceptable risk levels ranging from 1
in 10 000 to 1 in 1 000 000 (or 10-4 to 10-6) (Niemi 2013).
The cancer risk range that is deemed acceptable in various parts of the world is from 1
in 10 000 to 1 in 1 000 000. This risk range reflects a de minimis lifetime risk that is so trivial
that any action to reduce risk is not warranted (Kocher and Hoffman, 1994).
Accordingly, life time exposure risk ratings have been adopted in this study with 1 in 10
000 as the maximum tolerable risk to the public and any lesser risk being deemed to be
within the de minimis range. To put this into context for South Africa, it must be noted that
the overall (background) cancer risk for South Africans in 2009 was 1 in 8 for men and 1
in 9 for women (Herbst, 2015).
6.4.12 AIR QUALITY STANDARDS AND GUIDELINES COPPER
Inhalation of copper dust and fumes (from copper producing and processing facilities)
can affect the respiratory tract causing coughing, sneezing, and pain in the chest. It also
can adversely affect the gastrointestinal tract causing nausea and diarrhoea. Liver and
endocrine function may also be affected. Some studies have shown changes in blood
including decreased haemoglobin and erythrocyte count after exposure to copper by
inhalation. Copper dust and fumes can cause eye irritation, headaches and muscle
aches (ASTDR 2004).
The maximum daily Canada Ontario Limit of 50 µg/m3 is adopted herein as a guideline
limit in the absence of a national ambient standard.
6.4.13 AIR QUALITY STANDARDS AND GUIDELINES LEAD
The major sources of lead (Pb) emissions have historically been from fuels in on-road
motor vehicles and industrial sources. Once taken into the body, lead distributes
throughout the body in the blood and is accumulated in the bones. Depending on the
level of exposure, lead can adversely affect the nervous system, kidney function,
immune system, reproductive and developmental systems, and the cardiovascular
system. Lead exposure also affects the oxygen carrying capacity of the blood. The lead
effects most commonly encountered in current populations are neurological effects in
children and cardiovascular effects (e.g., high blood pressure and heart disease) in
adults. Infants and young children are especially sensitive to even low levels of lead,
which may contribute to behavioural problems, learning deficits and lowered IQ.
Ambient air quality guidelines and standards issued by various agencies and
organisations for Pb are given in Table 6-14. South African limit is consistent with the WHO
annual standard as proposed in 2000.
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Table 6-14: Air Quality Standards for Lead (Pb)
Authority
Maximum
1-hour
Concentration
Annual
Concentration
µg/m³ µg/m³
RSA (NEMAQA)(a) 0.5
Canada(b) 1.1
Ontario, Canada(c) 0.5
World Health Organisation(d) 0.5
Notes:
(a). Not to be exceeded.
(b). Canadian Environmental Quality Guidelines, Summary of Existing Canadian Environmental Quality Guidelines, Canada, 2003
(c). Ontario’s Ambient Air Quality Criteria, 2012, Standards Development Branch Ontario Ministry of the Environment
(d). WHO Ambient (outdoor) Air Quality and Health Guideline values. https://www.who.int/news-room/fact-
sheets/detail/ambient-(outdoor)-air-quality-and-health 2 May 2018.
6.4.14 AIR QUALITY STANDARDS AND GUIDELINES FOR MANGANESE
Manganese (Mn) is a heavy metal element that can exist in several valence states: 1, 2,
3, 4, 6 or 7; the most common being +2, +3 and +7. Although the toxicity of some metals
varies significantly depending on their oxidation state, there is not enough data to
determine significant adverse effects associated with the different forms of Mn (Mn(II),
Mn(III), and Mn(IV)) (Alberta, 2004).
Present in all living organisms, manganese (Mn) is an essential element and a cofactor
required for some enzymatic reactions. The toxicity of Mn can be determined by the
route of exposure. When ingested, Mn is considered one of the least toxic trace metals;
inhalation, however, can produce significant neurotoxicity (manganism [Mn toxicity])
(Alberta, 2004).
The primary end points of human toxicity associated with inhalation of inorganic
manganese compounds related to particulate matter are neurotoxicity, reproductive
dysfunction, and impairment of the respiratory system.
When absorption occurs via the respiratory tract, Mn does not pass through the liver
before circulating through the body. Once Mn enters the systemic circulation it is
transported in the plasma, distributed throughout the entire body, and is commonly
found in human tissue (including the brain), blood, serum, and urine. Manganese
concentrates in mitochondria and thus is found in tissues with high amounts of
mitochondria (pancreas, liver, kidneys, and intestines). It crosses the blood-brain barrier
and is retained longer in the brain than in the rest of the body (half-life in the body is 37
days); Mn (II) accumulates in the mitochondria in parts of the brain associated with
Manganism and neurological symptoms. Retention in tissues usually occurs with chronic,
not acute exposures. Manganese (Mn) also binds to melanin and thus accumulates in
cells containing melanin (Alberta, 2004).
Chronic effects generally occur as a result of long-term exposure to low concentrations
of long duration – generally repeated exposures for more than 12 months. The majority
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of human inhalation exposure data available has been collected after occupational
exposures. There are a number of limitations to be considered when using data from
people exposed in the work place:
(i) The person exposed generally is a healthy, young to middle aged, male adult;
(ii) Concurrent exposures to other chemicals are very likely; and
(iii) The exposure concentrations are often difficult to define.
The limits stipulated by international organisations for manganese over various averaging
periods are documented in Table 6-15 to Table 6-17. The guideline limit applied in this
study for comparison is the 2.5 µg/m3 24-hour from the Ontario MOE.
Table 6-15: Annual Average standards and guidelines for Manganese (Mn)
Country or
Agency Description
Value
(µg/m3)
Reference and Supporting
Documentation
US EPA
Reference
concentration
(RfC) 0.05
US Environmental Protection Agency.
IRIS
California
EPA
Chronic
reference
exposure level
(REL) 0.2
California Environmental Protection
Agency (Cal EPA). 1999. Determination
of Acute Reference Exposure Levels for
Airborne Toxicants.
New
Hampshire
DES Annual AAL 0.05
New Hampshire Administrative Rule.
Chapter Env-A 1400. Regulated Toxic Air
Pollutants. New Hampshire Department
of Environmental Services.
New Jersey
DEP
Risk
assessment
approach is
used (RfC) 0.05
New Jersey Administrative Code
(NJAC). Title 7, Chapter 27, Subchapter
8. New Jersey Department of
Environmental Protection.
Texas CEQ
Effects
screening
level (ESL) 0.2
Texas Natural Resource Conservation
Commission (TNRCC) 2001. Toxicology &
Risk Assessment (TARA) Section Effects
Screening Levels.
Vermont
ANR
Hazardous
ambient air
standard
(HAAS) 119
Vermont Air Pollution Control
Regulations. 2001. State of Vermont
Agency of Natural Resources.
World Health
Organization
Ambient air
guidance
value
0.15
World Health Organization (WHO). 2000.
Air Quality Guidelines for Europe, 2nd
Edition. WHO Regional Publications,
European Series, No. 91. WHO Regional
Office for Europe, Copenhagen. 273 pp
Average (g/m3 25°C 1
Atmosphere) 15.0
Table 6-16: 24-Hour Average standards and guidelines for Manganese (Mn)
Country or
Agency Description
Value
(µg/m3)
Reference and Supporting
Documentation:
Ontario
MOE
Ambient Air
Quality
Criterion
2.5
Ontario Ministry of the Environment.
1999. Point of Impingement Standards,
Point of Impingement Guidelines, and
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Table 6-16: 24-Hour Average standards and guidelines for Manganese (Mn)
Country or
Agency Description
Value
(µg/m3)
Reference and Supporting
Documentation:
(AAQC) Ambient Air Quality Criteria (AAQC).
1999. 12 pp.
Michigan
DEQ
Initial threshold
screening level
(ITSL)
0.05
Michigan Administrative Code (MAC).
Air Pollution Control Rules. Part 2 Air Use
Approval, R 336.1201 - 336.1299.
New
Hampshire
DES
24-hour
ambient air
limit (AAL)
1.006
New Hampshire Administrative Rule.
Chapter Env-A 1400. Regulated Toxic Air
Pollutants.
North
Carolina
ENR
Acceptable
ambient level
(AAL)
0.031
North Carolina Administrative Code
(NCAC). North Carolina Air Quality Rules
15A NCAC 2D.1100 – Air Pollution
Control Requirements
Oklahoma
DEQ
Maximum
acceptable
ambient
concentration
(MAAC)
100
Oklahoma Administrative Code (OAC).
Title 252. Chapter 100. Air Pollution
Control. 100:252-41 - Control of Emission
of Hazardous and Toxic Air
Contaminants.
Washington
DOE
Acceptable
source impact
level (ASIL)
0.4
Washington Administrative Code
(WAC). Chapter 173-460 WAC. Controls
for New Sources of Toxic Air Pollutants.
Wisconsin
DNR
Ambient air
concentration
(AAC)
4.8 Wisconsin Administrative Code (WAC).
Air Pollution Control Rules. NR 445.
Average (g/m3 25°C 1
Atmosphere) 15.5 (g/m3 25°C 1 Atmosphere)
Table 6-17: 8 Hour and 1 Hour Average standards and guidelines for Manganese
(Mn)
Time
Country
or
Agency
Description Value
(µg/m3)
Reference and Supporting
Documentation
8 h
Louisiana
DEQ
Ambient
air
standard
(AAS)
4.76
Louisiana Administrative Code
(LAC). Title 33 Environmental
Quality, Part III Air, Chapter 51.
Comprehensive Toxic Air Pollutant
Emission Control Program.
Average
(g/m3
25°C 1
Atm)
4.76
1 h
Ontario
MOE
Guideline
(30-min.
averaging
time)
7.5
Ontario Ministry of the Environment.
1999. Point of Impingement
Standards, Point of Impingement
Guidelines, and Ambient Air Quality
Criteria (AAQC). 1999. 12 pp.
Ohio EPA
Maximum
acceptabl
e ground-
level
119
Ohio Environmental Protection
Agency (EPA). 2003. Review of New
Sources of Toxic Emissions. Air Toxics
Unit, Division of Air Pollution Control,
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Table 6-17: 8 Hour and 1 Hour Average standards and guidelines for Manganese
(Mn)
Time
Country
or
Agency
Description Value
(µg/m3)
Reference and Supporting
Documentation
concentrat
ion
(MAGLC)
Ohio EPA.
Rhode
Island
DEM
Acceptabl
e ambient
level (AAL)
2
Rhode Island Department of
Environmental Management. 1992.
Air Pollution Control Regulation No.
22.
Texas
CEQ
Effects
screening
level (ESL)
2
Texas Natural Resource
Conservation Commission (TNRCC)
2001. Toxicology & Risk Assessment
(TARA)
Average
(g/m3
25°C 1
Atm)
32.63
6.4.15 AIR QUALITY STANDARDS AND GUIDELINES FOR NICKEL
Nickel is typically found as a component of silicate, sulphide, or arsenide ores and it is
found in the environment primarily combined with oxygen or sulphur as oxides or
sulphides. Respiratory effects have been reported in humans from inhalation exposure to
nickel. Human and animal studies have reported an increased risk of lung and nasal
cancers from exposure to nickel refinery dusts and nickel sub-sulphide. Animal studies of
soluble nickel compounds (i.e., nickel carbonyl) have reported lung tumours. EPA has
classified nickel refinery dust and nickel sub-sulphide as Group A, human carcinogens,
and nickel carbonyl as a Group B2, probable human carcinogen. Human studies have
reported an increased risk of lung and nasal cancers among nickel refinery workers
exposed to nickel refinery dust. Nickel refinery dust is a mixture of many nickel
compounds, with nickel sub-sulphide being the major constituent (EPA/600/8-83/012F).
The maximum daily Canada Ontario Limit, for Nickel in TSP, of 0.2 µg/m3 (and annual of
0.04 µg/m3) is adopted herein as a guideline limit in the absence of a national ambient
standard.
6.4.16 AIR QUALITY STANDARDS AND GUIDELINES FOR VANADIUM
Vanadium is a bright, white, ductile, and malleable, transition metal in its pure form. It is
often found in the iron related ores as Vanadium pentoxide (V2O5). Vanadium may also
be released during the combustion of coal in particulates. Inhalation exposure may result
in diffusion through the lungs into the bloodstream. A number of studies report acute and
chronic respiratory effects mainly due to V2O5 exposure. Bronchitis and pneumonitis may
occur at high levels of V2O5 and V2O3 exposure (WHO, 2000). Typical symptoms include:
• Changes in parameters of lung functions (Lees, 1980).
• Respiratory irritation (Zenz & Berg, 1967; Lewis, 1959; Nishiyama et al, 1977).
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• Irritating changes of mucous membranes of upper respiratory tract (Kiviluoto
et al, 1979)
The maximum hourly WHO Limit of 1 µg/m3 is adopted herein as a guideline limit in the
absence of a national ambient standard. Canada Ontario also has an hourly limit which
is less stringent at 2 µg/m3.
6.4.17 AIR QUALITY STANDARDS AND GUIDELINES FOR AMMONIA
Ammonia is a strong alkaline chemical, that in gas form is colourless with a pungent
odour that is noticeable in concentrations above 50 ppm (US EPA, 1995; California, 2010).
Ammonia is widely used in the industrial sector as a feed stock for nitrogen-based
chemicals such as fertilizers, plastics, and explosives (California, 2010). Further industries,
such as fossil fuel combustion, livestock management and refrigeration methods, are
emitters of ammonia (US EPA, 1995). Ammonia is an essential constituent of secondary
inorganic aerosols and thus contributes to PM2.5 (Schneider et al, 2014). It can be
poisonous if inhaled in great quantities and is irritating to the eyes, nose, and throat in
lesser amounts.
The United States and California EPA values are all based on the same occupational
study conducted by Holness et al (1989), and subsequently the Massachusetts value is
based off these two limits (Massachusetts, 2011). The maximum hourly Michigan limit of
350 µg/m3 and the USEPA, California and Michigan daily limit of 100 µg/m3 was adopted
herein as a guideline limit in the absence of a national ambient standard. No air quality
standards have been set in South Africa for Ammonia, international guideline for NH3 is
given in Table 6-18.
Table 6-18: Air Quality Standards for Ammonia (NH3)
Authority
Maximum
1-hour
Concentration
Maximum
24-hour
Concentration
Annual
Concentration
µg/m³ µg/m³ µg/m³
Alberta, Canada(a) 1 400
California, USA(b) 200
Ontario, Canada(c) 100
Massachusetts, USA(d) 100 100
Michigan, USA(e) 350
New Zealand(f) 8
Vermont, USA(g) 100
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Table 6-18: Air Quality Standards for Ammonia (NH3)
Authority
Maximum
1-hour
Concentration
Maximum
24-hour
Concentration
Annual
Concentration
µg/m³ µg/m³ µg/m³
Notes:
(a). Alberta, 2009, Alberta Ambient Air Quality Objectives and Guidelines
(b). California, 2010, OEHHA Acute, 8-hour and Chronic Reference Exposure Levels (RELs)
(c). Ontario’s Ambient Air Quality Criteria, 2012, Standards Development Branch Ontario Ministry of the Environment
(d). MassDEP Ambient Air Toxics Guidelines, Massachusetts Government, Department of Energy and Environmental Affairs,
https://www.mass.gov/service-details/massdep-ambient-air-toxics-guidelines#Background
(e). Michigan Department Environmental Quality - Air Quality Division, List of Screening Levels (ITSL, IRSL and SRSL) in Alphabetical Order,
https://www.michigan.gov/documents/deq/deq-aqd-toxics-ITSLALPH_244167_7.pdf
(f). New Zealand, 2002, Ambient Air Quality Guidelines, 2002 Update
(g). State of Vermont, 2007, Air Pollution Control Regulations
6.4.18 AIR QUALITY STANDARDS AND GUIDELINES FOR MERCURY
Mercury in its elemental form is a dense, silvery-white, shiny metal, which is liquid at room
temperature and boils at 357 °C. Mercury is emitted to the atmosphere by natural
degassing of the earth’s surface and by re-evaporation of mercury vapour previously
deposited on the earth’s surface (WHO, 2005). Annual natural emissions are estimated
between 2700 and 6000 tonnes, of which some originates from anthropogenic activities.
Mercury is used in chloralkaline plants (producing chlorine and sodium hydroxide), in
paints as preservatives or pigments, electrical switching equipment and batteries, in
measuring and control equipment, in the production and use of high explosives using
mercury fulminate and in fungicides in the agricultural sector (WHO, 2005).
In adults, the daily amount of mercury vapour absorbed into the bloodstream from the
atmosphere as a result of respiratory exposure is about 32 ng in rural areas and about
160 ng in urban areas, assuming rural concentrations of 2 ng/m³ and urban
concentrations of 10 ng/m³ (WHO, 2005). The health effects of mercury vapour results
mainly in damage of the nervous system, but effects are also seen in the oral mucosa
and kidneys (WHO, 2005).
The maximum daily Ontario limit of 2 µg/m3 is adopted herein as a guideline limit in the
absence of a national ambient standard. The WHO annual limit of 1 µg/m3 is also
adopted here (WHO, 2005). No air quality standards have been set in South Africa for
Mercury, international guideline for Hg is given in Table 6-19.
Table 6-19: Air Quality Standards for Mercury (Hg)
Authority
Maximum
1-hour
Concentration
Maximum
24-hour
Concentration
Annual
Concentration
µg/m³ µg/m³ µg/m³
California(a) 0.03
Ontario, Canada(b) 2
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Table 6-19: Air Quality Standards for Mercury (Hg)
Authority
Maximum
1-hour
Concentration
Maximum
24-hour
Concentration
Annual
Concentration
µg/m³ µg/m³ µg/m³
Massachusetts, USA(c) 0.14 0.07
Michigan, USA(d) 1 0.3
New Zealand(e) 0.13
Vermont, USA(f) 0.02 0.3
World Health Organisation(g) 1
Notes:
(a). California, 2010, OEHHA Acute, 8-hour and Chronic Reference Exposure Levels (RELs)
(b). Ontario’s Ambient Air Quality Criteria, 2012, Standards Development Branch Ontario Ministry of the Environment
(c). MassDEP Ambient Air Toxics Guidelines, Massachusetts Government, Department of Energy and Environmental Affairs,
https://www.mass.gov/service-details/massdep-ambient-air-toxics-guidelines#Background
(d). Michigan Department Environmental Quality - Air Quality Division, List of Screening Levels (ITSL, IRSL and SRSL) in Alphabetical Order,
https://www.michigan.gov/documents/deq/deq-aqd-toxics-ITSLALPH_244167_7.pdf
(e). New Zealand, 2002, Ambient Air Quality Guidelines, 2002 Update
(f). State of Vermont, 2007, Air Pollution Control Regulations
(g). WHO (2005) “WHO Air quality guidelines for particulate matter, ozone, nitrogen dioxide and sulphur dioxide.” Chapter 6.9: Mercury
6.4.19 AIR QUALITY STANDARDS AND GUIDELINES FOR HCL AND HF
Hydrogen fluoride (HF) and hydrogen chloride (HCl) are often emitted from waste
incineration when the high hydrogen content of waste along with chlorine and fluorine
from plastics and other materials react to form HCl and HF.
HCl is a sensory and respiratory irritant. Being highly soluble in water, following inhalation
the gas is readily deposited in the nose and upper respiratory tract. At raised
concentrations and at high breathing rates, it may penetrate deeper into the lower
respiratory tract.
HF is a highly irritating and corrosive gas with a pungent odour. Skin contact with liquid
HF can cause severe burns. It is a severe irritant to eyes, skin, and nasal passages. When
inhaled, the absorption of HF will be virtually complete, due to a strong reaction with
mucous membranes at the site of deposition. On absorption, HF gives rise to the fluoride
ion that is taken up by bone and enamel in teeth and is excreted mainly in the urine.
The critical effects of chronic exposure to low concentrations of hydrogen fluoride are
due to the systemic effects of fluoride (fluorosis), which affects the skeleton. Classical
symptoms are osteosclerosis, exostosis and ossification of ligaments (DEFRA 2006).
No air quality standards have been set in South Africa for HCl and HF, international
guideline for HCl is given in Table 6-20.
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Table 6-20: International ambient standards and guidelines for various pollutants
Pollutant (all in µg/m3 unless specified otherwise)
Averaging
Period
1-hour 24-hour
Hydrogen Chloride (HCl) 75 (a) 20 (a)
Hydrogen Fluoride (HF) 16 (b) 0.86 (a) a - Canada Ontario National Ambient Air Quality Limits (2012) b – United Kingdom Air Quality Standards (2008)
6.4.20 AIR QUALITY STANDARDS AND GUIDELINES FOR DIOXINS AND FURANS
(A.K.A. PCDD’S):
A dioxin is any compound containing the di-benzo-p-dioxin nucleus, while a furan is any
compound containing the di-benzofuran nucleus. The general formulae for each of
these are illustrated in Figure 6-1.
Figure 6-1: General structure for Dioxins (A) and Furans (B)
Dioxins and furans (polychlorinated dibenzo-para-dioxins and polychlorinated
dibenzofurans (PCDDs / PCDFs)) are hazardous air pollutants (HAPs). It is generally
accepted that dioxins and furans can be formed in thermal processes where chlorine
containing substances are burned together with carbon and a suitable catalyst in the
presence of excess air or oxygen. Dioxin and furan formation also tend to occur in the
zone when combustion gases cool from about 450 to 250 °C (de novo synthesis) and not
in the combustion chamber. Copper, iron, zinc, aluminium, chromium, and manganese
are known to catalyse PCDD/PCDF formation (UNEP 2005).
Dioxins and furans can cause a number of health effects. The U.S. EPA (EPA) has noted
that it is likely to be a cancer-causing substance to humans. In addition, people exposed
to dioxins and furans have experienced changes in hormone levels. High doses of dioxin
have caused chloracne. Animal studies show that animals exposed to dioxins and furans
experienced changes in their hormone systems, changes in the development of the
foetus, decreased ability to reproduce and suppressed immune system (ATSDR 2008
Toxicological Profile for Chlorinated Dibenzo-p-dioxins).
The toxic equivalency (TEQ) has been developed in order to assess the impacts
associated with dioxin exposure. The TEQ is used as a standard internationally to assess
impacts associated with dioxin exposure. International toxicity equivalency factors (ITEFs)
are applied to 17 dioxin and furan isomers of concern to convert them into 2,3,7,8- TCDD
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(tetrachlorodibenzo-p-dioxin) toxicity equivalents (Ontario Canada, 2001). The
conversion involves multiplying the concentration of the isomer by the appropriate I-TEF
to yield the TEQ for this isomer. Summing the individual TEQ values for each of the isomers
of concern provides the total toxicity equivalent level for the sample mixture (Ontario
Canada, 2001).
Table 6-21 summarises various international Ambient Air Quality Standards for Dioxins and
Furans.
Table 6-21: International ambient standards and guidelines for dioxins and
furans
Country
Standard (TEQ µg/m³)
Maximum
24-hour
Concentration
Annual
Concentration
Ontario, Canada(a) 0.0000001
Japan(b) 0.0000006
Connecticut, USA(c) 0.001 Notes:
(a). Ontario’s Ambient Air Quality Criteria, 2012, Standards Development Branch Ontario Ministry of the Environment
(b). Japan Environmental Quality Standards for Dioxins December 27,1999, Ministry of the Environment Government of
Japan (JCN1000012110001)
(c). Connecticut regulations for the abatement of air pollution, State of Connecticut Department of Energy and
Environmental Protection, April 15, 2014
6.4.21 AIR QUALITY STANDARDS AND GUIDELINES FOR POLYCYCLIC AROMATIC
HYDROCARBONS
Polycyclic Aromatic Hydrocarbons (PAH) is a term that encompasses a wide range of
compounds that are emitted from a number of sources that are formed during
incomplete combustion or pyrolysis of organic material and in connection with the use
of oil, gas, coal and wood in energy production (WHO, 2000). There are five major
emission source components of PAHs (1) domestic, (2) mobile, (3) industrial, (4)
agricultural and (5) natural. The most important industrial sources include; cookeries,
primary aluminium production, wood preservation waste incineration, cement
manufacturing, bitumen and asphalt industries and rubber tyre manufacturing
(European Commission, 2001). PAHs consist of two or more fused aromatic rings made
entirely from carbon and hydrogen. PAH containing 5 or more rings (including
Benzo(a)pyrene (BaP)) are found predominantly in the particulate phase; those
containing two or three rings are almost entirely present in the vapour phase. Four ring
compounds are particle-bound but have the greatest seasonal variability between
phases (European Commission, 2001). The majority of particle-bound PAH is found on
small particles (< 2.5 µm). PAH are semi-volatile in property which makes them highly
mobile throughout the environment, deposition and re-volatilisation distributing them
between air, soil, and water bodies (European Commission, 2001).
Airborne PAH include substances which, when inhaled, are believed to produce lung
cancer in humans (European Commission, 2001). Polycyclic aromatic hydrocarbons are
known to induce numerous adverse health effects, not just lung cancer. These effects
range from genotoxicity, carcinogenicity, immunotoxicity and reproductive toxicity.
Benzo(a)pyrene is often used as a proxy for these PAH’s as it is one of the more frequently
studied PAH’s and is classified as in group 1 of the WHO classifications (WHO 2000).
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In the absence of South African national standards for PAH, international ambient air
quality standards have been used as a proxy. These standards are listed below as a
guideline for acceptable ambient levels of PAH. Benzo(a)pyrene is used as a
measurement proxy for PAH’s as it is the most widely studied PAH (WHO, 2000).
Table 6-22: International Ambient Air Quality Standards for PAHs
Country
Ambient Air Standards
Significance of the
standard(s)
Standard(s)
(Using BaP* as reference unless indicated
otherwise). Belgium,
Flemish area(a)
Proposed values Annual average:
• 1 ng/m³ as a limit value
• 0.5 ng/m³ as a guide value
• 0.017 ng/m³ as a target value
Croatia(b) Guidelines Annual average:
• 2 ng/m³ as a limit guide value
• 0.1 ng/m³ as a recommended guide value
France(c) Recommended values Annual average:
• 0.7 ng/m³ as a limit value
• 0.1 ng/m³ as a quality objective
Germany(d) Target value Annual average:
• 1.3 ng/m³
Italy(e) Legal quality objective Running Annual average:
• 1 ng/m³
Netherlands(f) Non-legal air quality
objectives
Annual average:
• 1 ng/m³ as a ‘limit’ value
• 0.5 ng/m³ as a ‘guidance’ value
Sweden(g) Recommended
guidelines
• 0.1 ng/m³**;
Fluoranthene:
• 2 ng/m³
Switzerland - • 0.1 mg/m3**
Naphthalene:
• 100 mg/m3
Dibenzo(a,h) anthracene:
• 0.1 mg/m3
United
Kingdom(h)
Recommended Annual average:
• 0.25 ng/m³
WHO Unit risk Annual average:
• 8.7 x 10-2 [µg/m³]
Ontario,
Canada(i)
Ambient Air Quality
Criteria
24H Average:
• 0.05 ng/m³
Annual Average:
• 0.01 ng/m³ * Benzo(a)Pyrene
** Averaging period not indicated
Notes:
(a). E. Wauters. Belgium: Experience and Concentration levels. In: Workshop “State of the Art of PAHs’ Analysis in Ambient Air” (I spra,
22-23 March 1999). European Commission, JRC, Environ. Institute. EUR 18751 EN, p. 153-158.
(b). Fugas M. Legislation on protection of air quality in Croatia. WHO Newsletter, no. 19, 1997. WHO Collaborating Centre for Air Quality
Management and Air Pollution Control, Berlin.
(c). Conseil supérieur d’hygiène publique de France. Section des milieux de vie. Avis relative au projet de directiv e concernant la
pollution de l’air ambiant par les HAP. Séance du 17 Septembre 1997.
(d). LAI 1992, Länderausschuß für Immissionsschutz, Krebsrisikodurch Luftverunreinigungen, pub: Ministerium für Umwelt, Raumordnung
und Landwirtschaft des Landes Nordrhein-Westfalen (1992)
(e). Ministerial Decree 25 November 1994. Suppl. ord. Gazz. Uff. n. 290, 13 December 1994.
(f). Environmental Quality Objectives in the Netherlands - A review of environmental quality objectives and their policy framework in
the Netherlands. Ministry of Housing, Spatial Planning and the Environment, 1994.
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Table 6-22: International Ambient Air Quality Standards for PAHs
Country
Ambient Air Standards
Significance of the
standard(s)
Standard(s)
(Using BaP* as reference unless indicated
otherwise). (g). Boström C-E, Gerde P, Hanberg A, Jernstrom B, Johansson C, Kyrklund T, Rannug A, Tornqvist M, Westerholm R and Victorin K.
Cancer risk assessment, indicators and guidelines for polycyclic aromatic hydrocarbons (PAH) in the ambient air. Swedish
Environmental Protection Agency 1999, to be published in Environmental Health and Perspectives 2001.
(h). Expert Panel on Air Quality Standards. Polycyclic Aromatic Hydrocarbons. Department of the Environment, Transport and the
Regions. London, 1999. European Commission (2001) (i). Ontario’s Ambient Air Quality Criteria, 2012, Standards Development Branch Ontario Ministry of the Environment
6.4.21.1 CANCER RISK ASSESSMENT - PAHs
The World Health Organisation (WHO) and some countries, most notably the US, have
based air quality standard setting on quantitative risk assessment methods. This
approach seeks to extrapolate occupational data to lower concentrations and
therefore to quantify the additional risk of cancer at concentrations likely to occur in the
environment. There are many ways in which this extrapolation can be made depending
upon the assumed mechanism of carcinogenesis. It should be noted that quantitative
risk estimates should not be regarded as being equivalent to the true cancer risk but
represent plausible upper bounds which may vary widely according to the assumptions
on which they are based (WHO, 2000). Quantitative risk assessment gives a unit risk factor
which can be used to calculate the concentrations of an airborne pollutant associated
with a particular level of excess lifetime risk.
In the context of this assessment the intent is to undertake a predictive risk assessment.
Therefore, the RFC values and international ambient air quality standards are used to
determine the potential risk associated with lifetime exposure to ambient concentrations
of PAHs resulting from IGE’s predicted emissions.
The Polycyclic aromatic hydrocarbons expected to be emitted from the combustion of
plastic wastes are shown in Table 6-23.
Table 6-23: PAH emissions from the combustion of plastics (Li, Zhuang, Hsieh, Lee, & Tsao,
2001)
Polycyclic aromatic hydrocarbon Polypropylene
(PP)
High Density
Polyethylene
(HDPE)
Naphthalene 0.42% 0.91%
Acenaphthylene 0.03% 0.06%
Acenaphthene 0.02% 0.03%
Fluorene 0.03% 0.05%
Phenanthrene 0.04% 0.09%
Anthracene 0.04% 0.08%
fluoranthene 0.07% 0.13%
Pyrene 0.11% 0.22%
Cyclopenta[c,d]pyrene 0.72% 1.49%
Benz[a]anthracene 0.25% 0.51%
Chrysene 0.40% 0.73%
benzo[b]fluoranthene 15.56% 28.24%
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Table 6-23: PAH emissions from the combustion of plastics (Li, Zhuang, Hsieh, Lee, & Tsao,
2001)
Polycyclic aromatic hydrocarbon Polypropylene
(PP)
High Density
Polyethylene
(HDPE)
benzo[k]fluoranthene 1.05% 2.04%
Benzo[e]pyrene 5.32% 10.53%
Benzo[a]pyrene 53.39% 10.08%
Perylene 4.01% 5.60%
indeno[1,2,3,-c,d]pyrene 4.16% 9.18%
Dibenzo[a,h]anthracene 2.06% 4.51%
Benzo[b]chrycene 2.38% 5.31%
Benzo[ghi]perylene 2.52% 5.76%
Coronene 7.43% 14.45%
This list of PAHs was reduced to the PAHs classified as carcinogens as per the
classifications shown in Table 6-24. The list of carcinogenic PAHs expected from the
combustion of plastics is shown in Table 6-25.
Table 6-24: Classification of carcinogens by different health organisations
Description WHO (2000) US EPA
(1986) EC (2017)
Carcinogenic to humans Group 1 Group A Category
1A
Probably carcinogenic to humans Group 2a Group B Category
1B
Possibly carcinogenic to humans Group 2b Group C Category 2
Not classifiable as to carcinogenicity in
humans
Group 3 Group D
Probably not carcinogenic to humans Group 4 Group E
Table 6-25: Carcinogenic PAHs expected from the
combustion of plastics
Polycyclic aromatic hydrocarbon WHO
(2000)
Inhalation
Unit Risk
(IUR)**
(µg/m³)-1
Benz[a]anthracene B2 0.00011
benzo[b]fluoranthene B2 0.00011
benzo[k]fluoranthene B2 0.00011
indeno[1,2,3,-c,d]pyrene B2 0.00011
Dibenzo[a,h]anthracene B2 0.0012
Naphthalene C* 0.000034
Benzo[a]pyrene B2 0.0011
Chrysene B2 0.000011
*Napthalene grouped as per US EPA (1986)
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**The Inhalation Unit Risk (IUR) is the upper-bound excess lifetime cancer risk
estimated to result from continuous exposure to an agent at a concentration of 1
µg/m³ in air. The interpretation of inhalation unit risk would be as follows: if unit risk = 2
× 10⁻⁶ per µg/m³, 2 excess cancer cases (upper bound estimate) are expected to
develop per 1,000,000 people if exposed daily for a lifetime to 1 µg of the chemical
per m³ of air.
6.4.21.1.1 DEFINING ACCEPTABLE RISK
The notion that there is some level of risk that everyone will find acceptable is a difficult
idea to reconcile and yet, without such a baseline, it may never be possible to set
guideline values and standards, given that life can never be risk free.
One definition of acceptable risk that has been widely accepted in environmental
regulation, is if lifetime exposure to a substance increases a person’s chance of
developing cancer by one chance in a million or less. This level, which has come to be
taken as ‘essentially zero’, was apparently derived in the US in the 1960s during the
development of guidelines for safety testing in animal studies. A figure, for the purposes
of discussion, of 1 chance in 100 million (or 10-7) of developing cancer was put forward
as safe. This figure was adopted by the Food and Drug Administration in 1973 but
amended to one in a million in 1977. This level of 10–6 has been seen as something of a
gold standard ever since. The US Environmental Protection Agency (EPA) typically uses
a target reference risk range of 1 in 10 000 to 1 in 1 000 000 (or 10–4 to 10–6) for carcinogens
in drinking water, which is in line with World Health organization (WHO) guidelines for
drinking water quality which, where practical, base guideline values for genotoxic
carcinogens on the upper bound estimate of an excess lifetime cancer risk of 1 in 100 000
(or 10–5) (Adapted from WHO 2001).
Similar approaches have been adopted elsewhere and for other risks. In the UK, for
example, the Health and Safety Executive (HSE) adopted the following levels of risk, in
terms of the probability of an individual dying in any one year:
• 1 in 1000 as the ‘just about tolerable risk’ for any substantial category of workers
for any large part of a working life.
• 1 in 10,000 as the ‘maximum tolerable risk’ for members of the public from any
single non-nuclear plant.
• 1 in 100,000 as the ‘maximum tolerable risk’ for members of the public from any
new nuclear power station.
• 1 in 1,000,000 as the level of ‘acceptable risk’ at which no further improvements
in safety need to be made.
These probabilities may alternatively be represented as a percentage probability of
occurring as illustrated in Table 6-26.
Table 6-26: Risk expressed as a probability of occurring
Percentage
likelihood Fraction Risk description
0.1% to 0.01% 1 in 1 000 to 1 in 10 000
‘just about tolerable risk’ for any
substantial category of workers for
any large part of a working life
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Table 6-26: Risk expressed as a probability of occurring
Percentage
likelihood Fraction Risk description
0.01% to 0.001% 1 in 10 000 to 1 in 100 000
maximum tolerable risk’ for
members of the public from any
single non-nuclear plant
0.001% to 0.0001% 1 in 100 000 to 1 in 1 000 000
maximum tolerable risk’ for
members of the public from any
new nuclear power station
Less than 0.0001% Less than 1 in 1 000 000
‘acceptable risk’ at which no
further improvements in safety
need to be made
In general, regulatory agencies tend to use default approaches for carcinogens. For risks
calculated to be linear at low doses, agencies use acceptable risk levels ranging from 1
in 10 000 to 1 in 1 000 000 (or 10-4 to 10-6) (Niemi 2013).
The cancer risk range that is deemed acceptable in various parts of the world is from 1
in 10 000 to 1 in 1 000 000. This risk range reflects a de minimis lifetime risk that is so trivial
that any action to reduce risk is not warranted (Kocher and Hoffman, 1994).
Accordingly, life time exposure risk ratings have been adopted in this study with 1 in 10
000 as the maximum tolerable risk to the public and any lesser risk being deemed to be
within the de minimis range. To put this into context for South Africa, it must be noted that
the overall (background) cancer risk for South Africans in 2009 was 1 in 8 for men and 1
in 9 for women (Herbst, 2015).
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7 BACKGROUND LEVELS OF AMBIENT AIR POLLUTION
In the absence of measured ambient air quality data, the state of air quality in the area
cannot be determined with absolute certainty. The plant is not within any designated
priority area. However there are potentially significant sources of emissions within the
vicinity of the site. Mining activities include Kilo Sand located approximately 0.5km to the
east of the site and Gomes Sand Construction Company located approximately 2km
west of the Limeroc Business Park boundary, these are potentially significant sources of
airborne particulate matter as the main activities include the mining, processing and
packaging of sands.
The informal settlement 10m from Limeroc Business Park boundary and Diepsloot
residential area appear to be unelectrified. Domestic use of fuels, such as coal, wood
and paraffin for cooking and space heating purposes, particularly within informal, low-
income, and densely populated settlements, is a significant source of air pollutant
emissions, especially during winter.
Although there are some commercial activities in the surrounding areas, and their
related emissions may have a potentially significant impact on background air quality in
the area, this assessment focuses solely on the impact related to emissions from Industry
Green Energy Solutions’ proposed operations.
Figure 7-1: Regional Meteorological and Ambient Air Quality Monitoring Stations
According to the South African Air Quality Information System (SAAQIS) the nearest
ambient monitoring station is the Diepsloot station approximately 1.8km south west of the
Limeroc Business Park boundary, data from this station was incomplete for the period of
assessment (no data available for the period of 2016 at the time of request). SAAQIS
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describes the station as “Residential – low income. A location type situated in a low
income residential area”, (refer to Figure 7-1).
Considering the location of the station and the surrounding land use, it is expected that
the Diepsloot station would not be representative of the air quality for the site. Data from
the Diepsloot monitoring station shows that ambient air quality in the area is poor.
Measured 8-hour average O3, daily average SO2, and PM10 data show frequencies of
exceedance in excess of the legislated limits. A trend in ambient air quality could not be
concluded due to poor data availability (Table 7-1).
Table 7-1: Ambient Air Quality Data Availability
Monitoring Station Year Data Availability
SO2 PM10 O3
Diepsloot, City of
Johannesburg
2016 - - -
2017 16.62% 12.82% -
2018 90.88% 85.41% 37.82%
2019 78.15% 76.32% 51.40%
The Diepsloot measured 8-hour average O3 data shows 23 exceedances of the
regulated limit in 2018. The hourly SO2 shows nine exceedances of the regulated limit for
the period of 2019. There are no exceedances of the regulated limits of the daily and
annual SO2. The daily PM10 shows 42 and 107 exceedances of the regulated limit, in 2018
and 2019 respectively, exceeding the allowable number of exceedances (4
exceedances per year). Due to poor data availability, the measured annual average
ambient data for the period of 2017 – 2019 have not been displayed as the results are
not representative (Figure 7-2 to Figure 7-5).
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Figure 7-2: SO2 hourly average ambient air quality data from the Diepsloot AAQM
Station.
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Figure 7-3: SO2 daily average ambient air quality data from the Diepsloot AAQM
Station.
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Figure 7-4: PM10 daily average ambient air quality data from the Diepsloot AAQM
Station.
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Figure 7-5: O3 8-hour average ambient air quality data from Diepsloot AAQM Station.
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8 EMISSIONS QUANTIFICATION
Source specific data such as source type, height and diameter, emission rates and exit
conditions (temperature, velocity, and flow rate) are required for dispersion modelling.
An emission inventory for the proposed operations was formulated based on the
maximum allowable emissions for subcategory 8.1.
The main point source for the proposed facility will be a scrubber stack.
No potentially significant fugitive sources were identified for the proposed plant. Fugitive
emissions may occur from time to time due to leaking seals and other maintenance
issues, however these are intermittent, and unpredictable.
It was assumed that the process will run continuously and that the emissions will occur
continuously for 24 hours a day, 365 days a year. The plant would not operate on such a
continuous basis due to maintenance requirements and production scheduling. The
approach taken is therefore a worst possible case scenario in respect of emissions from
normal operating conditions.
The stack heights were calculated based on the Guideline for Determination of Good
Engineering Practice Stack Height (USEPA, 1985). The guideline indicates that the stack
should be a minimum of 1.5 times the height of the nearest building.
The general equation for stack height estimation is:
Hg = H + 1.5L Equation 1
where:
* Hg = good engineering practice stack height, measured from the ground-level
elevation at the base of the stack,
* A = height of nearby structure(s) measured from the ground-level elevation at the
base of the stack, and
* L = lesser dimension, height of projected width, of nearby structure(s).
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8.1 SITE EMISSIONS INVENTORY
The point source parameters for the site are described in Table 5-1 above, whilst the
emission rates for these point sources are presented below in Table 8-1.
Table 8-1: Point source emission rates
Point Source Chemical Symbol Maximum Allowable Emission
rates per GN 893 (g/s)
SS1 – SS4,
AS1 – AS4
PM 0.00139
CO 0.00697
SO2 0.00697
NOx as NO2 0.02789
HCl 0.00139
HF 0.00007
As+Sb+Pb+Cr+Co+Cu+Mn+V+
Ni 0.00001
Hg 0.00001
Cd TI 0.00001*
TOC 0.00139
NH3 0.00139
PCDD/PCDF ng I-TEQ /Nm3
0.00000000001
PAH 0.00000000001
*Although the limit for Cadmium and Thallium is listed as 10 mg/Nm3 under this
activity in GN 893 of 2013 as amended, all other waste related activities within
GN893 of 2013 as amended list the limit as 0.05 mg/Nm3.
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9 METEOROLOGY
9.1 GENERAL DESCRIPTION OF CLIMATOLOGY AND METEOROLOGY
The proposed facility is located in the City of Tshwane. This is a summer rainfall region that
is defined by a mid-latitude steppe/semi-arid cool climate and is situated near the
subtropical dry forest biome.
9.2 RAINFALL AND TEMPERATURE
The City of Tshwane has a subtropical climate resulting in short winters (June, July, and
August). Temperatures in winter can fall below freezing with frosty mornings, the minimum
recorded temperature over the period is 0°C. The average maximum temperature that
is reached in the winter months is 18.8°C for the period of 2017 - 2019. Rainfall occurs in
the summer months (December, January, and February), predominantly in December
and January with July being the lowest rainfall month (Figure 9-1).
9.3 WIND – MEASURED AND MODELLED
Observed wind direction and wind speed at the nearest ambient air quality monitoring
(AAQM) station (shown in Figure 7-1) is shown as wind roses (for 2017 through to 2018) in
Figure 9-2. The length of the colour-coded line is proportional to the frequency of
occurrence of wind blowing from that direction. Wind speed classes are also colour
coded and the length of each class/category is proportional to the frequency of
occurrence of wind speed. Figure 9-2 shows the wind rose developed for data obtained
from the Diepsloot AAQM Station situated approximately 1.8 km south west of Limeroc
Business Park. Data was not available for 2016 and data availability for 2018 is poor (see
Table 9-1). The combined data over the 2017 – 2018 period is poor (less than 65%).
Figure 9-1: Average monthly temperatures and rainfall from Diepsloot AAQM station
from 2017 – 2019.
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Table 9-1: Data availability for AAQM station.
Station Data Availability
2016 2017 2018 Combined
Diepsloot, City of
Johannesburg 0.00% 16.30% 90.23% 53.26%
Table 9-2: Wind speed comparison for the Diepsloot AAQM station.
Station
Wind speed (m/s)
2016 2017 2018 Combined
(2017 – 2018)
Measured - 2.80 2.74 2.75
Modelled 2.69 3.56 3.75 3.66
Measured Modelled
Annual
Summer
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Measured Modelled
Autumn
Winter
Spring
Figure 9-2: Average Wind Roses from 2017-2018 for Diepsloot AAQM station
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Atmospheric dispersion modelling is the mathematical simulation of how air pollutants
disperse in the ambient atmosphere. Atmospheric dispersion models use mathematical
algorithms that simulate the dispersion and transformation of pollutants in the
atmosphere. They are used to estimate or predict the downwind concentration of air
pollutants emitted from various sources. Dispersion models are also used to assist in the
design and assessment of various control strategies and abatement technologies for
emission reductions.
Air pollution models attempt to numerically solve the relationship between emissions and
ambient concentrations of pollutants by means of mathematical algorithms which
enable the modelling of pollutant dispersal and reaction. It takes into consideration the
factors that have resulted in these concentrations - such as the emission sources,
meteorological processes and any physical or chemical transformations. Numerical
"models" are used to describe complex systems of interacting physical, chemical, and
biological processes. These models consist of sets of mathematical equations that
attempt to describe processes observed in nature, allowing scientists to create replicas
of natural systems with a computer, so that the causes and effects of system behaviour
may be better understood.
The primary focus of dispersion modelling for regulatory applications (new and existing
facilities) is to assess compliance against air pollution standards by predicting deposition
flux rates, ambient concentrations and frequency of exceedance of air quality
standards for all criteria pollutants listed in the NEMAQA for which ambient standards
have been set. Additionally, dispersion modelling is the primary tool to determine the
relative contribution of the facility to the air pollution burden within the modelling
domain. This is achieved by scenario modelling to identify the individual contribution of
significant known background industrial point source emitters, household emitters and
the site’s specific emissions. The objective of undertaking source specific simulations is
also to identify the extent of the scale and transport of air pollution from background
sources to the site. This assessment enables the air pollution burden/contribution of
significant known source emitters, including low level emitters (e.g. stacks less than 50m
in height) within a 5km radius of the plant, at the local scale and all other industrial
emitters (listed activities and high emitters) beyond a 5km radius of the plant to be
quantified. The physical properties and meteorological conditions of the atmospheric
boundary layer (into which pollutants disperse) will largely influence the extent to which
air pollution disperse/accumulate at various temporal scales (daily, seasonally, and
annually).
9.4 DISPERSION POTENTIAL
The meteorological characteristics of a site, along with the characteristics of the source,
govern the dispersion, transformation and eventual removal of pollutants from the
atmosphere. The extent to which pollution accumulates or disperses in the atmosphere
is dependent on various factors such as the degree of thermal (convective) turbulence
and mechanical (friction and wind speed) turbulence within the earth's boundary layer
as well as precipitation.
Dispersion occurs three dimensionally. The stability of the atmosphere and the height of
the surface-mixing layer determine the vertical component of dispersion for non-
buoyant sources. Horizontal dispersion in the boundary layer is influenced by the wind
field characteristics, atmospheric stability and topography. The wind speed and
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turbulence determine the rate of transport downwind and the rate of mixing.
Mechanical turbulence is similarly a function of the wind speed and surface roughness.
Convective turbulence is determined by solar insolation, land cover, and wind speed
(Turner, 1970).
9.4.1 ATMOSPHERIC STABILITY
In the atmosphere, motion (air flow and turbulent eddies) occurs at all spatial scale
(micro, meso and synoptic), simultaneously. Meteorological pressure refers to the weight
of the atmosphere, the weight decreases with an increase in altitude above sea level
and varies for different weather conditions.
Pressure gradient force is a change in pressure measured across a given distance and is
directed from a high to low pressure. Pressure gradient force is responsible for triggering
the initial movement of air. Unequal heating of the atmosphere is responsible for creating
pressure differences generating wind as air flows from areas of high to low pressure. This
in turn influences atmospheric stability.
9.4.2 MIXING HEIGHTS
The degree of atmospheric stability influences the amount of plume rise that will occur
from an emission source. Stable conditions or low mixing heights generally trap pollution
plumes near the ground. These conditions are usually prominent in the early morning
before sunrise where visible emissions can be seen at low altitude for long distances
(where there is an appropriate emission source). Low mixing heights inhibit the dispersion
of pollutants without sufficient buoyancy, and these are often trapped by an elevated
inversion. Once the sun rises and heats the ground, convective heating occurs, and this
increases turbulent flow in the lateral and vertical geophysical spheres. This results in
surface inversion breakup or erosion of the capping layer whereby mixing heights
increase. Figure 9-3 illustrates the mixing heights throughout the day for the period of
2016 – 2018, modelled at the Industrial Green Energy Solution preferred site. The diurnal
mixing height increases from 08h00am, a few hours after sunrise. Mixing heights are
increased steadily until 15h00pm to a maximum of 2 100m above sea level. Mixing height
then rapidly decreases with less direct solar radiation. From 19h00 pm, the mixing heights
are generally below 500m until sunrise.
The boundary layer level or ground level turbulence plays a major role in pollutant
dispersion. The random motion of a body or volume of air can act to dilute or diffuse a
pollutant plume. Greater turbulence acts to increase the rate of dilution of diffusion of
the plume whereas weak turbulence can limit diffusion and can cause high plume
concentrations to occur downwind of a source. Periods of greater turbulence (which
are driven by incoming solar radiation, surface heating, convection, thermal and
pressure gradient induced wind flow) generally occur between 08h00am and 18h00pm,
and mixing heights are generally higher during periods where the sun is still elevated.
Diurnal variations in the minimum, maximum, and average mixing heights, based on
model CALMET generated meteorological data for the site are illustrated in Figure 9-3.
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Figure 9-3: Average CALMET Modelled Mixing Heights at Industrial Green Energy
Solutions preferred site.
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10 DISPERSION MODELLING
10.1 DESCRIPTION OF THE DISPERSION MODEL
There are a number of dispersion models that have been developed around the world.
The widely used CALPUFF dispersion model is one such example.
The simulation of pollutant emissions from the plant was undertaken with the well-known
and widely used CALPUFF (version 5.8, US-EPA approved) dispersion model. The CALPUFF
model is freely available and can be downloaded from the website:
http://www.src.com/.
10.1.1 CALPUFF SUITE OF MODELS
The CALPUFF system consists of a suite of models: CALMET (used to model 3-D
meteorology for CALPUFF), CALPUFF (to compute pollution dispersion simulations and
visibility assessments) and CALPOST (used for post-processing of CALPUFF output data).
The CALMET/CALPUFF modelling system can accurately simulate atmospheric dispersion
on transport scales from tens of metres to tens of kilometres (near-field) and from tens of
kilometres to hundreds of kilometres (far-field) (US EPA 1998). Furthermore, CALPUFF is a
multi-layer, multi-species non-steady-state puff dispersion model that simulates the
effects of time- and space- varying meteorological conditions on pollution transport,
transformation, and removal (Scire et al., 2000).
CALMET can simulate fine-scale three-dimensional wind flows in complex terrain (Scire et
al., 2000). CALMET has parameterizations to perform wind field adjustments of terrain,
such as slope flows and terrain blocking effects. CALMET creates gridded 3-D wind fields
and CALPUFF performs dispersion simulations along the wind vectors created by CALMET.
This model combination is a major departure from past US-EPA Guideline models that
have relied on a single hourly wind vector that was applied over the entire modelling
domain run in a steady-state mode. The CALMET and CALPUFF approach allows for
dynamic wind fields that change spatially and temporally, a characteristic that is true to
the real world.
CALMET/CALPUFF was developed to take whatever observational wind data are
available and adjust the flow fields to be consistent with the fine-scale terrain in CALMET.
The adjustments made by CALMET introduce structure to the flow field that is consistent
with the terrain, even in areas where observations do not exist. In complex terrain regions,
the representativeness of observational data is often quite limited spatially. Often the
wind flow at just a few hundred metres from an anemometer can be completely
different as a result of terrain-induced effects. These terrain effects on the wind flow may
have a substantial impact on the predicted concentrations produced by the dispersion
model.
10.1.2 CALPUFF / CALMET CHARACTERISTICS
There have been several journal papers, conference presentations and EPA documents
related to the evaluation of CALPUFF and the meteorological model CALMET. The
following provides a brief summary of the conclusions from several of these references
and summarises CALMET/CALPUFF’s abilities as follows:
The CALMET model used to generate the 3-D wind fields for the CALPUFF model can
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provide very good representations of the wind field, especially over complex
terrain, or in coastal regions
CALPUFF model results have been compared with ambient measurements of the
tracer SF6 after it has been released from existing stacks. The conclusions of several
studies are that:
o CALPUFF tends to over-predict concentrations but is typically within a factor of
two of the observed concentrations. Predicted values within a factor of two is
a criterion suggested by the EPA (US EPA 1998) and
o Maximum concentrations predicted by CALPUFF are higher than observed
concentrations, while average concentrations predicted by CALPUFF tend to
be close to the average observed concentrations (US EPA 1998)
10.1.3 MODEL INPUT DATA
Dispersion models require input data including meteorological data (for example wind
speed and direction, temperature, humidity) and emissions data such as source location
and height, diameter and exit velocity, temperature, and flow rate. Input data types
required for the CALMET/CALPUFF model system and for this study include: emissions
source data, meteorological data, and land cover/land use data. Parameters required
depend on the source type (point, line, area, or volume). CALPUFF requires input data in
the form of modelled 3-D gridded meteorological fields. Other inputs include stack
parameter data for point sources. These include source geo-location, height, and
diameter. Emissions and process data are also required. These include exit velocity,
temperature, and flow rate.
Meteorological data was obtained from the Weather, Research and Forecast Model
(WRF) which is a mesoscale, prognostic atmospheric model. WRF makes use of observed
data to accurately model meteorology over a regular grid that has a coarser resolution
than CALMET. The use of mesoscale model data in CALMET is advantageous compared
to using observed data. More data points are provided than observed data and it
provides upper air conditions. The higher number of data points increases accuracy in
CALMET when deriving fine scale flow patterns. Meteorology is an essential requirement
and is the principal factor to the dispersion of pollutants in the atmosphere. Important
meteorological factors that directly impact the dispersion of a pollutant include wind
speed and direction, atmospheric turbulence which is related to vertical dispersion, and
vertical temperature profiles associated with absolutely stable layers that affect vertical
dispersion.
10.1.4 GEOPHYSICAL DATA INPUT AND GENERAL DESCRIPTION OF THE AREA
Geophysical data requirements include land use type and terrain elevation. Land use
categories and terrain of the surrounding region are discussed in their relevant
subsections. These features (land use and terrain) have a strong influence on wind speed
and turbulence, which are key components for dispersion.
Geophysical data requirements include land use type and terrain elevation. Land use
categories and terrain of the surrounding region are discussed in their relevant
subsections. These features (land use and terrain) have a strong influence on wind speed
and turbulence, which are key components for dispersion.
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10.2 TOPOGRAPHY
Topographical features and variations may have a significant influence on the flow of
air and related dispersion of pollutants. Figure 10-1 demonstrates the 2-dimensional
topography in the region of interest surrounding the Limeroc Business Park. Terrain height
is considered in the model, especially in areas of complex and or varying terrain height,
as it affects wind speed and turbulence which, amongst other factors, affect
atmospheric stability and pollution dispersion.
Figure 10-1: The 2-dimensional terrain within the modelling domain
CALMET adjusts mesoscale wind speeds and direction to fine scale terrain features.
Elevation data with a resolution of 90m was aggregated to the 300m CALMET grid
resolution. The use of this high-resolution elevation data ensures that the complexity of
the terrain is represented in the model. This aids in simulating terrain induced
meteorological features like katabatic/anabatic flow and valley inversions.
10.3 LAND USE/ LAND COVER
Land use and land cover have two main effects on meteorology (see Appendix 1).
Reflective properties, or albedo, of the land cover determine how much radiation is
reflected which has implications for determining diurnal heating patterns and
atmospheric mixing levels. Mixing heights will determine the volume of air available in
which air pollutants can vertically disperse. Secondly, land use types have an associated
aerodynamic texture which effect turbulent or laminar flow in wind. This, in turn will affect
dispersion. Figure 10-2 illustrates the Land use types within the modelling domain with the
Limeroc Business Park at its centre.
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USGS global land cover characteristics data have been used to produce dominant land
use categories and land-use weighted values of surface and vegetation properties for
each CALMET grid cell. The land use data have been processed to produce a gridded
field of fractional land use categories for the CALMET modelling domain.
The 37 Level I USGS land use categories are mapped into 14 CALMET land use categories
as summarised in Table 10-1.
Table 10-1: Default CALMET Land Use Categories and Associated Geophysical
Parameters.
Land
Use
Type
Description
Surface
Roughness
(m)
Albedo Bowen
Ratio
Soil Heat
Flux
Parameter
Anthropo-
genic
Heat Flux
(W/m2)
Leaf
Area
Index
10
Urban or
Built-up
Land
1 0.18 1.5 0.25 0.2
20
Agricultural
Land -
Unirrigated
0.25 0.15 1 0.15 0 3
-20*
Agricultural
Land -
Irrigated
0.25 0.15 0.5 0.15 0 3
30 Rangeland 0.05 0.25 1 0.15 0 0.5
40 Forest Land 1 0.1 1 0.15 0 7
50 Water 0.001 0.1 0 1 0 0
51 Small Water
Body 0.001 0.1 0 1 0 0
Figure 10-2: CALMET Land use types within the modelling domain
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Table 10-1: Default CALMET Land Use Categories and Associated Geophysical
Parameters.
Land
Use
Type
Description
Surface
Roughness
(m)
Albedo Bowen
Ratio
Soil Heat
Flux
Parameter
Anthropo-
genic
Heat Flux
(W/m2)
Leaf
Area
Index
55 Large Water
Body 0.001 0.1 0 1 0 0
60 Wetland 1 0.1 0.5 0.25 0 2
61 Forested
Wetland 1 0.1 0.5 0.25 0 2
62
Non-
forested
Wetland
0.2 0.1 0.1 0.25 0 1
70 Barren Land 0.05 0.3 1 0.15 0 0.05
80 Tundra 0.2 0.3 0.5 0.15 0 0
90 Perennial
Snow or Ice 0.2 0.7 0.5 0.15 0 0
* Negative values indicate irrigated" land use "
Based on the U.S. Geological Survey Land Use Classification System (14-Category System) (Scire et al, 2000)
Parameters relating to land use type applied in the modelling are given in Table 10-2.
Surface properties such as albedo, Bowen ratio, roughness length, and leaf area index
are computed proportionally to the fractional land use within each grid cell.
Table 10-2: Land use codes and categories used in the model
Land
use
code
Description
Surface
roughness
(m)
Albedo Bowen
ratio
Soil heat
flux
(w/m2)
Leaf
area
index
10 Urban or built-
up land 1.0 0.18 1.5 0.25 0.2
20
Agricultural
land –not-
irrigated
0.25 0.15 1.0 0.15 3.0
30 Rangeland 0.05 0.25 1.0 0.15 0.5
40 Forest land 1.0 0.10 1.0 0.15 7.0
51 Water body 0.001 0.10 0.0 1.0 0.0
70 Barren land 0.005 0.30 1.0 0.15 0.05
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10.4 MODEL VERIFICATION
The index of agreement (IOA) is a measure of how well the model predicted variations
about the observed mean are represented. It provides a more consistent measure of
model performance than the correlation coefficient and an IOA with a value greater
than about 0.5 considered to be good (Hurley, 2000). Willmott (1981) was used to provide
the IOA calculation methodology.
A score of zero for IOA indicates little to no agreement between the observed and
modelled data. A score below 0.5 for the IOA indicates that there are inconsistencies
between the observed and modelled data, whilst a value of 1 indicates a uniform and
complete agreement between the two sets of data. In Figure 10-3 to Figure 10-4, the IOA
for the measured wind speed and direction data versus the CALMET modelled data are
presented for the period of 2017 and 2018, as no data is available for 2016 a model
verification cannot be performed. For the Diepsloot station, the wind speed data
comparison has an average IOA of 0.49, poor, across the period of 2017 - 2018. The 2018
wind speed has an IOA of 0.50, good, however the measured wind speed values are
relatively low across the period and are seemingly uncharacteristic of the area, it is
therefore unclear if the siting of the station may affect the results. The wind direction
comparison has an average IOA of 0.68, good, across the period of 2017 - 2018. The
average measured data availability at the time of request was poor (less than 65%) for
the Diepsloot ambient monitoring station as indicated in Table 9-1.
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Figure 10-3: The 2017 Diepsloot ambient monitoring station wind speed (top) and wind direction (bottom)
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Figure 10-4: The 2018 Diepsloot ambient monitoring station wind speed (top) and wind direction (bottom)
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10.5 ASSUMPTIONS AND LIMITATIONS
The following significant assumptions have been undertaken:
• It was assumed that reactors run continuously. It was assumed that emissions
occur continuously for 24 hours a day, 365 days a year. The plant would not
operate on such a continuous basis due to maintenance requirements and
production scheduling.
• The stack height was estimated based on The Guideline for Determination of
Good Engineering Practice Stack Height” (USEPA, 1985).
• Point source emissions have been modelled at the maximum allowable
emission concentration. The emissions modelled correspond with maximum
allowable concentrations for “new plant”. Although the limit for Cadmium and
Thallium is listed as 10 mg/Nm3 under this activity in GN 893 of 2013 as
amended, all other waste related activities within GN893 of 2013 as amended
list the limit as 0.05 mg/Nm3. It was assumed that the applicable limit for
Cadmium and Thallium is 0.05 mg/Nm3.
• Chemical transformation of gaseous pollutants (NOx and SO2) has not been
accounted for due to:
o Limitations in the availability of data on chemical and other
parameters contributing to chemical transformation (e.g. ambient
concentrations of ozone, reactive organic compounds etc.).
o The limitations of the modelling software. Although the CALPUFF suite is
a tier 3 system, and one of the best in its class, the ability of such
dispersion models in general to accurately account for chemical
transformation is relatively limited.
The predicted ambient concentrations of the gaseous pollutants are
thus typically expected to be over-predicted. This is in fitting with the
precautionary principle.
• A tier 2 approach was undertaken for atmospheric conversion of NOx
emissions to NO2.
• All PM emitted from point source was assumed to be PM10. This is potentially an
over-estimation of actual PM10 emissions.
• The emission rate of Cr(VI) was conservatively predicted through the analysis
of the wax waste sample that will form part of the feed material into the
pyrolysis reactor. The sample was analysed for Cr(VI), and the result was that
Cr(VI) concentration within the sample was below the detectable limit of 2
mg/kg. It was conservatively assumed that the Cr(VI) concentration within the
sample is 2 mg/kg.
• It has been assumed that all Cr(VI) remains in oxidised form and that there is
no significant reduction in the atmosphere. Notably the presence of acidic
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gases such as SO2 and NO2 from industrial activities, motor vehicle emissions,
and domestic fuel burning has not been considered. These may facilitate the
atmospheric reduction of Cr(VI).
• Wind entrained emissions from area sources have not been included as the
impacts from these sources are generally localised due the low emission
release heights and the low buoyancy of emissions from the sources. Due to
the temporal variability of these sources it is difficult to predict and accurately
model the varying emissions.
• Emissions from vehicles on the site are expected to be intermittent and
relatively insignificant. The contribution vehicle emissions in the area has not
been undertaken due to the deficiency of data available to quantify this
source.
• Wet deposition has not been modelled, thus the effects of atmospheric
scrubbing from precipitation have not been simulated. This conservative
approach is expected to result in an over-prediction of ambient impacts.
In general the predicted ambient concentrations are expected to be over-estimated.
This is in fitting with the precautionary principle.
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11 IMPACT OF ENTERPRISE ON THE RECEIVING ENVIRONMENT
11.1 ANALYSIS OF EMISSION’S IMPACT ON HUMAN HEALTH
11.1.1 PREAMBLE
It is important to note that NEMAQA defines ambient air as excluding air regulated by
the Occupational Health and Safety Act (Act 85 of 1993). Thus, ground level exposure in
the plant site is technically not regulated by the NAAQS. During working hours, working
persons, persons exposed at the plant are expected to:
1) Primarily work normal shifts (i.e. 8 to 12 hours long, and less than 60 hours per week)
2) Be within the age range of the generally accepted working populace (18 years
to 65 years)
In respect of the NAAQS, these receptors are not anticipated to be sensitive receptors
by virtue of their limited exposure time and their age range. Occupational exposure limits
apply within the plant boundary, these limits are orders of magnitude higher than
Ambient Air Quality Standards.
11.1.1.1 INTERPRETATION OF ISOPLETH MAPS
The spatial dispersion patterns and temporal distribution of predicted modelled ambient
concentrations for nitrogen oxides (NOx), particulate matter (PM) and sulphur dioxide
(SO2) are described for the proposed use of AFRs under normal operating conditions.
Predicted modelled ambient concentrations for pollutants are compared against
NAAQS and guidelines for the 1-hour, 24-hour, and annual maximums, where applicable.
Note that for the hourly and 24-hour maxima, the numbers of exceedances per annum
determine whether regulatory compliance is achieved. The maximum modelled values
are mapped to demonstrate the spread of the impact from the operations. Where there
are exceedances of the standard, the frequency of exceedance (FoE) is plotted to
illustrate compliance status.
The data is presented in the form of colour coded isopleth maps. The colour coding
follows the general format described in Table 11-1and Table 11-2.
Table 11-1: Predicted Ambient Concentrations – Colour Coding
No shading Less than 20% limit value
Shades of Blue Significantly lower than ambient limit value (typically 20%
- 60% of the limit value).
Note: In instances where all/most of the modelled are less
than 20% of the limit value, shades of blue may still be
used to demonstrate the impact spread.
Shades of Green Relatively close to the limit value (60% - 100% of the limit
value)
Shades Red Exceeds the limit value
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Table 11-2: Predicted Frequency of Exceedances – Colour Coding
No shading No exceedances of the limit value
Shades of Blue Significantly lower than the allowable FoE (typically < 60%
maximum FoE)
Shades of Green Relatively close to the maximum allowable FoE (60% -
100% of the maximum allowable FoE)
Shades of Red Exceeds the maximum allowable FoE
Predicted lifetime carcinogenic exposure risk resulting from the current operations at the
plant are presented here, lifetime exposure being equal to 30 years. The data is
presented in the form of colour coded contour maps. The colour coding follows the
general format described in Table 11-1.
Table 11-3: Predicted Chromium (VI) Lifetime Carcinogenic Risk – Colour Coding
Shades of Red Less than 1 in 10 000
Shades of
Orange
Between 1:10 001 and 1 in 100 000
Shades Green Above 1 in 100 000
• Note that results are presented for a modelled period spanning 3 calendar years.
• In order to prevent proliferation of maps, only those associated with significant
predicted ambient concentrations are presented.
11.1.1.2 PRESENTATION OF RESULTS
In general, the variance of hourly concentrations in comparison to the relative
stratification of the hourly, 24 hourly and annual standards are such that if there are no
exceedances of the hourly standard then there are generally no exceedances of the 24
hour and annual standards. The same applies to 24-hour averages, if there are no
exceedances of the 24-hour standard then there typically are no exceedances of the
annual standard.
Where there are no exceedances of the hourly standard (and subsequently the 24 hour
and annual standards), only the maximum hourly results are presented in order to keep
the report concise. The maximum hourly results typically demonstrate the worst-case
prediction. Should the above not be the case then the relevant results are presented
accordingly.
In accordance with the Regulations Regarding Air Dispersion Modelling (GN.R 533 of
2014), three consecutive meteorological years, of the last five years were modelled (2016
to 2018).
Two scenarios were modelled to display the potential dispersion:
i. Scenario 1: Preferred Site Location - All proposed sources modelled at the
preferred site location minimum emission standards for the applicable
regulated emissions per source as stipulated by Subcategory 3.1, 3.4 and
Subcategory 8.1 in GN893:2013, as amended.
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ii. Scenario 2: Baseline - Alternative Site Location - All proposed sources modelled
at the alternative site location minimum emission standards for the applicable
regulated emissions per source as stipulated by Subcategory 3.4 and
Subcategory 8.1 in GN893:2013, as amended.
11.1.2 SCENARIO 1: PREFERRED LOCATION
All proposed sources modelled at the preferred site location minimum emission
standards for the applicable regulated emissions per source as stipulated by
Subcategory 3.1, 3.4 and Subcategory 8.1 in GN893:2013, as amended. Measured Cr(VI)
emissions from the plant show that this emission concentration is achievable with the
abatement technologies proposed.
11.1.2.1 PREDICTED CONCENTRATIONS FOR PM10
Modelled particulate emissions have not been fractioned to indicate the percentage of
PM10 in the total particulates measured. For the purposes of this assessment it was
conservatively assumed that all particulates measured are PM10.
11.1.2.1.1 PREDICTED 24 HOUR CONCENTRATIONS FOR PM10
The predicted impact from the operations is well within the NAAQS limit of 75 µg/m3 for
the 24-hour averaging interval (Figure 11-1).
Figure 11-1: Scenario 1 Predicted PM10 24-Hour maximum modelled ambient
concentration.
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11.1.2.1.2 PREDICTED ANNUAL CONCENTRATIONS FOR PM10
The predicted impact from the operations is well within the NAAQS limit of 40 µg/m3 for
the annual averaging interval as well. For the three years assessed (2016 through to 2018)
the maximum PM10 concentration occurring over the area for the annual averaging
period is 0.05 µg/m3.
11.1.2.2 PREDICTED CONCENTRATIONS FOR PM2.5
Modelled particulate emissions have not been fractioned to indicate the percentage of
PM2.5 in the total particulates measured. For the purposes of this assessment it was
conservatively assumed that all particulates measured are PM2.5.
11.1.2.2.1 PREDICTED 24 HOUR CONCENTRATIONS FOR PM2.5
The predicted impact from the operations is well within the NAAQS limit of 40 µg/m3 for
the 24-hour averaging interval (Figure 11-2).
Figure 11-2: Scenario 1 Predicted PM2.5 24-Hour maximum modelled ambient
concentration.
11.1.2.2.2 PREDICTED ANNUAL CONCENTRATIONS FOR PM2.5
The predicted impact from the operations is well within the NAAQS limit of 20 µg/m3 for
the annual averaging interval as well. For the three years assessed (2016 through to 2018)
the maximum PM2.5 concentration occurring over the area for the annual averaging
period is 0.05 µg/m3.
11.1.2.3 PREDICTED CONCENTRATIONS FOR SO2
11.1.2.3.1 PREDICTED 1 HOUR CONCENTRATIONS FOR SO2
The predicted impact from the operations is well within the NAAQS limit of 350 µg/m3 for
the 1-hour averaging interval (Figure 11-3).
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Figure 11-3: Scenario 1 Predicted SO2 1-Hour maximum modelled ambient
concentration.
11.1.2.3.2 PREDICTED 24 HOUR CONCENTRATIONS FOR SO2
The predicted impact from the operations is well within the NAAQS limit of 125 µg/m3 for
the 24-hour averaging interval. For the three years assessed (2016 through to 2018) the
maximum SO2 concentration occurring over the area for the 24-hour averaging period
is 1.66 µg/m3.
11.1.2.3.3 PREDICTED ANNUAL CONCENTRATIONS FOR SO2
The predicted impact from the operations is well within the NAAQS limit of 50 µg/m3 for
the annual averaging interval as well. For the three years assessed (2016 through to 2018)
the maximum SO2 concentration occurring over the area for the annual averaging
period is 0.24 µg/m3.
11.1.2.4 PREDICTED CONCENTRATIONS FOR NO2
11.1.2.5 PRE-AMBLE NITROUS OXIDES
The national ambient air quality standards regulate ambient concentrations of NO2. It
must be noted that NOx represents all oxides of nitrogen species. NOx gases are
composed of chemical species other than NO2 which is typically in the order of only 5
to10% of NOx emitted from combustion sources. The primary NOx constituent of these off-
gases is typically NO (approximately 90% to 95%). NO will eventually be oxidised to NO2
in the atmosphere, and the rate of conversion is dictated by the kinetics of reaction in
the atmosphere. The downwind concentration of NO2 from the source is thus generally
over-estimated by assuming that all NOx emissions are NO2 (various sources – Cooper et
al, Yu et al, Hori et al). The implication is that the modelled results have over predicted
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the NO2 ambient concentration and the true ambient concentration of NO2 is
significantly less.
In terms of the Regulations Regarding Air Dispersion Modelling (GN. R 533 of 2014), the
dispersion model used for this air quality impact assessment, and in general all of those
recommended, do not have sufficiently detailed descriptions of atmospheric chemistry
to robustly account for NO to NO2 conversion and thus the predicted NOx concentration
must be equated to NO2, using a conversion factor. A tiered screening approach is
recommended to obtain annual average estimates of NO2 from point sources as
stipulated by the US EPA and other guidelines:
Tier 1: Total Conversion Method – Assume that all NOx is converted to NO2.
Tier 2: Ambient Ratio Method – Assume a national ratio of NO2/NOx of 0.80.
In the absence of reliable and complete measured ambient data for NO and NO2, the
tier 2 conversion has been applied in this assessment.
11.1.2.5.1 PREDICTED 1 HOUR CONCENTRATIONS FOR NO2
The predicted impact from the operations is within the NAAQS limit of 200 µg/m3 for the
1-hour averaging interval (Figure 11-4).
Figure 11-4: Scenario 1 Predicted NO2 1-Hour maximum modelled ambient
concentration.
11.1.2.5.2 PREDICTED ANNUAL CONCENTRATIONS FOR NO2
The predicted impact from the operations is within the NAAQS limit of 40 µg/m3 for the
annual averaging interval as well. For the three years assessed (2016 through to 2018)
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the maximum NO2 concentration occurring over the area for the annual averaging
period is 0.95 µg/m3.
11.1.2.6 PREDICTED CONCENTRATIONS AND CARCINOGENIC RISK FOR Cr(VI)
11.1.2.6.1 PREDICTED 1 HOUR CONCENTRATIONS FOR Cr(VI)
The emission rate of Cr(VI) was conservatively predicted through the analysis of the wax
waste sample that will form part of the feed material into the pyrolysis reactor. The
sample was analysed for Cr(VI), and the result was that Cr(VI) concentration within the
sample was below the detectable limit of 2 mg/kg. It was conservatively assumed that
the Cr(VI) concentration within the sample is 2 mg/kg.
The predicted impact from the operations is within the Alberta, Canada Ambient Air
Quality limit of 1 µg/m3 for the 1-hour averaging interval (Figure 11-5).
Figure 11-5: Scenario 1 Predicted Cr(VI) 1-Hour maximum modelled ambient
concentration.
11.1.2.6.2 PREDICTED LIFETIME CARCINOGENIC RISK USING THE WHO RFC
Figure 11-6 shows the predicted excess lifetime carcinogenic risk resulting from the
maximum anticipated emissions from the plant, based on the WHO recommendations
for linear dose-response relationships between exposure to Cr(VI) compounds and lung
cancer.
As noted in section 6.4.11.4 of this report life time exposure risk ratings have been
adopted in this study with 1 in 10 000 as the maximum tolerable risk to the public and any
lesser risk being deemed to be within the de minimis range.
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The predicted lifetime carcinogenic risk factor for a small area within the Limeroc Business
Park and Centurion Flight Academy is 1 in 330 000. Extending over the immediate
surrounds of the site there is a lifetime carcinogenic risk in the order of 1 in 500 000. No
residential areas are predicted to be exposed to a risk greater than 1 in 1 000 000. To
put this into context for South Africa, it must be noted that the overall (background)
cancer risk for South Africans in 2009 was 1 in 8 for men and 1 in 9 for women (Herbst,
2015).
Figure 11-6: Scenario 1 Predicted Cr(VI) lifetime carcinogenic risk with WHO RfC.
11.1.2.6.3 PREDICTED LIFETIME CARCINOGENIC RISK USING THE US EPA RFC
The predicted lifetime carcinogenic risk resulting from the maximum anticipated
emissions from the plant, based on the US EPA recommendations for linear dose-
response relationships between exposure to Cr(VI) compounds and lung cancer. As
noted in section 6.4.11.4 of this report life time exposure risk ratings have been adopted
in this study with 1 in 10 000 as the maximum tolerable risk to the public and any lesser risk
being deemed within the de minimis range
The predicted excess lifetime carcinogenic risk factor within the proximity of the Limeroc
Business Park and the immediate surrounds are predicted to be exposed to a risk less
than 1 in 1 000 000. To put this into context for South Africa, it must be noted that the
overall (background) cancer risk for South Africans in 2009 was 1 in 8 for men and 1 in 9
for women (Herbst, 2015).
11.1.2.7 PREDICTED LIFETIME CARCINOGENIC RISK FOR POLYCYCLIC AROMATIC
HYDROCARBONS
The potential impact of exposure to measured PAH emissions has been assessed in terms
of lifetime exposure cancer risk to PAHs based on the modelled ambient concentrations
and the Inhalation Unit Risks given in Table 6-25
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It is important to note that the emission have been modelled assuming continuous
emissions at the maximum allowable limit for PAHs, 24h per day, 365 days per year. This
is a significant exaggeration of the actual emissions scenario on the site. Emissions would
in reality be limited to periods where pyrolysis is actually underway and there are
emissions being generated by the reactors.
The assessment further does not account for the limited exposure periods of surrounding
industrial receptors based on their working hours, but assumes exposure 24h per day, 365
days per year. This is a significant exaggeration of the actual exposure in the vicinity of
the site where receptors would in reality work a limited number of hours per day, and a
limited number of days per year in accordance with general conditions of employment.
The calculated risk per compound as well as the cumulative risk for all PAHs expected to
be emitted is shown in Table 11-4.
Table 11-4: Calculated Cancer Risk of PAHs expected from the combustion of
plastics – Scenario 1
Polycyclic aromatic
hydrocarbon
Inhalation Unit Risk (IUR)
(µg/m³)-1
Maximum Risk based on
maximum Annual
Concentrations
*sum of Benz[a]anthracene benzo[b]fluoranthene benzo[k]fluoranthene indeno[1,2,3,-c,d]pyrene
0.00011
1 : 15 991 565
Dibenzo[a,h]anthracene 0.0012 1 : 12 994 868
Naphthalene 0.000034 1 : 2 284 130 034
Benzo[a]pyrene 0.0011 1 : 1 197 192
Chrysene 0.000011 1 : 8 803 257 617
Cumulative Risk 1 : 1 025 299
* Benz[a]anthracene, benzo[b]fluoranthene, benzo[k]fluoranthene and indeno[1,2,3,-
c,d]pyrene were grouped together as the compounds hold the same IUR of 0.00011 per
µg/m³.
Table 11-4 demonstrates that the maximum predicted lifetime exposure carcinogenic
risk from cumulative PAH emissions for scenario 1 is estimated to be 1 in 1 025 299.
As shown in Table 6-26 and section 6.4.21.1.1, a risk of 1 in 1 000 000 or lower is defined
as an ‘acceptable risk’ at which no further improvements in safety need to be made. To
put this into context for South Africa, it must be noted that the overall (background)
cancer risk for South Africans in 2009 was 1 in 8 for men and 1 in 9 for women (Herbst,
2015).
11.1.2.8 METALS AND OTHER POLLUTANTS OF CONCERN
Apart from lead (Pb) and Carbon Monoxide (CO) no ambient air quality standards have
been set in South Africa for the metals and other pollutants with emission limits for
Subcategory 8.1. Therefore, international guidelines have been used to assess the
impact of the predicted concentrations on ambient air quality. As shown by the table
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below (Table 11-5), the maximum predicted concentrations of other pollutants of
concern are well within the various ambient standards.
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Table 11-5: Metals and other pollutants
Name Symbol
Modelled
Emission
Limits
(mg/Nm³)
Ambient
Air
Quality
Limit
(μg/m³)
Predicted Maximum
Ambient
Concentration (μg/m³)
Averaging
time
Country /
agency
Thallium Tl 0.05 0.1 0.0002 Annual Michigan
Cadmium Cd 0.05 0.025 0.0017 24 h Ontario
0.005 0.0002 Annual Ontario
Carbon Monoxide CO 50 30 000 7.4892 1 h SA
10 000 2.9957 8 hr SA
Ammonia NH3 10
350 1.4978 1 h Michigan
100 0.3319 24 h Ontario
8 0.0608 Annual New Zealand
Antimony Sb 0.05 25 0.0017 24 h Ontario
Arsenic As 0.05 0.3 0.0017 24 h Ontario
Chromium Cr 0.05 0.5 0.0017 24 h Ontario
0.11 0.0017 Annual New Zealand
Cobalt Co 0.05 0.1 0.0017 24 h Ontario
Copper Cu 0.05 50 0.0017 24 h Ontario
Lead Pb 0.05 0.5 0.0002 Annual SA
Manganese Mn 0.05 2.5 0.0017 24h Ontario
0.15 0.0002 Annual WHO
Nickel* Ni 0.05 0.2 0.0017 24 h Ontario
0.04 0.0002 Annual Ontario
Vanadium V 0.05 1 0.0017 24 h WHO
Mercury Hg 10 2 0.0017 24 h Ontario
1 0.0002 Annual WHO
Hydrochloric acid HCl 10 75 1.4964 1 h UK
20 0.3315 24 h Ontario
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Table 11-5: Metals and other pollutants
Name Symbol
Modelled
Emission
Limits
(mg/Nm³)
Ambient
Air
Quality
Limit
(μg/m³)
Predicted Maximum
Ambient
Concentration (μg/m³)
Averaging
time
Country /
agency
Hydrofluoric acid HF 10 16 0.0749 1 h UK
0.86 0.0166 24 h Ontario
Dioxins/furans PCCD/
PCDF
ng I-
TEQ/Nm³ pg I-TEQ/Nm³
0.1 0.1 0.000003 24h Ontario
*using Nickel limits for Ni in TSP.
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11.1.3 SCENARIO 2: ALTERNATIVE LOCATION
All proposed sources modelled at the preferred site location minimum emission
standards for the applicable regulated emissions per source as stipulated by
Subcategory 3.1, 3.4 and Subcategory 8.1 in GN893:2013, as amended. Measured Cr(VI)
emissions from the plant show that this emission concentration is achievable with the
abatement technologies proposed.
11.1.3.1 PREDICTED CONCENTRATIONS FOR PM10
Modelled particulate emissions have not been fractioned to indicate the percentage of
PM10 in the total particulates measured. For the purposes of this assessment it was
conservatively assumed that all particulates measured are PM10.
11.1.3.1.1 PREDICTED 24 HOUR CONCENTRATIONS FOR PM10
The predicted impact from the operations is well within the NAAQS limit of 75 µg/m3 for
the 24-hour averaging interval (Figure 11-7).
Figure 11-7: Scenario 2 Predicted PM10 24-Hour maximum modelled ambient
concentration.
11.1.3.1.2 PREDICTED ANNUAL CONCENTRATIONS FOR PM10
The predicted impact from the operations is well within the NAAQS limit of 40 µg/m3 for
the annual averaging interval as well. For the three years assessed (2016 through to 2018)
the maximum PM10 concentration occurring over the area for the annual averaging
period is 0.04 µg/m3.
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11.1.3.2 PREDICTED CONCENTRATIONS FOR PM2.5
Modelled particulate emissions have not been fractioned to indicate the percentage of
PM2.5 in the total particulates measured. For the purposes of this assessment it was
conservatively assumed that all particulates measured are PM2.5.
11.1.3.2.1 PREDICTED 24 HOUR CONCENTRATIONS FOR PM2.5
The predicted impact from the operations is well within the NAAQS limit of 40 µg/m3 for
the 24-hour averaging interval (Figure 11-8).
Figure 11-8: Scenario 2 Predicted PM2.5 24-Hour maximum modelled ambient
concentration.
11.1.3.2.2 PREDICTED ANNUAL CONCENTRATIONS FOR PM2.5
The predicted impact from the operations is well within the NAAQS limit of 20 µg/m3 for
the annual averaging interval as well. For the three years assessed (2016 through to 2018)
the maximum PM2.5 concentration occurring over the area for the annual averaging
period is 0.04 µg/m3.
11.1.3.3 PREDICTED CONCENTRATIONS FOR SO2
11.1.3.3.1 PREDICTED 1 HOUR CONCENTRATIONS FOR SO2
The predicted impact from the operations is well within the NAAQS limit of 350 µg/m3 for
the 1-hour averaging interval (Figure 11-9).
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Figure 11-9: Scenario 2 Predicted SO2 1-Hour maximum modelled ambient
concentration.
11.1.3.3.2 PREDICTED 24 HOUR CONCENTRATIONS FOR SO2
The predicted impact from the operations is well within the NAAQS limit of 125 µg/m3 for
the 24-hour averaging interval. For the three years assessed (2016 through to 2018) the
maximum SO2 concentration occurring over the area for the 24-hour averaging period
is 1.86 µg/m3.
11.1.3.3.3 PREDICTED ANNUAL CONCENTRATIONS FOR SO2
The predicted impact from the operations is well within the NAAQS limit of 50 µg/m3 for
the annual averaging interval as well. For the three years assessed (2016 through to 2018)
the maximum SO2 concentration occurring over the area for the annual averaging
period is 0.18 µg/m3.
11.1.3.4 PREDICTED CONCENTRATIONS FOR NO2
11.1.3.5 PRE-AMBLE NITROUS OXIDES
The national ambient air quality standards regulate ambient concentrations of NO2. It
must be noted that NOx represents all oxides of nitrogen species. NOx gases are
composed of chemical species other than NO2 which is typically in the order of only 5
to10% of NOx emitted from combustion sources. The primary NOx constituent of these off-
gases is typically NO (approximately 90% to 95%). NO will eventually be oxidised to NO2
in the atmosphere, and the rate of conversion is dictated by the kinetics of reaction in
the atmosphere. The downwind concentration of NO2 from the source is thus generally
over-estimated by assuming that all NOx emissions are NO2 (various sources – Cooper et
al, Yu et al, Hori et al). The implication is that the modelled results have over predicted
the NO2 ambient concentration and the true ambient concentration of NO2 is
significantly less.
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In terms of the Regulations Regarding Air Dispersion Modelling (GN. R 533 of 2014), the
dispersion model used for this air quality impact assessment, and in general all of those
recommended, do not have sufficiently detailed descriptions of atmospheric chemistry
to robustly account for NO to NO2 conversion and thus the predicted NOx concentration
must be equated to NO2, using a conversion factor. A tiered screening approach is
recommended to obtain annual average estimates of NO2 from point sources as
stipulated by the US EPA and other guidelines:
Tier 1: Total Conversion Method – Assume that all NOx is converted to NO2.
Tier 2: Ambient Ratio Method – Assume a national ratio of NO2/NOx of 0.80.
In the absence of reliable and complete measured ambient data for NO and NO2, the
tier 2 conversion has been applied in this assessment.
11.1.3.5.1 PREDICTED 1 HOUR CONCENTRATIONS FOR NO2
The predicted impact from the operations is within the NAAQS limit of 200 µg/m3 for the
1-hour averaging interval (Figure 11-10).
Figure 11-10: Scenario 2 Predicted NO2 1-Hour maximum modelled ambient
concentration.
11.1.3.5.2 PREDICTED ANNUAL CONCENTRATIONS FOR NO2
The predicted impact from the operations is within the NAAQS limit of 40 µg/m3 for the
annual averaging interval as well. For the three years assessed (2016 through to 2018)
the maximum NO2 concentration occurring over the area for the annual averaging
period is 0.70 µg/m3.
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11.1.3.6 PREDICTED CONCENTRATIONS AND CARCINOGENIC RISK FOR Cr(VI)
11.1.3.6.1 PREDICTED 1 HOUR CONCENTRATIONS FOR Cr(VI)
The emission rate of Cr(VI) was conservatively predicted through the analysis of the wax
waste sample that will form part of the feed material into the pyrolysis reactor. The
sample was analysed for Cr(VI), and the result was that Cr(VI) concentration within the
sample was below the detectable limit of 2 mg/kg. It was conservatively assumed that
the Cr(VI) concentration within the sample is 2 mg/kg.
The predicted impact from the operations is within the Alberta, Canada Ambient Air
Quality limit of 1 µg/m3 for the 1-hour averaging interval (Figure 11-11).
Figure 11-11: Scenario 2 Predicted Cr(VI) 1-Hour maximum modelled ambient
concentration.
11.1.3.6.2 PREDICTED LIFETIME CARCINOGENIC RISK USING THE WHO RFC
Figure 11-12 shows the predicted excess lifetime carcinogenic risk resulting from the
maximum anticipated emissions from the plant, based on the WHO recommendations
for linear dose-response relationships between exposure to Cr(VI) compounds and lung
cancer.
As noted in section 6.4.11.4 of this report life time exposure risk ratings have been
adopted in this study with 1 in 10 000 as the maximum tolerable risk to the public and any
lesser risk being deemed to be within the de minimis range.
The predicted lifetime carcinogenic risk factor for a small area within the Limeroc Business
Park is 1 in 1 000 000. Extending over the immediate surrounds of the site there is a lifetime
carcinogenic risk in the order of 1 in 1 000 000. No residential areas are predicted to be
exposed to a risk greater than 1 in 1 000 000. To put this into context for South Africa, it
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must be noted that the overall (background) cancer risk for South Africans in 2009 was 1
in 8 for men and 1 in 9 for women (Herbst, 2015).
Figure 11-12: Scenario 2 Predicted Cr(VI) lifetime carcinogenic risk with WHO RfC.
11.1.3.6.3 PREDICTED LIFETIME CARCINOGENIC RISK USING THE US EPA RFC
The predicted lifetime carcinogenic risk resulting from the maximum anticipated
emissions from the plant, based on the US EPA recommendations for linear dose-
response relationships between exposure to Cr(VI) compounds and lung cancer. As
noted in section 6.4.11.4 of this report life time exposure risk ratings have been adopted
in this study with 1 in 10 000 as the maximum tolerable risk to the public and any lesser risk
being deemed within the de minimis range
The predicted excess lifetime carcinogenic risk factor within the proximity of the Limeroc
Business Park and the immediate surrounds are predicted to be exposed to a risk less
than 1 in 1 000 000. To put this into context for South Africa, it must be noted that the
overall (background) cancer risk for South Africans in 2009 was 1 in 8 for men and 1 in 9
for women (Herbst, 2015).
11.1.3.7 PREDICTED LIFETIME CARCINOGENIC RISK FOR POLYCYCLIC AROMATIC
HYDROCARBONS
The potential impact of exposure to measured PAH emissions has been assessed in terms
of lifetime exposure cancer risk to PAHs based on the modelled ambient concentrations
and the Inhalation Unit Risks given in Table 6-25
It is important to note that the emission have been modelled assuming continuous
emissions at the maximum allowable limit for PAHs, 24h per day, 365 days per year. This
is a significant exaggeration of the actual emissions scenario on the site. Emissions would
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in reality be limited to periods where pyrolysis is actually underway and there are
emissions being generated by the reactors.
The assessment further does not account for the limited exposure periods of surrounding
industrial receptors based on their working hours, but assumes exposure 24h per day, 365
days per year. This is a significant exaggeration of the actual exposure in the vicinity of
the site where receptors would in reality work a limited number of hours per day, and a
limited number of days per year in accordance with general conditions of employment.
The calculated risk per compound as well as the cumulative risk for all PAHs expected to
be emitted is shown in Table 11-6.
Table 11-6: Calculated Cancer Risk of PAHs expected from the combustion of plastics
– Scenario 2
Polycyclic aromatic
hydrocarbon
Inhalation Unit Risk (IUR)
(µg/m³)-1
Maximum Risk based on
maximum Annual
Concentrations
*sum of Benz[a]anthracene benzo[b]fluoranthene benzo[k]fluoranthene indeno[1,2,3,-c,d]pyrene
0.00011
1 : 64 986 180
Dibenzo[a,h]anthracene 0.0012 1 : 52 808 269
Naphthalene 0.000034 1 : 9 282 199 021
Benzo[a]pyrene 0.0011 1 : 4 865 124
Chrysene 0.000011 1 : 35 774 490 950
Cumulative Risk 1 : 4 166 587
* Benz[a]anthracene, benzo[b]fluoranthene, benzo[k]fluoranthene and indeno[1,2,3,-
c,d]pyrene were grouped together as the compounds hold the same IUR of 0.00011 per
µg/m³.
Table 11-6 demonstrates that the maximum predicted lifetime exposure carcinogenic
risk from cumulative PAH emissions for scenario 2 is estimated to be 1 in 4 166 587.
As shown in Table 6-26 and section 6.4.21.1.1, a risk of 1 in 1 000 000 or lower is defined
as an ‘acceptable risk’ at which no further improvements in safety need to be made. To
put this into context for South Africa, it must be noted that the overall (background)
cancer risk for South Africans in 2009 was 1 in 8 for men and 1 in 9 for women (Herbst,
2015).
11.1.3.8 METALS AND OTHER POLLUTANTS OF CONCERN
Apart from lead (Pb) and Carbon Monoxide (CO) no ambient air quality standards have
been set in South Africa for the metals and other pollutants with emission limits for
Subcategory 8.1. Therefore, international guidelines have been used to assess the
impact of the predicted concentrations on ambient air quality. As shown by the table
below (Table 11-5), the maximum predicted concentrations of other pollutants of
concern are well within the various ambient standards.
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Table 11-7: Metals and other pollutants
Name Symbol
Modelled
Emission
Limits
(mg/Nm³)
Ambient
Air
Quality
Limit
(μg/m³)
Predicted Maximum
Ambient
Concentration (μg/m³)
Averaging
time
Country /
agency
Thallium Tl 0.05 0.1 0.0002 Annual Michigan
Cadmium Cd 0.05 0.025 0.0019 24 h Ontario
0.005 0.0002 Annual Ontario
Carbon Monoxide CO 50 30 000 22.7520 1 h SA
10 000 9.1008 8 hr SA
Ammonia NH3 10
350 4.5504 1 h Michigan
100 1.4904 24 h Ontario
8 0.1668 Annual New Zealand
Antimony Sb 0.05 25 0.0019 24 h Ontario
Arsenic As 0.05 0.3 0.0019 24 h Ontario
Chromium Cr 0.05 0.5 0.0019 24 h Ontario
0.11 0.0019 Annual New Zealand
Cobalt Co 0.05 0.1 0.0019 24 h Ontario
Copper Cu 0.05 50 0.0019 24 h Ontario
Lead Pb 0.05 0.5 0.0002 Annual SA
Manganese Mn 0.05 2.5 0.0019 24h Ontario
0.15 0.0002 Annual WHO
Nickel* Ni 0.05 0.2 0.0019 24 h Ontario
0.04 0.0002 Annual Ontario
Vanadium V 0.05 1 0.0019 24 h WHO
Mercury Hg 10 2 0.0019 24 h Ontario
1 0.0002 Annual WHO
Hydrochloric acid HCl 10 75 1.1376 1 h UK
20 0.3726 24 h Ontario
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Table 11-7: Metals and other pollutants
Name Symbol
Modelled
Emission
Limits
(mg/Nm³)
Ambient
Air
Quality
Limit
(μg/m³)
Predicted Maximum
Ambient
Concentration (μg/m³)
Averaging
time
Country /
agency
Hydrofluoric acid HF 10 16 0.0569 1 h UK
0.86 0.0186 24 h Ontario
Dioxins/furans PCCD/
PCDF
ng I-
TEQ/Nm³ pg I-TEQ/Nm³
0.1 0.1 0.000015 24h Ontario
*using Nickel limits for Ni in TSP.
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11.2 ANALYSIS OF EMISSIONS’ IMPACT ON THE ENVIRONMENT
This report assumes that if there is compliance with the AAQS, the damage risk to the
environment would be considered to be within acceptable levels, for those pollutants
that are contained in AAQs. Notably the pollutants assessed are all well within the AAQs
identified.
The pollutants of concern may pose a variety of potential non-inhalation related
impacts. These include for example impacts from dry and wet acid depositions and
potential impact on vegetation and fauna. The absence of defined concentrations at
which damage in known/expected to occur, is the most challenging aspect of assessing
the impacts of these pollutants to the environment.
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12 CURRENT OR PLANNED AIR QUALITY MANAGEMENT INTERVENTIONS
Table 12-1: Appliances and Abatement equipment control technology used on site
Appliance Name
Appliance
Type or
Description
Appliance Function/Purpose
Envisaged
Reduction
in
Emissions
(%)
Pyrolysis Reactor Scrubber
The off-gases from the pyrolysis reactor will be routed through a scrubber to
remove sulphur dioxide (SO2), particulate matter and other soluble gases
before being released into the atmosphere via a scrubber stack.
95%
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13 EMERGENCY INCIDENTS
This is not applicable as the facility has not yet been constructed.
14 COMPLIANCE AND ENFORCEMENT HISTORY
This is not applicable as the facility has not yet been constructed.
15 COMPLAINTS
This is not applicable as the facility has not yet been constructed.
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16 CONCLUSIONS AND RECOMMENDATIONS
The emissions quantification and subsequent prediction of ambient impact have been
undertaken with conservativeness, with the effect that the modelled outcomes relating
to emissions from the site are expected to be over-predictions. The modelling further
does not account for wet deposition of the pollutants, thus further over-predicting
atmospheric concentrations.
Two scenarios were modelled:
i. Scenario 1 – All proposed sources modelled at the preferred site location
minimum emission standards for the applicable regulated emissions per source
as stipulated by Subcategory 3.1, 3.4 and Subcategory 8.1 in GN893:2013, as
amended; and,
ii. Scenario 2 - All proposed sources modelled at the alternative site location
minimum emission standards for the applicable regulated emissions per source
as stipulated by Subcategory 3.1, 3.4 and Subcategory 8.1 in GN893:2013, as
amended.
16.1 SCENARIO 1: PREFERRED LOCATION EMISSIONS
It is important to note that this scenario evaluates the potential impact of Industrial Green
Energy Solutions operating all its’ proposed sources at the maximum allowable emissions
rates on a continuous basis of 24h a day for 365 a year. This is in fact an exaggeration of
the actual impact of operating at the maximum allowable emission rates the sources do
not have 100% uptime, and actual emissions vary. However, it demonstrates the worst
case permitted emissions scenario and gives insight into the worst case impact that
would occur if the site operated at the very limit of compliance with the emissions
regulations.
16.1.1 PARTICULATE MATTER
16.1.1.1 PM10 - 24 HOUR
Predicted maximum ambient concentrations of PM10 from the proposed operations are
well within the 24-hour limit, 75 µg/m³.
16.1.1.2 PM10 - ANNUAL
Predicted maximum ambient concentrations of PM10 from the proposed operations are
well within the annual ambient air quality limit, 40 µg/m³.
16.1.1.3 PM2.5 - 24 HOUR
Predicted maximum ambient concentrations of PM2.5 from the proposed operations are
well within the 24-hour limit, 40 µg/m³.
16.1.1.4 PM2.5 - ANNUAL
Predicted maximum ambient concentrations of PM2.5 from the proposed operations are
well within the annual ambient air quality limit, 20 µg/m³.
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16.1.2 SULPHUR DIOXIDE
16.1.2.1 1-HOUR
Predicted maximum ambient concentrations of SO2 from the proposed operations are
within the 1-hour limit, 350 µg/m³.
16.1.2.2 24-HOUR
Predicted maximum ambient concentrations of SO2 from the proposed operations are
within the 24-hour limit, 125 µg/m³.
16.1.2.3 ANNUAL
Predicted maximum ambient concentrations of SO2 from the proposed operations are
within the annual limit, 50 µg/m³.
16.1.3 NITROGEN DIOXIDE
16.1.3.1 1-HOUR
Predicted maximum ambient concentrations of NO2 from the proposed operations are
within the 1-hour limit of 200 µg/m³.
16.1.3.2 ANNUAL
Predicted maximum ambient concentrations of NO2 from the proposed operations are
within the annual limit, 40 µg/m³.
16.1.4 HEXAVALENT CHROMIUM
16.1.4.1 1-HOUR
The maximum predicted 1-hour ambient concentrations from the operations are within
the Alberta state and Manitoba state 1-hour limits of 1 µg/m3 and 4.5 µg/m3, respectively.
16.1.4.2 PREDICTED LIFETIME CARCINOGENIC RISK USING THE WHO RFC
The predicted lifetime carcinogenic risk resulting from the maximum anticipated
emissions from the plant, based on the WHO recommendations for linear dose-response
relationships between exposure to Cr(VI) compounds and lung cancer for a small area
within the Limeroc Business Park and Centurion Flight Academy is 1 in 330 000. Extending
over the immediate surrounds of the site there is a lifetime carcinogenic risk in the order
of 1 in 500 000. No residential areas are predicted to be exposed to a risk greater than 1
in 1 000 000.
As noted in section 6.4.11.4 of this report life time exposure risk ratings have been
adopted in this study with 1 in 10 000 as the maximum tolerable risk to the public. The
cancer risk range that is deemed acceptable in various parts of the world is from 1 in
10 000 to 1 in 1 000 000. This risk range reflects a de minimis lifetime risk that is so trivial that
any action to reduce risk is not warranted (Kocher and Hoffman, 1994). To put this into
context for South Africa, it must be noted that the overall (background) cancer risk for
South Africans in 2009 was 1 in 8 for men and 1 in 9 for women (Herbst, 2015).
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16.1.4.3 PREDICTED LIFETIME CARCINOGENIC RISK USING THE US EPA RFC
The predicted lifetime carcinogenic risk resulting from the maximum anticipated
emissions from the plant, based on the US EPA recommendations for linear dose-
response relationships between exposure to Cr(VI) compounds and lung cancer, within
the proximity of the Limeroc Business Park and the immediate surrounds of the site is in
the order of 1 in 1 000 000.
As noted in section 6.4.11.4 of this report life time exposure risk ratings have been
adopted in this study with 1 in 10 000 as the maximum tolerable risk to the public. The
cancer risk range that is deemed acceptable in various parts of the world is from 1 in
10 000 to 1 in 1 000 000. This risk range reflects a de minimis lifetime risk that is so trivial that
any action to reduce risk is not warranted (Kocher and Hoffman, 1994). To put this into
context for South Africa, it must be noted that the overall (background) cancer risk for
South Africans in 2009 was 1 in 8 for men and 1 in 9 for women (Herbst, 2015).
16.1.5 POLYCYCLIC AROMATIC HYDROCARBONS
16.1.5.1 PREDICTED LIFETIME CARCINOGENIC RISK
Table 11-4 demonstrates that the maximum predicted lifetime exposure carcinogenic
risk from cumulative PAH emissions for scenario 1 is estimated to be 1 in 1 025 299.
As shown in Table 6-26 and section 6.4.21.1.1, a risk of 1 in 1 000 000 or lower is defined
as an ‘acceptable risk’ at which no further improvements in safety need to be made. To
put this into context for South Africa, it must be noted that the overall (background)
cancer risk for South Africans in 2009 was 1 in 8 for men and 1 in 9 for women (Herbst,
2015).
16.1.6 METALS AND OTHER POLLUTANTS
Apart from lead (Pb) and Carbon Monoxide (CO) no ambient air quality standards have
been set in South Africa for the metals and other pollutants with emission limits for
Subcategory 8.1. Therefore, international guidelines have been used to assess the
impact of the predicted concentrations on ambient air quality. The predicted ambient
concentrations for all relevant pollutants are well within international standards as shown
in Table 11-5.
16.2 SCENARIO 2: ALTERNATIVE LOCATION EMISSIONS
It is important to note that this scenario evaluates the potential impact of Industrial Green
Energy Solutions operating all its’ proposed sources at the maximum allowable emissions
rates on a continuous basis of 24h a day for 365 a year. This is in fact an exaggeration of
the actual impact of operating at the maximum allowable emission rates the sources do
not have 100% uptime, and actual emissions vary. However, it demonstrates the worst
case permitted emissions scenario and gives insight into the worst case impact that
would occur if the site operated at the very limit of compliance with the emissions
regulations.
16.2.1 PARTICULATE MATTER
16.2.1.1 PM10 - 24 HOUR
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Predicted maximum ambient concentrations of PM10 from the proposed operations are
well within the 24-hour limit, 75 µg/m³.
16.2.1.2 PM10 - ANNUAL
Predicted maximum ambient concentrations of PM10 from the proposed operations are
well within the annual ambient air quality limit, 40 µg/m³.
16.2.1.3 PM2.5 - 24 HOUR
Predicted maximum ambient concentrations of PM2.5 from the proposed operations are
well within the 24-hour limit, 40 µg/m³.
16.2.1.4 PM2.5 - ANNUAL
Predicted maximum ambient concentrations of PM2.5 from the proposed operations are
well within the annual ambient air quality limit, 20 µg/m³.
16.2.2 SULPHUR DIOXIDE
16.2.2.1 1-HOUR
Predicted maximum ambient concentrations of SO2 from the proposed operations are
within the 1-hour limit, 350 µg/m³.
16.2.2.2 24-HOUR
Predicted maximum ambient concentrations of SO2 from the proposed operations are
within the 24-hour limit, 125 µg/m³.
16.2.2.3 ANNUAL
Predicted maximum ambient concentrations of SO2 from the proposed operations are
within the annual limit, 50 µg/m³.
16.2.3 NITROGEN DIOXIDE
16.2.3.1 1-HOUR
Predicted maximum ambient concentrations of NO2 from the proposed operations are
within the 1-hour limit of 200 µg/m³.
16.2.3.2 ANNUAL
Predicted maximum ambient concentrations of NO2 from the proposed operations are
within the annual limit, 40 µg/m³.
16.2.4 HEXAVALENT CHROMIUM
16.2.4.1 1-HOUR
The maximum predicted impact from the operations are within the Alberta state and
Manitoba state 1-hour limits of 1 µg/m3 and 4.5 µg/m3, respectively.
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16.2.4.2 PREDICTED LIFETIME CARCINOGENIC RISK USING THE WHO RFC
The predicted lifetime carcinogenic risk resulting from the maximum anticipated
emissions from the plant, based on the WHO recommendations for linear dose-response
relationships between exposure to Cr(VI) compounds and lung cancer for a small area
within the Limeroc Business Park is 1 in 1 000 000. Extending over the immediate surrounds
of the site there is a lifetime carcinogenic risk in the order of 1 in 1 000 000. No residential
areas are predicted to be exposed to a risk greater than 1 in 1 000 000.
As noted in section 6.4.11.4 of this report life time exposure risk ratings have been
adopted in this study with 1 in 10 000 as the maximum tolerable risk to the public. The
cancer risk range that is deemed acceptable in various parts of the world is from 1 in
10 000 to 1 in 1 000 000. This risk range reflects a de minimis lifetime risk that is so trivial that
any action to reduce risk is not warranted (Kocher and Hoffman, 1994). To put this into
context for South Africa, it must be noted that the overall (background) cancer risk for
South Africans in 2009 was 1 in 8 for men and 1 in 9 for women (Herbst, 2015).
16.2.4.3 PREDICTED LIFETIME CARCINOGENIC RISK USING THE US EPA RFC
The predicted lifetime carcinogenic risk resulting from the maximum anticipated
emissions from the plant, based on the US EPA recommendations for linear dose-
response relationships between exposure to Cr(VI) compounds and lung cancer, within
the proximity of the Limeroc Business Park and the immediate surrounds of the site is in
the order of 1 in 1 000 000.
As noted in section 6.4.11.4 of this report life time exposure risk ratings have been
adopted in this study with 1 in 10 000 as the maximum tolerable risk to the public. The
cancer risk range that is deemed acceptable in various parts of the world is from 1 in
10 000 to 1 in 1 000 000. This risk range reflects a de minimis lifetime risk that is so trivial that
any action to reduce risk is not warranted (Kocher and Hoffman, 1994). To put this into
context for South Africa, it must be noted that the overall (background) cancer risk for
South Africans in 2009 was 1 in 8 for men and 1 in 9 for women (Herbst, 2015).
16.2.5 POLYCYCLIC AROMATIC HYDROCARBONS
16.2.5.1 PREDICTED LIFETIME CARCINOGENIC RISK
Table 11-6 demonstrates that the maximum predicted lifetime exposure carcinogenic
risk from cumulative PAH emissions for scenario 2 is estimated to be 1 in 4 166 587.
As shown in Table 6-26 and section 6.4.21.1.1, a risk of 1 in 1 000 000 or lower is defined
as an ‘acceptable risk’ at which no further improvements in safety need to be made. To
put this into context for South Africa, it must be noted that the overall (background)
cancer risk for South Africans in 2009 was 1 in 8 for men and 1 in 9 for women (Herbst,
2015).
16.2.6 METALS AND OTHER POLLUTANTS
Apart from lead (Pb) and Carbon Monoxide (CO) no ambient air quality standards have
been set in South Africa for the metals and other pollutants with emission limits for
Subcategory 8.1. Therefore, international guidelines have been used to assess the
impact of the predicted concentrations on ambient air quality. The predicted ambient
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concentrations for all relevant pollutants are well within international standards as shown
in Table 11-7.
16.3 RECOMMENDATIONS
Based on the results above, and in cognisance of both the limitations and conservative
over-predictions, it is concluded that environmental authorisation and related
Atmospheric Emissions Licence be granted for the operations. The emissions limits listed
in the Minimum Emission Standards as stipulated in GN 893:2013 must be met.
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17 DETAILS OF THE SPECIALIST
17.1 SPECIALISTS COMPILING THE REPORT
The Air Quality Impact Assessment was undertaken by EScience Associates (Pty) Ltd. A
summary of the consultants who undertook the specialist work is noted in Table 17-1.
Table 17-1: Details of the Specialists
Name Qualification Role/Responsibility
Abdul Ebrahim BEng (Hons) Env Eng.
BEng (Hons) Mech
Eng.
Principal Specialist
Sam Leyde BSc (Hons) Mechanical
Engineering
Emissions inventory construction and
Integrative report writing
James Pugin MSc (Archaeology) Geographical information systems
specialist - Geophysical data file
formulation, mapping, and
reporting.
Tiffany Seema BSc (Hons)Geology Integrative report writing
Zayd Ebrahim BSc Geology and
Environmental &
Geographical
Sciences
Meteorological and atmospheric
dispersion modelling
For further details on experience of the specialists refer to the Appendix 2.
17.2 DECLARATION OF INTEREST
The specialists who have undertaken this Air Quality Impact Assessment declare that:
• We act as the independent specialist in this application.
• Have performed the work relating to the application in an objective manner.
• There are no circumstances that may compromise our objectivity in performing
this work;
• We have expertise in conducting the specialist report relevant to this application,
including knowledge of the NEMA, NEMAQA, regulations and guidelines that
have relevance to the activity;
• We have not engaged in conflicting interests in the undertaking of the activity;
• We undertake to disclose to the applicant and the competent authority all
material information in our possession that reasonably has or may have the
potential of influencing an environmental authorisation or licencing decision to
be taken, with respect to this application, by the competent authority; and the
objectivity of any report, plan or document to be prepared by ourselves for the
competent authority relevant to this application;
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18 FORMAL DECLARATION
18.1 DECLARATION OF ACCURACY OF INFORMATION-APPLICANT
ONLY FINAL REPORT TO BE SIGNED
Name of Enterprise: Industrial Green Energy Solutions (Pty) Ltd
Declaration of accuracy of information provided:
Atmospheric Impact Report in terms of section 30 of the Act.
I, --------------------------------------------------------------------------------, [duly authorised], declare that
the information provided in this atmospheric impact report is, to the best of my
knowledge, in all respects factually true and correct. I am aware that the supply of false
or misleading information to an air quality officer is a criminal offence in terms of section
51(1)(g) of this Act.
Signed at ________________ on this _________Day of______________________ 2020.
________________________________
SIGNATURE
________________________________
CAPACITY OF SIGNATORY
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18.2 DECLARATION OF INDEPENDENCE – PRACTITIONER
ONLY FINAL REPORT TO BE SIGNED
Name of Practitioner: Abdul Ebrahim
Name of Registration Body: Engineering Counsel of South Africa
Professional Registration No:
Declaration of independence and accuracy of information provided:
Atmospheric Impact Report in terms of Section 30 of the Act.
I, Abdul Ebrahim, declare that I am independent of the applicant. I have the
necessary expertise to conduct the assessments required for the report and will perform
the work relating the application in an objective manner, even if this results in views and
findings that are not favourable to the applicant. I will disclose to the applicant and the
air quality officer all material information in my possession that reasonably has or may
have the potential of influencing any decision to be taken with respect to the
application by the air quality officer, the information provided in this atmospheric impact
report is, to the best of my knowledge, in all respects factually true and correct. I am
aware that the supply of false or misleading information to an air quality officer is a
criminal offence in terms of section 51(1) (g) of this Act.
Signed at: Oaklands (Johannesburg) on this ____ Day of __________________ 2020
________________________________
SIGNATURE
________________________________
CAPACITY OF SIGNATORY
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APPENDIX 1: RECLASSIFICATION OF SA LULC CODES INTO CALMET LULC CODES
Table 0-1: South African Land Use Land Cover (LULC) codes reclassified according to CALMET LULC codes
SA
LULC
code
USGS code
equivalent
USGS class
definition SA LULC class definition
1 40
Forest
(indigenous)
All wooded areas with a tree canopy > 70 %. A multi-strata community, with interlocking
canopies, composed of canopy, sub-canopy, shrub and herb layers. The canopy is composed
mainly of self-supporting, single stemmed, woody plants > 5 metres in height. Essentially
indigenous species, growing under natural or semi-natural conditions (although it may include
some areas of self-seeded exotic species). Excludes planted forests (and woodlots)
2 40
Woodland
All wooded areas with a tree canopy between 10 - 70%. A broad sparse - open – closed
canopy community, typically consisting of a single tree canopy layer and an herb (grass) layer.
The canopy is composed mainly of self-supporting, single stemmed, woody plants > 5 metres in
height. Essentially indigenous species, growing under natural or semi-natural conditions
(although it may include some areas of self-seeded exotic species). Excludes planted forests
(and woodlots)
(previously
termed Forest &
Woodland)
Canopy cover density classes may be mapped if desired, based on sparse (< 40%), open (40 –
70 %), and closed (> 70 %).
3 30
Thicket,
Bushland, Bush
Clumps, High
Fynbos
Communities typically composed of tall, woody, self-supporting, single or multi-stemmed plants
(branching at or near the ground), with, in most cases no clearly definable structure. Total
canopy cover is greater than 10%, with canopy heights between 2 – 5 metres. Essentially
indigenous species, growing under natural or semi-natural conditions (although it may include
some areas of self-seeded exotic species, especially along riparian zones). Presence of alien
exotic species can be modelled spatially using broad principles of unlikely structural / temporal
occurrences within a given vegetation biome or region. Dense bush encroachment would be
included in this category.
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Table 0-1: South African Land Use Land Cover (LULC) codes reclassified according to CALMET LULC codes
SA
LULC
code
USGS code
equivalent
USGS class
definition SA LULC class definition
Canopy cover density classes may be mapped if desired, based on sparse (< 40%), open (40 –
70 %), and closed (> 70 %).
4 30
Shrubland and
Low Fynbos
Communities dominated by low, woody, self-supporting, multi-5stemmed plants, branching at
or near the ground, between 0.2 and 2 m in height. Total tree cover < 0.1 Typical examples are
low Fynbos, Karoo and Lesotho (alpine) communities.
5 30 Herb land
Communities dominated by low, non-woody, non-grass like plants, between 0.2 and 2 m in
height. Total tree cover < 0.1 Typical examples are found in Namaqualand or “weed”
dominated degraded areas.
6 30
Natural
Grassland
All areas of grassland with < 10% tree and/or shrub canopy cover, and >0.1% total vegetation
cover. Dominated by grass-like, non-woody, rooted herbaceous plants. Essentially indigenous
species growing under natural or semi-natural conditions.
(previously
termed
Unimproved
Grassland)
7 30
Planted
Grassland
As above, except …. Planted grassland, containing either indigenous or exotic species,
growing under man-managed (including irrigated) conditions for grazing, hay or turf
production, recreation (i.e. golf) etc.
(previously
termed
Improved
Grassland)
8 40
Forest Plantations
(Eucalyptus spp) All areas of systematically planted, man-managed tree resources, composed of primarily exotic
species (including hybrids). Category includes both young and mature plantations that have
been established for commercial timber production, seedling trials and woodlot / windbreaks 9 40
Forest Plantations
(Pine spp)
Air Quality Impact Assessment
Industrial Green Energy Solutions (Pty) Ltd Waste Pyrolysis Plant, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 117
Table 0-1: South African Land Use Land Cover (LULC) codes reclassified according to CALMET LULC codes
SA
LULC
code
USGS code
equivalent
USGS class
definition SA LULC class definition
10 40
Forest Plantations
(Acacia spp)
of sufficient size to be identifiable on satellite imagery. Excludes all non-timber-based
plantations such as tea, sisal, citrus, nut crops etc.
11 40
Forest Plantations
(Other / mixed
spp)
12 40
Forest Plantations
(clear-felled)
13 50 Waterbodies
Areas of (generally permanent) open water. The category includes both natural and man-
made water bodies, which are either static or flowing, and fresh, brackish and salt-water
conditions. This category includes features such as rivers, major reservoirs, farm-level irrigation
dams, permanent pans, lakes and lagoons.
14 60 Wetlands
Natural or artificial areas where the water level is permanently or temporarily at (or very near)
the land surface, typically covered in either herbaceous or woody vegetation cover. The
category includes fresh, brackish and salt-water conditions. Examples include pans (with non-
permanent water cover), and reed-marsh or papyrus-swamp. Dry pans are included in this
category unless they are permanently dry.
15 70
Bare Rock and
Soil (natural)
Natural areas of exposed sand, soil or rock with no, or very little vegetation cover during any
time of the year, (excluding agricultural fields with no crop cover, and open cast mines and
quarries). Examples would include rock outcrops, beach sand, and dry riverbed material.
16 70
Bare Rock and
Soil (erosion:
dongas / gullies)
Non-vegetated areas (or areas of very little vegetation cover in comparison to the surrounding
natural vegetation), that are primarily the result of active gully erosion processes. Typically
located in association with areas of poor grassland cover along existing streamlines and / or on
slightly steeper slopes than sheet erosion areas (i.e. greater than 6-degree slope). In some areas
the full extent of donga activity may be obscured by either overhanging adjacent bushes,
encroaching thorn bush, or, in the case of more stable dongas, by bush or grass cover along
the actual streamline.
Air Quality Impact Assessment
Industrial Green Energy Solutions (Pty) Ltd Waste Pyrolysis Plant, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 118
Table 0-1: South African Land Use Land Cover (LULC) codes reclassified according to CALMET LULC codes
SA
LULC
code
USGS code
equivalent
USGS class
definition SA LULC class definition
17 70 Non-vegetated areas (or areas of very little vegetation cover in comparison to the surrounding
natural vegetation), that are primarily the result of active sheet erosion processes. Typically
located in association with areas of severe donga erosion and / or poor grassland cover (i.e.
low image NDVI rating). In some areas the full extent of this process may be obscured by
encroaching bush. Typically located on slopes less than or equal to 6 degrees.
Bare Rock and
Soil (erosion:
sheet)
18 70 Degraded Forest
& Woodland
19 70 Degraded
Thicket,
Bushland, etc.
Permanent or near-permanent, man-induced areas of very low vegetation cover (i.e. removal
of tree, bush, or herbaceous cover) in comparison to the surrounding natural vegetation cover.
Typically associated with subsistence level agriculture and rural population centres, where
overgrazing of livestock and / or wood-resource removal has been locally excessive. Often
associated with severe soil erosion problems.
20 70 Degraded
Shrubland and
Low Fynbos
21 70 Degraded Herb
land
22 70 Degraded
Unimproved
(natural)
Grassland
23 -20
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EScience Associates (Pty) Ltd Page 119
Table 0-1: South African Land Use Land Cover (LULC) codes reclassified according to CALMET LULC codes
SA
LULC
code
USGS code
equivalent
USGS class
definition SA LULC class definition
Cultivated,
permanent,
commercial,
irrigated
Land which has been ploughed and / or prepared for the raising of crops (excluding timber
production). Unless otherwise stated, includes areas currently under crop, fallow land, and land
being prepared for planting. Class boundaries are broadly defined to encompass the main
areas of agricultural activity and are not defined on exact field boundaries. As such all sub-
classes may include small inter-field cover types (e.g. hedges, grass strips, small windbreaks), as
well as farm infrastructure
Several sub-classes are defined, based on the following parameters:
Commercial: characterised by large, uniform, well managed field units (i.e. ± 50 ha), with the
aim of supplying both regional, national and export markets. Often highly mechanised.
Semi-Commercial: characterised by small – medium sized field units (i.e. ± 10 ha), within an
intensively cultivated site, often in close proximity to rural population centres. Typically based on
multi-cropping activities where annual (i.e. temporary crops) are produced for local markets.
Can be irrigated by either mechanical means or gravity-fed channels and furrows. Medium -
low levels of mechanisation.
24 20 Subsistence: characterised by numerous small field units (less than ± 10 ha) in close proximity to
rural population centres. Field units can either be grouped either intensive or widely spaced,
depending on the extent of the area under cultivation and the proximity to rural dwellings and
grazing areas. Includes both rain fed and irrigated (i.e. mechanical or gravity-fed), multi-
cropping of annuals, for either individual or local (i.e. village) markets. May include fallow and
'old fields', and some inter-field grazing areas (which are often classified as degraded).
Air Quality Impact Assessment
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EScience Associates (Pty) Ltd Page 120
Table 0-1: South African Land Use Land Cover (LULC) codes reclassified according to CALMET LULC codes
SA
LULC
code
USGS code
equivalent
USGS class
definition SA LULC class definition
Cultivated,
permanent,
commercial,
dryland
Permanent Crops: lands cultivated with crops that occupy the area for long periods and are
not re-planted after harvest. Examples would include sugar cane and citrus orchards. Note in
the case of sugar can, the growing season is typically 15 – 18 months per ratoon (i.e. harvest),
with 2 – 3 ratoons possible before re-planting. Sugar cane is mapped as a separate crop type,
and includes both large and small-scale commercial activities, as well as fallow (i.e. burnt /
cleared) areas.
25 -20 Temporary Crops: land under temporary crops (i.e. annuals) that are harvested at the
completion of the growing season, and that will remain idle until re-planted. In general, this
refers to maize and soya bean cultivation within the Pongola catchment, although cotton is
locally dominant amongst the larger commercial sugar cane plantation areas.
Cultivated,
permanent,
commercial,
sugarcane
Irrigated / Non-Irrigated: major irrigation schemes (i.e. areas supplied with water for agricultural
purposes by means of pipes, overhead sprinklers, ditches or streams), and are often
characterised
26 -20
Cultivated,
temporary,
commercial,
irrigated
27 20
Air Quality Impact Assessment
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EScience Associates (Pty) Ltd Page 121
Table 0-1: South African Land Use Land Cover (LULC) codes reclassified according to CALMET LULC codes
SA
LULC
code
USGS code
equivalent
USGS class
definition SA LULC class definition
Cultivated,
temporary,
commercial,
dryland
28 20
Cultivated,
temporary,
subsistence,
dryland
29 -20
Cultivated,
temporary,
subsistence,
irrigated
30x 10 Urban / Built-up A generic urban class, essentially comprising all formal built-up areas, in which people reside on
a permanent or near-permanent basis, identifiable by the high density of residential and
associated infrastructure. Includes both towns, villages, and where applicable, the central
nucleus of more open, rural clusters. This class should be used if it is not possible to identify more
industrial and transportation land-uses.
Air Quality Impact Assessment
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EScience Associates (Pty) Ltd Page 122
Table 0-1: South African Land Use Land Cover (LULC) codes reclassified according to CALMET LULC codes
SA
LULC
code
USGS code
equivalent
USGS class
definition SA LULC class definition
Low-density smallholdings frequently located on the urban / peri-urban fringe should be
mapped as a separate smallholding sub-classes, subdivided by the appropriate (level I)
background vegetation type. If visible, individual farm units are to be mapped as isolated
urban / built-up units (if no other class is applicable). Specific urban / built-up sub-classes as
listed below – in such cases it could include residential, commercial,
31x 10 Urban / Built-up
(rural cluster)
Areas of clustered rural dwellings (i.e. kraals) whose structural density is too low to be classified
as a formal village but are of sufficient level to be easily identifiable as such on satellite
imagery. Small scale cultivation / garden plots often form a major spatial component and are
located amongst the residential structures.
32 10 Urban / Built-up
(residential,
formal suburbs)
Permanent residential structures, either single or multi-level, located within new or well-
established residential areas, i.e. ‘garden-suburbs’, (often refers to ‘middle-class’ and ‘upper
class’ residential areas). Includes both low and high building densities.
33 10 Urban / Built-up
(residential,
flatland)
Permanent residential structures, consisting mainly of 3 or more levels (often up to 10), resulting
in a concentration of mid-to-high rise building, for example Hillbrow (Jhb) or Sunnyside (Pta).
34 10 Urban / Built-up
(residential,
mixed)
mixture …
35 10 Urban / Built-up
(residential,
hostels)
Permanent residential structures, typically located in formal township districts, consisting mainly
of 1 or 2 levels in concentrated block-like structures.
36 10 Urban / Built-up
(residential,
formal township)
Permanent (i.e. brick etc.) structures (predominately single level), usually located on serviced
sites within former black residential areas, laid out in an organised, pre-planned manner.
Includes both low and high building densities.
Air Quality Impact Assessment
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EScience Associates (Pty) Ltd Page 123
Table 0-1: South African Land Use Land Cover (LULC) codes reclassified according to CALMET LULC codes
SA
LULC
code
USGS code
equivalent
USGS class
definition SA LULC class definition
37 10 Urban / Built-up
(residential,
informal
township
Permanent / semi-permanent shack type dwellings (i.e. corrugated tin structures) laid out and
established in an organised, pre-planned manner on both serviced and non-serviced sites.
Includes both low and high building densities
38 10 Urban / Built-up
(residential,
informal squatter
camp)
Non-permanent shack type dwellings (i.e. tin, cardboard, wood etc.) typically established on
an informal, ad hoc basis, on non-serviced sites. Typically, high building densities
39 10 Urban / Built-up
(smallholdings,
forest &
woodland …)
see “residential’ definition above ...
40 10 Urban / Built-up
(smallholdings,
thicket,
bushland)
see “residential’ definition above ...
41 10 Urban / Built-up
(smallholdings,
shrubland …)
see “residential’ definition above ...
42 10 Urban / Built-up
(smallholdings,
grassland …)
see “residential’ definition above ...
43 10 Urban / Built-up,
(commercial,
mercantile)
Non-residential areas used primarily for the conduct of commerce and other mercantile
business, typically located in the central business district (CBD). Often consisting of a
concentration of multi-level buildings, but also includes small commercial zones (i.e. spaza
shops) within high density townships.
Air Quality Impact Assessment
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EScience Associates (Pty) Ltd Page 124
Table 0-1: South African Land Use Land Cover (LULC) codes reclassified according to CALMET LULC codes
SA
LULC
code
USGS code
equivalent
USGS class
definition SA LULC class definition
44 10 Urban / Built-up,
(commercial,
education,
health, IT)
Non-residential, non-industrial sites or complexes associated with educational (i.e. schools,
universities), business development centres such as industrial ‘techno-parks’, and / or social
services (i.e. hospitals), often consisting of a concentration of multi-level buildings (Note: only
mapped if clearly identifiable, otherwise included within ‘commercial / mercantile’ or
‘suburban’ categories.
45 10 Urban / Built-up,
(industrial /
transport: heavy)
Non-residential areas with major industrial (i.e. manufacture and/or processing of goods and
products) or transport related infrastructure. Examples would include power stations, steel mills,
dockyards, train stations and airports (i.e. Johannesburg).
46 10 Urban / Built-up,
(industrial /
transport: light
Non-residential areas with major technology, manufacturing or transport related infrastructure.
Examples would include light manufacturing units, warehouse dominated business
development centres, and small airports (i.e. Lanseria). Also includes similar structures such as
farm-based pig and battery hen breeding units.
47 70 Mines & Quarries
(underground /
subsurface
mining)
Active or non-active underground or sub-surface-based mining activities. Category includes all
associated surface infrastructure etc.
48 70 Mines & Quarries
(surface-based
mining)
Active or non-active surface-based mining activities. Includes both hard rock or sand quarry
extraction sites, and opencast mining sites i.e. coal. Category includes all associated surface
infrastructure.
49 70 Mines & Quarries
(mine tailings,
waste dumps)
Primarily non-vegetated, exposed mining (and heavy industry) extraction or waste material.
Major areas of managed vegetation rehabilitation on these sites can be mapped according to
the appropriate vegetation category.
Air Quality Impact Assessment
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EScience Associates (Pty) Ltd Page 125
APPENDIX 2: CV’S OF TEAM MEMBERS
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
Surname: Abdul Ebrahim
Date of birth: 07 December 1977
Country of Residency: Republic of South Africa
Position: Director
Key Qualifications: BEng (Hons) Environmental, BEng (Hons) Mechanical
Registrations: ECSA, EAPASA
Contact details
: 011 7186380
: 072 268 1119
: abdul@escience.co.za
Abstract
Abdul Ebrahim is a director of EScience Associates, an environmental consultancy specialising in waste and waste recovery, effluent, atmospheric emissions and air quality, as well as cleaner and renewable energy. EScience Associates caters for a diversity of industries and economic sectors and has forged strong relationships with other specialists, and specialist agencies, allowing the company to deal with complex and contentious environmental problems. Abdul Ebrahim holds a BEng (Hons) in both Mechanical and Environmental Engineering disciplines. He specialises in air quality management, hazardous waste management and cleaner production, as well as their related environmental authorisation and licensing processes. His work experience includes numerous environmental impact assessments, cleaner production, waste recover-recuse-recycling, hazardous waste management assessments, and air quality impact management projects in power generation, manufacturing, minerals processing, and mining industries. His interests range from atmospheric modelling and wind energy, to the beneficial use of industrial wastes and effluents. He is a certified Environmental Assessment Practioner (EAP) and member of amongst other professional organisations: Engineering Council of South Africa (ECSA), and the National Association of Clean Air (NACA). Abdul has provided Honours level lecturing at the University of Pretoria, UNISA, Cape Town University of Technology and various private training institutions in the fields of Environmental Compliance Enforcement, Environmental Impact Assessment, Cleaner Production and Air Quality Management since 2005. His work experience includes:
• Environmental strategic, legal, and technical compliance advisory services
• Environmental Permitting - Environmental Authorisation, Waste Management Licensing, Atmospheric Emissions Licensing, Mine Environmental Management Programme development, and their relating environmental impact assessment and stakeholder engagement processes.
• Air quality management and Air Quality Management Plan development – Emissions quantification; meteorological and air quality modelling and impact assessment; development of emissions abatement and management strategies;
• Waste management consulting - classification, landfill assessment, mine residue liner risk assessments, development of waste minimisation treatment & recycling strategies;
• Development of specialist training courses (including EIA Administration and Review, Environmental Enforcement, Environmental Compliance Achievement for Industry).
• Environmental Due Diligence – due diligence assessment to inform purchase or ownership transfer of existing going concerns or proposed new establishments.
Abdul has 20 years post graduate experience of which four years are in industry, and the remainder in consulting.
Education
BEng (Hons) Mechanical Engineering
BEng (Hons) Environmental Engineering
Languages
English (excellent speaking and writing) Limited French and Portuguese
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
Experience
Personal work experience includes:
• Cleaner and renewable energy strategy development, plan and project development;
• Technical and environmental due diligence – industrial and energy projects
• Waste management (classification, handling, storage, and disposal requirements;
• Development of waste minimisation treatment & recycling strategies);
• Air quality management and emissions inventorying¸ development of abatement and management strategies;
• Environmental Impact Assessment and Permitting
• Development and dissemination of specialist training for government and the private sector at NQF level 7 (honours degree).
Abdul’s work experience in a wide diversity of economic sectors and industries and provides him with a good understanding of both small scale and large scale impacts of waste and pollution, as well as keeping up to date with various management alternatives available and their individual advantages and disadvantages, both locally and internationally implemented and pilot scale. Various waste streams have been dealt with to determine the most applicable disposal methods and impacts on the environment, from various industries:
• Metallurgical processes
• Power generation
• Food processing
• Waste recovery, reuse, and recycling and waste to energy
• Mining
• Cement manufacturing
• General Commercial – General waste management from various industries
Professional Registration
Environmental Assessment Practioner (EAP) Engineering Council of South Africa (ECSA
Hourly Rate
Nature of expertise offered
• Ability to interpret and analyse technical material on wide range of subjects
• Engineering expertise in energy, waste, air quality and multi-disciplinary subjects
• Ability to undertake technology feasibility studies, technical and financial due diligence
• Understanding of the green economy and technologies, ICT and agricultural and agro-processing sectors
• Ability to undertake a market research and investigation into the industry
• Proposal evaluation expertise
Experience and relevant projects
1. AIR QUALITY MANAGEMENT:
1.1 Government & Regulatory
o Vaal Triangle Air-shed Priority Area - Air Quality Management Plan review, development of emissions inventory and Ambient Air Quality Impact Assessment.
o Highveld Priority Area Air Quality Management Plan – development of emissions inventory, and mitigation strategies.
▪ Reference: Dr Thulile Mdluli
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
▪ Tel: 012 310 3436
▪ Email : tmdluli@environment.gov.za
o Ekurhuleni Metropolitan Municipality - Development of an Air Quality Management Plan (AQMP)
▪ Reference: Mr Edmund van Wyk
▪ Tel: 011 999 2470
▪ Email: Edmund.vWyk@ekurhuleni.gov.za
o Nkangala District Municipality - Development of an Air Quality Management Plan (AQMP) ▪ Reference: Mr Vusi Mahlangu
▪ Tel: 013 249 2164
▪ Email: Mahlangumv@nkangaladm.gov.za
o North West Province - development of provincial emissions inventory (PM, NOx, SO2 etc)
o Development of National Air Quality Officers Companion Guide for the Republic of South Africa
o Development of the atmospheric emissions licensing department for Nkangala District Municipality
o EThekwini Municipality (Durban) - Greenhouse gas emissions quantification
o Newcastle Local Municipality - Development of an Air Quality Management Plan (AQMP) ▪ Reference: Mr Phelelani Ntshingila
▪ Tel: 034 328 3300
▪ Phelelani.Ntshingila@newcastle.gov.za
1.2 Industrial and Mining
o A large variety of major industrial and mining operation across the Highveld and Vaal Triangle as part of Highveld Priority Area and Vaal Triangle Air-shed Priority Area AQMP projects.
o Lanxess CISA Chrome Chemicals Plant Expansion, CO2 generation, Power Generation and hazardous waste treatment and recovery
o Samancor Chrome Proposed Chrome Chemicals plant
o Karbochem (Synthetic Rubber Manufacture) proposed Power Generation Plant
o PPC Cement Slurry Cement Plant Expansion
o PPC Cement Jupiter Cement Plant Expansion
o PPC Cement PE Cement Plant Expansion
o PPC Cement Dwaalboom waste heat recovery
o PPC Cement De Hoek, PE, Slurry, and Dwaalboom postponement applications
o Afrisam Cement - Dudfield Environmental Management Programme update.
o ClinX Medical Waste Incineration plant expansion
o Goedemoed organic waste incineration
o AWPP pyrolysis of organic waste
o Interwaste Waste Recovery, Waste to Energy and Waste Incineration plant
o Eskom power generation emissions off-setting
o Hayes Lemmerz SA Aluminium Wheel Manufacturing
o Evraz Highveld Steel and Vanadium proposed Powered Generation - Furnace Off-Gases
o Assmang Ferrochrome and Ferromanganese plants Powered Generation - Furnace Off-Gases
o Resource Generation Proposed Boikarabelo Power Station – coal fired
o Weir Minerals Africa (Isando, Alrode and Heavy Bay Foundries)
o Goedemoed Prison proposed Waste incineration and Landfill
o Consolidated Wire Industries Expansion
o Sylvania Proposed Open Cast PGE Mine and Processing Plant
o Assmang Black Rock proposed manganese mine expansion and sinter plant
o Assmang machadodorp proposed smelter plant expansion and cross-over to manganese
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
o Dwarsrivier Chrome Mine
o Nkwe proposed Platinum Mine
o Agricultural Research Commission hazardous and infectious waste incineration
o Sephaku Aganang proposed use of AFR’s in cement manufacture
o Idwala Phalaborwa atmospheric emission licence for magnetite drying
o Mandini Wealth (Pty) Ltd tyre pyrolysis air quality health risk assessment
o Johnson Tiles a Division of Norcros Sa (Pty) Ltd Air quality health risk assessment
o Lanxess CISA (Pty) Ltd Air quality health risk assessment
o Namakwa Sands, South Africa – Tronox
o Devon Valley Landfill expansion
o Groblersdal limestone mine
2. WASTE CLASSIFICATION, HAZARD RISK ASSESSMENT AND MANAGEMENT
o Weir Minerals Africa
o Heavy Bay foundry Port Elizabeth
o Lafarge Gypsum
o Consolidated Wire Industries
o BPB Gypsum
o PG Bison melamine plant
o ABBW Electrical manufacturing plant
o CBI copper and fibre optical cable manufacture
o Holcim Cement
o Lanxess Chrome Chemicals
o Assmang Chrome
o Assmang Manganese
o Hayes Lemmerz SA Aluminium Wheel Manufacturing
o Auto industrial group (Pty) Ltd
o CBI Electrical
o Various mining residues
3. ENVIRONMENTAL IMPACT ASSESSMENT:
o Assmang Black Rock Mine expansions, tailings facilities, water treatment facilities
o Highveld Steel furnace off-gas power generation
o Lanxess CISA chrome chemicals plant expansion and hazardous waste landfilling
o Samancor chrome chemicals plant development
o Hernic Ferrochrome power generation from furnace off-gases
o Kanhym Biogas project
o Alumicor secondary aluminium recovery rotary salt furnaces
o Hays Lemmerz Aluminium smelters, furnace and alloy die casting
o Agricultural Research Commission hazardous waste incineration plant
o Darkling Metal Industries
o Idwala Lime Danielskuil asbestos waste disposal
o Plettenburg Polo Estates
o PG Bison Decorative Panels
o British Aerospace Land Based OMC Systems
o BPB Gypsum phosphogypsum plant
o Extrupet HPDE and PET recycling plants
o Assmang BRMO
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
o Assmang Machadodorp
o Interwaste waste recovery and waste to energy plants
o PPC Cement expansions, electricity generation, use of alternative fuels and resources
o Sephaku cement use of alternative fuels and resources
o ClinX Healthcare Risk Waste Management
o Turfontein Race Course night racing
4. ENVIRONMENTAL LEGAL COMPLIANCE ASSESSMENT & RECTIFICATION PLANNING:
o SASOL Synfuels
o NATCOS Petrochem
o Dwarsrivier Chrome Mine
o Angloplatinum Base Metals Recovery
o Samancor Hotazel Manganese Mines
o PG Bison (Pty) Ltd MDF manufacturing
o Samancor Manganese Division Samancor Metalloys Meyerton
o Holcim SA (Pty) Ltd Cement Plants: ▪ DUDFIELD ▪ ULCO ▪ ROODEPOORT
o Natal Portland Cement Plants: ▪ NEWCASTLE
o Consolidated Wire Industries
o South African Airways (Pty) Ltd Technical Division
o TWK forestry strategic environmental legal compliance assessment
o Inergy Automotive Systems(Pty) Ltd
o Consolidated Wire Industries
o Mittal Steel Vereeninging and Dunswart plants – specialist assistance to DEAT environmental management inspectors
o Assmang Black Rock Mining Operations
o ClinX Medical Waste Management
o Extrupet PET and HDEP recycling plants
o Scaw Metals High Chromium Ball Plant
o Unilever waste recovery, recycling, and zero waste-to-landfill
o Numerous waste recycling facilities
o Oilflow
o The Smart Company
o Darkling Industrial Metals CC
o Unilever waste recovery, recycling, and zero waste-to-landfill
o Central Waste
o AT Packaging
o EWaste Africa
o Mpact Recycling
o Wasteplan
o Fine Metals
o Living Earth
o Industrial Plastic Recyclers
o SA Paper Mills
o Interwaste
o Matchem
o TGS
o Verigreen
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
o SB Boxes
o Drumpal
o Oscars Meat
o FOSECO South Africa (Pty) Ltd
o
5. GREENHOUSE GAS QUANTIFICATIONS AND ASSESSMENTS
o PPC Riebeeck
o Lafarge Licthenburg
o Ilangabi Investments coal mining
o Lanxess CISA (Pty) Ltd
o Consolidated Wire Industries
o ClinX Waste Management
o ArcelorMittal Newcastle
o Development of emission factors for ferrochrome smelting
6. CLEANER PRODUCTION AUDITS, WASTE TO ENERGY, ENERGY RECOVERY, WASTE RECOVERY AND
RELATED PROJECTS:
o Tuffy Plastics
o Proplas plastics
o WHS Distribution
o Premier Foods Pretoria Wheat Mill
o Alfred Nzou municipality
o Lanxess chrome chemicals residue recovery
o Karbochem power generation ash to bricks project
o Cement kilns alternative fuels and raw materials assessment for South Africa
o Kanhym Estates Biogas Generation from piggery effluent
o British American Tobacco:
o Tobacco Processors Zimbabwe
o Souza Cruz Brazil
7. ENVIRONMENTAL MANAGEMENT SYSTEM DEVELOPMENT & IMPLEMENTATION: ▪ British American Tobacco (full system development from scratch – ISO 14001 and ISO 9001)
o Weir Minerals Aspects Identification, Rating, Assessment and Development of EMPs
o Lafarge Gypsum Aspects Identification, Rating, Assessment and Development of EMPs
o Environmental Aspects Identification, rating and formulation of EMPs for Samancor Metalloys Meyerton
o Environmental Aspects Identification, rating and formulation of EMPs for DMS Powders.
o Holcim Slagment development & implementation of EMS components including waste and air quality management
o Holcim Roodepoort development & implementation of EMS components including waste and air quality management
o Consolidated Wire Industries Environmental Aspects Identification, rating and formulation of EMPs and operational control procedures.
o Samancor Metalloys Ferro Silicon Manganese and FerroSilicon production
o DMS FeSi dense media prodcution
8. ISO14001 AUDITING:
o Debswana Orapa and Letlhakane Mines
o Ingwe Colliery
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
o Arnot Colliery
o FOSECO South Africa (Pty) Ltd
o Lafarge Gypsum
o CWI
9. SPECIALIST TRAINING COURSE DEVELOPMENT & PRESENTATION
o 2011 Training of Atmospheric Emissions Licensing Authorities – air quality management, emissions quantification, regulation and enforcement.
o 2007-2015 Training of Authorities for EIA review and permiting
Responsible for development of NEMA EIA Review Course and Administrators EIA Review Manual, theoretical and
practical training material, and training of Government Officials responsible for EIA Review - responsible for the whole
manual other than Law applicable to EIA Review. As at May 2013 approximately 1000 officials from National,
Provincial and Local Government.
o 2005&6 Bridging Training for Environmental Management Inspectors and Enforcement
ESA was part of a consortium selected to develop and conduct the EMI Training. More than 2000 officials and
university students have completed the training.
o University Of Pretoria Specialist Lecturer
- Environmental Legal Compliance inspections and investigations (RSA)
- Environmental Legal Compliance achievement (RSA)
- Environmental Legal Compliance inspections and investigations (Africa)
o University Of South Africa Specialist Lecturer
- Environmental Legal Compliance inspections and investigations (RSA)
o Training for industry and mining
Development and presentation of training material for environmental impact identification and management in terms
of South African environmental law for the SABS and other training institutions.
10. SOIL AND GROUNDWATER CONTAMINATION ASSESSMENT:
o Weir Heavy Bay Foundry
o Lafarge Gypsum
o Kanhym Estates
o SABAT (Pty) Ltd Johannesburg – investigation of heavy metal contamination of soils and groundwater
o Chemiphos SA (Pty) Ltd – investigation of phosphate and heavy metal contamination of soils and groundwater
o Castrol Lubricants Zimbabwe
11. ENVIRONMENTAL DUE DILIGENCE AUDITS, INCLUDING ASSESSMENT OF ENVIRONMENTAL AND CLOSURE LIABILITY:
o Determination and quantification of financial provision for the environmental rehabilitation and closure requirements of smelting operations for Highveld Steel & Vanadium operations:
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
▪ HIGHVELD IRON AND STEEL WORKS ▪ VANCHEM ▪ TRANSALLOYS ▪ RAND CARBIDE ▪ MAPOCHS MINE
o Determination and quantification of financial provision for the environmental rehabilitation and closure requirements of smelting operations for TransAlloys
o Determination and quantification of financial provision for the environmental rehabilitation and closure requirements of mining operations for Samancor Chrome:
▪ MIDDELBURG FERROCHROME ▪ FERROMETALS ▪ TUBATSE FERROCHROME ▪ WESTERN CHROME MINES ▪ EASTERN CHROME MINES
o Determination of critical environmental liability associated with the purchase of Xmeco Foundry by Weir Minerals Africa, and subsequent legal compliance achievement programme
12.
Possible timelines to commit to the assignment
• Available for assignments over the next two years
• Not available during the December holiday period - from 15 December until 3 January – due to company’s closure for the festive season
POSTAL
ADDRESS:
PO Box 2950
Saxonwold
2132
PHYSICAL
ADDRESS:
9 Victoria Street
Oaklands
Johannesburg
WEB STE
www.escience.co.za
TEL:
+27 11 728 2683 Page 1
E MAIL:
zayd@escience.co.za
FAX:
+27 866 106703
CURRICULUM VITAE Zayd Ebrahim
Name Zayd Ebrahim
Date of Birth 25 April 1993
Identity Number 9304256010080
Position Air Quality and GIS Modeller
Qualifications
▪ BSc (Environmental and Geographical Sciences) 2013 – 2017
University of Cape Town
Key Experience
▪ Emissions Inventory Quantification of criteria pollutants and greenhouse gases for
industrial and non-industrial activities.
▪ Dispersion Modelling using the dispersion models Calpuff and Calmet.
▪ Mesoscale Modelling using the Weather Research and Forecast (WRF).
▪ Model Verification using statistics analysis to determine performance of
Calmet/Calpuff/WRF models accuracy.
▪ Air Quality Impact Assessments, providing relevant modelling scenarios as well as
report compiling for AQIAs.
Employment History & Project Experience
Environmental Science Associates 2018 – present
Air Quality and Geographical Information Systems Modeller 2018 - present
Mesoscale modelling and verification
The Weather Research and Forecast Model (WRF) and CALMET
• Verified WRF against surface and upper air measurements
o Wind Speed
• Development of meteorological data for dispersion model for various projects, in
numerous areas across South Africa;
o The Highveld region,
▪ Limpopo
▪ Gauteng
▪ Western Cape
ESCIENCE ASSOCIATES
Zayd Ebrahim
POSTAL
ADDRESS:
PO Box 2950
Saxonwold
2132
PHYSICAL
ADDRESS:
9 Victoria Street
Oaklands
Johannesburg
WEB STE
www.escience.co.za
TEL:
+27 11 728 2683
Page 2 E MAIL:
suzanne@escience.co.za
FAX:
+27 866 106703
Dispersion modelling (CALPUFF) and verification of:
• Point sources (scheduled emitters)
• Area sources
• Roads Emissions from un-tarred roads
• Cumulative scenarios
Point Source Modelling for Industry and Industrial / Mining Development
• PPC Cement Kiln Emissions
• Ezee Tile proposed Sand Drying Facility
• Stellenbosch Municipality Landfill Vents
Road Emissions modelling
• Un-tarred roads for Stellenbosch Municipality Impact Assessment
o Devon Valley Landfill
Air Quality Projects (For further detail and references on VOC related and Ambient Air
Quality Monitoring projects refer to annexure)
Assisted in the following Air Quality Impact Assessments/Reports, responsibilities include;
modelling and/or report writing;
• PPC Cement De Hoek Plant
• PPC Cement Hercules Plant
• PPC Cement Dwaalboom Plant
• PPC Cement Riebeeck Plant
• Mandini Green Proposed Tyre Pyrolysis Plant
• Clinx Waste Management
• Norcross/ Johnson Tiles – VOC ambient air quality investigation
Research Projects
Assisted in the following research projects;
• Long term WRFChem modelling and verification of wet and dry acid deposition
over South Africa, and investigation of impact of power generation stack emission
limits on acid deposition (Water Research Council funded project)
o Responsibilities include;
▪ Weather Research and Forecast Chemistry (WRFChem) modelling
▪ Report and scientific journal compiling
Education
ESCIENCE ASSOCIATES
Zayd Ebrahim
POSTAL
ADDRESS:
PO Box 2950
Saxonwold
2132
PHYSICAL
ADDRESS:
9 Victoria Street
Oaklands
Johannesburg
WEB STE
www.escience.co.za
TEL:
+27 11 728 2683
Page 3 E MAIL:
suzanne@escience.co.za
FAX:
+27 866 106703
University of Cape Town ▪ Bachelor of Science
o Major Courses:
▪ Environmental and Geographical Sciences
▪ Geology
Client name Project name Project Description Year Reference Contact Details
AIR QUALITY PROJECTS
Norcross/ Johnson Tiles
VOC ambient air quality investigation
Air Quality Monitoring of exposure to potentially hazardous gases from external sources using Radielleo diffusive and carbon tube high volume active samplers.
2019 Mr Charl Viljoen
Tel: +27 11 206 9700 Email: charl.viljoen@johnsontiles.co.za
Energy Partners (Pty) Ltd Alrode
Air Quality Impact Assessment Mandini Tyre Pyrolysis Plant, Alrode
Air Quality Impact Assessment including monitoring of VOCs and PAHs from production and tank farm.
2015& 2018
Mr N. Fleischman
Tel: +27 10 176 0950 Email: nick.f@energypartners.co.za
City of Ekurhuleni
Review of Municipal Air Quality Management Plan (2015 and 2020)
Emissions quantification, air pollution dispersion modelling, identification of hot spots, ambient air quality and emissions management strategies, municipal capacity review, and development of an AQMP implementation plan.
2015& 2020
Mr Edmund van Wyk
Tel: + 27 11 999 2740 Email: edmund.vanwyk@ekurhuleni.gov.za
Page 1 of 2
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Sam Leyde
Surname: Leyde
Name: Sam
Date of birth: 25 November 1985
Nationality: RSA
Position: Environmental Consultant
Key Qualifications: BSc(hons) Mechanical Engineering
Contact details
: 011 7186380
: sam@escience.co.za
Abstract
Sam Leyde is an employee of EScience Associates, an environmental consultancy specialising in waste and waste recovery, effluent, atmospheric emissions and air quality, as well as cleaner and renewable energy. EScience Associates caters for a diversity of industries and economic sectors and has forged strong relationships with other specialists, and specialist agencies, allowing the company to deal with complex and contentious environmental problems. Sam Leyde holds a BSc (Hons) in Mechanical Engineering. He specialises environmental authorisation and licensing processes. His work experience includes numerous environmental impact assessments, , waste recover-recuse-recycling, waste disposal and classification assessments, and air quality impact management projects in the manufacturing sector. Sam has 8 years post graduate experience of which 7 years are in industry, and the remainder in engineering.
Education
BSc (Hons) Mechanical Engineering
Languages
English (excellent speaking and writing)
Experience
Personal work experience includes:
• Environmental Authorisation, Waste Management Licensing, Atmospheric Emissions Licensing, Environmental Management Programme development, and their relating environmental impact assessment and stakeholder engagement processes.
• Waste management (classification, handling, storage, and disposal requirements, development of waste minimisation treatment & recycling strategies);
• Air Quality Impact Assessments;
• External Environmental Auditing – due diligence assessment to inform purchase or ownership transfer of existing going concerns or proposed new establishments.
Experience and relevant projects
1. ENVIRONMENTAL IMPACT ASSESSMENT:
o EIA for Sephaku Aganang proposed use of AFR’s in cement manufacture
o EIA for PPC Cement Slurry Cement Plant Expansion
o Extrupet HPDE and PET recycling plants
o Assmang Machadodorp Reverse Osmosis Plant and Stormwater Upgrades;
o Interwaste Waste Recovery and Waste to Energy Plant
o ClinX Healthcare Risk Waste Management
Page 2 of 2
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Sam Leyde
Experience and relevant projects
o EIA for proposed Refuse Derived Fuel Energy Recovery Facility, Athlone, Cape Town;
o EIA for proposed pyrolysis of organic/abattoir waste – Square Root Trading Seven, Kroonstad;
o EIA for Interwaste proposed Waste to Energy and Waste Incineration plant;
o EIA Sylvania Proposed Open Cast PGE Mine and Processing Plant;
o EIA for Assmang Machadodorp proposed water treatment plant;
o Basic Assessment for Assmang Machadodorp Storm Water management upgrades;
o Water Use License Application for Assmang Machadodorp Storm Water management upgrades and water treatment facility;
o Water Use Licence for SA Dorper Leather Tannery;
o Oilflow oil blending facility
o The Smart Company Copper melting facility
o Darkling Industrial Metals CC – Scrap Metal Recovery Facility
2. ENVIRONMENTAL LEGAL COMPLIANCE AUDITING & RECTIFICATION PLANNING:
o FFS Refiners, Storage facility Evander 2013 and 2019
o Assmang Black Rock Mining Operations
o ClinX Medical Waste Management
o Extrupet PET and HDEP recycling plants
o Scaw Metals High Chromium Ball Plant
o Oilflow oil blending facility
o The Smart Company Copper melting facility
o Darkling Industrial Metals CC – Scrap Metal Recovery Facility
3. AIR QUALITY MANAGEMENT:
o AQIA for Sephaku Aganang proposed use of AFR’s in cement manufacture
o AQIA for PPC Cement Slurry Cement Plant Expansion
o Lanxess CISA Chrome Chemicals Plant Expansion, CO2 generation, Power Generation and hazardous waste treatment and recovery
o ClinX Medical Waste Incineration plant expansion
o Interwaste Waste Recovery, Waste to Energy and Waste Incineration plant
o Weir Minerals Africa (Isando, Alrode and Heavy Bay Foundries)
o Sylvania Proposed Open Cast PGE Mine and Processing Plant
o Agricultural Research Commission hazardous and infectious waste incineration
o Johnson Tiles a Division of Norcros Sa (Pty) Ltd Air quality health risk assessment
o Proposed pyrolysis of organic/abattoir waste – Square Root Trading Seven, Kroonstad;
4. WASTE CLASSIFICATION, HAZARD RISK ASSESSMENT AND MANAGEMENT
o Weir Minerals Africa
o Wispeco Aluminium
DRAFT BASIC ASSESSMENT REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 122
APPENDIX 4.2: ARCHAEOLOGICAL AND CULTURAL HERITAGE SCREENING
ASSESSMENT
Archaeological Impact Assessment for IGE
Solutions’ Proposed Waste Treatment
Facility, Limeroc Business Park, Farm No.
385 Knopjeslaagte, Centurion, Gauteng
Province
Phase 1 Archaeological Impact Assessment
Prepared by:
Drs Matt Lotter1 and Tim Forssman2
1Association of Southern African Professional Archaeologists, Professional Member 339 with
CRM accreditation 2Association of Southern African Professional Archaeologists, Professional Member 307 with
CRM accreditation
Prepared for:
EScience Associates (Pty) Ltd
PO Box 2950, Saxonwold, 2132
9 Victoria Street, Oaklands, Johannesburg, 2192
VAT No: 473 025 4416
Reg No: 2009/014407/07
First draft: 20 July 2020
Second draft: 24 July 2020
Final draft: 4 Aug 2020
Declaration of Independence
The report has been compiled by Drs Matt Lotter and Tim Forssman acting as heritage
specialists. The results expressed in this report have been collected using standard
archaeological procedures and are objective. The authors declare no other conflicting interests
in this report.
Signed:
Dr Matt Lotter Dr Tim Forssman
1
This document has been prepared by:
Dr Matt Lotter
Association of Southern African Professional Archaeologists, Professional Member 339 with
CRM accreditation
+27732119832 (cell); mattlotter@gmail.com (email)
and
Dr Tim Forssman
Association of Southern African Professional Archaeologists, Professional Member 307 with
CRM accreditation
+27784224828 (cell); tim.forssman@gmail.com (email)
Both authors were responsible for draft report compilation, archaeological fieldwork and report
compilation.
Signed:
Dr Matt Lotter Dr Tim Forssman
2
List of acronyms
AIA Archaeological Impact Assessment
EIA Environmental Impact Assessment
ESA Earlier Stone Age
MSA Middle Stone Age
POI Point of Interest
LSA Later Stone Age
Glossary of terms
Find / Find spot Either term is used to refer to an isolated find, a single artefact or item of cultural heritage. These may be significant but are not considered sites.
Site An accumulation of cultural heritage, domestic remains or other human traces of human activity. It is a term used to refer to any area of this nature from very small (a few finds spatially associated with one another) to large and obvious residential or activity areas.
3
Executive Summary
Introduction
EScience Associates (Pty) Ltd contracted Drs Matt Lotter and Tim Forssman to perform an
Archaeological Impact Assessment on two areas of land on Farm Number 385 Knopjeslaagte,
within the Limeroc Business Park in Centurion, for the proposed development of a waste
treatment facility by IGE Solutions.
Methods
The relevant portions of land were investigated on foot for any surface traces of cultural
heritage. Where excavations had taken place on the property, these and their spoil heaps were
also examined for any heritage traces. All finds or sites were recorded following standard
archaeological procedures. A specially designed site recording form was used to notate any
observable traits, including cultural heritage types, deposit information and assemblage or site
context, and this was graded following a set rating criteria. All survey routes were GPS recorded
and every find was photographed along with the landscape.
Results
The survey identified several factors that might have disturbed any archaeological remains,
such as surface clearings, sporadic spoil stockpiles associated with construction and clearing
activities underway within the Limeroc Business Park, and vehicle traffic. However, no tangible
cultural heritage was found in either the preferred or alternative development locations.
Conclusions
It is anticipated that development will have no impact on cultural heritage in the proposed
development areas and no recommendations are put forward. Nonetheless, there may still be
cultural heritage subsurface that was not observable or inferable from surface finds, as is
always the case. Should any cultural heritage be observed once development commences, a
specialist must be consulted to perform an examination of the finds.
4
Table of Contents
1. Introduction
a. Scope of the study
b. Project description
c. Specialist expertise
d. South African legislation
2. Archaeological and historical background: desktop study
a. Overview of the local archaeological sequence
i. Stone Age
ii. Iron Age
iii. Colonial period
b. Archaeology and history of the study area and surrounds
c. Database consultation
3. Materials and methods
a. Site location and description
b. Study methods
i. Archival study: background literature review
ii. Site visit and survey
iii. Reporting
c. Constraints and limitations
4. Results and discussion
5. Development impact and proposed mitigation
a. Development impact
b. Recommendations
6. Conclusions
7. References
5
List of Figures
Figure 1: The distribution of Acheulean sites in South Africa (from Lotter & Kuman 2018: 44).
Figure 2: The appearance of farmer communities (Bantu-language speaking groups) in southern
Africa (from Huffman 2007: 336).
Figure 3: A depiction of Simon van der Stel’s Vergelegen compound with the surrounding lodges
(from Markell et al. 1995: 14).
Figure 4: Principle gold and silver mines in the Gauteng region (from Reeks 2012: xvi).
Figure 5: Google Earth map showing the study area: The study area’s context within Gauteng
(A; red circle=site location), Pretoria, Johannesburg and Centurion (B; white arrow pointing
towards Limeroc Business Park, which is outlined in green) and Diepsloot (C; showing Business
Park boundary and the two proposed development locations which are shown by the opaque
green polygons) and a bird’s eye view of the study area itself (D; with preferred and alternative
development locations indicated).
Figure 6: Survey tracklog indicated in red while the green polygons demarcate the development
area boundaries (A). The alternative development area to the west (B) and the preferred
development area to the east (C) are also indicated.
Figure 7: Various images of the preferred location looking southwest (A), east (B), southeast (C)
and south (D). All the images show the impact of surface clearing and vehicle traffic (save for
D), which may have impacted tangible cultural material if it was present.
Figure 8: Various images of the alternative development location. This flat parcel of land has a
gravel road and stockpiled sediment along its northwestern boundary (A). Natural quartz
geofacts (chucks) are frequently found at the surface (B; scale=10cm). General views of this
location (C and D) and additional surface disturbances (E) are also indicated.
List of Tables
Table 1: The Stone Age in southern Africa (from Lombard et al. 2012: 125).
6
1. Introduction
a. Scope of the study
EScience Associates (Pty) Ltd was appointed to conduct an Environmental Impact Assessment
(EIA) for a proposed waste treatment facility on portions 109, 111 and 331 of Farm Number 385
Knopjeslaagte in the Limeroc Business Park, Centurion, for IGE Solutions. Drs Matt Lotter and
Tim Forssman were subsequently appointed by EScience Associates to perform an
Archaeological Impact Assessment (AIA) of the proposed area, and the relevant portions of land
were examined.
b. Project description
The AIA covers all portions of the proposed development. The aim of the study was to identify
any tangible cultural heritage present on the land and assess its importance and establish
mitigation factors should an identified site or archaeological feature be at risk of destruction or
damage. To do so, a survey was performed recording and grading all surface remains.
Recording was performed following a standard record form. From these data, finds and sites
were graded based on the rating criteria, which includes various conditions. This follows
standard archaeological procedures.
c. Specialist expertise
Dr Matt Lotter has undertaken extensive and in-depth research at several Stone Age, Iron Age
and rock art localities around southern Africa, as well as internationally in China, Lesotho and
Botswana. He has been involved in a number of Phase 1 Heritage and Archaeological Impact
Assessments as well as Phase 2 mitigations. He has also published several scientific articles with
a focus on Earlier Stone Age technologies and geoarchaeological landscape evolution. He is
registered with the Association of Southern African Professional Archaeologists (ASAPA, ID
339).
Dr. Tim Forssman has undertaken extensive and in-depth research at several Stone Age, Iron
Age and rock art localities around southern Africa. He has been involved in a number of Phase 1
Heritage and Archaeological Impact Assessments as well as Phase 2 mitigations. He was the
Project Leader on the Polihali Project for a year, overseeing the mitigation of 12 Stone Age sites
and coordinating several specialists in the Stone Age, rock art, Iron Age and Intangible Cultural
Heritage fields. He has also published several scientific articles with a focus on the Later Stone
Age, Iron Age, rock art and archaeological methods. He is registered with the Association of
Southern African Professional Archaeologists (ASAPA, ID 307).
7
d. South African legislation
South African legislation (NHRA) dictates that any item of cultural heritage may not be
disturbed, interfered with, or destroyed without authorisation from a heritage authority.
Following Nema (No 107 of 1998; 23: 2(b)), one should “...identify, predict and evaluate the
actual potential impact on the environment, socio-economic conditions and cultural heritage”.
A specialist is required to perform the correct and appropriate identification, evaluating and
assessing of cultural heritage significance following a rating criteria. Requiring and governing
this assessment is the following South African legislation:
i. National Environmental Management Act (NEMA) Act 107 of 1998
ii. National Heritage Resources Act (NHRA) Act 25 of 1999
iii. Minerals and Petroleum Resources Development Act (MPRDA) Act 28 of 2002
iv. Development Facilitation Act (DFA) Act 67 of 1995
In each Act, the following sections are applicable in terms of the identification, evaluation and
assessment of cultural heritage resources:
i. National Environmental Management Act (NEMA) Act 107 of 1998:
a. Basic Environmental Assessment (BEA) – Section (23)(2)(d);
b. Environmental Scoping Report (ESR) – Section (29)(1)(d);
c. Environmental Impacts Assessment (EIA) – Section (32)(2)(d); and,
d. EMP (EMP) – Section (34)(b).
ii. National Heritage Resources Act (NHRA) Act 25 of 1999:
a. Protected Areas – Section 28;
b. Protection of Heritage Resources – Sections 34 to 36; and,
c. Heritage Resources Management – Section 38.
iii. Minerals and Petroleum Resources Development Act (MPRDA) Act 28 of 2002:
a. Section 39(3).
8
2. Archaeological and historical background: desktop study
a. Overview of the local archaeological sequence
Southern Africa has a lengthy archaeological sequence spanning approximately the last two
million years. This has been conveniently separated into ‘Ages’, which themselves are further
divided. While there are many issues with doing so, it provides a useful gauge for
understanding different techno-complexes, periods, and cultural sequences. We follow this
same categorisation here.
i. Stone Age
The Stone Age is composed of three divisions, which are further subdivided (Table 1). These
primary divisions are the Earlier, Middle and Later Stone Ages. In southern Africa, the Earlier
Stone Age (ESA) begins at approximately 2.1 million years ago. Early tools, which are ascribed to
the Oldowan Industry, are large tools most often made from locally available raw materials.
Tool form is not yet standardised and artefacts generally retain a limited number of flake
removals, which are struck off using a hammerstone (Kuman 2014). The Oldowan is followed by
the Acheulean Industry, from c. 1.75 to 0.3 million years ago, which is characterised by the
occurrences of handaxes and cleavers, although this is probably over-emphasised since some
Acheulean assemblages lack these. While a number of sites are known in southern Africa, they
are fairly scarce (Figure 1) (Lotter & Kuman 2018).
The Middle Stone Age (MSA) follows and begins between 300 and 250 thousand years ago and
gradually disappears between 40 and 20 thousand years ago. Assemblages older than 130
thousand years are rare, and from this time onwards more MSA sites are known. Assemblages
from these sites are generally thought to be characterised by blade technology, prepared cores,
formal tools exhibiting secondary retouch and a range of ornaments, jewellery and symbolic
devices, such as engraved ochre slabs. It must be noted that there is variability between regions
and time periods from 130 thousand years ago and the period has been divided into several
phases. Notably, the Howieson’s Poort Industry is one that is marked by smaller formal tools
and segmented artefacts; it is a unique development and an early example of what came to
characterise the following Later Stone Age (LSA). Assemblages dating between c. 100 and 50
thousand years ago are generally thought to possess cultural traits that indicate the appearance
of modern thought or cognition, sometimes called complexity (Wadley 2015).
9
Table 1: The Stone Age in southern Africa (from Lombard et al. 2012: 125).
Figure 1: The distribution of Acheulean sites >0.5 million years in South Africa (from Lotter &
Kuman 2018: 44).
10
The LSA is the final Age and begins during the transition from the MSA between 40 and 20
thousand years ago. This early period, though, is characterised by considerable variability that
only gives way to a regionally standardised toolkit from after 20 thousand years ago. Small
bladelets characterised this initial phase, which, around 12 thousand years ago, was replaced by
a larger tool industry characterised by scrapers and adzes. Following this, the Wilton arose
around eight thousand years ago and represents a highly standardised period of scraper,
backed tool and adze production, although several phases are known, and includes a wide
range of ornaments, jewellery, bone tools and rock art (Lombard et al. 2012). LSA-producing
foragers, or hunter-gatherers, lived in almost every landscape in southern Africa and are
represented today by Bushman or San communities (Mitchell 2002). 1
Rock art was produced by many communities, but the best known is the rock art of
hunter-gatherers who were also the producers of the LSA. The art typically captures trance
experiences, which is when a shaman enters the spirit world through a trance dance. While in
it, he or she will heal the sick, control game, ward off evil spirits and travel to neighbours or to
God’s village, as well as perform other tasks. Rock art generally depicts these scenes as well as
folklore and mythology (Forssman & Gutteridge 2012). Khoekhoe herders had their own
painting tradition, which is less well-understood, although at least some of it relates to girls’
initiation. Bantu-language speaking groups also painted and generally their depictions are to do
with initiation and conflict during the colonial era (Mitchell 2002). While their art is fairly
well-studied, it is their occupation sequence of southern Africa that has dominated Iron Age
research.
ii. Iron Age
Iron Age farmers began arriving in southern Africa little more than two thousand years ago. This
was initially from Angola, through southern Zambia, the Caprivi Strip in Namibia, northern
Zimbabwe and Botswana to settle in the central southern African region (Figure 2). Early
settlements just north of the Limpopo River date to around AD 200. Soon afterwards, they
entered what is now South Africa (Mitchell & Whitelaw 2005).
The most significant developments that occurred in the southern African region, at least at first,
were those that began around AD 900 in northern South Africa. Here, farmers began
exchanging local trade wealth for exotic items like glass beads from the Mozambique coastline
where travelling merchants from the north based themselves. These items supported the local
1 The terms Bushman and San have been used derogatorily in the past. Modern communities who draw their identity from present and past hunter-gatherers have requested that these terms be used to identify them when not referring to language groups. We do so here with the utmost respect and do not invoke any pejorative connotations.
11
growth of wealth, which was initially based on cattle and on locally sourced value items. This
growth led to the beginning of elite communities based at what came to be prominent
settlements. These then developed into political centres where social stratification appeared.
Around AD 1220, these developments, along with several others, resulted in the establishment
of Mapungubwe, southern Africa’s first state-level society. When it declined, around AD 1300,
Great Zimbabwe rose to prominence, which was succeeded by Khami and Thulamela (Huffman
2009). Although this gives the impression of a fairly straight-forward developmental process, it
was in fact fairly heterogeneous.
Figure 2: The appearance of farmer communities (Bantu-language speaking groups) in southern
Africa (from Huffman 2007: 336).
12
Around the mid-second millennium AD, groups from the north, known by their ceramics called
Ntsuanatsatsi, moved south into the North-West Province region. Here they established
political control, around AD 1450 to 1500, and became the Tswana empire. These communities
established massive urban centres, some over 3km in length, with complex political authorities
(Pistorius 1994). Many are known through missionary and traveller accounts, such as those
from William Burchell or Robert Moffatt in the 1800s, who encountered these capitals. The
Tswana polity, which was made up of several totems, spread as far as modern-day Gauteng
where they encountered Pedi, eSwati and Zulu communities (Sadr 2019).
Sometime between the 1810s and 1830s, the Difaqane (Sotho) or Mfecane (Zulu/Xhosa) took
place. This was a period marked by conflict, raiding, food insecurity, and warfare. Although
having its origins largely in KwaZulu-Natal, its impact was felt through-out much of eastern
southern Africa and further north. At this time, different Zulu groups were covering vast regions
and attacking settlements and villages taking resources, food, slaves and livestock. Some were
driven as far north as Uganda. The impact of the conflict resulted in new settlement patterns,
large-scale movements of people, and critical shortages of subsistence resources. It marked a
tumultuous period in southern Africa’s prehistory with the likely death of many thousands of
people (Wright 1989).
The Iron Age is a notably diverse and complex period. Many different identities interacted,
traded, fought, created alliances, and intermixed during this period. Thorough reviews exist but
are not necessary in the context of this report; only some key events or histories have been
discussed above (e.g. Huffman 2007). During this period, not only were farmer communities
living in the region and meeting one another, but foragers and herders were also present.
These three different communities had regular encounters that caused significant changes in
one another’s lifeways. The Iron Age also overlaps with the entire colonial period; even today
many people practice a subsistence-based farming much as they did in the past. In the
extended region, Iron Age settlements are located in the Magaliesburg and Rustenburg areas
(Huffman 2002) and further west in the Cradle of Humankind.
iii. Colonial period
Prior to the Dutch establishing a refreshment station in what is now the Western Cape in 1652,
Portuguese traders and travellers had made contact with local communities. Trading along
almost the entirety of southern Africa’s coastline for supplies and what to them was exotica,
they encountered many of the communities mentioned in the text here. Their interactions
included often detailed note taking and mapping of certain regions, which are hugely valuable
to this day in terms of understanding the local social landscape. For example, their accounts of
Sofala are highly valuable since this immensely influential trading post on the Mozambique
13
coastline has not been re-discovered. The Portuguese and also Arabic records are all we have of
its existence and role in local economies (Wood 2000). From the settlement of the Western
Cape, though, the influence of European colonisation was increasingly felt.
Settlement progressed slowly through southern Africa. At first, it was restricted to the fairly
amicable Cape region with missionaries, travellers, biologists and explorers travelling inland.
Contact with local herders and foragers was regular and there is evidence of some living or
trading regularly with forts and outposts (Schrire 2014). Slaves were also taken and at some of
the more prominent farms, such as Simon van der Stel’s Vergelegen, a slave lodge was
uncovered (Figure 3) (Markell et al. 1995). Interactions with local communities were highly
nuanced and variable.
Figure 3: A depiction of Simon van der Stel’s Vergelegen compound with the surrounding lodges
(from Markell et al. 1995: 14).
The British took control of the Cape Colony in 1795 after the Battle of Muizenberg. This began a
process of social disintegration with many European locals unwilling to contribute to the British
14
government and crown (although from 1803 to 1806 the Dutch regained authority
temporarily). The end result was the Great Trek. In 1832, Dr Andrew Smith and William Berg, an
Englishman and a Boer, set-off on an early exploratory trek along the coast towards what is
now KwaZulu-Natal. On returning, they convinced Boer leaders of the potential the land held
for farming, livestock and settlement. After a larger exploratory trek in 1834, the first wave of
trekkers left in 1835 followed in 1836 by more. About 6000 people in total left on the trek led
by now historically recognised figures such as Louis Tregerdt, Hans van Renburg and Hendrik
Potgieter, among others. This led to the widespread settlement of Boers and others in the
eastern and northern territories of South Africa, as well as conflicts with the Matabele and Zulu;
a notable battle was held at the contested Ncome/Blood River site (Ngobese & Mukhuba 2018).
In the late 1800s, when the Zuid Afrika Republic and Oranje Vrijstaat (Orange Free State) states
had been established, gold was discovered in the Transvaal (d. 1886). By this time, uitlanders
(European foreigners) were living among the local Boer community and working in
Johannesburg and Pretoria as well as paying taxes, for which they received less than the local
Boers. Tension between the British and Boer states arose. With the discovery of gold the British
saw it fit to attempt to take over the two states in order to protect their people living under
Boer rule and also to thwart a German attempt at taking control of large parts of Africa. While
this is hotly contested, and an over-simplification, it contributed to the South African War
(formerly Boer War) from 1899 to 1902. The war ultimately claimed the lives of probably over
50,000 Boer and black (from several communities) people as well as many British soldiers and
those from the colonies. The Boer’s ceded in May 1902 and the British formed the South
African Republic. Boers continued living in the new republic although many resisted and wished
to continue fighting. If it were not for the work of Jan Smuts and others, persistent warfare and
angst may have continued (Judd & Surridge 2013).
While southern African archaeology and history is a complex matter, what is presented here is
an overview and somewhat narrow summary of certain key events in the region’s prehistory
before about 1900. For a thorough review, see Mitchell (2002).
b. Archaeology and history of the study area and surrounds
Both ESA and MSA assemblages are known in the wider region, nearer Pretoria, but few LSA
sites have been investigated. The former two Stone Ages have been identified at several
locations in the Cradle of Humankind (Lombard et al. 2012), which is also where the nearest LSA
sites have been studied (Wadley 1989). However, with regard to ESA traces, Mason (1962)
investigated a number of nearby sites including in Wonderboom, approximately 30km
northeast of the development area. Some of the sites he investigated have yielded large and
impressive assemblages that may provide significant insights into the local Stone Age sequence.
15
It is conceivable that other areas in this region also contain impressive Stone Age assemblages.
No rock art is known of in the vicinity around Pretoria or Centurion, and the nearest site that
has received research attention is near Bronkhorstspruit (Forssman & Louw 2018).
The history of the Gauteng region is dominated by a single event; the discovery of gold in 1886.
The succeeding South African War was very much linked to the industry that developed after
the initial identification of gold reserves. Soon after its discovery, many individuals and
enterprises sought to gain their riches through gold mining activities. This is often termed ‘The
Gold Rush’. It led to a great influx of people into the Zuid Afrika Republic including many
European foreigners, and eventually led to British interference (Judd & Surridge 2013).
However, it was later realised that not only was gold available, but also many other minerals
and resources. Mining developed into a massive industry in the early 1900s and still is to this
day.
In the vicinity of Pretoria, silver was mined. Soon after ‘The Gold Rush’, silver mining began in
various areas. However, the market for silver varied from that of gold, which was far more
valuable and stable. Silver mining, for this reason, fluctuated between 1885 and the
mid-twentieth century. Reserves were found in many areas of eastern Pretoria and silver veins
extended throughout the wider region allowing mines to be set up in a number of locations
(Figure 4). Silverton, for example, was named as such because of the cluster of mines known in
the area. These mines largely belonged to prominent Randlords and businessmen and some
became their residential areas, such as at The Willows (Reeks 2012).
The potential for there being remains from any one of these periods or events in the Centurion
area, or within the proposed development area, exists. Moreover, the presence of Iron Age
people in the extended region and the Stone Age traces found in the Pretoria area, at sites such
as Wonderboom, make the possibility of finding these traces also high. However, based on
reports from the immediate area, the local preservation of these traces is unlikely.
16
Figure 4: Principle gold and silver mines in the Gauteng region (from Reeks 2012: xvi).
a. Database consulted
The South African Heritage and Resources Agency’s (SAHRA) online database, SAHRIS, was
consulted. Several reports from the vicinity were examined and these include impact
assessments, scoping reports and basic assessments. It should be noted that these reports are
generally from within 10km of the Limeroc Business Park, but studies from areas beyond this,
which are numerous, are only included here when they provide a significant contribution to this
assessment. Of greatest relevance though are two Phase 1 Heritage Impact Assessments that
were completed on the property in 2017, within the Limeroc Business Park boundary.
These assessments comprised part of portion 109 and a part of the remainder of portion 331
(Marais-Botes 2017a), and portion 111 (Marais-Botes 2017b). For the former (Marais-Botes
2017a), the survey was required prior to the proposed Peach Tree X 23 Development, which
would consist of a Light Industrial Township. Farming and previous infrastructural
developments were noted to have affected the two property portions, and no tangible or
intangible heritage sites were identified. Similarly, for the latter (Marais-Botes 2017b), a survey
was required prior to the proposed Industrial Extension 1 and 2 for the Peach Tree X 25
17
Development, during which it was also noted that the survey area was disturbed in a similar
fashion to the other portions (i.e., previous farming and infrastructure activities). No tangible or
intangible heritage sites were identified on portion 111 (Marais-Botes 2017b).
On the southern boundary of the N14 and located a short distance away from the Limeroc
Business Park, an 89ha portion of the Farm Diepsloot 388JR was surveyed ahead of
development. No archaeological or heritage traces were recorded but a single mud-stone
multi-room building was identified. It was recorded and no further recommendations for any
preservation or mitigation were made (Coetzee 2008). Given the close proximity of this survey
area and its archaeological sparseness, this supports the results contained in this report.
Beyond this, stretching in a south to southeastern arc and at its furthest point 7.7km away from
the development area, is the Lulamisa-Diepsloot East-Blue Hills-Crowthorne 88kV powerline. A
heritage assessment along this powerline resulted in no finds of any significance. Although this
survey examined only the development area and a buffer around it in a transect-like survey
design, thus missing large portions of the landscape with high occupation or activity potential, it
does provide insight into the localised distribution of heritage resources in the area (van
Schalkwyk 2018).
Archaeology Africa conducted a Phase 1 survey of the Cedar Park Development in Portions 5
and 64 of Bultfontein 533JQ, 9.5km southwest of the proposed development area (along the
N14). Four sites were identified: a cemetery and three historic multi-component sites, which
may also contain graves. It was recommended that the sites be preserved or mitigated should
they be impacted (Birkholtz 2007). As of 16 July 2020, it appears that development has not
been initiated.
Directly west, in the Blair Atholl Country Estate (12.2km), an archaeological assessment
identified Earlier and Middle Stone Age tools in a secondary/disturbed context. The area also
contained two stone-walled kraals from the last c. 500 years. None of these finds were
recommended for mitigation (van Schalkwyk 2004).
The National Cultural History Museum have conducted several surveys in the immediate and
extended region of the proposed development area. On the Farm Olifantsfontein 410JR in
Midrand, approximately 13km southeast, 14 sites were identified, all of which would be
impacted by developments. Here, it was noted that streams and rivers were used during Stone
Age times (van Schalkwyk 2002a). If a local trend, it might indicate that an area of concern
would be the watercourse to the east of the Business Park, which is not on the premises.
Nonetheless, any settlement nearby might have utilised a portion of the Farm Number 385
Knopjeslaagte.
18
Approximately 5km southwest from the Olifantsfontein Farm, the National Cultural History
Museum also surveyed an area of the Zonk’izizwe Property alongside the Grand Central Airport,
Midrand. No pre-colonial cultural remains were noted, but a racetrack with grandstands was
recorded and was not recommended for mitigation (van Schalkwyk 2007).
The following reports were consulted but none identified any archaeological or heritage
remains (arranged from nearest to furthest; approximate distances in parenthesis are from the
proposed development area, followed by direction):
● A survey of cultural resources for Laezonia, Centurion (van Schalkwyk 2002b): 1-4km,
west.
● Basic Cultural Heritage Assessment for the proposed Diepsloot East Power Line and new
substation, Gauteng Province (van Schalkwyk 2013a): 3.2km, southeast.
● Scoping report for the aggregate and sand mining right application by Carocode (Pty)
Ltd. (Isowel Trading and Project (Pty) Ltd. 2017): 4.2km, west (this is a scoping report
and an Archaeological Impact Assessment is forthcoming).
● Archaeological survey of Blue Hills Farm, Midrand (Huffman 1999): 6.2km, southeast.
● Basic Cultural Heritage Assessment for the proposed bulk water supply pipeline
between Lanseria and Cosmos City, Gauteng Province (van Schalkwyk 2013b): 15km,
southwest.
Based on this review of the available reports on SAHRIS, it appears that there are heritage
remains in the area and these include pre-colonial material culture and historic activities, such
as farming, track racing and other developments, as well as Earlier and Middle Stone Age tools
in the wider area. However, of the identified tangible cultural heritage, only a small proportion
has been recommended for preservation or mitigation and this is mostly when graves are
involved.
19
2. Materials and methods
a. Site location and description
The proposed waste treatment facility is currently earmarked for portions 109, 111 and 331 of
Farm Number 385 Knopjeslaagte, within the Limeroc Business Park, which is located in
Centurion and within the Tshwane Municipality (Figure 5). South of the proposed development
area is the N14 Highway and beyond this is Timsrand. To the west is the R511 and Laezonia and
east is Knoppieslaagte. Forming the northern boundary is the R114 (25° 54’ 19” S; 28° 02’ 05” E)
(Figure 5). Two specific development areas have been proposed, one of which is in the eastern
(25° 54’ 12” S; 28° 02’ 16” E, co-ordinates approximately from the centre of the development
area) and the other is in the western (25° 54’ 22” S; 28° 01’ 48” E) portion of the property. The
eastern portion is the preferred location (portion 111 of Farm Number 385 Knopjeslaagte) and
the western area is the alternative location (portions 109 and 331 of Farm Number 385
Knopjeslaagte; referred to as such henceforth).
Figure 5: Google Earth map showing the study area: The study area’s context within Gauteng
(A; red circle=site location), Pretoria, Johannesburg and Centurion (B; white arrow pointing
towards Limeroc Business Park, which is outlined in green) and Diepsloot (C; showing Business
Park boundary and the two proposed development locations which are shown by the opaque
green polygons) and a bird’s eye view of the study area itself (D; with preferred and alternative
development locations indicated).
20
The preferred development area (approximately 0.9ha) occurs towards the east of the Business
Park on gently sloping land that continues down towards a nearby drainage line (beyond the
Business Park perimeter boundary). This area is extensively modified and contains minimal
surface vegetation (sporadic clumps of grass along the boundaries) and un-modified (natural)
surface sediments. The area is currently a high-traffic zone due to nearby construction
activities.
The alternative development area to the west is approximately 0.6ha and comprises an open,
flat landscape that is covered in short grasses and occasional trees. The northern boundary
comprises a gravel road, stockpiled sediments and some associated shallow diggings. In the
central area, sporadic trees are clustered together around which there are other minor surface
disturbances and some sporadic associated debris.
b. Study methods
i. Archival study: background literature review
An archival and heritage desktop study was performed. Literary sources from previous
archaeological, anthropological and historical studies from the region were consulted, as well as
previous impact assessment from the area. The results from this study are presented in Section
2: Archaeological and Historical Background: desktop study.
ii. Site visit and survey
The site visit was conducted by Dr Matt Lotter on Tuesday, July 14th, 2020. This involved a foot
survey across the property as indicated by supplied location information (within both of the
relevant proposed delineations). A systematic sampling method was employed during the
survey, in which high profile areas and areas most likely to contain preserved archaeology were
visited. All archaeological occurrences were sufficiently recorded, photographed and described
and a GPS (Garmin 64s) was used to record the surveyed tracks.
The following equipment was utilised during the field assessment:
● Garmin GPS 64s
● Canon D70 DSLR camera
● Samsung Note tablet
● Field journal and stationery
● Photographic scales
● Compass
21
● Cellular telephones
● Tape measures
To record heritage remains, a standard site recording form designed by the consultants was
relied on in order to ensure consistency. This form records: location, site and deposit context,
human and animal interference, cultural material, chronological markers, deposit depth and
cultural material diversity. From this, each recording is provided a grading which is then
combined to generate an overall site rating out of 10. Sites above six are considered important
and assessed further in order to determine what mitigation, if any, is required.
Points of interest (POI) were also recorded. These are locations that have some item of interest,
although in the case of this report, these did not have any cultural heritage significance.
iii. Reporting
All finds are reported herein. Every detail recorded in the site recording form is presented along
with the location of the find or site and photographs, where applicable. The results from the
grading assessment, with their justification, are also presented alongside the find or site data.
In cases where no finds or sites are made, such an assessment is not provided.
c. Constraints and limitations
As listed in 4. Results and discussion (below), several factors have contributed to the potential
disturbance of archaeological remains, namely: surface clearings, sporadic spoil stockpiles
associated with construction and clearing activities underway within the Limeroc Business Park,
and vehicle traffic. The gravel road and stockpiled sediments in the alternative development
area may also have had a negative impact on the preservation and context of archaeological
remains, although on inspecting these no cultural material was identified.
Furthermore, as with all archaeological surveys, the primary goal is to identify cultural material
exposed on the surface. From this, one is able to make inferences about what may also lie
below the surface. However, without actual test trenches or geotrenches, it is not possible to
be certain what is represented underground. Moreover, underground heritage remains may
not be represented on the surface making their identification impossible. This serves as a
considerable limitation. Should any cultural heritage be identified when the development
begins, a specialist must be consulted to examine the finds.
22
4. Results and discussion
The entire portion of both the preferred and alternative development areas was surveyed as
shown in Figure 6. Therefore, from the survey, an accurate and inclusive assessment was
possible and the results apply to the entirety of each location. Since the survey was restricted
to these areas only, the findings cannot be applied to any area outside of the development
impact areas within the confines of the Limeroc Business Park.
Figure 6: Survey tracklog indicated in red while the green polygons demarcate the development
area boundaries (A). The alternative development area to the west (B) and the preferred
development area to the east (C) are also indicated.
Both the preferred and alternative development areas are disturbed. For example, in the
preferred area to the east, historic imagery in Google Earth indicates that it was largely
23
vegetated in early 2018, but thereafter and until early to mid-2019 there have been
considerable changes to the landscape. Currently, the area receives heavy traffic from
construction vehicles (Figure 7). As a result of this largely modified landscape, it is currently not
possible to determine what impact these activities have had on preserved heritage in the area
(if any, given its current complete absence). Part of the alternative development area appears
to have been agricultural fields within the last 10 years. Presently, there are sporadic spoil
stockpiles associated with construction and clearing activities and the landscape surface is
largely deflated (Figure 8).
Figure 7: Various images of the preferred location looking southwest (A), east (B), southeast (C)
and south (D). All the images show the impact of surface clearing and vehicle traffic (save for D),
which may have impacted tangible cultural material if it was present.
24
Figure 8: Various images of the alternative development location. This flat parcel of land has a
gravel road and stockpiled sediment along its northwestern boundary (A). Natural quartz
geofacts (chucks) are frequently found at the surface (B; scale=10cm). General views of this
location (C and D) and additional surface disturbances (E) are also indicated.
No cultural heritage was located on the surface in either the preferred or alternative
development areas; this supports the observations made in 2017 by Marais-Botes (2017a,b).
The stockpiled sediment in the alternative area provided a potential view for what may lie
below the surface, in conjunction with the associated shallow diggings adjacent to the gravel
road, but no tangible cultural material was noted within these deposits (Figure 8A). Sporadic
natural geofacts were also located, comprising quartz chunks and fragments, but these are
non-artefactual and non-archaeological (Figure 8B).
Although there are certain limitations that may have inhibited identification (2.c. Constraints
and limitations), it is highly unlikely that any surface archaeology was not identified.
25
5. Development impact and proposed mitigation
a. Development impact
The development within the limits of the proposed impact areas are not anticipated to have
any impact on cultural heritage. In addition, given the sparseness of archaeological sites and
material within the immediate area, based on a review of relevant heritage reports on SAHRIS
and the results of two prior HIA surveys on portions 109, 111 and 331 as reported by
Marais-Botes (2017a,b), it is unlikely that the proposed development will have any significant
impact on cultural heritage.
b. Recommendations
No heritage finds of any significance were identified in the impact footprint of the proposed
waste treatment facility. Therefore, regarding the visible cultural heritage, there are no
recommendations.
However, developers should be cognisant of the possibility that once development commences,
cultural heritage buried underground may be exposed. Should this occur, the development in
the vicinity of the find should be halted and a specialist must be consulted to examine the finds.
26
6. Conclusions
Escience Associates contracted Drs Matt Lotter and Tim Forssman to perform an Archaeological
Impact Assessment on portions 109, 111 and 331 of Farm Number 385 Knopjeslaagte, within
the Limeroc Business Park, Centurion, to assess the impact that a proposed waste treatment
facility may have on any heritage. The relevant portions of land were investigated for surface
traces of cultural heritage. Where sporadic, shallow surface diggings had taken place on the
property, these and their spoil heaps were also examined for any heritage traces. None were
found. Despite this, there may still be cultural heritage subsurface that was not observable or
inferable from surface finds, as is always the case. Should any cultural heritage be observed
once development commences, a specialist must be consulted to perform an examination of
the finds. It is, nonetheless, anticipated that development will have no impact on cultural
heritage in the proposed development area and no recommendations are put forward.
27
7. References
Birkholtz, P., 2007. Phase 1 Heritage Impact Assessment: proposed Cedar Park Development
situated on Portions 5 and 64 of the Farm Bultfontein 533 JQ, City of Johannesburg
Metropolitan Municipality, Gauteng Province. Unpublished report submitted to SAHRA.
Coetzee, F.P., 2008. Cultural Heritage Survey of the Proposed Township Development (Tanganani Ext 7) on Portion 119 (portion of Portion 2) of the farm Diepsloot 388JR, Gauteng. Unpublished report submitted to SAHRA.
Forssman, T. and Gutteridge, L., 2012. Bushman Rock Art: an interpretive guide. Barberton: 30
Degrees South.
Forssman, T. and Louw, C., 2018. The space of flow at Telperion Shelter: the rock art of a
recycled, reused and reimagined place. Time and Mind, 11(2), pp.185-208.
Huffman, T.N., 1999. Archaeological survey of Blue Hills Farm, Midrand. Unpublished report submitted to SAHRA.
Huffman, T.N. 2002. Regionality in the Iron Age: the case of the Sotho Tswana. Southern African
Humanities, 14, pp. 1-22.
Huffman, T.N., 2007. Handbook to the Iron Age. Pietermaritzburg: University of KwaZulu-Natal
Press.
Huffman, T.N., 2009. Mapungubwe and Great Zimbabwe: the origin and spread of social
complexity in southern Africa. Journal of Anthropological Archaeology, 28(1), pp.37-54.
Isowel Trading and Project (Pty) Ltd., 2017. Scoping report for the aggregate and sand mining right application by Carocode (Pty) Ltd. Unpublished report submitted to SAHRA.
Judd, D. and Surridge, K., 2013. The Boer War: A History. Oxford: Bloomsbury Academic.
Kuman, K., 2014. Oldowan industrial complex. Encyclopedia of Global Archaeology, pp.5560-5570.
Lombard, M., Wadley, L., Deacon, J., Wurz, S., Parsons, I., Mohapi, M., Swart, J. and Mitchell, P.,
2012. South African and Lesotho Stone Age sequence updated. South African Archaeological
Bulletin, 67(195), pp.123-144.
28
Lotter, M.G. and Kuman, K., 2018. The Acheulean in South Africa, with announcement of a new
site (Penhill Farm) in the lower Sundays River Valley, Eastern Cape Province, South Africa.
Quaternary International, 480, pp.43-65.
Marais-Botes, L., 2017a. Phase 1 Heritage Impact Assessment (HIA) for the Proposed Peach Tree
X 23 Development on a Part of Portion 109 and a Part of Remainder of Portion 331 of the Farm
Knopjeslaagte 385 - JR, Gauteng Province. Unpublished report.
Marais-Botes, L., 2017b. Phase 1 Heritage Impact Assessment (HIA) for the Proposed Peach
Tree X 25 for the Proposed Extension 1 and 2 Development Situated on Portion 111 of the Farm
Knopjeslaagte 385 - JR, Gauteng Province. Unpublished report.
Markell, A., Hall, M. and Schrire, C., 1995. The historical archaeology of Vergelegen, an early
farmstead at the Cape of Good Hope. Historical Archaeology, 29(1), pp.10-34.
Mason, R.J., 1962. Prehistory of the Transvaal: a record of human activity. Johannesburg:
Witwatersrand University Press.
Mitchell, P., 2002. The Archaeology of Southern Africa. Cambridge: Cambridge University Press.
Mitchell, P. and Whitelaw, G., 2005. The archaeology of southernmost Africa from c. 2000 BP to
the early 1800s: a review of recent research. The Journal of African History, 46(2), pp.209-241.
Ngobese, D. and Mukhuba, T., 2018. Re-inventing the battle of Ncome/Blood River: reflection
on its contested historical consciousness and commemorative events. Gender and Behaviour, 16(2), pp.11751-11761.
Pistorius, J.C., 1994. Molokwane, a seventeenth century Tswana village. South African Journal of
Ethnology, 17(2), pp.38-53.
Reeks, G.W., 2012. The History of Silver Mining in the Greater Pretoria Region, 1885 - 1999.
Unpublished MA thesis. Pretoria: University of South Africa.
Sadr, K., 2019. Kweneng: a newly discovered pre-colonial capital near Johannesburg. Journal of
African Archaeology, 1(aop), pp.1-22.
Schrire, C., 2014. Historical archaeology in South Africa: material culture of the Dutch East India
Company at the Cape. Left Coast Press.
29
Van Schalkwyk, J.A., 2002a. A survey of cultural resources on the Farm Olifantsfontein, Midrand Municipal Area, Gauteng Province. Unpublished report submitted to SAHRA. Van Schalkwyk, J.A., 2002b. A survey of cultural resources for Laezonia, Centurion. Unpublished report submitted to SAHRA. Van Schalkwyk, J.A., 2004. Archaeology. In: Wraypex (Ltd) Pty. Draft Scoping Report for the proposed Blair Atholl Country Estate: 61-62. Unpublished report submitted to SAHRA. Van Schalkwyk, J.A., 2007. Heritage Impact Assessment report for the proposed development on the Zonk’izizwe property, Midrand, Gauteng Province. Unpublished report submitted to SAHRA. Van Schalkwyk, J.A., 2013a. Basic Cultural Heritage Assessment for the proposed Diepsloot East Power Line and new substation, Gauteng Province. Unpublished report submitted to SAHRA. Van Schalkwyk, J.A., 2013b. Basic Cultural Heritage Assessment for the proposed bulk water supply pipeline between Lanseria and Cosmos City, Gauteng Province. Unpublished report submitted to SAHRA. Van Schalkwyk, J.A., 2018. The proposed construction of the Lulamisa to Diepslott East to Blue
Hills to Crowthorne 88kV power line and two substations, Gauteng Province. Unpublished
report submitted to SAHRA.
Wadley, L., 1989. Legacies from the Later Stone Age. South African Archaeological Society
Goodwin Series, 6, pp.42-53.
Wadley, L., 2015. Those marvellous millennia: the Middle Stone Age of southern Africa. Azania:
Archaeological Research in Africa, 50(2), pp.155-226.
Wood, M., 2000. Making connections: relationships between international trade and glass
beads from the Shashe-Limpopo area. South African Archaeological Society Goodwin Series, 8,
pp.78-90.
Wright, J., 1989. Political Mythology and the Making of Natal's mfecane. Canadian Journal of
African Studies/La Revue canadienne des études africaines, 23(2), pp.272-291.
30
DRAFT BASIC ASSESSMENT REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 123
APPENDIX 5: ENVIRONMENTAL MANAGEMENT PROGRAMME
REPORT
ENVIRONMENTAL MANAGEMENT
PROGRAMME REPORT (EMPr):
PROPOSED WASTE PYROLYSIS FACILITY,
INDUSTRIAL GREEN ENERGY SOLUTIONS
(PTY) LTD, CENTURION, GAUTENG
DEFF REFERENCE:
12/9/11/L200812122133/3/N
August 2020
ESCIENCE
ASSOCIATES
(PTY) LTD
POSTAL
ADDRESS:
PO Box 2950
Saxonwold
2132
PHYSICAL
ADDRESS:
9 Victoria Street
Oaklands
Johannesburg
2192
TEL:
+27 11 718 6380
FAX:
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WEBSITE:
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E-MAIL:
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R No 2009/014472/07
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page i
PROJECT INFORMATION SHEET
PROJECT:
PROPOSED WASTE PYROLYSIS FACILITY, INDUSTRIAL GREEN ENERGY SOLUTIONS (PTY) LTD,
CENTURION, GAUTENG
APPLICANT:
INDUSTRIAL GREEN ENERGY SOLUTIONS (PTY) LTD
Postal Address: 8 Summit Road, Knoppieslaagte 385, Centurion, South Africa
Contact: 012 940 3471
Contact Person: Barry Gonin
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: info@escience.co.za
Project Leader: Abdul Ebrahim
COMPETENT AUTHORITY:
NATIONAL DEPARTMENT OF ENVIRONMENT, FORESTRY AND FISHERIES
Postal Address: Private Bag X447, Pretoria, 0001, South Africa
Contact: Tel: (086) 111 2468
REPORT HISTORY AND DETAILS:
Environmental Management Programme Report for for distribution to Interested and
Affected Parties
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
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EScience Associates (Pty) Ltd Page ii
TABLE OF CONTENTS
1 INTRODUCTION .............................................................................................................................. 1
1.1 PROPOSED FACILITY OPERATIONS ............................................................................................... 1
1.1.1 Introduction .......................................................................................................................... 1
1.1.2 Feedstock preparation .......................................................................................................... 4
1.1.3 Pyrolysis ............................................................................................................................... 4
1.1.4 Fuel recovery ........................................................................................................................ 4
1.1.5 Energy Use ........................................................................................................................... 5
1.2 LOCATION AND SITE DESCRIPTION .............................................................................................. 5
1.3 PLANNED LIFE OF THE FACILITY ......................................................................................... 9
1.4 DETAILS OF ENVIRONMENTAL ASSESSMENT PRACTITIONER .................................... 9
1.5 ADMINISTRATIVE INFORMATION ....................................................................................... 9
1.6 EMP STRUCTURE ...................................................................................................................... 9
1.7 EMP IMPLEMENTATION ....................................................................................................... 10
2 ROLES & RESPONSIBILITIES .................................................................................................... 11
2.1 THE PROJECT PROPONENT/DEVELOPER (IGE) ................................................................ 11
2.2 PROJECT/SITE MANAGER (PSM) ......................................................................................... 11
2.3 ENVIRONMENTAL CONTROL OFFICER (ECO) ................................................................. 11
2.4 INDEPENDENT ENVIRONMENTAL OFFICER (IEO) .......................................................... 12
3 RECORD KEEPING ....................................................................................................................... 13
4 EMP REPORTING .......................................................................................................................... 13
5 EMP UPDATE .................................................................................................................................. 13
6 ASPECTS AND IMPACTS COVERED BY EMPR ..................................................................... 14
7 IMPACT MANAGEMENT OUTCOMES ..................................................................................... 15
7.1 PROJECT PLANNING AND DESIGN PHASE ................................................................................... 15
7.2 CONSTRUCTION PHASE ............................................................................................................... 15
7.3 OPERATIONAL PHASE ................................................................................................................. 15
7.4 CLOSURE ..................................................................................................................................... 15
8 ENVIRONMENTAL MANAGEMENT PROGRAMME ............................................................ 16
8.1 PROJECT PLANNING & DESIGN PHASE ............................................................................. 16
8.2 CONSTRUCTION PHASE ........................................................................................................ 18
8.3 OPERATIONAL PHASE ........................................................................................................... 23
8.4 CLOSURE .................................................................................................................................. 31
9 ENVIRONMENTAL INCIDENTS ................................................................................................. 32
10 CONCLUSION ................................................................................................................................. 32
11 UNDERTAKING .............................................................................................................................. 33
APPENDIX 1: EAP CURRICULUM VITAE ....................................................................................... 34
APPENDIX 2: INCIDENT REGISTER ................................................................................................. 35
APPENDIX 3: TRAINING RECORD ................................................................................................... 36
APPENDIX 4: NON-CONFORMANCE RECORD ............................................................................. 37
APPENDIX 5: COMPLAINTS REGISTER .......................................................................................... 38
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 1
1 INTRODUCTION
1.1 PROPOSED FACILITY OPERATIONS
1.1.1 INTRODUCTION
The primary intent of the proposed plant is to recover lighter hydrocarbons through
thermal treatment of non-hazardous wastes such as recovered waxes, non-hazardous
oils and lubricants and plastics, in order to produce various organic compounds and
fuel blends including but not limited to naphtha, petrol, diesel, and heavy fuel oil.
Objectives
The main targets of this project are to:
• Reduce waste to landfill to extend the landfill site air space life.
• Divert solid waste from landfill to productive utilization.
• Reduce fossil fuel dependency through the production of waste derived fuel
and energy.
Refer to Refer to Figure 1-1 for a process flow diagram and Figure 1-2 for the proposed
site layout.
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Figure 1-1: Process Flow Diagram
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Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 3
Figure 1-2: Proposed Site Layout
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1.1.2 FEEDSTOCK PREPARATION
A combination of hydrocarbons, waxes and plastic waste (feedstock) will be delivered to
site via road and stored onsite prior to preparation and processing. The waste will be
received in bags if solid or in flow bins if liquid.
The solid feedstock is to be fed into a mill where the size of the feedstock will be reduced
to below 5mm average particle diameter. It is anticipated that there may be blending
and/or homogenisation of the material to optimise further processing and products.
1.1.3 PYROLYSIS
Pyrolysis feeding arrangement
The pyrolysis process requires an atmosphere devoid of oxygen. The feed material is to be
introduced into the pyrolysis unit by means of two isolation valves where one of the two
valves is always closed to preserve the oxygen free atmosphere. A continuous nitrogen
purge between the valves further reduces the likelihood of oxygen entering the system.
Liquid feed will be fed with a slurry pump into the pyrolysis reactor.
Pyrolysis unit
A single pyrolysis reactor (a horizontal kiln)will be installed. It will convert the feed material
through various thermochemical reactions into a vapour product containing liquid (oil)
and gas (syngas) fractions, and a solid product (residue/char). The pyrolizer is heated
externally by combustion of LPG, syngas or solid residue from the pyrolysis process. The
actual conversion takes place inside the reactor, in the absence of oxygen, thus
preventing combustion of the feed material from taking place and allowing for
production of higher calorific value gas at the exit. The vapour exhaust temperature is
between 500°C and 700°C.
The vapour discharge is separated from the residue product (char) in a dropout box and
a settling chamber.
Pyrolysis char combustion/Vitrification furnace
The solid products of pyrolysis as well as any waste oils are to be sent to a
combustion/vitrification furnace where energy is recovered through combustion to
provide energy to the pyrolysis unit. The unit is run at a high temperature (~1300°C)
whereby the oxidised char will fuse to form a slag which can then be quenched into a
glass like substance in a process called vitrification. Alternatively, the furnace is operated
at a lower temperature such that the oxidised char remains as a free flowing solid. Any
excess combustion gases not used by the pyrolysis unit, as well as the exhaust gases from
the pyrolysis unit heating chamber are sent to the waste heat recovery boiler.
1.1.4 FUEL RECOVERY
Exhaust gas cooler
The superheated vapour product from the pyrolysis unit will pass through a heat
exchanger which cools the vapour to 350°C which prepares it for condensing in the diesel
condenser. The cooling medium used is atmospheric air, whereby the heat exchanger is
used as a preheater for this air before it is used for combustion to provide heat to the
pyrolysis reactor, thus improving efficiency.
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Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
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Diesel condensing tower
The vapour enters the diesel condenser tower at 350°C and is cooled down to 120°C on
the outlet by circulating the condensed and cooled diesel to the top of the tower. The
diesel is then filtered and cooled before sending it to the intermediate storage tanks for
quality control.
Naphtha/water condensing tower
The lower boiling point hydrocarbons, as well as any water, are then cooled down to
approximately 40°C in a second scrubbing tower utilising the cooled condensed naphtha
stream as scrubbing liquid. Water and naphtha are separated in a gravity settler and any
water recovered is used as cooling medium of the solid waste.
Gas handling
The remaining non-condensable portion of the pyrolysis gas is transferred to a gas bladder
by using a booster fan. The gas bladder allows for the gas to homogenise and allows for
minor process upsets which result in changes in gas production. A booster fan on the
outlet of the gas bladder is used to convey the gas to the burners on the pyrolysis unit.
Electricity Generation
Steam generated by the waste heat recovery boiler and combustion of excess cleaned
gas may be used to drive a turbine or organic Rankine cycle process to produce
electricity. If conducted this will be less than 10MW and thus will not require Environmental
Authorisation.
1.1.5 ENERGY USE
All feedstock is to be processed in an enclosed and sealed reactor allowing contaminants
to be efficiently captured and disposed of in ash collectors or through water scrubbing
processes. Pollutants are not to be released into the atmosphere in this process, as they
would be in a combustion-centric process.
Water used in the process will be supplied from municipal services and no industrial
effluent of significance is anticipated.
Measures within buildings and with other associated machinery to reduce energy usage
include:
• Machinery will be started sequentially and ramped up to minimise peak demand
at start up.
• Variable speed drives will be used wherever practical for controlling feed and flow
rates.
• Use of natural lighting will be optimized where practical.
• Low energy lighting will be used.
• Electricity and fuel usage will be monitored and discussed at management
meetings to ensure that energy usage is optimized and reduced where practical.
1.2 LOCATION AND SITE DESCRIPTION
The proposed facility will be located in the Limeroc Business Park, Knoppieslaagte 385-Jr,
Centurion within the City of Tshwane Metropolitan Municipality. The business park is
accessed from the R114 and is immediately surrounded by residential and commercial
activities as well as grassland/shrubland. The closest residential area is an informal
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 6
settlement located 10m west of the property boundary. Refer to Figure 1-3 and Figure 1-4
for maps showing the location of the facility.
The site falls within Ward 106 of the City of Tshwane Metropolitan Municipality.
Two locations within the Limeroc Business Park are being considered:
• Preferred Alternative:
o Portion 111 of Farm No. 385 Knopjeslaagte
• Alternative Location:
o Portion 109 of Farm No. 385 Knopjeslaagte
o Portion 331 of Farm No. 385 Knopjeslaagte
Refer to Table 1-1 for details on the properties.
Table 1-1: Property Description
Province Municipality Ward
No.
Erf Number SG 21 Key
Preferred Location
Gauteng
City of
Tshwane
Metropolitan
Municipality
106
Portion 111 of Farm No.
385 Knopjeslaagte
T0JR00000000038500111
Alternative Location
Portion 109 of Farm No.
385 Knopjeslaagte
T0JR00000000038500109
Portion 331 of Farm No.
385 Knopjeslaagte
T0JR00000000038500331
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Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 7
Figure 1-3: Proposed site locality
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Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 8
Figure 1-4: Proposed site locality - Zoomed
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EScience Associates (Pty) Ltd Page 9
1.3 PLANNED LIFE OF THE FACILITY
The facility is planned to operate permanently. If decommissioning is ever planned a
decommissioning plan must be developed. Given that de-commissioning is not
reasonably anticipated to occur in the foreseeable future, this EMP covers only a limited
set of impacts related to de-commissioning which are foreseeable.
1.4 DETAILS OF ENVIRONMENTAL ASSESSMENT PRACTITIONER
The Environmental Management Programme (EMPr) for this application was undertaken
by EScience Associates (Pty) Ltd, as independent Environmental Assessment Practitioners
(EAP) to IGE. The team was led by Mr. A Ebrahim (Table 1-2). Detailed curricula vitae are
attached as Appendix 1.
Table 1-2: Details of EAP (Author of the EMP)
Name of Company EScience Associates (Pty) Ltd.
Lead EAP Mr. Abdul Ebrahim
Contact Person Mr. Sam Leyde
Postal Address PO Box 2950, Saxonwold, Johannesburg, 2132
Physical Address 9 Victoria Street, Oaklands, Johannesburg, 2192
Telephone (011) 718 6380
Cell 074 570 8054
Fax 0866 106 703
Email sam@escience.co.za
Qualifications BSc Honours Mechanical Engineering
1.5 ADMINISTRATIVE INFORMATION
The following section and associated set of tables provide pertinent administrative
information pertaining to the development/lease area (Table 1-3 and Table 1-4).
Table 1-3: Name and Address of the Proponent.
Name Industrial Green Energy Solutions (Pty) Ltd
Physical Address 8 Summit Road, Knoppieslaagte 385, Centurion, South Africa
Telephone 071 877 7610
Table 1-4: Details of responsible person(s) at facility
Name Barry Gonin
Physical Address 8 Summit Road, Knoppieslaagte 385, Centurion, South Africa
Postal Address 8 Summit Road, Knoppieslaagte 385, Centurion, South Africa
Telephone 083 222 5222
1.6 EMP STRUCTURE
In order to realise the objectives of the EMP, the document:
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Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
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• Specifies the general roles and responsibilities for the implementation and
monitoring of the EMP;
• Identifies the specific aspects (i.e. activities related to the development) that may
result in environmental impacts and therefore require management/mitigation;
• Identifies the specific impacts or risks that may eventuate during the construction or
operational phases of the project;
• Determines and specifies the specific mitigation measures that must be
implemented;
• Identifies the related monitoring procedures;
• Specifies the responsible party for implementation of specific measures and
monitoring procedures; and
• Determines the frequency of implementing measures and monitoring procedures.
1.7 EMP IMPLEMENTATION
The EMP should not be seen as an additional requirement separate from the day-to-day
activities of the site and associated responsibilities. If it becomes merely another layer of
control, it could be perceived as an obstruction to normal duties and operations. The
EMP must be integrated with routine operations and responsibilities, which requires
commitment from management and the workforce alike (DEAT, 2004).
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2 ROLES & RESPONSIBILITIES
2.1 THE PROJECT PROPONENT/DEVELOPER (IGE)
IGE will be responsible for the overall implementation, monitoring and enforcement of the
activities as outlined in the EMP. The project manager or other senior designate from IGE
will be responsible for overseeing that environmental compliance and monitoring is
performed and will undertake all correspondence with the relevant authorities.
IGE remains ultimately responsible for ensuring that the activity is implemented according
to the provisions of the EMP and conditions of a potential Waste Management License
(WML) throughout all phases of the project. Although specific role-players will be
appointed by IGE to perform certain functions on its behalf, the ultimate responsibility is
not delegated. IGE has to ensure that sufficient resources (time, financial, human,
equipment, etc.) are available to these other parties to efficiently perform their tasks in
terms of the EMP. Because IGE is liable for restoring negligent damage caused to the
environment1, each member of staff has to be responsible and accountable for
compliance as per the EMP.
2.2 PROJECT/SITE MANAGER (PSM)
IGE must appoint/designate a senior representative as Project/Site Manager (PSM) to act
on its behalf. The duties of this representative, as relevant, would include:
• Ensure that the EMP is part of relevant contractual documentation so that any
contractors are bound to the conditions of the EMP and relevant licences,
permits/approvals/authorisations;
• Monitor the undertaking of environmental awareness training for all new personnel
coming onto site, or undertake environmental awareness courses themselves;
• Appoint an Environmental Control Officer (ECO) to assist with day-to-day EMP
implementation and monitoring duties;
• Ensure that the necessary waste licenses and permits have been obtained and
are maintained;
• Ensure that the requirements of the EMP are met;
• Monitor and verify that the EMP is adhered to at all times and take action if the
specifications are not followed;
• Monitor and verify that environmental impacts are kept to a minimum;
• Review operational procedures in conjunction with the ECO;
• Assist the ECO in finding environmentally responsible and effective solutions to any
problems encountered during implementation;
• Inspect the site and surrounding areas from time to time; and
• Monitor, review and verify compliance with the EMP as reported by the ECO.
2.3 ENVIRONMENTAL CONTROL OFFICER (ECO)
IGE’s ECO will be responsible for monitoring, reviewing and verifying compliance with the
EMP on a day-to-day basis. This role may be fulfilled by any suitably qualified and
1 In this respect see section 34 (Criminal Proceedings) of the National Environmental Management
Act, 1998 (Act No. 107 of 1998)
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responsible representative involved with daily on-site operations. In particular, the ECO
shall:
• Regularly inspect and continuously monitor the site to ascertain the level of
compliance with the EMP;
• The ECO must oversee all the environmental aspects relating to the development
and provide auditing of compliance with the EMP;
• Maintain inspection reports on file;
• Monitor and verify through bi-annual audits that the EMP is adhered to at all times
and take action if the specifications are not followed;
• Monitor and verify that environmental impacts are kept to a minimum;
• Assist IGE in finding environmentally responsible solutions to problems;
• Keep records of all activities/incidents concerning environment performance;
• Keep a register of complaints from IAPs;
• Provide material/manuals and support for raising environmental awareness of
staff;
• Ensure that activities on site comply with legislation of relevance to the
environment;
• Liaise with relevant authorities;
• Liaise with contractors regarding environmental management;
• Complete checklists as necessary; and
• Continually, internally review the EMP and submit monthly reports to the PSM.
2.4 INDEPENDENT ENVIRONMENTAL OFFICER (IEO)
An independent Environmental Officer (IEO) may be appointed by IGE to independently
review relevant environmental aspects relating to this development. The IEO would need
to conduct independent periodic external audits to assess compliance with the EMP and
be responsible for providing feedback on potential environmental problems associated
with the activities on site. The regularity of these external audits shall be determined by
the site’s Waste Management Licence.
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3 RECORD KEEPING
Record keeping must be done in such a way that all information generated is secure can
be accessed easily. The ECO will be responsible for maintenance of environmental
records and reports. The ECO will ensure that these are readily accessible for reporting to
site management as well relevant authorities within the timeframes stipulated in the
Waste Management Licence.
4 EMP REPORTING
Adequate monitoring, auditing and record keeping make reporting a simple task.
Information and existing reports can be assembled and presented to whoever may need
them. Knowing what reporting is necessary can help inform the type of monitoring and
the system of record keeping. Typical reporting requirements include:
• Company performance/management system reports (e.g. performance targets);
• Company environmental/sustainability reports (part of annual reports);
• Audit reports, including review of the EMP; and
• Incident/event reports.
5 EMP UPDATE
This EMP must be updated upon substantive amendment of the Waste Management
Licence. IGE may periodically review the EMP and update it to suit changing
circumstances. Updates/amendments must be undertaken in compliance with the
conditions of the Waste Management Licence. Where the Waste Management Licence
is not prescriptive in respect of such updates or amendments, the competent authority
must be informed of such intended updates/amendments to the EMP.
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6 ASPECTS AND IMPACTS COVERED BY EMPR
A summary of the impact assessment is presented in Table 6-1. The impacts of the proposed facility, with mitigation are all anticipated to
be negligible or acceptable.
Table 6-1: Impact Summary
Impact
( - / +)
Impact significance
without mitigation
Impact significance
with mitigation
Construction phase:
Potential impacts on soil and groundwater quality during construction - Low Negligible
Noise generation during construction activities. - Low Negligible
Waste generation during construction of infrastructure. - Low Negligible
Dust generation during construction activities. - Negligible Negligible
Archaeological and cultural impacts - No impact (refer to section specialist assessment)
Operational phase:
Potential impacts on groundwater quality during operations - Moderate Negligible
Potential impacts on soil during operations - Negligible Negligible
Noise - Low Negligible
Air Quality Low to negligible (refer to specialist assessment)
Reduction of waste to landfill + Positive (Negligible)
Socio-Economic - Job creation + Positive (Moderate)
Decommissioning Phase
Potential impacts on surface and groundwater quality during
construction - Low Negligible
Noise generation during decommissioning activities. - Low Negligible
Waste generation during decommissioning of infrastructure. - Low Negligible
Dust generation during decommissioning activities. - Negligible Negligible
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7 IMPACT MANAGEMENT OUTCOMES
The impact management outcomes, as described in the sub-sections below, were
identified and taken into consideration during the development of this EMPr.
7.1 PROJECT PLANNING AND DESIGN PHASE
• Ensure that competent staff are appointed to develop procedures and
implement the requirements of the EMPr;
• Update the EMPr to reflect the requirements of the Waste management
Licence;
• Contractors and Staff must be trained in all environmental aspects related to
their duties.
7.2 CONSTRUCTION PHASE
• Maintain soil integrity and minimise erosion;
• Maintain a hygienic environment in construction site and construction camp;
• Minimise the risk of fires;
• Avoid atmospheric pollution;
• Avoid excessive noise generation from construction activities;
• Prevent land and water pollution;
• Minimise the generation of waste.
7.3 OPERATIONAL PHASE
• Ensure environmental legal requirements are identified and are met;
• Contractors and staff must be made aware of the provisions and requirements
of the EMPr and Waste Management License relevant to their activities;
• Ensure ongoing inspections and maintenance of the facility to prevent liquid
and gas leakage;
• Emergency situations to be dealt with efficiently and all staff to be trained to do
so;
• Maintain pest control measures;
• Avoid atmospheric pollution;
• Prevent land and water pollution.
7.4 CLOSURE
Given that de-commissioning is not reasonably anticipated to occur in the foreseeable
future, this EMP covers only a limited set of impacts related to de-commissioning which
are foreseeable.
• A decommissioning plan must be formulated prior to commencement of
decommissioning to manage or avoid environmental impacts
• Maintain soil integrity and minimise erosion;
• Minimise the risk of fires;
• Avoid atmospheric pollution;
• Avoid excessive noise generation from decommissioning activities;
• Prevent land and water pollution;
• Minimise the generation of waste.
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8 ENVIRONMENTAL MANAGEMENT PROGRAMME
The mitigation tables that follow have been compiled consist of five (5) criteria, as follows:
▪ Aspect – The broad area of application with respect to the waste management activity (E.g. Waste storage, air emissions);
▪ Activity - This column will identify the issue being addressed, e.g. Activities potentially impacting on air quality;
▪ Management Actions and Monitoring - This column will include all the necessary mitigation measures for each activity and /or area
under scrutiny;
▪ Frequency of action – This column provides time guidelines for the ‘Responsible party’ by which he/she is to action or manage the
required mitigation;
▪ Responsible Party – Indicates that party who is ultimately responsible for ensuring that the prescribed mitigation measures are
appropriately implemented within the specified time-frames;
8.1 PROJECT PLANNING & DESIGN PHASE
Table 8-1: Environmental Management Plan - Planning and Design Phase
ASPECT ACTIVITY MANAGEMENT ACTIONS & MONITORING RESPONSIBILITY FREQUENCY
1. Project Planning & Design Phase
1.1 Management
(Set-up structures
and procedures for
implementation of
EMP)
Appointment of and
duties of ECO
Appoint an Internal Environmental Control Officer (ECO) who will
be required to monitor the activities with a direct hands-on
approach, and ensure compliance and co-operation of all
personnel.
PSM
Before
commencem
ent
Update the EMP after
detailed design has
been completed
This EMP must be updated to ensure that it is relevant to the
detailed design of the facility. PSM, ECO
Before
commencem
ent
Update the EMP to
reflect the
requirements of the
WML
This EMP must be updated to ensure that all conditions of the
WML and other environmental approvals (e.g. permits, licenses
etc) issued for this project have been incorporated into the EMP,
as necessary.
ECO
Before
commencem
ent
Appointment and
duties of IEO
The project proponent must appoint an independent
Environmental Officer (IEO) who must monitor compliance with
the EMP. PSM, ECO
When
required
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Table 8-1: Environmental Management Plan - Planning and Design Phase
ASPECT ACTIVITY MANAGEMENT ACTIONS & MONITORING RESPONSIBILITY FREQUENCY
Management of staff
and contractors
The EMP must be made binding to the any contractors and
should be included in tender documentation for any applicable
contracts.
PSM, ECO
Once-off
before
contractor
appointment
s
The EMP must be made available to the contractors, staff, as
well as other relevant role-players associated with the project. PSM, ECO Continuous
1.2 Layout Design
Clear demarcation of
activities
Internal routes, drop-off, pick-up and storage areas must be
clearly demarcated. PSM
Before
commencem
ent
Roads A clear space should be provided along the site internal road for
pedestrian walking. PSM Continuous
Parking Parking should be provided based on the local town planning
scheme requirements PSM Continuous
Noise Sources of potentially significant noise must ideally be positioned
away from sensitive receptors as far as is practical. PSM
Before
commencem
ent
1.3 Signage
Information for the
public and waste
deliverers
A general notice board must be erected at the site entrance in
appropriate official languages. The notice must have details of
emergency contact persons and procedures and operational
hours, unless the WML indicates otherwise.
ECO
Before
conducting
the
authorised
activities
1.4 Training Training of staff and
contractors
Staff must be trained in all environmental aspects of their duties
and responsibilities relating to the WML and the EMPr. Records of
training and verification of competence must be kept by IGE.
ECO
Prior to
commencem
ent of work
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8.2 CONSTRUCTION PHASE
Table 8-2: Environmental Management Plan – Construction Phase
ASPECT POTENTIAL
IMPACT/RISK/ISSUE
MANAGEMENT ACTIONS & MONITORING RESPONSIBILITY FREQUENCY
2. Construction Phase
2.1 Monitoring and
Reporting
Compliance with the
EMP & WML
Monitor site activities and compliance with EMP. ECO Continuous
Identify, propose, monitor and sign off on the implementation of
any required rectification measures. ECO, PSM Continuous
Audit compliance with EMP and report to authorities. ECO
IEO
As
determined
by the WML
2.2 Environmental
incidents
Environmental
incidents during the
construction phase
Serious incidents must be report as per S30 of NEMA. A record of
these incidents must be kept (See Appendix 2).
NEMA S30(1a) stipulates: “incident” means an unexpected,
sudden and uncontrolled release of a hazardous substance,
including from a major emission, fire or explosion, that causes,
has caused or may cause significant harm to the environment,
human life or property;
PSM As required
IGE will be responsible for rehabilitating any damages caused to
the environment due to any incident occurring on site that is as
a direct result of the construction activities.
PSM As required
2.3 Construction site
management
Atmospheric pollution
and odours
Ensure that no wastes are burnt on the premises or on
surrounding premises. Contractor, Daily
The Contractor is to take appropriate measures to minimise the
generation of dust as a result of construction works, to the
satisfaction of the ECO.
Contractor, ECO, As necessary
Soil integrity and
erosion
The Contractor shall take appropriate and active measures to
prevent erosion resulting from his works. Contractor As required
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 19
Table 8-2: Environmental Management Plan – Construction Phase
ASPECT POTENTIAL
IMPACT/RISK/ISSUE
MANAGEMENT ACTIONS & MONITORING RESPONSIBILITY FREQUENCY
Construction hazards
Construction/activities must be planned and undertaken in
compliance with the Occupational Health and Safety
Amendment Act, Act No. 181 of 1993, and the regulations
thereunder, including but not necessarily limited to: General
Safety Regulations, 1986, Construction Regulations, 2003; and,
the National Building Regulations and Building Standards Act,
1977 (Act No.103 of 1977) and regulations thereunder.
PSM, Contractors Continuous
Noise
Use of construction vehicles, and activities, which may create a
disturbing noise must be undertaken during typical business
hours in accordance with locally applicable by-laws during the
week. These activities must be avoided as far as is practical
during night-time and weekends.
PSM, Contractors Continuous
Vehicles to comply with the standards as provided in the
International Finance Corporation’s Environmental Health &
Safety Regulations.
PSM, Contractors Continuous
Acoustic screening measures to be installed in and around noise
sources which generate a noise exceeding 85.0dBA at the
source
PSM, Contractors Once-off (if
necessary)
Hygiene
If applicable, ablution facilities supplied for construction
personnel, must be removed upon completion of construction. Contractor, ECO As required
If utilised, temporary toilets must be emptied and maintained in
working order throughout the construction period, and emptied
timeously.
Contractor, ECO Weekly
Risk of fires
No open fires are to be allowed on site to prevent any fire
damage to surrounding buildings. Contractor Continuous
Welding, gas cutting or cutting of metal will only be permitted
inside the working areas. ECO, Contractors Continuous
Suitable and sufficient fire-extinguishing equipment must be
placed at strategic locations and must be adequately
maintained.
ECO, Contractors Continuous
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
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EScience Associates (Pty) Ltd Page 20
Table 8-2: Environmental Management Plan – Construction Phase
ASPECT POTENTIAL
IMPACT/RISK/ISSUE
MANAGEMENT ACTIONS & MONITORING RESPONSIBILITY FREQUENCY
The Contractor shall pay the costs incurred to organisations
called to put out any fires started by him. The Contractor shall
also pay any costs incurred to reinstate burnt areas as deemed
necessary by the ECO.
ECO, Contractors Continuous
Hazardous Substances
Hazardous substances such as fuel and oil must be stored within
appropriately sized, impermeable, bund walls, with the
appropriate warning signage.
ECO, Contractors Continuous
The ECO must ensure that the storage and utilization of
potentially hazardous material such as diesel, petrol, oils and
lubricants, etc does not result in any form of soil and water
contamination.
ECO, Contractors Continuous
Spill kits to be readily available at all points where hazardous
substances will be stored and/or transferred (e.g. refuelling
points)
ECO, Contractors Continuous
2.4 Preparation of
Building Material &
Cement works
Surface water and
ground water
pollution prevention.
Where possible building materials are to be prepared at the
batching plant, to enable the effects of cement and other
substances, and the resulting effluent to be more easily
managed.
Contractor, ECO Once-off &
inspect daily
Cement contaminated water may not enter a natural or man-
made water system. Contractor, ECO
Once-off &
inspect daily
Excess or spilled concrete should be confined within the works
area and then removed to a suitable waste site. Contractor, ECO
Once-off &
inspect daily
2.5 Waste
Management
Land and water
pollution, littering. No littering of site or surrounds is permitted. Contractor, ECO
Continuous,
inspect daily
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 21
Table 8-2: Environmental Management Plan – Construction Phase
ASPECT POTENTIAL
IMPACT/RISK/ISSUE
MANAGEMENT ACTIONS & MONITORING RESPONSIBILITY FREQUENCY
Adequate Bins and/or skips must be provided on the site to
provide for general waste. Waste sorting must be done at source
or within a dedicated area. Undesired or non-recyclable waste
must be collected by an appropriate waste management
service provider.
ECO Once off;
Ensure that no refuse or builders rubble generated on the
premises be placed, dumped or deposited on
adjacent/surrounding properties including road verges, roads or
public places and open spaces during or after the construction
period.
Contractor, ECO Continuous,
inspect daily
All discard materials produced during construction that will not
be recovered or recycled must be taken offsite and deposited
in an appropriate, licenced landfill site
Contractor, ECO Continuous,
inspect daily
The Contractor shall ensure that waste and surplus food, food
packaging and organic waste are not deposited by his
employees anywhere on the site except in dedicated refuse
bins for removal on a daily basis by the Contractor. Refuse bins
shall be weather-proof.
Contractor Continuous,
inspect daily
2.6 Vehicles and Fuel
Storage
Land and water
pollution
If vehicle and/or construction machinery maintenance is to
occur onsite, a suitable leak proof container for the storage of
oiled equipment (filters, drip tray contents and oil changes etc.)
must be established.
Contractor, ECO Continuous,
inspect daily
Drip trays to be appropriately placed under vehicles and
machinery that stay over-night on bare soil surfaces. Contractor, ECO
Continuous,
inspect daily
All servicing of onsite mechanical machinery must have a drip
tray present to prevent accidental spillage of oils and fuels. Contractor, ECO
Continuous,
inspect daily
All vehicles, equipment, fuel and petroleum services and tanks
must be maintained in a condition that prevents leakage and
possible contamination of soil or water supplies.
Contractor, ECO Continuous,
inspect daily
Refuelling areas must be bunded and secured to prevent soil
and water contamination. Contractor, ECO
Continuous,
inspect daily
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 22
Table 8-2: Environmental Management Plan – Construction Phase
ASPECT POTENTIAL
IMPACT/RISK/ISSUE
MANAGEMENT ACTIONS & MONITORING RESPONSIBILITY FREQUENCY
Fuels and flammable materials are to be stored in suitably
equipped storage areas complying with general fire safety
requirements.
Contractor, ECO Continuous,
inspect daily
Where hydrocarbon spills occur the soil is to be removed for
treatment or disposal as soon as practical. Contractor, ECO Continuous
2.7 Heritage
Management
Destruction of
Heritage Resources
Should any cultural heritage buried underground be exposed,
the development in the vicinity of the find should be halted and
a specialist must be consulted to examine the finds.
Contractor, ECO Continuous
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
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EScience Associates (Pty) Ltd Page 23
8.3 OPERATIONAL PHASE
Table 8-3: Environmental Management Plan – Operational Phase
ASPECT POTENTIAL
IMPACT/RISK/ISSUE
MANAGEMENT ACTIONS & MONITORING RESPONSIBILITY FREQUENCY
3. Operational Phase
3.1 Legal
Compliance
Identification of
environmental legal
requirements
Procedures must be drawn up to ensure that all relevant
environmental legal requirements and amendments are
identified, and that this EMPr can be updated to ensure that
those legal requirements are met.
PSM
Before
commencem
ent of
operation.
Updating the EMPr
The EMPr must be reviewed, and if necessary updated, on a
periodic basis to ensure that environmental legal requirements
for the operations are adhered to.
PSM
At least once
per calendar
year
3.2 Awareness and
Training
Training of Staff and
Contractors
Contractors and staff must be adequately trained in all
environmental aspects relating to their role in the operation.
Contractors and staff must be made aware of the provisions and
requirements of the EMPr and the WML relevant to their
activities. Records of training and verification of competence
must be kept by IGE.
PSM,
Contractors,
ECO.
Before
commencem
ent of
operations.
Any persons having duties that are or may be affected by the
WML must have convenient access to a copy thereof, a copy of
which must be kept at or near the place where those duties are
carried out.
ECO Continuous
IGE must ensure that all personnel who work with hazardous
substances are trained to deal with these potential hazardous
situations so as to minimise the risk involved. Records of training
and verification of competence must be kept by IGE.
ECO
Before
commencem
ent of
operations.
3.3 Monitoring and
Reporting
Compliance with the
EMPr and WML
Monitor site activities and compliance with EMPr. ECO Continuous
Internal audits must be conducted biannually by the ECO and
on each audit occasion an official report must be compiled to
report the findings of the audits, which must be made available
to the PSM.
ECO Bi-Annual
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 24
Table 8-3: Environmental Management Plan – Operational Phase
ASPECT POTENTIAL
IMPACT/RISK/ISSUE
MANAGEMENT ACTIONS & MONITORING RESPONSIBILITY FREQUENCY
Where non-compliance occurs - Identify, propose, monitor and
sign off on the implementation of rectification measures. ECO, PSM Continuous
If required by the WML, IGE must appoint an independent
external auditor to audit the site annually and the auditor must
compile an audit report documenting the findings of the audit
according to conditions of the WML.
The audit report must:
a) Specifically state whether conditions of the licence are
adhered to;
b) Include an interpretation of all available data and test
results regarding the operation of the site and all its impacts
on the environment;
c) Specify target dates for the implementation of the
recommendations by the Licence Holder to achieve
compliance;
d) Contain recommendations regarding non-compliance
and must specify target dates for the implementation of
the recommendations by the Licence Holder and whether
corrective action taken for the previous audit non-
conformities was adequate; and
e) Where applicable, show monitoring results graphically and
conduct trend analyses.
ECO, IEO Annual
Emissions Monitoring
Air emissions monitoring and reporting must be undertaken as
per the conditions of the Atmospheric Emissions Licence (AEL)
relating to each listed activity immediately upon
commencement of operation, unless otherwise stipulated in the
AEL.
ECO, IEO As required by
AEL
Compliants A complaints register shall be maintained and kept at reception
in order to record complaints of noise, odour or any other
complaints. (See Appendix 5)
ECO Continuous
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 25
Table 8-3: Environmental Management Plan – Operational Phase
ASPECT POTENTIAL
IMPACT/RISK/ISSUE
MANAGEMENT ACTIONS & MONITORING RESPONSIBILITY FREQUENCY
3.4 Emergency
Preparedness
Emergency Response
IGE must develop, implement and maintain an emergency
preparedness plan and review it annually when conducting an
audit, and after each emergency incident and major accident.
The plan must, amongst others, include measures to address:
a) Equipment malfunction;
b) Site fires;
c) Spillage (on Site);
d) Natural disasters such as floods; and
e) The plan must include contact details of the nearest police
station, ambulance services and the emergency centre.
ECO
Once-off &
updated as
required
Ensure that the contact details of the emergency response
services (ambulance service, fire brigade) are available on site. ECO
Once-off &
updated as
required
Fire prevention and
response
Undertake a risk assessment to identify all potential sources of fire
or propagation of fire or uncontrolled combustion. ECO
After
construction,
Before
commencem
ent of
operations.
Annual
inspections.
Suitable (type) and sufficient (volume) fire-extinguishing
equipment must be placed at strategic locations to respond
immediately to fires. These must be well maintained and the fire
extinguishers must be inspected annually.
ECO
After
construction,
Before
commencem
ent of
operations.
Annual
inspections.
Environmental All staff will be made aware of emergency procedures. ECO Continuous
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 26
Table 8-3: Environmental Management Plan – Operational Phase
ASPECT POTENTIAL
IMPACT/RISK/ISSUE
MANAGEMENT ACTIONS & MONITORING RESPONSIBILITY FREQUENCY
Incidents Key staff to be trained in emergency techniques e.g. first aid
and firefighting. ECO Continuous
The competent authority and other relevant authorities must
immediately be informed should any serious incident occur
which is likely to have detrimental effects on the environment. A
record of these incidents must be kept. All incidents must be
reported as per the requirements of S30 of the National
Environmental Management Act, No. 107 OF 1998.
“Incident” means an unexpected, sudden and uncontrolled
release of a hazardous substance, including from a major
emission, fire or explosion, that causes, has caused or may cause
significant harm to the environment, human life or property;
As soon as
reasonably
practicable
after obtaining
knowledge of
the incident,
Preferably within
24 hours.
Environmental
incidents
IGE will be responsible for rehabilitating any damage caused to
the environment due to any incident occurring on site. ECO If required
3.5 General
Maintenance
Land and water
pollution
All mechanical equipment, forklifts and trucks used must be
clean and free from leaks of oil, petrol, diesel, hydraulic fluid,
etc.
PSM Daily
inspections
Where maintenance is undertaken, adequate measures must
be implemented to prevent contamination of soil and/or water.
All maintenance undertaken outside buildings (i.e. on roads,
paving or any exposed area exposed) must be undertaken with
drip trays to capture any spills or leaks.
PSM Continuous
Air pollution
All machinery and equipment capable of emitting atmospheric
pollutants (e.g. forklifts) must be adequately maintained to
prevent noxious and avoidable emissions.
PSM Daily
inspections
3.6 Waste
management
Land and water
pollution
All waste must be stored in compliance with the Norms and
Standards set out in GN926 National Environmental
Management: Waste Act (59/2008): National norms and
standards for the storage of waste.
PSM, ECO Continuous
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 27
Table 8-3: Environmental Management Plan – Operational Phase
ASPECT POTENTIAL
IMPACT/RISK/ISSUE
MANAGEMENT ACTIONS & MONITORING RESPONSIBILITY FREQUENCY
Waste management practices must adhere to the regulations
set out in GN.R634 National Environmental Management: Waste
Act (59 / 2008): Waste Classification and Management
Regulations.
PSM, ECO Continuous
All waste and storage areas must be clearly demarcated and
maintained. ECO
Once off,
weekly
inspection
Storage of waste is to take place under roof on an impermeable
surface and within a bunded area. PSM, ECO Continuous
Storage areas for recyclable material generated by IGE must be
allocated and effectively maintained. PSM, ECO Continuous
Procedures to deal with litter must be put in place and staff
should be trained in these procedures. Daily housekeeping
within the site must be undertaken.
ECO Daily
Waste Handling
Transportation and handling of waste must be conducted in
such a manner that leachate does not leak onto roads or
parking areas and that windblown material is prevented.
ECO Continuous
Pest control (General)
A pest control procedure must be formulated and implemented
to prevent pest propagation. A registered pest control operator
must be consulted in this regard (Fertilizers, Farm Feeds,
Agricultural Remedies and Stock Remedies Act 36 of
1947Section 7(2)(a)(i)).
ECO
Before
commencing
operations
Records of treatments undertaken onsite must be kept. PSM, ECO Continuous
Poison, traps, and other pest control measures must be placed in
several places within the facility and maintained by an
independent hygiene contractor.
PSM Continuous
Disposal of waste
Waste that cannot be re-used or recycled is to be disposed of at
an adequately licenced landfill PSM As required
All records of waste disposed to landfill must be kept and made
available to relevant parties on request. PSM As required
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 28
Table 8-3: Environmental Management Plan – Operational Phase
ASPECT POTENTIAL
IMPACT/RISK/ISSUE
MANAGEMENT ACTIONS & MONITORING RESPONSIBILITY FREQUENCY
Non-Recyclable /
Non-Reusable
General Waste
Non-Recyclable General Waste must be disposed of at a
permitted disposal site. ECO
Continuous,
Within 3
months of
commencem
ent of
operation
Record Keeping
The site must keep accurate and up to date records of the
management of waste, which must reflect—
• the specific types of waste generated;
• the quantity of each type of waste generated, expressed
in tons per month; and
• the quantities of each type of waste that has either been
re-used, recycled, recovered, treated or disposed of.
ECO
Continuous:
Monthly
records
Such records must be made available to the relevant authority
upon request and kept on record for a period of at least five (5)
years.
ECO Continuous
3.7 Air emissions
Air quality
The plant must comply with the conditions and minimum
emission standards of the Atmospheric Emissions Licence (AEL)
relating to each listed activity immediately upon
commencement of operation, unless otherwise stipulated in the
AEL.
PSM Continuous
Odour
A complaints register shall be maintained and kept at reception
in order to record complaints of odour. (See Appendix 5).
If any complaints are received the root cause of the complaint
must be investigated and resolved.
ECO
Before
commencem
ent of
operation and
Continuous
3.8 Storm Water
Management
Surface water runoff
from the operations
A Storm Water Management Plan must be implemented and
adhered to. PSM, ECO Continuous
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
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Table 8-3: Environmental Management Plan – Operational Phase
ASPECT POTENTIAL
IMPACT/RISK/ISSUE
MANAGEMENT ACTIONS & MONITORING RESPONSIBILITY FREQUENCY
Interceptors should be installed to prevent solid waste from
entering the storm water drainage systems. These interceptors
must be cleared regularly.
PSM
Once off and
weekly
monitoring
All waste must be stored in compliance with the Norms and
Standards set out in GN926 National Environmental
Management: Waste Act (59/2008): National norms and
standards for the storage of waste.
PSM Continuous
No contaminated runoff water may be discharged to a water
course unless it complies with the quality requirements specified
in the General Standards, as published by the Department of
Water Affairs in Government Notice 991 of 18 May 1984 or its
successor.
ECO Continuous
Prevent storm water contamination through regular inspection
and maintenance of the storm water management system. PSM
Monthly and
continuous
monitoring of
these areas
All drainage structures must be cleared of organic and inorganic
debris, and accumulated silt. PSM
Continuous
monitoring of
these areas
3.9 Dangerous Goods
Storage and
Handling
Storage, handling and
transportation of
hazardous goods
Dangerous goods are to be stored and handled as per the
requirements of SANS 10231, 10232, and 10131, as well the
hazardous chemicals regulations under the Occupational Health
and Safety Amendment Act, Act No. 181 of 1993.
ECO, PSM
Before
commencem
ent of
operation
Hazardous substances such as fuel and oil must be stored within
appropriately sized, impermeable, bund walls, with the
appropriate warning signage.
ECO, PSM Continuous
Dangerous goods storage bunds should be able to contain 110%
of the volume of fuel stored. ECO, PSM
Before
commencem
ent of
operation
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 30
Table 8-3: Environmental Management Plan – Operational Phase
ASPECT POTENTIAL
IMPACT/RISK/ISSUE
MANAGEMENT ACTIONS & MONITORING RESPONSIBILITY FREQUENCY
Spill kits to be readily available at all points where hazardous
substances will be stored and/or transferred. PSM Continuous
3.10 Socio-
economics
Local community
beneficiation
Where practical, IGE should attempt to source unskilled and
possibly skilled employees from the local surrounding
community.
PSM,
Contractors Continuous
3.11 Occupation
health and safety
Safety, Health and
Environment
The site must be managed in accordance with the provisions of
the Occupational Health and Safety Act, 1993 (Act No. 85 of
1993).
ECO Continuous
The facility must comply with the National Building Regulations
and By-law relating to fire Safety. ECO Continuous
An on-site safety plan must be available, and all staff must be
trained in the appropriate emergency procedures. ECO Continuous
A protocol for reporting and recording incidents must be
developed and maintained (See Appendix 2). ECO Continuous
Contact details of emergency personnel must be readily
available on-site. ECO Continuous
Fire-fighting equipment must be readily available on-site and
these must be maintained and regularly checked. ECO Continuous
The necessary protective clothing must be provided by IGE and
worn on-site by the relevant personnel. ECO Continuous
Visitors to the site must wear the appropriate protective clothing. ECO Continuous
Ablution facilities and rest areas must be designated and kept
neat and tidy. ECO Continuous
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
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8.4 CLOSURE
The facility is planned to operate permanently. If decommissioning is to take place a decommissioning plan must be developed. Given
that de-commissioning is not reasonably anticipated to occur in the foreseeable future, this EMP covers only a limited set of impacts
related to de-commissioning which are foreseeable.
Table 8-4: Environmental Management Plan – Decommissioning Phase
ASPECT POTENTIAL
IMPACT/RISK/ISSUE
MANAGEMENT ACTIONS & MONITORING RESPONSIBILITY FREQUENCY
4. Closure
4.1 Permanent
closure and
decommissioning
Legal Compliance &
Planning
A decommissioning plan must be formulated prior to
commencement of decommissioning. Relevant environmental
legislation in force at the time must be consulted to ensure that
decommissioning is undertaken in accordance.
ECO, PSM
Once off at
the time of
decommission.
Recyclable/Recoverable
Waste
All recyclable waste must be recovered and passed on to
appropriate recycling operators. This includes steel, plastics,
glass etc. ECO, PSM
Once off at
the time of
decommission.
Non-Recyclable Waste
Non-recyclable waste must be disposed of to an appropriate
disposal facility in accordance with legislation in force. ECO, PSM
Once off at
the time of
decommission.
Noise
De-commissioning activities which may result in significant noise
must be undertaken during general business hours where they
occur during the week.
PSM
Once off at
the time of
decommission.
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
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9 ENVIRONMENTAL INCIDENTS
An environmental incident is defined as any unplanned event that results in actual or
potential damage to the environment, whether of a serious or non-serious nature. An
incident may involve non-conformance with any of the following:
• Legal requirements;
• Requirements of the EMP;
• Conditions/Requirements of the WML; and
• Any verbal or written order given by the ECO/PSM on-site.
Corrective actions to mitigate an incident must be appropriate to the nature and scale
of the incident. Any residual environmental damage caused by the incident or by the
mitigation measures themselves must also be rehabilitated. The contractor must also
change his/her operating procedures, where applicable, to prevent a recurrence of
an incident.
The ECO must inform the PSM of serious incidents immediately upon occurrence of the
incident. The ECO must complete an Incident Report for all environmental incidents.
The ECO shall investigate incidents with a view to determine the cause of the incident
and to prevent a recurrence of similar incidents (not to apportion blame).
The ECO must maintain Incident Reports for inspection by the environmental authority if
required, and for reporting as part of audit reports. In the case of serious incidents or
emergencies, the incident report must be sent to the authority as soon as possible after
the incident has been recorded.
10 CONCLUSION
This EMPr and associated Basic Assessment have been compiled in terms of the
provisions to meet regulatory requirements under the National Environmental
Management Act (Act No. 107 of 1998)[NEMA] and its associated 2014 EIA Regulations.
This EMP addresses potential environmental impacts on all relevant aspects related to
activities on the site and allows for continuous improvement through regular monitoring
and reporting to IAPs and relevant spheres of Local, Provincial and National
Government.
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
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11 UNDERTAKING
(Note, undertaking to be signed by appointed the PSM and/or ECO prior to
construction)
I, ________________________________________________________________________
the undersigned, and duly authorised thereto by Industrial Green Energy Solutions (Pty)
Ltd have studied and understand the contents of this document in its entirety and
hereby duly undertake to adhere to the conditions as set out therein.
Signed at _________________________________________________
this _______ day of ________________________
Applicant’s name:
Designation:
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 34
APPENDIX 1: EAP CURRICULUM VITAE
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
Surname: Abdul Ebrahim
Date of birth: 07 December 1977
Country of Residency: Republic of South Africa
Position: Director
Key Qualifications: BEng (Hons) Environmental, BEng (Hons) Mechanical
Registrations: ECSA, EAPASA
Contact details
: 011 7186380
: 072 268 1119
: abdul@escience.co.za
Abstract
Abdul Ebrahim is a director of EScience Associates, an environmental consultancy specialising in waste and waste recovery, effluent, atmospheric emissions and air quality, as well as cleaner and renewable energy. EScience Associates caters for a diversity of industries and economic sectors and has forged strong relationships with other specialists, and specialist agencies, allowing the company to deal with complex and contentious environmental problems. Abdul Ebrahim holds a BEng (Hons) in both Mechanical and Environmental Engineering disciplines. He specialises in air quality management, hazardous waste management and cleaner production, as well as their related environmental authorisation and licensing processes. His work experience includes numerous environmental impact assessments, cleaner production, waste recover-recuse-recycling, hazardous waste management assessments, and air quality impact management projects in power generation, manufacturing, minerals processing, and mining industries. His interests range from atmospheric modelling and wind energy, to the beneficial use of industrial wastes and effluents. He is a certified Environmental Assessment Practioner (EAP) and member of amongst other professional organisations: Engineering Council of South Africa (ECSA), and the National Association of Clean Air (NACA). Abdul has provided Honours level lecturing at the University of Pretoria, UNISA, Cape Town University of Technology and various private training institutions in the fields of Environmental Compliance Enforcement, Environmental Impact Assessment, Cleaner Production and Air Quality Management since 2005. His work experience includes:
• Environmental strategic, legal, and technical compliance advisory services
• Environmental Permitting - Environmental Authorisation, Waste Management Licensing, Atmospheric Emissions Licensing, Mine Environmental Management Programme development, and their relating environmental impact assessment and stakeholder engagement processes.
• Air quality management and Air Quality Management Plan development – Emissions quantification; meteorological and air quality modelling and impact assessment; development of emissions abatement and management strategies;
• Waste management consulting - classification, landfill assessment, mine residue liner risk assessments, development of waste minimisation treatment & recycling strategies;
• Development of specialist training courses (including EIA Administration and Review, Environmental Enforcement, Environmental Compliance Achievement for Industry).
• Environmental Due Diligence – due diligence assessment to inform purchase or ownership transfer of existing going concerns or proposed new establishments.
Abdul has 20 years post graduate experience of which four years are in industry, and the remainder in consulting.
Education
BEng (Hons) Mechanical Engineering
BEng (Hons) Environmental Engineering
Languages
English (excellent speaking and writing) Limited French and Portuguese
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
Experience
Personal work experience includes:
• Cleaner and renewable energy strategy development, plan and project development;
• Technical and environmental due diligence – industrial and energy projects
• Waste management (classification, handling, storage, and disposal requirements;
• Development of waste minimisation treatment & recycling strategies);
• Air quality management and emissions inventorying¸ development of abatement and management strategies;
• Environmental Impact Assessment and Permitting
• Development and dissemination of specialist training for government and the private sector at NQF level 7 (honours degree).
Abdul’s work experience in a wide diversity of economic sectors and industries and provides him with a good understanding of both small scale and large scale impacts of waste and pollution, as well as keeping up to date with various management alternatives available and their individual advantages and disadvantages, both locally and internationally implemented and pilot scale. Various waste streams have been dealt with to determine the most applicable disposal methods and impacts on the environment, from various industries:
• Metallurgical processes
• Power generation
• Food processing
• Waste recovery, reuse, and recycling and waste to energy
• Mining
• Cement manufacturing
• General Commercial – General waste management from various industries
Professional Registration
Environmental Assessment Practioner (EAP) Engineering Council of South Africa (ECSA
Hourly Rate
Nature of expertise offered
• Ability to interpret and analyse technical material on wide range of subjects
• Engineering expertise in energy, waste, air quality and multi-disciplinary subjects
• Ability to undertake technology feasibility studies, technical and financial due diligence
• Understanding of the green economy and technologies, ICT and agricultural and agro-processing sectors
• Ability to undertake a market research and investigation into the industry
• Proposal evaluation expertise
Experience and relevant projects
1. AIR QUALITY MANAGEMENT:
1.1 Government & Regulatory
o Vaal Triangle Air-shed Priority Area - Air Quality Management Plan review, development of emissions inventory and Ambient Air Quality Impact Assessment.
o Highveld Priority Area Air Quality Management Plan – development of emissions inventory, and mitigation strategies.
▪ Reference: Dr Thulile Mdluli
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
▪ Tel: 012 310 3436
▪ Email : tmdluli@environment.gov.za
o Ekurhuleni Metropolitan Municipality - Development of an Air Quality Management Plan (AQMP)
▪ Reference: Mr Edmund van Wyk
▪ Tel: 011 999 2470
▪ Email: Edmund.vWyk@ekurhuleni.gov.za
o Nkangala District Municipality - Development of an Air Quality Management Plan (AQMP) ▪ Reference: Mr Vusi Mahlangu
▪ Tel: 013 249 2164
▪ Email: Mahlangumv@nkangaladm.gov.za
o North West Province - development of provincial emissions inventory (PM, NOx, SO2 etc)
o Development of National Air Quality Officers Companion Guide for the Republic of South Africa
o Development of the atmospheric emissions licensing department for Nkangala District Municipality
o EThekwini Municipality (Durban) - Greenhouse gas emissions quantification
o Newcastle Local Municipality - Development of an Air Quality Management Plan (AQMP) ▪ Reference: Mr Phelelani Ntshingila
▪ Tel: 034 328 3300
▪ Phelelani.Ntshingila@newcastle.gov.za
1.2 Industrial and Mining
o A large variety of major industrial and mining operation across the Highveld and Vaal Triangle as part of Highveld Priority Area and Vaal Triangle Air-shed Priority Area AQMP projects.
o Lanxess CISA Chrome Chemicals Plant Expansion, CO2 generation, Power Generation and hazardous waste treatment and recovery
o Samancor Chrome Proposed Chrome Chemicals plant
o Karbochem (Synthetic Rubber Manufacture) proposed Power Generation Plant
o PPC Cement Slurry Cement Plant Expansion
o PPC Cement Jupiter Cement Plant Expansion
o PPC Cement PE Cement Plant Expansion
o PPC Cement Dwaalboom waste heat recovery
o PPC Cement De Hoek, PE, Slurry, and Dwaalboom postponement applications
o Afrisam Cement - Dudfield Environmental Management Programme update.
o ClinX Medical Waste Incineration plant expansion
o Goedemoed organic waste incineration
o AWPP pyrolysis of organic waste
o Interwaste Waste Recovery, Waste to Energy and Waste Incineration plant
o Eskom power generation emissions off-setting
o Hayes Lemmerz SA Aluminium Wheel Manufacturing
o Evraz Highveld Steel and Vanadium proposed Powered Generation - Furnace Off-Gases
o Assmang Ferrochrome and Ferromanganese plants Powered Generation - Furnace Off-Gases
o Resource Generation Proposed Boikarabelo Power Station – coal fired
o Weir Minerals Africa (Isando, Alrode and Heavy Bay Foundries)
o Goedemoed Prison proposed Waste incineration and Landfill
o Consolidated Wire Industries Expansion
o Sylvania Proposed Open Cast PGE Mine and Processing Plant
o Assmang Black Rock proposed manganese mine expansion and sinter plant
o Assmang machadodorp proposed smelter plant expansion and cross-over to manganese
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
o Dwarsrivier Chrome Mine
o Nkwe proposed Platinum Mine
o Agricultural Research Commission hazardous and infectious waste incineration
o Sephaku Aganang proposed use of AFR’s in cement manufacture
o Idwala Phalaborwa atmospheric emission licence for magnetite drying
o Mandini Wealth (Pty) Ltd tyre pyrolysis air quality health risk assessment
o Johnson Tiles a Division of Norcros Sa (Pty) Ltd Air quality health risk assessment
o Lanxess CISA (Pty) Ltd Air quality health risk assessment
o Namakwa Sands, South Africa – Tronox
o Devon Valley Landfill expansion
o Groblersdal limestone mine
2. WASTE CLASSIFICATION, HAZARD RISK ASSESSMENT AND MANAGEMENT
o Weir Minerals Africa
o Heavy Bay foundry Port Elizabeth
o Lafarge Gypsum
o Consolidated Wire Industries
o BPB Gypsum
o PG Bison melamine plant
o ABBW Electrical manufacturing plant
o CBI copper and fibre optical cable manufacture
o Holcim Cement
o Lanxess Chrome Chemicals
o Assmang Chrome
o Assmang Manganese
o Hayes Lemmerz SA Aluminium Wheel Manufacturing
o Auto industrial group (Pty) Ltd
o CBI Electrical
o Various mining residues
3. ENVIRONMENTAL IMPACT ASSESSMENT:
o Assmang Black Rock Mine expansions, tailings facilities, water treatment facilities
o Highveld Steel furnace off-gas power generation
o Lanxess CISA chrome chemicals plant expansion and hazardous waste landfilling
o Samancor chrome chemicals plant development
o Hernic Ferrochrome power generation from furnace off-gases
o Kanhym Biogas project
o Alumicor secondary aluminium recovery rotary salt furnaces
o Hays Lemmerz Aluminium smelters, furnace and alloy die casting
o Agricultural Research Commission hazardous waste incineration plant
o Darkling Metal Industries
o Idwala Lime Danielskuil asbestos waste disposal
o Plettenburg Polo Estates
o PG Bison Decorative Panels
o British Aerospace Land Based OMC Systems
o BPB Gypsum phosphogypsum plant
o Extrupet HPDE and PET recycling plants
o Assmang BRMO
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
o Assmang Machadodorp
o Interwaste waste recovery and waste to energy plants
o PPC Cement expansions, electricity generation, use of alternative fuels and resources
o Sephaku cement use of alternative fuels and resources
o ClinX Healthcare Risk Waste Management
o Turfontein Race Course night racing
4. ENVIRONMENTAL LEGAL COMPLIANCE ASSESSMENT & RECTIFICATION PLANNING:
o SASOL Synfuels
o NATCOS Petrochem
o Dwarsrivier Chrome Mine
o Angloplatinum Base Metals Recovery
o Samancor Hotazel Manganese Mines
o PG Bison (Pty) Ltd MDF manufacturing
o Samancor Manganese Division Samancor Metalloys Meyerton
o Holcim SA (Pty) Ltd Cement Plants: ▪ DUDFIELD ▪ ULCO ▪ ROODEPOORT
o Natal Portland Cement Plants: ▪ NEWCASTLE
o Consolidated Wire Industries
o South African Airways (Pty) Ltd Technical Division
o TWK forestry strategic environmental legal compliance assessment
o Inergy Automotive Systems(Pty) Ltd
o Consolidated Wire Industries
o Mittal Steel Vereeninging and Dunswart plants – specialist assistance to DEAT environmental management inspectors
o Assmang Black Rock Mining Operations
o ClinX Medical Waste Management
o Extrupet PET and HDEP recycling plants
o Scaw Metals High Chromium Ball Plant
o Unilever waste recovery, recycling, and zero waste-to-landfill
o Numerous waste recycling facilities
o Oilflow
o The Smart Company
o Darkling Industrial Metals CC
o Unilever waste recovery, recycling, and zero waste-to-landfill
o Central Waste
o AT Packaging
o EWaste Africa
o Mpact Recycling
o Wasteplan
o Fine Metals
o Living Earth
o Industrial Plastic Recyclers
o SA Paper Mills
o Interwaste
o Matchem
o TGS
o Verigreen
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
o SB Boxes
o Drumpal
o Oscars Meat
o FOSECO South Africa (Pty) Ltd
o
5. GREENHOUSE GAS QUANTIFICATIONS AND ASSESSMENTS
o PPC Riebeeck
o Lafarge Licthenburg
o Ilangabi Investments coal mining
o Lanxess CISA (Pty) Ltd
o Consolidated Wire Industries
o ClinX Waste Management
o ArcelorMittal Newcastle
o Development of emission factors for ferrochrome smelting
6. CLEANER PRODUCTION AUDITS, WASTE TO ENERGY, ENERGY RECOVERY, WASTE RECOVERY AND
RELATED PROJECTS:
o Tuffy Plastics
o Proplas plastics
o WHS Distribution
o Premier Foods Pretoria Wheat Mill
o Alfred Nzou municipality
o Lanxess chrome chemicals residue recovery
o Karbochem power generation ash to bricks project
o Cement kilns alternative fuels and raw materials assessment for South Africa
o Kanhym Estates Biogas Generation from piggery effluent
o British American Tobacco:
o Tobacco Processors Zimbabwe
o Souza Cruz Brazil
7. ENVIRONMENTAL MANAGEMENT SYSTEM DEVELOPMENT & IMPLEMENTATION: ▪ British American Tobacco (full system development from scratch – ISO 14001 and ISO 9001)
o Weir Minerals Aspects Identification, Rating, Assessment and Development of EMPs
o Lafarge Gypsum Aspects Identification, Rating, Assessment and Development of EMPs
o Environmental Aspects Identification, rating and formulation of EMPs for Samancor Metalloys Meyerton
o Environmental Aspects Identification, rating and formulation of EMPs for DMS Powders.
o Holcim Slagment development & implementation of EMS components including waste and air quality management
o Holcim Roodepoort development & implementation of EMS components including waste and air quality management
o Consolidated Wire Industries Environmental Aspects Identification, rating and formulation of EMPs and operational control procedures.
o Samancor Metalloys Ferro Silicon Manganese and FerroSilicon production
o DMS FeSi dense media prodcution
8. ISO14001 AUDITING:
o Debswana Orapa and Letlhakane Mines
o Ingwe Colliery
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
o Arnot Colliery
o FOSECO South Africa (Pty) Ltd
o Lafarge Gypsum
o CWI
9. SPECIALIST TRAINING COURSE DEVELOPMENT & PRESENTATION
o 2011 Training of Atmospheric Emissions Licensing Authorities – air quality management, emissions quantification, regulation and enforcement.
o 2007-2015 Training of Authorities for EIA review and permiting
Responsible for development of NEMA EIA Review Course and Administrators EIA Review Manual, theoretical and
practical training material, and training of Government Officials responsible for EIA Review - responsible for the whole
manual other than Law applicable to EIA Review. As at May 2013 approximately 1000 officials from National,
Provincial and Local Government.
o 2005&6 Bridging Training for Environmental Management Inspectors and Enforcement
ESA was part of a consortium selected to develop and conduct the EMI Training. More than 2000 officials and
university students have completed the training.
o University Of Pretoria Specialist Lecturer
- Environmental Legal Compliance inspections and investigations (RSA)
- Environmental Legal Compliance achievement (RSA)
- Environmental Legal Compliance inspections and investigations (Africa)
o University Of South Africa Specialist Lecturer
- Environmental Legal Compliance inspections and investigations (RSA)
o Training for industry and mining
Development and presentation of training material for environmental impact identification and management in terms
of South African environmental law for the SABS and other training institutions.
10. SOIL AND GROUNDWATER CONTAMINATION ASSESSMENT:
o Weir Heavy Bay Foundry
o Lafarge Gypsum
o Kanhym Estates
o SABAT (Pty) Ltd Johannesburg – investigation of heavy metal contamination of soils and groundwater
o Chemiphos SA (Pty) Ltd – investigation of phosphate and heavy metal contamination of soils and groundwater
o Castrol Lubricants Zimbabwe
11. ENVIRONMENTAL DUE DILIGENCE AUDITS, INCLUDING ASSESSMENT OF ENVIRONMENTAL AND CLOSURE LIABILITY:
o Determination and quantification of financial provision for the environmental rehabilitation and closure requirements of smelting operations for Highveld Steel & Vanadium operations:
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Abdul
Ebrahim
▪ HIGHVELD IRON AND STEEL WORKS ▪ VANCHEM ▪ TRANSALLOYS ▪ RAND CARBIDE ▪ MAPOCHS MINE
o Determination and quantification of financial provision for the environmental rehabilitation and closure requirements of smelting operations for TransAlloys
o Determination and quantification of financial provision for the environmental rehabilitation and closure requirements of mining operations for Samancor Chrome:
▪ MIDDELBURG FERROCHROME ▪ FERROMETALS ▪ TUBATSE FERROCHROME ▪ WESTERN CHROME MINES ▪ EASTERN CHROME MINES
o Determination of critical environmental liability associated with the purchase of Xmeco Foundry by Weir Minerals Africa, and subsequent legal compliance achievement programme
12.
Possible timelines to commit to the assignment
• Available for assignments over the next two years
• Not available during the December holiday period - from 15 December until 3 January – due to company’s closure for the festive season
Page 1 of 2
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Sam Leyde
Surname: Leyde
Name: Sam
Date of birth: 25 November 1985
Nationality: RSA
Position: Environmental Consultant
Key Qualifications: BSc(hons) Mechanical Engineering
Contact details
: 011 7186380
: sam@escience.co.za
Abstract
Sam Leyde is an employee of EScience Associates, an environmental consultancy specialising in waste and waste recovery, effluent, atmospheric emissions and air quality, as well as cleaner and renewable energy. EScience Associates caters for a diversity of industries and economic sectors and has forged strong relationships with other specialists, and specialist agencies, allowing the company to deal with complex and contentious environmental problems. Sam Leyde holds a BSc (Hons) in Mechanical Engineering. He specialises environmental authorisation and licensing processes. His work experience includes numerous environmental impact assessments, , waste recover-recuse-recycling, waste disposal and classification assessments, and air quality impact management projects in the manufacturing sector. Sam has 8 years post graduate experience of which 7 years are in industry, and the remainder in engineering.
Education
BSc (Hons) Mechanical Engineering
Languages
English (excellent speaking and writing)
Experience
Personal work experience includes:
• Environmental Authorisation, Waste Management Licensing, Atmospheric Emissions Licensing, Environmental Management Programme development, and their relating environmental impact assessment and stakeholder engagement processes.
• Waste management (classification, handling, storage, and disposal requirements, development of waste minimisation treatment & recycling strategies);
• Air Quality Impact Assessments;
• External Environmental Auditing – due diligence assessment to inform purchase or ownership transfer of existing going concerns or proposed new establishments.
Experience and relevant projects
1. ENVIRONMENTAL IMPACT ASSESSMENT:
o EIA for Sephaku Aganang proposed use of AFR’s in cement manufacture
o EIA for PPC Cement Slurry Cement Plant Expansion
o Extrupet HPDE and PET recycling plants
o Assmang Machadodorp Reverse Osmosis Plant and Stormwater Upgrades;
o Interwaste Waste Recovery and Waste to Energy Plant
o ClinX Healthcare Risk Waste Management
Page 2 of 2
EScience Associates
9 Victoria Road, Oaklands
Johannesburg, 2192
Tel: +27 (0)11 718 6380
Curriculum Vitae:
Sam Leyde
Experience and relevant projects
o EIA for proposed Refuse Derived Fuel Energy Recovery Facility, Athlone, Cape Town;
o EIA for proposed pyrolysis of organic/abattoir waste – Square Root Trading Seven, Kroonstad;
o EIA for Interwaste proposed Waste to Energy and Waste Incineration plant;
o EIA Sylvania Proposed Open Cast PGE Mine and Processing Plant;
o EIA for Assmang Machadodorp proposed water treatment plant;
o Basic Assessment for Assmang Machadodorp Storm Water management upgrades;
o Water Use License Application for Assmang Machadodorp Storm Water management upgrades and water treatment facility;
o Water Use Licence for SA Dorper Leather Tannery;
o Oilflow oil blending facility
o The Smart Company Copper melting facility
o Darkling Industrial Metals CC – Scrap Metal Recovery Facility
2. ENVIRONMENTAL LEGAL COMPLIANCE AUDITING & RECTIFICATION PLANNING:
o FFS Refiners, Storage facility Evander 2013 and 2019
o Assmang Black Rock Mining Operations
o ClinX Medical Waste Management
o Extrupet PET and HDEP recycling plants
o Scaw Metals High Chromium Ball Plant
o Oilflow oil blending facility
o The Smart Company Copper melting facility
o Darkling Industrial Metals CC – Scrap Metal Recovery Facility
3. AIR QUALITY MANAGEMENT:
o AQIA for Sephaku Aganang proposed use of AFR’s in cement manufacture
o AQIA for PPC Cement Slurry Cement Plant Expansion
o Lanxess CISA Chrome Chemicals Plant Expansion, CO2 generation, Power Generation and hazardous waste treatment and recovery
o ClinX Medical Waste Incineration plant expansion
o Interwaste Waste Recovery, Waste to Energy and Waste Incineration plant
o Weir Minerals Africa (Isando, Alrode and Heavy Bay Foundries)
o Sylvania Proposed Open Cast PGE Mine and Processing Plant
o Agricultural Research Commission hazardous and infectious waste incineration
o Johnson Tiles a Division of Norcros Sa (Pty) Ltd Air quality health risk assessment
o Proposed pyrolysis of organic/abattoir waste – Square Root Trading Seven, Kroonstad;
4. WASTE CLASSIFICATION, HAZARD RISK ASSESSMENT AND MANAGEMENT
o Weir Minerals Africa
o Wispeco Aluminium
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 35
APPENDIX 2: INCIDENT REGISTER
This is record of incidents as defined in NEMA, NEMWA and the NWA. Incidents must be recorded and reported to the applicable
authorities.
Date of
Incident Details of Incident
Responsible
party/ies Corrective action taken
Date action
completed.
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 36
APPENDIX 3: TRAINING RECORD
Date of
Training Name of Attendee Signature
Details of
Training Course
Training
provided by
(Name)
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 37
APPENDIX 4: NON-CONFORMANCE RECORD
This is record of non-compliances with the EMP, i.e. any action taken that is in violation of the EMPR must be recorded e.g. site staff using
neighbouring properties as toilet facilities, dumping of material outside demarcated areas etc.
Date of non-
conformance
Details of non-
conformance
Party/ies responsible Corrective action taken Date action
completed
ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT
Proposed Waste Pyrolysis Facility, Industrial Green Energy Solutions (Pty) Ltd, Centurion, Gauteng
EScience Associates (Pty) Ltd Page 38
APPENDIX 5: COMPLAINTS REGISTER
Date of
complaint
Details of complaint Complainant Details Corrective action taken Date action
completed