proposed waste pyrolysis facility, industrial green energy ...

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:

[email protected]

ESCIENCE


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: [email protected]

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


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

mailto:[email protected]




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.



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.



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


Noise generation during decommissioning activities. - Low Negligible

Waste generation during decommissioning of

infrastructure. - Low Negligible

Dust generation during decommissioning activities. - Negligible Negligible



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.



EScience Associates (Pty) Ltd Page vi

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



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



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



EScience Associates (Pty) Ltd Page ix

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



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



EScience Associates (Pty) Ltd Page xi

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



EScience Associates (Pty) Ltd Page 1

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


Category A

– Activity (3)




Reason: Recycling of up to 40 tons/day general waste (wax and plastics)

to produce fuels

Category A -

Activity (5)






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)




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).




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




• Alternative Location:



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


385 Knopjeslaagte

T0JR00000000038500109


385 Knopjeslaagte

T0JR00000000038500331




Figure 1-1: Proposed site locality




Figure 1-2: Proposed site locality - Zoomed




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


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 [email protected]

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





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 –



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




Table 1-8:Authorised activities for preferred location (ref GAUT 002/ 17-18/E0184)

Activity


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


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




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


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—



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 –



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


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


bioregional plans; or

The specialist studies that were undertaken as part of this application for Environmental

Authorisation included:




• Fauna and Flora Habitat Assessment


• Services Report

• Traffic impact Study





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.




Figure 2-1: Process Flow Diagram




Figure 2-2: Proposed Site Layout




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.




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




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.




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




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.




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




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




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.




• 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




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.




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;




(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




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




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


Category A

– Activity (3)




Reason: Recycling of up to 40 tons/day general waste to produce fuels

Category A -

Activity (5)






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)




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.




Figure 4-1: Basic Assessment Process




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




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.




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




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




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







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


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.




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.



Symbol

Plant

Status

mg/Nm3 under

normal conditions


kPa


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.



Symbol

Plant

Status

mg/Nm3 under

normal conditions


kPa

Particulate matter N/A New 10

Existing 25

Carbon monoxide CO New 50




Table 4-9: GN 893:2013 Subcategory 8.1: Thermal Treatment of Hazardous and

General Waste






Symbol

Plant

Status

mg/Nm3 under

normal conditions


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;




• 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”.




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.




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.




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.




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.




Figure 7-1 Land cover at the site and surrounding areas




Figure 7-2: Surrounding Land Use




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.




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




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




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




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





• Wetland Assessment


• Service Report

• Traffic Impact Study

• Storm Water Management Report

Alternative Location:

• Fauna and Flora Habitat Assessment


• Services Report

• Traffic impact Study


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.




Figure 7-11: Photograph 1 of preferred location





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





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.




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

https://screening.environment.gov.za/screeningtool/index.html#/pages/welcome




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


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.

https://sahris.sahra.org.za/map/palaeo




Figure 8-1: Palaeontological sensitivity Map (https://sahris.sahra.org.za/map/palaeo)

8.1.4 TERRESTRIAL BIODIVERSITY IMPACT ASSESSMENT


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


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


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

https://sahris.sahra.org.za/map/palaeo




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


Limeroc Business Park. There will be no clearance of vegetation. A Plant Species Assessment

is therefore deemed unnecessary.

8.1.12 ANIMAL SPECIES ASSESSMENT


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.




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.




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:




• 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]




• 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.




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.




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.




• 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


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.


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


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


• 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.

11.1.3 WASTE GENERATION, HANDLING AND DISPOSAL


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.


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


Negative Impact (S)

N x (E+D) x I x P ÷ ½(M+R) Low 16

Significance Rating

with Mitigation -

Negative Impact (S)



• 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


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




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.


Table 10-6: Air Quality – Dust Generation (Construction)

Nature (N) Negative impact on ambient air quality. 1


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


of the construction 4

Significance Rating


Negative Impact (S)


Significance Rating

with Mitigation -

Negative Impact (S)



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.


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


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.

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.




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)




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.




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.




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


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.


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




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



Significance Rating


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


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


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.











• 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


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.


Noise during operational activities of proposed infrastructure and equipment is expected

to have no significant impact outside of the site provided that the recommended


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



Significance Rating


Negative Impact (S)

N x (E+D) x I x P ÷ ½(M+R) Low 14

Significance Rating

with Mitigation -

Negative Impact (S)



• Noise generating activities should be limited to normal working hours, in accordance





• 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.




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


SS3 Scrubber


SS4 Scrubber


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


AS3

Alternative

Scrubber

Stack 3


AS4

Alternative

Scrubber

Stack 4





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.




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


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).




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






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


SULPHUR DIOXIDE 1-HOUR






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


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).




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


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.




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.






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.






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




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


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




11.2.3.3 IMPACT DISCUSSION & SIGNIFICANCE ASSESSMENT - SCENARIO 2:

ALTERNATIVE LOCATION EMISSIONS








regulations.

PARTICULATE MATTER PM10 - 24 HOUR




concentration.

PM10 - ANNUAL



PM2.5 - 24 HOUR







concentration.

PM2.5 - ANNUAL



SULPHUR DIOXIDE 1-HOUR







concentration.

24-HOUR



ANNUAL



NITROGEN DIOXIDE 1-HOUR







concentration.

ANNUAL



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




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.


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.







PREDICTED LIFETIME CARCINOGENIC RISK USING THE US EPA RFC











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.



METALS AND OTHER POLLUTANTS









in Table 10-13





Name Symbol Modelled Emission

Limits (mg/Nm³)

Ambient Air Quality

Limit (μg/m³)

Predicted Maximum Ambient


Averagin

g time

Country /

agency





10 000 2.9957 8 hr SA

Ammonia NH3 10

350 1.4978 1 h Michigan

100 0.3319 24 h Ontario











Nickel Ni 0.05 0.2 0.0017 24 h Ontario


Vanadium V 0.05 1 0.0017 24 h WHO


1 0.0002 Annual WHO


20 0.3315 24 h Ontario


0.86 0.0166 24 h Ontario


PCDF

ng I-TEQ/Nm³ pg I-TEQ/Nm³

0.1 0.1 0.000003 24h Ontario




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


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.


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


It is envisaged that the plant will employ approximately 11 people during operations.


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




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


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.


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




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



Significance Rating


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


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


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.


Noise during decommissioning activities of proposed infrastructure and equipment is

expected to have no significant impact outside of the site provided that the recommended


Table 10-17: Noise impacts (Decommissioning)

Nature (N) Negative impact: Decommissioning related activities

to be limited to normal working hours, in accordance


1


surrounds

2




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



Significance Rating


Negative Impact (S)

N x (E+D) x I x P ÷ ½(M+R) Low 16

Significance Rating

with Mitigation -

Negative Impact (S)



• 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


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.


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


of the construction. 4




Table 10-18: Waste generation impact (Decommissioning)

Significance Rating


Negative Impact (S)

N x (E+D) x I x P ÷ ½(M+R) Low 16

Significance Rating

with Mitigation -

Negative Impact (S)



• 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.








11.3.4 AIR QUALITY – DUST GENERATION


During decommissioning, it is not anticipated that rehabilitation will be required. Dust

generation would potentially come from the potential demolition of buildings.


Table 10-19: Air Quality – Dust Generation (decommissioning)

Nature (N) Negative impact on ambient air quality. 1


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


of the decommissioning phase 4

Significance Rating


Negative Impact (S)


Significance Rating

with Mitigation -

Negative Impact (S)






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,


predicted.




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.




Table 12-1: Impact Summary

Impact

( - / +)

Impact significance without

mitigation

Impact significance with

mitigation

Construction phase:

Potential impacts on soil and groundwater quality





Archaeological and cultural impacts - No impact (refer to section 0)

Operational phase:

Potential impacts on groundwater quality during

operations - Moderate Negligible



Air Quality Low to negligible (refer to section 9.1)




Potential impacts on surface and groundwater quality



Waste generation during decommissioning of

infrastructure. - Low Negligible





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).




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,


predicted.




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




APPENDIX 1: PUBLIC PARTICIPATION DOCUMENTATION

APPENDIX 1.1 PROOF OF ADVERTISEMENTS

Advert and site notice wording




Proof of Advert – The Star 16 July 2020




Proof of Advert – Pretoria News 16 July 2020




Proof of Advert – Fourways Review 31 July 2020




APPENDIX 1.2 PROOF OF SITE NOTICES

Site notice put up at main security entrance to Limeroc business Park




Site notice put up at main security entrance to Limeroc business Park




Site notice put up on fence of preferred site




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) [email protected] 0829354287

Brink Cilliers Constituency Head (106, 48, 77) [email protected] 0674079701

Surrounding Wards

Wakelin Kingsley Neighbouring Ward Councillor - Ward 48 (Tshwane) [email protected] 0824984356

Cox Sean Neighbouring Ward Councillor - Ward 77 (Tshwane) [email protected] 0729290243

Kreusch Sean Neighbouring Ward Councillor - Ward 113 (COJ) [email protected] 0823020315

Kreusch Sean Neighbouring Ward Councillor - Ward 95 (COJ) (Diepsloot)

[email protected]

0823020315

Foley David Neighbouring Ward Councillor - Ward 94 (COJ) [email protected] 0829025003

Mackenzie Cameron Constituency Head (113, 94, 95) [email protected] 0836944510

Authorities

Mahlangu Lucas Department of Environment, Forestry and Fisheries: Waste

[email protected] 012 399 9791

Ramaila Pertunia Department of Environment, Forestry and Fisheries: Waste


Baloyi Tiyani Department of Environment, Forestry and Fisheries: Waste


Patric City of Tshwane: Environmental Management Service

[email protected] 082 499 2445 / 012 358 2347

Moatshe Elizabeth City of Tshwane: Air Quality Officer [email protected] 012 358 8714

Mzondi Sanelisiwe City of Tshwane: Air Quality Officer [email protected] 012 358 6777

Ramogotswa William City of Tshwane [email protected]

Matlou Marcus City of Tshwane [email protected]

Moseta Mmapula City of Tshwane Emergency services:Fire [email protected]


















Surname Name or Initials Organisation / Capacity Email Telephone

Godobedzha Tshifhiwa City of Tshwane [email protected]

072 050 6633/012 358 5599

Mukheli Rudzani City of Tshwane [email protected]

079 958 0360/012 358 8731

Ngati Mosili City of Tshwane [email protected]

084 836 1921/012 358 0277

Mthembu Sibusisio Department of Water and Sanitation [email protected] 082 615 4730/012 392 1300

Khwinana Phillimon Department of Water and Sanitation [email protected] 012 392 1356

National Office Department of Water and Sanitation [email protected]

Baloyi Alice Gauteng Department of Agriculture and Rural Development

[email protected]

Malaza Phindy Gauteng Department of Agriculture and Rural Development

[email protected]

Mathibeli Palesa Gauteng Department of Agriculture and Rural Development

<[email protected]>

Kolisa Mthobeli City of Tshwane: Environment Strategic Executive Director/Infrastructure and community services

[email protected]

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










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.




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.




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

: [email protected]

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


Languages

English (excellent speaking and writing) Limited French and Portuguese

EScience Associates


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


Johannesburg, 2192

Tel: +27 (0)11 718 6380

Curriculum Vitae:

Abdul

Ebrahim

▪ Tel: 012 310 3436

▪ Email : [email protected]

o Ekurhuleni Metropolitan Municipality - Development of an Air Quality Management Plan (AQMP)

▪ Reference: Mr Edmund van Wyk

▪ Tel: 011 999 2470

▪ Email: [email protected]

o Nkangala District Municipality - Development of an Air Quality Management Plan (AQMP) ▪ Reference: Mr Vusi Mahlangu

▪ Tel: 013 249 2164


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

▪ [email protected]

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


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 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


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 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 South African Airways (Pty) Ltd Technical Division

o TWK forestry strategic environmental legal compliance assessment

o Inergy Automotive Systems(Pty) Ltd


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 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


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 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


Johannesburg, 2192

Tel: +27 (0)11 718 6380

Curriculum Vitae:

Abdul

Ebrahim

o Arnot Colliery


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


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


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

of 2

EScience Associates


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

: [email protected]

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


• 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.



o EIA for Sephaku Aganang proposed use of AFR’s in cement manufacture

o EIA for PPC Cement Slurry Cement Plant Expansion


o Assmang Machadodorp Reverse Osmosis Plant and Stormwater Upgrades;

o Interwaste Waste Recovery and Waste to Energy Plant


of 2

EScience Associates


Johannesburg, 2192

Tel: +27 (0)11 718 6380

Curriculum Vitae:

Sam Leyde


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 AQIA for Sephaku Aganang proposed use of AFR’s in cement manufacture

o AQIA for PPC Cement Slurry Cement Plant Expansion








o Proposed pyrolysis of organic/abattoir waste – Square Root Trading Seven, Kroonstad;



o Wispeco Aluminium

EScience Associates


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

: [email protected]

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




APPENDIX 3: AUTHORITY CORRESPONDENCE




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 [email protected]

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.




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 [email protected], reports to be uploaded to sfiler.

application to be emailed to [email protected]





Solutions (Pty) Ltd, Centurion, Gauteng APPENDIX 1: Process Flow Diagram and Locality Map




APPENDIX 3.2: DEFF ACKNOWLEDGEMENT OF RECEIPT OF APPLICATION




APPENDIX 4: SPECIALIST STUDIES




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:

[email protected]

Air Quality Impact Assessment

Industrial Green Energy Solutions (Pty) Ltd Waste Pyrolysis Plant, Centurion, Gauteng


AIR QUALITY IMPACT ASSESSMENT REPORT


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


ON BEHALF OF APPLICANT:

Industrial Green Energy Solutions (Pty) Ltd

8 Summit Road

Knoppieslaagte 385

Centurion

2196

Tel: (012) 940 3471

August 2020




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.

http://www.epa.gov/ttn/atw/nata/gloss1.html



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


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



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



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



EScience Associates (Pty) Ltd Page vi

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



EScience Associates (Pty) Ltd Page vii

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



EScience Associates (Pty) Ltd Page viii

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



EScience Associates (Pty) Ltd Page ix

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




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.


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.




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 [email protected]

After hours Contact Details 083 222 5222




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).




Figure 2-1: Site Location




Figure 2-2: Site Location & Surrounding Land use




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.


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.




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


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




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


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.




Figure 3-1: Site Process Flow Diagram




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




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




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


SS2 Scrubber


SS3 Scrubber


SS4 Scrubber


AS1

Alternative

Scrubber

Stack 1


AS2

Alternative

Scrubber

Stack 2


AS3

Alternative

Scrubber

Stack 3


AS4

Alternative

Scrubber

Stack 4





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


Maximum Release Rate Duration of

Emissions (mg/Nm³) Date to be

Achieved By

Average

Period

SS1 – SS4,

AS1 – AS4










vanadium

Pb +As+ Sb + Cr +

Co + Cu + Mn+ Ni

+ V



Cadmium Thallium Cd TI 10 Immediate 24 Hours Continuous




Immediate 24 Hours Continuous

0.1





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


Maximum Release Rate Duration of

Emissions (mg/Nm³) Date to be

Achieved By

Average

Period

SS1 – SS4,

AS1 – AS4










vanadium

Pb +As+ Sb + Cr +

Co + Cu + Mn+ Ni +

V



Cadmium Thallium Cd TI 10 Immediate 24 Hours Continuous




Immediate 24 Hours Continuous 0.1





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.




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




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.



PM10 24-hours 75 4 Immediate


NO2 1-hour 200 88 Immediate







SO2

10-min (running) 500 526 Immediate

1-hour 350 88 Immediate



CO 1-hour 30 88 Immediate

8-hours (running)^ 10 11 Immediate


^ 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


PM2.5


25 4 01 January 2030


15 0 01 January 2030





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.




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).



Symbol

Plant

Status

mg/Nm3 under

normal conditions


kPa


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.


Plant

Status

mg/Nm3 under

normal conditions


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




Table 6-5: GN 893:2013 Subcategory 8.1: Thermal Treatment of General and

Hazardous Waste





Plant

Status

mg/Nm3 under

normal conditions


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




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,




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.

http://www.deh.gov.au/atrnosphere/airaualitv/standards.htrnl.

https://www.eea.europa.eu/themes/air/air-quality-standards

https://uk-air.defra.gov.uk/assets/documents/Air_Quality_Objectives_Update.pdf.

http://www.ena.gov/air/criteria.htrnl.

https://www.who.int/news-room/fact-sheets/detail/ambient-(outdoor)-air-quality-and-health





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 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










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



United States EPA*(e) 200


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.


(d). UK Air Quality Objectives. https://uk-air.defra.gov.uk/assets/documents/Air_Quality_Objectives_Update.pdf.




*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.







https://uk-air.defra.gov.uk/assets/documents/reports/cat06/0502160851_Conversion_Factors_Between_ppb_and.pdf





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



United States EPA*(e) 192 101


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.




*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













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).

http://eurona.eu.int/comm/environment/air/ambient.htm

https://www.env.go.jp/en/air/aq/aq.html

http://uk-air.defra.gov.uk/documents/National_air_quality_objectives.pdf

https://www.epa.gov/criteria-air-pollutants/naaqs-table




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


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





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.




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.




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.




Page 31

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


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







7x10-5 μg/m3

(Annual average)



Quebec

(MENV)

8.0x10-5 μg/m3

(Annual average)


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)


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


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.






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)



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


RfC


inhalation unit risk




for permitting.

Initial Risk Screening Level (IRSL).

Secondary Risk Screening Level (SRSL).






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


RfC






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


for permitting.

0.1 μg/m3

(Annual average)


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


RfC

2003 Reference Concentration for

Inhalation.

0.1 μg/m3

For hexavalent chromium particulates


RfC

2003

2.0x10-3 μg/m3

For total chromium


HEAST (1997)

2003

8x10-5 μg/m3



inhalation unit risk value



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)


TLV-TWA

2003 Ambient Guideline Concentration.

Used for permitting.

4.5x10-5 – 0.59 μg/m3

(annual, AGCs)

For various chromium compounds


TLV-TWA

2003 The values for the individual

compounds were adjusted based on

the ratio of the molecular weights.






0.1 μg/m3

(annual, AGC)

For trivalent chromium


TLV-TWA



2.0x10-5 μg/m3

(annual, AGC)


Based on the chronic

REL of the OEHHA for

chromium trioxide as

chromic acid mist



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).


8.3x10-5 μg/m3

For bioavailable chromate pigments and

non-specific hexavalent chromium

compounds, as hexavalent chromium

equivalent





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.


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.






applicable to all forms

of Cr(VI) compounds.

Vermont 8.3x10-5 μg/m3

(Annual average)


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)


Top end of WHO values

but lower than the US

EPA’s carcinogen value.


European

Union (EU)

21 μg/m3

(HT25)


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


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.






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




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.


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



new nuclear power station





Percentage


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).




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


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.




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-


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






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)


Documentation:

Ontario

MOE

Ambient Air

Quality

Criterion

2.5

Ontario Ministry of the Environment.

1999. Point of Impingement Standards,

Point of Impingement Guidelines, and




Table 6-16: 24-Hour Average standards and guidelines for Manganese (Mn)

Country or

Agency Description

Value

(µg/m3)


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)


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,




Table 6-17: 8 Hour and 1 Hour Average standards and guidelines for Manganese

(Mn)

Time

Country

or

Agency

Description Value

(µg/m3)


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).




• 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




Table 6-18: Air Quality Standards for Ammonia (NH3)

Authority

Maximum

1-hour

Concentration

Maximum

24-hour

Concentration

Annual

Concentration


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


California(a) 0.03

Ontario, Canada(b) 2






Table 6-19: Air Quality Standards for Mercury (Hg)

Authority

Maximum

1-hour

Concentration

Maximum

24-hour

Concentration

Annual

Concentration


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,


(d). Michigan Department Environmental Quality - Air Quality Division, List of Screening Levels (ITSL, IRSL and SRSL) in Alphabetical Order,


(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.






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




(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).




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.




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%




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)




**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.


single non-nuclear plant.


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.


Percentage


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





Percentage


0.01% to 0.001% 1 in 10 000 to 1 in 100 000



single non-nuclear plant

0.001% to 0.0001% 1 in 100 000 to 1 in 1 000 000



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).




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).




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




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).




Figure 7-2: SO2 hourly average ambient air quality data from the Diepsloot AAQM

Station.




Figure 7-3: SO2 daily average ambient air quality data from the Diepsloot AAQM

Station.




Figure 7-4: PM10 daily average ambient air quality data from the Diepsloot AAQM

Station.




Figure 7-5: O3 8-hour average ambient air quality data from Diepsloot AAQM Station.




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).




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.




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.




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




Measured Modelled

Autumn

Winter

Spring

Figure 9-2: Average Wind Roses from 2017-2018 for Diepsloot AAQM station




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




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.




Figure 9-3: Average CALMET Modelled Mixing Heights at Industrial Green Energy

Solutions preferred site.




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




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.




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.




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




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




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.




Figure 10-3: The 2017 Diepsloot ambient monitoring station wind speed (top) and wind direction (bottom)




Figure 10-4: The 2018 Diepsloot ambient monitoring station wind speed (top) and wind direction (bottom)




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




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.




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




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.




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




concentration.




11.1.2.1.2 PREDICTED ANNUAL CONCENTRATIONS FOR PM10


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


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




concentration.

11.1.2.2.2 PREDICTED ANNUAL CONCENTRATIONS FOR PM2.5



the maximum PM2.5 concentration occurring over the area for the annual averaging


11.1.2.3 PREDICTED CONCENTRATIONS FOR SO2

11.1.2.3.1 PREDICTED 1 HOUR CONCENTRATIONS FOR SO2







concentration.



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 maximum SO2 concentration occurring over the area for the annual averaging


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




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




concentration.

11.1.2.5.2 PREDICTED ANNUAL CONCENTRATIONS FOR NO2


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


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




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.





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).


11.1.2.6.3 PREDICTED LIFETIME CARCINOGENIC RISK USING THE US EPA RFC



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




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



2015).

11.1.2.8 METALS AND OTHER POLLUTANTS OF CONCERN




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.





Name Symbol

Modelled

Emission

Limits

(mg/Nm³)

Ambient

Air

Quality

Limit

(μg/m³)

Predicted Maximum

Ambient


Averaging

time

Country /

agency





10 000 2.9957 8 hr SA

Ammonia NH3 10

350 1.4978 1 h Michigan

100 0.3319 24 h Ontario











Nickel* Ni 0.05 0.2 0.0017 24 h Ontario


Vanadium V 0.05 1 0.0017 24 h WHO


1 0.0002 Annual WHO


20 0.3315 24 h Ontario





Name Symbol

Modelled

Emission

Limits

(mg/Nm³)

Ambient

Air

Quality

Limit

(μg/m³)

Predicted Maximum

Ambient


Averaging

time

Country /

agency


0.86 0.0166 24 h Ontario


PCDF

ng I-

TEQ/Nm³ pg I-TEQ/Nm³

0.1 0.1 0.000003 24h Ontario

*using Nickel limits for Ni in TSP.




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


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




concentration.

11.1.3.1.2 PREDICTED ANNUAL CONCENTRATIONS FOR PM10



the maximum PM10 concentration occurring over the area for the annual averaging





11.1.3.2 PREDICTED CONCENTRATIONS FOR PM2.5


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




concentration.

11.1.3.2.2 PREDICTED ANNUAL CONCENTRATIONS FOR PM2.5



the maximum PM2.5 concentration occurring over the area for the annual averaging


11.1.3.3 PREDICTED CONCENTRATIONS FOR SO2








concentration.



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 maximum SO2 concentration occurring over the area for the annual averaging


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.




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




concentration.

11.1.3.5.2 PREDICTED ANNUAL CONCENTRATIONS FOR NO2


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





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




cancer.


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.


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 (Herbst, 2015).


11.1.3.6.3 PREDICTED LIFETIME CARCINOGENIC RISK USING THE US EPA RFC



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




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.







2015).

11.1.3.8 METALS AND OTHER POLLUTANTS OF CONCERN




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.





Name Symbol

Modelled

Emission

Limits

(mg/Nm³)

Ambient

Air

Quality

Limit

(μg/m³)

Predicted Maximum

Ambient


Averaging

time

Country /

agency





10 000 9.1008 8 hr SA

Ammonia NH3 10

350 4.5504 1 h Michigan

100 1.4904 24 h Ontario











Nickel* Ni 0.05 0.2 0.0019 24 h Ontario


Vanadium V 0.05 1 0.0019 24 h WHO


1 0.0002 Annual WHO


20 0.3726 24 h Ontario





Name Symbol

Modelled

Emission

Limits

(mg/Nm³)

Ambient

Air

Quality

Limit

(μg/m³)

Predicted Maximum

Ambient


Averaging

time

Country /

agency


0.86 0.0186 24 h Ontario


PCDF

ng I-

TEQ/Nm³ pg I-TEQ/Nm³

0.1 0.1 0.000015 24h Ontario

*using Nickel limits for Ni in TSP.




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.




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%




13 EMERGENCY INCIDENTS

This is not applicable as the facility has not yet been constructed.

14 COMPLIANCE AND ENFORCEMENT HISTORY


15 COMPLAINTS





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


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


as stipulated by Subcategory 3.1, 3.4 and Subcategory 8.1 in GN893:2013, as

amended.

16.1 SCENARIO 1: PREFERRED LOCATION EMISSIONS








regulations.

16.1.1 PARTICULATE MATTER

16.1.1.1 PM10 - 24 HOUR


well within the 24-hour limit, 75 µg/m³.

16.1.1.2 PM10 - ANNUAL



16.1.1.3 PM2.5 - 24 HOUR



16.1.1.4 PM2.5 - ANNUAL






16.1.2 SULPHUR DIOXIDE

16.1.2.1 1-HOUR



16.1.2.2 24-HOUR



16.1.2.3 ANNUAL



16.1.3 NITROGEN DIOXIDE

16.1.3.1 1-HOUR


within the 1-hour limit of 200 µg/m³.

16.1.3.2 ANNUAL



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


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.


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).




16.1.4.3 PREDICTED LIFETIME CARCINOGENIC RISK USING THE US EPA RFC













16.1.5 POLYCYCLIC AROMATIC HYDROCARBONS

16.1.5.1 PREDICTED LIFETIME CARCINOGENIC RISK







2015).

16.1.6 METALS AND OTHER POLLUTANTS






in Table 11-5.

16.2 SCENARIO 2: ALTERNATIVE LOCATION EMISSIONS








regulations.

16.2.1 PARTICULATE MATTER

16.2.1.1 PM10 - 24 HOUR






16.2.1.2 PM10 - ANNUAL



16.2.1.3 PM2.5 - 24 HOUR



16.2.1.4 PM2.5 - ANNUAL



16.2.2 SULPHUR DIOXIDE

16.2.2.1 1-HOUR



16.2.2.2 24-HOUR



16.2.2.3 ANNUAL



16.2.3 NITROGEN DIOXIDE

16.2.3.1 1-HOUR


within the 1-hour limit of 200 µg/m³.

16.2.3.2 ANNUAL



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.




16.2.4.2 PREDICTED LIFETIME CARCINOGENIC RISK USING THE WHO RFC


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.








16.2.4.3 PREDICTED LIFETIME CARCINOGENIC RISK USING THE US EPA RFC













16.2.5 POLYCYCLIC AROMATIC HYDROCARBONS

16.2.5.1 PREDICTED LIFETIME CARCINOGENIC RISK







2015).

16.2.6 METALS AND OTHER POLLUTANTS









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.




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;




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




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




19 REFERENCES

Alberta (2015), Assessment Report on Naphthalene for Developing Ambient Air Quality

Objectives 2013 Update, Alberta Government, Canada, 2015.

Alberta (2016), Alberta Ambient Air Quality Objectives – Naphthalene, AEP Air Policy,

2016, No. 1, September 1, 2016. ISBN 978-1-4601-2581-6 (PDF)

Arsenic Compounds 107-02-8 - EPA 2014 - Online [Accessed]

http://www.epa.gov/ttn/atw/hlthef/antimony.html [17 March 2014].

ATSDR (1992), Agency for Toxic Substances and Disease Registry (ATSDR). Toxicological

Profile for Antimony. U.S. Public Health Service, U.S. Department of Health and

Human Services, Atlanta, GA. 1992.

ATSDR (2004), Toxicological Profile for Copper. Agency for Toxic Substances and Disease

Registry (ATSDR), (2004, September). Provides exposure risks, exposure limits, and

health effects for copper

Canadian Environmental Quality Guidelines, Summary of Existing Canadian

Environmental Quality Guidelines, Canada, 2003

CEPA/FPAC (1998), “Working Group on Air Quality Guidelines” National Ambient Air

Quality Objectives for Particulate Matter, Ministry of Public Works & Government

Services Canada.

Cleaver-Brooks (1998). Boiler Emission Guideline. http://cleaverbrooks.com/reference-

center/insights/CB-7435%20Emissions%20Guide.pdf

Cosijn C. (1995), Elevated Absolutely Stable Layers: A Climatology for South Africa,

Unpublished Msc. Proposal submitted to the Department of Geography and

Environmental Studies, University of the Witwatersrand, Johannesburg.

Cooper, C D and Alley, F C (2002), Air Pollution Control: A Design Approach 3rd ed.

Waveland Press, Illinois, USA.

DEAT (2007), The National Framework for Air Quality Management in the Republic of

South Africa. 2007. Department of Environmental Affairs & Tourism.

Dockery DW, Pope III CA (1994), Acute respiratory effects of particulate air pollution,

Annual Review of Public Health, 15, 107-132.

European Commission (2001), Ambient Air Pollution by Polycyclic Aromatic

Hydrocarbons (PAH): Position Paper

European Council, (2008), Regulation (EC) No 1272/2008 of the European Parliament and

of the Council of 16 December 2008 on classification, labelling and packaging of

http://www.epa.gov/ttn/atw/hlthef/antimony.html

http://cleaverbrooks.com/reference-center/insights/CB-7435%20Emissions%20Guide.pdf

http://cleaverbrooks.com/reference-center/insights/CB-7435%20Emissions%20Guide.pdf




substances and mixtures, amending and repealing Directives 67/548/EEC and

1999/45/EC, and amending Regulation (EC) No 1907/2006. Official Journal of the

European Union, 2008, L353:1–1355.

Herbst MC. (2015). Fact Sheet on the Top Ten Cancers per Population Group. Cancer

Association of South Africa (CANSA).

HEW (2001), Health, Environment and Work: Learning about air quality. Available at

http://www.agius.com

Holness, D L, Purdham, J T and Nethercott, J R, (1989), Acute and chronic respiratory

effects of occupational exposure to ammonia. AIHA J 50: 646-650

Freiman, T and Piketh, S J (2003), “Air Transport into and out of the Industrial Highveld

Region of South Africa” Journal of Applied Meteorology. 2003 (42), 994-1002.

IARC (1990). Chromium, nickel, and welding. IARC Monogr Eval Carcinogen Risks Hum,

49: 1–648. PMID:2232124

IARC (2002), Some traditional herbal medicines, some mycotoxins, naphthalene and

styrene. Lyon, International Agency for Research on Cancer, 2002 (IARC

Monographs on the Evaluation of Carcinogenic Risks to Humans, Vol. 82).

Kiviluoto, M, Räsänen, O, Rinne, A and Rissanen, M (1979a), Effects of vanadium on the

upper respiratory tract of workers in a vanadium factory. Scand J Work Environ

Health 5:50–58.

Kocher, DC and Hoffman, FO (1994), A Proposed Framework for Consistent Regulation

of Public Exposures to Radionuclides and Other Carcinogens. Oak Ridge National

Laboratory, Oakridge, Tennessee, Review Vol. 26, No. 1.

Korte, Nic. A guide to the technical evaluation of environmental data. CRC Press, 1999.

Lewis, C. E. (1959), The biological effects of vanadium. II. The signs and symptoms of

occupational vanadium exposure. AMA Arch Ind Health. 19 (5): 497 – 503.

Li, Chun-Teh & Zhuang, Huan-Kai & Hsieh, Lien-Te & Lee, Wen-Jhy & Tsao, Meng-Chun.

(2001). PAH emission from the incineration of three plastic wastes. Environment

international. 27. 61-7. 10.1016/S0160-4120(01)00056-3.

Niemi (2013), “Acceptable” risk levels for carcinogens: their history, current use, and how

they affect surface water quality criteria Policy Forum #3 February 8, 2013, Human

Health Criteria and Implementation Tools Rule-makings

Nishiyama K, Suzuki Y, Fujii N, Yano N, Ohkita T and Ichikawa A (1978), Effects of the

inhalation of manganese dioxide dust on monkey lungs. Tokushima J. Exp. Med.

25: 119-125

http://www.agius.com/




Pilusa, T.J, Shukla, M and Muzenda, E (2013), Pyrolytic Tyre Derived Fuel: A Review

(International Conference on Chemical. Mining and Metallurgical Engineering

Nov 2013)

Preston-Whyte, R.A. and Tyson, P.D. (1988), The Atmosphere and Weather of Southern

Africa. Oxford University Press, Cape Town, 374pp.

RAIS (Risk Assessment Information System) (1992), Formal Toxicity Summary for chromium.

Prepared by: Mary Lou Daugherty, M.S., Chemical Hazard Evaluation and

Communication Group, Biomedical and Environmental Information Analysis

Section, Health and Safety Research Division*, Oak Ridge, Tennessee. Prepared

for: Oak Ridge Reservation Environmental Restoration Program. *Managed by

Martin Marietta Energy Systems, Inc., for the U.S. Department of Energy under

Contract No. DE-AC05-84OR21400. September 1992.

SANS 1929, SOUTH AFRICAN NATIONAL STANDARD Ambient air quality — Limits for

common pollutants. SANS 1929: 2005. Edition 1.1 ISBN 0-626-16514-8

SANS 1929:2005, SANS 1929:2005 SOUTH AFRICAN NATIONAL STANDARD Ambient air

quality — Limits for common pollutants, Edition 1.1. South African Bureau of

Standards.

Scire, JS, Strimaitis, DG, Yamartino, RJ (1999), A User’s Guide for the CALPUFF Dispersion

Model (Version 5.0). Earth Tech, Concord, MA.

Scire, JS, Strimaitis, DG, and Yamartino, RJ (2000), A User's Guide for the CALPUFF

Dispersion Model (Version 5), Earth Tech Inc.

Schneider, J., Nagl, C. and Read, B., 2014, EU Air Quality Policy and WHO Guideline

Values for Health, Directorate General for Internal Policies, Policy Department A:

Economic and Scientific Policy, IP/A/ENVI/2014-06

Schulze B.R. (1986), Climate of South Africa. Part 8: General Survey, WB 28, Weather

Bureau, Department of Transport, Pretoria, 330 pp.

Susa, D and Haydary, J (2013), Sulphur distribution in the products of waste tyre pyrolysis

www.researchgate.net/publication/257908950_Sulphur_distribution_in_the_products_of

_waste_tire_pyrolysis

TA Luft (2002), First General Administrative Regulation Pertaining the Federal Immission

Control Act (Technical Instructions on Air Quality Control – TA Luft. Joint Ministerial

Gazette (Gemeinsames Ministerialblatt). Federal Ministry of Environment, Nature

Conservation and Nuclear Safety. 24 July 2002. Pg 68.

Turner, D. B (1970). Workbook of Atmospheric Dispersion Estimates. Air Resources Fied

Research Office, Environmentla Science Services Administration. United States

Department of Health, Education, and Welfare. Public Health Service.

Environmental Health Service. National Air Pollution Control Administration.

Cincinnati, Ohio. Revised 1970. Pg 1.




US EPA (1991), United States Environmental Protection Agency. Chromium(VI). Integrated

Risk Information System (IRIS). Environmental Criteria and Assessment Office,

Office of Health and Environmental Assessment, Cincinnati, OH.

US EPA (1995), Control and Pollution Prevention Options for Ammonia Emissions, EPA-

456/R-95-002.

US EPA (1997), “AP42, Compilation of Air Pollutant Emissions Factors” 5th ed.

http://www.epa.gov/ttnchie1/ap42/ [05 July 2010]

US EPA (1998), PEER REVIEW OF THE CALMET/CALPUFF MODELING SYSTEM Authors: K. J.

Allwine Environmental Services, Richland, W. F. Dabberdt National Center for

Atmospheric Research, Boulder, L. L. Simmons Energy and Environmental

Management, Inc., Murrysville, August 28, 1998. Available at

http://www.epa.gov/scram001/7thconf/calpuff/calpeer.pdf

USEPA (1998,) Naphthalene (CASRN 91-20-3). Washington, DC, US Environmental

Protection Agency, 1998 (http://www.epa.gov/ncea/iris/subst/0436.htm)

US EPA (2008), Emissions Factors & AP 42, AP 42, Fifth Edition Compilation of Air

Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources United

States Environmental Protection Agency, September 5th, 2008.

US EPA (2002), Potential Environmental Impacts of Dust Suppressants:” Avoiding

another time beach”, An Expert Panel Summary, United States Environmental

Protection Agency, March 2004.

Vicusi (1995), Symposium on Risk Assessment in the Federal Government Equivalent

Frames of Reference for Judging Risk Regulation Policies, W. Kip Viscusi, New York

University Environmental Law Journal, 1995

WHO (2000), World Health Organization air quality guidelines for Europe, 2nd edition,

2000. WHO Regional Publications, European Series, No. 91. ISBN 92 890 1358.

WHO (2001), WHO Acceptable Risk - 2001 WHO Water Quality Guidelines, Standards and

Health. World Health Organization (WHO). Water Quality: Guidelines, Standards

and Health. Edited by Lorna Fewtrell and Jamie Bartram. Published by IWA

Publishing, London, UK. ISBN: 1 900222 28 0

Yu et al (2009), “Observations of high rates of NO2-HONO conversion in the nocturnal

atmospheric boundary layer in Kathmandu, Nepal), Y. Yu1, B. Galle1, A. Panday2,

E. Hodson2, R. Prinn, and S. Wang. Atmos. Chem. Phys., 9, 6401–6415, 2009,

www.atmos-chem-phys.net/9/6401/2009/

Zenz, C& Berg, BA (1967), Human responses to controlled vanadium pentoxide exposure.

Archives of environmental health, 14: 709-712 (1967). 33

http://www.epa.gov/scram001/7thconf/calpuff/calpeer.pdf

http://www.epa.gov/ncea/iris/subst/0436.htm

http://www.atmos-chem-phys.net/9/6401/2009/




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.





SA

LULC

code

USGS code

equivalent

USGS class


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)





SA

LULC

code

USGS code

equivalent

USGS class


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.





SA

LULC

code

USGS code

equivalent

USGS class


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





SA

LULC

code

USGS code

equivalent

USGS class


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).





SA

LULC

code

USGS code

equivalent

USGS class


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





SA

LULC

code

USGS code

equivalent

USGS class


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.





SA

LULC

code

USGS code

equivalent

USGS class


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.


(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).


(residential,

mixed)

mixture …


(residential,

hostels)

Permanent residential structures, typically located in formal township districts, consisting mainly

of 1 or 2 levels in concentrated block-like structures.


(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.





SA

LULC

code

USGS code

equivalent

USGS class



(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


(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


(smallholdings,

forest &

woodland …)

see “residential’ definition above ...


(smallholdings,

thicket,

bushland)



(smallholdings,

shrubland …)



(smallholdings,

grassland …)


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.





SA

LULC

code

USGS code

equivalent

USGS class



(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.


(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).


(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.


(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.


(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.




APPENDIX 2: CV’S OF TEAM MEMBERS

EScience Associates


Johannesburg, 2192

Tel: +27 (0)11 718 6380

Curriculum Vitae:

Abdul

Ebrahim




Position: Director



Contact details

: 011 7186380

: 072 268 1119

: [email protected]

Abstract









Education



Languages


EScience Associates


Johannesburg, 2192

Tel: +27 (0)11 718 6380

Curriculum Vitae:

Abdul

Ebrahim

Experience












• Food processing


• Mining





Hourly Rate














EScience Associates


Johannesburg, 2192

Tel: +27 (0)11 718 6380

Curriculum Vitae:

Abdul

Ebrahim

▪ Tel: 012 310 3436




▪ Tel: 011 999 2470



▪ Tel: 013 249 2164







▪ Tel: 034 328 3300




























EScience Associates


Johannesburg, 2192

Tel: +27 (0)11 718 6380

Curriculum Vitae:

Abdul

Ebrahim















o Lafarge Gypsum


o BPB Gypsum




o Holcim Cement


o Assmang Chrome

o Assmang Manganese



o CBI Electrical



















o Assmang BRMO

EScience Associates


Johannesburg, 2192

Tel: +27 (0)11 718 6380

Curriculum Vitae:

Abdul

Ebrahim








o SASOL Synfuels

o NATCOS Petrochem




















o Oilflow

o The Smart Company



o Central Waste

o AT Packaging

o EWaste Africa

o Mpact Recycling

o Wasteplan

o Fine Metals

o Living Earth


o SA Paper Mills

o Interwaste

o Matchem

o TGS

o Verigreen

EScience Associates


Johannesburg, 2192

Tel: +27 (0)11 718 6380

Curriculum Vitae:

Abdul

Ebrahim

o SB Boxes

o Drumpal

o Oscars Meat


o


o PPC Riebeeck









RELATED PROJECTS:

o Tuffy Plastics

o Proplas plastics

o WHS Distribution









o Souza Cruz Brazil













o Ingwe Colliery

EScience Associates


Johannesburg, 2192

Tel: +27 (0)11 718 6380

Curriculum Vitae:

Abdul

Ebrahim

o Arnot Colliery


o Lafarge Gypsum

o CWI






















o Lafarge Gypsum

o Kanhym Estates






EScience Associates


Johannesburg, 2192

Tel: +27 (0)11 718 6380

Curriculum Vitae:

Abdul

Ebrahim






12.




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:

[email protected]

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:

[email protected]

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:

[email protected]

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: [email protected]

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: [email protected]

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: [email protected]




of 2

EScience Associates


Johannesburg, 2192

Tel: +27 (0)11 718 6380

Curriculum Vitae:

Sam Leyde

Surname: Leyde

Name: Sam


Nationality: RSA



Contact details

: 011 7186380

: [email protected]

Abstract


Education


Languages


Experience














of 2

EScience Associates


Johannesburg, 2192

Tel: +27 (0)11 718 6380

Curriculum Vitae:

Sam Leyde



































o Wispeco Aluminium




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:


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); [email protected] (email)

and

Dr Tim Forssman

Association of Southern African Professional Archaeologists, Professional Member 307 with

CRM accreditation

+27784224828 (cell); [email protected] (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


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


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




APPENDIX 5: ENVIRONMENTAL MANAGEMENT PROGRAMME

REPORT

ENVIRONMENTAL MANAGEMENT

PROGRAMME REPORT (EMPr):


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:

+27 86 516 6627

WEBSITE:

www.escience.co.za

E-MAIL:

[email protected]

R No 2009/014472/07

http://www.escience.co.za/


ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT



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


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





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




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




• 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.




Figure 1-1: Process Flow Diagram




Figure 1-2: Proposed Site Layout





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


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.




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


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


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 1-3 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:


• Alternative Location:



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


385 Knopjeslaagte

T0JR00000000038500111

Alternative Location


385 Knopjeslaagte

T0JR00000000038500109


385 Knopjeslaagte

T0JR00000000038500331




Figure 1-3: Proposed site locality




Figure 1-4: Proposed site locality - Zoomed




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 [email protected]

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


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


1.6 EMP STRUCTURE

In order to realise the objectives of the EMP, the document:




• 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).




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)




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.




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.




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




Archaeological and cultural impacts - No impact (refer to section specialist assessment)

Operational phase:

Potential impacts on groundwater quality during operations - Moderate Negligible



Air Quality Low to negligible (refer to specialist assessment)




Potential impacts on surface and groundwater quality during

construction - Low Negligible


Waste generation during decommissioning of infrastructure. - Low Negligible





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;


• 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 excessive noise generation from decommissioning activities;

• Prevent land and water pollution;

• Minimise the generation of waste.




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




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




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





ASPECT POTENTIAL

IMPACT/RISK/ISSUE


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.


Vehicles to comply with the standards as provided in the

International Finance Corporation’s Environmental Health &

Safety Regulations.


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





ASPECT POTENTIAL

IMPACT/RISK/ISSUE


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.


Hazardous Substances

Hazardous substances such as fuel and oil must be stored within

appropriately sized, impermeable, bund walls, with the

appropriate warning signage.


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.


Spill kits to be readily available at all points where hazardous

substances will be stored and/or transferred (e.g. refuelling

points)


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





ASPECT POTENTIAL

IMPACT/RISK/ISSUE


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


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.


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.


inspect daily

Refuelling areas must be bunded and secured to prevent soil

and water contamination. Contractor, ECO

Continuous,

inspect daily





ASPECT POTENTIAL

IMPACT/RISK/ISSUE


Fuels and flammable materials are to be stored in suitably

equipped storage areas complying with general fire safety

requirements.


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




8.3 OPERATIONAL PHASE

Table 8-3: Environmental Management Plan – Operational Phase

ASPECT POTENTIAL

IMPACT/RISK/ISSUE


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





ASPECT POTENTIAL

IMPACT/RISK/ISSUE


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





ASPECT POTENTIAL

IMPACT/RISK/ISSUE


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





ASPECT POTENTIAL

IMPACT/RISK/ISSUE


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





ASPECT POTENTIAL

IMPACT/RISK/ISSUE


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





ASPECT POTENTIAL

IMPACT/RISK/ISSUE


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





ASPECT POTENTIAL

IMPACT/RISK/ISSUE


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





ASPECT POTENTIAL

IMPACT/RISK/ISSUE


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




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


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.




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.




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:




APPENDIX 1: EAP CURRICULUM VITAE