Environmental Performance Audit RoD Final · 2016-09-20 · ArcelorMittal Vanderbijlpark Environmental Performance Audit - RoD 16-0063 06 September 2016 Page vi Whilst the approval

63 Wessel Road, Rivonia, 2128 PO Box 2597, Rivonia, 2128 South Africa

Tel: +27 (0) 11 803 5726 Fax: +27 (0) 11 803 5745 Web: www.gcs-sa.biz

GCS (Pty) Ltd. Reg No: 2004/000765/07 Est. 1987

Offices: Durban Johannesburg Lusaka Maseru Ostrava Pretoria Windhoek

Directors: AC Johnstone (Managing) PF Labuschagne AWC Marais S Pilane (HR) W Sherriff (Financial)

Non-Executive Director: B Wilson-Jones

www.gcs-sa.biz

Environmental Performance Audit Record of Decision

Report

Version – Final

06 September 2016

ArcelorMittal Vanderbijlpark

GCS Project Number: 16-0063

Client Reference: 6019646321 / 2016.04.18

Record of Decision Number: GUAT 002/4-05/1126

ArcelorMittal Vanderbijlpark Environmental Performance Audit - RoD

16-0063 06 September 2016 Page ii

Environmental Performance Audit

Record of Decision

Report Version – Final

06 September 2016

ArcelorMittal Vanderbijlpark

16-0062

DOCUMENT ISSUE STATUS

Report Issue Final

GCS Reference Number GCS Ref - 16-0063

Client Reference 6019646321 / 2016.04.18

Title External Environmental Performance Assessment – Record of Decision Audit Report

Name Signature Date

Author Grant Cornish-Bowden

06 September 2016

Document Reviewer Jacques Harris

06 September 2016

Unit Manager Jacques Harris

06 September 2016

LEGAL NOTICE This report or any proportion thereof and any associated documentation remain the property of GCS until the mandator effects payment of all fees and disbursements due to GCS in terms of the GCS Conditions of Contract and Project Acceptance Form. Notwithstanding the aforesaid, any reproduction, duplication, copying, adaptation, editing, change, disclosure, publication, distribution, incorporation, modification, lending, transfer, sending, delivering, serving or broadcasting must be authorised in writing by GCS.


16-0063 06 September 2016 Page iii

EXECUTIVE SUMMARY

ArcelorMittal South Africa Vanderbijlpark Works was established in 1942 and commenced

production in 1952. ArcelorMittal South Africa Vanderbijlpark Works is one of the largest steel

producers in South Africa. The ArcelorMittal South Africa Vanderbijlpark Works manufacture

steel products by charging raw materials such as iron ore, coke and dolomite into blast

furnaces to produce liquid iron. The liquid iron is refined in basic oxygen furnaces and electric

arc furnaces to produce liquid steel. The liquid steel is further processed into various rolled

and coated steel products.

Record of Decision (RoD) was issued by the Gauteng Department of Agriculture, Conservation

and Environmental (GDACE) on 22 February 2007 in terms of Section 22 of the Environmental

Conservation Act, 1989 (Act No. 73 of 1989) (ECA).

In terms of the RoD conditions, ArcelorMittal South Africa Vanderbijlpark Works is required

to appoint an independent external auditor, to conduct an Environmental Performance Audit

(EPA) on compliance with the conditions of the RoD. It is in that regard that GCS Water and

Environment (Pty) Ltd. (GCS) was appointed to undertake the necessary external compliance

audit.

The audit was undertaken in a phased approach, the specific phases being:

• Project Planning Phase;

• Conducting the Audit including:

o Kick off meeting and interviews

o Site Visit

• Evaluating the audit results;

• Presenting the audit results; and

• Decision making and corrective action.


16-0063 06 September 2016 Page iv

Audit Methodology

In line with conditions of ArcelorMittal’s approved WML, the Audit focused on all the

conditions included as part of the WML to ensure that the specified conditions are executed

and adhered to.

The external audit process followed, included the following steps:

• Step 1: Conducting the opening meeting in order to:

o ensure mutual understanding of the objectives, as well as scope of the audit; and

o discuss the relevant documentation such as the audit checklist and site layout

before conducting the on-site audit activities;

• Step 2: Conducting the on-site audit observation, using the prepared checklists; and

• Step 3: Conducting the closing meeting at the end of the audit.

The findings of the Audit are included in Error! Reference source not found. of this Report.

The audit findings also include practical recommendations whereby the various non-

compliance issues can be corrected.

All findings were ranked according to the following criteria:

• Compliance

• Minor Non- compliance

• Moderate Non- compliance

• Major Non- compliance

The following colour coding was used to indicate areas of compliance, minor non-compliance,

moderate non-compliance, and major non-compliance:

- Compliant;

- Minor non-compliance;

- Moderate non-compliance; and

- Major non-compliance.

- Noted/ Not applicable

- Repeat Condition.

Each colour coding has a value (score) attached to it. Kindly refer to the scoring indicated

below:


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Compliant 2

Minor non-compliance 1

Noted/Not Applicable 0

Repeat Condition -

Moderate non-compliance -1

Major non-compliance -2

The findings are entered into the audit spreadsheet which tabulates the percentage of

compliance to the regulatory requirements.

Key findings

As was reported in the previous audit the leachate drainage system from the waste transfer

station is not directed to the H:H leachate dam. It is reported that water from this area drains

to a sump and is then pumped to a dust suppression tank. There are reportedly plans to direct

potential overflow from this area to the leachate dam. This has however not yet been

constructed and as such the auditor is of the opinion that this condition poses a potential risk

to the environment and that the condition should be rectified.

The auditor observed that the lined concrete channels that drain water from the waste site

to the leachate dam were overgrown with reeds and had a significant amount of

sedimentation. This would reduce the capacity of the canals and could result in an overflow.

These canals need to be free of obstruction and the design capacity should be restored by

removal of the silt.

During the audit interview it was noted that the ground water monitoring locations were not

specifically approved by the Department of Environmental Affairs (DEA). It was reported to

the auditor that ArcelorMittal has submitted a Ground Water Management Plan to the

Department of Water and Sanitation (DWS) and that this has been approved by the DWS (letter

dated 1 June 2012 and referenced by number 16/2/7/C222/B11/Y2/1). ArcelorMittal has sent

the stated approval letter to the Department of Environmental Affairs indicating the

approval. No formal acknowledgement or approval of this letter has been sent and as such it

cannot be assumed that this has automatically been accepted. This is despite the statement

that ArcelorMittal assumes that no response to this letter within the stated timeframe implies

approval. It is important to note that this finding does not indicate that monitoring is not

being undertaken at the site. It further does not imply that there is any risk to the

groundwater resource given that there is an extensive monitoring network around the specific

site and the plant as a whole. It rather indicates that DEA approval for the monitoring system

should be confirmed and proof of this confirmation should be kept on record.


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Whilst the approval and construction status of the salt cells falls outside the audit period the

auditor recommends that the recommendations made in the previous audit period regarding

this site be confirmed by ArcelorMittal. The implication of the new waste act should be

considered in resolving the disposal and or storage of salts.


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CONTENTS PAGE

1 INTRODUCTION .......................................................................................................................... 1

2 SCOPE OF WORK ........................................................................................................................ 2

3 OBJECTIVES OF THE AUDIT ......................................................................................................... 3

4 METHODOLOGY ......................................................................................................................... 3

4.1 PROJECT PLANNING ....................................................................................................................... 4 4.2 CONDUCTING THE AUDIT................................................................................................................. 4 4.3 EVALUATING THE AUDIT RESULTS ...................................................................................................... 5 4.4 PRESENTING THE AUDIT RESULTS ....................................................................................................... 5

5 DECISION MAKING AND CORRECTIVE ACTION ............................................................................ 7

6 DETAILS OF THE AUDITOR .......................................................................................................... 8

7 ASSUMPTIONS AND LIMITATIONS .............................................................................................. 8

8 SUMMARY TABLE OF AUDIT SCORING ........................................................................................ 9

9 COMPLETE AUDIT TABLES WITH FINDINGS AND RECOMMENDATIONS .................................... 10

10 MONITORING RESULTS AND TRENDS ....................................................................................... 22

10.1 GROUND WATER QUALITY MONITORING ......................................................................................... 22 10.2 STORM WATER QUALITY ............................................................................................................... 28 10.3 H:H LEACHATE DAM .................................................................................................................... 28 10.4 AIR QUALITY MONITORING ........................................................................................................... 29 10.5 WASTE DISPOSAL RESULTS ............................................................................................................ 32

11 EMP COMPLIANCE .................................................................................................................... 35

11.1 GENERAL EMP CONDITIONS .......................................................................................................... 36 11.2 CLOSURE AND REHABILITATION OF THE OLD WASTE SITE ....................................................................... 36 11.3 NEW DRY METALLURGICAL WASTE DISPOSAL SITE FACILITY................................................................. 36 11.4 H:H LEACHATE CONTROL DAM ....................................................................................................... 37 11.5 NEW H:H SALT CELL .................................................................................................................... 38 11.6 GENERAL WASTE DISPOSAL SITE ..................................................................................................... 38 11.7 NEW H:H SLUDGE DAM ................................................................................................................ 38 11.8 NEW BLAST FURNACE SLAG STORAGE AREA ..................................................................................... 38

12 CONCLUSIONS AND RECOMMENDATIONS ............................................................................... 38

LIST OF TABLES

Table 4-1 Audit Information Gathering Techniques Utilised ........................................ 4 Table 4-2 Ranking criteria and colour coding scores ................................................. 5 Table 8-1 Summary of Audit Scoring .................................................................... 9 Table 9-1 Complete Audit Tables ....................................................................... 10 Table 10-1 Borehole PL-3D ............................................................................... 22 Table 10-2 Borehole Geo-3D ............................................................................. 22 Table 10-3 Borehole PL-5D ............................................................................... 23 Table 10-4 Borehole P-7D ................................................................................ 24 Table 10-5 Borehole P-8D ................................................................................ 24 Table 10-6 Borehole PL-6D ............................................................................... 25 Table 10-7 Borehole PL-8D ............................................................................... 25 Table 10-8 Borehole GEO-5D ............................................................................ 26 Table 10-9 Storm Water Quality Runoff ............................................................... 28 Table 10-10 Waste Site Dust Fall Out .................................................................. 31 Table 10-11 Waste Summary Results ................................................................... 32 Table 10-12 Waste Management Summary ............................................................ 32 Table 10-13 Total Waste and By-product Generated ............................................... 33


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Table 10-14 Waste Disposed Internally ................................................................ 33 Table 10-15 By-product Recycled and Re-used ...................................................... 34 Table 10-16 By-products Sold ........................................................................... 34 Table 10-17 By-product Stored .......................................................................... 35 Table 10-18 Vereeniging Waste Disposal .............................................................. 35

LIST OF APPENDICES

Appendix A decleration of the independence of the auditor Appendix B information submittted on an annual basis: condition 5.2.1 and 9.1 Appendix c form to be used for chemical information: Condition 9.3 Appendix d external compliants register Appendix e Emergency response plan Appendix f Environmental response plan Annexure g Waste Management System Annexure h Incident Register Annexure I Internal Audits Annexure j Linier inspection report Annexure K Procedure for water sampling Annexure l Monitoring committee report


16-0063 06 September 2016 Page 1

1 INTRODUCTION

ArcelorMittal South Africa Vanderbijlpark Works was established in 1942 and commenced

production in 1952. ArcelorMittal South Africa Vanderbijlpark Works is one of the largest steel

producers in South Africa. The ArcelorMittal South Africa Vanderbijlpark Works manufacture

steel products by charging raw materials such as iron ore, coke and dolomite into blast

furnaces to produce liquid iron. The liquid iron is refined in basic oxygen furnaces and electric

arc furnaces to produce liquid steel. The liquid steel is further processed into various rolled

and coated steel products.

A Record of Decision (RoD) was issued by the Gauteng Department of Agriculture,

Conservation and Environmental (GDACE) on 22 February 2007 in terms of Section 22 of the

Environmental Conservation Act, 1989 (Act No. 73 of 1989) (ECA).

In terms of the RoD conditions, ArcelorMittal South Africa Vanderbijlpark Works is required

to appoint an independent external auditor, to conduct an Environmental Performance Audit

(EPA) on compliance with the conditions of the RoD. It is in that regard that GCS Water and

Environment (Pty) Ltd. (GCS) was appointed to undertake the necessary external compliance

audit. It is noted here that the RoD has been audited in conjunction with a corresponding

WML. The audit report has been issued to ArcelorMittal as a separate document for procedural

purposes.

A one (1) day site visit was undertaken at the Vanderbijlpark Works site on 16 March 2016.

The site visit was initiated with a project kick-off meeting during which GCS met with Mr.

Phila Mkemezulu, ArcelorMittal’s designated Waste Management Control Officer (WMCO) and

Environmental Control Officer (ECO) for the site under Authorisation. Following the kick-off

meeting, a comprehensive review of the WML documentation and associated audit checklists

was undertaken. This assessment assessed compliance in terms of document control, systems

and procedures. Following the checklist audit and documentation review, the remaining time

was spent on site observing and inspecting the activities being conducted.



Accordingly, the following activities were undertaken as part of the EPA Audit:

• Assessment and comparison of the current site activities with those described in the

approved WML;

• Comparison of environmental mitigation measures implemented on site to those required

and committed to in terms of the approved WML in order to assess whether these comply

with the management objectives committed to in the WML;

• Assessment of monitoring requirements to current monitoring practices; and

• Assessment of relevant documentation pertaining to various compliance aspects.

2 SCOPE OF WORK

The scope of the audit included auditing the activities related to the described RoD (GAUT

002/4-5/1126) at the ArcelorMittal Vanderbijlpark works. The scope of work specifically

excludes any other associated applications, approvals or permits required by other

government departments and is limited to site activities that have occurred during this audit

period.

The conditions of the RoD stipulate that regular performance assessments need to be

undertaken to ensure compliance with the prescribed conditions as contained in the said

documents. Specifically, Condition 3.2.25 of the RoD requires that the Authorisation holder

appoint an independent external auditor to audit the site annually and that the audit report

documenting the findings of the audit must be submitted to the Department. As has been

done in previous audits the submission of the report to the department will be undertaken

by ArcelorMittal.

This EPA Audit is taken to mean a regular, systematic, documented verification of whether

ArcelorMittal is in compliance with the conditions of the RoD and whether environmental

performance objectives and targets are being met.



3 OBJECTIVES OF THE AUDIT

The objectives of any audit should be clearly defined and settled before either an internal or

external audit begins. The setting of objectives is important as it is against these objectives

that ArcelorMittal will be reviewed and expected to improve.

The following objectives formed the basis for the EPA Audit:

• Ensuring compliance in terms of the approved RoD;

• Checking that the environmental management tools to achieve compliance are used

correctly and efficiently;

• To check whether the environmental management tools are effectively fulfilling their

intended purpose of environmental compliance;

• Ensuring environmental performance on a continuous basis, i.e. throughout the life cycle

of the Vanderbijlpark Works site;

• To facilitate the transference of information or best practice between operating units;

and

• To increase environmental awareness among the employees.

4 METHODOLOGY

The audit was undertaken in a phased approach, the specific phases being:

• Project Planning Phase;

• Conducting the Audit including:

o Kick off meeting and interviews

o Site Visit

• Evaluating the audit results;

• Presenting the audit results; and

• Decision making and corrective action.



4.1 Project Planning

Project planning included requesting, and receiving pre-audit information from the WMCO /

ECO and finalising audit logistics. In addition to this audit tables were compiled to facilitate

a systemic assessment of the sites compliance to all licence conditions.

4.2 Conducting the Audit

The auditor then met with the WMCO / ECO in the Environmental Department at the

Vanderbijlpark Works on the 16th of May. This kick off meeting established the common

understanding for the audit objectives. The auditor then utilised various audit information

gathering techniques as summarised in table Table 4-1.

Table 4-1 Audit Information Gathering Techniques Utilised

ACTION DESCRIPTION

Inspection Inspection consists of examining records and documents. Inspection of

records and documents provides audit evidence of varying degrees of

reliability depending on their nature and source and the effectiveness

of internal controls over their processing.

Observation Observation consists of on-site observation of the activities being

conducted on site.

Enquiry Enquiry consists of seeking information of knowledgeable persons

inside the organisation.

Confirmation Confirmation consists of making enquiries to corroborate information

contained in the WML.

Computation Computation consists of checking the accuracy of source documents

and the site’s records or performing independent checks of information

relating to environmental aspects and impacts.

A site visit was conducted on the day of the audit. This included assessing documents in the

weighbridge office and an inspection of the waste transfer and disposal areas. The inspection

included a detailed inspection of the pollution control dam and the associated site drainage

systems that transport contaminated water to this installation.



4.3 Evaluating the audit results

GCS audit methodology includes a calculated audit compliance score which is presented as a

percentage. This score is then evaluated by the auditor who assesses the final compliance

percentage in terms of the realistic representation of on-site activities taking into account

components such as materiality and or scale of impacts caused by the contributing

compliance and or non-compliant aspects. As such the any decisions made based on this audit

report should consider both the final audit score and objective compliance observations made

by the auditor.

4.4 Presenting the audit results

The findings of the audit are summarised in Error! Reference source not found. of this Report.

Full audit tables detailing all audit findings, observations and practical compliance

recommendations whereby the various non-compliance issues can be corrected are included

in Error! Reference source not found. of this report.

All findings were ranked according to the criteria indicated in Table 4-2. The colour coding

assigned to the rankings is used to visually indicate areas of compliance, minor non-

compliance, moderate non-compliance, and major non-compliance. Furthermore, to indicate

which conditions are not applicable to the on-site activities and which are repeat conditions

that have already been scored. Each colour coding has a value (score) attached to it.

Table 4-2 Ranking criteria and colour coding scores

RANKING SCORE

Compliant 2

Minor non-compliance 1

Noted/Not Applicable 0

Repeat Condition -

Moderate non-compliance -1

Major non-compliance -2



All findings were ranked according to the following criteria:

Noted/Not-Applicable:

• The specific condition is not relevant to the current on-site activities.

Repeat Condition:

• The specific condition is a repeat of a previous condition.

Compliant:

• ArcelorMittal complies with the conditions as stated in the WML.

Non-compliance:

• Minor Non-compliance:

o Isolated observations demonstrating that full compliance to the environmental

requirements on site have not been, or will not be, fully achieved.

• Moderate Non-compliance:

o There is a substantial failure to meet the environmental requirements for the

project, there is a possibility of substantial environmental degradation and/or

pollution, and/or objective evidence was observed raising doubt as to the

integrity of data or records inspected.

• Major Non-compliance:

o There is a critical failure against legal requirements or management response

that presents an immediate or significant risk to the environment that could

result in prosecution and/or adverse legal findings due to failure to meet

regulatory requirements; result in immediate injury and or serious injury; result

in prolonged business outage; and/or could result in serious damage to the

project’s reputation.

The findings of the audit are entered into the audit spreadsheet which tabulates the

percentage of compliance to the licence requirements. The table can be interpreted as

follows:

• Maximum Score – represents the score if 100% compliance is achieved; i.e. the

number of conditions minus the conditions which are not applicable or repeated,

multiplied by the score allocation of 2.



• Compliance, minor non-compliance, moderate non-compliance and major non-

compliance – represent the number of times the specific rating was triggered;

• Score – represents the sum of the ratings (rating times the corresponding score); and

• Percentage (%) compliance - represents the score divided by the maximum score.

It must be noted that duplicate conditions are marked as a Repeat Condition and are not

scored due to the fact that this will disproportionately influence the scoring results in either

a positive or negative manner. Duplicate conditions are however retained in the audit tables

to ensure transparency and to demonstrate that they were considered during the audit.

5 DECISION MAKING AND CORRECTIVE ACTION

Decision making, based on the audit results, should to improve the present situation and to

institute fair and reasonable corrective action. ArcelorMittal should make decisions based on

the significance of the problem or non-compliance and the resources required to improve the

situation. It is thus recommended that an environmental action plan be implemented to

address the audit recommendations. The plan may include:

• Goals;

• Strategies;

• Performance indicators;

• Responsibilities; and

• A timetable for achievement.

An EPA Audit is an effective management tool on condition that the recommendations, as

identified in this audit, are considered and implemented. The audit provides a basis for

recommending actions to correct any deficiencies and to address any areas of environmental

non-compliance recorded as part of the audit findings.



6 DETAILS OF THE AUDITOR

GCS, appointed by ArcelorMittal to conduct an external EPA Audit, has more than 30 years of

experience and expertise in undertaking and compiling compliance Audits. The audit was

undertaken by Mr Grant Cornish-Bowden who is an experience environmental auditor with

over 10 years environmental compliance management experience. The audit has been

technically reviewed and approved in terms of the GCS quality procedure by Mr Jacques Harris

who has over 20 years’ experience in the environmental field.

7 ASSUMPTIONS AND LIMITATIONS

The findings, results, observations, conclusions and recommendations given in this Audit are

based on the Auditor’s best legal and professional knowledge as well as available information

made available to the auditor and from observations made on the day of the site visit.

Although GCS exercises due care and diligence in rendering services and preparing

documents, GCS accepts no liability, and the client by receiving this document, indemnifies

GCS and its directors, managers, agents and employees against all actions, claims, demands,

losses, liabilities, costs, damages and expenses arising from or in connection with services

rendered, directly or indirectly by GCS and by the use of the information contained in this

document.

This audit report must not be altered or added to without the prior written consent of the

auditor. This also refers to electronic copies of this Audit which are supplied for the purposes

of inclusion as part of other reports, including main reports. Similarly, any recommendations,

statements or conclusions drawn from or based on this audit must make reference to this EPA

Audit. If these form part of a main audit relating to this investigation or report, this audit

must be included in its entirety as an annexure or separate section to the main audit.

Refer to Appendix A for the Declaration of Independence of the Auditor.



8 SUMMARY TABLE OF AUDIT SCORING

Table 8-1 Summary of Audit Scoring

Environmental Performance Assessment Audit Results 2016

Scoresheet % C

om

pli

an

ce

Sco

re

Ma

xim

um

Sco

re

Co

mp

lia

nce

No

ted

/

No

t A

pp

lica

ble

Re

pe

at

Co

nd

itio

n

Min

or

No

n-C

om

pli

an

ce

Mo

de

rate

No

n-C

om

pli

an

ce

Ma

jor

No

n-C

om

pli

an

ce

RoD GUAT 002/4-05/1126 98% 55 56 27 45 0 1 0 0

27

45

0 1 0 0

Compliance Noted/

Not Applicable

Repeat Condition Minor

Non-Compliance

Moderate

Non-Compliance

Major

Non-Compliance

ArcelorMittal Vanderbijlpark Environmental Performance Audit – RoD

16-0063 06 September 2016 Page 10

9 COMPLETE AUDIT TABLES WITH FINDINGS AND RECOMMENDATIONS

Table 9-1 Complete Audit Tables

No Conditions Status Score Observations

3 Conditions Noted/Not Applicable

0

Description and extent of the activity Noted/Not Applicable

0

3.1 The authorisation applies in respect of the operation towards closure of the existing waste disposal site and the establishment of a new waste disposal site.

Noted/Not Applicable

0

3.1.1 The closure of existing waste disposal site will entail: Noted/Not Applicable

0

Reshaping the waste disposal site; Compliance 2

The site has been reshaped at completed sections/phases

Establishing a series of canals; Compliance 2 Storm water canals are in place

Capping the side slopes and top of the waste disposal site;

Compliance 2

Phase 1 and 2 have been completed. Portion 3 is still underway and it is reported that portions of Phase 3 are still open and are scheduled to be closed within 3 - 4 years.

Top soiling using the fertilisers; and Compliance 2

Topsoil has been placed and the need for fertiliser is being assessed.

Seeding to encourage the establishment of vegetation which will allow the waste dump to visually blend into the surrounding topography.

Compliance 2

It is noted that phase one of the seeding was successful and has resulted in a relatively dense stand of mixed grasses. The second phase has been undertaken but a significant amount of seeds failed to germinate. This allowed in-situ seeds from the topsoil seedbank to germinate. The species composition of this could not be established at the time of the audit as the site had recently been mowed to encourage grass species. The site needs to be monitored and it is recommended that an ecologist assess the species present when the currently cut vegetation has re-grown. This will determine the need for re-seeding.


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3.1.2 The new waste disposal site is part of the CRMF and will cover an area of 47 ha to be constructed in three phases comprising of 13 cells of approximately 4ha each. The other components of the CRMF to be constructed within the existing waste disposal site and adjacent the proposed waste disposal site include:

Compliance 2

Leachate control dam consisting of an H:H Lagoon of 1 ha in extent and 6m deep with a capacity of 54m3;

Compliance 2

Salt cell to cater for an interim 4 year period of salt deposition and will have capacity of 16 000 tons/annum;


0

No activity regarding the salt cells was reported in this audit period. Note the comments on licencing activities and site compliance from the previous audit period. It is noted that dry salts are currently being stored in a closed facility and when sufficient volume is obtained a new site will be established. It is recommended that the current waste legislation be considered as the storage may trigger waste management activities.

Sludge dam consisting of one cell with six separate compartments and will have capacity of 72000m2 Noted/Not

Applicable 0

Internal process changes have been made and as a result it is reported that there is no requirement for the facility.

General waste site with a foot print of 5.5 ha in extent and capacity of 24 000 tons/annum;

Compliance 2

Blast Furnace slag storage and processing facility covering an area of 45 000 m2 while processing waste amounting to 80 000 tons/annum; and


0 Not yet constructed. Process changes made, no requirement for the facility.

Waste Transfer station covering an area of 3,8 ha and total disposal of 930 250 tons/annum.

Compliance 2

3.2 Specific Conditions Noted/Not Applicable

0

General Noted/Not Applicable

0

3.2.1 MS VS will be held liable for any damages to the environment and associated costs, resulting from the


0


16-0063 06 September 2016 Page 12


proposed activity as provided for in the applicable legislation,

3.2.2 A summary of all recommendations in the Environmental Impact Report and specialist studies regarding both a) closure of the existing waste disposal facility and b) construction and operation of the new waste disposal facility must be included in an amended EMP. The amended EMP must also include operational, monitoring and reporting protocol and all conditions set by other relevant authorities, The amended EMP must be structured in such a way that the requirements and recommendations relating to the closure of the existing facility are separated from those relating to the new disposal facility. The amended EMP must also indicate the reduction target for the different waste streams and time frames regarding the ongoing investigations to reduce waste streams.


0

No amendments were made in the audit period. It is however noted that the EMP was amended and approved by GDARD in 2009. This was again updated in April 2013 and sent to GDARD. The update included the Vereeniging Black and White Slag and Reduction targets were included in the EMP. Records of update are available and compliance is covered in the previous audit period.

3.2.3 An independent suitably qualified and competent person must verify that all aspects requiring inclusion have been included in the amended EMP.


0

No amendments were made in the audit period. It is however noted that verification was undertaken by GCS in 2008, and the EMP was again updated by Zantow Environmental in 2013.

3.2.4 This amended EMP must be submitted to this Department within three (3) months after the date of this authorisation. Written approval on the EMP must be obtained from the Department before the project can commence.


0

No amendments were made in the audit period. It is noted that the EMP was approved on the 2nd June 2009 and updated again in 2013 by Zantow Environmental Consulting Service.

3.2.5 Once the Department has approved the amended EMP it must be adhered to throughout the life cycle of the project. The EMP is considered as an extension of this Record of Decision (ROD) and a non-compliance with any provision of the EMP will amount to a non-compliance with a condition of this ROD.


0

It is noted that compliance to the EMP is a RoD requirement.


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3.2.6 All mitigation measures identified during further studies, monitoring, auditing or other activities, as the case may be, must be included in the EMP on an ongoing basis. The amendments must be communicated to the Department within one (1) month of inclusion.


0

No amendments made during this reporting period. However it is noted that an EMP update (April 2013) submitted to GDARD on 5 July 2013 and approved. GDARD requested that DEA approve the EMP in the future. The amendment was subsequently submitted to DEA on the 11 July 2013 and a signed copy was re-sent on 15 April 2014. A compliance opinion regarding the EMP and the submission thereof is discussed in the previous period’s audit.

3.2.7 The contents of the EMP and its objectives must be made known to all contractors, sub-contractors, agents working on the site. The applicant and its successors will be held accountable for any breach or deviation from the EMP and conditions of this authorisation.

Compliance 2

Amended EMP is given to contractors and training is provided.

3.2.8 The approved amended EMP must be kept on-site, Compliance 2 EMP is available on site


16-0063 06 September 2016 Page 14


3.2.9 Different mitigation measures for dust suppression must be investigated in order to reduce ambient inhalable particulate and dust fallout levels from the MSVS waste disposal site. The preferred measures that will be implemented with timeframe for implementation must be submitted to the Department within three (3) months of the date of this authorisation and prior to commencement of both closure activities and construction activities. Reduction of nuisance dust must be achieved through mitigation of the source of dust emissions through speed and traffic reduction, source improvement (e.g. tarring, gravelling) and surface treatment (watering or chemical stabilisation) to reduce dust from roads.

Minor non-compliance

1

Both closure and construction activities commenced prior to the audit period. As such reporting is not covered in this audit period. It is however noted that the previous audit indicated that the issue of late submission has been resolved. In terms of dust reduction measures, wetting at transfer station and haul roads was observed at the time of the audit. An analysis of the dust monitoring results indicates that DB3 and DB6 experienced isolated elevated spikes during the audit period. These are unrelated as they occurred in different months and are thus considered anomalies to the generally low dust levels (generally under 500mg/m2.day). DB9 is however problematic as it is experienced 4 exceedances during the audit period. Three of these, as has been reported to the Monitoring Committee, occurred early in the year with a prolonged period where levels were under significantly reduced and were within the limits. However the last three months have seen an increase with December exceeding the threshold and Jan and Feb both being elevated when compared to the previous compliant months. It is reported that this location is adjacent to a main haul road. This is a high traffic location and further measures for control were recommended in the previous audit. It is indicated that additional wetting can control dust in this location. The recommendations of the last audit are repeated. It is further noted that the number of exceedances contravene the national dust regulations. This non-compliance requires specific investigation and reporting. The levels are presented in the monitoring committee but this does not satisfy the requirements of the regulations.


16-0063 06 September 2016 Page 15


3.2.10 An updated project schedule with time-frames must be submitted to the Department 30 (thirty) calendar days prior to the commencement of both closure activities and construction activities of the new waste disposal facility. The schedule must clearly indicate the different phases of operation and rehabilitation as well as environmental performance measurements.


0

No construction was reported during the audit period and as such this is not applicable to this audit.

3.2.11 The results of the third phase of the groundwater modelling must be submitted to the Department within one (1) month after it has been finalised, Depending on the results, the Department may amend the ROD or impose additional conditions on MSVS as provided for in the applicable legislation.

Compliance 2

The ground water management plan has been submitted to Department of Water Affairs for approval. It has however not been submitted to GDARD or DEA. As the Department of Water Affairs is the Competent Authority in this regard the GWMP cannot be considered as finalised until feedback and approval for the plan has been given. ArcelorMittal is of the opinion that the submission should be to the relative Competent Authority and that the communication should then be made. It is however recommended that AM submit the modelling to GDARD and DEA once the report is finalised / approved.

3.2.12 An Environmental Control Officer (ECO) must be appointed to audit environmental performance against the requirements of the approved EMP (both for the existing waste disposal site and the new waste disposal site), Internal environmental audit reports in this regard must be submitted to the Department for review every 2 (two) months starting from the date of the commencement of this project. The reports must include a compliance checklist and incorporate any deviation and remedial actions undertaken in case of non-compliance.

Compliance 2

Mr Phila Mkemezulu appointed as ECO 19 June 2014 and remained appointed through the audit period. Audits are undertaken and submitted to the department.

Construction of new waste disposal facility Noted/Not Applicable

0

3.2.13 The Department must be informed of the date on which construction will commence and of the date on which construction has been completed. Such notification must reach the Department seven (7) calendar days prior to and 7 (seven) calendar days after these respective events.


0

No construction was reported during the audit period and as such this is not applicable to this audit.


16-0063 06 September 2016 Page 16


3.2.14 The establishment and operation of a landfill requires Section 20(1) Waste disposal site Permit, hence MSVS must obtain relevant approvals from the Department of Environmental Affairs and Tourism (DEAT).

Compliance 2

A waste management licence was issued to the facility and this is valid for the audit period.

3.2.15 The sludge dam, leachate collection dam, new waste disposal site phase 1-3, leachate collection system, general waste and new waste disposal site must be constructed in line with Minimum Requirements for disposal by landfill (DWAF 1998) or amended / updated version thereof, as well as according to DEAT Section 20(1) Waste disposal site Permit. Copies of final drawings issued under Section 20(1) Waste disposal site Permit must be forwarded to the Department as soon as they have been issued.


0

No activity was reported during the audit period. It is noted for clarity that this has been found compliant in previous audits and that the licence and all drawings were sent to the department. In addition the WML was distributed to the Waste Sites Monitoring Committee. DWS, DEA, GDARD, Emfuleng, NGOs are part of the committee and quarterly meetings are held. Every second meeting includes a site visit.

3.2.16 A buffer zone of 25m from the new waste disposal must be implemented around all hydrological features with the exception of the reticulation pond, as recommended on page 31 of the Ecological and Aquatic sensitivity Assessment.

Compliance 2

No hydrological features were noted within the waste area.

3.2.17 An ecological management plan for all systems must be compiled by a suitably qualified specialist and form part of the amended EMP. This ecological management plan must be implemented and compliance to the plan must be discussed in the annual environmental report referred to in 3.2.25

Compliance 2

An ecological management plan was developed by GCS 2010. The report is considered by the most recent EMP update which notes requirements from the 2010 Ecological Plan in Appendix A. It is however noted that Golder updated the Ecological Plan in 2013. This is not referred to in the most recent EMP update. The conditions of said plan should be reviewed and any changes should be incorporated in the EMP.

Operation Noted/Not Applicable

0

3.2.18 The operation of the existing waste disposal facility, new waste disposal facility, waste transfer station, BF slag crushing plant and storage area, leachate control dam, sludge dam, salt cells and general waste disposal site must be carried out as indicated in the Operational Response, Monitoring and Closure (ORMC) plan and in accordance with the Minimum Requirements for disposal

Compliance 2

It is reported that the Operational Management and Closure Plan was incorporated into the EMP.


16-0063 06 September 2016 Page 17


by landfill (DWAF 1998) or an amended / updated versions thereof.

3.2.19 The Residue stabilisation and utilisation of the resulting product must be guided by the guiding principles and results summary in the background and progress report undertaken at the end of June 2005, and submitted as part of the EIR: Appendix H


0

No action was required during the audit period. It is however noted that the required studies were undertaken and that whilst theoretically possible the operational requirements and costs of stabilisation and utilisation were economically unfeasible.

Closure and Rehabilitation Noted/Not Applicable

0

3.2.20 Closure and rehabilitation of the existing waste disposal facility and other waste disposal facility that form part of the CRMS must be carried out as indicated in the Closure, Rehabilitation and End- use Plan submitted as part of the EIR; Appendix G

Compliance 2

The most recent EMP amendment indicates that the requirements of the Closure, Rehabilitation and End-use Plan were taken into account and incorporated in the operational Closure plan being followed.

Monitoring Committee Noted/Not Applicable

0

3.2.21 A multi stakeholder monitoring committee as required by the DWAF's minimum requirements must be established to monitor the short-term operation with a view to closure, remediation and opening of a new waste disposal facility, This committee must be established and meet before the proposed activity commences and quarterly thereafter, Significant environmental issues identified in the committee meetings as well as plans for their resolution must be forwarded to this Department within 7 (seven) calendar days from the date of the meeting.

Compliance 2

The Multi Stakeholder monitoring Committee has been established and did meet during the audit period. It is noted that the attendance has been limited despite all members being invited to attend. This is noted in previous audits and a letter has been submitted to DEA proposing that the monitoring committee should meet bi-annually.

Monitoring Noted/Not Applicable

0


16-0063 06 September 2016 Page 18


3.2.22 Monitoring and reporting for the existing waste disposal site, new waste disposal site, waste transfer station, BF slag crushing plant and storage area, leachate control dam, sludge dam, salt cell and general waste disposal site must be undertaken as indicated in the monitoring plan submitted as part of EIR: Appendix G,

Compliance 2

Monitoring incorporated in EMP

3.2.23 Ground Water monitoring must be undertaken as indicated in the Groundwater Monitoring Procedure submitted as part of EIR: Appendix 6.

Compliance 2

Procedure exists and is implemented During the audit interview it was noted that the ground water monitoring locations were not specifically approved by the Department of Environmental Affairs (DEA). It was reported to the auditor that ArcelorMittal has submitted a Ground Water Management Plan to the Department of Water and Sanitation (DWS) and that this has been approved by the DWS (letter dated 1 June 2012 and referenced by number 16/2/7/C222/B11/Y2/1).

3.2.24 Surface Water monitoring must be undertaken as indicated in the monitoring plan submitted as part of the EIR: Appendix 5.

Compliance 2

Procedure exists and is implemented Surface water monitoring locations have been approved by DWS (approval letter dated 24-02-2016 and referenced 16/2/7/C222/B11/Y2/1)

Reporting Requirements Noted/Not Applicable

0

3.2.25 An annual environmental performance audit conducted by an independent, certified auditor must be submitted to the Department, the first audit being due 12 (twelve) months after the signature of the authorisation for the operation towards closure of the landfill site, rehabilitation and establishment of a new waste disposal facility and annually thereafter. The annual audit must include, inter alia, the following (results in graph format as applicable):

Compliance 2

Previous audit was completed by Zantow Environmental Consulting Services and submitted on the 03rd of June 2015.

Results of water quality, i.e. monthly monitoring results from upstream and downstream boreholes.


0


16-0063 06 September 2016 Page 19


Monitoring of relevant boreholes with respect to detecting any pollution from all facets of the operation towards closure, rehabilitation and establishment of a new waste disposal site,


0

Quality, quantity and management of leachate generated (if any).


0

A review of the stability/integrity of the capping material and/or layers.


0

Reporting on progress regarding investigations to reduce the waste streams.


0

Reporting on progress of rehabilitation, Noted/Not Applicable

0

Success of vegetation establishment. Noted/Not Applicable

0

Environmental incidents and complaints pertaining to the operation towards closure, rehabilitation and establishment of a new waste disposal facility.


0

Compliance with provisions of the approved EMP. Noted/Not Applicable

0

Compliance with all the conditions of this RoD. Noted/Not Applicable

0

Compliance with the ecological management plan, Noted/Not Applicable

0

3.2.26 Detailed and up to date records must be kept of all incidents and complaints pertaining to the operation towards closure, rehabilitation and establishment of a new waste disposal facility, how these were managed, and the recurrence thereof prevented. These records must be made available to the Department within 14 (fourteen) calendar days upon written request by the Department

Compliance 2

Incident register is in place and is incorporated as part of this audit.

3.3 General Conditions Noted/Not Applicable

0

3.3.1 Any changes to, or deviations from, the project description set out in this letter must be approved, in writing, by the Department before such changes or deviations may be effected. In assessing whether to grant


0

No changes were required during the audit period.


16-0063 06 September 2016 Page 20


such approval or not, the Department may request such information as it deems necessary to evaluate the significance and impacts of such changes or deviations.

3.3.2 This Department may review the conditions contained in this letter from time to time and may, by notice in writing to the applicant, amend, add or remove a condition.


0

No amendments reported during the audit period

3.3.3 The applicant must notify the Department, in writing, at least 10 (ten) days prior to the change of ownership, project developer or the alienation of any similar rights for the activity described in this letter. The applicant must furnish a copy of this document to the new owner, developer or person to whom the rights accrue and inform the new owner, developer or person to whom the rights accrue that the conditions contained herein are binding on them.


0

No change during the audit period

3.3.4 Where any of the applicant’s contact details change, including the name of the responsible person, the physical or postal address and/ or telephonic details, the applicant must notify the Department as soon as the new details become known to the applicant,


0

It was reported to the auditor that no changes were made during the audit period. The change in name as per 3.3.3 above is noted.

3.3.5 Authorisation for the activity is granted in terms of the Environment Conservation Act, 1989 (Act 73 of 1989) only and does not exempt the holder from compliance with other relevant legislation.


0

3.3.6 The applicant shall be responsible for ensuring compliance with the conditions contained in this letter by any person acting on his behalf, including but not limited to, an agent, servant, or employee or any person rendering a service to the applicant in respect the activity, including but not limited to, contractors and consultants.

Compliance 2

Contractors are made aware of the contents and compliance requirements

3.3.7 Departmental officials shall be given access to the property referred to in 1 above for the purpose of assessing and/ or monitoring compliance with the

Compliance 2


16-0063 06 September 2016 Page 21


conditions contained in this document at all reasonable times.

3.3.8 The applicant must notify the Department within 24 (twenty four) hours if any condition of this authorisation cannot, or is not, adhered to. The notification must be supplemented with reasons for non-compliance.

Compliance 2

No significant non-compliance is noted for the audit period

4 Consequences of non-compliance Noted/Not Applicable

0

The applicant must comply with the conditions set out in this letter. Failure to comply with any of the above conditions may result in, inter alia, the Department withdrawing the authorisation, issuing directives or notices to address the non-compliance - including an order to cease the activity - as well as instituting criminal and/or civil proceedings to enforce compliance.


0

5 Appeals Noted/Not Applicable

0


16-0063 06 September 2016 Page 22

10 MONITORING RESULTS AND TRENDS

10.1 Ground Water Quality Monitoring

It has been reported that ground water samples are conducted bi-annually and annually on

the boreholes specifically identified for the waste site. As is reported to the Multi Stakeholder

Monitoring Committee and as per the previous audit reporting methodology electrical

conductivity is reported on as an indicator of water quality.

Table 10-1 Borehole PL-3D

Table 10-2 Borehole Geo-3D

0

5

10

15

20

25

30

35

40

11

/14

/20

12

1/1

6/2

01

32

/12

/20

13

3/1

1/2

01

34

/16

/20

13

5/7

/20

13

6/1

0/2

01

37

/2/2

01

38

/7/2

01

39

/3/2

01

31

1/5

/20

13

1/1

4/2

01

42

/4/2

01

43

/6/2

01

44

/9/2

01

45

/13

/20

14

6/3

/20

14

7/2

9/2

01

48

/12

/20

14

9/2

/20

14

10

/3/2

01

41

1/6

/20

14

12

/18

/20

14

1/2

2/2

01

52

/4/2

01

53

/17

/20

15

4/7

/20

15

5/1

3/2

01

56

/19

/20

15

7/2

7/2

01

58

/11

/20

15

9/1

1/2

01

51

0/9

/20

15

11

/4/2

01

51

2/1

8/2

01

5

mS

/m

Borehole No. PL-3D Up Stream Waste Site

EC (ms/m)

0

50

100

150

200

250

300

11

/14

/20

12

2/1

2/2

01

3

4/1

6/2

01

3

6/1

0/2

01

3

8/7

/20

13

11

/5/2

01

3

2/4

/20

14

4/9

/20

14

6/3

/20

14

8/1

2/2

01

4

10

/3/2

01

4

12

/18

/20

14

2/4

/20

15

4/7

/20

15

6/1

9/2

01

5

8/1

2/2

01

5

10

/17

/20

15

12

/12

/20

15

mS

/m

Borehole No. GEO-3D Up Stream Waste Site

EC (ms/m)


16-0063 06 September 2016 Page 23


Monitoring boreholes PL-3D, GEO-3D and PL-5D are indicated as being upstream of the waste

site. PL-3D indicated a downward in EC to the end of 2013. After this point the results stabilise

and remain at 20mS/m. This trend is continued in the latest results as reported to the auditor.

In general GEO-3D is elevated in comparison to the other two up-stream sites. It is noted that

GEO-3D the closest upstream monitoring site to the waste facility and may as such be

experiencing some site influence.

0

10

20

30

40

50

60

20

12

11

14

20

12

12

14

20

13

01

28

20

13

02

08

20

13

03

20

20

13

04

16

20

13

05

06

20

13

06

22

20

13

07

20

20

13

08

06

20

13

09

03

20

13

11

05

20

14

01

14

20

14

02

04

20

14

03

06

20

14

04

09

20

14

05

13

20

14

06

03

20

14

07

29

20

14

08

12

20

14

09

02

20

14

10

03

20

14

11

06

20

14

12

18

20

15

01

22

20

15

02

04

20

15

03

17

20

15

04

07

20

15

05

13

20

15

06

19

20

15

07

27

20

15

08

11

20

15

09

11

20

15

10

09

20

15

11

04

20

15

12

18

mS

/mBorehole No. PL-5D Up Stream Waste Site

EC (ms/m)


16-0063 06 September 2016 Page 24

Table 10-4 Borehole P-7D

Table 10-5 Borehole P-8D

0

50

100

150

200

250

20

12

11

14

20

12

12

14

20

13

01

28

20

13

02

08

20

13

03

20

20

13

04

16

20

13

05

06

20

13

06

22

20

13

07

20

20

13

08

06

20

13

09

03

20

13

11

05

20

14

01

14

20

14

02

04

20

14

03

06

20

14

04

09

20

14

05

13

20

14

06

03

20

14

07

29

20

14

08

12

20

14

09

02

20

14

10

03

20

14

11

06

20

14

12

18

20

15

01

22

20

15

02

04

20

15

03

17

20

15

04

07

20

15

05

13

20

15

06

19

20

15

07

27

20

15

08

12

20

15

09

11

20

15

10

09

20

15

11

04

20

15

12

18

mS

/mBorehole No. P-7D Downstream of Waste site

EC (ms/m)

200

250

300

350

400

450

500

20

13

01

28

20

13

02

08

20

13

03

20

20

13

04

16

20

13

05

06

20

13

06

22

20

13

07

20

20

13

08

06

20

13

09

03

20

13

11

05

20

14

01

14

20

14

02

04

20

14

03

06

20

14

04

09

20

14

05

13

20

14

06

03

20

14

07

29

20

14

08

12

20

14

09

02

20

14

10

03

20

14

11

06

20

15

01

22

20

15

02

04

20

15

03

17

20

15

04

07

20

15

05

13

20

15

06

19

20

15

07

27

20

15

08

12

20

15

09

11

20

15

10

17

20

15

11

04

20

15

12

12

mS

/m

Borehole No. P-8D Downstream of Waste Site and Du Preez Corner

EC (ms/m)


16-0063 06 September 2016 Page 25



0

20

40

60

80

100

120

140

160

180

200

20

12

11

14

20

12

12

14

20

13

01

28

20

13

02

08

20

13

03

20

20

13

04

16

20

13

05

06

20

13

06

22

20

13

07

20

20

13

08

06

20

13

09

03

20

13

11

05

20

14

01

14

20

14

02

04

20

14

03

06

20

14

04

09

20

14

05

13

20

14

06

03

20

14

07

29

20

18

08

12

20

14

09

02

20

14

10

03

20

14

11

06

20

14

12

18

20

15

01

22

20

15

02

04

20

15

03

17

20

15

04

07

20

15

05

13

20

15

06

19

20

15

07

27

20

15

08

11

20

15

09

11

20

15

10

09

20

15

11

04

20

15

12

18

mS

/mBorehole No. PL-6D Down Stream Waste Site

EC (ms/m)

0

5

10

15

20

25

30

35

40

11

/14

/20

12

2/1

2/2

01

3

4/1

6/2

01

3

6/1

0/2

01

3

8/7

/20

13

11

/5/2

01

3

2/4

/20

14

4/9

/20

14

6/3

/20

14

8/1

2/2

01

4

10

/3/2

01

4

12

/18

/20

14

3/1

7/2

01

5

5/1

3/2

01

5

7/2

7/2

01

5

9/1

1/2

01

5

11

/4/2

01

5

mS

/m

Borehole No. PL-8D Down Stream Waste Site

EC (ms/m)


16-0063 06 September 2016 Page 26

Table 10-8 Borehole GEO-5D

Monitoring sites P-7D, P-8D, PL-6D, PL-8D and GEO-5D are considered downstream sites.

Initially P-7D was trending between 50 and 100 mS/m. At the end of 2013 this increased

significantly to 200 mS/m. This has been trending slightly downward since this peak and is

now measured at approximately 125 mS/m.

P-8D generally experiences EC bound between 400 and 450 mS/m. This has however

experienced significant dips in EC most recently seen at the end of 2015. These are short

lived and results generally only last one monitoring period. The general level has remained

relatively stable but is elevated in comparison to upstream locations.

PL-6D showed a decreasing trend from a high level of approximately 170 mS/m in 2012. At

the start of 2015 the level seems to have changed trend and is now generally trending

upwards. This is however still below the initial high point and seems to be indicating some

stabilisation.

PL-8D has remained very stable through the data set. This site generally measures around 25

mS/m and fluctuates very slightly. It is noteworthy that this site is relatively far from the

site and indicates levels similar to those seen in PL-3D which is far upstream of site.

GEO-5D is slightly elevated in comparison to PL-8D and shows slightly more fluctuation.

However it is similar to the previously mentioned site in that it trends within a range that

resembles upstream quality and is significantly more stable that sites closer to the site.

0

10

20

30

40

50

60

70

80

11

/14

/20

12

2/1

2/2

01

3

4/1

6/2

01

3

6/1

0/2

01

3

8/7

/20

13

11

/5/2

01

3

2/4

/20

14

4/9

/20

14

6/3

/20

14

8/1

2/2

01

4

10

/3/2

01

4

12

/18

/20

14

2/4

/20

15

4/7

/20

15

6/1

9/2

01

5

8/1

2/2

01

5

10

/9/2

01

5

12

/18

/20

15

mS

/mBorehole No. GEO-5D Down Stream Waste Site

EC (ms/m)


16-0063 06 September 2016 Page 27

In general monitoring localities in close proximity to the site seem to experience elevated EC

in comparison to those located further away.

As has been stated in previous audits the context of the ground water needs to be taken into

account when interpreting the results presented. The current facility is a modern lined

facility that is built in, or in the case of the general waste site, on the old unlined facility.

This facility would have been contributing to the groundwater condition prior to the current

facility. The remedial action of decommissioning the old site and taking engineering actions

to reduce potential contamination was a large factor in the planning process and was reported

as a positive activity at the EIA phase. It is further noted that the improvement in ground

water conditions is expected to take many years. It is thus important to consider the current

conditions as an improving situation and to continue monitoring the quality to verify this

improvement.


16-0063 06 September 2016 Page 28

10.2 Storm Water Quality

Table 10-9 Storm Water Quality Runoff

The graph above indicates that a significant improvement was seen after the first phase of

capping. This is evidence of the success of the phase and has significantly improved the

environmental conditions on site. It is further noted that the current levels trend in a similar

(but slightly elevated) range to upstream ground water.

10.3 H:H Leachate Dam

Contaminated water from the new waste disposal facility is collected and channelled into

the leachate collection dam. It was reported to the auditor that the system works well and

generally evaporates. If required water can be pumped to the Main Treatment Plant (MTP)

for treatment and reuse.

020406080

100120140160180200220240260280300320340360380400420440460480500

28-J

an

-10

31-M

ar-

10

11-N

ov-1

0

17-N

ov-1

0

06-J

an

-11

02-M

ar-

11

18-M

ar-

11

11-O

ct-

11

24-N

ov-1

1

28-D

ec-1

1

09-J

an

-12

20-F

eb

-12

18-S

ep

-12

14-N

ov-1

2

25-A

pr-

13

29-N

ov-1

3

06-F

eb

-14

04-M

ar-

14

20-N

ov-1

5

12-D

ec-1

5

23-J

an

-16

Ele

ctr

ica

l c

on

du

cti

vit

y (

mS

/m)

Date sampled

Storm water quality run off from Disposal site (EC)

Prior to capping at phase 1

After completion of capping at phase 1

After completion of capping at phase 2


16-0063 06 September 2016 Page 29

A summary of the results as presented in the monitoring committee report is provided. For

specific graphical representation of these results please see the annexed monitoring

committee report.

In general the EC of the water quality in the leachate dam has a slight upward trend. In

general the EC did not breach 10000uS/cm level prior to March 2015. Since March 2015 the

level has been above 10000uS/cm in all but one case. This peaks in January 2016 with the

final data point dropping significantly from this point. There are a number of reasons that

could have contributed to the increase in EC. It is however noted that the system is designed

as a closed system and as such this is not a significant risk. The noted audit observation that

the canal draining the site to the leachate dam is clogged needs to be addressed however.

The leachate dam was observed to be in good condition during the audit. It had significant

freeboard and did not seem to pose any risk of overflow. The results of rainfall and dam level

back this observation with the site breaching 55% full on only 3 occasions since January 2011.

10.4 Air Quality Monitoring

It is noted that ambient air quality results were provided as summary results from the

Monitoring Committee Report.

Air quality related to the site is reported to include PM10 and dust fall out. PM10 is monitored

in the north and west stations and is reported to average 54.30 ug/m3 in the north and

44.16ug/m3 in the west stations respectively.

Dust fall out is measured on site and is graphically represented below.

It is noted that the levels are elevated at monitoring site DB9. This site is located adjacent

to the main haul road to the waste site and is being significantly influenced by entrained dust

from passing vehicles. This station did however experience elevated levels in the previous

audit period and was highlighted as an area of environmental improvement. During the audit

it was observed that the road in this area was being watered to suppress dust. The results

presented indicate that with diligent suppression levels can be kept below the industrial air

quality standard of 1200 mg/m.day. This is evidenced by the fact that the site was maintained

below this level from May 2015 to February 2016 (with one exception in December 2015).


16-0063 06 September 2016 Page 30

It is noted here that national Air Quality Regulations require exceedances to be reported once

a site has experienced more than 2 non sequential exceedance events occur. The fact that

this station is clearly being influenced by the road is material to the elevated levels. It is also

noted that the results are discussed in the MSMC and that the department is invited to the

meetings. The department should however be approached and clarity should be sought on

the required formal reporting.


16-0063 06 September 2016 Page 31

Table 10-10 Waste Site Dust Fall Out

0.00

500.00

1000.00

1500.00

2000.00

2500.00

3000.00

3500.00

DB 1 DB 3 DB 4 DB 5 DB 6 DB 9

Waste Site Dust Fall Out 2015 - 2016

Feb-15 Mar-15 Apr-15 May-15 Jun-15 Jul-15 Aug-15

Sep-15 Oct-15 Nov-15 Dec-15 Jan-16 Feb-16

DB 9 located along the main access road to domestic

waste site

mg

/m2

.


16-0063 06 September 2016 Page 32

10.5 Waste Disposal Results

Table 10-11 Waste Summary Results

Produced Disposed Internally Reused Sold Stored Holfontein

Jan-15 248 081 126 937 21 214 91 698 7 444 434

Feb-15 183 481 88 057 17 202 66 811 10 270 800

Mar-15 216 609 112 025 20 804 80 049 2 866 571

Apr-15 176 641 85 827 17 100 66 427 6 779 272

May-15 166 932 75 706 16 396 69 509 4 427 702

Jun-15 159 685 71 952 17 636 64 788 4 631 510

Jul-15 188 484 91 807.7 20 327 69 355 5 035 1 645

Aug-15 167 073 82 698 17 123 62 150 4 543 384

Sep-15 133 348 62 070 12 892 54 889 2 329 1 037

Oct-15 146 395 67 909 15 856 46 049 13 880 2 624

Nov-15 143 711 65 256 15 387 56 697 5 755 507

Dec-15 144 206 77 200 14 935 42 478 5 755 695

Total 2015 2 074 645 1 007 446 206 872 770 901 73 714 10 179

Average12 172 887 83 954 17 239 64 242 6 143 848

Table 10-12 Waste Management Summary

48.69%

10.00%

37.26%

3.56%0.49%

Total 2015

Disposed Internally Reused Sold Stored Holfontein


16-0063 06 September 2016 Page 33

Table 10-13 Total Waste and By-product Generated

Table 10-14 Waste Disposed Internally

0

50 000

100 000

150 000

200 000

250 000

300 000

Jan

-15

Feb-1

5

Mar-

15

Ap

r-15

May-1

5

Jun

-15

Jul-1

5

Au

g-1

5

Se

p-1

5

Oct-

15

Nov-1

5

Dec-1

5

Waste and By-products generated

0

20 000

40 000

60 000

80 000

100 000

120 000

140 000

Jan

-15

Feb-1

5

Mar-

15

Ap

r-15

May-1

5

Jun

-15

Jul-1

5

Au

g-1

5

Se

p-1

5

Oct-

15

Nov-1

5

Dec-1

5

Waste Disposed internally


16-0063 06 September 2016 Page 34

Table 10-15 By-product Recycled and Re-used

Table 10-16 By-products Sold

0

5 000

10 000

15 000

20 000

25 000

Jan

-15

Feb-1

5

Mar-

15

Ap

r-15

May-1

5

Jun

-15

Jul-1

5

Au

g-1

5

Se

p-1

5

Oct-

15

Nov-1

5

Dec-1

5

By-products Recycled and re used

0

10 000

20 000

30 000

40 000

50 000

60 000

70 000

80 000

90 000

100 000

Jan

-15

Feb-1

5

Mar-

15

Ap

r-15

May-1

5

Jun

-15

Jul-1

5

Au

g-1

5

Se

p-1

5

Oct-

15

Nov-1

5

Dec-1

5

By-products Sold


16-0063 06 September 2016 Page 35

Table 10-17 By-product Stored

Table 10-18 Vereeniging Waste Disposal

11 EMP COMPLIANCE

As per previous audit procedure the EMP has been audited concurrent to the RoD. The level

of overlap in mitigation measures allows for the reporting on EMP compliance to be

undertaken as general observations rather than aspect specific reporting.

In this regard the following observations are noted.

0

2 000

4 000

6 000

8 000

10 000

12 000

14 000

16 000

Jan-15 Feb-15 Mar-15 Apr-15 May-15 Jun-15 Jul-15 Aug-15 Sep-15 Oct-15 Nov-15 Dec-15

Stored

96%

4%

Vereeniging Waste

Disposed Internally Holfontein


16-0063 06 September 2016 Page 36

11.1 General EMP Conditions

Conditions listed as general and as such applicable to all sites covered by the authorisation

were observed to be adhered to. Health and Safety Standards on the sites appeared to be in

order at the time of the site visit and the general impression was one of a well maintained

operation.

Formal site access and control is well managed and is restricted by physical and management

measures. It was reported to the auditor that people did access the site informally to

“scavenge” recyclable material from the facility. This poses potential risks to the people

accessing the site as well as secondary risks such as the reported small fires started by these

people. This is managed through the security system and the incidents are recorded in the

incident log.

11.2 Closure and rehabilitation of the old waste site

Closure and rehabilitation is being undertaken in a phased approach. This has been reported

on in the RoD compliance audit. The activities are progressing in what appears to be a

satisfactory manner and the closure of the site is having positive impacts such as evidenced

by the improvement and stabilisation of the stormwater quality.

Revegetation on earlier capping phases were observed to be well established. The most

recent revegetation activities had recently been mowed which made assessment difficult. It

was however reported that the germination was relatively unsuccessful and that the cut plant

material was mainly from in-situ seeds. These are generally pioneer species and this will need

to be assessed in the future to determine if fertiliser and or re-seeding is required. The

cutting of this vegetation is however considered to be the correct corrective action as this

will allow any viable grasses contained in the seed mix to establish themselves.

11.3 New Dry Metallurgical Waste Disposal Site Facility

The New facility was constructed prior to the audit period and as such only operational

management is considered.

In general there is compliance to the operational environmental management plan. One issue

that has been considered is the occurrence of dust within the site. This is particular to DB9


16-0063 06 September 2016 Page 37

which is located in in close proximity to the access / haul road. This is an issue in both this

and the previous audit period and should as such be rectified. Dust suppression management

was observed during the site visit and the results of the dust monitoring do indicate that the

site can be managed effectively. The site was generally dust free at the time of the audit

and there were no obvious odours or other air quality or noise nuisance conditions related to

the waste facilities noted.

Vehicles observed were well maintained and it is reported that there is a scheduled

maintenance plan for the relevant vehicles.

The drainage system from the toe drain to the leachate control dam needs to be maintained

as this is overgrown and is clogged with sediment. Maintenance on this needs to be

implemented to prevent potential overflow during rainfall events.

The waste acceptance criteria are well documented and there is significant control prior to

the site. This is in the form of weigh bridges and gates which are manned. There were a few

incidents in the incident register relating to inappropriate disposal but the fact that these

are being observed and addressed indicates that management control is in place and is

effective.

Mechanical removal (cutting) of alien vegetation is undertaken and recently mowed areas

were observed during the site visit. The most current EMP included the recommendations of

the ecological management plan. The Golder ecological management plan was not observed

during the audit and it is noted that this is an updated plan which is not included in the most

current EMP.

11.4 H:H leachate control dam

The leachate control dam was observed to be in good condition and there was sufficient

freeboard at the time of the audit. This is confirmed to be a general state as the level

monitoring data indicates that it only rarely exceeds 55% capacity.

As has been noted water from the transfer station does not flow directly to this dam. It is

however reported that this enters a sump and is then pumped to a dust suppression tank.

Overflow is reportedly directed to the leachate dam. Again as has been noted the cement

lined canal from the toe drain to the dam was observed to be overgrown and silted. This is a

maintenance issue and should be rectified.


16-0063 06 September 2016 Page 38

11.5 New H:H Salt Cell

No new activity is reported in this facility. Approval process discussions have been

documented in the previous audit and from the interview conducted on site is evident that

these are ongoing.

11.6 General Waste Disposal Site

The general waste disposal site was generally well operated within the requirements of the

EMP. The site was observed to be relatively clean at the time of the site visit but continuous

litter clean-up is recommended. Waste separation bins were noted in office areas indicating

waste sorting as required by the EMP.

11.7 New H:H sludge Dam

This has not been constructed and is as such not applicable to the audit period.

11.8 New Blast Furnace Slag Storage Area

This has not yet been constructed and as such is not relevant to this audit period

12 CONCLUSIONS AND RECOMMENDATIONS

In conclusion the site is broadly compliant to the conditions of the RoD and EMP. There are

some items that need to be resolved. These include

• Provision of the formal approval of the Ground Water Monitoring Plans (surface water

plans have been approved).

• Resolution regarding the construction of the Salt Cells (although this was undertaken

outside the audit period).

• Maintenance of the water canal to the leachate lagoon.


16-0063 06 September 2016 Page 39

• Assessing the latest rehabilitation measures once the current mowed areas have

regrown.

• Assessing the current EMP and ensuring that the Ecological Management requirements

recommended by Golder are considered.

Despite these observations the auditor is of the opinion that the site demonstrates

management control and that material environmental degradation is prevented in the

operation of the site.


16-0063 06 September 2016

APPENDIX A DECLERATION OF THE INDEPENDENCE OF THE AUDITOR

DECLARATION OF THE ENVIRONMENTAL AUDITOR

I, Grant Cornish-Bowden , declare that –

General declaration:

• I act as the independent environmental auditor in this assessment;

• I perform the work relating to the assessment in an objective manner, even if this results in

views and findings that are not favourable to the authorisation holder;

• I declare that there are no circumstances that may compromise my objectivity in performing

such work;

• I have no, and will not engage in, conflicting interests in the undertaking of this assessment;

• I undertake to disclose to the holder and the competent authority 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 competent authority; and - the objectivity of any

report, plan or document to be prepared by myself for submission to the competent authority;

• I will provide the competent authority with access to all information at my disposal regarding

the assessment, whether such information is favourable to the holder or not;

• All the particulars furnished by me in this form are true and correct;

Disclosure of Vested Interest

• I do not have and will not have any vested interest (either business, financial, personal or other)

in the proposed activity proceeding other than remuneration for work performed in terms of

the Environmental Impact Assessment Regulations, 2014;

Signature of the environmental auditor

GCS Water and Environment Pty Ltd

Name of company

17 / 08 / 2016

Date


16-0063 06 September 2016

APPENDIX B INFORMATION SUBMITTTED ON AN ANNUAL BASIS: CONDITION 5.2.1 AND 9.1


16-0063 06 September 2016

APPENDIX C FORM TO BE USED FOR CHEMICAL INFORMATION: CONDITION 9.3


16-0063 06 September 2016

APPENDIX D EXTERNAL COMPLIANTS REGISTER

Date Complainant Complaint Comments /Findings Responsible

investigator

24 hour

report

PIVOT Pivot Nr Responded

2015

07-Mar-15

Annelie van der Merwe

(resides at Johan Dewing

residence)

Ms Annelie van der Merwe a resident at a

neighboring small holding laid a complaint to Johan

Hattingh (Environmental Manager ArcelorMittal,

Vanderbijlpark Works) that on the afternoon of 7

March 2015 as well as the week before she and

other people on the property alledgely suffered

physical complications and experienced an acid

smell on the property. She blamed Vanderbijlpark

Works as the source of the acid smell and

symptoms they alledgely experienced.

Environmental management have requested security to

visit Du Preez corner to confirm allegations. Nothing

could be smelled or observed by security. On previous

occasions Mr Dewing complaint but nothing originating

from Vanderbijlpark Works could be confirmed during

the investigations. This complaint was investigated and

no source from the Works could be identified during

the investigtion. Ms Van Der Merwe was provided with

a feedback letter on 12 March 2015.

Johan Hattingh /

Pheello Bambo / J

Daffue

Yes Yes VDB-2015-03-067 Yes

13-Mar-15



residence)

Ms Annelie van der Merwe a resident at a

neighboring small holding laid a second complaint

with a sms to Johan Daffue at 08:17 on Friday 13

March. She also laid a complain on 7 March 2015.

She alledgely suffered physical complications and

experienced an acid smell on the property. She

blamed Vanderbijlpark Works as the source of the

acid smel and symptoms they alledgely

experienced.

Environmental management drove to Du Preez corner,

but nothingh could be be smelled. on previous

occasions Mr Dewing complaint but nothing originating

from Vanderbijlpark Works could be confirmed during

the investigations.

Johan Hattingh /

Pheello Bambo / J

Daffue

Yes Yes VDB-2015-03-093 Yes

02-Apr-15



residence)

Complaint concerned an alleged bad smell and

perceived symptoms emanating from the Works.

The wind was blowing from a southern direction (from

Sasolburg north towards Vanderbilpark) during the time

in which the complainant experienced the oily smell.

People in Vaalpark as well as in the western suburbs of

Vanderbijlpark also experienced an oily smell during

the same time of the complaint. The source of the smell

therefore is likely to be in the Sasolburg area.

No upset conditions in Vanderbijlpark Works could be

detected from internal monitoring during the time.

Feedback letter issued on 8 Apr 2015.

Johan Daffue No Yes VDB-2015-04-041 Yes

15-Jun-15 Johan Dewing Complaint concerned an alleged bad smell

emanating from the Works.

The officer on duty reported that no offensive odours

could be detected from the Works at the time of the

complaint. Upon further investigation, it was

established that the wind was blowing from a south-

westerly direction when the complaint was received,

indicating that the source of the foul smell detected at

the complainant's residence could in all likelihood not

originate from activities at the Works

Terrence Wilson Yes Yes VDB-2015-06-149 Yes

External Complaints Register

01-Jul-15 Johan Dewing

Complaint concerned an alleged bad smell (tar

smell / burning plastic smell) emanating from the

Works.

No tar smell was observed by the responder to the

complaint at 19h45. Data obtained from the ambient

monitoring station located towards the south-east of the

Works reveals relatively high concentrations of

benzene from external sources at the time of the

complaint, which may, in part, be indicative of plastic or

domestic coal burning in neighbouring informal

settlements. The wind was blowing predominantly from

an east-south-easterly direction. Emissions in the area

are elevated in winter months when coal and other

combustible materials (including wood, plastics, and

rubber) are burnt as a source of heat. Conditions are

exacerbated by the atmospheric phenomenon known

as the inversion layer, which is typical on the Highveld

in winter.

Terrence Wilson No Yes VDB-2015-07-022 Yes


16-0063 06 September 2016

APPENDIX E EMERGENCY RESPONSE PLAN

This printed document is uncontrolled unless it is an OBET training manual or bears a control stamp Page 1 of 5

Centre Vanderbijlpark Works Document Type KPR Effective Date 01 December 2015

Document MHROAD0000005 Version 08 Revision Date 01 December 2016

Status Released Approved By RADESH RUBIKESAN

Title ENVIRONMENTAL RESPONSE PLAN

1. RESPONSE ACTION PLAN

In the event of failure in the design and/or operation of the ArcelorMittal Vanderbijlpark Works Consolidated Residue Management Facility (CRMF), this Response Action Plan will be utilized to deal with the situation rapidly and efficiently. This document also outlines the procedure to be followed in the event of emergencies occurring within the CRMF.

Ambulance point 58A is situated at the road weighbridge to the existing waste disposal site.

2. RELATED DOCUMENTS

• Vanderbijlpark Works SHE Emergency Plan (Risk-Mang-040)

• Disposal Dust Suppression Operation (MHROAD0000006)

• Fatality Prevention Standard on Confined Spaces 3. DEFINITION CRMF: Consolidated Residue Management Facility. The CRMF comprises the following facilities:

• Waste disposal site

• Dam 10

• CETP sludge dams

• Maturation Ponds

• Dams 1-4

• Raw material and by-products storage areas

• Emergency Dams

• Open veldt areas

• Salt Cell

4. EMERGENCY CONTACT DETAILS

The following emergency numbers will be displayed prominently inside the waste site access control building, and will be stored on the cellular phone of the Site Supervisor:

Ambulance: (016) 889-4444 / 88

Fire Brigade: (016) 889-4444 / 88

Police: (016) 910-9046

Site Supervisor: (016) 889-4156or 5029short cell

This document replaces MHROAD0000005, KPR, 000, 07

Reason for revision REVISED TO INCLUDE OTHER FACILITIES LOCATED WITHIN THE CRMF AREA.

Destination group ROAD TRANSPORT CONTRACTORS, AMCC & EQUIPMENT YARD PERSONNEL, ALL

OTHER PERSONNEL AND CONTRACTORS WITH ACCESS TO THE CRMF

MHROAD0000005 Vers ion 08


5. EMERGENCY RESPONSE

In case of an emergency situation occurring within the CRMF area, the Site Supervisor (displayed on notice board) will immediately be informed of such a situation, where after the Site Supervisor will take appropriate action. All personnel within the CRMF at the time of such an emergency occurring will make themselves available for assistance in resolving the emergency and will co-operate fully with the Site Supervisor until the emergency is brought under control. They will however not be required to put their lives in danger. The Site Supervisor will determine the seriousness of the situation, and may stop all operations on the site until the situation has been resolved. The Site Supervisor will, at the earliest convenient opportunity, inform the Responsible Person of the incident. The Responsible Person will assist in resolving any problem as soon as possible.

Any incident happening within the CRMF will be regarded in a serious light, and immediate attention will be given to resolve the issue. The Site Supervisor will not leave the site until such time as every aspect of the incident has been brought under control, and until the conditions on site are safe and have normalized. As soon as possible after the conclusion of an emergency event, the Site Supervisor will compile a report of the incident and will submit this to the Responsible Person. This report will include all details, circumstances, times, names and actions taken to enable the reader to determine whether all reasonable steps were taken in response to the incident. The Site Supervisor will also give recommendations on how such an incident can be prevented in future. The Response Action Plan will be discussed with all personnel and contractors during the site induction program (specifically those people who will be entering the CRMF on a frequent basis).

The most likely emergencies that could occur within the CRMF include:

• Fire – including veldt fires and vehicle / machinery fires (call fire brigade and Site Supervisor);

• Vehicle accidents and railway incidents (call ambulance and Site Supervisor);

• Medical emergencies (call ambulance and report to Site Supervisor);

• Contaminated waste bins (report to Site Supervisor);

• Surface water contamination (report to Site Supervisor);

• Ground surface contamination (report to Site Supervisor);

• Air pollution (report to Site Supervisor);

• Accidental and unauthorized disposal (report to Site Supervisor);

• Disruption of essential services, such as potable water supply (report to Site Supervisor);

• Spillage of raw materials, products, by-products and waste (report to Site Supervisor);

• Natural disasters (call Site Supervisor);

• Disposal site slope failure (call Site Supervisor);

• Accidents at disposal site tip station (call ambulance and Site Supervisor);

• Engulfment / Entrapment in confined spaces (e.g. storm water manholes) (call ambulance and Site Supervisor)

5.1 FIRES

• No fires will be permitted on, or near, the CRMF.

• Whenever a veldt fire is noticed within and in the vicinity of the CRMF, the Site Supervisor will inform Asset Protection Services (Site Fire Brigade) of this event, and will request that they extinguish the fire. All fires within a 1km radius from the site will be regarded as an incident and will be reported on the applicable forms held at the road weighbridge.

• Whenever a veldt fire progresses to a position that is near or within the CRMF site boundary, the Site Supervisor will stop all activities within the vicinity of the fire and take the appropriate action under the circumstances. These actions might include:

o Ordering all personnel within the CRMF to assist in putting the fire out o Ordering equipment within the CRMF to be moved to a safe location o Ordering the evacuation of people within the CRMF to a safe location

• The Site Supervisor will, under all circumstances, consider the safety of the people to be the primary responsibility. A secondary responsibility is the safety of equipment on site, and the CRMF itself.

• Combustion of waste material within the site will be extinguished as soon as it has been noticed.



5.2 VEHICLE AND RAILWAY ACCIDENTS

• All vehicle and railway accidents will be reported to Asset Protection Services, who will obtain the necessary assistance and ensure that the accident is dealt with in the correct manner. The Site Supervisor will also be informed about the accident.

• The Site Supervisor will manage, or re-route, the traffic until the accident is cleared in order to minimize potential delays or further accidents; and

• The weighbridge personnel will inform all traffic entering/exiting the CRMF of the temporary safety measures until the accident is cleared.

5.3 MEDICAL EMERGENCIES

• All medical emergencies (snake bites, bee stings, etc) will be reported to Asset Protection Services, who will obtain the necessary medical assistance and ensure that the employee/contractor receives the correct medical attention. The Site Supervisor will also be informed about the accident.

• In case of an emergency, RCAT will be followed to identify the deficiency.

• An Incident Report will be completed within 24 hours (or before) the same task has to be performed again.

• Corrective actions will be implemented and reviewed after the investigation is completed.

• Each employee/contractor, at induction, will be informed of following: o Nearest emergency exit to their workstation; o Alternate exit and route; o All emergency numbers; o Nearest telephone; and o Reporting system.

5.4 CONTAMINATED WASTE BINS

• No contaminated waste bins (grease, oil, tar sludge etc.) will be authorised to enter the disposal site area.

• Any contaminated waste bins will be reported to the Site Supervisor and the Road Transport Control Room (016-889-2569).

• If a waste bin arrives at the weighbridge and the weighbridge operator is uncertain of what materials is in the bin, he/she will contact the Site Supervisor who will inspect and approve the material before allowing it to be dumped.

5.5 GROUND WATER POLLUTION

• No liquid waste will be allowed onto the waste site for disposal unless it is approved by the Manager Environmental Management and the permit (ad-hoc disposal form) is taken with the load to the road weighbridge as proof.

• An incident of this nature will be reported to the Site Supervisor, who will in turn inform the Manager: Environmental Management, and record the incident in the incident report book.

5.6 SURFACE WATER CONTAMINATION

• Raw materials, products, by-products and waste will be stored / disposed of in designated areas. Deviations are to be reported to the Site Supervisor.

• Spillage of raw materials, products, by-products and/or waste en-route to designated storage / disposal areas will be cleaned as soon as practically possible to prevent storm water contamination.

5.7 AIR POLLUTION

• Un-surfaced roads will be watered regularly to prevent excessive fugitive dust emissions.

• Vehicles and equipment with excessive exhaust smoke will be prevented from entering the CRMF by the weighbridge personnel.



5.8 ACCIDENTAL UNAUTHORIZED DISPOSAL

5.8.1 Disposal of Medical / Flammable / Radioactive waste

• No medical, flammable or radioactive waste will be allowed into the site for disposal.

• Any attempted disposal of such wastes at the facility will be reported immediately to the Site Supervisor. The Site Supervisor will in turn immediately inform the Responsible Person when such material is found.

• A note will be made of the load in the record book and the reason for rejection of the load will be mentioned.

• The Responsible Person will take appropriate action when such waste streams are encountered to prevent the occurrence of a similar incident in the future.

5.9 DISRUPTION OF ESSENTIAL SERVICES

• Any disruption to essential services, such as to the potable water supply to manned stations in the CRMF, will be reported to the Site Supervisor as soon as possible.

• The Site Supervisor will inform the Responsible Person for rectification.

5.10 SPILLAGE OF RAW MATERIALS, PRODUCTS, BY-PRODUCTS AND/OR WASTE EN ROUTE


• Any spillages en route to storage / disposal areas will be reported to the Site Supervisor.

• The Site Supervisor will co-ordinate clean-up of the spillage.

5.11 NATURAL DISASTERS

• Incidents arising from natural disasters will be dealt with on a case by case basis.

• Should evacuation be necessary, the procedure outlined in RISK-MANG-040 will be followed.

• The required reporting will also be done in accordance with RISK-MANG-040.

5.12 DISPOSAL SITE SLOPE FAILURE

• Disposal of waste will conform to operating design criteria so as not to exceed the angle of repose.

• Slope integrity will be inspected on an annual basis as part of the audit to be conducted by a registered engineer.

5.13 ACCIDENTS AT DISPOSAL SITE TIP STATION

• The procedure for Disposal Dust Suppression Operation (MHROAD0000006) will be conformed to at all times.

• Any accidents will be reported to Asset Protection Services and the Site Supervisor.

5.14 ENGULFMENT / ENTRAPMENT IN CONFINED SPACES

• All contactors and personnel working within the CRMF area shall conform to the Fatality Prevention Standard on Confined Spaces.

• No unauthorized entry into confined spaces is allowed.

6. EVACUATION PLAN

During an emergency where the Site Supervisor has given the instruction to evacuate the waste site or CRMF, or when an individual within the CRMF deems it unsafe to retain their presence within the area, the following evacuation plan will be followed:

• The appropriate emergency numbers will be contacted (if time allows without compromising safety).

• The access gate controller will ensure that the access booms are open so that any emergency vehicles can have easy access into the facility (if time allows without compromising safety).



• The first aid representative within the CRMF will collect the first aid kit when exiting the building (if time allows without compromising safety).

• All people will vacate the CRMF, if necessary.

• Any people who have been injured, have a disability or require assistance, will be assisted in the evacuation.

• Individuals within one of the cells within the waste facility will proceed to the nearest possible exit point.

• All people will proceed along the access road towards the entrance/exit gate and continue outside of the CRMF area. People will retreat to a safe distance from the incident and await assistance from the Asset Protection Services.

• The Responsible Person will be contacted and informed regarding the emergency and evacuation. APPENDIX – ACCIDENT/INCIDENT REPORT

ACCIDENT/INCIDENT REPORT

ARCELORMITTAL VANDERBIJLPARK

DISPOSAL SITE

Date of Accident/Incident: Time of Accident/Incident:

Reported By: Site Supervisor Signature

Reported on (Date)


16-0063 06 September 2016

APPENDIX F ENVIRONMENTAL RESPONSE PLAN


Centre Vanderbijlpark Works Document Type KPR Effective Date 01 December 2015

Document MHROAD0000005 Version 08 Revision Date 01 December 2016

Status Released Approved By RADESH RUBIKESAN

Title ENVIRONMENTAL RESPONSE PLAN

1. RESPONSE ACTION PLAN

In the event of failure in the design and/or operation of the ArcelorMittal Vanderbijlpark Works Consolidated Residue Management Facility (CRMF), this Response Action Plan will be utilized to deal with the situation rapidly and efficiently. This document also outlines the procedure to be followed in the event of emergencies occurring within the CRMF.

Ambulance point 58A is situated at the road weighbridge to the existing waste disposal site.

2. RELATED DOCUMENTS

• Vanderbijlpark Works SHE Emergency Plan (Risk-Mang-040)

• Disposal Dust Suppression Operation (MHROAD0000006)

• Fatality Prevention Standard on Confined Spaces 3. DEFINITION CRMF: Consolidated Residue Management Facility. The CRMF comprises the following facilities:

• Waste disposal site

• Dam 10

• CETP sludge dams

• Maturation Ponds

• Dams 1-4

• Raw material and by-products storage areas

• Emergency Dams

• Open veldt areas

• Salt Cell

4. EMERGENCY CONTACT DETAILS

The following emergency numbers will be displayed prominently inside the waste site access control building, and will be stored on the cellular phone of the Site Supervisor:

Ambulance: (016) 889-4444 / 88

Fire Brigade: (016) 889-4444 / 88

Police: (016) 910-9046

Site Supervisor: (016) 889-4156or 5029short cell

This document replaces MHROAD0000005, KPR, 000, 07

Reason for revision REVISED TO INCLUDE OTHER FACILITIES LOCATED WITHIN THE CRMF AREA.

Destination group ROAD TRANSPORT CONTRACTORS, AMCC & EQUIPMENT YARD PERSONNEL, ALL

OTHER PERSONNEL AND CONTRACTORS WITH ACCESS TO THE CRMF



5. EMERGENCY RESPONSE

In case of an emergency situation occurring within the CRMF area, the Site Supervisor (displayed on notice board) will immediately be informed of such a situation, where after the Site Supervisor will take appropriate action. All personnel within the CRMF at the time of such an emergency occurring will make themselves available for assistance in resolving the emergency and will co-operate fully with the Site Supervisor until the emergency is brought under control. They will however not be required to put their lives in danger. The Site Supervisor will determine the seriousness of the situation, and may stop all operations on the site until the situation has been resolved. The Site Supervisor will, at the earliest convenient opportunity, inform the Responsible Person of the incident. The Responsible Person will assist in resolving any problem as soon as possible.

Any incident happening within the CRMF will be regarded in a serious light, and immediate attention will be given to resolve the issue. The Site Supervisor will not leave the site until such time as every aspect of the incident has been brought under control, and until the conditions on site are safe and have normalized. As soon as possible after the conclusion of an emergency event, the Site Supervisor will compile a report of the incident and will submit this to the Responsible Person. This report will include all details, circumstances, times, names and actions taken to enable the reader to determine whether all reasonable steps were taken in response to the incident. The Site Supervisor will also give recommendations on how such an incident can be prevented in future. The Response Action Plan will be discussed with all personnel and contractors during the site induction program (specifically those people who will be entering the CRMF on a frequent basis).

The most likely emergencies that could occur within the CRMF include:

• Fire – including veldt fires and vehicle / machinery fires (call fire brigade and Site Supervisor);

• Vehicle accidents and railway incidents (call ambulance and Site Supervisor);

• Medical emergencies (call ambulance and report to Site Supervisor);

• Contaminated waste bins (report to Site Supervisor);

• Surface water contamination (report to Site Supervisor);

• Ground surface contamination (report to Site Supervisor);

• Air pollution (report to Site Supervisor);

• Accidental and unauthorized disposal (report to Site Supervisor);

• Disruption of essential services, such as potable water supply (report to Site Supervisor);

• Spillage of raw materials, products, by-products and waste (report to Site Supervisor);

• Natural disasters (call Site Supervisor);

• Disposal site slope failure (call Site Supervisor);

• Accidents at disposal site tip station (call ambulance and Site Supervisor);

• Engulfment / Entrapment in confined spaces (e.g. storm water manholes) (call ambulance and Site Supervisor)

5.1 FIRES

• No fires will be permitted on, or near, the CRMF.

• Whenever a veldt fire is noticed within and in the vicinity of the CRMF, the Site Supervisor will inform Asset Protection Services (Site Fire Brigade) of this event, and will request that they extinguish the fire. All fires within a 1km radius from the site will be regarded as an incident and will be reported on the applicable forms held at the road weighbridge.

• Whenever a veldt fire progresses to a position that is near or within the CRMF site boundary, the Site Supervisor will stop all activities within the vicinity of the fire and take the appropriate action under the circumstances. These actions might include:

o Ordering all personnel within the CRMF to assist in putting the fire out o Ordering equipment within the CRMF to be moved to a safe location o Ordering the evacuation of people within the CRMF to a safe location

• The Site Supervisor will, under all circumstances, consider the safety of the people to be the primary responsibility. A secondary responsibility is the safety of equipment on site, and the CRMF itself.

• Combustion of waste material within the site will be extinguished as soon as it has been noticed.



5.2 VEHICLE AND RAILWAY ACCIDENTS

• All vehicle and railway accidents will be reported to Asset Protection Services, who will obtain the necessary assistance and ensure that the accident is dealt with in the correct manner. The Site Supervisor will also be informed about the accident.

• The Site Supervisor will manage, or re-route, the traffic until the accident is cleared in order to minimize potential delays or further accidents; and

• The weighbridge personnel will inform all traffic entering/exiting the CRMF of the temporary safety measures until the accident is cleared.

5.3 MEDICAL EMERGENCIES

• All medical emergencies (snake bites, bee stings, etc) will be reported to Asset Protection Services, who will obtain the necessary medical assistance and ensure that the employee/contractor receives the correct medical attention. The Site Supervisor will also be informed about the accident.

• In case of an emergency, RCAT will be followed to identify the deficiency.

• An Incident Report will be completed within 24 hours (or before) the same task has to be performed again.

• Corrective actions will be implemented and reviewed after the investigation is completed.

• Each employee/contractor, at induction, will be informed of following: o Nearest emergency exit to their workstation; o Alternate exit and route; o All emergency numbers; o Nearest telephone; and o Reporting system.

5.4 CONTAMINATED WASTE BINS

• No contaminated waste bins (grease, oil, tar sludge etc.) will be authorised to enter the disposal site area.

• Any contaminated waste bins will be reported to the Site Supervisor and the Road Transport Control Room (016-889-2569).

• If a waste bin arrives at the weighbridge and the weighbridge operator is uncertain of what materials is in the bin, he/she will contact the Site Supervisor who will inspect and approve the material before allowing it to be dumped.

5.5 GROUND WATER POLLUTION

• No liquid waste will be allowed onto the waste site for disposal unless it is approved by the Manager Environmental Management and the permit (ad-hoc disposal form) is taken with the load to the road weighbridge as proof.

• An incident of this nature will be reported to the Site Supervisor, who will in turn inform the Manager: Environmental Management, and record the incident in the incident report book.

5.6 SURFACE WATER CONTAMINATION


• Spillage of raw materials, products, by-products and/or waste en-route to designated storage / disposal areas will be cleaned as soon as practically possible to prevent storm water contamination.

5.7 AIR POLLUTION

• Un-surfaced roads will be watered regularly to prevent excessive fugitive dust emissions.

• Vehicles and equipment with excessive exhaust smoke will be prevented from entering the CRMF by the weighbridge personnel.



5.8 ACCIDENTAL UNAUTHORIZED DISPOSAL

5.8.1 Disposal of Medical / Flammable / Radioactive waste

• No medical, flammable or radioactive waste will be allowed into the site for disposal.

• Any attempted disposal of such wastes at the facility will be reported immediately to the Site Supervisor. The Site Supervisor will in turn immediately inform the Responsible Person when such material is found.

• A note will be made of the load in the record book and the reason for rejection of the load will be mentioned.

• The Responsible Person will take appropriate action when such waste streams are encountered to prevent the occurrence of a similar incident in the future.

5.9 DISRUPTION OF ESSENTIAL SERVICES

• Any disruption to essential services, such as to the potable water supply to manned stations in the CRMF, will be reported to the Site Supervisor as soon as possible.

• The Site Supervisor will inform the Responsible Person for rectification.

5.10 SPILLAGE OF RAW MATERIALS, PRODUCTS, BY-PRODUCTS AND/OR WASTE EN ROUTE


• Any spillages en route to storage / disposal areas will be reported to the Site Supervisor.

• The Site Supervisor will co-ordinate clean-up of the spillage.

5.11 NATURAL DISASTERS

• Incidents arising from natural disasters will be dealt with on a case by case basis.

• Should evacuation be necessary, the procedure outlined in RISK-MANG-040 will be followed.

• The required reporting will also be done in accordance with RISK-MANG-040.

5.12 DISPOSAL SITE SLOPE FAILURE

• Disposal of waste will conform to operating design criteria so as not to exceed the angle of repose.

• Slope integrity will be inspected on an annual basis as part of the audit to be conducted by a registered engineer.

5.13 ACCIDENTS AT DISPOSAL SITE TIP STATION

• The procedure for Disposal Dust Suppression Operation (MHROAD0000006) will be conformed to at all times.

• Any accidents will be reported to Asset Protection Services and the Site Supervisor.

5.14 ENGULFMENT / ENTRAPMENT IN CONFINED SPACES

• All contactors and personnel working within the CRMF area shall conform to the Fatality Prevention Standard on Confined Spaces.

• No unauthorized entry into confined spaces is allowed.

6. EVACUATION PLAN

During an emergency where the Site Supervisor has given the instruction to evacuate the waste site or CRMF, or when an individual within the CRMF deems it unsafe to retain their presence within the area, the following evacuation plan will be followed:

• The appropriate emergency numbers will be contacted (if time allows without compromising safety).

• The access gate controller will ensure that the access booms are open so that any emergency vehicles can have easy access into the facility (if time allows without compromising safety).



• The first aid representative within the CRMF will collect the first aid kit when exiting the building (if time allows without compromising safety).

• All people will vacate the CRMF, if necessary.

• Any people who have been injured, have a disability or require assistance, will be assisted in the evacuation.

• Individuals within one of the cells within the waste facility will proceed to the nearest possible exit point.

• All people will proceed along the access road towards the entrance/exit gate and continue outside of the CRMF area. People will retreat to a safe distance from the incident and await assistance from the Asset Protection Services.

• The Responsible Person will be contacted and informed regarding the emergency and evacuation. APPENDIX – ACCIDENT/INCIDENT REPORT

ACCIDENT/INCIDENT REPORT

ARCELORMITTAL VANDERBIJLPARK

DISPOSAL SITE

Date of Accident/Incident: Time of Accident/Incident:

Reported By: Site Supervisor Signature

Reported on (Date)


16-0063 06 September 2016

ANNEXURE G WASTE MANAGEMENT SYSTEM


Centre Vanderbijlpark Works Document Type KPR Effective Date 20 January 2015

Document SHERQ-SYS-061 Version 12 Revision Date 20 January 2016

Status In Work Approved By GERT LUBBE

Title WASTE MANAGEMENT

1 PURPOSE

The Vanderbijlpark Works waste objective is to achieve an 80% reduction in solid waste disposal by 2018. Good waste management entails good housekeeping practices such as: 1. Reduce the amount of waste generated. 2. Reuse waste. 3. Recycle waste. 4. Sort and discard waste into the correct bin or container. The purpose of this document is to provide guidelines to ensure that proper:

• Waste separation and classification is performed

• Control is exercised for the removal and disposal of hazardous waste and materials.

2 TERMS AND DEFINITIONS

TERMS DEFINITIONS

Building and demolition waste

Means waste, excluding hazardous waste, produced during the construction, alteration, repair or demolition of any structure, and includes rubble, earth, rock and wood displaced during that construction, alteration, repair or demolition.

Business waste Means waste that emanates from premises that are used wholly or mainly for commercial, retail, wholesale, entertainment or government administration purposes.

By-product Means a substance that is produced as part of a process that is primarily intended to produce another substance or product and that has the characteristics of an equivalent virgin product or material.

Coke samples (grey bin)

Waste coke that remains after testing are disposed of in a grey skip bin. This applies only at the Iron Making Laboratories (under supervision of Quality Management).

Dangerous goods declaration / waste manifest

Means a document supplied by the contractor that must be signed by the plant, the driver of the vehicle and the Waste Disposal site operator. This document states what is in the vehicle e.g. 20 000kg Tin Sludge, and where it is going to be disposed of from what plant and by whom.

Driver A person in control of a vehicle.

This document replaces SHERQ-SYS-061/11

Reason for revision The following were changed: Technician waste management to Superintendent Waste

management. RMH & Logistics name changes to Engineering Transport .

PROCEDURE FOR THE TRANSPORTATION OF MTP AND DESALINATION PLANT

SALTS included in document.

Destination group ALL VANDERBIJLPARK WORKS EMPLOYEES AND CONTRACTORS

SHERQ-SYS-061 Vers ion 12


Domestic waste (yellow bin):

Means waste, excluding hazardous waste that emanates from premises that are used wholly or mainly for residential, educational, health care, sport or recreation purposes.

TERMS DEFINITIONS

General waste (yellow bin)

Means waste that does not pose an immediate hazard or threat to health or the environment, and includes – (a) domestic waste (b) building and demolition waste (c ) business waste; and (d) inert waste.

Dust (blue bin) Plant clean-up dust and off gas system dust.

Hazard Sign (orange diamond)

Means the identification “Hazardous Chemical” sign of the chemicals being transported, which is placed on the front of the vehicle.

Hazardous waste (green bin):

Means any waste that contains organic or inorganic elements or compounds that may have significant adverse effect on public health and environment, owing to the inherent physical, chemical or toxicological. Any waste that directly or indirectly represents a threat to human health or to the environment by introducing one or more of the following risks:

• Explosions or fire;

• Infections, pathogens, parasites or their vectors;

• Chemical instability, reactions or corrosion;

• Acute or chronic toxicity;

• Cancer, mutations, tumours or birth defects;

• Toxicity, or damage to the ecosystems or natural resources;

• Accumulation in biological food chains, persistence in the environment, or multiple effects;

That requires special attention and cannot be released into the environment, or is added to sewerage, or is stored in a situation, which is either open to the air or from which aqueous shall be taken to be leachate could emanate. In other words this includes all substances listed in the hazardous substances inventory, as well as waste products or effluents from a plant that contains any of the listed materials, mixtures or products thereof. All domestic waste contaminated with oil or chemicals are included. Study MSDS’s for more detail. If not sure contact Environmental Management.

Reclamation department

The department that sells all re-usable assets at Vanderbijlpark Works. Orange bins can be ordered from RMH & Logistics to transport re-usable assets to Reclamation (e.g. electric cables and panels, etc.).

Safe disposal Disposal to a suitable waste disposal facility.

Disposal Means the burial, deposit, discharge, abandoning, dumping, placing or release of any waste into, or onto, any land.

Inert waste

Means 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.



Minimization When used in relation to waste, means to avoidance of the amount and toxicity of waste that is generated and, in the event where waste is generated, the reduction of the amount and toxicity of waste that is disposed of.

Recovery Means the controlled extraction of a material or the retrieval of energy from waste to produce a product.

TERMS DEFINITIONS

Recycle Means a process where waste is reclaimed for further use, which process involves the separation of waste from a waste stream for further use and the processing of that separated material as a product or raw material.

Reuse Means to utilise articles from the waste stream again for a similar or different purpose without changing the form or properties of the articles.

Storage Means the accumulation of waste in a manner that does not constitute treatment or disposal of that waste.

Transit Means the continuous passage from one border of the Republic to another such border without storage other than temporary storage incidental to transport.

Treatment Means any method, technique or process that is designated to – (a) change the physical, biological or chemical character or composition of an waste; or (b) remove, separate, concentrate or recover a hazardous or toxic component of a waste; or (c ) destroy or reduce the toxicity of a waste, In order to minimise the impact of the waste on the environment prior to further use or disposal.

Waste Means any substance, whether or not that substance can be reduced, re-used, recycled and recovered – (a) that is surplus, unwanted, rejected, discarded, abandoned or disposed of; (b) which the generator has no further use of for the purpose of production; (c ) that must be treated or disposed of; or (d) that is identified as a waste by the Minister by notice in the Gazette, and includes waste generated by the mining, medical or other sector, but – (i) a by-product is not considered waste; and (ii) any portion of waste, once re-used, recycled and recovered, ceases to be waste.

Waste disposal facility

Means any site or premises used for an accumulation of waste with the purpose of disposing of that waste at that site or on that premise.

Medical waste Medical waste includes the following components: infectious waste, sharp objects, anatomical waste, pharmaceutical waste (medicine and pills), pressurized containers, hazardous chemical waste.

Steel Making sludge (black bin)

Sludge originating from the Steel Making process (V1, V2, and V3 only) is disposed of in a black skip bin.

Spent refractory material / bricks

Waste arising from maintenance and rebuilding of torpedo’s, furnaces and ovens.

Steel scrap (red bin)

All steel scrap with more than 30% steel in it, except electrical motors because the copper content influences the quality parameters of steel in the furnaces. Examples: plant spares, side scrap, tail and end scrap and bearings

TREM card Means the transport emergency card listing the hazards and emergency information for a material being transported for use by the driver during an incident, or by the emergency services. Note: only applicable to transportation of hazardous waste.

Sanitary Waste Sanitary Waste includes waste from She Bins that needs to be incinerated



UN number

An internationally excepted four digit number to make life easier in multi-language situations to indicate the correct name for the product / chemicals being transported. The UN identification number shall be displayed on the pleading on the back and sides of the vehicle transporting the hazardous waste.

TERMS DEFINITIONS

Single load placard:

Where one product is transported that correlated with the UN number on the placarding.

Multi-load placard:

Where more than one product is carried - as is usually the case where packaged goods are concerned - a multi-load diamond is used unless the products are all of the same class of hazard. Telephone numbers: The telephone number under the UN number is the telephone number of the hauler who is held responsible for the costs deriving from an incident including rehabilitation of the area and any civil liability claims. The bottom telephone number is of the specialist responder who can give advice and assistance to the responders as to the possible effects of products mixing and how to minimize the effects.

ArcelorMittal Coke and Chemicals (AMCC)

The Business Unit that sells all by products such as granulating slag, raw tar, etc.

RMH & Logistics The department that manages all waste.

3 ABBREVIATIONS

AMCC – ArcelorMittal Coke and Chemicals MSDS - Material Safety Data Sheet PCB - Polychlorinated biphenyls PPE - Personal Protective Equipment RTCR - Road Transport Control Room TREM - Transport Emergency UN - United Nations

4 RELATED DOCUMENTS AND FORMS

• SANS 10228 (SABS 0228): The identification and classification of dangerous goods for transport.

• SANS 10229-1 and SANS10229-2: Transport of hazardous goods.

• Material safety data sheets (MSDS’s).

• Plant Environmental Management Programmes.

• Environmental emergency plan (Environ 000028).

• Weighbridge note.

• Checklist for disposable hazardous waste – Form W.0173 (performed by plant).

5 METHOD OF CONTROL

The plant / department / section, where the waste is generated, will keep an accurate database of waste generation, trade, storage, transport and disposal. These safe disposal certificates are kept at RTCR control room (2-2569) and a copy can be obtained from the central location on request. The managers will handle all deviations from this document.



Note: Please report all new waste streams to Environmental Management for the necessary waste classification and arrangements.

6 WASTE MANAGEMENT PRINCIPLES

PREVENTION

MINIMISATION

REUSE

RECYCLE

TREAT

DISPOSE

6.1 All production processes inevitably lead to waste generation. Many countries experienced shortages in waste disposal landfill capacities and need to implement a waste management programme via waste reduction, reuse and waste recycling to reduce the amount of waste entering the waste stream. The plant or producer of the waste is responsible with input from Environmental Management and the environmental specialist from the SHEQ systems department to manage and minimise their waste.

6.2 Responsible waste management involves the use of efficient technologies and the training of workers in order to make provision for waste separation and easy recovery for reuse and recycling purposes.

6.3 The focus of waste management will have to, prevent, reduce, reuse and recycle, then as a last option the waste musts be treated to reduce toxicity before disposal.

6.4 The following guidance can be used if needed:

� Preventing pollution at the source should be considered first. The generation of waste can be prevented and using a more suitable raw material can optimise production. A better quality raw material will result in higher production figures and less waste being generated.

� The next step will be to minimise the waste through waste reduction. Waste reduction can be achieved by developing clean technologies and processes that requires less material in the end products and produce less waste during manufacturing. This may involve the development of new technologies or adaptations of existing processes. Other methods include the development and manufacture of longer lasting products which are likely to result in less waste when they are used. The waste can also be reused and recycled in the plant to minimise the amount that needs to be discarded of.

� Reuse involves using a product more than once or using it in another application for example the use of tyres for the offloading of oil drums or to be used as rail truck fenders, coke breeze at the Sinter plant, coke samples, etc.

� The third step in waste management is waste recovery. There a number of different types of waste recovery such as

• material recycling (e.g. paper, glass, plastic, cold drink cans, scrap metal, tyres, etc.),

• composting, and

• energy recovery (such as coke oven and blast furnace gas).

� Clean technology, redesign and repair of equipment, waste reduction, waste reuse, waste recovery and recycling focus on minimising the amount of waste that is destined for permanent disposal. All have a minimisation role to play. Waste recovery needs source separation which requires 100% commitment from plant waste generators in managing the waste they produced.



� Recognising that not all wastes can be eliminated through waste reduction, waste reusing, and waste recovery methods or recycling efforts, viable treatment processes must be considered for managing remaining wastes. These include incineration and a host of additional treatment alternatives. Treatment can generally be divided into three categories namely chemical, biological and physical treatment. Treating the waste to reduce its toxicity or volume that needs to be disposed of is the second last step in waste management (e.g. laboratory chemicals to the Desalination plant to form salt crystals). In most of the cases it is a specialised process and can be performed by an external contractor if methods exist to reduce toxicity of a waste stream.

� Lastly, the waste must be disposed of on a correctly designed waste disposal facility for that class of waste. By addressing, the management of waste and making use of the above five steps in the waste management program we will greatly reduce the amount of waste that needs to be disposed of.

7 WASTE REPORTING

In order for Vanderbijlpark Works to manage their waste totally the waste streams and quantities must be tracked per month and reported during the Environmental Management Review as tons per month for the last 12 months. Engineering Transport must track the solid waste quantities that are handled and transported to the disposal or storage sites. This information will be reported monthly to the SHE Practitioners / SHERQ Administrators. The information will be used to track compliance to Vanderbijlpark Works Objectives and Targets. RMH & Logistics will supply on request to each plant, their specific waste information. All the waste streams must be tracked by the individual departments per month and reported during the Environmental Management review of that department. The waste reporting information must be used by Plant managers and managers to determine the yearly waste reduction in order to achieve the 80% reduction in solid waste by 2018.

8 CLASSIFICATION OF WASTE

The classification of solid waste determines handling methods and the ultimate disposal of material. Waste is classified into hazardous waste and non-hazardous waste.

WASTE

CLASSIFICATION

HAZARDOUS NON-

HAZARDOUS

Soil, construction debris and building rubble, tires, steel scrap (metal scrap), timber / wood, electrical components such as cables, panels, motors, plastic such as bottles, bags, personal protective equipment (PPE), rubber, conveyor belt, electronic waste (computers, keyboards, etc.), laser jet and printer cartridges, fiber glass and cold drink cans.

X

Anything contaminated / soiled by hazardous chemicals, oil or organic compounds, oil (containing PCB’s)and grease (lubricants), phenolic waste paint and/or solvents, waste containing appreciable properties of fibrous asbestos, sewerage sludge, explosive waste, aerosol containers, medical waste, radioactive sources, asbestos (such as asbestos heaters), fluorescent tubes, discharge lamps, batteries (wet and/or dry), catalytic and electrochemical sensors (of gas analyzers), instrumentation cells. Man-made mineral fibers also known as Kay wool is classified as hazardous waste due to health reasons.

X

Empty drums (depends on prior use). Empty paint and coating containers (depends on composition).

X

X

Office waste X & Spec 1

Restaurant and/or canteen waste Spec 1

Plant dust / dust extraction system dust, mud/sludge and slag.

Spec 2 Spec 2



WASTE

CLASSIFICATION

HAZARDOUS NON-

HAZARDOUS

Examples: Coke Making: raw tar, (tar sludge collected by the contractor ), coke breeze (re-use) Sinter: ESP dust (re use), AG, BG, CG dust Blast Furnace: furnace dust, stock house dust, scrubber mud, granulating slag, Air cooled slag, coke breeze, tap floor dust Direct Reduction: furnace dust, dolochar, raw materials BOF: furnace dust, mud, grid, BOF RHI material, Desulphurization slag, LF slag, furnace slag Rolling Galv: zinc dross (EDT graphite sludge, EGL sludge and Ortosilicate sludge collected by the contractor) Foundry: silica sand, cyclone dust, Foundry slag Works: A-grade mill scale, oily mill scale, x-grade mill scale, oil, grease, building material, refractory material/bricks (Candy sludge and CETP sludge (oily sludge) collected by the contractor) AMCC: Pickle line (SPL), Lurgi oxide

Spent refractory material / bricks Spec 2 Spec 2

Medical waste Spec 3

Sanitary Waste Spec 3 Note: Any non-hazardous waste such as glass, plastic products, packaging material, cardboards, paper, wood PPE, soil, etc. which is contaminated with oil or chemicals must be reclassified as hazardous waste. If doubt exists on the classification of waste a memorandum / report stating the classification must be obtained from Environmental Management before disposed of. Spec 1: Special Conditions 1. The Approved contractor removes this waste. The contractor is responsible for the removal of the unsoiled paper and plastic bottles out of these wastes for recycling. Spec 2: Special Conditions 2. This waste streams have been tested and analyzed to determine the hazardous properties, characterized and components of waste and will be used to classify and confirm whether the waste is hazardous or not according to minimum requirements. The analysis and classification can be obtained from Environmental Management. Spec 3: Special Conditions 3. This waste must be removed and disposed by the approved contractor. Discarding sharp objects and medical waste.

8.1 SPENT REFRACTORIES

Spent refractory materials and/or bricks are classified into hazardous and non-hazardous based on analysis results available from Environmental Management.

SPENT REFRACTORIES

CLASSIFICATION

HAZARDOUS NON-

HAZARDOUS

Coke oven battery refractory bricks X

Sinter refractory bricks – awaiting samples



SPENT REFRACTORIES

CLASSIFICATION

HAZARDOUS NON-

HAZARDOUS

Blast Furnace bricks X

BF Stoves refractory brick X

Torpedo bricks from BOF X

Refractory bricks from BOF X

RH Mg-Cr bricks from BOF X

SEN refractory bricks from V1 and V2 X

DR Kilns bricks X

PTP hardening and normalizing bricks from Plate Mills X

Furnace 5 and 6 from Plate Mills X

Bricks from 2050mm HSM X

Bricks from Foundry X

Disposal of spent refractory material / bricks Spent refractory material and/or bricks are allowed to be disposed of in an applicable bin or skip as organised with Engineering Transport. Note:

• Spent refractory material / bricks to be disposed of in bin or skip not more than ¾ full.

• Do not mix refractory bricks with other type of waste such as paper, food rest, etc. in the bin.

9 RECYCLING OF WASTE

Recyclable Item Contract number Place / Responsible person / contractor

Contact telephone number

Electronic waste (computers, keyboards, etc.)

Gijima -AST x2-6116

Laser jet and ink cartridges

Wet batteries (vehicle batteries)

MHE Workshop x2-3119 / 6832 Short cell

“Clean” Kay wool (man-made fibers)

4603000797

Insulation Refractory Consultants (IRC) (Gathering point for kaywool bags is Coke Making Plant Battery 9)

Coke Making Refractory Maintenance Supt x2-9310

Paper 4603000736 Enviroserv Cell 5174

Plastic 4603000736 Enviroserv Cell 5174

Tires 4603001197 Tire workshop: Technician

x2-3313 or Cell 5027

B302 redundant / obsolete items

Reclamation at Vanderbijlpark Works

x2-9014

Scrap Scrap Supply at Steel Making

x2-8997/8

Empty drums Reclamation x2-9014



Used oil Fixtrade contract at AMCC

083 6322952

Conveyor belts Reclamation

X2-9014

9.1 STEEL WASTE:

All steel scrap with more than 30% steel in it must be collected in the red waste bin and will be recycled at Steel Making. The recycling containers used to recycle scrap metal contaminated with oil or grease, must be stored in an area suitable for the storage of hazardous waste materials, to prevent oil leaching out of the containers, causing soil and water pollution. Note: Electrical motors not to be disposed of it the red steel bins due to the high copper (Cu) content in the motors. This will cause quality deviations of the steel.

9.2 OILS:

Oil reclaimed for recycling should also be handled according to this procedure for disposal of hazardous waste, but instead of a waste contractor, the contractor for recycling oil must be used. Contact: Fixtrade at 083 632 2952 Note: Before the disposal of any oily waste product it is advisable that a sample of the sludge is given to Fixtrade to see if they will be able to recycle it. Only if it is not suitable for their use should it be disposed of to a hazardous waste disposal site. Contact Superintendent Waste Management at x2-4156 or cell 5029 for the disposal details.

9.3 RECYCLABLE ITEMS FOR RECLAMATION (to be disposed of in orange bin):

All recyclable waste for Reclamation: bulk bags, ropes, wood such as pallets and cable reels, conveyor belt pieces will be collected in the orange waste bin (on an ad hoc basis) and will be transported to Reclamation. The following redundant items need a B302 form which must be submitted to Reclamation: conveyor belts, microwaves, television sets, damaged furniture, electrical components such as motors, panels, and cables, etc. copper and brass shavings. These items are not to be loaded into a bin. Note: If a plant has sufficient recyclable items for an orange bin, contact the Superintendent Waste Management at x2-4156 or cell 5029 to provide an orange bin.



9.4 GENERAL WASTE TO BE RECYCLED:

The following waste type can be recycled:

Recyclable Not recyclable

Paper

Computer and/or printer paper All paper that can be written on Copier paper

Paper soiled with oily substances; any paper with a plastic lining, including the covers of the office paper is unacceptable.

Brown paper Packaging paper

Corrosion (rust) protective paper and reinforced paper and any paper with plastic linings are unacceptable.

Empty paper bags without plastic linings Empty cement paper bags

Laminated paper and/or posters. The paper bags not completely empty.

Carton

Colored carton Carton boxes, but it has to be flattened. Packaging cartons

Carton soiled with oily/hazardous substances; laminated cardboard or carton with a plastic lining is unacceptable.

Plastic

Bottles and containers, plastic bags, packaging plastic

Plastic contaminated with hazardous chemicals. Plastic bottles contain unknown liquid(s),

Wood

All pallets and cable reels broken or whole All loose pieces of wood

Wood soiled with oily/hazardous substances.

Scrap metal for Steel Making

Mechanical scrap, wire rope slings Steel straps Redundant equipment

Scrap metal containing waste with less than 30% iron or steel in it. Scrap metal contaminated with asbestos. Aerosol containers (due to explosion hazards).

Redundant or obsolete goods

Redundant or obsolete goods must be sent to Reclamation via B302 form:

• Conveyor belts

• Damaged furniture

• Electrical components such as cables, panels and electrical motors.

• Microwave ovens

• Television sets

• Copper and brass shavings and pieces

• Empty reinforced tanks (1000L) (also known as a “Tote”)

The following material / items/ goods cannot be sold by Reclamation and there for not be reclaimed: Steel scrap that can be used in the Steel Making process. Any material / item / substances that might endanger or pollute the environment if not dispose of in a properly approved way or system such as asbestos heaters, radioactive sources such as smoke detectors, fluorescent tubes, etc. unless a contact exits with an approved reputable firm or if it is sold back to the original supplier.


Electronic waste (such as computers, key boards, etc.)

“Clean” Kay wool (not contaminated) Kay wool soiled with hazardous chemical substances such as tar, lubricants, etc.



10 SEPARATION OF WASTE IN COLOUR CODED BINS, ALLOCATED BOXES AND AREAS

WASTE

WASTE SEPARATION AND COLOUR OF BINS

Domestic waste

Recyclable waste for

Reclamation Dust

Steel scrap

Coke samples

Sludge Hazardous

waste

Yellow bin

Orange bin Blue bin

Red bin

Grey bin

Black bin

Green bin

Plastic, paper, glass, packaging material, cardboard, ropes, rubber, PPE, cloth, polystyrene, food rest, carbon brushes, dust filters, steel scrap containing less than 30% steel, fiber glass.

X

Wood such as pallets and cable reels, bulk bags, ropes, conveyor belts, empty reinforced overflow tanks.

X

Off gas system dust and plant clean-up dust.

X

Any scrap which contains more than 30% steel. Empty steel containers and drums, steel wire ropes, steel structures and redundant equipment.

X

Coke samples. X

Steel Making sludge. X

Hazardous chemicals, aerosols, dry batteries, lubricants, Kay wool if not recyclable. Note: all general waste, Kay wool and spent refractory material / bricks which are contaminated or soiled with hazardous chemicals and lubricants.

X

Dry cell batteries X



WASTE

WASTE SEPARATION

Allocated boxes, white wheelie bins and yellow ash trays / containers in offices

Allocated areas

Paper and cardboard Collected by Enviroserv Cell 5174

Mixed recyclables Collected by Enviroserv Cell 5174


Reclamation

Restaurant waste

Restaurant and Canteens: 6 cube yellow skips located at all the canteens. If full contact the RTCR at 2-2569 to empty the skip bins at the internal domestic site.

Kitchen waste Collected by external party (pig farmer)

Food / Kitchen waste is collected by a pig farmer for feeding purposes.

Tires

Tires FROM AM vehicles will be stored by the contractor and removed from site 2-2481.

“Clean” Kay wool

Coke Making Battery no 9: Bags containing Kay wool to be collected by Insulation Refractory Consultants (IRC) for recycling as per contract. Contract person at Coke Making: Refractory Maintenance Supt x2-9310.

Building rubble (not spent refractory material / bricks)

Ad hoc at different plants and organize with Engineering Transport. Rubble to be collected by dumper trucks / tipper to be disposed of in internal disposal site 2-2991

Granulating slag

Blast furnace granulating area: Collected by contractor (under supervision of for AMCC)

Laboratory chemicals

Chemicals to be transported to the Desalination plant (for re-use).

Batteries (wet) such as vehicle batteries

MHE workshop 2-3119

Plant redundant equipment (such as motors, panels, damaged furniture, conveyor belts, microwave ovens, television sets).

To be transported to Reclamation by plant. B302 to be submitted.

Used oil Collected by Fixtrade - AMCC (to be recycled).

Used oil drums Collected by Reclamation

Oil containing PCB’s (transformer oil)

Refer to document ENVIRON000029

Waste contaminated with PCB’s such as soil and ballast stones, etc.

Transported by the contractor to a hazardous waste site [Need a PCB certificate before quotation can be submitted by the contractor – every plant should have a certificate to show the amount of the PCB’s in the transformer]

Asbestos

Bins to be transported to a hazardous waste site please contact



WASTE

WASTE SEPARATION

Allocated boxes, white wheelie bins and yellow ash trays / containers in offices

Allocated areas

Occupational Hygiene department Manager on 2-3043

Fluorescent tubes and discharge lamps See ENVIRON000004

Boxes to be ordered on SAP and collected at the contractor. Material number to be used: 60300006468.

Medical waste

Medical station.

Radioactive sources

Sources to be transported to Pelindaba (NECSA).

Sanitary Waste Collected by the approved cleaning contractor for incineration

11 PROCEDURE FOR WASTE SEPARATION

NOTE: Nobody is allowed to store any waste even if only temporary, on a piece of land not specifically authorized and approved.

11.1 GUIDELINES FOR WASTE CONTAINERS

• Engineering Transport will supply bins for recycling and waste disposal (according to drawing V21-5-70) and to be ordered from “Plating and Welding”.

• Containers and/or the container position must be colour coded and/or marked to point out what kind of waste should be put inside. Display waste separation pictograms near bins.

• Bin positions must be accessible to the vehicles collecting the bins without unduly damaging equipment or building surrounds

• COLOUR MARKINGS / CODING FOR BINS AND/OR CONTAINERS:

Type of waste Type of container Color coding

Off gas dust and clean-up dust 6m3 bin Blue

Metal scrap 6m3 bin Red

Hazardous waste 6m3 bin Green

Domestic waste (general waste) 6m3 bin Yellow

Coke samples 6m3 bin Light grey

Steel Making Sludge 6m3 bin Black

Recyclable waste for Reclamation 6m3 bin Orange

Paper Carton boxes and/or wheelie bins

White

Mixed recyclables Wheelie bins Yellow

• The correct person must be contacted (tel. x2-2569) if or when bins are full and are not emptied. Place a task at RTCR.

• The plant must ensure that the waste is managed according to this document before removing the bins from the plant. Any deviations will be reported to the plant by Engineering Transport.

• Bins that are overloaded and/or not safe for transportation will be left at the plant to be corrected by responsible person. Bins with mixed waste will also be left at the plant for the mixed waste to be separated into the correct type of bins.



• Mesh cages for wood, packaging material, etc. can be built, it is cheaper than bins. Ash bins or domestic waste bins (plastic or steel) may be used.

• Hazardous waste can only be disposed of with a bin supplied by an approved contractor.

• Boxes and white wheelie bins may be used for paper. Yellow wheelie bins must only be used for cold drink cans, plastic bottles and other recycled waste.

• Use bags for the transportation of kaywool to Coke Making for collection by approved contractor.

• DWS or DEA requirements for hazardous waste: o Storage period must be less than 90 days o The storage area is fenced off. o Display notice board at entrance area with the words “Hazardous Waste, Unauthorised entry

prohibited”.

11.2 SEPARATION OF DOMESTIC WASTE

All domestic waste which is not contaminated with hazardous substances must be separated and recycled where possible (see section 9: Recycling). All articles that cannot be recycled must be stored in a suitable bin (yellow) for the disposal to the Vanderbijlpark Works disposal site by Engineering Transport. Wheelie bins are supplied for recycled waste and paper. Contact number of the contractor is Cell 5174.

11.2.1 BUILDING RUBBLE

Note: No building rubble is allowed to be disposed in any waste bin and should be disposed of with a tipper or dump truck. a) The contractor that is doing the construction, erecting or maintenance must transport waste arising from the construction, erecting or maintenance of a building to the Vanderbijlpark Works domestic waste disposal facility. b) Engineering Transport will be responsible to dispose any building rubble should it not form part of the contractors’ contract. Contact Engineering Transport at x2-2569. A notification should be placed on S24 main work centre (MWC) ESAE.

11.3 SEPARATION AND DISPOSAL OF HAZARDOUS WASTE:

Note:

• No temporary storage of hazardous waste allowed outside approved and authorized areas.

• When oil and/or grease is transported to a hazardous disposal site in 210 litre drums, these drums must be in a good condition (not leaking) and properly sealed and labelled. Labels to be supplied by the contractor responsible for disposal at a hazardous waste site.

• Refer to the relevant disposal procedures for asbestos (or any other item which contain properties of fibrous asbestos such as heaters, fascia boards, ceiling boards, etc.), fluorescent tubes or discharge lamps, medical waste and radioactive sources.

11.3.1 PROCEDURE FOR THE TRANSPORT AND DISPOSAL OF HAZARDOUS WASTE BY ENVIROSERV (see Annexure 3: flow diagram)

TASKS RESPONSIBLE PERSON(S)

10.1 The plant will request a new task from RTCR by calling them on 2-2569 Plant (Planner)

10.2 Enter the new tasks on system 500-08. (By using the computer in the RTCR). This is to keep record of the tasks done and cost reclamation purposes and to obtain a task number from the system.

RTCR

10.3 A purchase requisition is generated with the suitable material number to remove the waste. The order is released and an order is placed on the contractor to remove the bin.

RTCR

10.4 The contractor must report to the Superintendent or Planner in that area before lifting the bin.

Contractor



10.5

The Contractor will supply a Waste Manifest to the plant before starting the task. The plant must ensure that all the relevant detail is correct before signing the manifest. (Delivery point, description of the area, waste stream collected.) If the details are not correct or the bin is overloaded do not sign the manifest before it is corrected).

Contractor

10.6 Once the task is completed the driver must report to the RTCR. To inform the RTCR personnel about the status/change of a task and to obtain a gate release from the RTCR.

Contractor

10.7 An inspection will be done by the RTCR before supplying a gate release to the contractor to ensure all the documents are correct and the load is safe to be transported.

RTCR

10.8 The driver transports the load to the hazardous waste site where it is offloaded. A safe disposal certificate and a weighbridge slip is completed

Contractor

10.9

To finalise the payment for the tasks completed during the month. The contractor supplies Vanderbijlpark Works (Superintendent Waste Management) with the invoices of the completed tasks, weigh bridge slips and safe disposal certificates.

Contractor

10.10

The Superintendent Waste Management processes all the invoices to ensure that the weighbridge slip, safe disposal certificate, task number and amount are correct on the invoice.

Superintendent Waste Management

10.11 Superintendent Waste Management completes the M115C process electronically and signs the document.

Superintendent

10.12

The Superintendent supplies the contractor with the signed M115C document, for the contractor to take it to the finance department (Completed M115C can be obtained from the Superintendent Waste Management’s office)

Contractor

10.13 The Superintendent Waste Management will file the safe disposal manifest for future Audits from internal and external auditors


10.14

Only EnviroServ is authorised by Vanderbijlpark Works for the transportation and disposal of hazardous waste to Holfontein. Take note: Different contractors are authorised for the collection of asbestos, medical waste, radio active sources, oil contained PCB’s, etc. and to transport waste to other disposal sites such as Olifantsfontein, Pelindaba, Holfontein, etc.


10.15 Plant must obtain disposal certificate numbers from Engineering Transport to be linked to order numbers.

Plant

11.3.2 DISPOSAL CERTIFICATES FOR HAZARDOUS WASTE

Vanderbijlpark Works have to retain the disposal certificates for 5 years because the Works might need proof of how we disposed of hazardous waste. All disposal certificates are kept at the RTCR control room Engineering Transport building 2-2569.

Type of Original at Responsibilities of plant

Medical waste. Medical Station Fitness counter

Manifest or proof of disposal must be Kept.



PCB oil transported by Thermal Destruction for incineration at Olifantsfontein.

Electrical Distribution Manifest or proof of disposal must be Kept.

Asbestos removed by SGB Cape and ISC Matla and disposed of at Holfontein

Medical Station: Occupational Hygiene. x2-2830


Radioactive sources transported by NECSA and disposed of at Pelindaba.

Administrative Assistance SHERQ Systems Vanderbijlpark Works


Other hazardous waste transported by EnviroServ and disposed of at Holfontein.

Engineering Transport Manifest or proof of disposal must be Kept.

Medicine and pills (part of medical waste)

Medical Station Fitness counter


12 PROCEDURE FOR THE TRANSPORTATION OF MTP AND DESALINATION PLANT SALTS.

This procedure is divided into the normal operating procedure and the Emergency procedure. BACKGROUND The salts from the MTP and CETP plant will be transported by making use of a Bell tractor and trailer combination. The trailers will be placed directly beneath the chutes at the MTP and CETP plants. When a trailer is nearing its full capacity the operator at the plant will contact the Road Transport Control Room (RTCR) at 2-2569 to place a task for that trailer to be emptied. The person in the RTCR will record the task on the RTCR system and contact the approved contractor’s coordinator and inform him about the task to be done. NORMAL OPERATING PROCEDURE The following operating procedure applies:

• The approved contractor’s coordinator receives a task from the RTCR for the trailer at either the MTP or CETP plant that must be emptied at the designated storage facility.

• The coordinator arrange for a Bell tractor to be send to empty the full trailer at the plant.

• When the driver arrives at the plant he must inspect the trailer for any signs of leaks, damage and must ensure that the trailer is not overloaded.

• If any faults is found on the equipment he must inform his coordinator who will inform the RTCR and wait for further instructions.

• If no faults is found on the equipment the driver then couple the trailer to the tractor and removes it from under the chute and park the tractor and trailer in a designated area for further inspection.

• The driver must inspect the wheels for any sings of salts, if traces of salts is found on the wheels he must the use the facilities supplied to remove the salts from the wheels.

• If it is a raining day the trailer must be covered with a tarpaulin to prevent spillages.

• The driver takes the trailer to the storage facility where he empties the trailer in the facility.

• When the trailer is emptied the driver the parks the tractor and trailer in a designated area for an inspection.

• The driver must inspect the wheels for any sings of salts, if traces of salts is found on the wheels he must the use the facilities supplied to remove the salts from the wheels.

• The driver can now proceed to place the empty trailer back under the chute at the plant.

• The contractor appointed will to conform to all the applicable road traffic and road transport legislation.



RISK PREVENTION MEASURES INHALATION SHOULD NOT OCCUR.

• Eye contact: RINSE OPENED EYE FOR SEVERAL MINUTES UNDER RUNNING WATER.ASSURE DEQUATE FLUSHING BY SEPARATING THE EYELIDS WITH FINGERS.SEEK EMERGENCY MEDICAL CARE IF IRRITATION PERSISTS.

• If digested: DO NOT INDUCE VOMITING. IF CONSCOIUS, HAVE PERSON DRINK CUPIOUS AMOUNTS OF WATER. SEEK MEDICAL ATTENTION IMMEDIATELY.

EMERGENCY OPERATING PROCEDURE The following emergency operating procedure applies in the event of a spillage:

• When the driver notices a spillage or spillage occurred as a result of an accident he must immediately stop the equipment and inform his coordinator who in return must inform the RTCR immediately..

• The RTCR must contact the Manager Road Transport or Superintendent Road Transport to inform him about the incident. Environmental Management must also be informed.

• The contractor must then arrange for rapid clean-up of the salts and removal to the salt store.

13 WASTE AUDITS / ASSESSMENTS

Vanderbijlpark Works need to ensure that all people performing tasks for, or on behalf of the organisation, including contractors, subcontractors and own workers, have had an appropriate assessment for their potential to cause significant environmental impact and the associated competence required. `

Type of audits/ Assessments Responsible person(s)

11.1

Audits/assessments will be conducted according to Internal Audit Assessments and External Audit Schedule to ensure compliance to procedures.

Coordinated by SHEQ Systems

11.2 Duty to care external and internal audits at landfill sites such as Holfontein, Pelindaba, etc.

Engineering Transport and SHERQ Functionaries

11.3 Duty to care contractor audits such as Enviroserv, Fixtrade etc. Engineering Transport, SHERQ Functionaries and Reclamation

11.4 Monthly waste separation audits (waste bins audits). SHE and Environmental reps at the plants

11.5 Plant walkabouts and housekeeping inspections. Plant Managers

11.6 Waste streams, waste classification and separation, waste storage, waste minimisation, waste signage and communication / awareness.

SHE Specialists and Environmental Representatives

14 COMPLIANCE CERTIFICATES

Vanderbijlpark Works must ensure that all contractors performing waste removal tasks for, or on behalf of the organisation, including contractors, subcontractors and own workers, have had compliance certificates

15 TRANSPORTATION OF RAW MATERIALS, BY PRODUCTS, PRODUCTS AND WASTE

Do not overload trucks and train trucks with raw materials and products such as coke, granulating slag, scrap, etc. Overloading of vehicles does not only pose a safety risk, but also results in the spillage of materials. Waste removal contractors have signed an agreement not to remove overloaded skips and bins and this will cause a time delay on removal of full bins and/or skips. Spilled material causes damage to roads, adds to the waste burden and causes wastage of resources. Report illegal dumping e.g. raw materials, plant equipment, building rubble, tires.


16-0063 06 September 2016

ANNEXURE H INCIDENT REGISTER


16-0063 06 September 2016

ANNEXURE I INTERNAL AUDITS


16-0063 06 September 2016

ANNEXURE J LINIER INSPECTION REPORT


16-0063 06 September 2016

ANNEXURE K PROCEDURE FOR WATER SAMPLING


Centre Vanderbijlpark Works Document Type KPR Effective Date 09 June 2014

Document ENVIRON000005 Version 05 Revision Date 26 May 2016

Status In Work Approved By JOHAN HATTINGH

Title PROCEDURE FOR WATER SAMPLING

1 Purpose

2 Definition and terms

3 Method of control

4 SHE & Ergonomics

5 Compliance of water quality sampling

6 The objective of sampling

Sampling variables

Equipment preparation

Guidelines on sample bottles to be used and preservation of samples

Marking of bottles

7. Water Sampling Technique

8. Sample Preservation

9. References

This document replaces ENVIRON000005/04

Reason for revision New approval manager

Destination group Environmental Management

ENVIRON000005 Vers ion 05


PURPOSE

• To monitor surface and ground water.

• To check efficiency of treatment processes.

• To spot possible contamination of water in the process

• To check the quality of water at the point of use.

• Comply to environmental legislation and water use license

DEFINITION AND TERMS

Water quality?

“The term water quality is generally used to describe the microbiological, physical and chemical

properties of the water that determine the fitness for use of the specific water source”

Microbiological quality:

Refers to the presence of pathogenic organisms like protozoa, bacteria and viruses in the water. Faecal and

total coliform bacteria are commonly used as indicator organisms to determine microbiological status and

safety of the supply.

Physical quality:

Refers to the water properties like colour, odour, dissolved and suspended solids, conductivity, pH and

turbidity.

Chemical quality:

Refers to the chemical elements and compounds in the water, such as calcium, carbon dioxide, nitrates, etc.

Trip Blank:

A trip blank is a set of sample vessels filled with blank water (water, which is free of contaminants that may

interfere with the analyses to be conducted) at the beginning of a sampling day and carried around in the field

under exactly the same conditions as the samples. It serves as a check on sample contamination originating

from sample transport, shipping and from the site conditions.

Field Blank:

A field blank is a sample of blank water (water, which is free of contaminants that may interfere with the

analyses to be conducted), which is transferred from one sample bottle to another sample bottle at the sample

point. It serves as a check on reagent and environmental contamination.

When sampling for VOC’s, the organic sample must be sampled before the inorganic sample.



METHOD OF CONTROL

Analyses and evaluation of results by qualified personnel.

Ground water monitoring frequency is prescribed in ArcelorMittal South Africa Vanderbijlpark Work’s

Water Use License and Waste Management Licence and ROD

Sampling positions and supportive procedures can be found in document Environmental Monitoring Plan

SHE & Ergonomics

• Boreholes are situated in specific locations within and surrounding the works. Beware of risks in the

area when moving through plant areas.

• Beware of snakes in and around boreholes in the field area. Long boots must be worn when ground

water sampling takes place.

• Beware of moving trains in the plant and field area.

• Before opening a borehole, make sure that there are no bees in the borehole.

• Surgical gloves must be worn during sampling to prevent contamination and skin contact (irritation).

• Move along roads from borehole to borehole where possible.

• Make sure that the first aid kit is in the vehicle, during the ground water sampling period.

• Ensure that you take enough liquid in, to prevent dehydration.

• Rather bend your knees while sampling than hanging over the casing with a bended back.

• Always wear the correct PPE.



COMPLIANCE OF WATER QUALITY SAMPLING

Why do we take water samples?

• To check the level of treatment required; ensuring that the water is suitable for the intended use.

• The efficiency of water treatment.

• To locate and investigate contamination of the water in the system.

• To monitor water quality at the point of use.

• To monitor the water quality at the point of discharge.

• Compliance to relevant authorizations

Formal Compliance

• ArcelorMittal South Africa Vanderbijlpark Work’s Water Use License and Waste Management Licence

and ROD

• DWAF – Minimum Requirements for Monitoring at Waste Management Facilities are further applicable

regulatory requirements.



THE OBJECTIVE OF SAMPLING

Before any sample is taken, define the objective of taking the sample:

• The variables or parameters to be analyzed.

• The method of analysis

• Preparation steps that must be taken before sampling.

• Preservation method to be used after sampling

Sampling variables:

• The sampling point conditions.

• Sample frequency.

• The type of analyses to be done on the sample.

• How much volume is required for the analyses.

• The method of analyses to be used.

• How long the sample is going to be stored.

• EC profile.

Equipment preparation

The sampling equipment to sample at the ground water sampling localities is the same except for the external

users where the boreholes are equipped with pumps. At these monitoring localities the borehole is pumped for

15 minutes before a sample is taken at the pump outlet. Boreholes equipped with windmills and hand pumps

must similarly be sampled after 5 minutes of being pumped.

Sampling equipment for surface water sampling should be cleaned before use.

Inorganic sampling:

Equipment that is needed for a routine monitoring sampling run at the ground water monitoring localities

namely the External Users, Perched Aquifer and the Shallow Weathered Zone Aquifer, are as follows:

• Monitoring field form/clipboard and pen/pencil.

• Marking pen.

• Masking tape and isolation tape.

• Laboratory pre-washed plastic sample bottles – 750 ml.

• Laboratory prepared preservation sample bottles – 250 ml (optional, see sample preservation).

• Disposable bailer, single or double valve.

• Water level meter.

• Cooler boxes – 25 liter.



• Plastic container with 10 liter de-mineralised water.

• Paper towel roll.

• Small bottle of dish washing liquid.

• Roll of cheesecloth.

• Plastic dustbin bag.

Organic sampling:


• Marking pen.


• Adequate disposable hand gloves.

• Adequate glass bottles for organic sampling :

o Semi-VOC samples – 500 ml glass bottles with glass or Teflon stoppers.

o PHENOL samples – 40 ml glass bottles with Teflon lined screw caps.

o VOC samples – 40 ml glass bottles with Teflon lined screw caps.

• MAO3 soap to wash sampler.

• Disposable Teflon bailer or stainless steel sampler.

• Water level meter.

• Adequate cooler boxes – 25 liter.

• Plastic container with 20-liter water.

• Plastic container with 20 liter de-mineralised water.





The following equipment is needed for rivers, streams and storm water monitoring sampling run:




• Marking pen.


• Laboratory pre-washed plastic bulk sample bottles 1 000 ml.

• Sampler scoop bucket with hand line.

• Cooler boxes 25 liter.

• Plastic container with 10 liter demineralised water.







Guidelines on sample bottles to be used and preservation of samples

Substance Type of sample bottle Remarks

Biological Glass or plastic bags Bottles must be

sterilized

Physical Plastic or glass Should preferably be

measured onsite

Organic chemical Glass (sealed with foil on the

cap)

A new bailer for each

sampling point

Inorganic chemical Plastic Bottles must be clean

Make certain that sample bottles are clean, and for biological sampling that they are sterilized. Sterilized

bottles should be kept closed up to the point when they are filled with the sample and therefore not have any

empty space between the sample and the lid, unless a bacteriological sample is taken.

Always consult with the laboratory personnel if uncertain about equipment to use.

Marking of bottles

It is imperative for each sample to have a clear identification, date and time when the sample was taken.

A sampling note accompanying the samples is required with the full details of the analysis to be performed,

names of the samples, time samples were taken and time they were submitted to the lab.

• All bottles must be marked with a waterproof marking pen.

• Identify the sample e.g. labeling HS-I5, label must be as descriptive as possible

• Full standard format (Date sample taken, date sample handed in to the lab and what type of analysis must

be done, inorganic, bacteriological, organic, etc.)

WATER SAMPLING TECHNIQUE

Surface water:

Immense the sampling bottle in the water facing the direction at the stream flow, river, channel etc. (One can

use a clean bailer if the river is under a bridge or in a position where sampling is out of reach).

Make sure that sampling apparatus are clean (always use a clean bailer). If not rinse with drinking water and

then with the water about to be sampled.

NB: Always take a representative sample. If the water is deep enough take samples at different depths and

across the stream.



• Rinse the inside of the bottle and lid three times with the water you are about to sample.

• Ensure that the cap remains clean while taking a sample.

• Label the sample clearly and unambiguously.

• Record the physical conditions at each sampling point.

• For chemical samples do not leave any space under the cap, tighten the cap to make sure that water does

not leak out.

• For bacteriological samples, leave ±2cm space under the cap. Do not touch the inside of the bottle and the

cap. Tighten the cap making sure that water does not leak.

Ground water sampling:

• Measure the water level.

• Measure the borehole depth.

• Calculate the height of the borehole.

• Calculate the volume of the borehole.

• If there is a pump in the borehole pump three times the volume of the borehole (if the volume is

sustainable).

• If there is no pump, use your own pump, to pump three times the borehole volume(if the volume is

sustainable).

• Lower the bailer to at least 0.5m below the water surface and collect the sample.

• Use a clean bailer with a clean rope on each borehole.

NB: If more than one sample needs to be taken, always take the microbiological first to prevent contamination

of the source.

Inorganic sampling:

For equipped boreholes to be sampled, the same procedure is to be followed as described below, except to

ensure that the borehole is discharging for at least 15 minutes before filling the sample bottle at pump outlet.

Note the time after the start of the pump when a sample is taken. Standardize as far as possible on 15

minutes.

External Users, Perched Aquifer, Shallow Weathered Zone Aquifer (open boreholes)

• Measure the static water level in the borehole prior to sampling and note it on the monitoring field form.

• Remember to clean the water level instrument between boreholes by rinsing it with distilled water.

• Note the borehole number, date of sampling and time of sampling on the sample bottle.



• Note the sample number/borehole number, depth of sampling, date of sampling, as well as any comments

on the monitoring field form.

• Take the water sample with a disposable bailer/sampler at prescribed horizon.

• Pour the sample taken, directly into the pre-marked sample bottles.

• The bottles are to be filled to the brim, squeezed slightly while lid is screwed on tightly in order to expel

all the air from the bottles.

• Replace the full sample bottles in the cooler box. If preservation is indicated, store the samples

separately.

• Dispose the bailer in the black plastic dustbin bag.

• If a stainless steel bailer is use for sampling, the sampler must be washed.

• Make notes of the method used for decontamination of the bailer at each borehole.

• Wash and dry hands if necessary.

• Dispose any other waste e.g. paper towels in the black dustbin bag.

• Move to the next sampling locality.

• The sampling procedure is to be standardized and adhered to as far as possible.

• Always try to follow the same sampling route.

• Hand the samples in at the designated Laboratory, if possible at the end of each consecutive day of

sampling before closing time.

• The list of variables to be analyzed for as indicated in Water Use License.

• A copy of the monitoring field form is to be attached to the letter of instructions to the designated

laboratory.

• All macro/micro analysis results should be accompanied by anion/cation balancing.

• The original field form is to be filed and stored locally.

• Make arrangements for the next batch of sample bottles well in advance of the next monitoring run.

Organic sampling:

Perched Aquifer and Shallow Weathered Zone Aquifer

Trip and field blank samples to check for cross-contamination should be included during the sampling of the

organic samples in accordance with the designated laboratory’s specifications.

The following sampling procedure should be followed in the field:

• Measure the static water level in the borehole prior to sampling, and note it on the monitoring field form.



• Note the borehole number, date of sampling and time of sampling on the sample bottle.

• Note the sample number/borehole number, depth of sampling, date of sampling, time of sampling, dam

level status were applicable, as well as any comments on the monitoring field form.

• The person responsible for organic sampling should be using disposable hand gloves when sampling.

• Take the water sample with a disposable Teflon bailer/stainless steel sampler at the prescribed horizon.

• Pour the sample taken, slowly with minimal turbulence into the pre-marked sample bottles.

• The bottles are to be filled to the brim. Ensure that no air is captured in the sample bottle.

• Place the full sample bottles in the cooler box. If the laboratory indicates preservation ensure that the

correct procedure for the preservation is followed.

• Dispose the bailer and hand gloves in the black plastic dustbin bag.

• If a stainless steel bailer is used for sampling, the sampler must be washed in the 2% MAO3 soap and water

solution.

• This step is followed by a thorough rinse of the sampler in clean water and finally distilled water.

• Wash and dry hands if necessary.

• Dispose any other waste e.g. paper towels in the black plastic dustbin bag.

• Move to the next sampling locality.

• The sampling procedure is to be standardized and kept to as far as possible.

• Always try to follow the same sampling route.

• If possible, hand the samples in at the designated laboratory, at the end of each consecutive day of

sampling before closing time.

• An accompanying letter with instructions to the designated laboratory is to be drafted and forwarded. The

instructions should include the following :

o A copy of the monitoring field form is to be attached to the letter of instructions to the designated

laboratory.

o The original field form is to be filed and stored locally.

o Make arrangements for the next batch of sample bottles well in advance of the next monitoring run.

SAMPLE PRESERVATION

After sampling, the chemical properties of the water can change to different extents due to physical, chemical

and biological reactions, and for this reason the sample must be preserved. It must be noted, however, that

preservation does not stop the reaction totally but rather retard them. Therefore analyses have to be

performed as soon as possible to get representative results of the sampled water at the time.



• To minimize the change in water quality, it is important to analyze the sample as practically soon

possible.

• No preservation is necessary if the analysis is performed within six hours of sampling period (take the

samples to the lab immediately).

• Samples must be stored in a cooler box.

• If the samples are going to stand for more than six hours, keep them in a refrigerator between 2-5 0C or in

a cool box equipped with ice. Avoid using dry ice as it may freeze the samples.

• Find out from the lab the necessary preservation chemicals that may be used and ensure full understanding

of how to use them.

NB: Make arrangements in advance with the lab for the sample to be analyzed immediately. Sample

preservation (organic & inorganic) should, however, always be done in accordance with the relevant analytical

laboratory’s specifications.

REFERENCES:

Quality of domestic water supplies

Volume 2: Sampling guide DWAF

South African Standard

Drinking water ABS241-1999

South African Standard

Water quality sampling

Part 3: Guidance on the preservation and handling

of samples SABS ISO5667-3 1994

South African Standards

Water quality – sampling

Part 3: Guidance on sampling techniques SABS ISO 5667-2 1991


16-0063 06 September 2016

ANNEXURE L MONITORING COMMITTEE REPORT

Waste Disposal Site Monitoring Committee Meeting

02 September 2015

Held On 2015-09-02 at 10:00 at ArcelorMittal South Africa Vanderbijlpark Works

1. Attendance:

Name ABBR Org Tel e-mail

Lance Hill LH Hill & Associates 083 556 9113 [email protected]

Johan Hattingh JH ArcelorMittal 083 463 1742 [email protected]

Terrence Wilson TW ArcelorMittal 072 500 0901 [email protected]

Phila Mkemezulu PM ArcelorMittal 083 298 7095 [email protected]

Dakalo Rambuda DR DWA 012 392 1452 [email protected]

Mabokela Seiphi MS DWA 081 421 5452 [email protected]

Sylvestor Dube SD SDM 082 901 6847 [email protected]

Phillimon Khwinana PK DWA 082 884 1898 [email protected]

Velaphi Mokgabudi VM ELM 078 547 2129 [email protected]

Legend : Present Apology Scribe Chairperson

2. Minutes of Meeting

Description Resp. Date

General Matters

The Chairperson welcomed everyone. Everybody present was satisfied with the adoption of previous minutes and the agenda. LH explained the background and Terms of Reference to Mabokela Seiphi and all in attendance. LH had previously noted that AMSA is in a process of drafting a request to reduce frequency of meeting due to recurring poor attendance. However a report will be prepared and submitted on a quarterly basis. AMSA received feedback from GDARD, AMSA to provide the minutes of previous Multi-Stakeholder Monitoring Committee meeting held from 2011 and copies of Environmental Authorisations of the facility. AMSA received a letter from DEA acknowledging receipt of proposal on the 29

th of June 2015. Awaiting DEA

PM to follow-up on what is outstanding from DEA and send information to SS to initiate action or obtain a response – Done, awaiting DEA Monitoring Report The Monitoring report was presented by PM, ArcelorMittal Environmental Technologist. Licenses LH mentioned that the Licence Review is needed for March 2016 - Noted Groundwater Monitoring PM was requested to Check why P-7D conductivity is high? This was investigated and found to be a blocked toe-drain. The toe-drain has been unblocked and monitoring the borehole will commence.

AMSA PM AMSA

2015 2015 2015

mailto:[email protected]



02 September 2015


DR to follow-up on groundwater and surface water monitoring points and plans. Leachate Dam VM had a query about Leachate Dam conductivity. AMSA monitoring the lined contained dam, if it is full it will be pumped. Dust Buckets The committee raised a question regarding the high dust fall out measured at dust bucket DB 9, PM responded by mentioning that the bucket is still located within the centre of the boundary next to the main access road used by road transport for both internal and external material handling and adjacent to the current by-products area which contributes to the elevated levels recorded. The storage of by-products will be assigned to a new area by end of 2015.

DWS AMSA AMSA

2015 2015 Dec 2015

Site visit

A Site Visit was conducted on the 02nd

of September 2015

Next meeting

Date: 02 December 2015 Time: 10h00 – 12H00 Venue: ArcelorMittal Vanderbijlpark Works


03 June 2015


1. Attendance:


Lance Hill LH Hill & Associates 083 556 9113 [email protected] P

Johan Hattingh JH ArcelorMittal 083 463 1742 [email protected] ( Phila Mkemezulu PM ArcelorMittal 083 298 7095 [email protected] P# Katlego Mabatle KM DEA 012 399 9835 [email protected] P Dakalo Rambuda DR DWS 012 392 1452 [email protected] P Thya Pather TP DWS 082 809 5729 [email protected] P Sylvestor Dube SD SDM 082 901 6847 [email protected] P Shiba Sebone SS DEA 012 399 9783 [email protected] P Phillimon Khwinana PK DWS 082 884 1898 [email protected] P Velaphi Mokgabudi VM ELM 078 547 2129 [email protected] P

Legend : PPresent ( Apology # Scribe Chairperson

2. Minutes of Meeting Description Resp. Date General Matters The Chairperson welcomed everyone. Everybody present was satisfied with the adoption of previous minutes and the agenda. LH explained the Terms of Reference to Velaphi Mokgabudi. LH mentioned that AMSA is in a process of drafting a request to reduce frequency of meeting due to recurring poor attendance. However a report will be prepared and submitted on a quarterly basis. AMSA received feedback from GDARD, AMSA to provide the minutes of previous Multi-Stakeholder Monitoring Committee meeting held from 2011 and copies of Environmental Authorisations of the facility. AMSA received a letter from DEA acknowledging receipt of proposal on the 29th of June 2015. AMSA to follow up TR from DEA recommended that the latest available External Audit Report be discussed during the next meeting. One meeting per year after the External Audit Report is available for discussion was also suggested. PM discussed the External Audit Report recommendations LH suggested that we get an approval during and after capping on phase 3 from DEA and GDARD – Inspected by DWS. TP asked if a liner is installed at the new storm water drain? The storm water runoff is of good quality due to capping, no need for a liner. TP suggested that AMSA install a well to capture the storm water – An instrument for the continuous monitoring of conductivity has been installed should there be storm water run-off PM to Send the External Audit Report to all - Done PM to follow-up on what is outstanding from DEA and send information to SS to initiate

AMSA

2015


03 June 2015

Description Resp. Date action or obtain a response - Done Monitoring Report The Monitoring report was presented by PM, ArcelorMittal Environmental Technologist. Licenses LH mentioned that the Licence Review is needed for March 2016 - Noted Groundwater Monitoring PM to Check why P-7D conductivity is high – To be investigated DR to follow-up on groundwater and surface water monitoring points and plans. Leachate Dam PM to explain the leachate dam capacity e.g. 100% is at what salt crystals level – No suspended solids. All salts currently in soluble form. Dust Buckets The committee raised a question regarding the high dust fall out measured at dust bucket DB 9, PM responded by mentioning that the bucket is still located within the centre of the boundary next to the main access road used by road transport for both internal and external material handling and adjacent to the current by-products area which contributes to the elevated levels recorded. The storage of by-products will be assigned to a new area by end of 2015.

AMSA AMSA DWS AMSA

July 2015 July 2015 Sept 2015 Dec 2015

Site visit A Site Visit will be conducted during the next meeting in September 2015 Next meeting Date: 02 September 2015 Time: 10h00 – 12H00 Venue: ArcelorMittal Vanderbijlpark Works


04 March 2015


1. Attendance:





Terrence Wilson TW ArcelorMittal 072 500 0901 Terrence.Wilson@ arcelormittal.com


Thya Pather TP DWA 082 809 5729 [email protected]


Phillimon Khwinana PK DWA 082 884 1898 [email protected]



Description Responsible Date

General Matters

The Chairperson welcomed everyone. Everybody present was satisfied with the adoption of previous minutes and the agenda. LH explained the Terms of Reference to Phillimon Khwinana LH mentioned that AMSA is in a process of drafting a request to reduce frequency of meeting due to recurring poor attendance. However a report will be prepared and submitted on a quarterly basis. Recieved feed back from GDARD, AMSA to provided the minutes of previous Multi-Stakeholder Monitoring Committee meeting held from 2011 and copies of Environmental Authorisations of the facility. TR from DEA recommended that the latest available External Audit Report be discussed during the next meeting. One meeting per year after the External Audit Report is available for discussion was also suggested. LH suggested that we get an approval during-after capping on phase 3 from DEA and GDARD Monitoring Report The Monitoring report was presented by PM, ArcelorMittal Environmental Technologist. Licenses None Groundwater Monitoring Map TP requested that AMSA to compare ground water results with WQO standard, more details will be communicated to ArcelorMittal in due course. He was informed that it

AMSA

March 2015 TBC




04 March 2015

Description Responsible Date

won’t be possible to compare ground water and WQO standard since Rietspruit water conductivity is 700mS/m (significantly above the maximum result obtained from monitoring boreholes), drinking water is 150 mS/m and no one makes use of relevant boreholes as a source of water for consumption. Leachate Dam TP enquired whether there has been any accumulation of salts at the bottom of the leachate dam and asked if this has had an impact on the containment capacity of the leachate dam. AMSA informed him that there are no known salt deposits in the dam but will reconfirm the status. TW mentioned that AMSA is continuously assessing the salt content and dam water level. Dust Buckets The committee raised a question regarding the high dust fall out measured at dust bucket DB 9, PM responded by mentioning that the bucket is still located within the centre of the boundary next to the main access road used by road transport for both internal and external material handling and adjacent to the current by-products area which contributes to the elevated levels recorded. The storage of by-products will be assigned to a new area by end of first quarter of 2015.

AMSA

2015

Site visit

A Site Visit was conducted on the 04th March 2015.

AMSA requested that confirmation of attendance of this meeting be submitted at least a week prior to the meeting date in order to make suitable arrangements for transport on site, report copies etc.

Next meeting

Date: 03 June 2015 Time : 10h00 – 11H00 Venue: ArcelorMittal Vanderbijlpark Works


09 December 2015


1. Attendance:




Terrence Wilson TW ArcelorMittal 072 500 0901 [email protected]




Tiaan Van den Berg TvdB ArcelorMittal 083 390 7504 [email protected]

Velaphi Mokgabudi VM ELM 078 547 2129 [email protected]




General Matters

The Chairperson welcomed everyone. Everybody present was satisfied with the adoption of previous minutes and the agenda. LH had previously noted that AMSA is in a process of drafting a request to reduce frequency of meeting due to recurring poor attendance. However a report will be prepared and submitted on a quarterly basis. AMSA received feedback from GDARD, AMSA to provide the minutes of previous Multi-Stakeholder Monitoring Committee meeting held from 2011 and copies of Environmental Authorisations of the facility. AMSA received a letter from DEA acknowledging receipt of proposal on the 29

th of June 2015. Awaiting DEA

PM to follow-up on what is outstanding from DEA and send information to SS to initiate action or obtain a response – Done, awaiting DEA Monitoring Report The Monitoring report was presented by PM, ArcelorMittal Environmental Technologist. Licenses LH mentioned that the Licence Review is needed for March 2016 - Noted Groundwater Monitoring DR to follow-up on groundwater and surface water monitoring points and plans. Leachate Dam None

AMSA PM AMSA DWS

Quarter 1 2016 Quarter 1 2016 Quarter 1 2016 Quarter 1 2016




09 December 2015


Dust Buckets The committee raised a question regarding the high dust fall out measured at dust bucket DB 9, PM responded by mentioning that the bucket is still located within the centre of the boundary next to the main access road used by road transport for both internal and external material handling and adjacent to the current by-products area which contributes to the elevated levels recorded. The storage of by-products will be assigned to a new area in 2016. Dust fallout rates have declined and are below the guideline for the past 7 months.

AMSA

2016

Site visit

None

Next meeting

Date: 09 March 2016 Time: 10h00 – 11H00 Venue: ArcelorMittal Vanderbijlpark Works


16-0063 06 September 2016

ANNEXURE L WATER MONITORING LETTER TO DEA


16-0063 06 September 2016

ANNEXURE L SURFACE WATER MONITORING LETTER

Documents

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