Landfill Gas to Electricity Project at Shongweni Landfill Sitepravinamar.com/reports/downloads/shongweni_gas_project/LFG at SLS... · iii • a variety of health problems such as

Project Number: S0388

Report Number: S0388/01

Revision Number: 1

Report Status: Draft for Public Review

Date: 5 August 2010

Prepared By: Matthew Hemming

Authorised By: Neil Brink

Environmental Services

PO Box 1822Rivonia, 2128

Tel: +27 (0)11 807 8225

[email protected]: +27 (0)11 807 8226

Working Together

ENVIROSERV WASTE MANAGEMENT (PTY) LTD

Application for a Waste Management Licence for the

Landfill Gas to Electricity Project at

Shongweni Landfill Site

DRAFT BASIC ASSESSMENT REPORT

i

APPLICATION FOR WASTE MANAGEMENT LICENCE:

ENVIRONMENTAL AUTHORITY:

Department of Environmental Affairs

Directorate: Authorisation and Waste Disposal Management

DEA Reference Number: ___pending_____________

[DAEARD Reference Number: DN/WML/0008/10]

Contact Person: The Director

Tel: 012 310 3920

Fax: 012 310 3753

Postal Address: Private Bag X447, Pretoria, 0001

PROJECT (ACTIVITY):

Landfill Gas to Electricity Project at the Shongweni Landfill Site.

REPORT:

Landfill Gas to Electricity Project at the Shongweni Landfill Site: BASIC ASSESSMENT REPORT.

Report Number: S0388/01

Report Status: Draft for Public Review

Revision No: 1

Date: 5 August 2010

PROJECT PROPONENT (APPLICANT):

EnviroServ Waste Management (Pty) Ltd (EnviroServ)

Contact Person: Neil Brink

Tel: 011 456 5400

Fax: 011 453 9048

Email: [email protected]

Postal Address: PO Box 9385, Edenglen

PROJECT DEVELOPER:

ENER-G Systems (PTY) LTD (Ener-G)

Contact Person: David Cornish Tel: 031 564 0222 Fax: 031 564 3802 Email: [email protected] Postal Address: P.O. Box 202126, Durban North, 4016

INDEPENDENT ENVIRONMENTAL CONSULTANT:

Synergistics Environmental Services (Pty) Ltd (Synergistics)

Tel: 033 343 4642

Fax: 011 807 8226

Email: [email protected]

Postal Address: PO Box 1822, Rivonia, JHB, 2128

Contact Person: Matthew Hemming

Qualifications: M.Sc Conservation Biology (UCT)

Experience: 4.5 years as an EAP

Affiliations: IAIA

ii

S0388 5 August 2010

LANDFILL GAS TO ELECTRICITY PROJECT

AT THE SHONGWENI LANDFILL SITE

BASIC ASSESSMENT REPORT

EXECUTIVE SUMMARY

Introduction

EnviroServ Waste Management (Pty) Ltd and Ener-G Systems (Pty) Ltd have entered into an

agreement to develop a landfill gas to electricity project at the Shongweni Landfill Site (SLS).

Ener-G Systems will establish and operate the landfill gas to electricity project.

The extraction, recovery and flaring of landfill gas is listed, in terms of Section 20 of the National

Environmental Management: Waste Act (59 of 2009), as a waste management activity that may

not be undertaken without a waste management licence. The activity is listed in Category A of the

schedule and requires the undertaking of a basic environmental assessment as stipulated in the

Environmental Impact Assessment Regulations (GN 385, 21 April 2006) of the National

Environmental Management Act No 107 of 1998.

Synergistics Environmental Services (Pty) Ltd undertook a basic environmental assessment of

the proposed project. This basic assessment report summarises the results of the public

participation and environmental assessment undertaken for the landfill gas to electricity project. A

draft basic assessment report is presented for public review and comment.

Background

Waste disposal sites generate landfill gas (LFG) which consists mostly of methane (~50 to 60 %)

and carbon dioxide (~ 20 – 30 %). A small percentage (~1 %) of the LFG is comprised of a large

number of trace components, primarily non-methane organic compounds. Among the trace

components of landfill gas may be ozone-depleting substances, hazardous compounds and air

pollutants. The release of LFG into the environment through uncontrolled surface emissions is

one of the priority health and environmental concerns surrounding waste disposal facilities. LFG

emissions may potentially contribute to:

• global climatic change induced by the methane component;

• reduced air quality through ground-level ozone formation

• odour nuisance from malodorous compounds; and

iii

• a variety of health problems such as cancer, respiratory irritation and central nervous

system damage from the hazardous trace gases.

LFG can be recovered from waste disposal facilities through active gas extraction, thereby

preventing, or at least reducing its emission into the atmosphere. Once captured, landfill gas is

typically combusted (through flaring). Combustion of LFG provides an effective and safe means

of disposing of the flammable constituents and results in the conversion of methane into carbon

dioxide. This minimises the adverse effect of LFG emissions on global warming. During the

combustion process many of the trace compounds in LFG are destroyed or converted into either

less odorous or less hazardous forms. The combustion of landfill gas also produces heat energy

which can be utilised to generate electricity.

Although modern landfill gas combustion technology has been designed to ensure complete

combustion and the “total destruction” of the LFG, there is a concern that combustion may result

in the formation of other more hazardous compounds. The formation of compounds such oxides

of nitrogen, oxides of sulphur, dioxins and furans are possible during or post the combustion

process. Many of these compounds are potentially hazardous to humans. The health risks

associated with the combustion of LFG need to be considered and compared with the health risks

posed by raw LFG.

Project Description

The principal goal for Ener-G Systems is to develop a landfill gas to electricity project that

produces greenhouse gas emission reductions and energy under the Clean Development

Mechanism (CDM). However, due to the complexity of generating and selling electricity and the

relative simplicity of capturing and destroying methane, Ener·G Systems will develop the project

in a two phased approach. In the first phase Ener·G Systems will install a state-of-the-art gas

collection system into the landfill body to maximize the extraction of landfill gas. Landfill gas

production at the SLS has been estimated from first principles and the SLS is anticipated to

produce at least 600 m3 of gas per hour. The captured gas will be pumped to a flare and

combusted. During phase 1 Ener-G Systems will develop the project’s CDM component in order

to register and verify the project’s greenhouse gas emission reductions. In the second phase

Ener·G Systems will install and operate a gas engine and generator for the production of

electricity. It is anticipated that gas production will be sufficient to produce 1MW of electricity. As

the electricity will be sold into the national grid, this phase will be dependant on the conclusion of

a power purchase agreement with Eskom.

iv

Study Approach and Methodology

The objectives of the basic assessment were to:

• Collate site, project and environmental baseline information;

• Describe the need and desirability of the project;

• Identify alternatives for the proposed development;

• Identify landowners, interested and affected parties, local authorities and

environmental authorities as well as other stakeholders that may have an interest in

the project.

• Inform landowners, authorities, stakeholders, interested and affected parties (IAPs) of

the proposed project;

• Engage IAPs and identify their issues and concerns;

• Engage environmental authorities and confirm legal and administrative requirements;

• Identify and assess potential direct and cumulative environmental impacts associated

with the proposed project; and

• Present management and mitigation measures recommended by the EAP.

Public participation was undertaken in terms of the EIA Regulations and made use of the

Shongweni Landfill Monitoring Committee forum. Synergistics maintained a register of interested

and affected parties and documented the issues and concerns raised by the public. The impact

assessment involved the identification and assessment of environmental impacts associated with

the proposed project. Scientific measurements and professional judgement were used to

determine the nature of the impact and the significance of the predicted environmental change.

The process involves consideration of, inter alia: the environmental status of the project location,

the purpose and need for the project; views and concerns of interested and affected parties and

compliance with environmental legislation and guidelines.

An Air Quality Impact Assessment was the only specialist study undertaken. Airshed Planning

Professionals (Pty) Ltd had completed an assessment for the establishment and operation of

Valley 2 at the SLS (Airshed 2008). That study quantified the potential gaseous and particulate

emissions from the SLS operations, modelled the potential dispersion of the pollutants and

recommended odour and health buffers zones for the SLS. The assessment included landfill gas

extraction as a mitigation measure, but did not consider the emissions from LFG combustion.

Airshed were therefore asked to revise the air quality impact assessment to include the emissions

that could be anticipated from the combustion of LFG through a flare and gas engine. Potential

health impacts of the combustion emissions were assessed against air quality standards.

v

Results of Public Consultation

Various members of the public asked questions of the project team and raised issues and

concerns with respect to the landfill gas to electricity project. Most of the IAP concerns came from

members of the Shongweni Landfill Monitoring Committee who are well versed on the operations

and issues of the SLS. The major concern related to the composition of the LFG at Shongweni

given the hazardous nature of the waste; the possible production of hazardous compounds during

LFG combustion; and the potential health risks from these compounds. Dioxins were identified as

a potential product of combustion that is highly hazardous. LFG samples were taken and the

trace gas component analysed in the UK. The Air Quality Impact Assessment specifically

investigated the potential emissions and health risks of LFG combustion. The study used

modelling as well as international literature to make conservation predictions. A number of other

questions were raised on the landfill gas to electricity project and were mostly answered at the

public meeting. A few issues relating to the general management of the SLS were also raised and

these were referred to EnviroServ management.

Impact Assessment

The impact assessment of the landfill gas to electricity project at the SLS did not identify any fatal

flaws or negative environmental impacts of significance. In fact the development of the landfill gas

to electricity project will result in significant environmental benefits. These include:

• the conversion of significant amounts of methane gas into carbon dioxide, thereby

reducing the sites contribution to global warming. This and the destruction of other gases

with ozone depleting potential will improve the sustainable waste disposal practices at the

SLS.

• the destruction of hazardous air pollutants contained in the raw LFG will reduce the

potential health risks to both on-site and discreet receptors.

• a reduction in gaseous emissions (bulk and trace gases) from the site will ensure that

potential odour and health risk impacts are restricted to within the designated

management and buffer zones.

• the generation of electricity from LFG provides the added environmental benefit of

offsetting non-renewable fossil fuels that would otherwise be used to generate the same

amount of energy. This avoids CO2 emissions and can also lead to significant reductions

in regulated air pollutants such as nitrogen oxides (a major contributor to urban ozone),

sulphur dioxide (a major contributor to acid rain) and particulate matter (a contributor to

respiratory health problems and often carcinogenic).

vi

The main negative effects of the landfill gas to electricity project will be the production of

hazardous air pollutants in the combustion emissions and certain occupational health risks. The

combustion emissions may include oxides of nitrogen, oxides of sulphur, dioxins and furans.

Dioxins in particular are a concern as they are probable human carcinogens, disperse widely in

the atmosphere, are long-lived and bio-accumulate. The production of these compounds could

affect occupational health as well as the health of off-site receptors.

The assessment (and international literature) concludes that although these compounds may be

highly toxic, they are produced in such minute amounts during LFG combustion, and do not pose

a significant risk.. LFG combustion destroys the great majority of the hazardous air pollutants in

LFG and results in an overall reduction in the health risk when compared with that of raw LFG

emissions. The Study by the Natural Resources Defense Council (March 2003) concluded that

“raw landfill gas is approximately 23 times more carcinogenic to human health than landfill gas

combustion exhaust”.

The occupational health and safety risks will be confined to specific situations and can be

mitigated with adequate inductions and training, communication between Ener-G and SLS

personnel and the correct use of PPE.

It is thus concluded that the addition of the landfill gas to electricity project at the SLS will have an

overall positive benefit to the environment and human health. The project should be implemented

to maximise the capture and combustion of LFG, using the most combustion-efficient technology.

All operations must be undertaken by trained personnel with due consideration for the

occupational health and safety risks from the landfill gas to electricity project and the SLS

operations. All components of the landfill gas to electricity project must be optimally maintained

to ensure efficient combustion and minimal production of potentially hazardous gases. Ener-G

must undertake the construction and operation of the landfill gas to electricity project in terms of

the operations manual and the equipment suppliers’ specifications. An environmental

management plan is recommended.

In concluding it is also important to note the combustion of LFG is required in order to implement

the extraction of LFG. Thus the benefits derived from the extraction of the LFG as assessed and

discussed in the EICR for Valley 2 (ie. reduced health risk buffer zone and odour management

zone), can only be realised if the LFG is combusted.

Landfill Gas to Electricity at Shongweni Landfill Site Basic Assessment Report (S0388)

vii SYNERGISTICS ENVIRONMENTAL SERVICES

TABLE OF CONTENTS

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

1.1 Project Motivation..............................................................................................2

1.1.1 Generation of Landfill Gas...................................................................................2

1.1.2 Odour and Health Risks from LFG Emissions.....................................................2

1.1.3 LFG and Global Climatic Change........................................................................3

1.1.4 Limiting Emissions of Landfill Gas.......................................................................4

1.1.5 Generation of Electricity.......................................................................................4

1.1.6 Potential Risks of LFG Combustion.....................................................................4

1.1.7 Existing LFG Projects ..........................................................................................7

1.1.8 Need and Desirability at the Shongweni Landfill Site..........................................7

1.2 Terms of Reference .........................................................................................11

2. LEGISLATIVE FRAMEWORK ...............................................................................11

2.1 Waste Permit ....................................................................................................11

2.2 Need for a Waste Management Licence ........................................................12

2.3 Applicable Legislation.....................................................................................12

2.3.1 National Environmental Management: Waste Act, No. 59 of 2009...................12

2.3.2 National Environmental Management Act, No. 107 of 1998 .............................13

2.3.3 EIA Regulations .................................................................................................13

2.3.4 National Environmental Management: Air Quality Act (No 39 of 2004) ............14

2.3.5 National Water Act (No 36 of 1998)...................................................................14

2.3.6 National Heritage Resources Act (No. 25 of 1999) ...........................................14

2.3.7 National Environmental Management: Biodiversity Act (No 10 of 2004) ..........15

2.3.8 Conservation of Agricultural Resources (No 43 of 1983)..................................15

3. STUDY APPROACH AND METHODOLOGY.........................................................16

3.1 Objectives .........................................................................................................16

3.2 Information Collation.......................................................................................16

3.2.1 Environmental Impact Control Report ...............................................................16

3.3 Public Participation .........................................................................................17

3.3.1 Shongweni Landfill Monitoring Committee ........................................................17

3.3.2 Identification of Interested and Affected Parties................................................17

3.3.3 Public meeting ...................................................................................................18

3.3.4 Registration of I&APs.........................................................................................18

3.3.5 Review of Draft Basic Assessment Report........................................................19

3.4 Authority Consultation....................................................................................19

3.5 Impact Assessment Methodology..................................................................19


viii SYNERGISTICS ENVIRONMENTAL SERVICES

3.5.1 Identification and Description of Impacts...........................................................19

3.5.2 Evaluation of Impacts and Mitigation Measures................................................20

3.5.3 Direct and Cumulative Impacts..........................................................................23

3.5.4 Project Phases...................................................................................................23

3.6 Assumptions and Limitations ........................................................................23

3.7 Specialist Study - Air Quality Impact Assessment ......................................24

4. THE SHONGWENI LANDFILL SITE ......................................................................27

4.1 General ..............................................................................................................27

4.1.1 Location..............................................................................................................27

4.1.2 Site Infrastructure...............................................................................................27

4.2 Waste permit.....................................................................................................27

4.3 Standard Operating Conditions .....................................................................28

4.3.1 General Operations, Monitoring and Maintenance............................................28

4.3.2 Disposal Volumes ..............................................................................................29

4.3.3 Storm Water Management.................................................................................30

4.3.4 Leachate Management ......................................................................................30

4.3.5 Planned Life and Site Development ..................................................................30

4.3.6 Labour and Staff Requirements.........................................................................30

4.3.7 Monitoring and Auditing .....................................................................................31

4.3.8 Closure Plan.......................................................................................................31

5. PROJECT DESCRIPTION......................................................................................32

5.1 Introduction ......................................................................................................32

5.2 Landfill Gas Generation ..................................................................................32

5.2.1 Landfill Gas Quantity..........................................................................................32

5.2.2 Landfill Gas Quality............................................................................................33

5.3 Phase 1..............................................................................................................34

5.3.1 General Layout ..................................................................................................34

5.3.2 Extraction Wells .................................................................................................36

5.3.3 Carrier Main and Blower ....................................................................................36

5.3.4 Flare ...................................................................................................................38

5.4 Phase 2..............................................................................................................38

5.5 Operations ........................................................................................................42

5.5.1 Gas wells and extraction system .......................................................................42

5.5.2 Flare ...................................................................................................................43

5.5.3 Gas Engine and Generator................................................................................43

5.5.4 Vehicles and Machinery.....................................................................................44

5.5.5 Water Use and Supply.......................................................................................44


ix SYNERGISTICS ENVIRONMENTAL SERVICES

5.5.6 Power Supply.....................................................................................................44

5.6 Labour and Staff Requirements .....................................................................44

5.6.1 Health and Safety ..............................................................................................44

5.7 Project Schedule..............................................................................................45

5.8 Decommissioning............................................................................................45

5.9 Project Alternatives .........................................................................................45

5.9.1 Use of Alternative Technologies........................................................................45

5.9.2 Alternative Designs for the Landfill Gas Extraction System ..............................46

5.9.3 No Go Alternative...............................................................................................47

6. BRIEF DESCRIPTION OF THE AFFECTED ENVIRONMENT...............................48

6.1 Land Ownership, Zoning and Land Use........................................................48

6.1.1 Shongweni Buffer Zone .....................................................................................48

6.1.2 Surrounding Land ..............................................................................................49

6.2 Topography ......................................................................................................50

6.3 Climate ..............................................................................................................50

6.3.1 Gaseous emissions............................................................................................51

6.4 Ecology and Biodiversity................................................................................51

6.4.1 Vegetation and Habitat Status ...........................................................................51

6.4.2 Animal Life .........................................................................................................52

6.5 Hydrology .........................................................................................................52

6.5.1 Catchment..........................................................................................................52

6.5.2 Water Use and Management.............................................................................52

6.5.3 Water Quality .....................................................................................................53

6.6 Geohydrology...................................................................................................54

6.6.1 Groundwater Level, Gradient and Flow.............................................................54

6.6.2 Characterisation of the Aquifers ........................................................................54

6.6.3 Groundwater use and management ..................................................................54

6.6.4 Groundwater Quality ..........................................................................................55

6.7 Air Quality .........................................................................................................57

6.7.1 Landfill Gas Composition...................................................................................57

6.7.2 Air Quality...........................................................................................................58

6.8 Heritage Resources .........................................................................................59

6.9 Noise..................................................................................................................59

6.10 Socio-Economics.............................................................................................60

6.10.1 Odour Complaints Register ...............................................................................60

6.10.2 Monitoring Committee Issues ............................................................................61

6.11 Health and Safety.............................................................................................62

6.11.1 Occupational Health...........................................................................................62


x SYNERGISTICS ENVIRONMENTAL SERVICES

6.11.2 Public Nuisance and Health...............................................................................63

7. RESULTS OF PUBLIC CONSULTATION..............................................................66

7.1 Collation of Issues and Concerns..................................................................66

7.2 Synthesis of Issues Raised` ...........................................................................66

8. ENVIRONMENTAL, SOCIAL AND CULTURAL IMPACTS....................................70

8.1 Land Use and Zoning ......................................................................................70

8.2 Climate ..............................................................................................................70

8.3 Geology and Soils............................................................................................71

8.4 Hydrology .........................................................................................................71

8.5 Geohydrology...................................................................................................71

8.6 Ecology .............................................................................................................72

8.7 Air Quality .........................................................................................................72

8.7.1 Compliance of Criteria Pollutants ......................................................................72

8.8 Heritage Resources .........................................................................................73

8.9 Traffic ................................................................................................................73

8.10 Noise..................................................................................................................73

8.11 Socio-Economics.............................................................................................73

8.12 Health and Safety.............................................................................................73

8.12.1 Occupational ......................................................................................................73

8.12.2 Public .................................................................................................................75

8.13 Potential ‘Upsets’.............................................................................................77

9. CONCLUSIONS .....................................................................................................86

DECLARATION BY CONSULTANT ....................................................................................88

References........................................................................................................................89

10. ENVIRONMENTAL MANAGEMENT PLAN ...........................................................90

10.1 Planning and Design .......................................................................................90

10.2 Construction.....................................................................................................91

10.3 Operations ......................................................................................................102

10.4 Closure and Rehabilitation ...........................................................................111

10.5 Financial Provisions ......................................................................................113

10.5.1 Environmental Monitoring ................................................................................113

10.5.2 Provision and replacement of infrastructure....................................................113

10.5.3 Restoration and aftercare ................................................................................114


xi SYNERGISTICS ENVIRONMENTAL SERVICES

LIST OF APPENDICES

Appendix 1: Minutes and Presentation from the Shongweni Landfill Monitoring

Committee Meeting i

Appendix 2: Proof of Press Advertisements ii

Appendix 3: Proof of Site Notices iii

Appendix 4: Notification Letter iv

Appendix 5: Notification Letter Distribution List v

Appendix 6: Registered Interested and Affected Party Database vi

Appendix 7: IAP Comments and Responses Report vii

Appendix 8: Air Quality Impact Assessment viii

Appendix 9: User and Operations Manuals for the Landfill Gas to Electricity Project at

the SLS ix

LIST OF FIGURES

Figure 1: Regional Location of the Shongweni Landfill Site 9

Figure 2: Layout of Shongweni Landfill Site 10

Figure 3: Landfill Gas Generation Curve for the SLS 33

Figure 4: Proposed Layout of the Landfill Gas Extraction System at the Shongweni

Landfill Site 35

Figure 5: Typical layout of a vertical gas well 37

Figure 6: Typical layout of the blower and gas flare 40

Figure 7: Typical layout of the Gas Engine and Generator Unit 41

LIST OF TABLES

Table 1: Environmental Impact Rating (Judging) Criteria 20

Table 2: Site Landowner Information 27

Table 3: Average Monthly Waste Volume and Composition (2009) 29

Table 4: Ownership of Properties surrounding the SLS 49

Table 5: Summary of Environmental Impacts and Environmental Management

Measures 78

Table 6: Construction Environmental Management Plan 92

Table 7: Operations Environmental Management Plan 102

Table 8: Closure and Rehabilitation Environmental Management Plan 111


xii SYNERGISTICS ENVIRONMENTAL SERVICES

TERMS AND ABBREVIATIONS

~ Approximately

CDM Clean Development Mechanism

CERs Certified Emission Reductions

CH4 Methane gas

CO2 Carbon dioxide gas

CO2 e Carbon dioxide equivalents

dB Decibel

DAEARD Department of Agriculture, Environmental Affairs & Rural Development

DEA Department of Environmental Affairs

DWA Department of Water Affairs

EAP Environmental Assessment Practitioner

ECA Environment Conservation Act 73 of 1989

EIA Environmental Impact Assessment

EICR Environmental Impact Control Report

EMP Environmental Management Plan

Ener-G Ener-G Systems (Pty) Ltd

EnviroServ EnviroServ Waste Management (Pty) Ltd.

G General Waste

GHG Greenhouse Gas

GN Government Notice

GWP Global Warming Potential

H Hazardous waste

HDPE High Density Poly Ethylene

H:h Rating of a waste disposal facility where certain classes of hazardous waste may be disposed.

IAP Interested and Affected Parties

IPCC International Panel on Climate Change

km kilometre

KZN KwaZulu-Natal Province

LFG Landfill Gas

m metre

m3 cubic metre

mamsl Metres above mean sea level


xiii SYNERGISTICS ENVIRONMENTAL SERVICES

NEMA National Environment Management Act 107 of 1998

NEM:WA National Environment Management: Waste Act 59 of 2009

Nm3 Normal cubic metres, at standard temperature and pressure.

NMOC Non-Methane Organic Compounds

PCDD polychlorinated dibenzodioxins or Dioxins

PCDF polychlorinated dibenzofurans or Furans

PPE Personal Protective Equipment

SANS South African National Standards

SLS Shongweni Landfill Site

Site Refers to the SLS

tpa Tonnes per annum

VOC Volatile Organic Compound


1 SYNERGISTICS ENVIRONMENTAL SERVICES

S0388 5 August 2010

LANDFILL GAS TO ELECTRICITY PROJECT

AT THE SHONGWENI LANDFILL SITE

BASIC ASSESSMENT REPORT

1. INTRODUCTION

EnviroServ Waste Management (Pty) Ltd and ENER-G Systems (Pty) Ltd have entered into an

agreement to develop a landfill gas to electricity project at the Shongweni Landfill Site (Figure 1).

EnviroServ own and operate the Shongweni Landfill Site (SLS) in terms of an existing waste

permit (16/2/7U602/B3/Y1/P270).

Ener-G Systems will establish and operate the landfill gas to electricity project which, will be

developed in two phases. In the first phase gas wells will be sunk into the landfill body to extract

landfill gas generated through the decomposition of waste. The captured gas will be pumped to a

flare where the gas is combusted. The capture and combustion of landfill gas reduces emissions

from the landfill and converts many of the gases into heat energy. In the second phase gas

engines and generators will be added to the system for the production of electricity. The electricity

generated on the site will be sold to Eskom.

The extraction of landfill gas is listed as a waste management activity that may have a detrimental

effect on the environment (GN R 718, July 2009). In terms of Section 20 of the National

Environmental Management: Waste Act (59 of 2009), such listed activities may not be undertaken

without a waste management licence. The extraction, recovery and flaring of landfill gas are listed

in Category A of the schedule and as such require a basic environmental assessment process as

part of the application for waste management licence.

The purpose of this basic assessment report is to summarise the results of the public participation

and environmental assessment undertaken for the landfill gas to electricity project at the

Shongweni Landfill Site and to present this information to the competent authority in support of

the application for a waste management licence.



1.1 Project Motivation

1.1.1 Generation of Landfill Gas

Waste disposal sites generate and emit landfill gas (LFG). Landfill gas consists mostly of

methane (~50 to 60 %) and carbon dioxide (~ 20 – 30 %). Methane (CH4) is produced by

methanogenic micro-organisms, which, under anaerobic conditions, decompose the

biodegradable waste fractions disposed within the waste body. A small percentage (~1 %) of the

LFG is comprised of a large number of trace components, primarily non-methane organic

compounds1. The various trace components are produced through the variety of chemical

reactions that take place within the waste body. Among the trace components of landfill gas may

be ozone-depleting substances, hazardous air pollutants, and volatile organic compounds

(VOCs) which can contribute to odour nuisances, adverse health risks and smog (low level

ozone).

LFG can either: be trapped and retained within the waste cells; migrate through the sub-surface

soils into surrounding areas; or be emitted to the atmosphere by diffusive and convective flux

mechanisms. The sub-surface migration of landfill gas can pose a risk as it may cause pollution,

fires and / or explosions. Methane displaces oxygen and causes asphyxiation; it is also

flammable at certain concentrations. The release of landfill gas into the environment through

uncontrolled surface emissions is one of the priority health and environmental concerns

surrounding waste disposal facilities. Landfill gas emissions may potentially contribute to:

• global climatic change induced by the methane component;

• reduced air quality through ground-level ozone formation

• odour nuisance from malodorous compounds; and

• a variety of health problems such as cancer, respiratory irritation and central nervous

system damage from the hazardous trace gases.

1.1.2 Odour and Health Risks from LFG Emissions

The trace gas component of LFG is known to comprise a huge variety of compounds. These are

primarily non-methane organic compounds and volatile organic compounds as well as inorganic

toxic contaminants like mercury. The composition of the trace gas component depends on the

wastes that were disposed within the landfill and the conditions under which the waste has

decomposed or reacted.

1 The trace gases may include: aromatic and chlorinated hydrocarbons such as benzene, chloroform, hydrogen sulphide, carbon

monoxide, dichloroflouromethane, nitric acid and odorous reduced sulfur gases such as hydrogen sulfide



Certain of the compounds present in LFG, in particular hydrogen sulphide, are also highly

malodorous. These malodorous compounds, apart from having an unpleasant odour, may also

trigger reflexes in the body such as

• Nausea

• Vomiting

• Headache

• Upsetting of stomach or appetite

• Upsetting of sleep

• Shallow breathing and coughing

• Decreased heart rate and constriction of blood vessels in skin and muscles

• Alteration of cells of the olfactory bulbs of the brain

• Irritation of eyes, nose and throat

• Annoyance, anger and depression

• A general decrease in well-being and enjoyment

Many of the compounds found in the trace gas component of LFG are known to be hazardous

and at elevated concentrations or exposures can cause carcinogenic, teratogenic and other

health effects in humans. Although some studies have shown increases in health conditions of

persons living near landfills, most information indicates that the constituents of landfill gas, with

potentially toxic effects, are rarely present in sufficient concentrations to present a health hazard.

Most modern landfill are operated with a buffer zone to ensure that the public are not exposed to

significant concentrations of landfill gas.

1.1.3 LFG and Global Climatic Change

Methane is a major greenhouse gas and is known to contribute to the effects of global warming

because of its potential to trap long wave radiation within the earth’s atmosphere. The

International Panel on Climate Change (IPCC) has assigned Methane a global warming potential

of 25 times that of carbon dioxide (CO2)2. This means that methane is 25 times more effective at

trapping heat than carbon dioxide, over a hundred year period, and is therefore 25 times more

potent than carbon dioxide in terms of its contribution to global warming3.

2 The global warming potential of greenhouse gases are measured relative to the global warming potential of carbon dioxide over a

specific time period. 3 The 2007 IPCC Fourth Assessment Report gives methane a global warming potential of 25; while the Third Assessment Report of

the IPCC indicated methane’s GWP at 23. Many sources indicated methane’s GWP at 21 times that of carbon dioxide.



According to the United States Environmental Protection Agency (USEPA), waste disposal

facilities are the single largest human source of methane emissions in the United States,

accounting for 33 % of all methane emission sources. The concentration of methane in the

atmosphere has increased 148% above levels recorded in 1750 (USEPA).

1.1.4 Limiting Emissions of Landfill Gas

Landfill gas can be recovered from waste disposal facilities through active gas extraction, thereby

preventing, or at least reducing its emission into the atmosphere. Once captured, landfill gas is

typically combusted (through flaring). Combustion provides an effective and safe means of

disposing of the flammable constituents and results in the conversion of methane into carbon

dioxide. Combustion of LFG reduces the emission of greenhouse gases into the atmosphere by a

factor equal to the global warming potential of methane. This serves to minimise the adverse

effect of LFG emissions on global warming.

During the combustion process many of the trace compounds in LFG are destroyed or converted

into either less odorous or less hazardous forms. In the absence of extraction and combustion

these gases would be emitted from the landfill and could potentially result in low level ozone

formation, odour nuisance or health risks. The extraction and combustion of the trace

components will limit any adverse environmental effect and reduce the significance of the landfill

sites’ impacts on nearby receptors.

1.1.5 Generation of Electricity

The combustion of landfill gas produces heat energy which is either released to the atmosphere

or captured and utilised. The generation of electricity from landfill gas provides energy from an

alternative energy source. South Africa is actively pursuing technologies to enable the generation

of electricity from alternative and renewable sources (DME, White Paper on Renewable Energy,

2003)

Ener-G Systems (Pty) Ltd are well placed to exploit the energy available at the SLS and have

international experience and access to word-class technology. Ener-G Systems is the UK’s

leading independent landfill gas electricity supplier and one of the leaders in installing and

operating landfill gas technology in developing countries. Ener-G Systems has more than 90 MW

of installed capacity in the United Kingdom (UK) and worldwide.

1.1.6 Potential Risks of LFG Combustion

There is a concern that the combustion of landfill gas, while destroying certain of the gases, may

result in the formation of other more hazardous compounds. Matter cannot be created or



destroyed and combusting LFG does not destroy all the molecules, but changes them into

alternative forms. The formation of compounds such oxides of nitrogen, oxides of sulphur, dioxins

and furans are possible during or post the combustion process. All of these compounds are

potentially hazardous to humans and their formation should be avoided where possible. Dioxins

and furans are of particular concern – see Section 1.1.6.1 below.

Modern landfill gas combustion technology (flares and gas engines) has been designed to

minimise the risk of the formation of hazardous compounds with high temperature operations and

long flame retention times. These measures are designed to ensure complete combustion and

the “total destruction” of the landfill gas through high-efficiency combustion. However, all

combustion processes produce exhaust gases which will contain a certain amount of toxic

compounds.

The health risks associated with the combustion of LFG cannot be considered in isolation but

need to be compared with the health risks posed by raw LFG.

1.1.6.1 Dioxins and Furans

Dioxins or polychlorinated dibenzodioxins (PCDDs) and Furans or polychlorinated dibenzofurans

(PCDFs) are hazardous compounds produced in small concentrations when organic material is

burned in the presence of chlorine (chloride ions or as organochlorine compounds), promoted by

a transition metal catalyst.

Dioxins and furans occur in a variety of congeners that vary in their toxicity depending on the

specific structure of each molecule. The group are probable human carcinogens that may also

cause severe reproductive and developmental problems. Dioxins are also known to damage the

immune system, interfere with hormonal systems, reduce sperm counts, and cause

endometriosis, birth defects, diabetes, learning disabilities, immune system suppression, lung

problems, skin disorders and lowered testosterone levels.

Dioxins are particularly dangerous to human health because they can travel very long distances,

break down very slowly and bio-accumulate. Low concentrations of dioxins exist in nature due to

natural combustion and geological processes. Concentrations of dioxins in the atmosphere, soil,

plants, animals and humans have been increasing since the industrial revolution and are typically

higher in industrialised countries. The most common method of human exposure is from the

ingestion of food, specifically meat, fish and dairy products (dioxins are fat soluble and bio-

accumulate up the food chain). Particular point sources with uncontrolled emissions can also

create inhalation risks and even home fires, braais and cigarette smoke may generate dioxins in

small amounts.



The pathways for the formation of dioxins and furans require specific conditions and the presence

of specific molecules in order to take place. Dioxins and furans are known to form during

incomplete combustion in two ways:

1. in the gas phase at temperatures of 500 – 800 ºC by free radical reactions

(Homogeneously); and

2. on solid combustion products (i.e. fly ash) as combusted gas cools down through the

temperature window of 200 - 400 ºC (Heterogeneously, known as the De Novo

Mechanism).

According to the most recent USEPA data, the major sources of dioxins are broadly the following:

• Combustion sources

• Metal smelting

• Refining and process sources

• Chemical manufacturing sources

• Natural sources

• Environmental reservoirs

According to the USEPA the incineration of municipal solid waste, medical waste, sewage sludge,

and hazardous waste was together responsible, in 1987, for more than 80% of known dioxin

sources. As a result, the USEPA implemented regulations to control waste incineration processes

and reduce dioxin stack emissions. Incinerator emissions of dioxins have been reduced by over

90% as a result of emissions control requirements. The USEPA now claims that waste

incineration in the USA contributes less than 3% of all dioxin emissions (2006).

Landfill gas from the SLS may contain the necessary precursor compounds (chorobenzenes,

chlorophenols, phenol, and benzene) as well as a chlorine donor compounds (chlorine, polyvinyl

chloride (PVC), and gaseous hydrogen chloride) to potentially enable the formation of dioxins and

furans. Thus the combustion of landfill gas could potentially result in the formation of dioxins and

furans. The De Novo formation in the cooling exhaust gases from the combustion of LFG is

unlikely to occur as the mechanism requires the presence of solid combustion products (ie. ash)

and a metal catalyst.



1.1.7 Existing LFG Projects

Landfill gas extraction projects have been successfully implemented on landfill sites throughout

the world. In the USA the Environmental Protection Agency runs a voluntary program to assist

landfill sites to reduce methane emissions by encouraging the recovery and beneficial use of

landfill gas as an energy resource (Landfill Methane Outreach Program (LMOP)). There are

currently more than 500 landfill sites in the USA with operational landfill gas extraction system,

and another 500+ that have been identified as candidate sites (LMOP, April 2010). LFG

extraction is also widely used throughout Europe. The flares, engines and generators used on

these operational projects are required to comply with the stringent emissions regulation

standards applied in Europe.

There are also many local examples of operational landfill gas projects in South Africa. The

majority of these have or are being developed in terms of the Clean Development Mechanism

(CDM). The CDM is a project scheme developed under the Kyoto Protocol for achieving

measurable reductions in greenhouse gas emissions. The CDM has accepted the extraction and

flaring of landfill gas as an approved methodology and such projects have been used worldwide

for the reduction of green house gas emissions. South Africa acceded to the Kyoto Protocol in

2002 and, being recognised as a developing country, can serve as a host for CDM projects.

Landfill gas extraction projects in South Africa that are registered with the CDM include: the

Durban Landfill Gas to Electricity Project, Chloorkop Landfill Gas Recovery, Alton Landfill Gas to

Electricity, various Ekurhuleni Metropolitan Municipality Landfill Gas Recovery Sites, New

England Landfill Gas to Energy Project, Bulbul Drive Landfill Gas to Electricity, Buffalo City

Landfill Gas to Electricity, Nelson Mandela Bay Metropolitan Landfill Gas, Belville Landfill, Coastal

Park Landfill, Vissershok Landfill, Faure and Swartklip Landfills etc, etc.

1.1.8 Need and Desirability at the Shongweni Landfill Site

The implementation of a landfill gas extraction project is supportive of South Africa’s acceptance

of the Kyoto Protocol and the countries’ international drive to reduce greenhouse gas emissions

and promote sustainable waste disposal practises. The overall benefits of the LFG to electricity

project at Shongweni and its contribution to sustainable development will include:

• The recovery and combustion of methane gas will reduce the sites emission of greenhouse

gas.

• The destruction of many of the trace gases in landfill gas will reduce the ozone depletion

potential of the SLS.

• The reduced ozone depletion potentials and global warming potentials will have positive

transboundary impacts as these are global phenomena.



• The destruction of many of the trace gases will reduce local odour nuisances and low level

ozone formation.

• The destruction of many of the trace gases in landfill gas will reduce the health risk.

• Promotion of local economic development for the equipment and materials required by the

project (i.e. piping and flares).

• Potential direct foreign investment in South Africa through the sale of emission reduction or

carbon credits generated through the combustion of methane.

• The downstream utilisation of the heat energy generated by the process comprises the use of

an alternative source of energy. As such, the project supports the South African government’s

drive towards the use of energy from alternative sources.

An important consideration in assessing the risks and benefits of an LFG combustion project is

the balance of the environmental and health risks of the uncombusted LFG emissions versus

risks that result from the by-products of combustion. Modelling of the emissions to the air, pre and

post LFG combustion was used to provide an indication of the potential costs and benefits. The

biophysical and socio-economic environmental impacts of the project (both beneficial and

adverse) have been assessed and are discussed in Section 8 of this report. No fatal flaws or

negative impacts of high significance were identified to cast doubt on the environmental and

social acceptability of the project – the assessment concluded that the benefits of the project

outweigh its costs.



Figure 1: Regional Location of the Shongweni Landfill Site



Figure 2: Layout of Shongweni Landfill Site



1.2 Terms of Reference

Synergistics Environmental Services (Pty) Ltd was appointed by Ener-G Systems as independent

environmental consultant to undertake the necessary work to meet the requirements of informing

a waste management licence decision from the Department of Environmental Affairs:

Authorisation and Waste Disposal Management (DEA) for the development of the landfill gas

extraction system at the Shongweni Landfill Site. The DEA is the competent authority as the

Shongweni Landfill Site handles hazardous wastes.

This basic assessment report documents the environmental assessment and public participation

process undertaken. It presents the proposed project, an assessment of the potential impacts and

the management and mitigation measures recommended by the environmental assessment

practitioner. The basic assessment report has been compiled in accordance with sub regulation

23 published in GN R 385.

2. LEGISLATIVE FRAMEWORK

2.1 Waste Permit

The SLS was commissioned in late 1992, early 1993 and was permitted, in terms of Section 20(1)

of the Environment Conservation Act (No. 73 of 1989) (ECA), by the Department of Water Affairs

and Forestry (DWAF) in July 1993 (B33/1/1920/P71). The original permit for the SLS was revised

in 1997 (16/2/7U602/B3/Y1/P270). Specific conditions of the SLS permit have subsequently been

amended in August and December of 2005 (16/2/7/U602/B3/Y1) and again in 2007

(16/2/7/U602/B3/Y1/P270/A5). The waste permit is held by EnviroServ Waste Management (Pty)

Ltd.

Although Section 20 of the ECA has been repealed by the National Environmental Management:

Waste Act (59 of 2008) the NEMWA specifically states, in Section 81(1), that “Despite the repeal

of section 20 of the ECA by this Act, a permit issued in terms of that section remains valid subject

to subsection (2) and (3)”. The waste disposal permit for the SLS is therefore valid and activities

allowed for in the permit can continue to be undertaken. Landfill gas extraction is however not

contemplated in the SLS permit.



2.2 Need for a Waste Management Licence

The requirements of the National Environmental Management: Waste Act (No. 59 of 2008)

(NEMWA) came into effect on 1 July 2009. The NEMWA makes provision for the identification of

various waste management activities which have or are likely to have a detrimental effect on the

environment. A waste management activity identified in terms of the Act may not commence, be

undertaken or conducted except in accordance with published standards or a Waste

Management Licence.

On 3 July 2009 the list of waste management activities requiring a Waste Management Licence

from a competent authority were published (GN R 718). Listed waste management activities are

divided into Category A and Category B in the schedule. Activities identified in Category A require

a basic assessment process, as stipulated in the Environmental Impact Assessment Regulations

(GN 385, 21 April 2006) of the National Environmental Management Act No 107 of 1998, in order

to inform an application for a waste management licence.

Although the waste permit for the SLS remains valid in terms of the NEMWA, activities not

originally contemplated in the existing permit need to be licensed in terms of the NEMWA. Landfill

gas extraction, recovery and flaring were not contemplated in the SLS waste permit and these

activities are not authorised. The following waste management activities relate to the construction

and operation of the landfill gas to electricity project at the SLS:

Government Notice Activity No Description of the listed activity

GNR 718 A(13) The extraction, recovery or flaring of landfill gas.

GNR 718 A(18) The construction of facilities for activities listed in Category A.

GNR 718 A (19) The expansion of facilities or changes to existing facilities for any process or activity, which requires an amendment of an existing permit or license or a new permit or licence in terms of legislation governing the release of pollution, effluent or waste.

2.3 Applicable Legislation

In accordance with EIA sub regulation 23 (2)(e) under GN 385 (21 April 2006), all legislation and

guidelines that have been considered in the preparation of the basic assessment report are to be

documented. This section lists environmental legislation that has been identified as being

pertinent to the proposed development of the landfill gas to electricity project.

2.3.1 National Environmental Management: Waste Act, No. 59 of 2009

As discussed above.



2.3.2 National Environmental Management Act, No. 107 of 1998

The National Environmental Management Act (107 of 1998) (NEMA) makes provision for the

identification of various activities which have or are likely to have a detrimental effect on the

environment. The listed activities identified in terms of the NEMA may not commence without

environmental authorisation from the competent authority. Environmental Impact Assessment

Regulations were promulgated in terms of Section 24(5) of NEMA on 21 April 2006 in

Government Notice GN) R 385. The regulations define the requirements in terms of Chapter 5 of

NEMA for the submission, processing, consideration and decision of applications for

environmental authorisation of listed activities. Two lists, defining activities that require either a)

basic assessment or b) scoping and environmental impact assessment in terms of Sections 24

and 24D of NEMA were published in Government Notice R 386 and R 387 respectively. Any

activity that is captured under either of these lists requires environmental authorisation from the

competent authority. The assessment process is to be undertaken in accordance with GN R 385

of the EIA Regulations.

The extraction or processing of natural gas, including gas from landfill sites was captured as a

listed activity in the schedule of activities requiring scoping and environmental impact assessment

(1(i) of GN R 387). However, with the introduction of the NEM:WA and the listing of waste

management activities, landfill gas was omitted from the EIA Regulations with effect from 9

October 2009 (GN 971).

2.3.3 EIA Regulations

The NEM:WA stipulates that the basic assessment process required in support of the waste

management licence (for a category A activity) must be undertaken in terms of the Environmental

Impact Assessment Regulations made under section 24(5) of the NEMA. The EIA Regulations

provide clear instructions on the required content of a basic assessment report and this report

has been prepared in accordance with sub-section 23 of the regulations.

In addition, a number of guidelines to NEMA and the EIA Regulations have been published to

assist in the scoping and EIA process. Guidelines that have been considered include:

• Guideline 3: General Guideline to the Environmental Impact Assessment Regulations

(DEAT, 2006);

• Guideline 4: Public Participation in support of the Environmental Impact Assessment

Regulations (DEAT, 2006);

• Guideline 5: Assessment of alternatives and impacts in support of the Environmental

Impact Assessment Regulations (DEAT, 2006).



2.3.4 National Environmental Management: Air Quality Act (No 39 of 2004)

The National Environmental Management: Air Quality Act (39 of 2004) (NEM:AQA) was

promulgated with the intent to reform the law regulating air quality in order to protect the

environment. The NEM:AQA makes provision for the identification of various activities which have

or may have a detrimental effect on the environment (GN R 248, March 2010) and also specifies

compliance limits for air quality emissions. The activities identified in terms of the NEM:AQA

require an atmospheric emissions licence from the competent authority. The schedule includes

minimum emission standards for the various activities.

The combustion of gas, including natural gas is identified as an activity for which minimum

emission standards have been set and an atmospheric emissions licence is required. The listing

is however only applicable to installations with a design capacity equal to or greater than 50 MW

heat input per unit, based on the lower calorific value of the fuel used. Emissions limits are also

set for particulate matter, SO2 and NO2. The landfill gas to electricity project at the SLS is not

anticipated to exceed these criteria and an atmospheric emissions licence is not required.

2.3.5 National Water Act (No 36 of 1998)

Section 21 of the National Water Act (No. 36 of 1998) (NWA) lists water uses for which a water

use licence must be obtained. The landfill gas extraction project will not require a water use as

listed in the NWA and no licence will be required.

2.3.6 National Heritage Resources Act (No. 25 of 1999)

The National Heritage Resources Act provides for the protection of all archaeological and

paleontological sites and meteorites. Section 38 of the Act defines the categories of development

for which the responsible heritage resources authority must be notified. Under Section 38 (c) ’any

development or other activity which will change the character of a site-‘(i) exceeding 5000m2’ the

responsible heritage authority must be informed of a development. The footprint of the landfill gas

extraction project will be located within the SLS which has previously been assessed and thus no

heritage assessment is required.



2.3.7 National Environmental Management: Biodiversity Act (No 10 of 2004)

The Act provides for the Minister or MEC to list species and ecosystems which are threatened

and in need of protection as well as to identify threatening processes within these ecosystems.

No ecosystems or processes have as yet been listed. A list of threatened and protected species

and regulations pertaining thereto has been published (GN R 150, 151 & 152, February 2007).

The site has been previously disturbed by waste disposal activities and there is little to no chance

of any sensitive species occurring, thus no mitigation or permits are required.

2.3.8 Conservation of Agricultural Resources (No 43 of 1983)

The Act defines a list of registered weeds and invader plants, categorises them into different

classes and introduces restrictions where these plants may occur. The act prohibits the spread of

weeds and requires that listed weeds be controlled. An alien and invasive plant control

programme is currently applied at the SLS.



3. STUDY APPROACH AND METHODOLOGY

3.1 Objectives

The objectives of the basic assessment were to:

• Collate site, project and environmental baseline information;

• Describe the need and desirability of the project;

• Identify alternatives for the proposed development;

• Identify landowners, interested and affected parties, local authorities and

environmental authorities as well as other stakeholders that may have an interest in

the project.

• Inform landowners, authorities, stakeholders, interested and affected parties (IAPs) of

the proposed project;

• Engage IAPs and identify their issues and concerns;

• Engage environmental authorities and confirm legal and administrative requirements;

• Identify and assess potential direct and cumulative environmental impacts associated

with the proposed project; and

• Present management and mitigation measures recommended by the EAP.

3.2 Information Collation

The data sources used in the basic assessment are listed below:

• Previous studies and monitoring from the SLS, as presented in the EICR;

• Internet sources on landfill gas and flaring;

• EnviroServ, the site operators; and

• Ener-G Systems, the project developer.

3.2.1 Environmental Impact Control Report

The EICR for the Shongweni Landfill Site was prepared in 2009 to identify the various ways in

which the SLS and the development of Valley 2 affects the receiving environment. The EICR

documented the current knowledge of the SLS and the state of the environment (based on all

studies and monitoring to date), described the issues and impacts related to the site and

identified the management and mitigation measures required to control or eliminate impacts.



3.3 Public Participation

The public participation process was undertaken by Synergistics Environmental Services with the

assistance of Pravin Amar Development Planners who facilitate the Shongweni Landfill

Monitoring Committee. Synergistics produced the various public information documents,

maintained the register of interested and affected parties and documented the issues and

concerns raised by the public. Pravin Amar Development Planners were involved to distribute

project information through the existing lines of communication and facilitate public meetings.

3.3.1 Shongweni Landfill Monitoring Committee

Continued public consultation at the SLS is facilitated through regular meetings of the Shongweni

Landfill Monitoring Committee (SLMC). This committee was established to provide a forum for

discussion on issues relating to the operation, management and monitoring of the SLS. The

SLMC has been managed by Pravin Amar Development Planners on behalf of EnviroServ since

1997. The SLMC has met on a regular basis since then, with meetings being held on a monthly

basis during 2009. New projects, developments and monitoring results are presented at the

SLMC meetings. The local communities are provided with the opportunity to ask questions and

raise issues and concerns. Minutes are recorded at each of the SLMC meetings and are made

available to the committee members.

Public participation for this waste management licence application process was facilitated through

the SLMC platform. All members on the SLMC mailing list were notified of the project and invited

to attend a special meeting to introduce the project and discuss the basic assessment process. In

addition to the use of the SLMC forum, and in order to meet the requirements of NEMA,

Synergistics undertook to notify and consult with land owners and other potentially interested and

affected parties.

3.3.2 Identification of Interested and Affected Parties

As the SLMC is an established committee that has been running for many years the committee’s

database of IAPs was used as a starting point for the distribution of project information. Additional

measures to identify IAPs included the placement of site posters and newspaper advertisements.

Networking and referral by informed IAPs has helped register additional IAPs.

3.3.2.1 Press Advertisements

A notification advertisement was placed in the Mercury, Highway Mail and the Ilanga newspapers

in February 2010 (Appendix 2). The adverts notified the public of the project and invited IAPs to

contact the public participation office and register as an interested and affected party. The



advertisement also invited all IAPs to attend the public meeting to discuss the landfill gas to

electricity project at the SLS.

3.3.2.2 Site Notice

A3 size posters providing notification of the project and the basic assessment process, requesting

the public to register as IAPs and inviting all parties to the public meeting were placed at the site

entrance and on the access road to the site (Appendix 3).

3.3.2.3 Notification Letter

A notification letter, providing basic information on the project, notifying persons of the waste

management licence process, inviting the public to register as IAPs and to attend the public

meeting was distributed to all persons on the SLMC mailing list and was available to those

persons whom attended the public meeting or who contacted the public participation office.

The letter was sent by registered mail to the local authorities (including officials at the eThekwini

Metropolitan Municipality and the local ward councillors) and businesses near to the SLS. The

letter is provided in Appendix 4 and the distribution list is given in Appendix 5.

3.3.3 Public meeting

A public meeting was held at the Assegay Hotel on 15 April 2010 to introduce the landfill gas to

electricity project and to discuss the basic assessment process as required for the waste

management licence application. Presentations were made on the proposed project and on the

enviro-legal requirements and the public were provided with the opportunity to ask questions and

raise issues. Minutes of the meeting and the presentation made there are included in Appendix

1.

3.3.4 Registration of IAPs

IAPs were asked to register before 28 April 2010. All persons and organisations that attended

the public meeting or contacted the public participation office were registered as IAPs and will

receive any further information regarding the project. The IAP database is included as Appendix

6. Copies of the responses received from the IAPs are provided in Appendix 7.



3.3.5 Review of Draft Basic Assessment Report

The basic assessment report is being made available to all IAPs for review at the SLS site office,

the Hillcrest Public Library and the Mkhiza Store in Salem. The report is also available on the

internet at www.synergistics.co.za from 6 August until 15 September 2010. Pravin Amar

Development Planners also have a copy of the draft report. All registered and affected parties

were notified by fax, email or telephone of the report’s availability. Comments received from IAPs

on or before 15 September 2010 will be incorporated into the final basic assessment report.

3.4 Authority Consultation

Notification letters and a BID for the project were sent to officials of the eThekwini Metropolitan

Municipality, including the Mayor, City Manager and Environmental Manager. Project notifications

were also sent to the local ward councillors, including wards 7, 10 and 14. The local KwaZulu-

Natal Department of Agriculture, Environmental Affairs and Rural development were also notified

of the application. The draft basic assessment report has also been made available to the

authorities for review including the DEA, KZN DAEARD and the eThekwini Metropolitan

Municipality.

3.5 Impact Assessment Methodology

The identification and assessment of environmental impacts is a multi-faceted process, using a

combination of quantitative and qualitative descriptions and evaluations. It involves the

application of scientific measurements and professional judgement to determine the significance

of environmental impacts associated with the project. The process involves consideration of, inter

alia: the purpose and need for the project; views and concerns of interested and affected parties;

environmental legislation and guidelines; and general public interest. The systematic approach

and generic criteria used to identify, describe and assess impacts is outlined below.

3.5.1 Identification and Description of Impacts

For each environmental component (i.e. visual, air quality, ecology), impacts were identified and

considered in terms of the nature of the impact and the significance of the predicted

environmental change. Compliance with legislation and accepted standards were also

considered.



3.5.2 Evaluation of Impacts and Mitigation Measures

Potential impacts and proposed management and mitigation measures were assessed. An

explanation of the criteria that were systematically applied throughout the assessment process,

and terms used in the rating process are provided in Table 1 below. The impact assessment has

taken into account the current environment at the SLS and the details of the proposed project.

Cognisance was given to both positive and negative impacts that may arise.

Table 1: Environmental Impact Rating (Judging) Criteria

Rating Criteria Symbol Qualitative Description / Explanation of the Rating Criteria

H High level of degradation, significant transformation has affected the item.

L Low level of degradation, little transformation has occurred.

Current level of Degradation

/ Unaffected, no transformation has taken place.

Intensity

N Neutral. Impacts are insignificant or not measurable / discernable.

L Low / slight disturbance or nuisance. Impacts would be intermitted and/or present for short periods of time. Impacts are rapidly and easily reversible, requiring only minor interventions / cleanup actions. Targets / Limits / Thresholds of concern not exceeded. Only sporadic complaints expected during the impact’s occurrence.

M

Moderate disturbance / discomfort. Targets / Limits / Thresholds of concern occasionally exceeded. Impacts are reversible but may require some effort, cost and time. Regular complaints expected during impact occurrence.

Adverse Impacts

( -)

H High / obvious impact associated with noticeable deterioration / degradation. May involve illness, injury or death. Targets / Limits / Thresholds of concern regularly or continually exceeded. Widespread community mobilisation expected during impact occurrence.

L Low / slight improvement to current situation.

M Moderate improvement to current situation.

Beneficial Impacts

( + )

H High / substantial improvement to current situation.

L Local impact confined to within the Shongweni Landfill Site or within the buffer zone, thus the impact is localised and confined to within an achievable management zone. Very few, if any, sensitive receptors would be affected. As a general rule, impacts are limited to within 450 m from the site boundary.

M Moderate extent. The impact extends beyond the buffer zone (450 m) up to ~2.5 km from the site and may affect sensitive receptors.

Extent

H Widespread impact. Impacts extend far beyond the site boundary. May be Regional / National / International or Transboundary.

L Short term, risk/potential of impacts occurring is limited to the construction phases or less than the project’s lifespan. Impacts are rapidly reversible.

M Medium term. The risk/potential of impacts occurring is present throughout the life of the project, up to and including decommissioning. Impacts are reversible over time.

Duration

(Risk Period)

H Long term. Residual impacts will remain after decommissioning. Permanent or difficult to reverse.




VL Conceivable, but only in extreme circumstances (< 10 %)

L Has not occurred to date, but it could occur (10 - 30 %)

M Could happen and has occurred here or elsewhere (30 - 50 %)

H Could easily happen (50 - 70 %)

Probability of risk occurrence

VH Happens often (> 70 %)

G Good / high potential to successfully implement proposed mitigation measures.

R Reasonable potential to successfully implement proposed mitigation measures.

Mitigation Potential

U Unknown / Unlikely. Lack of information. No or little mechanism to mitigate impacts.

– Adverse (Negative) Impact

+ Beneficial (Positive) Impact

Status

/ Not relevant / not applicable

VL Lowest order impact with minimal real effect. Adverse impacts:

– Mitigation is possible / easily achieved.

– Physical, ecological, social, cultural and economic activities can continue unchanged.

Beneficial impacts:

– Alternative means of achieving the same benefits are likely to be significantly easier, cheaper, more effective and less time-consuming.

L Low order impact with minimal real effect. Adverse impacts:

– Mitigation is possible / easy and/or little mitigation is required.

– Physical, ecological, social, cultural and economic activities can continue with very little change.

Beneficial impacts:

– Alternative means of achieving the same benefits are likely to be easier, cheaper, more effective and less time-consuming.

M Impact is real, but not substantial in relation to other impacts. Adverse impacts:

– Mitigation is both feasible and fairly easily implemented.

– Physical, ecological, social, cultural and economic activities of communities are changed but can continue in an altered state.

– Within control targets / limits / thresholds.

Beneficial impacts:

– Other means of achieving the same benefit are about equal in time, costs and effort.

Significance

(function of intensity extent, duration and

probability)

Rated ‘without mitigation’ and ‘with

mitigation’.

H Impact of a high order. Adverse impacts: Mitigation is either not feasible, or is difficult / expensive to implement. May not keep impacts within levels, standards, guidelines

– Beneficial impacts:

– Other means of achieving benefits are marginally more expensive in time, cost and effort.




VH Impact of a highest order. Adverse impacts:

– There is no mitigation or mitigation is difficult, expensive, time-consuming or any combination of the above.

– Physical, ecological, social, cultural and economic activities of communities are disrupted.

– Exceed legal or regulatory requirements, standards or guidelines.

– Exceed thresholds of concern.

– High level of risk to public health.

– May result in extinction of species / loss of genetic diversity, rare or endangered species, or critical habitats.

Beneficial impacts:

– Substantial. Other means to achieve same benefits are likely to involve more time, costs and effort.

N Neutral. No discernable impact, or where the impacts are discernable, they would not result in any real impact on sensitive receptors.

FF Fatal Flaw. A situation that prevents the development of an environmentally acceptable development, except at prohibitive cost.

G Good / high level of confidence in information. Substantial supportive data available to verify the results.

R Reasonable confidence based on existing information. Additional data may be required for final verification of assessment results but this does not prevent the project to proceed to the detailed design phase.

Degree of Certainty

U Unsure / Unknown. Uncertainty / lack of information / lack of reliable information. Assessment cannot be completed without additional data. Following the precautionary principle, a final decision about the future of the project cannot be taken for any NEGATIVE HIGH impacts where the degree of certainty is ‘UNSURE’.

To be Confirmed ? Cannot be rated. Additional data and/or consultation with IAPs required.

Although the criteria used for the assessment of impacts attempts to quantify the significance, it is

important to note that the assessment is generally a qualitative process and therefore the

application of these criteria is open to interpretation. The process adopted involves the application

of scientific measurements and professional judgment to determine the significance of

environmental impacts associated with the project. The assessment thus largely relies on

experience of the environmental assessment practitioner (EAP) and the information available for

the local environment.

Where the consequence of an event is not known or cannot be determined, the “precautionary

principle” is adhered to and the worst-case scenario assumed. Where required, additional impact

control measures will be recommended to reduce the significance of negative impacts and

enhance positive impacts.



3.5.3 Direct and Cumulative Impacts

Existing infrastructure and activities at the SLS have, in many cases, altered the environment to a

less than natural state. In order to understand the environmental context of the SLS the baseline

environment is considered in terms of the existing impacts and current levels of environmental

degradation as described in the EICR. This assessment has focussed on environmental impacts

associated with the development of the landfill gas to electricity project at the SLS. No attempt

has been made to consider impacts at the SLS which are not influenced by the landfill gas to

electricity project.

The direct impacts of the landfill gas to electricity project are those that arise solely as a result of

the landfill gas to electricity project. The total or cumulative impacts of the landfill gas to electricity

project at the SLS are the sum of the direct impacts from the project and the existing impacts

from the SLS. The cumulative impacts may be more severe than the baseline (when the landfill

gas to electricity project has a negative impact), or an improvement on the current baseline (when

the landfill gas to electricity project has a positive effect.

3.5.4 Project Phases

In the assessment consideration has been given to impacts that may result from the construction

and operational phase of the landfill gas to electricity project. However, as the construction of

certain aspects of the project may be undertaken while other components of the project are

operational, all impacts are discussed together.

The consideration of impacts during decommissioning is limited as it is estimated that the facility

will be in operation for at least a further 20 years. The status of the environment may have

changed significantly at that stage.

3.6 Assumptions and Limitations

The key assumptions and limitations of this assessment are detailed below.

• Details of the site operations and design information used to describe the project and identify

impacts were provided by EnviroServ, the site operators, and Ener-G Systems, the project

developer.

• Monitoring data and the results of specialist studies formed the basis for the assessment of

impact significance. It was assumed that the information from these sources is relevant and

accurate. The assumptions and limitations of the specialist study are detailed in that report.



• The identification of environmental impacts, the rating of impact significance and the

recommendation of mitigation measures assumed that the design parameters and standard

operating conditions of the landfill gas to electricity project were implemented with an

acceptable level of management and maintenance efficiency. Occasional non-compliances or

limited failures are an accepted part of operations and were thus included in the impact

assessment.

• This study does not, and cannot assess the environmental risks associated with fires,

accidents, very poor site management or maintenance and acts of nature.

3.7 Specialist Study - Air Quality Impact Assessment

The only specialist study required to consider the potential impact of the landfill gas to electricity

project was an air quality impact assessment.

Airshed Planning Professionals (Pty) Ltd completed an Air Quality Impact Assessment for the

establishment and operation of Valley 2 at the SLS (Airshed 2008). The purpose of that study

was to quantify the potential gaseous and particulate emissions from the SLS operations to

determine the possible impacts on the surrounding environment and human health. The

assessment evaluated the potential air quality, odour and health risks of emissions from the SLS

and included landfill gas extraction as a mitigation measure. The modelling demonstrated that the

extraction of LFG from the SLS would have a positive effect by reducing the total emissions from

the landfill body, thereby reduce the frequency and extent of impacts on odour and health. The

odour and health buffers zones that the study recommended were based on a scenario with

landfill gas extraction (see buffer in Figure 2).

The 2008 assessment did not however consider the potential emissions or air quality impacts that

may result from the combustion of the LFG extracted from the waste body. Airshed Planning

Professionals were therefore asked to revise the air quality impact assessment to include the

emissions that could be anticipated from the combustion of LFG through a flare and gas engine.

The air quality impact assessment is attached as Appendix 8.

Airshed’s methods were as follows: The establishment of an emissions inventory formed the

basis for the assessment of the impacts from the proposed operation’s emissions on the receiving

environment. Gaseous and particulate emissions from the engine and the flare were estimated

based on a combination of design specifications, emission limits, mass balance methods and

concentrations of typical compounds found in the exhaust of LFG gas plants as reported

internationally. Cumulative particulate emissions (PM10, particulate matter with an aerodynamic

diameter of less than 10 µm) as a result of the proposed gas plant in addition to fugitive

particulate emissions from land filling operations were included in the assessment.



Given the complexity of terrain and therefore the surface wind-field in the study region, the United

States Environmental Protection Agency (US EPA) approved CALPUFF dispersion model was

selected for application in the investigation. This suite includes a complex meteorological model

(CALMET) and a non-steady state Lagrangian puff dispersion model (CALPUFF). The

meteorological modelling domain comprised an area of 10 km by 10 km with a grid resolution of

100 m. Terrain and land use data were input at the 100 m grid resolution. Three dimensional

MM5 data for an area covering 120 by 120 km was used as input in the meteorological modelling.

MM5 is a widely-used three-dimensional numerical meteorological model that contains non-

hydrostatic dynamics and a variety of physics options and is also capable of simulating a variety

of meteorological phenomena such as tropical cyclones, severe convective storms, sea-land

breezes, and terrain forced flows such as mountain valley wind systems (Atmospheric Studies

Group (ASG), 2008). The hourly three dimensional meteorological parameters at 12 km intervals

included wind speed, wind direction, temperature, pressure, geo-potential height, vertical velocity

and relative humidity.

The compliance and health risk assessment was done by comparing predicted pollutant

concentrations to the National Ambient Air Quality Standards (NAAQS) of South Africa and

international health risk guidelines. The following pollutants were included in the study:

• Carbon monoxide (CO);

• Nitrogen dioxide (NOx as NO2);

• PM10;

• Sulphur dioxide (SO2); and

• Dioxins and Furans (included as 2,3,7,8 – Tetrachlorodibenzo-p-dioxin (TCDD)).

Limitations and assumptions pertaining to the assessment were:

• Predicted air pollution impacts only include those pollutants associated with the

combustion of LFG. Particulate and carbon monoxide emissions were cumulatively

assessed, whereas other LFG emissions (trace gases and bulk gases) from the surface

of the landfill cells, with and without gas utilisation, were addressed in the air quality

impact assessment for the operation of Valley 2 (Burger and Krause, 2008).

• Emissions and impacts from the engine and flare were estimated individually under full

load operating conditions. The assessment also considered the potential of

simultaneously operating the flare and engine.

• The gas plant will be located in an already cleared area. Fugitive dust emissions from

construction activities associated with the installation of the gas plant are expected to be

minimal and were omitted from the air quality impact assessment.



• It was assumed that all combustion operations will have ceased by the closure phase of

the project. The potential for impacts during this phase will depend on the extent of

demolition and rehabilitation efforts during closure and on features which will remain.

• Information regarding the extent of demolition and/or rehabilitation procedures were

limited and therefore not included in the emissions inventory or the dispersion modelling.

• Emissions were estimated for the engine and flare operating at full capacity with an

annual design operational availability of 88%.

• Nitrogen Oxide (NO) is rapidly converted in the atmosphere into the much more

poisonous NO2. The rate of this conversion process is determined by both the rate of the

physical processes of dispersion and mixing of the plume and the chemical reaction rates.

As a conservative measure, and in the absence of accurate ozone (O3) data, all long- and

short term NOx impacts were assumed to be NO2.

• Some members of the polychlorinated dibenzodioxins (PCDDs), or dioxins, are organic

compounds that have been shown to bio-accumulate in humans and wildlife and are

known teratogens, mutagens and suspected human carcinogens. The word "dioxins" may

also refer to a similar but unrelated compound, the polychlorinated dibenzofurans

(PCDFs), or furans, of similar environmental importance. 2,3,7,8 - Tetrachlorodibenzo-p-

dioxin (TCDD) is the most toxic of the congeners and is used in the investigation as a

surrogate for all dioxin and furan congeners. This is considered a conservative approach.

• Since the dispersion model cannot compute real-time processes; maximum consumption,

production and emission rates were therefore used. Operational locations and periods

were selected to reflect the worst case scenarios.

• The range of uncertainty of the model predictions could to be -50% to 200%. There will

always be some error in any geophysical model, but it is desirable to structure the model

in such a way to minimise the total error. A model represents the most likely outcome of

an ensemble of experimental results. The total uncertainty can be thought of as the sum

of three components: the uncertainty due to errors in the model physics; the uncertainty

due to data errors; and the uncertainty due to stochastic processes (turbulence) in the

atmosphere.



4. THE SHONGWENI LANDFILL SITE

4.1 General

The Shongweni Landfill Site is a class H:h site waste disposal permitted for the disposal of

hazardous waste of Hazard Groups 3 and 4 and delisted waste for co-disposal with domestic

waste. Waste disposal takes place in engineered waste disposal cells. Valley 1 was used for

disposal until recently but has reached capacity (1 480 000 m3 of airspace). Valley 2 has been

developed for further waste disposal at the SLS and provides an additional 1 500 000 m3 of

airspace (Figure 2).

4.1.1 Location

The Shongweni Landfill Site is located near Shongweni (Figure 1) in the eThekwini Municipality of

the KwaZulu-Natal Province. The SLS is located on Portion 36 of the farm Remainder of Kirkfalls

14227. The approximate centre of the SLS is at S29º 49.635 E30 º 44.901. The adjacent portion

of land is owned by EnviroServ and is retained as a buffer zone.

Table 2: Site Landowner Information Farm Portion Zoning Owner Title Deed

Remainder of

Kirkfalls 14227

36 Special for

Waste Disposal

EnviroServ Waste

Management

T4743/1990

Remainder of

Kirkfalls 14227

37 Buffer EnviroServ Waste

Management

T4743/1990

4.1.2 Site Infrastructure

The SLS consists of waste cells in Valley 1 and Valley 2, access roads, offices and laboratory,

weigh bridge, workshops, wash bay, storm water and leachate management dams and a borrow

area (Figure 2).

4.2 Waste permit

The SLS was commissioned in late 1992, early 1993 and was permitted, in terms of Section 20(1)

of the Environment Conservation Act (No. 73 of 1989) (ECA), by the Department of Water Affairs

and Forestry (DWAF) in July 1993 (B33/1/1920/P71). The original permit for the SLS was revised

in 1997 (16/2/7U602/B3/Y1/P270). Specific conditions of the SLS permit have subsequently been

amended in August and December of 2005 (16/2/7/U602/B3/Y1) and again in 2007

(16/2/7/U602/B3/Y1/P270/A5). The waste permit is held by EnviroServ Waste Management (Pty)

Ltd.



The SLS is registered as a H:h class waste disposal site with authorisation to accept hazardous

waste of Hazard Groups 3 and 4 and delisted waste for co-disposal with domestic waste. The

permit and annexures detail waste which may be accepted at the SLS. Both solid and liquid

wastes are accepted and co-disposal is practiced. The site is operated in terms of the permit

conditions, the DWAF Minimum Requirements for Waste Disposal Series and the SLS

Operations Manual.

4.3 Standard Operating Conditions

4.3.1 General Operations, Monitoring and Maintenance

The SLS is used for the disposal of general and hazardous waste including class 3 and 4 wastes.

The landfill operates with a day and a night shift on Monday to Saturday and is open from 07H30

to 03H00. On Sundays the site is open between 08H00 to 15H00.

Non-hazardous waste is accepted at the SLS and is used as an absorbent and barrier for

hazardous and/or liquid wastes. All vehicles entering the site are weighed and then directed to an

appropriate area at the site for disposal. Once the waste is disposed then the departing vehicle is

weighed.

Hazardous waste is only accepted at the site on a 24-hr notice basis. Waste that is intended for

disposal at the SLS is subject to tests and analyses. All hazardous waste that is planned for

disposal is recorded on the Control Authorisation Sheet (CAS). Site management uses the CAS

to plan the quantities of treatment chemicals, the type of equipment and the volume of ash etc,

which will be required to effect disposal. Vehicles arriving at the site must have a Waste Manifest

Document and the volume and type of waste is verified against the CAS. The waste may then be

sampled and analysed to confirm the disposal instruction. The vehicle then passes over the

weigh-bridge prior being directed to the disposal site. Any treatment procedures are then applied

and the waste disposed of. The empty vehicle exits via the weighbridge.



The standard operating, monitoring and maintenance procedures for the SLS are defined in the

SLS Operations Manual which is updated on a regular basis, most recently in March 2009. The

SLS Operations Manual details, in writing, procedures to be followed by all persons carrying out

certain tasks at the SLS. In this way the tasks are always carried out following the same methods

which, minimises the risks in the operation of the landfill site and therefore helps in protecting the

environment, employees and surrounding communities from any harmful practices which could

arise from operations at the SLS. The document is also used to provide training of staff and

ensures continuity of operational practices when there are changes in staff. The SLS Operations

Manual details the following information:

• Construction and site development;

• Tests and analyses;

• Waste acceptance;

• Waste access control;

• Landfill operating principles;

• Waste disposal;

• Water management;

• Air quality management;

• Monitoring;

• Reporting and auditing;

• Health and safety; and

• Communication and public participation.

4.3.2 Disposal Volumes

The average monthly quantity of waste disposed at SLS over the course of the 2009 year is

estimated at approximately 23 000 tons. The average composition of this waste is summarised

below in Table 2. Monthly airspace consumption at the site is approximately 13 715 m3.

Table 3: Average Monthly Waste Volume and Composition (2009) General Waste 3,691.06

Ash 3,495.11

Builders Rubble 376.29

Cover 2,182.50

Dry Hazardous 7,699.82

DRY WASTES

Total dry waste 17,444.78

Sludge solids 1,466.59 WET WASTES

Sludge liquids 1,592.31



Liquids 2,927.33

Total wet waste 5,986.22

TOTAL MONTHLY WASTE 23,431.01t

4.3.3 Storm Water Management

Storm water at the SLS is managed to ensure the separation of clean and contaminated water.

Clean storm water is diverted around the site and released to the environment. Any water that

has come into contact with waste or other potentially contaminated materials is contained on-site

in the storm water dam and is treated as leachate. Controls are implemented to prevent erosion.

4.3.4 Leachate Management

Leachate generated in the waste body is collected in the leachate drain, drained from the waste

body and contained in a leachate dam. The leachate is pumped from the dam to storage tanks

where it is diluted with contaminated storm water before it is removed by a contractor for disposal

to sewer. The leachate is disposed to the Southern Works Treatment Facility in terms of an

agreement with the municipality.

Many of the air quality problems in the past have resulted from the exposure of the leachate weir

and dam. The leachate weir has been covered and the leachate dam will be replaced with closed

tanks.

4.3.5 Planned Life and Site Development

Valley 1 has recently reached capacity and Valley 2 is to be used for future waste disposal.

Valley 2 will provide an additional 1 500 000 m3 of airspace which, at predicted disposal rates this

will provide 9.5 years of disposal, and revise the commencement of closure to approximately

2020. The development of Valley 2 is being done in a phased approach with the Valley being

constructed in a number of cells.

4.3.6 Labour and Staff Requirements

Currently 26 persons are employed by EnviroServ at the SLS.



4.3.7 Monitoring and Auditing

Sub-surface gas and ambient air quality is monitored in terms of the permit conditions and is

undertaken by Margot Saner & Associates. Surface and groundwater monitoring is also done in

terms of the permit conditions and is undertaken by Jones & Wagener. Slope stability is

monitored twice a month. Internal and external audits are undertaken in accordance with the

frequency required by the permit. The external audits are undertaken by Environmental and

Chemical Consultants. Employee exposure monitoring of various hazardous compounds is also

undertaken by Margot Saner & Associates on a regular basis. Employee medical surveillance is

undertaken by qualified medical staff.

4.3.8 Closure Plan

Closure of the SLS or any portion thereof will require rehabilitation and the preparation of a

closure plan. The end use of the site (future land use after closure) has not yet been defined.



5. PROJECT DESCRIPTION

5.1 Introduction

The principal goal for Ener-G Systems is to develop a landfill gas to electricity project that

produces greenhouse gas emission reductions and energy under the Clean Development

Mechanism. However, due to the complexity of generating and selling electricity and the relative

simplicity of capturing and destroying methane, Ener·G Systems will develop the project in a two

phased approach. In the first phase Ener·G Systems will install a state-of-the-art gas collection

system to maximize the extraction and combustion of landfill gas. During phase 1 Ener-G

Systems will develop the project’s CDM component in order to register and verify the project’s

greenhouse gas emission reductions. In the second phase Ener·G Systems will install and

operate a gas engine and generator for the production of electricity. As the electricity will be sold

into the national grid, this phase will be dependant on the conclusion of a power purchase

agreement with Eskom.

5.2 Landfill Gas Generation

The decomposition of waste in a landfill site produces landfill gas, the quantity and composition of

which is dependant on the waste in the landfill and the conditions under which the decomposition

takes place. The SLS has received and disposed of a unique variety of wastes since 1993,

including both general and hazardous wastes. This is likely to impact on both the quantity and

composition of the landfill gas produced.

5.2.1 Landfill Gas Quantity

Landfill gas production at the SLS has been estimated from first principles, on the basis of waste

input data supplied by EnviroServ (Figure 3). At the current production estimates, Ener-G

Systems anticipates to be able to extract at least 600 m3 of gas per hour from the SLS. Gas

production at these levels is likely to continue until at least 2021, after which it will begin to taper

off. The SLS will continue to produce significant quantities of landfill gas until after 2030. The gas

production curve will be more accurately defined once landfill gas extraction is underway and can

be monitored.



Figure 3: Landfill Gas Generation Curve for the SLS

5.2.2 Landfill Gas Quality

Monitoring of the landfill gas quality at the SLS has been undertaken at the sub-surface gas

probes as part of the Air Pathway Analysis System (monitoring at on-site locations and off-site

receptors measures ambient conditions). The analysis of the sub-surface samples only

considered the bulk gases such as Methane, Carbon Dioxide, Oxygen and Hydrogen Sulphide.

Landfill gas also includes a huge number of trace gases which are unique to each site.

As part of this assessment two samples of the landfill gas from the SLS were sent to the UK

accredited Waste Recycling Group laboratory for analysis of the trace gas component. The

analysis indicated a very high (> 68%) methane concentration and variable concentrations of

substances such as hydrogen sulphide, sulphur and chlorine. Of the trace gas components

Toluene, Dichloroethene, Vinyl Chloride, Methanethiol, isoPentane, Pentane, Xylene and

Ethylbenzene were recorded in significant concentrations. The results of the analysis are

provided in Appendix C of the Air Quality Study.



5.3 Phase 1

The landfill gas extraction system entails the installation of vertical wells and horizontal collectors

into the waste body to extract the landfill gas. Extraction wells and collectors will be connected to

a carrier main pipe in which gas is collected under vacuum and channelled to the flare for

combustion. Phase 1 will be developed as quickly as possible in order that the maximum volume

of green house gas emission reductions can be earned by the project.

5.3.1 General Layout

The footprint of the proposed project falls entirely within the Shongweni Landfill Site, and largely

within the area permitted for waste disposal (Valley 1 and Valley 2). Phase 1 of the landfill gas

extraction facility will consist of the following main components:

• A well field (vertical wells and horizontal collectors);

• Connector and carrier main pipes;

• A blower and flare unit;

The well field will be installed into the waste body of Valley 1. Connector pipes will join the wells

to a carrier main pipe that will transport the gas to the combustion facility. The combustion facility

will be fenced with non-lethal, electrified fences and locked to prevent unauthorised entry. The

preferred conceptual layout of the project in Valley 1 is illustrated on Figure 4. A similar system of

wells, connections and carrier pipes will be installed in Valley 2 as waste is disposed there.



Figure 4: Proposed Layout of the Landfill Gas Extraction System at the Shongweni Landfill Site



5.3.2 Extraction Wells

Approximately 26 vertical wells, with 40 m centres, will be installed in Valley 1. The 300 mm

diameter holes are drilled into the waste body to a depth of 15-20 m into the waste (ending above

the cell liner). Perforated well liners, consisting of 200 mm diameter HDPE pipes, perforated at

150 mm intervals with 20 mm diameter holes, are installed and the well holes backfilled with

gravel. The upper end of the well will be sealed with a bentonite or clay plug (Figure 5). This

ensures an adequate seal to prevent the ingress of oxygen into the landfill body when suction is

applied to the wells. The wells will be equipped with well heads, which have a valve to control gas

flow as well as monitoring ports to conduct field measurements. The basic features of a gas well

are shown in Figure 5.

As Valley 2 is currently being used for waste disposal the establishment of extraction wells into

the waste body may be different. Vertical wells as described above may be installed. However,

horizontal collectors may also be installed within the waste body of Valley 2 during the waste

deposition phase. The installation of horizontal collectors involves the excavation of trenches into

the surface of the waste body at intervals of approximately ten (10) metres. Perforated HDPE

collector pipes will be installed in the trenches, and these will be backfilled with washed gravel

and covered with geo-textile material, which prevents clogging of the pipes with sand or other fine

material.

5.3.3 Carrier Main and Blower

Each gas well is connected to large diameter carrier main pipe by a 63 mm pipe (Figure 4). The

landfill gas will be collected in the carrier main under a small vacuum using a blower and

channelled to the flare for combustion. The spark-proof blower provides the vacuum required to

operate the well field and the pressure to move the gas to the flare or energy recovery equipment.

The gas passes through a liquid ‘knock-out’ vessel or ‘scrubber’, which removes entrained liquid

and particulates from the gas. The collected liquid is referred to as ‘condensate’, which is

removed from the system and disposed to the leachate system at the SLS.



Figure 5: Typical layout of a vertical gas well



5.3.4 Flare

A Biogas low emission ground flare system (2000 Nm3 per hour) will be used for the flaring

process. The flare is composed of a cylindrical combustion chamber, approximately 7.85m tall,

which is designed to enclose the flame, thereby preventing quenching and resulting in a relatively

uniform flame with high destruction efficiencies and low emissions. The combustion chamber, 1.8

m in diameter, has a thick ceramic lining and insulation to retain heat and provide retention times

of approximately 0.5 seconds. This ensures the total destruction of the combustible components

within the feed gas. The basic features of the blower unit and flare are shown in Figure 6.

Flares are well proven technology and are designed with the following safety features:

• Flame arrestor - prevents the flame from travelling down the pipes into the wells thus

preventing ignition of the subsurface gas;

• Flame detector - to ensure the continuous presence of a flame;

• Ignition system - to automatically re-ignite the flare should the flame fail thus preventing

any emissions of uncombusted landfill gas; and

• Failsafe valve - shuts off gas supply to the flare should re-ignition fail or another problem

be detected, thus preventing emissions of uncombusted landfill gas.

5.4 Phase 2

During the implementation of the first phase, Ener·G Systems will work toward the electrical

generation phase of the project. An application will be made to Eskom for a power purchase

agreement that will be based on the gas field production and electrical generation capacity. Once

an agreement is finalised then the gas engines and generators will be installed and will enable

the generation of electricity from the combustion of the landfill gas. The electrical production

aspect will require the addition of the main components:

• Spark ignition gas engine;

• electrical generator; and

• Connection to the grid.

The gas engines and generator to be used at the SLS will be a containerised unit with an output

capacity of 1.15 MW. The gas engines and generator will be installed at the flare compound. The

basic features of the gas engine and generator are shown in Figure 7. A switch valve

arrangement will be installed to enable the diversion of the gas from the flare to the engine. The

flare will remain on-site and will operate when the gas engine is being maintained or shut down

for any reason.



The electrical connection to the Eskom grid will be made at the existing 1.6 MVA power line that

runs along the southern border of the SLS. A switching station will also be installed.



Figure 6: Typical layout of the blower and gas flare



Figure 7: Typical layout of the Gas Engine and Generator Unit



5.5 Operations

As the LFG to electricity project will be constructed and operated at the SLS, an active landfill

site, all activities will be undertaken in terms of the site operator’s requirements. Compliance to

the SLS permit conditions and the SLS operations manual is compulsory. All activities planned for

the site will be presented to and approved by the SLS Site Manager prior to their undertaking. All

Ener-G site personnel will undergo an induction at the SLS and use appropriate personal

protective equipment (PPE).

The landfill gas to electricity system will be managed in terms of a site operations manual

compiled by Ener-G Systems (see Appendix 9). This document details work instructions for all

activities undertaken at the site and includes the user manuals provided by the suppliers of each

piece of equipment. The site operations manual has been compiled by Ener-G and has drawn on

their international experience, site knowledge and information drawn from the manuals of all the

systems components.

5.5.1 Gas wells and extraction system

Gas will be extracted from the wells under a slight vacuum created by the blower. Gas extraction

will continue on a 24 hr per day basis. The operating, monitoring and maintenance of the gas

wells will be undertaken by Ener-G Systems’ personnel trained in the operation of the landfill gas

system. Daily operations will include the taking of gas readings, balancing the gas collection

system, monitoring of production and performance and inspections of key components. Routine

maintenance will be carried out as required.

5.5.1.1 Landfill Gas Condensate Management

Landfill gas condensate is a liquid produced in landfill gas collection systems. It is composed

primarily of water and organic compounds which often separate into a watery (aqueous) phase

and a floating organic (hydrocarbon) phase. Condensate is not reactive but may contain

numerous organic pollutants, at levels higher than recommended by the US EPA, which make it a

hazardous substance (US EPA, 1988). Landfill gas condensate is also highly odourous.



The landfill gas condensate must be removed from the collection piping system as the liquid can

interfere with the steady flow and collection of landfill gas, thereby reducing the efficiency of the

extraction system and wasting energy. In some cases, landfill gas condensate may cause a

complete flow blockage in the affected collection pipes. Condensate will be collected and

removed by in-line knock-outs. These devices will be located on the collection system and in the

blower flare system. Collected condensate will be collected and disposed to the leachate system

at the SLS.

5.5.1.2 Leachate Management

Leachate may be encountered in the gas collection wells. When leachate is present and

interferes with gas collection this will be pumped out of the wells and disposed to the leachate

collection system at the SLS.

5.5.2 Flare

The Biogas flare will be operated in terms of the Technical Manual provided by Biogas

Technology Limited (see Appendix 9). The operating, monitoring and maintenance of the flare will

be undertaken by Ener-G Systems’ personnel who have undergone training.

5.5.2.1 Flare Emissions Monitoring

International experience and the results of the air quality modelling show that the emissions from

flaring will be well within applicable air quality limits. As such, monitoring of flare emissions are

not viewed as a critical operational aspect of the project.

It is however recommended that operational parameters of the flare be monitored and maintained

within manufacturer’s specifications, in order to ensure that complete combustion is achieved and

the potential for emissions minimised. The input gas will be continuously analysed to ensure that

the operational parameter of the flare or engine are correct.

5.5.3 Gas Engine and Generator

The gas engine and generators will be operated in terms of the Technical Manuals provided by

suppliers (see Appendix 9). The operating, monitoring and maintenance of the gas engine and

generators will be undertaken by Ener-G Systems’ personnel who have undergone training in

terms of the manufacturer’s specifications.



5.5.4 Vehicles and Machinery

Construction of the project will be achieved using on-site vehicles and machinery with the

exception of the vertical wells which will be drilled by a drilling rig. Construction material will be

delivered as and when required. Thus, construction and operation of the project will not require

any additional on-site vehicles, machinery or refuelling stations and there will be virtually no

additional traffic loads.

5.5.5 Water Use and Supply

There will be no change to the water use and supply to the SLS facility due to the development of

the gas extraction project.

5.5.6 Power Supply

Power supply will be from electricity through the SLS’s existing supply network. No generators will

be required. Once the system is producing electricity it will be self sufficient. Should the power fail

the blower will shutoff and no gas will be brought through the system.

5.6 Labour and Staff Requirements

Two permanent operator positions will be created for the operation of the landfill gas to electricity

system. Ener-G will appoint a Senior Technician responsible for the management and operation

of the site. A Junior Technician will be responsible for daily checks on the gas collection system;

taking gas readings; balancing the gas collection system and routine maintenance. All Ener-G

personnel will be trained in terms of the site operations manual. It is anticipated that 10 persons

will be employed as contractors for the construction of the landfill gas to electricity system.

5.6.1 Health and Safety

The contractor responsible for the drilling of the wells will be experienced in this field and

adequate personal protective equipment (PPE) will be a requirement during the time on the site.

The PPE will include acid proof overalls and gloves, safety shoes, glasses and dust masks.

Respirators must be available during excavations and used when required. Smoking is only

permitted in the designated areas at the SLS.



The flare and engine will be mounted on a concrete slab and the area will be fenced with a

lockable gate to prevent unauthorised access. The facility will be sign posted. PPE currently

required by on-site personnel working at the landfill include overalls, dust masks, safety shoes

and rubber gloves. These PPE requirements will also apply to personnel working on the landfill

gas extraction project with the addition of safety glasses. A field gas analyser, gloves, boots and

safety glasses are required during the sampling of the wells.

5.7 Project Schedule

The following project schedule is proposed for the landfill gas to electricity system at the SLS:

• Basic assessment and waste management licence: Feb 2010 – Oct 2010

• Construction: June 2011 – Sept 2011

• Flare operation: Sept 2011 onwards

• Gas engine and generator operation: Dec 2011?

5.8 Decommissioning

Although Valley 2 at the SLS is anticipated to reach capacity in ~ 2020, the site will continue to

produce LFG for sometime beyond the cessation of active waste disposal. The period for which

the landfill gas to electricity system can continue to operate will depend on the volume and

quantity of landfill gas being produced, but may be 20 to 30 years after closure of the site.

Once the volume of gas drops below volumes suitable for the production of electricity, the engine

and generator will be decommissioned and removed from site. The flare will continue to operate

for as long as the sufficient volumes of gas are produced. Once gas production has tailed off the

entire system will be decommissioned and all components removed.

5.9 Project Alternatives

5.9.1 Use of Alternative Technologies

Passive extraction systems with carbonated filters are used at landfill sites to remove landfill gas

and extract some of the odour and health risk components. Such systems are only suited to sites

with very low emissions and do not combust landfill gas. They only remove a limited suite of the

gases, do not reduce the emission of green house gases or result in the production of energy.



The active collection and combustion of landfill gas is a practise that is used internationally to

manage LFG. Gas extraction wells, enclosed flares and gas engines are the preferred

technologies. Ener-G Systems have access to the best available technology and will make use of

specific components most suited to the SLS. This not only ensures the most effective capture and

conversion of the landfill gas to electricity, but also the best economic returns for the operator. As

the operator has selected the most appropriate technology, other technologies were not

considered viable and were not assessed for the project.

5.9.2 Alternative Designs for the Landfill Gas Extraction System

5.9.2.1 Vertical Wells versus Horizontal Collectors

Valley 1 has been developed to final height and all waste is in situ. The choice of the gas

extraction system is limited to vertical wells, because this is the only feasible method of

constructing gas extracting wells in situ waste bodies.

Horizontal collectors may be preferred for areas of Valley 2 where waste is still being deposited,

as this permits earlier recovery of the landfill gas generated. Early access to the gas is an

important consideration of landfill gas extraction in order to maximise the capture of gas.

5.9.2.2 Position of the Wells

The final positioning of the wells and collectors is dependent on the character, size and depth of

the waste body to ensure optimised gas extraction from the waste body. The layout as depicted in

Figure 4 has been selected as optimal for the SLS.

5.9.2.3 Location of the System Components

The proposed landfill gas to electricity project falls entirely within the permitted footprint of the

SLS. The SLS is designated for waste disposal and related activities and is thus an appropriate

location for the landfill gas project. The landfill gas to electricity facility would not be appropriate

outside of the SLS.

The wells, pipelined and combustion facility have been located within the infrastructure zone of

the SLS. No other appropriate sites have been identified within the SLS as space is limited. In this

location the system will interference with current or future waste disposal operations and will be

less.



5.9.2.4 Flares vs Gas Engine

Both flaring and gas engines are proposed at the SLS. In both cases Ener-G Systems will source

the key components from partners with significant expertise in the field of LFG extraction and

combustion. These components were chosen as those most suitable to the conditions at the SLS.

Although the operational parameters of the two systems do vary in certain aspects, the overall

performance of the systems is very similar. In both systems the gas will be combusted at high

temperatures and the system components will be managed to ensure the maximum efficiency of

combustion.

5.9.3 No Go Alternative

The no-go option entails the continued operation of the SLS without LFG extraction. The no-go

option is feasible in South Africa since applicable regulations, permit conditions and current

emission levels do not mandate gas extraction and flaring. Under the no-go development option

and in the absence of the proposed project:

• The emission of landfill gas into the atmosphere will continue unmitigated, without reduction

of gases with global warming and ozone depleting potential;

• Potential health risks and odour nuisance from the emissions will not be reduced;

• Larger health-risk and odour management buffer zones may be required at the SLS:

• A potential alternative energy source would be irreversibly lost;

• No additional economic benefits will be derived from the landfill gas.



6. BRIEF DESCRIPTION OF THE AFFECTED ENVIRONMENT

The bulk of the following information has been taken from the Environmental Impact Control

Report prepared for the Shongweni Landfill Site in March 2009. Only those sections relevant to

the consideration of a landfill gas extraction and electricity generation system have been

presented.

6.1 Land Ownership, Zoning and Land Use

EnviroServ own portions 36 and 37 of the farm Remainder of Kirkfalls 14227 on which the SLS is

located Portion 36 is zoned for the disposal of waste. The adjacent portion of land is zoned as a

buffer zone. The main purpose of the SLS is the disposal of general and hazardous waste. Areas

within the SLS property that are not actively used for the disposal of waste or for support activities

are either let to THG for agricultural purposes or are unused.

6.1.1 Shongweni Buffer Zone

The permit for SLS requires the creation and maintenance of a buffer zone around the site. The

recently approved EICR (2009) for the site recommended that the extent of the buffer zone be

altered. The extent of the buffer zone was determined from modelled air quality and health

impacts and extends (see Figure 2):

• 500 m from the north;

• 500 m to the south;

• 850 m to the east; and

• 450 m to the west.

The zoning of the site and the maintenance of the buffer zone places a restriction on the land use

of the surrounding properties. No residential or light industrial land uses may take place within the

buffer zone. The permit does allow for the establishment of heavy industries, or industries which

may themselves create nuisance conditions within the buffer zone. The only land use currently

occurring within the buffer zone is agriculture (sugar cane) and the remaining land comprises

natural vegetation and is unutilised.

EnviroServ investigates all land sales and re-zoning applications and challenges those that would

affect the buffer zone. The SLS permit requires that the air dispersion model be reviewed and the

adequacy of the buffer zone assessed if the site operations change in a manner that may

influence the buffer.



6.1.2 Surrounding Land

The properties surrounding the EnviroServ SLS property, some of which fall within the buffer

zone, are privately owned. These properties are zoned agricultural or have an undetermined land

use (see Table 2).

Table 4: Ownership of Properties surrounding the SLS Farm Portion Zoning Owner Title Deed

Kirkfalls 8 Agricultural 3 Current Owner: TOMER INV 50CC.

Previously owned by Tongaat Hulett

Group

T264/2004

Kirkfalls 22 Private Open

Space

Natal Racing Properties PTY (Ltd) T13909/1992

Kirkfalls 16 Private Open

Space

Natal Racing Properties PTY (Ltd) T13909/1992

Land use in the region generally comprises sugarcane farming on the plateau areas and less

steep land and natural coastal forest (or alien invasive vegetation) and grassland on the steeper

slopes and valley head areas (see Figure 2). Potentially sensitive receptors located within 2 km of

the site include (See Figure 1):

• the Braeside farm labour compound (1.3 km northwest of the site);

• the Kwalinda and KwaNdengenzi rural settlements (> 1.5 km south of the site)

• Salem (Damini) rural settlement (> 1.5 km south west of the site);

• the Tongaat Mushroom Farm (1 km north of the site);

• the Clifton Country House B&B (1 km north east of the site); and

• the Deville Wood railway station (1.1 km southwest of the site).

The SLS is 2.5 km south east of the Summerveld suburb and racing establishment, 3.6 km south

west of the Plantations development, 5.5 km south of the centre of Hillcrest and ~6 km southeast

of the town of Hammersdale, Kwazulu-Natal,. The Shongweni Dam is located 3.5 km south west

of the SLS and is currently used mainly for recreational purposes and is managed as a

conservation area by Msinsi Resorts and Holdings. Access to the Shongweni Dam is on the road

past the SLS.



6.2 Topography

The topography of the Shongweni area comprises numerous steeply incised valleys divided by

narrow ridges. The SLS is situated on the eastern edge of the Shongweni-Kloof escarpment, at

an elevation of between 450 and ~ 540 metres above mean sea level. The slopes in the area are

steep and gradients vary between 10 and 40º.

The SLS lies close to the divide between the Mlazi and Mhlatuzana River Valleys. These valleys

form the major topographical features of the area and are orientated in a north-west - south east

direction. The topography to the east of the site is characterised by steeply undulating terrain,

with mildly undulating terrain occurring to the west of the site along the north-south trending spur

just west of the Shongweni Dam road. The SLS site consists of a number of steep-sided valleys

which are separated by narrow ridges. These valleys drain eastwards to a larger north south

trending valley.

6.3 Climate

The site falls within the summer rainfall area of South Africa and is characterised by heavy

summer rainfall and warm temperatures. Climate conditions are typical of coastal regions with

elevated humidity levels and moderated temperatures. Drought and night frost are less common

than in other areas of South Africa.

Rainfall data were sourced from the South African Weather Bureau Station located at Durban

International Airport and on-site measurements. The mean annual precipitation is ~ 786 mm and

the mean annual A-pan evaporation is approximately ~ 2200 mm. Rainfall occurs in high-intensity

events that are largely confined to the summer months. The average daily maximum temperature

for the area is approximately 32°C in midsummer and 22°C in midwinter. The average daily

minimum temperature for the area is 10°C in midsummer and 3°C in midwinter.

Wind patterns in the area are complicated and influenced by coastal and frontal winds on a

macro-scale and valley and slope winds on a site-scale. Wind patterns in the area are

complicated by the deeply incised valleys and steep topography. Wind data has been sourced

from the MM5 database (see Figures in Appendix 8). Winds in spring and summer are distributed

between south westerly and north easterlies with the strongest winds coming from the south.

During the winter months there is an increase in the frequency of westerly and north westerly

winds although the strongest intensity winds remain from the south. On-site wind recording has

taken place over the last 2 years but the data is not reliable.



6.3.1 Gaseous emissions

The decomposition, under anaerobic conditions, of waste disposed to landfill results in the

production of landfill gas (LFG). LFG is typically composed of CH4, CO2, H2S, N2, O2, water

vapour and numerous trace gases. The exact composition of the LFG is dependant on the waste

type and combination, moisture content, temperature and other environmental variables. LFG

production is known to continue for as long as 20 years after waste disposal ceases. The LFG is

emitted from the landfill to the atmosphere.

LFG, and in particular methane, are known green house gases (GHG) and contribute in a

significant manner to global warming. Certain of the other gases in LFG may contribute to air

pollution through the formation of low level smog. The various compounds in LFG may also result

in odours as well as health risks, both at the site and at remote receptors. Currently the SLS is

emitting LFG to the atmosphere. The quantity and quality of LFG being emitted from the SLS is

discussed under Air Quality.

6.4 Ecology and Biodiversity

6.4.1 Vegetation and Habitat Status

The vegetation of the region has largely been mapped as Eastern Valley Bushveld with patches

of Scarp Forest and KwaZulu-Natal Sandstone Sourveld (Mucina and Rutherford, 2006) and

comprises areas of bushveld and grassland, with small forest patches in the deeply incised

valleys. Areas west and north of the SLS, up to Summerveld and the N3 highway consist entirely

of sugar cane fields. The areas to the south and east of the site consist of indigenous coastal

bush interspersed with grassland on the flatter areas.

The greater portion of the SLS property has been disturbed and transformed, either by

agriculture, alien invasive species or as part of the waste disposal operations. The majority of

vegetation patches and open spaces are generally highly disturbed; show a high level of habitat

transformation, with low species diversity and a large number of non-indigenous species. The

areas are extensively invaded by exotic invasive species such as Bluegum, Black Wattle,

Syringa, Chromalaena, Lantana and Bugweed. Given the disturbed state and the low species

diversity of all the majority of the vegetation units comprising the surrounding areas, the

possibility of encountering red data species in the area is considered low.



6.4.2 Animal Life

The natural vegetation of the area, even in its disturbed state, hosts populations of species such

as Vervet Monkey, Grey Duiker, Slender Mongoose and Rock Dassie. Other nocturnal species

such as Large-spotted Genet, Porcupine and Bushpig are also likely to occur in the area. All of

these species are reasonably common in the region and are not considered to be of conservation

concern. Bird species recorded on the site include species typical of the local Scarp Forest and

bush patches.

Other than species expected in the indigenous bush (described above) and the problem species

associated with the operation of a waste disposal facility (i.e. rodents, flies, domestic cats and

Sacred Ibis), EnviroServ site personnel have not reported sightings of any animals of

conservation importance. The potential of the site or surrounding areas to harbour red data

species of conservation importance is extremely low as a result of the disturbed, fragmented and

secondary nature of habitats in surrounding areas. The area should thus be regarded as of low

conservation importance.

6.5 Hydrology

6.5.1 Catchment

The SLS is situated within quaternary catchment U60D, just south of the water divide with the

U60F catchment. The area drains southwards via an un-named tributary to the Mgoshongweni

River and then to the Mlazi River, some 3.3 km to the south-east. There are no major rivers or

natural dams on the site. Each of the valleys on the SLS forms the head of a small tributary that

drain to the east. The Shongweni Dam is the most significant surface water resource in the region

although it is located upstream of the SLS.

6.5.2 Water Use and Management

The SLS has water management systems designed in accordance with the parameters as

specified in the Minimum Requirements for waste disposal facilities. The design features include,

inter alia, the provision of a storm water management system to keep clean and contaminated

water separated and the containment of contaminated water on site. Dirty water captured on the

SLS is stored in a storm water dam and is pumped into the leachate tank and treated with the

leachate. It is estimated that 8330 m3 of storm water is retained on the site per annum.

Surface water monitoring at the SLS is undertaken at a number of on-site and off-site locations

and is conducted in terms of the monitoring protocol (J&W 2008).



6.5.3 Water Quality

Background surface water qualities at the SLS are characterised by low electrical conductivity

values of between 25 and 35 mS/m, elevated sodium and chlorine concentrations of 29 mg/l and

56 mg/l are present. Monitoring at most the surface points (with water) returned electrical

conductivity values of between 28 mS/m and 57 mS/m, with no constituents exceeding the DWAF

screening guidelines. No organic constituents were detected in any of the surface water samples.

Downstream surface water quality at the SLS continues to improve and the electrical conductivity

value at point SW5 has halved since 2006. It is likely that this improvement is due to the

improvement in the capturing and pumping system of the sub-soil seepage from Cell 1, 2 and 3

and the storm water dam (ie. implementation of the Green tank System). The current impact of

the SLS on surface water qualities in the downstream catchment is negligible.

The SLS storm water dam, which contains contaminated water, was found to have an elevated

electrical conductivity value (614 mS/m) with high concentrations of ammonia, chlorine, fluoride,

sodium, potassium, magnesium and manganese. Low concentrations of benzene, chlorobenzene

and xylene were detected in the storm water dam. This water is treated as leachate and is used

to dilute leachate prior to its disposal to sewer.

Bio-monitoring of the Mgoshongweni stream upstream of and below the site was last undertaken

by GroundTruth in April 2010. The results, from both monitoring positions, showed the presence

of invertebrate families that have a very low tolerance to pollution indicating the good health of the

stream. Negligible differences were detected between the upstream and downstream sites,

indicating that currently the SLS appears to be having no negative impact on the surrounding

water sources.



6.6 Geohydrology

6.6.1 Groundwater Level, Gradient and Flow

Groundwater flow is generally towards the south and south east, at an average angle of 10%.

Flow direction was established with the aid of a conceptual groundwater model, followed by

particle tracking to trace groundwater flow lines. There is a difference of 300 m in water levels

across the SLS as a result of the steep topography of the site. The hydraulic conductivity in the

aquifer is estimated as 0.55 m/day and the porosity of the aquifer material is estimated at 15%.

Groundwater velocity was thus predicted to average 0.37 m/day or 133.8 m per annum.

Groundwater flow rates are relatively high due to the steep groundwater gradient and higher rates

may be expected on a localised basis in individual fractures. Due to the steep slopes,

groundwater converges into the surface water within a short distance of the site.

6.6.2 Characterisation of the Aquifers

Two aquifer types are generally present in the geological terrain of the SLS. The first is a shallow,

weathered aquifer, which is classified as phreatic or unconfined. The second is a deeper

fractured aquifer that in this case is classified as confined. Based on drilling cores the aquifer

underlying the SLS appears to be a confined, fractured aquifer. Groundwater flow occurs mainly

through the faults and fractures although seepage does occur at the weathered formations. The

geology of the SLS varies considerably across the site; some boreholes are drilled into granite

and others drilled into sandstone, but intersecting granite at depth.

6.6.3 Groundwater use and management

Groundwater is extracted from borehole BH9 for general use but not for drinking water use. The

volumes extracted from the borehole are metered. Drinking water is imported to the SLS. No

other groundwater is used at the SLS and there are no known groundwater users downstream of

the SLS. The THG mushroom farm extracts water from boreholes upstream of the SLS.

The waste cells of Valley 1 are lined and are equipped with leachate detection layers and sub-soil

seepage collectors. Leachate from the leachate detection system is captured in the leachate

dam. Water in the sub-soil seepage system is captured within the Green Tank on the downstream

side of the storm water dam. Similarly, all weathered aquifer water is captured in the leakage

detection system of the storm water dam, which is also captured in the Green Tank. This water is

pumped to the storm water dam. The leachate and water in the storm water dam is pumped to

the Leachate tank prior to disposal to sewer.



The groundwater monitoring network at the SLS comprises a number of boreholes as well as

sampling and detection points. Groundwater, leachate, sub-soil seepage and leachate/leakage

detection points are monitored. Groundwater monitoring at the SLS is conducted in terms of the

monitoring protocol (J&W 2008). Due to the steep slopes, groundwater converges into the

surface water within a short distance of the site and the impact of the SLS on the downstream

catchment is therefore best observed in the surface water quality.

6.6.4 Groundwater Quality

6.6.4.1 Boreholes

The background groundwater quality at the SLS is generally very good with the electrical

conductivity values within all upstream boreholes not exceeding 30 mS/m. Electrical conductivity

values in these boreholes have remained relatively constant over the last 4 years. The only

inorganic constituents found to exceed the screening guidelines were iron in borehole BH6 and

fluoride in boreholes BH6 and BH11. Both of these constituents would be derived from the

underlying geology.

The borehole pair BH05 12S / BH05 12D was drilled between the storm water dam and the waste

body. The weathered aquifer borehole BH05 12S has an elevated electrical conductivity value of

278 mS/m, which has decreased over the last 2 years. The ammonia, fluoride, iron and

manganese concentrations were found to exceed the screening guidelines in the weathered

aquifer. The fractured aquifer borehole BH05 12D also has an elevated electrical conductivity

value of 116 mS/m, with fluoride being the only constituent to exceed the screening guideline.

The electrical conductivity value of borehole BH05 12D has also decreased from a high of

186mS/m over the monitoring period. The majority of these constituents would be derived from

the underlying geology. This water is collected in the sub-soil seepage system on the

downstream side of the storm water dam, from where it is pumped up to the storm water dam.

The borehole pair BH05 10S / BH05 10D is located 350 m downstream of the landfill site.

Electrical conductivity values of 57 mS/m in the fractured aquifer and 46 mS/m in the weathered

aquifer were recorded. These values are slightly higher than the upstream background levels.

The only constituent found to exceed the insignificant risk guideline within these boreholes was

fluoride in the fractured aquifer, and this has most likely originated from the underlying geology.

No organic constituents were detected in either borehole BH6 or BH9 while the other upstream

boreholes had low concentrations of tetrachlorethene or trichlorethene. Downstream boreholes

presented similar results with no organic constituents in borehole BH05-12s while low

concentrations of tetrachlorethene or trichlorethene were recorded in the other boreholes.



6.6.4.2 Leachate, Sub-soil Seepage and Leachate/Leakage Detection

Leachate that drains from the Cells in Valley 1 collects in the leachate tank. The leachate is

characterised by high electrical conductivity (2291 mS/m) as a result of elevated concentrations

of bicarbonate, ammonia, chloride, fluoride, sodium, potassium, magnesium, arsenic, iron and

manganese. A number of organic constituents were detected within the leachate in July 2008

with the ethyl benzene, xylene and 1,2,4-trimethylbenzene concentrations found to exceed the

screening guidelines.

Leachate is detected beneath the primary liner at the site. The electrical conductivity and oxygen

demand values at the monitoring positions are elevated, up to two orders of magnitude higher

than the background groundwater quality. Electrical conductivity values varied between 1574

mS/m and 3580 mS/m. Sampling at the leachate / leakage monitoring points detected flow rates

of between 0 and 0.025 litres / second. Positions 5 LD3P, 6 SLSD3, 7 SLSD4 and 14, 15 and 16

were dry over the sampling period.

A portion of the leachate at the SLS does, however, move through the leachate detection system

and into the sub-soil seepage system. This can be seen by the elevated electrical conductivity

values within the sub-soil seepage system, although these are lower than those detected in the

leachate detection system. Sub-soil seepage sampling at point 17 recorded water characterised

by an elevated electrical conductivity value (701 mS/m). The ammonia, chloride, fluoride, sodium

and cyanide concentrations exceed the screening guidelines. Sampling at point 9 GW123 found

elevated electrical conductivity values over the monitoring period, with the current value being

538 mS/m. The ammonia, chloride, fluoride, sodium, magnesium and manganese concentrations

exceed the screening guidelines. A number of organic constituents were detected within the sub-

soil seepage points, although only the 1,2,4-trimethylbenzene concentration was found to exceed

the screening guideline in July 2008.

Similarly, the weathered aquifer immediately downstream of the waste disposal operations has an

elevated electrical conductivity value. These values are, however, again lower than those

recorded in the sub-soil seepage system. Thus the current impact of the SLS on groundwater

quality is negligible.



6.7 Air Quality

General air quality in the Shongweni area is known to be reasonable, although there are

occasional instances when strong, chemical odours are reported by residents of adjacent suburbs

and from suburbs further afield. The unique topography and weather patterns of the Shongweni

area make it difficult to pinpoint the source of any odour. Residents in the area have reported

various conditions and health impacts that they ascribe to the odours and chemical pollutants.

These include itching and streaming eyes, coughing, sinus problems and breathing difficulties.

Similar problems have also been cited in animals within the area.

Local pollution sources include the Shongweni Landfill Site, various chemical and industrial sites,

vehicle traffic, sewerage facilities, the combustion of household fuels and the combustion of

agricultural products. Local agricultural lands are sources of dust emissions. Landfill sites are

known sources of air pollutants and odours and are characterised by two main types of air quality

pollutants, viz. gaseous emissions and fugitive dust emissions. Gaseous emissions from the SLS

emanate from the working face of the landfill, the covered portions of the landfill body and other

sources such as the leachate dams. Landfill gas is comprised largely of carbon dioxide and

methane with as many as 200 other trace gases comprising the balance. It is this subset of the

other gases that create odours and health risks. Sources of fugitive dust emissions include

vehicle entrained dust from paved and unpaved roads; materials handling operations such as

waste compaction and tipping operations; wind erosion of open areas and soil cover and

earthmoving activities.

6.7.1 Landfill Gas Composition

LFG composition at the SLS is sampled quarterly at the sub-surface gas probes by Margot Saner

& Associates. Only the bulk gases including methane, carbon dioxide, oxygen and hydrogen

sulphide are analysed. Although some of the concentrations do exceed the DWAF guidelines

(largely from those probes within the landfill) the low flow rates and site topography are likely to

prohibit off-site sub-surface gas migration.

During this assessment two LFG samples were taken from the SLS and subjected to a detailed

analysis of both the bulk and trace gas components. The analysis was undertaken by the

accredited laboratory of the Waste Recycling Group in the UK. The analysis indicated a very high

(> 68%) methane concentration and variable concentrations of substances such as hydrogen

sulphide, sulphur and chlorine. Of the trace gas components Toluene, Dichloroethene, Vinyl

Chloride, Methanethiol, isoPentane, Pentane, Xylene and Ethylbenzene were recorded in

significant concentrations. The results of the analysis are provided in the Air Quality Assessment

(Appendix 8).



6.7.2 Air Quality

Margot Saner & Associates conduct quarterly monitoring at the SLS as part of the Air Pathway

Analysis System. The results are used for the health and odour risk assessment through

comparison with relevant guidelines and exposure limits.

On-site Ambient Monitoring

On-site monitoring is conducted at two monitoring stations. Results from the on-site sampling of

ambient air concentrations showed that hydrogen sulphide levels were well below the UK

Environmental Assessment Levels (EAL) for all sampling periods. H2S levels at the leachate dam

were higher than the levels at Gate 3 and were in excess of the odour thresholds for four of the

five sampling periods. The H2S levels at the site have reduced over last two years. The covering

of the leachate weir and the installation of whirlybirds with activated carbon filters impregnated

with potassium permanganate appears to have been effective in ensuring adequate control of

hydrogen sulphide emissions within the vicinity of the leachate tank.

Ammonia levels were well below the UK EALs at both sampling locations for all periods.

Recorded concentrations for NMOC were below the UK EALs for the first two sampling periods.

Elevated Benzene concentrations were detected in the third sampling period and in the fourth

period this exceeded the UK EALs at the leachate dam. In the fifth period these levels had

subsequently dropped below the thresholds. Sampling of the Aldehyde yielded elevated results,

in excess of the UK EALs, for the Formaldehyde, Acrolein and Butyraldehyde compounds during

the first sampling period. The concentrations were significantly lower in the subsequent two

sampling periods with no individual compound exceeding the thresholds. The Formaldehyde and

Butyraldehyde concentrations were again elevated in the final two sampling periods and were

above the UK EALs. The monitoring results support the view that the Aldehyde concentrations

are seasonal in nature and become elevated during the winter periods with increased veld and

cane fires in the region.

The recorded PM10 levels ranged between 9 and 17 µg/m3 and were, without exception, well

below both the DEAT Annual Limit for PM10 (60 µg/m3) and the proposed ambient air quality

standard of 50 µg/m3 (SANS 1929:2005).

Off-Site Monitoring



Result from the off-site ambient air sampling, at the various local residences, showed that all of

the monitored compounds, with the exception of the Aldehyde group, were below the relevant UK

EALs and the odour thresholds. The measured Aldehyde concentrations related to elevated

concentrations of Formaldehyde and Butyraldehyde. These levels mirrored the results obtained at

the on-site stations and support the premise that seasonal veld-fires and cane burning are the

most likely source of the elevated Aldehyde concentrations, rather than on-site activities.

Predicted Air Quality

Emissions and air quality impacts associated with Valley 1 and Valley 2 operations at Shongweni

were addressed extensively in the air quality impact assessment for Valley 2 operations (Airshed,

2008). The study concluded that emissions from the SLS presented no significant health risks to

any off-site receptors and that compliance with all emissions related legislation and guidelines

could be achieved at the buffer zone.

6.8 Heritage Resources

According to Heritage KwaZulu-Natal (Amafa) the entire footprint of the SLS was checked for

heritage artefacts during the initial permit application. No sites or artefacts of heritage value were

discovered.

6.9 Noise

Current ambient noise sources in the area include:

• On-site noise from waste disposal operations:

• Traffic on the N3 highway,

• General localised traffic,

• Agricultural activities.

The various residential suburbs in the area represent noise sensitive receptors. However, these

areas are generally located at least 1.5 km away from the SLS. Noise impacts are generally

correlated with distance and line of sight. With the rugged terrain of the area there is generally no

line of site from receptors to the SLS. Noise from the SLS does not generally affect receptors

and no noise complaints have been lodged.



6.10 Socio-Economics

The SLS falls within Ward 10 of the eThekweni Metropolitan Municipality. The majority of the

ward and residents thereof, are located to the north of the N3 freeway and includes the suburbs

of Hillcrest, Gillits and Kloof. The ward is largely comprised of higher income suburbs and

residents have good access to municipal services such as electricity, water, sewage and refuse

removal. The area around the SLS is comprised of wards 7, 12 and 13. These wards generally

comprise a much higher percentage of low-incomer residents. The area has approximately 31

000 residents (Census 2001) of which the great majority are Zulu speaking Africans. The ward

has nearly 15 000 economically active persons, but only half, approximately 51%, are employed.

EnviroServ currently employs 26 people at the SLS.

The immediate surrounds of the SLS are characterised by extensive agriculture with a number of

isolated agricultural holdings and businesses. Residential suburbs are variously distributed within

a 5 km radius of the site (see Section 4.1.3). Communities living near a waste disposal facility

often complain about visual eyesores, dust, pests (i.e. flies), odours, and heath problems due to

the emissions emanating from waste disposal facilities.

6.10.1 Odour Complaints Register

The public complaints log for the SLS has been active since February 2000. Complaints are

generally logged as a result of odours. These include strong sulphur smells, chemical smells and

smoke. It is considered that the trenching and disposal activities and exposed leachate are the

primary sources of odour emissions at the SLS. Other complaints relate to spillages of waste on

the roads, illegal dumping, dust and scavengers. The frequency of complaints received at the

SLS has been decreasing over the last 3 years with 121 complaints logged in 2006, 75

complaints logged in 2007 and only 25 complaints logged in 2008.

While it is possible that the reduction in complaints is as a result of public frustration or apathy it is

also plausible that improved management and operations practices at the SLS are resulting in

fewer issues.



6.10.2 Monitoring Committee Issues

The SLMC meets regularly to discuss issues and concerns surrounding the SLS. Over the course

of the last 10 years numerous issues have been brought to the attention of the SLMC. Local

residents, elected community representatives and NGOs have raised concerns over the operation

of the SLS and have at times demanded the closure of the site. Issues such as poor management

practices, environmental degradation, odours and serious health concerns have come to the fore.

Over the last few years the issues and concerns raised at meetings of the SLMC include :

• Lack of proper management or poor management of the site including:

• Failure to cover the working face on a daily basis;

• Extensive wind scatter of litter;

• Scavengers on the site;

• Spillages and wind scatter of waste from trucks;

• Vehicle accidents resulting in hazardous spillages

• Odour complaints from residents in following suburbs:

• Shongweni;

• Kwandengezi;

• Summerveld;

• Alverston;

• Assegay;

• Hillcrest; and

• Plantations.

• Gaseous emissions resulting in human and animal health problems in the surrounding

suburbs;

• Water pollution of downstream resources; and

• Death of cattle from health impacts.

These issue and concerns indicate strong opposition from various sectors of the surrounding

communities to the continued operation of the SLS. Copies of minutes from all of the SLMC

meetings are held by Pravin Amar Development Planners.

Issues and concerns raised during consultation for the landfill gas to electricity project are

discussed in Section 7 of this report. Comments from IAPs are provided in Appendix 7.



6.11 Health and Safety

Modern landfills are very complex systems where various chemical and biological processes

occur simultaneously. These processes, including bacterial decomposition, volatilization and

chemical reactions act on the waste substances to produce liquids, gases and other chemical

compounds known to have environmental and health risks. The composition, rate and volume of

chemical and gas production depends on landfill characteristics such as waste composition, the

age of the refuge, the presence of oxygen in the waste, the moisture content of the waste and

temperature. Particulate emissions from waste disposal operations are also commonly associated

with landfill sites. Levels and concentrations of potentially hazardous substances are generally

highest at the source (ie within the waste body) and decrease with distance from the source.

There are numerous factors that affect the dispersion of pollutants from the source including the

local topography and weather conditions.

Emissions (including gases, particles and liquids) from landfills create potential health risks and/or

nuisance conditions. Nuisance conditions, while not pleasant, do not pose risks with the same

severity as potential health risks. It is possible the same pollutant pose nuisance as well as health

impacts, however the pollutant would be present in concentrations that vary by orders of

magnitude. Health risks and nuisance factors must therefore be considered separately.

Various on-site occupational and off-site ambient guidelines and standards have been developed

to regulate acceptable chemical, gaseous and particulate emissions limits from landfill sites.

These guidelines are based on extensive research and medical evidence to determine the levels

at which effects are recorded. Only if these guidelines or standards are exceeded is a health risk

anticipated. In many cases South Africa does not have suitable guidelines and applicable

international standards are adopted. The guidelines and standards that have been set both

internationally and in South Africa are generally very conservative.

6.11.1 Occupational Health

Employees at the SLS are potentially exposed to both general and hazardous wastes and the

associated health risk substances. Exposure levels are recorded and compared to standards that

have been set that govern the acceptable limits for occupational exposures to health risk

compounds.



Monitored on-site non-cancer health risks were in excess of the National Exposure Limits during

all but one sampling period, largely as a result of the elevated Aldehyde concentrations. These

elevated Aldehyde concentrations are likely to be related to an increase in the incidence of off-

site cane and/or veld fires during the winter periods, rather than on-site activities. Despite the

exceedances, the qualitative descriptor for the on-site health risk is between minimal and low.

The on-site cancer health risk, from elevated Benzene (confirmed human carcinogen) levels, was

low during all but one of the sampling periods when it was described as moderate. The on-site

cancer health risk from the Formaldehyde (suspected human carcinogen) levels was low during

all sampling periods.

Occupational exposure air sampling is conducted on the employees at the SLS twice per annum.

The sampling conducted includes VOC, semi-VOC, ammonia, aldehydes, hydrogen sulphide,

total inhalable particulate matter, PM10 and heavy metals, nickel, cadmium, lead, chromium.

Asbestos sampling is also conducted on the employees. Medical surveillance of employees is

also undertaken on a regular basis by a doctor and an on-site nurse is available to address health

concerns. The surveys and surveillance have showed minimal exposure levels, well below

accepted standards, and thus no health effects on employees are being predicted.

6.11.2 Public Nuisance and Health

6.11.2.1 Dust

Landfilling activities, vehicle movement and wind erosion are potential dust sources at the SLS.

The total dust generated at a site may result in a nuisance impact while the finer (PM10) fraction

poses a health risk. On-site measurements of PM10 levels at Valley 1 have not recorded

concentrations above the SA ambient standards. The air quality model for Valley 2 predicted that

highest daily average on-site PM10 concentrations could be expected above the SA standard of

75 µg/m3, but that the annual average on-site PM10 concentrations would be below the SA

standard. This indicates that extreme site and weather conditions may result in occasional dust

levels above the standards, but that overall dust standards are not expected to be of significance.

Any expected exceedance of the PM10 standards would be confined to just beyond the site

boundary and within the SLS buffer zone. Thus no significant dust (nuisance or health) impacts

are anticipated.

6.11.2.2 Health Risk

Health risks from gaseous emissions are the most pressing public concern relating to the disposal

of waste at the SLS. Many sectors of the public feel very strongly about the presence of a

hazardous landfill site in the Shongweni area and have argued for the closure of the SLS on the

basis of health impacts. Complaints such as itchy eyes, sore throats, chronic coughing,



headaches and irritability have been recorded by residents in the suburbs surrounding the SLS.

These conditions are thought by some residents to be due to emissions from the SLS.

However, continuous monitoring of ambient airborne contaminant compounds that has been

undertaken on-site at the SLS and at various discreet receptors for the past 9 years (APAS

Reports by Margot Saner & Associates), has not recorded elevated levels of any compounds or

chemicals that can be attributed to the SLS. The concentrations of health risk compounds, for

both non-carcinogenic and carcinogenic risks, are in fact orders of magnitude lower than any of

the pollutant-specific risk factors and are not considered significant.

Based on this scientific evidence the health risks associated with the SLS are considered very

low to minimal. Occasional visits by medical staff to clinics and hospitals have also not found any

evidence of health concerns that can be attributed to the SLS. No health concerns, substantiated

by a medical doctor, have been reported to EnviroServ or their medical staff. Based on the

scientific and medical evidence at hand the impact on human health is considered to be low.

The air quality impact assessment considered the development of Valley 2 with the covering of all

leachate bodies and the extraction of LFG as mitigation scenarios. The impact assessment, with

the addition of Valley 2 at the SLS, reported that no exceedances of the health risk thresholds

were predicted for any of the pollutants and thus no non-carcinogenic health risks are anticipated.

The on-site cancer risk for all carcinogenic substances was a maximum of 1:162 000 (low risk) in

the mitigated scenario. The cancer risk at all of the discreet receptors was less than 1: 1000 000

for all scenarios. These levels are considered as a low to very low health risk. The development

of Valley 2 was not anticipated to increase the risk category of the health impact zone at the SLS.

The model did recommend that the extent of the health impact zone (defined by predicted

exceedances of the daily average SA PM10 standards and the US-EPA chronic inhalation

reference for hydrogen sulphide) be enlarged from the current buffer zone. Based on a

combination of the exceedance areas for these health risk substances, the extent of the buffer

zone, as measured from the footprint of Valley 2, were projected as follows: ~500 m to the north

and south, ~450 m west and ~850 m to the east (Figure 2).

6.11.2.3 Odour

Regular complaints regarding odour have been reported from most of the suburbs within 3 km of

the SLS. Odours are reported more frequently from the suburbs to the north and north-east of

the SLS with very few comments received from areas to the south. The odour complaints have

been variously described as chemical, acrid, smoke, glue, toxic and dangerous, unpleasant and

sulphur based. The sulphur smell is the most common complaint. The odours are generally



thought to emanate from the SLS and have occurred under various wind conditions (up-wind,

down-wind and still). On-site monitoring of gases has occasionally recorded elevated levels,

particularly H2S, near potential sources. The leachate weir, the leachate tanks, leachate day-

lighting on surface and waste exposed during landfilling operations have been identified as

potential sources. The odour nuisance impact is considered of high significance as the concern is

great enough for members of the public to register complaints. Management and operational

changes have been made at the SLS to address the release of odours. The number of odour

complaints has however declined somewhat over the last few years. This is attributed to the

improved operational measures implemented at the SLS and indicates that progress has been

made in the management of odours, but some odours do still occur.

The addition of Valley 2 at the SLS will increase the volume of waste and the potential for LFG

generation. Odour threshold exceedances, for maximum operations in 2019, were predicted to

occur due to on-site concentrations of ethanetiol (ethyl mercaptan), hydrogen sulphide and

methanetiol (methyl mercaptan). The maximum odour threshold exceedance was associated with

hydrogen sulphide concentrations. The exceedance of the 2 OU/m3 threshold level (acceptable

for areas with more than 2000 residents) for hydrogen sulphide was predicted for a distance of

less than 1 km from the site boundary. The air quality impact assessment considered the

development of Valley 2 with the covering of all leachate bodies and the extraction of LFG as

mitigation scenarios. Modeling predicted that the odour impact zone at the SLS should reduce in

size, provided that LFG extraction is implemented.



7. RESULTS OF PUBLIC CONSULTATION

7.1 Collation of Issues and Concerns

Issues and concerns relating to the landfill gas to electricity project at the SLS have been

captured by means of:

• Minutes from the special SLMC meeting (Appendix 1); and

• Responses received following public notification of the project (Appendix 7).

7.2 Synthesis of Issues Raised`

IAP Question or Comment Project Response

Please send us a complete quantitative chemical analysis

of the gas, particularly the portion usually referred to as

“other” which will be extracted and burnt in the flare and

used to fire the engine.

Samples of landfill gas for Shongweni were sent to the UK

for analysis of the trace gases. The results of the analysis

are provided in the Air Quality Assessment.

Will the exhaust gasses by analysed on a regular basis to

determine their composition?

Exhaust gas sampling is difficult and expensive. Samples

of the exhaust gases will be taken 6 months after

commissioning and analysed. Result will be used to fine

tune the operating parameters.

What measures will be taken to eliminate dioxins and

furans in the exhaust?

The flare is designed to ensure efficient combustion. High

temperatures and long retention times are used. During

gas combustion there is little solid matter or metals and

thus dioxin formation will be limited.

The Landfill site area must be securely fenced with visible

appropriate signage.

The landfill site is fenced. The combustion facility will be

located within the SLS and will be fenced and sign posted

separately.

A significant fire break will be required. Precautions will to taken to limit the risk of fire from the

LFG project.

The road access to the site requires improvement. The

verges are overgrown and there is serious risk of an

accident as the waste trucks cannot see around the sharp

corners. The verges should be pulled back significantly

and the road should be widened by approximately 100

metres on either side of the entrance to allow for a glide-

off and improved visibility.

This is beyond the scope of the LFG project but has been

passed to EnviroServ for comment.



Will building plans be submitted for approval? Municipal approval of building plans is required for all built

structures.

How much electricity /Voltage will be generated? Approximately 1.15 MW at 11 000 Volts. Dependent on

gas recovery.

Gas analysis report for Shongweni Samples of landfill gas for Shongweni were sent to the UK

for analysis of the trace gases. The results of the analysis

are provided in the Air Quality Assessment.

Of the more than 133 gases found in landfill sites, 47 are

chlorinated organic compounds. This is thus the potential

for dioxins and furans formation.

Incomplete combustion processes can result in the

formation of dioxins and furans, provided that chlorine

donor compounds are present under certain conditions.

The landfill gas at the SLS does contain some of these

compounds and dioxin formation is possible. Emissions

modelling of the combustion process at the SLS have

indicated that dioxins and furans are unlikely to be formed

in concentrations which will present a health risk to

adjacent receptors.

Who is responsible for the implementation of the EMP EnviroServ, as the licence holder, will be ultimately

responsible for compliance with the authorisation and

environmental management plan. Ener-G systems as the

operator of the landfill gas to electricity project will be

accountable to EnviroServ.

How was the public participation process advertised? Adverts were placed in the Highway Mail, Mercury and

ILanga newspapers. Site notices erected at the site

entrance and on the Shongweni Dam Road. Notification

letters were sent to all members of the SLMC and local

authorities. See Appendix 4.

What did the adverts entail? The adverts indicated the undertaking of a basic

assessment process in support of a waste management

licence and were prepared in accordance with the EIA

Regulations and Guidelines. See Appendix 2.

Are dioxins and furans dangerous?

Do they have an adverse effect on the atmosphere?

Dioxins and furans have been implicated as having a high

human health risk. They are probable human carcinogens

and may also cause severe reproductive and

developmental problems.

Dioxins do exist in the atmosphere, both naturally and

from human sources. Inhalation exposure is generally not

significant (unless exposed to a significant point source).

Most exposure results from food consumption as dioxins



bio-accumulate, particularly in fats.

How easily are they (dioxins) dispersed and how long do

they persist in the atmosphere?

Dispersion in the atmosphere is dependant on local

atmospheric conditions. International studies have shown

that dioxin molecules can disperse widely (ie. Mexico to

Canada). Concentrations tend to be higher in

industrialised areas than in natural areas.

The half-life of dioxin and furan molecules is dependant

on the molecule structure and its location.

Does the SLS produce odours? Landfill sites do produce malodourous compounds, in

particular hydrogen sulphide. The leachate tanks and

drain/weir have been identified as possible sources of

odours at the SLS. Measures have been taken to address

these and prevent odours.

Please make the results of the gas sampling and air

quality assessment available?

See Appendix 8.

It is important to ensure that what is produced from flaring

is not more negative than the existing emissions.

The modelling of emissions from the LFG combustion

facility has considered the health risks of the

uncombusted gases versus those of the combusted

gases. In both cases the health risks to off-site receptors

are minimal, but combustion does reduce the overall

health risk. See Appendix 8.

Will electricity be produced immediately? Phase 1 will only involve flaring. Phase 2, with the

generation of electricity will only be implemented once a

power purchase agreement has been concluded with

Eskom.

Will there be odour generated from the combustion

process?

The majority of malodourous compounds are destroyed

during combustion. The combustion of LFG is anticipated

to reduce potential odours at the SLS

Is the SLS gas of good quality and how long will the gas

last?

Analysis of the LFG from the SLS has shown the gas to

have a very high methane content (>68%) which is good

for the production of energy and emission reductions. The

LFG also has variable concentrations of other compounds

(eg. Toluene, vinyl chloride, hydrogen sulphide, pentane

ethylbenzene) that may effect emissions and performance

of the system.

LFG production will probably continue for about ± 40

years after the closure of the landfill site. Quantities that

are useable in a production situation will be produced for



a shorter period.

What intervention is planned to manage liquids in the

waste cells that may flow to the wells?

If leachate is encountered in the wells it will be managed

in terms of the current SLS operations. If required, the

wells will be fitted with submersible pumps to allow for the

extraction of the leachate.

Tongaat-Hulett: EnviroServ have failed to comply with the

conditions of approval regarding the buffer zone between

the site and the residential and/or light industrial area as

well as of planned development in the area during the

operative life of the site.

EnviroServ is complying with the conditions of its permit

issued under section 20 of the Environment Conservation

Act. The condition to which Tongaat-Hulett refers states

that: “The Permit Holder shall take reasonable steps, such

as suitable zoning and/or written agreements with

adjacent landowners, to establish and maintain an unbuilt

area or “buffer zone”, as specified in the Revised Air

Quality Impact Assessment and Buffer Zone, dated 15

August 2003, between the site and nearest residential

and/or light industrial areas during the operative life of the

site” As is clear, EnviroServ is required to take reasonable

measures to ensure that land uses compatible with waste

management take place within the buffer zone of its land

fill site. The precise measures that must be taken are not

stipulated; various possibilities are set out. EnviroServ has

complied with these requirements, including entering into

a lease agreement with Tongaat-Hulett for the use of the

land for the purposes of growing sugar cane. It will also

take reasonable measures to prevent the establishment of

incompatible land uses within the buffer zone should they

be proposed.



8. ENVIRONMENTAL, SOCIAL AND CULTURAL IMPACTS

Potential impacts associated with the development of the landfill gas to electricity project at the

SLS are discussed in the following sections. Only those environmental aspects that may be

impacted are discussed.

8.1 Land Use and Zoning

The proposed landfill gas to electricity project will be located within the SLS. The layout of the

project (i.e. positioning of the wells, collector pipes and combustion facility) has been planned to

ensure that there will be no interference with current or planned waste disposal operations.

Although operation of the landfill gas extraction facility will be undertaken by Ener-G Systems, all

operations will be integrated with EnviroServ’s operations. Ener-G systems will comply with the

permit conditions and all operating procedures and management plans set out by EnviroServ.

Actions planned by Ener-G Systems must be approved by the SLS Site Manager prior to

implementation. There is no conflict with the current land use or zoning of the site.

The buffer zone around the SLS, as prescribed by the landfill permit and defined in EICR, will

remain unaffected by the landfill gas to electricity project. In fact, the extent of the current buffer

zone was determined with landfill gas extraction as a mitigation measure. The landfill gas to

electricity project would not require any changes to the extent of the buffer zone, nor would it

place any restrictions on land use beyond the buffer zone.

8.2 Climate

The main purpose of the project is to extract and combust LFG in order to generate green house

gas emission reductions. During the combustion process methane will be converted to carbon

dioxide, thereby significantly reducing the global warming potential of the SLS. Over the 20 to 30

year operational period of the project a significant volume of methane will be combusted. The

emission of carbon dioxide equivalents from the SLS with LFG flaring are expected to be reduced

by at least 25%. The project will thus result in a reduction of global warming potentials of the

SLS.

Although the SLS emits very low levels of ozone depleting substances, the ozone depletion

potentials of emissions from the SLS will be reduced with flaring. The project will result in a

reduction of ozone depletion potentials.



The reduction of emissions of these two gas groups will improve the sustainable waste disposal

practice at the SLS. Overall, reduced ozone depletion potentials and global warming potentials

will have positive transboundary impacts as ozone depletion and global warming potentials are

global phenomena.

Once phase 2 of the project is developed electricity will be generated from the LFG. Although the

generating capacity of the SLS will be limited to approximately 1.1 MW, the use of LFG as an

alternative energy source will reduce the need for energy generation at coal-fired power

stations. Such a reduction will contribute to small reductions in impacts from the power station

(ie: air and water quality and global warming).

8.3 Geology and Soils

The extraction of landfill gas reduces the pressure and concentration of gaseous components

within the waste body, thereby reducing the pressure and concentration gradients. Although not

considered a concern at the SLS, the LFG extraction will minimize lateral migration of landfill

gas to surrounding soils.

8.4 Hydrology

Sources of potentially hazardous materials that may impact on surface water quality include:

• Waste material exposed during well augering.

• Leachate that may be collected from the gas extraction wells.

• Condensate collected from the knock-outs.

• Hydrocarbons from vehicles and equipment used on the site.

The proposed project will operate within the physical boundaries of the SLS’s storm water

management systems. Due to the presence of the waste disposal facility’s containment

structures, no impact on surface water quality is expected. There will be no change to water

use at the SLS and thus no impact on the resource.

8.5 Geohydrology

The landfill gas extraction project will operate within the boundaries of the SLS and largely within

the lined areas of the site, which was designed to meet the specifications of the Minimum

Requirements. Leachate and condensate that may be encountered through the landfill gas

extraction system will be managed together with the site’s leachate. Hazardous substances that

infiltrate into the waste body will be contained by the existing liners and leachate management

system. No negative impact on groundwater quality is expected.



Drilling of gas wells into the landfill and the operation of heavy plant on the waste body could

endanger the integrity of the cells liners. If the liner were to be damaged then leachate could

escape from the landfill and contaminate groundwater. Planning and management supervision

will be required to ensure that the sites liner is not damaged. Provided that due care is exercised

no negative impacts on groundwater are expected.

Drilling and infrastructure that penetrates the waste body may provide a preferential path for

surface water to ingress into the waste body. The extraction of LFG may also cause the landfill

body to settle, and potentially crack the sites capping. Additional water entering the waste body

would result in increased leachate production that would either require disposal, or may increase

the hydrostatic head on the liner, resulting in leakages to groundwater. All excavations must be

sealed once complete to prevent the ingress of water. The sites capping, and areas around wells

in particular, must be inspected regularly for subsidence and cracks. Repairs must be affected.

Provided that due care is exercised no negative impacts on groundwater are expected.

8.6 Ecology

Due to the fact that the project is located on a waste disposal facility and will be contained with

the sites management structures, there will be no loss of any natural habitats or species of

conservation importance.

Although no impacts to vegetation quality or composition from LFG have been documented at the

SLS, it is possible that increased concentrations of methane in the air may be impacting on

vegetation in adjacent habitats. LFG extraction will reduce methane concentrations and limit

the chance of impacts on vegetation.

8.7 Air Quality

8.7.1 Compliance of Criteria Pollutants

Emissions from the flare and gas engine were not predicted to exceed the National Ambient Air

Quality Standards for CO, NO2 and PM10. The predicted dioxin concentrations did not exceed the

California OEHHA chronic inhalation reference concentration. No exceedances of the legal

standards are expected to result for these compounds.

Exceedence of the National Ambient Air Quality Standards for SO2 was predicted to occur off-site

following combustion of the LFG. However, the predicted SO2 impact area falls within the buffer

zone approved for the SLS. As the buffer zone is set out to protect receptors from potential

impacts the non-compliance with the SO2 standards is of low significance.



8.8 Heritage Resources

No archaeological, historical or cultural sites or artefacts will be affected. No impacts on heritage

are anticipated.

8.9 Traffic

Deliveries of construction material will be the only minor increase in traffic to the site. There will

be occasional additional vehicles to the site during the operation of the project. No impacts on

traffic are anticipated.

8.10 Noise

Due to the fact that there are no receptors within earshot of the site and that the project is located

at a facility with existing noise generation from on-site vehicles and machinery, the noise

generated by the flares and engines will have a no impact on current noise levels.

8.11 Socio-Economics

There will be only limited employment opportunities arising from the project, although the two

permanent positions will be long-term. Local economic development would be promoted

during construction through the hire and purchase of equipment and materials required by the

project (i.e. piping and well drilling). The local communities would also benefit from

improvements in the operating conditions of the landfill (less odours etc). The project may

also result in direct foreign investment in South Africa through the purchase of emission

reduction certificates by an overseas buyer. This is dependant on the project being registered

with the CDM Board.

8.12 Health and Safety

8.12.1 Occupational

Extraction of LFG will reduce subsurface migration and prevent accumulation of methane in

structures thereby reducing the risk of an explosion on-site. Personnel working in enclosed

spaces or excavations are potentially exposed to the risk of asphyxiation which will be

reduced by LFG extraction.



With the implementation of landfill gas extraction, the on-site cumulative lifetime cancer risk will

be reduced from a baseline value of ~1:124 000 to ~1:162 000 (Airshed 2008). This is

considered a low risk. The combustion of landfill gas will result in maximum direct lifetime cancer

risk from dioxins of 1:380 000. This is also considered a low risk and will not significantly alter

the on-site cumulative lifetime cancer risk. The cumulative non-cancer health risk on site with

gas extraction was predicted to be significantly less than any of the hazard quotients (Airshed

2008). The combustion of LFG will increase the on-site non-cancer health risk by a small margin,

but the risk will remain below all of the hazard quotients. Thus the landfill gas to electricity project

will not significantly alter the on-site non-cancer health risk.

The landfill gas to electricity project will also introduce additional risks at the SLS. Combustion of

landfill gas involves exposing flammable gases to an open flame, there is the thus the risk of an

explosion at the flare and the risk of ignition of the subsurface gases within the gas

extraction system. The flare operates at extremely high temperatures and produces very hot

exhaust gases which may result in burns to exposed personnel. The handling of waste,

leachate or condensate extracted from the landfill poses a risk of exposure to hazardous waste

materials. The generator will produce high voltage electricity and will pose a risk of

electrocution. All of these aspects pose potentially high occupational risks, but the impacts are

likely to be of low significance as long as training, PPE and the correct procedures and

operating parameters are maintained.

The SLS is an operational landfill that handles hazardous waste and there are many on-site

occupational risks. All of the landfill gas to electricity project operations and actions by operators

and contractors must be undertaken in terms of the SLS operations manual to ensure the safety

of personnel. Activities planned for the landfill gas to electricity project must be approved by SLS

Manager. It is essential that existing and new personnel at the SLS are given a thorough health

and safety induction. The induction topics should deal with the risks of both the SLS and landfill

gas to electricity project operations. The required PPE for each activity or operation must also be

detailed and all personnel must be trained in the use of the PPE. Each operational area must be

appropriately sign posted to indicate the potential risks and the required PPE.



8.12.2 Public

8.12.2.1 Particulates (TSP and PM10)

Fugitive particulate emissions are generated primarily by vehicular activity and wind action on

expose surfaces at the waste disposal facility. The previous impact assessment (Airshed 2008)

predicted that PM10 levels would be higher than the SA daily standards at the site boundary, but

would not impact any of the discrete receptors. The buffer zone required for the SLS was based

partially on the PM10 levels. The current assessment concluded that very limited particulate

matter will be emitted by the combustion of the LFG. Thus, the project will not alter the existing

levels of fugitive particle emissions (TSP and PM10) emanating from the SLS under standard

operating conditions. The current buffer zone must continue to be implemented to protect

receptors.

8.12.2.2 Health Risks (Non-Carcinogenic and Cancer Risks)

A study done by the Natural Resources Defense Council (March 2003) investigated concerns

about the health impacts of the exhaust from the burning of landfill gas in the USA. The study

acknowledges that:

• Landfill gas is a threat to human health and global warming.

• Flaring it greatly reduces its climate change impact.

• Burning LFG serves to mitigate its public health impact by destroying the majority of

hazardous air pollutants in landfill gas through the combustion process.

• LFG combustion produces minute quantities of dioxins, an extremely toxic group of

chemicals that are harmful even in very small amounts

The study utilised data and information on LFG and combustion from a wide variety of sources in

trying to assess, as quantitatively as possible, the emissions and health risks from raw LFG

versus the combustion of LFG. The study compared equivalent volumes of raw LFG versus

exhaust gases from combusted LFG and considered the cumulative inhalation-cancer potency of

the hazardous air pollutants in each. The Natural Resources Defense Council states that “Raw

LFG contains many hazardous air pollutants, many of which are carcinogenic. The destruction of

the vast majority of these more than makes up for the formation of minute amounts of dioxins.

Our analysis of the inhalation cancer-risk factor suggests that the overall toxicity of LFG

combustion is 23 times less than that of raw LFG”.

The Natural Resources Defense Council study concludes that it would be best, for human health

and the environment, to avoid land filling of waste completely, but that given the given the current

practice of disposal, all landfill sites should combust landfill gas.



The previous impact assessment (Airshed 2008), which used the strictest risk factors available for

each pollutant, predicted that the cumulative lifetime cancer risk for SLS operations at the

discreet receptors was significantly less then 1 in a million for all scenarios. This is a very low risk.

The assessment also concluded that the extraction of the landfill gas would reduce the cancer

risks over the non-extraction scenario. The current assessment (Airshed 2010) of the LFG

combustion aspect concluded that the predicted lifetime cancer risk from dioxin exposure would

be less than 1 in a million at all discreet receptors. This is a very low risk. The assessment was

also very conservative in that it considered the maximum reported dioxin concentrations and

assumed that all dioxin compounds were equivalent to the most hazardous congener. The

assessment concluded that the risk at the site boundary with the implementation of the LFG

combustion would be approximately 1.5 times (~30%) lower than the risk without extraction. Thus

no significant cancer risk to off-site receptors is anticipated from the combustion of the

LFG.

The previous impact assessment (Airshed 2008) assessed the combined chronic hazard rating

associated with inhalation exposure of all potential non-carcinogenic emissions. The assessment

concluded that the chronic hazard rating would not exceed 1 at the site boundary or at any of the

receptors under any scenario. The extraction of landfill gas would reduce the non-cancer risks

over the non-extraction scenario. The current assessment (Airshed 2010) concluded that

combined chronic hazard rating would increase with the LFG combustion, largely as a result of

the SO2 emissions. However, the combined chronic hazard rating would not exceed 1 on-site or

at any of the off-site receptors. Thus no significant non-cancer risk is anticipated from the

combustion of the landfill gas. The current buffer zone must continue to be implemented to

protect receptors.

8.12.2.3 Odour

The previous impact assessment (Airshed 2008) predicted that exceedances of the odour

threshold for Hydrogen Sulphide were likely to occur off-site under all scenarios. The extraction of

the landfill gas resulted in reduced exceedances of the odour threshold at the site boundary. No

exceedances of the H2S odour threshold were predicted at any of the residential receptors. The

current assessment predicted that combustion of the LFG would not produce any odourous

substances and would in fact destroy many odourous substances. The odour impact area is

anticipated to reduce with the combustion of the LFG. The current odour management zone

must continue to be implemented to protect receptors.



8.13 Potential ‘Upsets’

Upset events may allow for the direct releases of LFG into the atmosphere. There are two

specific forms of potential ‘upsets’ associated with the landfill gas to electricity project. The first is

the emissions resulting from disturbance to the waste body during the installation of the gas

extraction system. The second relates to the emission of concentrated, uncombusted gases in

the event of a leak or if the combustion facility is not in operation. Such upsets would negatively

affect the benefits derived from the combustion of LFG. However the magnitude of these events

is likely to be small in comparison with the overall impact of the project through its life.

Management measures are in place to prevent such events and to limit their magnitude when

they do occur. During well installation only a single well may be excavated and must be

completed and sealed as rapidly as possible. All wells and pipes must be equipped with valves

and these kept closed. Leaks in the gas system will be detected through drops in pressure or

increases in oxygen concentrations. Venting through the stack when the flare is not operational is

only permitted for short test periods. It is unlikely to occur during operation as the technology has

fail-safe ignition systems to ensure the flame is active. The technology also has measures in

place for rapid shutdown during emergencies.



Table 5: Summary of Environmental Impacts and Environmental Management Measures

Rating Criteria Significance

Current level

of

degradation

Nature of the Impact

Intensity

Extent

Duration

Probability

Mitigation

Potential

Status

With

mitigation

Cumulative

Recommended Environmental Management

Degree of

Certainty

Land Use & Zoning

/ Conflict with the current land use on the site

M L M M G - M N All operations to be undertaken in terms of the SLS permit conditions and operations manual. All actions to be approved by SLS Manager.

G

M Changes to buffer extent or restrictions on surrounding land use L L M L G - L M

Implement LFG combustion. All operations to be undertaken in terms of the

Ener-G operations manual. G

Climate

L Reduction of global warming potentials H H M VH G + M L G

L Reduction of ozone reduction potentials L H M M G + L L G

L

Positive transboundary impacts as the reduction of ozone depletion and global warming potentials are global phenomena

M H M H G + M L

Implement LFG combustion Maintain flare/engine in accordance with

manufacturer’s specifications and maintain services records.

Implement periodic monitoring of inlet gas concentrations to determine trace gas

composition and destruction efficiencies. Maintain systems and prevent upset events.

G

Reduction of power station impacts through use of alternative energy source.

L H M M U + VL IPP agreement with Eskom.

Maximise generation of electricity R

Geology and Soils

L Reduction in the lateral migration of landfill gas to surrounding soils

L L M M G + L VL Maximise extraction of LFG.

Continue monitoring at subsurface gas probes G



Rating Criteria Significance Current level

of

degradation


Intensity

Extent

Duration

Probability

Mitigation

Potential

Status

With

mitigation

Cumulative


Degree of

Certainty

Hydrology

VL Contaminants impacting on surface water quality

M M H VL G - VL VL G

/ No change to water use at the site / N N

All activities within SLS storm water systems. Maintain current storm water systems to

contain dirty water. G

Geohydrology

VL

Contaminants impacting on groundwater quality through: - Exposure of contaminants - Damage to liner allowing leachate to contaminate groundwater - Damage to cap allowing ingress of water

M M H VL G - VL VL

All actions to be approved by SLS Manager. All activities within SLS water and leachate

management systems. Drilling of wells planned and controlled to

protect liner. Close wells and excavations to prevent ingress

of water. Repair cracks, erosion and fill in depressions

where ponding may occur on landfill.

G

Ecology

H No loss of any natural habitats or species of conservation importance

N L L VL G / N H All operations within footprint of SLS G

/ Reduction in methane levels allowing improved vegetation growth

L L M M G + VL H Maximise extraction of LFG.

Maintain systems and prevent upset events. G

Air Quality

Compliance of Criteria Pollutants

Exceedance of limits as set by the National Ambient Air Quality Standards for

/ - Carbon monoxide / N N

/ - Nitrogen oxides / N N

L - PM10 / N L

L - Sulphur dioxide L L L M R - L L

Maximise extraction of LFG. Maintain systems and prevent upset events. Maintain optimal flare/engine functioning to ensure minimal emissions from combustion.




of

degradation


Intensity

Extent

Duration

Probability

Mitigation

Potential

Status

With

mitigation

Cumulative


Degree of

Certainty

/ - Dioxins and Furans (included as 2,3,7,8 – Tetrachlorodibenzo-p-dioxin

M L M H G / N N Monitoring of inlet gas composition.

G

For potential impacts on odour, dust and health see section on Health and Safety

Heritage Resources

/ No impacts / N N None required G

Traffic

L Minor traffic increase during construction and operations.

L L L L U - VL L Investigate measures to improve visibility and

safety at entrance G




of

degradation


Intensity

Extent

Duration

Probability

Mitigation

Potential

Status

With

mitigation

Cumulative


Degree of

Certainty

Noise

/ No change to current noise levels

/ N N Operate and maintain flare/engine in terms of

manufacturer’s specifications. G

Socio-Economics

Local employment opportunities

L M M M R + VL L Use local labour and contractors where

possible G

Promotion of local economic development

L M L M R + VL VL Use local parts and equipment suppliers where

possible R

L

Benefits to local communities through improvements in operating conditions of the SLS M M M H G + M L

Implement LFG combustion Maximise extraction of LFG.

Maintain systems and prevent upset events. Maintain optimal flare/engine functioning to ensure minimal emissions from combustion.

G

/ Direct foreign investment in South Africa from sale of emissions reductions

L M M H G + L L Complete project to CDM requirements G




of

degradation


Intensity

Extent

Duration

Probability

Mitigation

Potential

Status

With

mitigation

Cumulative


Degree of

Certainty

Health and Safety

OCCUPATIONAL

L Reduction in on-site odours M L M H G + L VL G

L

Reduction in gas emissions causing occupational health risks (cancer and non-cancer)

M L M H G + M L

Maximise extraction of LFG. Maintain optimal flare/engine functioning to ensure minimal emissions from combustion.

Monitoring of inlet gas concentrations to determine trace gas composition and

destruction efficiencies Maintain systems and prevent upset events.

G

VL Reduction in risk of on-site explosion L L M H G + VL VL R

VL Reduction in the risk of asphyxiation to on-site personnel

M L M H G + VL VL

Implement LFG combustion Continue monitoring at subsurface gas probes R

Risk of an explosion at the flare H L M VL G - VL VL G

Risk of ignition of the landfill gas within the gas extraction system

H L M VL G - VL VL

Flare/engine has built-in safety features, see operations manual.

Training of relevant personnel. Access control and signage at operations area

Emergency Response Plan in case of emergency.

G




of

degradation


Intensity

Extent

Duration

Probability

Mitigation

Potential

Status

With

mitigation

Cumulative


Degree of

Certainty

L Risk of exposure when handling waste leachate or condensate

M L M L G - VL L Training of personnel, correct use of PPE G

Risk of burns through exposure to high temperature equipment and gases

M L M VL G - VL VL

Training of personnel. Access control and signage at operations area


G

Risk of electrocution through exposure to generator and cabling

H L M VL G - VL VL

Training of personnel. Access control and signage at operations area


G




of

degradation


Intensity

Extent

Duration

Probability

Mitigation

Potential

Status

With

mitigation

Cumulative


Degree of

Certainty

PUBLIC

Particulates

L Change in levels of particulate emissions

L M M L G / N L Limit vehicle speeds on unpaved road.

Maintain optimal flare/engine functioning to ensure minimal emissions from combustion.

G

Health Risks

L No significant change to the area of anticipated health-risks

/ N L G

L Reduction of the off-site cumulative cancer risk (including from dioxins)

L M M M G + L L G

L

Increase of the off-site non-cancer risks

L M M M G - L L

Implement the buffer zone. Maximise extraction of LFG.

Maintain optimal flare/engine functioning to ensure minimal emissions from combustion.

Implement monitoring of bulk inlet gas concentrations. Periodic analysis of trace gases

to determine trace gas composition and destruction efficiencies.

Maintain systems and prevent upset events.

G

Odour

L

Reduction in the magnitude, distance and frequency of exceedance of odour thresholds

M M M H G + M VL

Maximise extraction of LFG. Maintain optimal flare/engine functioning to ensure minimal emissions from combustion.

Implement monitoring of bulk inlet gas concentrations. Periodic analysis of trace

gases to determine trace gas composition and destruction efficiencies.

Maintain systems and prevent upset events

G




of

degradation


Intensity

Extent

Duration

Probability

Mitigation

Potential

Status

With

mitigation

Cumulative


Degree of

Certainty

Potential Emissions Associated with Upsets

/

Potential emissions resulting from disturbance to the waste body during the installation of the gas extraction system

H M L L G - L L

Single vertical wells will be installed at one given time and will immediately be backfilled

and sealed. Daily check to see that valves etc are closed.

G

/

Emission of concentrated, uncombusted organic compounds in the event that the flare is not in operation or a leak develops in the extraction system H M L VL G - L L

The flares are equipped with automatic re-ignition in the event that the flare cease. The

flare also has a fail safe valve, which prevents the venting of gas in the event that the flare is

not in operation. Inspections and maintenance as per Ener-G

operations Manual.

G



9. CONCLUSIONS

The development of the landfill gas to electricity project at the SLS will result in significant

environmental benefits. These include:

• the conversion of significant amounts of methane gas into carbon dioxide, thereby

reducing the sites contribution to global warming. This and the destruction of other gases

with ozone depleting potential will improve the sustainable waste disposal practices at the

SLS.

• the destruction of hazardous air pollutants contained in the raw LFG will reduce the

potential health risks to both on-site and discreet receptors.

• a reduction in gaseous emissions (bulk and trace gases) from the site will ensure that

potential odour and health risk impacts are restricted to within the designated

management and buffer zones.

• the generation of electricity from LFG provides the added environmental benefit of

offsetting non-renewable fossil fuels that would otherwise be used to generate the same

amount of energy. This avoids CO2 emissions and can also lead to significant reductions

in regulated air pollutants such as nitrogen oxides (a major contributor to urban ozone),

sulphur dioxide (a major contributor to acid rain) and particulate matter (a contributor to

respiratory health problems and often carcinogenic).

The main negative effect of the landfill gas to electricity project will be the production of

hazardous air pollutants in the combustion emissions. These may include oxides of nitrogen,

oxides of sulphur, dioxins and furans. Dioxins in particular are a concern as they are probable

human carcinogens, disperse widely in the atmosphere, are long-lived and bio-accumulate. The

production of these compounds could affect occupational health as well as the health of off-site

receptors.

The assessment and international literature concludes that although these compounds may be

highly toxic, they are produced in minute amounts during LFG combustion. LFG combustion

destroys the great majority of the hazardous air pollutants in LFG and results in an overall

reduction in the health risk when compared with that of raw LFG emissions. The Study by the

Natural Resources Defense Council (March 2003) concluded that “raw landfill gas is

approximately 23 times more carcinogenic to human health than landfill gas combustion exhaust”.



It is concluded that the addition of the landfill gas to electricity project at the SLS will have an

overall positive benefit to the environment and human health. The project should be implemented

to maximise the capture and combustion of LFG, using the most combustion-efficient technology.

There are potential occupational and public health and safety risks from the landfill gas to

electricity project and the installation and operation of the landfill gas to electricity project must be

undertaken with due care, both for the SLS operations and the personnel involved. All

components of the landfill gas to electricity project must be optimally maintained to ensure

efficient combustion and minimal production of potentially hazardous gases.

In concluding it is also important to note the combustion of LFG is required in order to implement

the extraction of LFG. Thus the benefits derived from the extraction of the LFG as assessed and

discussed in the EICR for Valley 2 (ie. reduced health risk buffer zone and odour management

zone), can only be realised if the LFG is combusted.



DECLARATION BY CONSULTANT

Synergistics Environmental Services acted as independent consultants to Ener-G Systems.

Synergistics has no financial interest in the undertaking of the activity, other than remuneration for

work performed in terms of the Environmental Impact Assessment Regulations, 2006.

Synergistics has made every effort to disclose, to the competent authority and interested and

affected parties, all relevant facts and material information that has the potential to influence the

decision of the competent authority or the objectivity of any report, plan or document required in

terms of the Environmental Impact Assessment Regulations, 2006.

I, the undersigned herewith declare that this basic assessment report represents an objective

assessment of the environmental issues associated with the proposed development of the landfill

gas to electricity project at the SLS.

COMPILED BY:

Matthew Hemming

Director

For Synergistics Environmental Services (Pty) Ltd

PO Box 1822

Rivonia

2128



References

Reference in text

Airshed Planning Professionals, Air Quality Impact Assessment for the Development of Valley 2 at the Shongweni Hazardous Waste Disposal Site 2008.

(Airshed, 2008)

Airshed Planning Professionals, Air Quality Impact Assessment for the

Proposed Landfill Gas Utilisation Plant at the Shongweni Hazardous

Waste Disposal Site, July 2010.

(Airshed, 2010)

Department of Water Affairs and Forestry, Minimum Requirements for the Handling, Classification and Disposal by of Hazardous Waste. Waste Management Series, Second Edition, 1998.

(DWAF, 1998)

GroundTruth, EnviroServ Shongweni Landfill Site, Routine Bio-monitoring of the Mgoshonweni Tributary, April 2010

(GroundTruth, 2010)

Jones & Wagener, Water Monitoring Protocol for the Shongweni Landfill Site, March 2008.

(Jones & Wagener, 2008)

Jones & Wagener, Water Quality Monitoring for the Shongweni Landfill Site, July 2009.

(Jones & Wagener, 2009)

Margot Saner & Associates, Air Pathway Analysis System for the Shongweni Landfill Site, Annual Report, July 2009.

(MS&A, 2009)

Natural Resources Defense Council, Is Landfill Gas Green Energy?

March 2003. NRDC, 2003)

Synergistics Environmental Services, Environmental Impact Control Report: for the Development of Valley 2 at the Shongweni Landfill Site, September 2009.

(SES, 2009)



10. ENVIRONMENTAL MANAGEMENT PLAN

This environmental management plan (EMP) has been prepared in support of the basic

assessment report submitted to the DEA. The EMP has been prepared to meet the requirements

of sub-regulation 34, ‘Content of Environmental Management Plans’ of the Environmental Impact

Assessment Regulations (GN R385), promulgated in terms of the National Environmental

Management Act (107 of 1998).

The EMP details the actions and management measures that must be implemented during each

phase of the Landfill Gas to Electricity Project. The measures are aimed to minimise the potential

negative environmental impacts (to an acceptable level of significance) and enhance the positive

impacts of the Landfill Gas to Electricity Project. The effective implementation of the mitigation

measures will ensure the protection of the environment. The EMP has also aimed to define the

roles and responsibilities of environmental management personnel on site, as well as to provide a

framework for environmental compliance and monitoring.

The EMP has considered actions that may be necessary during the following project phases:

• Planning and Design;

• Construction;

• Operation, and

• Closure and Rehabilitation

The EMP is further structured to include:

• The project activity/aspect requiring management;

• The management objective arising from these activities/aspects;

• The management and monitoring actions to be implemented, and

• The timeframes associated with the required management or monitoring action.

10.1 Planning and Design

Planning and design of the Landfill Gas to Electricity Project is at an advanced stage. Ener-G

Systems have drawn on best practice and international experience to ensure that the most

appropriate equipment and systems are used at the SLS. The overall design of the project will be

completed to the highest standards in order to ensure compliance with the CDM Executive Board

requirements and to maximize the generation of emission reduction credits.

Site specific measures that have been undertaken to ensure that future impacts are minimised or

effectively mitigated include:



• Design of the of the LFG extraction system after consideration of the SLS layout plan

and operations.

• Location and depth of wells based on as-built surveys of waste body. Consideration

given to the depth of the liner.

• The use of a suitably sized flare and gas engines with the necessary combustion times

and temperature to ensure complete combustion of the landfill gas.

• The installation of in-line flow rate metres and gas analysers to monitor the volume and

content of the LFG.

10.2 Construction

The construction EMP relates to all aspects during the installation or construction of the Landfill

Gas to Electricity Project. As the SLS is an operational landfill site it is essential that activities do

not interfere with site operations or contravene the permit conditions. All activities must be

planned in terms of the SLS permit and operations manual and must be communicated with the

SLS Manager for approval.

The construction and installation specifications, methods and procedures for the wellfield,

pipeline, flare and generator units must be done in terms of the instructions or manuals provided

by the respective suppliers. These manuals are referenced in the EMP and the conditions therein

have not been repeated here.

The installation of the various well-field and combustion unit components will be undertaken by

contractors. All contractors must be informed of the requirements to comply with the site

conditions and permit, the conditions of the EMP and the requirements of the various manuals.

It is essential for the safe operation of the landfill site, that any additions or alterations to the

landfill gas system infrastructure, from that shown in the current plans, are communicated to and

approved by the Site Manager of the SLS.



Table 6: Construction Environmental Management Plan Implementation Programme

Scheduling Objectives and Goals Management and Monitoring Actions

Implementation Frequency

Corporate Responsibility

– Ultimate responsibility for environmental management and compliance with the Construction EMP rests with EnviroServ.

– From commencement of the project.

– Continuous EMP Responsibility

– To assign roles and responsibilities for environmental management and the implementation of the Construction EMP. – EnviroServ is to ensure that Ener-G Systems and all

sub-contractors are aware of and familiar with site operations, the key environmental issues and consequences of non-compliance to the EMP.

– Adherence to the permit, SLS Operations Manual and the EMP must be included as a contractual requirement.

– In all project tenders and contracts

– When required

– EnviroServ is to nominate a member of the SLS staff to be responsible for overseeing construction of the landfill gas to electricity project.

– This person must be responsible for implementation, monitoring and auditing of compliance with the permit, SLS Operations Manual and the EMP during construction.

– The responsible person is to undertake weekly compliance checks during any construction period. Records are to be kept.


– During construction

– Continuous

– When required

– The Landfill Gas to Electricity Project is to be included as an item in the quarterly internal and annual external audits at the SLS.

– From next audit – Quarterly, Annually

– Ener-G and each sub contractor is to provide – Prior to – When



Implementation Programme



EnviroServ with a signed letter indicating their acknowledgement of the conditions of the permit, SLS Operations Manual and the EMP.

commencement of work

required

– Ener-G and their sub-contractors are to ensure continuous compliance with the permit, SLS Operations Manual and the EMP.


– Continuous

– Ener-G must designate a member of staff as a responsible person.

– This person must be responsible for implementation of the conditions of the permit, SLS Operations Manual and the EMP during construction.

– The responsible person is to record all incidents and report them to EnviroServ.

–






Site Awareness

– To ensure that all members of the construction workforce are aware of site conditions, the risks and the required procedures and PPE.

– EnviroServ is to provide Ener-G, their sub-contractors and all personnel with an induction on the SLS, permit and operations manual, the health and safety risks, the procedures and the PPE. Records are to be kept of attendance at inductions

– The Ener-G designated person is to ensure on-going awareness and compliance.

– Prior to commencement of work

– When required

Environmental Awareness

– To ensure that all members of the construction workforce are aware of their responsibilities toward environmental protection and the EMP requirements.

– EnviroServ is to provide Ener-G, their sub-contractors and all personnel with an induction on the local environment and EMP conditions. Records are to be kept of attendance at inductions

– The Ener-G designated person is to ensure on-going awareness and compliance.

– Prior to commencement of work

– When required

Public Relations

– To keep affected parties aware of the progress and developments of the project.

– Inclusion of the Landfill Gas to Electricity Project as an item on the monitoring committee meeting agenda.

– Progress reports, incidents, studies or analyses done for the project to be reported on.

– From next committee meeting.

– At every SLMC meeting.

– Follow up on all reasonable concerns received. – By the following meeting

General

Infrastructure

– To ensure that all planned infrastructure is compatible with SLS operations.

– EnviroServ must supply Ener-G with accurate layout information for the SLS.

– Ener-G must provide all design and construction drawings to the SLS Site Manager for approval.

– Ener-G is responsible for ensuring that all infrastructure is implemented as per the approved

– During construction – As required






drawings.

– Ener-G must communicate any changes to the LFG infrastructure or construction schedule to the SLS Site Manager for approval.

– Ener-G must supply as built drawings to EnviroServ

Activities

– To ensure that Ener-G and all sub-contractors undertake construction activities in a manner that is compatible with SLS operations and environmentally responsible.

– EnviroServ must supply Ener-G with the current SLS operations manual and any relevant procedures or work instruction.

– Ener-G must discuss all planned activities with the SLS Site Manager for his approval.

– When required, Work Procedures must be prepared and approved by the SLS Site Manager.

– Ener-G is responsible for ensuring that all activities are undertaken as per the approved procedures.


– The location of construction camp and laydown area must be approved by the SLS Site Manager.

– Site access procedures must be approved by the SLS Site Manager.

– Sufficient ablution facilities must be made available to construction personnel.

– All hydrocarbons and chemicals must be stored in a bunded area with 110% capacity.

– Material Safety Data Sheets (MSDS) for on-site chemicals and hydrocarbons must be readily available.







Health and Safety

– Minimise the occupational health and safety risks

– EnviroServ to provide Ener-G, their sub-contractors and all personnel with an induction on the SLS, the health and safety risks, the procedures and the PPE.

– Ener-G to undertake work as per Occupational Health and Safety Act and the SLS Operations Manual.

– Ener-G to conduct risk assessments of each construction activity and ensure correct work procedures and appropriate PPE.

– Undertake all work in terms of the Construction Regulations.

– Only use equipment that is intrinsically safe.

– Demarcate all well excavations and open trenches and have danger signage in place.

– Restrict access to areas with operating machinery or open excavations.

– Smoking only at designated smoking areas at the SLS.

– Ener-G to test methane levels at work sites periodically with a gas instrument. Log to be kept.

– Ventilate confined spaces.

– Never work alone in a confined space - always employ the buddy system.

– At appointment of contractor.

– Continuous






Emergency Response

– Ensure appropriate response to an emergency

– EnviroServ to provide Ener-G and their sub-contractors with a copy of the SLS Emergency Response Plan.

– All personnel to be made aware of the Emergency Response Plan.

– In the case of an emergency the appropriate response in terms of the SLS Emergency Response Plan should be initiated.

– EnviroServ to update SLS Emergency Response Plan to include the LFG gas project.

– At appointment of contractor.

– Continuous

Incident Management

– To ensure that the impacts of any incident are minimised.

– To prevent the recurrence of repeat incidents.

– Ensure that a response to an incident is implemented within 3 hours from detection.

– Any significant incident, which may cause environmental pollution, health risks or nuisance conditions must be reported to the DEA within 24 hrs.

– An action plan, detailing the measures to correct and/or prevent the recurrence of such an incident, must be compiled by Ener-G and submitted to DEA within 14 days of the incident.

– During construction, at an incident

– When required

– Within 24hrs

– Within 14 days

Installation of Wellfield and Pipelines

Climate and Air Quality Protection

– Prevent the venting of landfill gas that may occur as a result of disturbances to the waste body.

– Prevent the release of landfill gas to the atmosphere as a result of a leak, accidental or

– Only install vertical wells into waste cells that have been capped with at least an interim capping layer.

– Construct a single vertical well at a time and complete the well to specification before commencing with further wells.

– During construction.

– Continuous






uncontrolled venting. – Ensure each wellhead is fitted with a primary valve and that it is closed.

– Connector or header pipes may only be connected to wells if the pipe can be sealed at the isolation valve or the wellhead valve is confirmed shut.

– At daily cessation of work on a well ensure that the well hole and any conduits exiting the well are sealed to prevent the venting of landfill gas.


– Daily

– Prevent accidental damage to wellfield infrastructure during operation of the landfill site

– Ensure that the SLS Site Manager has as-built plans detailing the layout of all project infrastructure.

– Communicate all changes to the SLS Site Manager.

– Wellheads to be demarcated with appropriate signage.

– During construction, at any addition or removal of infrastructure

– When required

Water Quality

– Prevent damage to the waste cell liners.

– Consult with SLS Site Manager prior to drilling each well.

– Ensure that wells terminate above the cell liners.

– During construction – Continuous

– Prevent impacts on water quality – Undertake all activities within the dirty water area of the SLS.

– Material excavated from SLS during construction to be disposed to landfill.

– All equipment and vehicles that have operated on the waste body to be washed prior to departing the SLS.


– When required

Traffic

– Minimise impacts on local traffic flow.

– Combine material deliveries whenever practical to reduce the number of vehicle trips.

– Schedule delivery of construction materials for







quieter periods of the day. Do not plan deliveries between 7 and 8:30 am or between 4 and 5:30 pm.

Noise

– Minimise the noise produced during construction.

– Only operate heavy machinery during working hours as scheduled in the SLS Operations Manual.

– Ensue that all machinery is fitted with appropriate silencers.

– During construction – Daily

Safety

– Minimise the risk of ignition of the landfill gas

– Smoking only at designated smoking areas at the SLS.

– Test the work site for methane levels with a gas instrument prior to any activity that generates sparks or has an open flame. Log to be kept.



– Continuous

– Minimise exposure of personnel to hazardous substances.

– PPE requirements as set by SLS Site Manager.

– Do not handle excavated waste material from the waste cells without appropriate PPE.

– Do not handle liquid from the waste cells and condensate traps without appropriate PPE.

– Immediately rinse any area of the body exposed to landfill liquid with clean water.


– Continuous

– Minimise the risk of on-site personnel asphyxiating

– Test the work site periodically with a gas instrument. Log to be kept.




– Continuous

Installation of Combustion Units







– Prevent the release of landfill gas to the atmosphere as a result of a leak, accidental or uncontrolled venting.

– The unit must be installed as per the manufacturer’s specifications.

– The blower unit, once connected to the header pipe, should not be operated unless the flare is functioning. (with the exception of valid testing)

– Piping, connected to wells, must be closed off with a valve if not connected to the flare.

– Setup and testing of the unit must be done as per the manufacturer’s specifications.

– The inlet pipe system must have a port for the sampling of LFG.


– Ensure that the Site Manager of SLS has as-built plans detailing the layout of all project infrastructure.


– When required






Safety

– Prevent tampering with the combustion units by unauthorised personnel.

– Minimise the risk of on-site personnel asphyxiating

– Minimise the risk of injury to on-site personnel

– Reduce the risk of an explosion at the flare.

– Combustion units to be in a gated, fenced area with appropriate signage.

– Only authorised personnel to operate, test or adjust the combustion units. This must always be done in terms of the manufacturer’s specifications.

– The master valve must be closed if the combustion units are not operational.

– Test the work site periodically with a gas instrument. Log to be kept.


– Never work alone in a confined space, always employ the buddy system.

– During construction

– Continuous



10.3 Operations

The Operations EMP contains the actions required to addresses potential environmental impacts arising from the operation of the Landfill Gas to

Electricity Project (Phase 1 and Phase 2). In addition to complying with the conditions of this EMP, it is crucial that all operations and activities of the

Landfill Gas to Electricity Project are undertaken in terms of the site permit and the SLS Operations Manual. It is also essential, for the safe operation

of the landfill site, that the operations and activities of the Landfill Gas to Electricity Project (and changes thereto) are communicated to the Site

Manager of the SLS.

Most of the equipment used in the Landfill Gas to Electricity Project (ie. wellfield, pipeline, flare, engine and generator units) is supplied with user

manuals. Adherence to the specifications contained therein for installation, operations and monitoring, is required to ensure safe and efficient

functioning of the equipment. Ener-G Systems have also developed a site operations manual that details the work instructions to cover all the activities

undertaken on the site, from induction presentations through to weekly, monthly checks and training records. The conditions recommended by these

manuals have not been repeated in the EMP, but the manuals are referenced in the EMP.

Table 7: Operations Environmental Management Plan Implementation Programme




EMP Responsibility

– To assign roles and responsibilities for the implementation of the Operations EMP.

– Ultimate responsibility for the implementation of and compliance with the Operations EMP rests with EnviroServ.

– From project commencement.

– Continuous

– EnviroServ is to ensure that Ener-G Systems and all sub-contractors are aware of and familiar with site operations, the key environmental issues and consequences of non-compliance to the EMP.

– EnviroServ is to ensure that adherence to the permit, SLS Operations Manual and the EMP is

– In all project tenders and contracts

– When required.

– Weekly






included as a contractual commitment for all contractors operating or maintaining any aspect of the Landfill Gas Recovery Project.

– The Ener-G appointed Senior Technician is responsible for operation of the landfill gas to electricity project. This responsibility includes compliance of the project with the permit, SLS Operations Manual and the EMP.

– From commencement of operations.

- Continuous

– The Senior Technician is to undertake monthly performance and compliance audits of all gas recovery facilities.

– Results of the audit are to be submitted to the SLS Site Manager at a monthly meeting.


– monthly

– The Landfill Gas to Electricity Project is to be included as an item in the quarterly internal and annual external audits at the SLS.

– From next audit – Quarterly, Annually

Site Awareness

– To ensure that all members of the Ener-G workforce are aware of site conditions, the risks and the required procedures and PPE.

– EnviroServ is to provide Ener-G personnel with an annual induction on the SLS, permit and operations manual, the health and safety risks, the procedures and the PPE.

– The Ener-G Senior Technician is to ensure on-going awareness and compliance.

– At commencement of project, or on appointment of new project staff

– Annually or when required


– To ensure that all members of the operation and management workforce are aware of their responsibilities toward environmental protection and the EMP requirements.

– EnviroServ is to provide Ener-G personnel with an annual induction on environmental issues and the EMP conditions.


– At commencement of project, or on appointment of new project staff

– Annually or when required

Public Relations

– To keep affected parties aware of the project

– Inclusion of the Landfill Gas to Electricity Project as an item on the SLS monitoring committee

– From next committee

– At every SLMC meeting.






meeting agenda.

– Progress reports, incidents, studies or analyses done for the project to be reported on.

meeting. and project issues

– Follow up on all reasonable concerns received. – By the following meeting

General

Infrastructure

– To ensure that all infrastructure is compatible with SLS operations.

– EnviroServ must inform the Ener-G Senior Technician of any changes at the SLS.

– Ener-G is responsible for ensuring that all infrastructure is per the approved designs.

– Ener-G must communicate any changes to the LFG infrastructure to the SLS Site Manager for approval.

– During operations

– As required

Activities

– To ensure that Ener-G undertake operations activities in a manner that is both compatible with SLS operations.

– EnviroServ must supply Ener-G with any up-dates to the SLS operations manual, procedures or work instruction.

– Ener-G is responsible for ensuring that all activities are undertaken as per the approved procedures.

– Ener-G to update site operations manual on an annual basis.

– Ener-G must discuss all planned activities with the SLS Site Manager for his approval.

– During operation

– As required

– Site access for all Ener-G personnel must be approved by the SLS Site Manager.

– All hydrocarbons and chemicals must be stored in a bunded area with 110% capacity.

– Material Safety Data Sheets (MSDS) for on-site chemicals and hydrocarbons must be readily available.


– As required






Health and Safety

– Minimise the occupational health and safety risks

– EnviroServ to provide Ener-G personnel with an annual induction on the health and safety risks, the procedures and the PPE.


– Ener-G to undertake all operations work as per Occupational Health and Safety Act and the SLS Operations Manual.

– Smoking only at the designated smoking areas.

– Ener-G to test work sites periodically with a gas instrument. Log to be kept



– During operation.

– Annually

Emergency Response

– Ensure appropriate response to an emergency.

– EnviroServ to provide Ener-G with a copy of the SLS Emergency Response Plan.

– The Ener-G Senior Technician is to ensure on-going awareness of the SLS Emergency Response Plan.

– In the case of an emergency the appropriate response in terms of the SLS Emergency Response Plan should be initiated.

– Such responses are to be tested by means of both scheduled and unscheduled drills.


– Continuous






Incident Management

– To ensure that the impacts of any incident are minimised.

– To prevent the recurrence of repeat incidents.

– Ensure that a response to an incident is implemented within 3 hours from detection.

– Any significant incident, which may cause environmental pollution, health risks or nuisance conditions, must be reported to the DEA within 24 hrs.

– An action plan, detailing the measures to correct and/or prevent the recurrence of such an incident, must be compiled by Ener-G and submitted to DEA within 14 days of the incident.

– During operation, at an incident

– When required

– Within 24hrs

– Within 14 days

– The Senior Technician is to record all incidents and report them to EnviroServ.


– As required

– Monthly

Operation of the Wellfield and Pipeline



– Senior Technician to ensure that all instructions as outlined in Operations Manuals are followed.

– Ener-G must ensure that the site drawings and operations manual reflects the current situation and is updated annually.


– Continuous

– Junior Technician to do:

– Daily balancing of wellfield.

– Daily reading and recording of meters.

– Report any errors or anomalies to Senior Technician.

– Shut down of wellfield if faults are detected.

– Senior Technician to:

– Ensure that faults are repaired timeously.

– Wellfield parameters are in line with specifications.


– Daily







– Weekly inspection of wells, pipelines, joins and valves for performance and physical condition.


– Shut down of wellfield if faults are detected.




– Weekly


– Conduct monthly surveys of the landfill surface to inspect for cracks, opening and settlement.

– Conduct monthly surveys of all key components of the wellfield.


– Prepare monthly performance and compliance audit report.


– Monthly

– Quarterly sampling and analysis of landfill gas (including trace components) to ensure that combustion facility is set to function optimally.


– Quarterly

Water Quality

– Prevent the pollution of any water resource by condensate

– Ensure that all operations remain within the SLS dirty water system

– Store all chemicals and hydrocarbons within bunded area.

– Dispose of the leachate or condensate to the leachate dam.

– Dispose of all wastes to landfill site.


– When required

– Quarterly

Safety

– Minimise the risk of the ignition of the landfill

– Ener-G to ensure that all personnel are appropriately qualified and trained. Only authorised


– As required






gas within the extraction system. personnel to operate, maintain or adjust equipment.

– Smoking only at designated areas at the SLS.

– Confined work sites to be tested with a gas instrument prior to conducting any maintenance or repair work. Log to be kept


– Never work alone in a confined space- always employ the buddy system.

– Minimise the risk of skin damage resulting from contact with condensate.

– Personnel dealing with leachate or condensate to wear appropriate PPE.


– Continuous

– Minimise the chance of offsite accumulation of landfill gas.

– Continue with monitoring of off-site sub-surface probes.

– Existing – As per current schedule

Operation of the Flare, Engine and Generator



– Prevent the venting of uncombusted landfill gas a result of outages.

– Minimise the production of toxic, gaseous compounds during the combustion of landfill gas.

– Senior Technician to ensure that all instructions as outlined in Operations Manuals are followed.

– Ener-G must ensure that the operations manual reflects the current situation and is updated annually.

– No unnecessary venting of unflared landfill gas is allowed.

– Ensure that the flare is functioning optimally at all times.

– Ensure continuous monitoring of gas flow and bulk components to ensure optimal flare functioning and to enable early detection of leaks, fires etc.

– Ensure that rectification, isolation or shutdown of the flare or engine occurs within 3 hours from the detection of an incident.


– Continuous







– Monitoring of flare and engine function.

– Daily reading and recording of meters.


– Shut down of flare or engine if faults are detected.




– Daily


– Weekly inspection of pipelines, joins, valves and sumps for performance and physical condition.


– Shut down of flare or engine if faults are detected.




– Weekly


– Conduct monthly surveys of the landfill surface to inspect for cracks, opening and settlement.

– Conduct monthly surveys of all key components of the wellfield.


– Prepare monthly performance and compliance audit report.


– Monthly

– Conduct emergency shut down tests on the flare, engine and wellfield.

– Conduct sampling of the inlet gases


– Quarterly






– Take action to improve gas quality if issues are detected.

– Conduct detailed analysis of inlet gas (bulk and trace components).

– Conduct sampling and analysis of combustion emissions to confirm emission rates of the criteria pollutants: SO2, NO2 and PM10.

– Use results to refine operating parameters to improve efficiency and reduce emissions.

– Results to be reviewed by air quality specialist in terms of legislation and health-risk guidelines. Need for and frequency of further monitoring to be defined by specialist.


– 6 months after commissioning of gas extraction from Valley 1

– Repeat 6 months after commissioning of gas extraction from Valley 2

Water Quality

– Prevent the pollution of any water resource

– Dispose of the condensate from sumps and traps to the leachate dam.

– Ensure that all engines operate over a drip tray or within a bund.

– Used oils to be sent for recycling.

– Spillages of any contaminant to be contained and the affected area cleaned up.


– When required

Safety

– Minimise the risk of an explosion at the flare

– Minimise health and safety risks

– Ener-G to ensure that all personnel are appropriately qualified and trained.

– Only authorised personnel to operate, maintain or adjust equipment.

– No smoking or fires at the combustion facility.

– Secure the combustion facility in a fenced and access controlled area.

– Danger and safety signs to be erected.

– PPE is compulsory.


– Continuous



10.4 Closure and Rehabilitation

The Landfill Gas to Electricity Project is likely to continue operating for a further 20 or 30 years after the landfill site is closed. It is thus not practical to

prescribe specific closure actions at this stage. Thus only general closure objectives have been proposed.

Table 8: Closure and Rehabilitation Environmental Management Plan Implementation Programme




EMP Responsibility

– To assign roles and responsibilities for the implementation of the Closure EMP.

– Ultimate responsibility for the implementation of and compliance with the Closure EMP rests with EnviroServ.

– From decision to close project

– Continuous


– To ensure that all members of the closure workforce are aware of their responsibilities toward environmental protection and the EMP requirements.

– All personnel involved in the project closure are to undergo environmental induction and awareness training.

– During closure

– At commencement of project closure

Public Relations

– To keep affected parties aware of the project status.

– Notify the monitoring committee of the intended closure.

– Present results of any reports, studies or analyses done for the closure.

– At closure – At Shongweni Landfill Committee Meeting






Landfill Gas Project

General Rehabilitation

– To ensure that all project equipment is dismantled.

– All above ground equipment not required for further function at the SLS must be removed from the site by Ener-G

– Ener-G must ensure that any equipment required to remain is functional.

– Ener-G must rehabilitate areas from where equipment was removed to a state equivalent to the balance of the site.

– At closure


– Prevent the release of landfill gas to the atmosphere during or after closure.

– Removal of landfill gas equipment should only be contemplated if gas production is below levels required to operate equipment.

– Wells or pipes that are left in-situ must be sealed to prevent gaseous emissions.

– At closure

– EnviroServ must investigate and implement alternative measures to manage residual emissions ie passive extractors.

– At closure

Safety

– Ensure that the landfill gas facility does not pose a health or safety risk.

– Ener-G must make the areas from where equipment was removed safe.

– Ener-G must make gas wells safe.

– Any equipment required to remain must be safe.

– Appropriate danger signage must remain.

– At closure



10.5 Financial Provisions

10.5.1 Environmental Monitoring

EnviroServ already undertakes environmental monitoring at the SLS of surface water quality,

aquatic biota, groundwater quality, sub-surface gases and on-site and off-site ambient air quality.

The costs of this monitoring are covered by EnviroServ through the operation of the SLS.

The only additions to the monitoring schedule for the landfill gas to electricity project will be:

• continuous analysis of the bulk components of the inlet landfill gas supply to the flare or

engine during operation;

• detailed analysis of inlet gas composition (bulk and trace gases) 6 months after

commissioning to determine ideal operating parameters; and

• analysis of combustion gases 6 months after commissioning to determine emissions and

refine operating parameters.

It is assumed that after a 6 month period the composition of the gas being drawn from the landfill,

and thus the combustion emissions, will remain relatively constant. There will thus be no need for

regular analysis of the trace component of the inlet gas or combustion emissions. The detailed

analysis of inlet gas and the combustion gas analysis will be repeated 6 months after the

incorporation of gas collection from Valley 2. The results of the detailed gas analysis and the

combustion gas analysis must be subjected to a review in terms of the applicable legislation and

health-risk guidelines by an air quality specialist. The findings will be used to determine the

requirement for and frequency of further monitoring. If compounds of concern are detected at

elevated levels in either the inlet gas or emissions then regular analysis may be warranted. The

cost of this monitoring will be covered by Ener-G as part of the operations cost.

10.5.2 Provision and replacement of infrastructure

All equipment that will be installed at the SLS has been designed for use at landfill gas to

electricity projects and generally has an operational life equivalent to that of the project life. All

equipment will be regularly serviced and maintained as per the supplier’s specifications. Ener-G

will set aside amount of R 289 000 in the annual operations budget for the replacement of

equipment that has aged, failed or been damaged.



10.5.3 Restoration and aftercare

Restoration and aftercare of the SLS will be undertaken by EnviroServ in terms of the SLS permit.

Ener-G will be responsible for the removal of all landfill gas to electricity components once gas

production is insufficient to maintain commercial LFG combustion. Ener-G will remove all above

surface infrastructure from the SLS. Equipment that is underground will remain in situ, provided

that it is buried at least 0.5 m below surface. All pipes and wells will be sealed to prohibit venting

of LFG. Any damages to the cap or vegetation thereon done during the removal of landfill gas to

electricity components will be repaired by Ener-G. Ener-G will set aside an amount of R 100 000

as a provision for the restoration and making safe of the landfill gas to electricity components.

Aftercare of the SLS will remain the responsibility of EnviroServ.


i SYNERGISTICS ENVIRONMENTAL SERVICES

Appendix 1: Minutes and Presentation from the Shongweni Landfill Monitoring

Committee Meeting


ii SYNERGISTICS ENVIRONMENTAL SERVICES

Appendix 2: Proof of Press Advertisements


iii SYNERGISTICS ENVIRONMENTAL SERVICES

Appendix 3: Proof of Site Notices


iv SYNERGISTICS ENVIRONMENTAL SERVICES

Appendix 4: Notification Letter


v SYNERGISTICS ENVIRONMENTAL SERVICES

Appendix 5: Notification Letter Distribution List


vi SYNERGISTICS ENVIRONMENTAL SERVICES

Appendix 6: Registered Interested and Affected Party Database


vii SYNERGISTICS ENVIRONMENTAL SERVICES

Appendix 7: IAP Comments and Responses


viii SYNERGISTICS ENVIRONMENTAL SERVICES

Appendix 8: Air Quality Impact Assessment


ix SYNERGISTICS ENVIRONMENTAL SERVICES

Appendix 9: User and Operations Manuals for the Landfill Gas to Electricity Project at the SLS

User and operations manuals that are referred to in this environmental management plan include:

• Biogas Technical manual - attached;

• Cat Engine user manual – to be supplied on delivery;

• Generator operations manual – to be supplied on delivery; and

• Ener-G Site Operations Manual – Confidential document.

Documents

Landfill Gas to Electricity Project at Shongweni Landfill Sitepravinamar.com/reports/downloads/shongweni_gas_project/LFG at SLS... · iii • a variety of health problems such as