PROPOSED POWER GENERATION PLANT THROUGH THE … Draft EIA Report... · 2019-10-23 · proposed power generation plant through the pyrolysis of abattoir waste, kroonstad, free state

PROPOSED POWER GENERATION

PLANT THROUGH THE PYROLYSIS

OF ABATTOIR WASTE,

KROONSTAD, FREE STATE

DRAFT ENVIRONMENTAL IMPACT

ASSESSMENT (EIA) REPORT

DEA waste licence Ref No: 12/9/11/L1391/2

July 2014

ESCIENCE

ASSOCIATES

(PTY) LTD

POSTAL

ADDRESS:

PO Box 29Saxonwold

2132

PHYSICAL

ADDRESS:

9 Victoria Street

Oaklands

Johannesburg

2192

TEL:

+27 (0)11 728 2683

FAX:

086 512 5681

WEBSITE:

www.escience.co.za

E-MAIL:

[email protected]

DRAFT EIA REPORT

PROPOSED POWER GENERATION PLANT THROUGH THE PYROLYSIS OF ABATTOIR WASTE, KROONSTAD

EScience Associates (Pty) Ltd Page i

ENVIRONMENTAL IMPACT ASSESSMENT REPORT: PROPOSED POWER GENERATION PLANT THROUGH THE PYROLYSIS OF

ABATTOIR WASTE, KROONSTAD, FREE STATE

COMPILED BY EAP:

EScience Associates (Pty) Ltd.

PO Box 2950

Saxonwold

2132

Tel: (011) 728 2683

Fax: 086 610 6703

E-mail: [email protected]

ON BEHALF OF APPLICANT:

Square Root Trading Seven (Pty) Ltd

T/A Country Meat Abattoir

PO Box 1932

Kroonstad

9500

Tel: (056) 631 0120

Fax: (056) 631 0120


PREPARED FOR REVIEW BY COMPETENT AUTHORITY:

National Department of Environment Affairs (DEA)

2nd Floor, North Tower

Fedsure Forum Building

315 Pretorius Street

c/o Pretorious and van der Walt Streets

Pretoria

0001

Tel: (012) 310 3920

Fax: (012) 310 3753

July 2014

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PROJECT INFORMATION SHEET

Project:

PROPOSED POWER GENERATION PLANT THROUGH THE PYROLYSIS OF ABATTOIR WASTE,

KROONSTAD

Project Applicant:

Square Root Trading Seven (Pty) Ltd T/A Country Meat Abattoir

Postal Address: PO Box 1932, Kroonstad, 9500

Tel: (056) 631 0120

Fax: (056) 631 0120


Environmental Assessment Practitioner:

EScience Associates (Pty) Ltd.

Postal Address: PO Box 2950, Saxonwold, 2132

Contact: Tel: (011) 718 6380

Fax: 086 610 6703


Project Leader: Theo Fischer

Competent Authority:

National Department of Environment Affairs (DEA)

Postal Address: 2nd Floor, North Tower, Fedsure Forum Building

315 Pretorius Street, Pretoria, 0001

Contact: Malepo Phoshoko

Tel: (012) 310 3741

Fax: (012) 310 3753

Report history and details:

Report Name and Status: Draft EIA

Draft report issued for public review: July 2014

mailto:[email protected]

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EScience Associates (Pty) Ltd Page iii

EXECUTIVE SUMMARY

Square Root Trading Seven (Pty) Ltd. (hereafter referred to as SRTS) has appointed

EScience Associates (Pty) Ltd. (hereafter referred to as ‘ESA’), as independent

Environmental Assessment Practitioner (EAP), to undertake an Environmental Impact

Assessment (EIA) to assess the environmental feasibility of the proposed establishment

of a power generation plant through the pyrolysis of abattoir waste in Kroonstad, Free

State. ESA was appointed to facilitate the application for obtaining a Waste

Management License and an Atmospheric Emissions Licence for the proposed facility.

The aforementioned application was submitted to the National Department of

Environmental Affairs (DEA) on 14th November 2013, and acknowledged by the DEA

on 22nd November 2013. The application was assigned the reference number

12/9/11/L1391/2. The final scoping report, after having undergone public review, was

submitted to the DEA on 29th May 2014. The DEA accepted the scoping report on 4th

July 2014 and a letter stating the acceptance of the Scoping Report was received by

the EAP on 7th July 2014

The process of pyrolysis involves heating organic materials to greater than 600°C in the

absence of oxygen. The SRTS project will use dewatered abattoir waste that would

otherwise be disposed to landfill. Resulting products are renewable electricity and bio-

char/ pyrolysis ash. Reprocessing /recovery is ranked third out of seven waste

management options in the internationally recognised waste management hierarchy,

after reuse but above recycling. As it is not feasible to reuse abattoir waste, recovery of

energy and other products is most likely to qualify as the Best Practicable

Environmental Option.

The existing abattoir site will be used to house the facility and the waste generated

from the abattoir which is, at present, transported off site to be disposed of at a landfill

disposal site will be fed into the pyrolysis plant so as to produce syngas which will be

utilised in the generation of electricity by means of internal combustion engines. There

will be provisions made for the storage of 40m3 of the dewatered waste on site for

utilisation over weekends. The proposed facility’s primary activities would be as follows:

The separation of water from the abattoir waste through a screw press or similar

mechanical means, thereby separating a large percentage of water from the

waste;

Short term storage of dewatered abattoir waste for processing and generation

of electricity when abattoir is not operational;

The pyrolysis of the abattoir waste for the generation of syngas (heating organic

materials to greater than 600°C in the absence of oxygen); and

Generation of electricity to be used by abattoir through the combustion of

syngas in an internal combustion engine.

The proposed project requires SRTS to undertake several so-called ‘listed’ waste

management activities, which may not commence prior to obtaining a Waste

Management Licence, in terms of Section 20(b) of the National Environmental

Management: Waste Act, 2008 (Act No. 59 of 2008)[NEM:WA]; where Schedule 1 under

NEM:WA (GN. R. 921 of November 2013) provides an inclusionary list of waste

management activities for which licencing is required.

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Due to the nature and/or scale of the activities that would be associated with the

subject waste license application, the NEM:WA requires that the potential

environmental impacts must be considered, investigated, assessed and reported on to

the competent authorities through a Scoping and detailed Environmental Impact

Assessment (EIA) process, as per the relevant provisions of GN. R. 543 of June 2010 as

amended by GN.R 1159 of December 2010 (the so called 2010 NEMA EIA Regulations),

promulgated in terms of Section 24(5) of NEMA. The application was submitted whilst

the waste management activities were listed under GN.R 718 of 2009 which has since

been replaced by GN. R.921 of 29 November 2013.

Waste management activities that will be triggered according to Categories A and B

of Schedule 1 (GN. R.921 of 29 November 2013) to the NEM:WA, are as follows:

Applicable ‘Category A’ (Basic Assessment) Activities:

Category A -

Activity No. 3

(12)

The construction of a facility for a waste management activity listed in

Category A of this schedule (not in isolation to associated waste

management activity).

REASON: The establishment of the facility will require the construction

of structures and infrastructure supporting of the proposed waste

management activities identified above.

Applicable ‘Category B’ (Scoping and EIA) Activities

Category B -

Activity (3)

The recovery of waste including the refining, utilisation, or co-

processing of the waste at a facility that processes in excess of 100

tons of general waste per day or in excess of 1 ton of hazardous waste

per day, excluding recovery that takes place as an integral part of an

internal manufacturing process within the same premises.

REASON: the proposed facility would have the capacity to recover 10

tons of hazardous waste per day in order to generate electricity.

Category B -

Activity (4)

The treatment of hazardous waste in excess of 1 ton per day

calculated as a monthly average; using any form of treatment

excluding the treatment of effluent, wastewater or sewage.

REASON: The pyrolysis of waste is considered treatment.

Category B -

Activity (10)

The construction of facilities for a waste management activity listed in

Category B of this schedule (not in isolation to associated activity).

REASON: The establishment of the facility will require the construction

of structures and infrastructure supporting of the proposed waste


A scoping report was completed in order to identify and discuss issues of potential

environmental significance, and where possible, indicate the significance of those

impacts, so as to inform the scope of the Environmental Impact Assessment (EIA)

phase. The initial identification and assessment of environmental impacts revealed the

following potentially significant environmental aspects which required further detailed

assessment:

Emissions, air quality and odour impact, and

Waste management handling and disposal

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Environmental Impact Assessment aims to ensure effective compliance and

governance concerning the sustainable use of environmental resources, while

simultaneously focusing on key issues such as stakeholder empowerment, providing

access to relevant and concise information to enable informed decision-making. This

EIA Report was compiled through the execution of a methodology set out to produce

a report in compliance with the requirements of Section 31 of GN. R.543 as amended

by GN.R 1159 of December 2010, in terms of Chapter 5 of the National Environmental

Management Act,1998 (Act No. 107 of 1998, as amended)[NEMA].

It is the professional opinion of the EAP that the EIA process undertaken for the project

to date has been procedurally correct, in terms of, inter alia, the requirements outlined

in Government Notice No. 543-546 of June 2010 as amended by GN.R 1159 of

December 2010. The EAP, furthermore, believes that the significant issues that may

potentially be realised through the possible authorisation of the project by the

Competent Authority have indeed been identified to the greatest extent possible /

practical. The EAP also believes that the information provided in this EIA Report was

sufficient /substantive for IAPs to have contributed meaningfully to the EIA process thus

far (as required by Government Notice 543 as amended by GN.R 1159 of December

2010) and for the competent authority (CA) to make an informed decision as to

whether, or not activity should be authorised. It is, therefore, the EAPs recommendation

that the CA approve this activity based on the substantive content provided in the

report itself.

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TABLE OF CONTENTS

EXECUTIVE SUMMARY III

1. INTRODUCTION 1

1.1 BACKGROUND 1 1.2 WHAT IS AN EIA? 5

1.2.1 Scoping and Scoping Report 6 1.2.2 Plan of Study for EIA 8

1.3 DETAILS OF ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP) 9 1.4 RELEVANT AUTHORITIES 9 1.5 CONSULTATION WITH THE COMPETENT AUTHORITY 10

2. OVERVIEW OF CURRENT OPERATIONS 11

2.1 SURFACE INFRASTRUCTURE 11 2.2 CURRENT SITE WATER MANAGEMENT AND SUPPLY 11

2.2.1 water supply 11

3. PROJECT DESCRIPTION 12

3.1 PROPOSED WASTE MANAGEMENT ACTIVITIES 12 3.1.1 Hazardous waste Storage 13 3.1.2 General Waste Storage 13 3.1.3 Treatment and disposal of water seperated from waste 13 3.1.4 Pyrolysis of waste for generation of Syngas 13

3.2 PROPOSED ELECTRICITY GENERATION 14 3.2.1 .Gas clean-up system 14

3.3 THE USE OF ASH AS FERTILISER & SOIL ADDITIVE 14

4. ALTERNATIVES 16

4.1 SITE ALTERNATIVES 16 4.2 PROCESS/TECHNOLOGY ALTERNATIVES 17

4.2.1 Non-Thermal WTE Alternatives 17 4.2.2 Thermal WTE alternatives 18

4.3 LAYOUT, DESIGN OR SCALE ALTERNATIVES 22 4.4 OPERATION AND SCHEDULING ALTERNATIVES 22 4.5 NO-GO ALTERNATIVE 22

5. LEGAL AND POLICY FRAMEWORK 23

5.1 NATIONAL ENVIRONMENTAL MANAGEMENT ACT (NEMA) 23 5.1.1 Duty of Care 24

5.2 WASTE MANAGEMENT AND LICENSING 25 5.2.1 Definition of Waste 25 5.2.2 WASTE MANAGEMENT LICENSING 26

5.3 WASTE CLASSIFICATION 30 5.4 AIR QUALITY AND LICENSING 32 5.5 OTHER RELEVANT LEGISLATION TO BE CONSIDERED 38

5.5.1 National Water Act 38 5.5.2 OCCUPATIONAL HEALTH AND SAFETY 38 5.5.3 The Noise Control Regulations 39 5.5.4 National Heritage Resources Act 39 5.5.5 Access to information 39

6. PUBLIC PARTICIPATION 41

6.1 PUBLIC PARTICIPATION PROCESS FOR SCOPING PHASE 41 6.1.1 Participation Process 41

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6.1.2 Comments and issues 42 6.2 PUBLIC PARTICIPATION PROCESS FOR EIA PHASE 42

6.2.1 Participation Process 42 6.2.2 Key dates 42

7. DESCRIPTION OF THE RECEIVING ENVIRONMENT 43

7.1 LOCATION, LAND-USE AND ZONING 43 7.2 CLIMATE 44

7.2.1 Temperature 44 7.2.2 Rainfall 44 7.2.3 Wind 45

7.3 TOPOGRAPHY 46 7.4 GEOLOGY AND SOILS 46 7.5 FAUNA AND FLORA 46 7.6 SURFACE WATER 47

7.6.1 Surface water quality 47 7.7 GROUNDWATER 49

7.7.1 Aquifer characterisation 49 7.8 GROUNDWATER QUALITY 50 7.9 AMBIENT AIR QUALITY 50

8. IMPACT ASSESSMENT METHODOLOGY 52

8.1 INTRODUCTION 52 8.2 TYPE OF IMPACTS 54 8.3 DETERMINING SIGNIFICANCE 55

8.3.1 Nature 55 8.3.2 Extent 55 8.3.3 Duration 55 8.3.4 Intensity 56 8.3.5 Probability 56 8.3.6 Mitigation or Enhancement 56 8.3.7 Reversibility 58

8.4 CALCULATING IMPACT SIGNIFICANCE 58 8.5 UNDERSTANDING IMPACT SIGNIFICANCE 59

9. IMPACT SIGNIFICANCE ASSESSMENT/ANALYSIS 61

9.1 INDICATORS OF POTENTIAL IMPACT SIGNIFICANCE 61 9.2 CONSTRUCTION PHASE 62

9.2.1 Noise 63 9.2.2 Biodiversity 65 9.2.3 Construction and installation waste generation (contribution to landfill) 65 9.2.4 Groundwater and Surface water quality 67 9.2.5 Air quality 68

9.3 OPERATIONAL PHASE 70 9.3.1 Noise 70 9.3.2 Groundwater Pollution 72 9.3.3 Air quality 74 9.3.4 Socio Economic 79

10. ASSESSMENTS OF CUMULATIVE IMPACTS 80

11. CONCLUSIONS AND EAP RECOMMENDATIONS 81

11.1 IN SUMMARY 81 11.2 CONCLUSIONS 81

11.2.1 Construction 81 11.2.2 Operation 81

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12. REFERENCES 83

APPENDIX 1: AUTHORITY CORRESPONDENCE 84

APPENDIX 2: WASTE MANAGEMENT LICENSE APPLICATION FORM 85

APPENDIX 3: LAYOUT PLAN FOR PROPOSED STRUCTURES AND INFRASTRUCTURE 86

APPENDIX 4: PUBLIC PARTICIPATION DOCUMENTATION 87

APPENDIX 5: SCOPING REPORT 88

APPENDIX 6: EAP CV’S 89

APPENDIX 7: AIR QUALITY IMPACT ASSESSMENT 90

APPENDIX 8: WASTE ASSESSMENT 91

APPENDIX 9: ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT 92

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LIST OF FIGURES

Figure 1-1: Regional Locality ....................................................................................................... 3 Figure 1-2: Satellite Image of the SRTS abattoir and surrounding land-use ......................... 4 Figure 1-3: Fezile Dabi District Municipality ............................................................................... 5 Figure 1-4: Generic Scoping and EIA Process Flow Diagram ................................................ 7 Figure 3-1: Overview of proposed operations ....................................................................... 15 Figure 4-1: Anaerobic Digestion WTE Plant ............................................................................. 17 Figure 4-2: Incineration .............................................................................................................. 18 Figure 4-3: Plasma arc gasification WTE plant ....................................................................... 19 Figure 4-4: Thermal Depolymerisation (TDP) plant (adapted from Cutting Edge, 2006) . 20 Figure 4-5: Gasification WTE Plant ............................................................................................ 21 Figure 5-1: Scoping and EIA Process for Waste Licensing .................................................... 29 Figure 5-2: Interrelationship between the EIA and AEL Processes....................................... 37 Figure 7-1: Annual Wind Rose Kroonstad SAWS station from 2005-2008. ........................... 45 Figure 7-2: Topographical map ............................................................................................... 46 Figure 7-3 Middle Vaal Water Management Area ............................................................... 48 Figure 7-4: Highveld and Vaal Triangle Priority Areas ........................................................... 51 Figure 9-1: Predicted PM10 maximum 24-Hour average ambient concentration for the

Proposed Waste to Energy Project .................................................................................. 75 Figure 9-2: Predicted SO2 maximum hourly average ambient concentration for the

Proposed Waste to Energy Project .................................................................................. 76 Figure 9-3: Predicted NOx hourly maximum ambient concentration for the Proposed

Waste to Energy Project .................................................................................................... 77 Figure 9-4: Predicted CO hourly maximum ambient concentration for the Proposed

Waste to Energy Project .................................................................................................... 78

LIST OF TABLES

Table 1-1: Details of the EAPs ..................................................................................................... 9 Table 1-2: Authority Consultation ............................................................................................. 10 Table 5-1: EIA Activities .............................................................................................................. 24 Table 5-2: NEMWA Listed Waste Management Activities at the time of Application,

listed under GN R.718 ......................................................................................................... 27 Table 5-3: NEMWA Listed Waste Management Activities listed under GN R.921 ............. 28 Table 5-4: Waste type classification of waste according to concentration thresholds

from the national norms and standards (23 August 2013) ........................................... 30 Table 5-5: Landfill requirements based on waste type from the national norms and

standards (23 August 2013) ............................................................................................... 30 Table 5-6: Category 8: Thermal Treatment of Hazardous and General Waste................. 33 Table 6-1: Key Dates in EIA Phase ............................................................................................ 42 Table 7-1 Aerial over view of Square Root Trading Seven (Pty) Ltd (Google) .................. 43 Table 7-2 Average monthly rainfall (mm) for Kroonstad ...................................................... 44 Table 8-1: Selected Definitions of Significance ...................................................................... 53 Table 8-2: Scoring for Significance Criteria............................................................................. 58 Table 8-3: Final Significance Scoring ....................................................................................... 59 Table 9-1: Impacts on Ambient Noise Levels (Construction) ............................................... 64 Table 9-2: Impacts on biodiversity (Construction) ................................................................. 65 Table 9-3: Impacts of Construction Waste Generation (Construction)............................. 66 Table 9-4: Impacts on Water Resource Quality (Construction) ........................................... 67 Table 9-5: Impacts on Air Quality (Construction) .................................................................. 69

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Table 9-6: Impacts on Ambient Noise Levels (Operation) ................................................... 71 Table 9-7: Impacts on Water Resource Quality (operation) ................................................ 72

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ABBREVIATIONS

AQIA Air Quality Impact Assessment

DEA Department of Environmental Affairs

DWA Department of Water Affairs

ECA Environment Conservation Act, Act No. 73 of 1989

EIA Environmental Impact Assessment

EIR Environmental Impact Report

EMP Environmental Management Plan

IAPs Interested and Affected Parties

IDP Integrated Development Plan

IPWM Integrated Pollution and Waste Management

NEMA National Environmental Management Act, Act No. 107 of 1998

NEMA EIA

Regulations Regulations GN R.543, R.5444, 545 and R.546 (18 June 2010), as amended

by GN.R 1159 of December 2010, promulgated in terms of Section 24(5) read with

Section 44, and Sections 24 and 24D of the National Environmental Management Act,

1998

NEMAQA National Environment Management: Air Quality Act, Act No. 39 of 2004

NEMWA National Environmental Management: Waste Act, Act No. 59 of 2008

NWA National Water Act, Act No. 36 of 1998

POSEIA Plan of Study for EIA

SR Scoping Report

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DEFINITIONS Alternative - A possible course of action, in place of another, that would meet the same

purpose and need defined by the development proposal. Alternatives considered in the

EIA process can include location and/or routing alternatives, layout alternatives, process

and/or design alternatives, scheduling alternatives or input alternatives.

Aspect – Element of an organisation’s activities, products or services that can interact with

the environment.

Auditing - A systematic, documented, periodic and objective evaluation of how well the

environmental management plan is being implemented and is performing with the aim of

helping to safeguard the environment by: facilitating management control which would

include meeting regulatory requirements. Results of the audit help the organisation to

improve its environmental policies and management systems.

Contamination - Polluting or making something impure.

Corrective (or remedial) action - Response required to address an environmental problem

that is in conflict with the requirements of the EMP. The need for corrective action may be

determined through monitoring, audits or management review.

Degradation - The lowering of the quality of the environment through human activities, e.g.

river degradation, soil degradation.

Environment - Our surroundings, including living and non-living elements, e.g. land, soil,

plants, animals, air, water and humans. The environment also refers to our social and

economic surroundings, and our effect on our surroundings.

Environmental Impact Assessment (EIA) - An Environmental Impact Assessment (EIA) refers

to the process of identifying, predicting and assessing the potential positive and negative

social, economic and biophysical impacts of a proposed development. The EIA includes

an evaluation of alternatives; recommendations for appropriate management actions for

minimising or avoiding negative impacts and for enhancing positive impacts; as well as

proposed monitoring measures.

Environmental Management System (EMS) - Environmental Management Systems (EMS)

provide guidance on how to manage the environmental impacts of activities, products

and services. They detail the organisational structure, responsibilities, practices,

procedures, processes and resources for environmental management. The ISO14001 EMS

standard has been developed by the International Standards Organisation.

Environmental policy - Statement of intent and principles in relation to overall

environmental performance, providing a framework for the setting of objectives and

targets.

Hazardous waste – Waste, even in small amounts, that can cause damage to plants,

animals, their habitat and the well-being of human beings, e.g. waste from factories,

detergents, pesticides, hydrocarbons, etc.

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Impact - A description of the potential effect or consequence of an aspect of the

development on a specified component of the biophysical, social or economic

environment within a defined time and space.

Infrastructure - The network of facilities and services that are needed for economic

activities, e.g. roads, electricity, water, sewerage.

Integrated Environmental Management (IEM) - A way of managing the environment by

including environmental factors in all stages of development. This includes thinking about

physical, social, cultural and economic factors and consulting with all the people affected

by the proposed developments. Also called "IEM".

Mitigation - Measures designed to avoid, reduce or remedy adverse impacts on the

environment.

Proponent – Entity which applies for environmental approval and is ultimately accountable

for compliance to conditions stipulated in the Environmental authorisation (EA) and

requirements of the EMP.

Resources - Parts of our natural environment that we use and protect, e.g. land, forests,

water, wildlife, and minerals.

IAPS / Stakeholders - A sub-group of the public whose interests may be positively or

negatively affected by a proposal or activity and/or who are concerned with a proposal

or activity and its consequences. The term includes the proponent, authorities and all

interested and affected parties.

Waste Management – Classifying, recycling, treatment and disposal of waste generated

during construction, operation and decommissioning activities.

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1. INTRODUCTION

1.1 BACKGROUND Square Root Trading Seven (Pty) Ltd. (hereafter referred to as SRTS) has appointed

EScience Associates (Pty) Ltd. (hereafter referred to as ‘ESA’), as independent

Environmental Assessment Practitioner (EAP), to undertake an Environmental Impact

Assessment (EIA) to assess the environmental feasibility of the proposed establishment of a

power generation plant through the pyrolysis of abattoir waste in Kroonstad, Free State.

ESA was appointed as independent EAP to conduct the scientific investigations of the EIA,

and to facilitate the associated legal and administrative processes required to obtain the

necessary Environmental Authorisations (namely a Waste Management Licence, and an

Atmospheric Emissions Licence) for the proposed facility.

The aforementioned application was submitted to the National Department of

Environmental Affairs (DEA) on 14th November 2013, and acknowledged by the DEA on

22nd November 2013. The application was assigned the reference number

12/9/11/L1391/2. The final scoping report, after having undergone public review, was

submitted to the DEA on 29th May 2014. The DEA accepted the scoping report on 4th July

2014 and a letter stating the acceptance of the Scoping Report was received by the EAP

on 7th July 2014

SRTS presently operates an abattoir on 22 11th Avenue, Kroonstad, Free State and intends

to establish the pyrolysis plant on this site. The site lies on the outskirts of Kroonstad Industria.

Refer to Figure 1-1 to Figure 1-3.

• The site currently hosts the Country Meat abattoir capable of slaughtering 200

animals per day.

• The abattoir buys feedlot cattle on a daily basis for slaughter from various farmers

and feedlots in and around Kroonstad.

• The property is approximately 2.4 ha in extent, and the total existing infrastructure

coverage (buildings, offices, workshops etc.) on-site occupies approximately 50% of

the site.

• The area on which the proposed facility is to be constructed is roughly 60m2.

High cost of energy and the potential to recover energy through improved waste

management coupled to this is the high cost of transporting the abattoir waste to suitable

landfills has led to SRTS exploring alternative, more sustainable means of dealing with the

abattoir waste it generates as part of it operations.

The proposed development, if implemented, would act towards solving some significant

issues currently facing South Africa; such as the current power crisis, the retrieval of

material and energy value from waste, reduction of waste to landfill, reducing of

hazardousness of waste before disposal.

The existing abattoir site will be utilised for the waste to energy facility and the waste

generated from the abattoir which is, at present, transported off site to be disposed of will

be fed into the pyrolysis plant. The pyrolysis technology will utilise abattoir waste to

produce synthetic gas (syngas) for use in a gas engine for power generation (guaranteed

0.12 MW). Pyrolysis involves heating organic materials to temperatures greater than 350 °C

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in the absence of oxygen. Under these conditions, the abattoir waste is decomposed and

a large portion of the dry mass is volatilised to produce syngas with the remaining solids

converted into a char product. The syngas generated in the pyrolysis phase will then be

sent to a generator for electricity generation. Additionally provision will be made for

storage of 40m3 of abattoir waste on site. The proposed facility’s primary activities would

be as follows:

• Storage of abattoir waste;

• The drying of abattoir waste in a centrifuge, thereby separating a large

percentage of water from the waste;

• The generation of syngas through the pyrolysis of the abattoir waste; and

• Generation of electricity from the syngas which is to be used by abattoir

The proposed project concerns renewable energy generation and will be bid in terms of

the Department of Energy Small Renewables Bid programme.

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Figure 1-1: Regional Locality

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Figure 1-2: Satellite Image of the SRTS abattoir and surrounding land-use

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Figure 1-3: Fezile Dabi District Municipality

1.2 WHAT IS AN EIA?

The International Association for Impact Assessment (IAIA) defines an environmental

impact assessment as "the process of identifying, predicting, evaluating and mitigating

the biophysical, social, and other relevant effects of development proposals prior to major

decisions being taken and commitments made.” Environmental Impact Assessment (EIA)

in South Africa is predominantly undertaken in response to, and within the bounds of, a

well-defined and robust legal framework. A myriad of ‘environmental’ Acts, Regulations,

Policies and Guidelines have relevance in this regard (Section 5 refers), all of which aim at

giving effect to the fundamental environmental rights enshrined upon all South African

Citizens within section 24 of the constitution, 1996 (Act No. 108 of 1996).

An EIA is a methodical and systematic process to identify potential positive and negative

impacts on the bio-physical, socio-economic and /or cultural environment that may result

from an activity (i.e. opencast mining operations in this instance). The minimum

requirements for EIA practice in South Africa are largely prescribed in Regulations (GN. R.

543 of June 2010 as amended by GN.R 1159 of December 2010) under the National

Environmental Management Act (Act N0. 107 of 1998) [NEMA]. The NEMA EIA Regulations

lay out clear enviro-legal administrative requirements for EIA process, public participation

(stakeholder engagement) and reporting alike.

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The EIA aims to ensure effective compliance and governance concerning the sustainable

use of environmental resources, while simultaneously focusing on key issues such as

stakeholder empowerment, and providing access to relevant and concise information to

enable informed decision-making by competent authorities exercising a regulatory role in

any aspect of the project proposal.

The EIA process is also used to examine alternatives and management measures to

minimise negative- and optimise positive impacts resulting from a project, or activity. The

ultimate objectives of the EIA process are to prevent significant detrimental impact on the

environment and to ensure sustainable development into the future. An EIA should not

aim to stop, hinder or obstruct development, but should rather act as a ‘green-filter’ to

development proposals, that seeks to ensure that developments / activities proceed in an

environmentally acceptable and sustainable manner (unless of course significant impact

may result from an activity that truly renders the undertaking of that activity ‘fatally

flawed’).

The EIA has to consider the different perspectives and requirements of all role players, who

derive different benefits from participating in the EIA process. These include the following:

Decision-making Authorities:

Enables informed decision making

Ensuring protection of environmental quality

Supporting the management, monitoring and sustainable utilisation of resources

Understanding demands on bulk services, waste disposal sites, etc.

Project proponents:

Pro-actively considering environmentally sustainable design and management

principles in all that they undertake

Investigating natural resource opportunities and constraints

Identifying the risks and opportunities associated with environmental and

operational aspects

Evaluating the potential for pollution and the prevention thereof

Optimising energy, water and other resource use

Interested and affected parties (IAPs):

Providing an opportunity to be informed and give comment/express concerns

Protecting environmental rights

Utilising local and indigenous knowledge

Increasing knowledge and environmental awareness

Informing the decision-making process

1.2.1 SCOPING AND SCOPING REPORT

The ‘Scoping and EIA’ process prescribed in the 2010 NEMA EIA Regulations (GN. R. 543 of

June 2010 as amended by GN.R 1159 of December 2010), as the name suggests, is

divided into two main phases. These are the initial ‘scoping’ and the subsequent ‘EIA

phase’ (Figure 1-4). The scoping phase of this environmental assessment sought to identify

the key issues and potential impacts, from the project proposal that warranted further

detailed investigation during the EIA phase of the process.

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Figure 1-4: Generic Scoping and EIA Process Flow Diagram

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The preceding scoping report thus resulted in the establishment of the technical terms of

reference (ToR), in the form of a Plan of Study for EIA (PoSEIA,) for this EIA phase.

1.2.2 PLAN OF STUDY FOR EIA

A methodology for specialist study has been developed; this is referred to as a plan of

study for EIA. This has been formulated to meet the requirements for a Plan of Study for

Environmental Impact Assessment (EIA) as set out in regulation 29.1(i) of GN R.385,

promulgated in terms of chapter 5 of the National Environmental Management Act (Act

No. 107 of 1998) (Full Plan of Study for EIA can be found in Appendix 5: Scoping Report.

The following key aspects were identified be informed by specialist study (and are

addressed in respective specialist studies):

Air quality impact assessment: to study criteria pollutants emitted by various

sections of the proposed site operations with focus on pyrolysis plant, so as to allow

specification of emissions abatement technology and plant parameters (e.g. stack

height) and ensure that no odour impacts result, based on the DEA Guideline to Air

Dispersion Modelling for Air Quality Management; and

Waste treatment and disposal process assessment: to investigate requirements for

waste handling, storage, treatment and disposal.

Also it was determined during the Scoping phase that operational control and

monitoring of the facility will be required to ensure that impacts are minimised as

follows (and is addressed in Appendix 9: Environmental Management Programme

Report)

The identification and initial assessment of environmental aspects revealed the following

potentially significant environmental aspects are assessed in further detail in this EIA-

phase:

Operational and Environmental Management and Monitoring: to assess the

adequacy of operational plans and developing environmental management and

monitoring plans adequate to ensure potentially significant impacts do not realise

from the site.

The PoSEIA was used as the basis for defining the nature and extent of the investigations

and specialist assessments undertaken as part of the EIA phase. This impact significance

assessment thus involves the execution of those ToR; where it aims to assess in detail, and

quantify as far as possible, the significance (in respect of the nature, duration, extent,

intensity and probability of occurrence thereof) of the identified environmental impacts

posed by the proposed project.

One needs to, however, bear in mind that the natural environment is the most threatened

and irreplaceable resource upon which all the other human aspects depend. The analysis

of impact significance for potential project impacts, furthermore, needs to consider

impacts that may be realised through all project phases, as follows:

Construction/establishment

Operation

Decommissioning and closure

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Impact analysis is, in a sense, the core of the EIA process. It is the phase where all relevant

project information that has been gathered is manipulated and distilled – it is the

Environmental Impact Assessment. The impact analysis has two major goals, starting with

listing and describing all possible environmental impacts and then proceeding to give

some perspective on the relative significance of the various impacts. The predicted

effects of mitigation measures also need to be factored into the impact analysis.

1.3 DETAILS OF ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP)

The EIA for this application was undertaken by EScience Associates (Pty) Ltd., as

independent Environmental Assessment Practitioners (EAP). The study team was led by Mr.

T. Fischer, senior environmental scientists with more than 10 years’ experience in

environmental management (see Appendix 6: EAP CV’s). Brief details of the key

consultants are shown in the table below.

Table 1-1: Details of the EAPs

Name Qualification

Theo Fischer BSc Natural Science

Sam Leyde BSc (Mechanical Engineering)

1.4 RELEVANT AUTHORITIES

The site is located within the jurisdiction of the Moqhaka Local Municipality within the Free

State Province. Authorities with jurisdiction in the application are as follows:

• NEMWA: Due to application concerning the processing of hazardous waste, the

competent authority in terms of this waste license application is the national

Department of Environmental Affairs (DEA).

• NEMAQA: The atmospheric emissions licensing authority resides with the Fezile Dabi

District Municipality.

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1.5 CONSULTATION WITH THE COMPETENT AUTHORITY

Table 1-2: Authority Consultation

Process Phase Details Date

Application Lodge application and declaration of

interest

14th November 2013

Receive confirmation of application 22nd November 2013

Scoping Lodge Scoping Report (Including Plan of

Study for EIA)

29th May 2014

Consideration of Scoping Report and

PoS for Environmental Impact

Assessment

May, June, July 2014

Receive confirmation of acceptance of

Scoping Report and PoSEIA

7th July 2014

EIR Lodge Environmental Impact

Assessment Report

Not yet completed

Receive confirmation of acceptance of

EIR

Not yet completed

Decision on application Not yet completed

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2. OVERVIEW OF CURRENT OPERATIONS

The site is located at 22 11th Avenue, Kroonstad, Free State in an industrial area named

Kroonstad Industria.

The site currently hosts the Country Meat abattoir capable of slaughtering 200

animals per day.

The abattoir buys feedlot cattle on a daily basis for slaughter from various farmers

and feedlots in and around Kroonstad.

The property is approximately 2.4 ha in extent, and the total existing infrastructure

coverage (buildings, offices, workshops etc.) on-site occupies approximately 50%

of the site.

The area on which the proposed facility is to be constructed is roughly 60m2.

2.1 SURFACE INFRASTRUCTURE The total existing infrastructure on site including concrete slabs, roofed warehouses/sheds,

storm water management infrastructure, administrative buildings, access and internal

road network, etc. occupies approximately 1.2 ha of the 2.4 ha site. The proposed Waste

to Energy (WTE) facility to be constructed is roughly 60m2.

2.2 CURRENT SITE WATER MANAGEMENT AND SUPPLY

2.2.1 WATER SUPPLY

Water is released from Serfontein Dam to the Vals River, where it is pumped to Bloemhoek

Dam which supplies water to Kroonstad. 30 % of the total water utilised by the abattoir

originates from this water source.

Municipal water (30%) and borehole water (70%) supply is used for all operations and

processes. The abattoir currently uses 400 000 L of water per day, a large portion of this is

for the cleaning of abattoir floors.

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3. PROJECT DESCRIPTION

The proposed facility will utilise the waste products from the abattoir to generate

electricity. Waste streams, which will predominantly be comprised of blood and paunch

contents but also include condemned carcasses, will be processed though dewatering

and then either fed directly into the pyrolysis plant or stored in a dedicated cold room

prior to being fed into the pyrolysis plant.

The waste will be dewatered down to a 10% moisture content through the use of a screw

press and then pyrolysed to form syngas. The syngas will then be combusted in an internal

combustion engine to generate electricity to be used by the facility itself. Figure 3-1 shows

an overview of the proposed operations. The following sections provide an overview of

the proposed activities envisaged at the site.

3.1 PROPOSED WASTE MANAGEMENT ACTIVITIES

Waste management activities that will be triggered according to Categories A and B of

Schedule 1 (GN. R.921 of 29 November 2013) to the NEM:WA, are as follows:


Category A -

Activity No. 3

(12)




REASON: The establishment of the facility will require the construction of

structures and infrastructure supporting of the proposed waste



Category B -

Activity (3)

The recovery of waste including the refining, utilisation, or co-processing

of the waste at a facility that processes in excess of 100 tons of general

waste per day or in excess of 1 ton of hazardous waste per day,

excluding recovery that takes place as an integral part of an internal

manufacturing process within the same premises.



Category B -

Activity (4)

The treatment of hazardous waste in excess of 1 ton per day calculated

as a monthly average; using any form of treatment excluding the

treatment of effluent, wastewater or sewage.


Category B -

Activity (10)






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3.1.1 HAZARDOUS WASTE STORAGE

The pyrolysis plant is to be run continuously while the abattoir is only operational from

Monday to Friday. In order for the pyrolysis plant to be run over weekends and public

holidays a stockpile of the abattoir waste will need to be to be created. This stockpile of

abattoir waste will be stored on site in a dedicated cold room. The proposed facility

would thus act as a temporary storage facility for this hazardous waste prior to the

recovery thereof. The system will be designed in a “first in, first out” manner so that no

waste is left in storage for too long a period.

3.1.2 GENERAL WASTE STORAGE

Ash will be generated during the pyrolysis process. This will be stored on site until such time

that it has accumulated to a point that is economically feasible to be transported away

from site and disposed of at a licensed disposal facility.

3.1.3 TREATMENT AND DISPOSAL OF WATER SEPERATED FROM WASTE

The abattoir waste will need to be dewatered down to a moisture content of roughly 10%.

This will be achieved by means of a screw press. This water will then be treated to an

acceptable quality before being discharged to the sewer. Output will be approximately

4440 litres per day or 1620 cubic metres per year.

3.1.4 PYROLYSIS OF WASTE FOR GENERATION OF SYNGAS

The abattoir waste will go through a process called pyrolysis. Pyrolysis involves the thermal

conversion of carbonaceous material into solid, liquid and gaseous fuels in the absence of

oxygen at temperatures above 220 degrees Celsius. Biomass materials (including abattoir

waste) are typical pyrolysis feed materials, others include other waste streams including

plastics and rubbers each resulting in different products.

There are two types of pyrolysis technologies namely, fast pyrolysis and slow pyrolysis. Fast

pyrolysis takes place at moderate temperatures (450°C – 550°C) and requires feedstock

with a moisture content of less than 10% as well as smaller feedstock particle sizes. In slow

pyrolysis feedstock is converted into primarily char under low temperatures and over long

residence times. Unlike, fast pyrolysis, the feedstock does not require drying or size

reduction prior to pyrolysis.

The products of pyrolysis include syngas and a solid residue called char. Syngas is a

mixture of gases with high proportion of carbon monoxide, hydrogen and methane. This

also contains condensable oils, waxes and tars. Syngas has a high calorific value allowing

it to be used directly in an internal combustion engine for electric power generation as

described previously.

Thermal treatment of waste requires an Atmospheric Emission Licence. The required air

emission standards set in terms of the NEMAQA S21 Minimum Emission Standards published

in Notice No. 893 in Government Gazette 37054 of 22 November 2013 will have to be met

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3.2 PROPOSED ELECTRICITY GENERATION

The gas produced from pyrolysis is to be fed into an internal combustion engine where it is

combusted. This engine will in turn power a generator that is to generate 0.13MW

electricity which will be utilised by the plant itself. The proposed project will be bid in terms

of the Department of Energy Small Renewables Bid programme.

3.2.1 .GAS CLEAN-UP SYSTEM

Before the gas is combusted in the turbine it is required to be cleaned, to remove

substances such as sub-micron particulate matter, tars, ammonia and acid gases, as

these substances will have a detrimental effect on the operation of the turbine. The gas is

to be cleaned in a scrubber as well as tar and oil condensers. The removed substances

are then to be returned to the pyrolyser, while the removed ash is to be stored and

subsequently disposed of at a licensed disposal facility

3.3 THE USE OF ASH AS FERTILISER & SOIL ADDITIVE

The bio-char/ pyrolysis ash is high in fertiliser and carbon as well as other micronutrients

derived from blood, bone and other abattoir waste materials. The -char/ pyrolysis ash will

likely qualify as an “organic fertiliser” in terms of Fertilizers, Farm Feeds, Agricultural

Remedies and Stock Remedies Act No. 36 of 1947 ) FFARSRA ) and Regulation 75 of 8

February 2013 (Regulations relating to the production and registration of fertilizers).

The first issue of the scoping report for public review (Date: 14 March 2014) indicated the

intent to utilise char/ pyrolysis ash for use as a soil conditioner/ fertiliser and included

proposed methodology for comprehensive bio-char/ pyrolysis ash analyses and green

house plant potting trials to determine whether the material meets the requirements of a

fertiliser in terms of.

Note that due to a lack of adequate volumes of bio-char/ pyrolysis ash as well as

compositional differences in the bio-char/ pyrolysis ash produced by pilot plant and that

which is expected from the full plant, this component of the study has been removed. The

investigation into the suitability of the into the suitability of the ash in terms of FFARSRA

Regulations will now be undertaken once the plant is operational and producing

representative bio-char/ pyrolysis ash for evaluation.

In the case that the ash is not used a fertiliser it will be considered a waste and the

bio-char/ pyrolysis ash to be disposed of will need to be assessed before disposal as

is regulated in terms of:

o GN 635:2013 – National Norms and Standards for the Assessment of Waste for

Landfill Disposal; and

o GN 636:2013 – National Norms and Standards for Disposal of Waste to Landfill

If the bio-char/ pyrolysis ash is shown to meet the requirements of a fertiliser then in

terms of FFARSRA it will be considered a product and not a waste.

If the bio-char/ pyrolysis ash does not meet the requirements for a fertiliser in terms

of FFARSRA but is demonstrated to be beneficial in application to land, then DEA

will be approached with respect to licensing requirements.

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Figure 3-1: Overview of proposed operations

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4. ALTERNATIVES

The requirement for consideration of development alternatives were introduced into

South Africa’s ‘environmental’ legislation to encourage developers, ‘industry’ and

‘mining’ to consider different ways of doing things that would have different

environmental impacts, whilst still achieving the development goal. The ultimate goal

of consideration of alternatives is to both reduce negative environmental impacts and

to increase or introduce positive environmental impacts.

Typical factors assessed for evaluating alternatives include:

financial feasibility

environmental impact

socio-economic impact

land use planning

future expansion of the operations

logistical constraints – power, water, raw materials, labour, market, etc.

Alternatives can take the form of relatively small adjustments to an operation, in which

case they blur into mitigation, or totally different activities, depending on how widely

the development goal has been stated. Generally, whatever the scale of the

alternative, they are grouped into various types, including the following main groups

(after DEAT, 2004):

location or routing alternatives

activity or process alternatives

layout, design or scale alternatives

operational or scheduling alternatives

no-go alternative

The role of assessing alternatives in the EIA process is to reach the most desirable

outcome for all parties involved in and affected by the proposed project. Having

alternatives allows the comparison and selection of the best option, considering the

pro’s, con’s and costs of each of those alternatives. Ultimately, the alternative that

minimises negative impacts and maximises benefits should be the chosen one

(provided that the chosen alternative is economically feasible).

4.1 SITE ALTERNATIVES

For practical purposes, the proposed project must be undertaken within proposed

existing SRTS site. The abattoir already exists on the site and the space required for the

proposed facility is available on the site.

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4.2 PROCESS/TECHNOLOGY ALTERNATIVES

There are various process alternatives which may be considered for waste to energy.

4.2.1 NON-THERMAL WTE ALTERNATIVES

Non-Thermal WTE involves the conversion of waste into combustible gases such as

methane, methanol or synthetic fuel which can be used to generate electricity.

Technically feasible technologies for this type of application include:

Anaerobic digestion

Mechanical Biological Treatment (MBT)

Anaerobic Digestion

Anaerobic digestion is a biological decomposition of biodegradable waste in the

absence of oxygen. The products of this process include biogas which contains high

proportions of methane with much of the remainder being carbon dioxide and

digestate which contains fibre and liquor. The biogas can be used directly in engines

for combined heat and power (CHP) generation or treated to remove CO2 and then

be used as a fuel in gas turbines or be combusted to generate heat. The digestate

which may contain valuable nutrients such as nitrogen and potassium can be used as

a renewable fertilizer or a soil conditioner. Figure 4-1 shows a typical anaerobic digester

WTE plant.

Figure 4-1: Anaerobic Digestion WTE Plant

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4.2.2 THERMAL WTE ALTERNATIVES

Thermal WTE involves the conversion of waste into electricity or heat by combustion or

heating the waste without the presence of oxygen. Technically feasible technologies

for this type of application include:

Incineration

Plasma arc gasification

Thermal Depolymerisation (TDP)

Gasification

Pyrolysis

Incineration

Incineration involves the combustion of un-sorted waste using excess air at

temperatures exceeding 850oC. In this process waste is converted into primarily ash

and flue gas which contains a wide variety of gases depending on the waste.

Incineration is an attractive option for waste reduction mostly because it can reduce

the volume of waste by 80% to 95% thereby decreasing demand for landfill space. This

process also releases more of the available energy relative to pyrolysis and gasification.

This energy can be used to generate electricity through a steam turbine as depicted in

Figure 4-2. Various other thermal electricity cycles may also be used e.g. organic

rankine cycle, open or combined cycle gas turbines etc. The main disadvantages of

waste incineration are the high capital and operational costs. It is estimated that 35%

of the cost is attributed to mitigating emissions (Rand, Haukohl, and Mauxen, 2000).

Figure 4-2: Incineration

Plasma arc gasification

Plasma arc gasification involves the use of plasma torches to convert waste into syngas

which can be used as a fuel to generate electricity through a gas turbine. In this

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process waste is converted into syngas and slag at extremely high temperatures

(2800oC – 4400oC).

Plasma gasification accepts different feedstock such as biomass, tires, hazardous

waste, MSW etc.

Plasma gasification provides a number of key benefits:

Superior energy output - It unlocks the greatest amount of energy from waste

relative to the other technologies considered herein

Feed material flexibility - Feedstock can be mixed, such as municipal solid

waste, biomass, tires, hazardous waste, and auto shredder waste

Valuable slag - Metals resulting from plasma pyrolysis can be recovered from

the slag

It produces syngas, which can be combusted in a gas turbine or

reciprocating to produce electricity or further processed into chemicals,

fertilizers, or transportation fuels—thereby reducing the need for virgin

materials to produce these products

High reaction temperatures and efficiency reduce the potential for

formation of toxic gaseous by products (e.g. dioxins, furans etc.)

Figure 4-3: Plasma arc gasification WTE plant

Thermal Depolymerisation (TDP)

TDP is a thermal process which mimics the natural geological process thought to be

responsible for fossil fuel production. In this process waste is converted into crude oil

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products under high temperatures and pressures. Waste used in TDP include: wood,

leaves, grass, food, paper, plastic, paint, cotton, synthetic fabrics, sludge from sewage

and animal matter.

Figure 4-4 shows a typical TDP plant, the process begins with waste being crushed and

mixed with water to create slurry. The slurry is fed into a pressurized reactor operating at

a temperature in the order of 300°C depending on the composition of the waste. The

mixture is then released into a low pressure environment where the water immediately

boils off creating steam which is recycled back into the grinder to save energy. The

minerals and metals settle out and are collected to be sold. The carbon containing

material that remains is sent to a second reactor where long carbon chains are broken

into simple hydrocarbons at temperatures in the order of 500°C. These simple

hydrocarbons are separated using distillation columns into heavy oils, petrols and light

oils which can then be stored in their respective storage tanks (Cutting Edge, 2006).

Figure 4-4: Thermal Depolymerisation (TDP) plant (adapted from Cutting Edge, 2006)

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Gasification

Gasification involves the combustion of a substance using insufficient oxygen to promote

incomplete combustion. This occurs at temperatures above 650°C and the products

include syngas and ash which contains small amounts of carbon. The syngas typically

contains CO, H2 and to some extent CH4 and can thus be used as a fuel to generate

electricity in a gas turbine. Figure 4-5 shows a typical MWS WTE gasification plant.

Waste heat from the gas turbine can be recovered in a heat recovery steam generator

(HRSG) to produce high pressure steam which can be used to in a steam turbine to

generate additional electricity; this system is called the Integrated Gasification Combined

System (IGCC).

Figure 4-5: Gasification WTE Plant

Pyrolysis

Refer to Section 0 for a discussion on pyrolysis as well as a graphical representation of a

conventional WTE pyrolysis plant.

Pyrolysis involves the thermal conversion of carbonaceous material into solid, liquid and

gaseous fuels, in the absence of oxygen, at temperatures above 220 degrees Celsius.

Biomass, abattoir waste and municipal solid waste (MSW) are typical pyrolysis feed

materials, each resulting in different products. The products of pyrolysis include syngas and

a solid residue called char. Syngas is a mixture of gases with high proportion of carbon

monoxide, hydrogen and methane, it has a high calorific value allowing it to be used

directly in a gas turbine for electric power generation.

The advantages of pyrolysis

Pyrolysis can be performed at relatively small scale and at remote locations

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It is efficient and relatively low on cost

Reduce transport and handling costs of waste.

It also provides an opportunity for the processing of waste into clean energy

The disadvantages of pyrolysis were also considered and they include:

High start-up cost

Need for oil management

Emissions to the environment

Not mobile

4.3 LAYOUT, DESIGN OR SCALE ALTERNATIVES

Due to the layout of existing operations and the fact that it is only practical to have the

plant on the existing SRTS site it was the most viable option to place the pyrolysis plant as

graphically shown in Appendix 3: Layout plan for proposed structures and infrastructure,

and thus no alternatives were considered.

4.4 OPERATION AND SCHEDULING ALTERNATIVES

Seeing that the pyrolysis plant will result in energy supply to the abattoir it would not be

feasible to shut down the plant or adopt an operation schedule.

4.5 NO-GO ALTERNATIVE

The no-go option refers to the alternative of the proposed development not going ahead

at all. The baseline status quo is maintained in this case. This alternative will avoid

potentially positive and negative impacts on the environment. In this case, the no-go

option would mean that:

All waste continues to be disposed of to landfill

Excess costs continue to be incurred in the transport of waste to landfill

The abattoir continues to draw all its electricity requirements from the national grid.

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5. LEGAL AND POLICY FRAMEWORK

The Constitution of the Republic of South Africa (Act No. 108 of 1996) has significant

implications for environmental management. The main effects are the protection of

environmental and property rights, the drastic change brought about by the sections

dealing with administrative law such as access to information, just administrative action

and broadening of the locus standi of litigants.

These aspects provide general and overarching support and are of major assistance in

the effective implementation of the environmental management principles and structures

of the NEM:WA and NEMA. Section 24 in the Bill of Rights of the Constitution specifically

states:

"Everyone has the right - to an environment that is not harmful to their health or

well-being”;

“To have the environment protected, for the benefit of present and future

generations, through reasonable legislative and other measures that -

Prevent pollution and ecological degradation;

Promote conservation”; and

Secure ecologically sustainable development and use of natural

resources while promoting justifiable economic and social

development."

5.1 NATIONAL ENVIRONMENTAL MANAGEMENT ACT (NEMA)

The National Environmental Management Act (NEMA), 1998 (Act 107 of 1998, as

amended) is South Africa’s overarching environmental legislation, and contains a

comprehensive legal framework to give effect to the environmental rights contained in

section 24 of The Constitution. Section 2 of NEMA contains environmental principles that

form the legal foundation for sustainable environmental management in South Africa.

NEMA introduces the principle of integrated environmental management that is achieved

through the environmental assessment process in Section 24, which stipulates that certain

identified activities may not commence without an Environmental Authorisation from the

competent authority. Section 24(1) of NEMA requires applicants to consider, investigate,

assess and report the potential environmental impact of these activities. The requirements

for the investigation, assessment and communication of potential environmental impacts

are contained in the so-called 2010 amendment EIA Regulations (GN R.543, R.544, R.545

and R.546; June 2010 as amended by GN.R 1159 of December 2010).

The assessment required (Figure 1-4) is, therefore, comprehensive and detailed where

appropriate, and is a systematic process to identify potential positive and negative

impacts on the environment (biophysical, socio-economic, and cultural) associated with

proposed, as well as existing, activities, which aims to:

Examine alternatives / management measures to minimise negative and optimise

positive consequences;

Prevent substantial detrimental impact to the environment;

Improve the environmental design of the proposal;

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Ensure that resources are used efficiently; and

Identify appropriate management measures for mitigation and the monitoring

thereof.

Importantly, the licensing process for the subject waste management activities, and the

supporting information required is the same as for activities listed in GN R.544, GN R.545

and R.546 that require an Environmental Authorisation in terms of the NEMA. In order to

avoid duplication by requiring two approvals for the same activity, waste activities listed in

the EIA Regulations were removed by means of General Notice No: 719 on 3 July 2009,

which means that currently, waste activities only require a Licence in terms of NEM:WA,

and not an Environmental Authorisation in terms of NEMA too. The proposed activities are

thus only subject to an application for waste management licencing, as detailed in the

Waste Management and Licensing section that follows, and not subject to an application

for environmental authorisation as well.

The activities that would be associated with the proposed SRTS facility are listed below in

Table 5-1.

Table 5-1: EIA Activities

GN R.545 Scoping and EIA activities (June 2010)

Activity No. 5: The construction of facilities or infrastructure for any process or activity

which requires a permit or licence in terms of national or provincial legislation governing

the generation or release of emissions, pollution or effluent and which is not identified in

Notice No. 544 of 2010 or included in the list of waste management activities published in

terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No.

59 of 2008) in which case that Act will apply.

REASON: The proposed pyrolosis plant waste to energy plant will require an Air Emission

Licence in terms of the NEM: Air Quality Act (2004).

Activity No. 26: Commencing of an activity, which requires an atmospheric emission

licence in terms of section 21 of the National Environmental Management: Air Quality Act,

2004 (Act No. 39 of 2004), except where Activity 28 in Notice No. R. 544 of 2010 applies.

REASON: pyrolosis of waste is deemed to be an incineration activity and accordingly

require an Air Emission Licence in terms of the NEM: Air Quality Act (2004).

5.1.1 DUTY OF CARE

The National Environmental Management Act, Act 107 of 1998, (NEMA) places a duty to

care on all persons who may cause significant pollution or degradation of the

environment. Specifically, Section 28 of the Act states:

“28 (1) Every person who causes, has caused or may cause significant pollution or

degradation of the environment must take reasonable measures to prevent such pollution

or degradation from occurring, continuing or recurring, or, in so far as such harm to the

environment is authorised by law or cannot reasonably be avoided or stopped, to

minimise and rectify such pollution or degradation of the environment.

(2) Without limiting the generality of the duty in subsection (1), the persons on whom

subsection (1) imposes an obligation to take reasonable measures, include an owner of

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land or premises, a person in control of land or premises or a person who has a right to use

the land or premises on which or in which-

(a) any activity or process is or was performed or undertaken; or

(b) any other situation exists, which causes, has caused or is likely to cause

significant pollution or degradation of the environment.

(3) The measures required in terms of subsection (1) may include measures to-

(a) investigate, assess and evaluate the impact on the environment;

(b) inform and educate employees about the environmental risks of their work

and the manner in which their tasks must be performed in order to avoid

causing significant pollution or degradation of the environment;

(c) cease, modify or control any act, activity or process causing the pollution or

degradation;

(d) contain or prevent the movement of pollutants or the causant of

degradation;

(e) eliminate any source of the pollution or degradation; or

(f) remedy the effects of the pollution or degradation.”

Consequently, in the context of this assessment, SRTS must take “reasonable steps” to

prevent pollution or degradation of the environment which may result from the proposed

activities. These reasonable steps include the investigation and evaluation of the potential

impact and identification of means to prevent an unacceptable impact on the

environment, and to contain or minimise potential impacts where they cannot be

eliminated.

5.2 WASTE MANAGEMENT AND LICENSING

In the past, waste management activities were regulated under the Environment

Conservation Act (ECA), 1989 (Act 73 of 1989), specifically Section 20(1), which states that

“no person shall establish, provide or operate any disposal site without a permit issued by

the Minister of Water Affairs”. Based on strict interpretation applied by authorities, any

waste handling facility, including waste storage and treatment, also required permitting

(or at least exemption) in terms of Section 20(1). These requirements have however been

replaced by the National Environmental Management: Waste Act (Act 59 of 2008)

(NEMWA), which was enacted on 10 March 2009 and came into force on 01 July 2009.

NEMWA was published in 2008 to, amongst other objectives, to:

reform the law regulating waste management in order to protect health and the

environment by providing reasonable measures for the prevention of pollution and

ecological degradation and for securing ecologically sustainable development;

provide for national norms and standards for regulating the management of waste

by all spheres of government; and

provide for specific waste management measures.

5.2.1 DEFINITION OF WASTE

The NEMWA defines ‘Waste’ as “any substance, whether or not that substance can be

reduced, re-used, recycled and recovered -

(a) that is surplus, unwanted, rejected, discarded, abandoned or disposed of

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(b) which the generator has no further use of for the purposes of production

(c) that must be treated or disposed of

(d) that is identified as a waste by the Minister by notice in the Gazette, and includes

waste generated by the mining, medical or other sector, but- (i) a by-product is not

considered waste; and (ii) any portion of waste, once re-used, recycled and recovered,

ceases to be waste”.

Other key definitions in NEMWA are:

Hazardous Waste: Any waste that contains organic or inorganic elements or

compounds that may, owing to the inherent physical, chemical or toxicological

characteristics of that waste, have a detrimental impact on health and the

environment;

General Waste: Waste that does not pose an immediate hazard or threat to

health or to the environment, and includes (a) domestic waste; (b) building and

demolition waste; (c) business waste; and (d) inert waste; and

Inert Waste: Waste that (a) does not undergo any significant physical, chemical

or biological transformation after disposal; (b) does not burn, react physically or

chemically biodegrade or otherwise adversely affect any other matter or

environment with which it may come into contact; and (c) does not impact

negatively on the environment, because of its pollutant content and because

the toxicity of its leachate is insignificant.

5.2.2 WASTE MANAGEMENT LICENSING

According to Section 19(1) and 19(3) of the Act, the Minister may publish a list of waste

management activities that have, or are likely to have, a detrimental effect on the

environment, and must specify whether a waste management licence is required to

conduct these activities. Under these provisions, a list of ‘Category A’ and ‘Category B’

waste management activities, which require a Waste Management Licence in terms of

Section 20(b) of NEMWA, were published via Government Notice No: 718 on 3 July 2009 as

Schedule 1 to NEMWA. On 29 November 2013 the minister amended the list through the

publishing of Government Notice No. 921.

The activities now fall under Categories A, B and C. In terms of this notice, a person who

wishes to commence, undertake or conduct any of these listed activities must, as part of

the Waste Management Licence application, conduct either a Basic Assessment process

(for Category A activities), or a Scoping and EIA (for Category B) as stipulated in the EIA

Regulations (GN R.543 as amended by GN.R 1159 of December 2010). For Category C

activities a person wishing to undertake such activities must comply with relevant

standards specified by the minister and listed in GN No. 921.

The licencing process for waste management activities and the supporting information

required is therefore the same as for activities listed in GN R.544, GN R.545 and R.546 that

require an Environmental Authorisation. In order to avoid duplication by requiring two

approvals for the same activity, waste activities listed in the EIA Regulations were removed

by means of General Notice No: 719 on 3 July 2009, which means that currently, waste

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activities only require a Licence in terms of NEMWA, and not an Environmental

Authorisation in terms of NEMA in addition thereto.

In terms of Section 43(1)(a) of NEMWA, the Minister (i.e. national DEA) is the licensing

authority where the waste management activity involves the establishment, operation,

cessation or decommissioning of a facility at which hazardous waste has been, or is to be,

stored, treated or disposed of. The waste management activities that are listed in

Schedule 1 to NEMWA, which are likely to form part of the project and that may require a

licence (but subject to interpretation of the definition of waste, the classification and final

management, which would all be assessed during the EIA), are listed below. It is to be

noted that at the time of application the activities listed under GN R.718 were in place.

Table 5-2: NEMWA Listed Waste Management Activities at the time of Application, listed

under GN R.718


Category A -

Activity No. 3

(2)

The storage including the temporary storage of hazardous waste at a

facility that has the capacity to store in excess of 35m3 of hazardous

waste at any one time, excluding the storage of hazardous waste in

lagoons.

REASON: The site store waste in a cold room or freezer if pyrolysis plant is

not running, as well as to build up a stock pile for when the abattoir is not

running.

Category A -

Activity No. 3

(8)


of the waste at a facility that has the capacity to process in excess of

three tons of general waste or less than 500kg of hazardous waste per

day, excluding recovery that takes place as an integral part of an

internal manufacturing process within the same premises.

REASON: The proposed facility would have the capacity to recover

energy from waste (general and hazardous).

Category A -

Activity No. 3

(18)

The construction of facilities for activities listed in Category A of this

schedule (not in isolation to associated activity).




Category A -

Activity No. 3

(19)

The expansion of facilities of or changes to existing facilities for any

process or activity, which requires an amendment of an existing permit or

license or a new permit or license in terms of legislation governing the

release of pollution, effluent or waste.

REASON: The establishment of the facility will require a new waste

management license.


Category B -

Activity No. 4

(3)

The recovery of hazardous waste including the refining, utilisation or co-

processing of waste at a facility with a capacity to process more than

500kg of hazardous waste per day excluding recovery that takes place

as an integral part of an internal manufacturing process within the same

premises or unless the Minister has approved re-use guidelines for the

specific waste stream.

REASON: The proposed facility would have the capacity to recover

energy from waste (general and hazardous).

Category B - The biological, physical or physico-chemical treatment of hazardous

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Activity No. 4

(4)

waste at a facility that has the capacity to receive in excess of 500 kg of

hazardous waste per day.

REASON: The pyrolysis of waste is considered physico-chemical

treatment.

Category B -

Activity No. 4

(5)

The treatment of hazardous waste using any form of treatment regardless

of the size or capacity of such a facility to treat such waste.

REASON: The pyrolysis of waste is considered physic-chemical treatment.

Category B -

Activity No. 4

(8)

Incineration of waste regardless of the capacity of such a facility

REASON: The waste will undergo pyrolysis which is considered

incineration.

Category B -

Activity No. 4

(11)

The construction of facilities for activities listed in Category B of this

schedule (not in isolation to associated activity).




Table 5-3 below lists the corresponding activities now listed under GN.R 921.

Table 5-3: NEMWA Listed Waste Management Activities listed under GN R.921


Category A -

Activity No. 3

(12)








Category B -

Activity (3)


of the waste at a facility that processes in excess of 100 tons of general

waste per day or in excess of 1 ton of hazardous waste per day,

excluding recovery that takes place as an integral part of an internal

manufacturing process within the same premises.



Category B -

Activity (4)

The treatment of hazardous waste in excess of 1 ton per day calculated

as a monthly average; using any form of treatment excluding the

treatment of effluent, wastewater or sewage.


Category B -

Activity (10)






With the activities being listed in both Category A and B of the aforementioned

Government Notice (GN.R 921, 29 November 2013), the process of applying for

Environmental Authorisation includes a requirement to conduct an initial Scoping phase,

followed by a detailed Environmental Impact Assessment as part of the application, in

terms of Government Notice R.543 (the so called NEMA EIA Regulations as amended by

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GN.R 1159 of December 2010) promulgated in terms of Section 24(5) of the National

Environmental Management Act (NEMA), 1998 (Act 107 of 1998, as amended). The

assessment process required (Figure 4-1) is, therefore, comprehensive and detailed where

appropriate, and is a systematic process to identify potential positive and negative

impacts on the environment (biophysical, socio-economic, cultural) associated with

proposed activity, which aims to:

Examine alternatives/management measures to minimise the negative and

optimise the positive consequences of the proposed operation;

Prevent substantial detrimental impact to the environment

Improve the environmental design of the proposal

Ensure that resources are used efficiently

Identify appropriate management measures for mitigation and the monitoring

Figure 5-1: Scoping and EIA Process for Waste Licensing

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5.3 WASTE CLASSIFICATION

The recently promulgated “National norms and standards for the assessment of waste for

landfill disposal” was published on the 23rd August 2013 in the government gazette

(GN635:2013). These require that all wastes that are to be disposed of in landfills be

assessed in terms of its composition and its leaching properties. These values are then

compared to threshold values to determine the classification of the waste.

If any of the concentrations (total or leach) of the compounds are higher than a given

threshold, the waste is given a specific rating; the lowest waste type in the waste will be

used. Type 4 wastes are the least hazardous while Type 0 is the most hazardous.

Table 5-4: Waste type classification of waste according to concentration

thresholds from the national norms and standards (23 August 2013)

Leachable

Concentration Total Concentration Waste Type

LC ≤ LCT0 TC ≤ TCT0 Type 4#

LCT0 < LC ≤ LCT1 TC ≤ TCT1 Type 3

LCT1 < LC ≤ LCT2 TC ≤ TCT1 Type 2

LCT2 < LC ≤ LCT3 TCT1 < TC ≤ TCT2 Type 1

LCT3 < LC TCT2 < TC Type 0 # Waste Type 4 has additional concentration limits that should not be exceeded

The waste types relate to specific landfill requirements as stated in the “National Norms

and Standards for Disposal of Waste to Landfill” (23 August 2013) (Table 5-5).

Table 5-5: Landfill requirements based on waste type from the national norms and

standards (23 August 2013)

Waste

type Landfill requirements

Type 0 The disposal of Type 0 waste to landfill is not allowed. The waste must be treated and re-assessed in terms of the Norms and Standards for Assessment of Waste for Landfill Disposal.

Type 1

Type 1 waste may only be disposed of at a Class A landfill designed in accordance with section 3(1) and (2) of these Norms and Standards, or, subject to section 3(4) of these Norms and Standards, may be disposed of at a landfill site designed in accordance with the requirements for a Hh/HH landfill as specified in the Minimum Requirements for Waste Disposal by Landfill (2nd Ed., Department of Water Affairs and Forestry, 1998).

Type 2

Type 2 waste may only be disposed of at a Class B landfill designed in accordance with section 3(1) and (2) of these Norms and Standards, or, subject to section 3(4) of these Norms and Standards, may be disposed of at a landfill site designed in accordance with the requirements for a GLB+ landfill as specified in the Minimum Requirements for Waste Disposal by Landfill (2nd Ed., DWAF, 1998).

Type 3

Type 3 waste may only be disposed of at a Class C landfill designed in accordance with section 3(1) and (2) of these Norms and Standards, or, subject to section 3(4) of these Norms and Standards, may be disposed of at a landfill site designed in accordance with the requirements for a GLB+ landfill as specified in the Minimum Requirements for Waste Disposal by Landfill (2nd Ed., DWAF, 1998).

Type 4 Type 4 waste may only be disposed of at a Class D landfill designed in accordance with section 3(1) and (2) of these Norms and Standards, or, subject to section 3(4) of these Norms

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Table 5-5: Landfill requirements based on waste type from the national norms and

standards (23 August 2013)

Waste

type Landfill requirements and Standards, may be disposed of at a landfill site designed in accordance with the requirements for a GLB landfill as specified in the Minimum Requirements for Waste Disposal by Landfill (2nd Ed., DWAF, 1998).

Waste obtained from the pyrolysis will consist primarily of bone ash, as almost all of the

other tissue would likely have been converted to syngas. This waste assessment focused

on reviewing the bone ash produced and discussed its use as a fertilizer and it’s

classification in terms of the SANS 10234 as required by the National Environmental

Management: Waste Act (NEMWA, 2008) Waste Classification and Management

Regulations (GN.R 634, 2013). A Literature review conducted on bone ash confirms it to be

non-hazardous. Refer to Appendix 8: Waste Assessment for the results.

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5.4 AIR QUALITY AND LICENSING

The National Environmental Management: Air Quality Act (NEMAQA), 2004 (Act 39 of

2004) regulates air quality in general, as well as, activities that may have an impact on

ambient air quality. All sections of the NEMAQA have been enacted and have replaced

the Atmospheric Pollution Prevention Act of 1965 (APPA).

According to S21 of NEMAQA, the Minister must publish, by notice in the Government

Gazette, a list of activities, which result in atmospheric emissions and which the Minister

reasonably believes have or may have a significant detrimental effect on the

environment.

Furthermore, such a notice must establish minimum emission standards for substances

resulting from a listed activity, including the permissible amount or concentration of

substances being emitted, as well as, the manner in which measurements of such

emissions must be carried out. The notice may also contain transitional and other special

arrangements in respect of activities which are carried out at the time of their listing.

The DEA has given effect to Section 21 through the Listed Activities and Minimum Emission

Standards (March 2010), which include air emission standards for new plants such as

boilers and waste to energy plants, and would accordingly require an Air Emission Licence

(Figure 4-3). In Accordance with the Air Quality Act (NEMAQA), 2004 (Act 39 of 2004) a list

of activities which result in atmospheric emissions which have or may have a significant

detrimental effect on the environment, including health, social conditions, economic

conditions, ecological conditions or cultural heritage has been published. The list was

published on the 31st of March 2010 (Government Gazette No. 33064) and has since been

amended in Government Gazette No. 37054 published on 22 November 2013. The

minimum emissions applicable to the proposed waste management facility are given in

Table 5-6 below

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Table 5-6: Category 8: Thermal Treatment of Hazardous and General Waste

Subcategory 8.1: Thermal Treatment of General and Hazardous Waste

Description: Facilities where general and hazardous waste are treated by the application of heat.

Application: All installations treating 10 Kg or more per day of waste.

Substance or mixture of substances Plant status

mg /Nm3 under normal

conditions of 273 Kelvin

and 101.3 kPa.

Common name Chemical symbol

Particulate matter N/A New 10

Existing 25

Carbon monoxide CO New 50

Existing 75

Sulphur dioxide S02 New 50

Existing 50

Oxides of nitrogen NOx expressed as NO2 New 200

Existing 200

Hydrogen chloride HCI New 10

Existing 10

Hydrogen fluoride HF New 1

Existing 1

Sum of Lead, arsenic, antimony, chromium, cobalt, copper, manganese, nickel, vanadium

Pb As+ Sb+ Cr + Co+ Cu + Mn+ Ni V

New 0.5

Existing 0.5

Mercury Hg New 0.05

Existing 0.05

Cadmium Thallium Cd + TI New 0.05

Existing 0.05

Total organic compounds TOC New 10

Existing 10

Ammonia NH3 New 10

Existing 10

ng I-TEQ/Nm3 under normal conditions of 10% 02 , 273

Kelvin and 101 3 kPa.

Dioxins and furans PCDD/PCDF New 0.1

Existing 0.1

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The following special arrangements shall apply:

1. For pyrolysis, reference oxygen content does not apply.

2. The facility shall be designed, equipped, built and operated in such a way so as to

prevent the emissions into the air giving rise to significant ground-level air pollution

(i.e. leading to the exceedance of an accepted ambient air quality threshold

standard).

3. Monitoring equipment shall be installed and acceptable techniques used in order

to accurately monitor the parameters, conditions and mass concentrations

relevant to the co-processing of AFR and incineration of waste.

4. All continuous, on-line emission monitoring results must be reported as a Daily

Average concentration expressed as mg/Nm3, and at 'normalised' conditions of

10% 02, 101.3 kPa, 273 K / 0 °C, dry gas.

5. Discontinuous (periodic) emission monitoring results must be expressed as mg/Nm3,

or ng/Nm3 I-TEQ for PCDD/PCDF, and at 'normalised' conditions of 10% 02, 101.3

kPa, 273 K / 0 °C, dry gas.

6. Exit gas temperatures must be maintained below 200 °C.

7. Pollution control devices (exhaust gas cooling and bag filter or ESP) must have a

daily availability of 98% (i.e. maximum downtime of 2% or 30 minutes per running 24

hours). The cumulative annual downtime (total downtime over a one year period)

may however not exceed 60 hours (0.685 % per annum).

8. Continuous, on-line measurement of the following emissions and operating

parameters is required:

Particulate matter (total particulate);

O2;

CO;

NOx;

SO2;

HCI;

HF;

VOC/TOC;

Emission exhaust volume (e.g. Nm3/hr) and flow rate (e.g. m/s);

Water vapour content of exhaust gas (humidity);

Exhaust gas temperature;

Internal process temperature/s;

Pressure; and

Availability of air pollution control equipment (including exit gas cooling).

9. Appropriate installation and functioning of automated, continuous monitoring

equipment for emissions to air, which are subject to quality control and to an

annual surveillance test. Independent accredited calibration must be undertaken

by means of parallel measurements with the reference methods, at a frequency as

per the requirements of the equipment, but as a minimum every 3 years.

10. Periodic measurements of heavy metals and dioxin and furan emissions must be

undertaken, using national (if available) or internationally acceptable methods, by

independent/external, accredited specialists twice during the first 12 months of

waste incineration / AFR co-processing, and annually thereafter.

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11. Average emission values for heavy metals are to be measured over a minimum

sample period of 60 minutes to obtain a representative sample, and a maximum of

8 hours, and the average values for dioxins and furans (expressed as I-TEQ) over a

sample period of a minimum of 60 minutes and maximum of 8 hours.

12. Periodic measurements of heavy metals and dioxins and furans are to be carried

out representatively to provide accurate and scientifically correct emission data

and results, and sampling and analysis must be carried out by independent,

accredited laboratories.

13. To ensure valid monitoring results are obtained, no more than five half-hourly

average values in any day, and no more than ten daily average values per year,

may be discarded due to malfunction or maintenance of the continuous

measurement system.

14. All measurement results must be recorded, processed and presented in an

appropriate manner in a Quarterly Emissions Monitoring Report in order to enable

verification of compliance with permitted operating conditions and air emission

standards. Quarterly Emission Monitoring Reports must include, amongst others:

Daily average results of all continuous, on-line emission monitoring

parameters, reported on line graphs that include individual, daily

average data points, and indicating the relevant air emission limit if

applicable;

Results of all continuous, on-line operational monitoring parameters,

reported on line graphs that correspond in scale with the emission

monitoring results;

Results of periodic emission measurements of heavy metals, and dioxins

and furans;

Confirmation of residence times and temperatures of specific wastes

coprocessed as determined by the specific feed points, plant dimensions

and material and gas flow rates;

Discussion on availability or air pollution control equipment, together with

reasons for and management of downtime;

All relevant results must be compared with baseline measurements taken

prior to the co-processing of AFR or hazardous waste; and

Detailed evaluation and discussion of any non-compliance during the

reporting period.

15. Treatment of High Level POPs Containing Waste (as defined by the Stockholm and

Basel Conventions) are to be preceded by an independently monitored

Performance Verification Test to determine the Destruction Efficiency (DE) and

Destruction and Removal Efficiency (DRE) of principal organic hazardous

compounds (POHC) using a suitable verification compound (e.g. trichloroethane).

16. A plan for conducting a Performance Verification Test must be submitted to the

relevant Government Department/s at least 3 months prior to the commencement

of such a test, and must include, amongst others, the following:

Motivation for why the plant should be used for treatment of High Level

POPs;

A feasibility study showing that the plant is technically qualified;

Planned date for commencement of the test and expected duration;

Details on the waste to be co-processed during the test, including

source, volume, composition etc.;

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Motivation for the particular choice of waste and its suitability in

providing an accurate and representative indication of the plant's DE

and DRE, and therefore suitability to treat High Level POPs Containing

Waste;

Extension of monitoring regime to include Chlorobenzenes, HCB, PCBs,

Benzene, Toluene, Xylenes, PAHs, and NH3;

Monitoring and analysis to be conducted, the associated methodologies

and independent parties responsible for monitoring.

17. A detailed, independent report documenting and interpreting the results of the

Performance Verification Test must be compiled. As a minimum, a DE/DRE of

99.9999% would be required, as well as compliance with Air Emission Standards.

18. An Air Quality Improvement Plan for achieving emission limits over time must be

developed if transitional arrangements apply to compliance with emission

standards.

19. Compliance time frames for health care risk waste incineration will be as specified

in paragraphs (8); (9); and (10) unless specific compliance time frames for health

care risk waste incineration have been set under health care risk waste regulations,

in which case, the specific compliance time frames for health care risk waste

incineration set under health care risk waste regulations shall apply.

20. Continuous emission monitoring for Health Care Risk Incinerators shall be complied

with by 31 March 2014.

21. Combustion of solid, liquid and gaseous waste materials in installations primarily

used for steam for steam raising or electricity generation must comply with the

emission standards of this subcategory.

NEMAQA also makes provisions for the establishment of national standards for ambient

concentrations of specified substances or mixtures of substances in ambient air, which

through ambient concentrations, bioaccumulation, deposition or in any other way,

present a threat to health, well-being or the environment or which are reasonably

believed to present a threat.

The Minister of Water and Environmental Affairs has accordingly published national

ambient air quality standards referring to various pollutants. In addition, criteria and limits

for dust deposition and regulations on the management of dust pollution have also been

set.

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Figure 5-2: Interrelationship between the EIA and AEL Processes

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5.5 OTHER RELEVANT LEGISLATION TO BE CONSIDERED

The following list of legislation was considered during the Scoping and EIA process for the

proposed SRTS development:

5.5.1 NATIONAL WATER ACT

The National Water Act (NWA), 1998 (Act 36 of 1998), aims to manage national water

resources in order to achieve sustainable use of water for the benefit of all water users.

This requires that the quality of water resources is protected, and integrated management

of water resources takes place. In terms of the National Water Act, a water use licence

application (WULA) is required for:

(a) taking water from a water resource;

(b) storing water;

(c) impeding or diverting the flow of water in a watercourse;

(d) engaging in a stream flow reduction activity contemplated in section 36;

(e) engaging in a controlled activity identified as such in section 37 (1) or declared

under section 38 (1) ;

(f) discharging waste or water containing waste into a water resource through a pipe,

canal, sewer, sea outfall or other conduit;

(g) disposing of waste in a manner which may detrimentally impact on a water

resource;

(h) disposing in any manner of water which contains waste from, or which has been

heated in, any industrial or power generation process;

(i) altering the bed, banks, course or characteristics of a watercourse;

(j) removing, discharging or disposing of water found underground if it is necessary for

the efficient continuation of an activity or for the safety of people; and

(k) using water for recreational purposes.

5.5.2 OCCUPATIONAL HEALTH AND SAFETY

The Occupational Health and Safety Act (OHSA) 1993 (Act 85 of 1993) regulations include

Regulation 1179 (Hazardous Chemical Substances) and Regulation 7122 (Major Hazard

Installations).

A “hazardous chemical substance” is defined in Government Notice R.1179 Hazardous

Chemical Substances Regulations (1995) as any toxic, harmful, corrosive, irritant or

asphyxiant substance, or a mixture of such substances for which (a) an occupational

exposure limit is prescribed, or (b) an occupational exposure limit is not prescribed; but

which creates a hazard to health.

A ‘major hazard installation’ means an installation:

(a) where more than the prescribed quantity of any substance is or may be kept,

whether permanently or temporarily; or

(b) where any substance is produced, used, handled or stored in such a form and

quantity that it has the potential to cause a major incident.”

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The proposed project, nor any of the existing structures subject to this application, will

require the storage of substances in more than prescribed quantities required in terms of

the relevant OHSA Regulations. No element of the proposed project is thus deemed to fall

within the definition of a MHI.

5.5.3 THE NOISE CONTROL REGULATIONS

The Noise Control Regulations (R 154 GG 13717 of 10 January 1992), promulgated in terms

of ECA, defines:

nuisance noise as, “any sound which disturbs or impairs or may disturb or impair

the convenience or peace of any person”;

disturbing noise as, “any noise level which exceeds the zone sound level or, if no

zone sound level has been designated, a noise level which exceeds the

ambient sound level at the same measuring point by 7 dBA or more”.

Regulation 4 states, “No person shall make, produce or cause a disturbing noise, or allow it

to be made, produced or caused by any person, machine, device or apparatus or any

combination thereof”. The operation of the propose plant is not anticipated to generate

noise on the existing industrial site that could be regarded as nuisance or disturbing noise

(as defined in the Noise Regulations).

5.5.4 NATIONAL HERITAGE RESOURCES ACT

The National Heritage Resources Act, 1999 (Act 25 of 1999) legislates the necessity for

cultural and heritage impact assessment in areas earmarked for development, which

exceed 0.5 hectares (ha) and where linear developments (including pipelines) exceed

300 metres in length. The Act makes provision for the potential destruction to existing sites,

pending the archaeologist’s recommendations through permitting procedures. Permits

are administered by the South African Heritage Resources Agency (SAHRA).

Given that the site at which the proposed activity is proposed is a “brown-fields” site (that

is to say that the site already subject to disturbance through previous ‘industrial’ activities),

the above Act is not deemed to be of any relevance to this particular project.

5.5.5 ACCESS TO INFORMATION

The Promotion of Access to Information Act (Act 2 of 2000) [PAIA] recognises that

everyone has a Constitutional right of access to any information held by the state and by

another person when that information is required to exercise or protect any rights. The

purpose of the Act is to foster a culture of transparency and accountability in public and

private bodies and to promote a society in which people have access to information that

enables them to exercise and protect their rights.

The EIA process undertaken, and particularly the Public Participation component thereof,

are aligned with the PAIA in the sense that all registered stakeholders in the EIA process

will be provided a fair opportunity to review and comment on any reports (Scoping

Report, Plan of Study for EIA, EIA Report and Environmental Management Plan) submitted

to the Competent Authority for decision making.

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The public participation component of this report is outlined in Section 6.

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6. PUBLIC PARTICIPATION

Public participation provides the opportunity for IAPs (interested or affected parties) to

participate on an informed basis, and to ensure that their needs and concerns are

considered during the impact assessment process. In so doing, a sense of ownership of

the project is vested in both the project proponent and interested or affected parties. The

Public Participation Process is aimed at achieving the following:

Provide opportunities for IAPs and the authorities to obtain clear, accurate and

understandable information about the expected environmental and socio-

economic impacts of the proposed development.

Establish a formal platform for the public with the opportunity to voice their

concerns and to raise questions regarding the project.

Utilise the opportunity to formulate ways for reducing or mitigating any negative

impacts of the project, and for enhancing its benefits.

Enable project proponent to consider the needs, preferences and values of

IAPs in their decisions.

Clear up any misunderstandings about technical issues, resolving disputes and

reconciling conflicting interests.

Provide a proactive indication of issues which may inhibit project progress

resulting in delays, or which may result in enhanced and shared benefits.

Ensure transparency and accountability in decision-making.

The public participation process to the end of the Scoping phase is outlined below. Refer

to Appendix 4: Public Participation Documentation for further detail, which includes:

Newspaper advertisements and site notices.

I&AP’s list

Proof of notification of I&AP’s

Proof of distribution of scoping report to I&AP’s and DEA

Proof of communication with Fezile Dabi District Municipality

6.1 PUBLIC PARTICIPATION PROCESS FOR SCOPING PHASE

6.1.1 PARTICIPATION PROCESS

The public and stakeholder participation process to date have entailed the following:

Pre-identification of interested and affected parties (IAPs).

Advertising the proposed project and associated EIA process in “Kroonnuus” on

the 3rd December 2013. The advertisements indicated where written comments

may be directed to and who to contact in order to be registered on the IAP list.

A2-size site notices were erected at the site’s entrance gate.

A draft Scoping report was made available for public comment between 25th

April 2014 and 10th May 2014.

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6.1.2 COMMENTS AND ISSUES

No comments were received from I&APs in the scoping phase.

6.2 PUBLIC PARTICIPATION PROCESS FOR EIA PHASE

6.2.1 PARTICIPATION PROCESS

The proposed public participation process for the Environmental Impact Assessment will

consist of:

Presenting registered Interested and Affected Parties and stakeholders with the

opportunity to read and comment on environmental impact assessment report

including specialist reports;


opportunity to read and comment on draft environmental management plans

compiled in terms of regulation;


opportunity to read and comment on the final reports submitted to the National

Department of Environment Affairs: Waste Permitting.

6.2.2 KEY DATES

Table 6-1: Key Dates in EIA Phase

Draft EIA and EMP report issued to IAP’s for comment 09 July 2014

Comment period closed, EIA updated to Final and submitted

to DEA 19 August 2014

Authority decision-making August, September,

October 2014

Appeal period (Chapter 7 – 2010 NEMA EIA Regulations) November/December

2014

.

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7. DESCRIPTION OF THE RECEIVING ENVIRONMENT

7.1 LOCATION, LAND-USE AND ZONING

The proposed pyrolysis and power generation facility is located at 22 11th Avenue,

Kroonstad, 9499. The site falls within the jurisdiction of the Moqhaka Local Municipality and

the Fezile Dabi District Municipality The site is currently zoned ‘Industrial’.

The closest residential area is approximately 300m away to the north east of the site.

Table 7-1 Aerial over view of Square Root Trading Seven (Pty) Ltd (Google)

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7.2 CLIMATE

7.2.1 TEMPERATURE

The average midday temperatures for Kroonstad range from 17°C in June to 28.7°C in

January. The region is the coldest during June when the temperature drops to 0°C on

average during the night

7.2.2 RAINFALL

The site is located in a summer rainfall region and therefore receives most of its rainfall

from December to January. While gentle soaking rains do occur, the rainfall in the area is

often characterised by intense thunderstorms, which occur mainly in the late afternoon.

The annual average rainfall is 560 mm (Mucina and Rutherford, 2006).

Table 7-2 Average monthly rainfall (mm) for Kroonstad

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7.2.3 WIND

Figure 7-1: Annual Wind Rose Kroonstad SAWS station from 2005-2008.

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7.3 TOPOGRAPHY

Kroonstad occurs at an altitude of 1300-1640m (Mucina and Rutherford, 2006). Refer to

Figure 7-2 for topographical map of the area in which Square Root Trading Seven (Pty) Ltd

operates.

Figure 7-2: Topographical map

7.4 GEOLOGY AND SOILS

Kroonstad Sedimentary mudstones and sandstone mainly of the Adelaide Subgroup

(Beauford Group, Karoo Supergroup) as well as those of the Ecca Group (Karoo

Supergroup) underlie the area. This gives rise to vertic, melanic and red soils. Less common

intrusive dolerites of the Jurassic Karoo Dolerite Suite support dry clayey soils is also typical

of the landscape type (Mucina and Rutherford, 2006).

7.5 FAUNA AND FLORA

Koonstad occurs within the Central Free State Grasslands. This biome is characterised by

undulating plains supporting short grassland, in natural conditions Themeda triandra

dominates while Eragrostis curvula and E. chloromelas become dominant in degraded

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areas. Dwarf karoo bushes establish in severely degraded clayey bottomlands.

Overgrazed and trampled low-lying areas with heavy clayey soils are prone to Acacia

karroo encroachment (Mucina and Rutherford, 2006).

7.6 SURFACE WATER

The SRTS site is located within the Middle Vaal water management area which is situated

in the central part of South Africa, in the Free State and North West Provinces. The Middle

Vaal water management area is situated between the Upper Vaal and Lower Vaal water

management areas and also borders on the Crocodile (West) and Marico as well as the

Upper Orange water management areas. The Vaal River is the only main river in the water

management area. It flows in a westerly direction from the Upper Vaal water

management area, to be joined by the Skoonspruit, Rhenoster, Vals and Vet Rivers as

main tributaries from the Middle Vaal water management area, before flowing into the

Lower Vaal water management area and then into the Orange River.

Kroonstad falls within the Rhenoster-Vals Sub-area which was again sub divided into the

Vals sub-catchment.C60D.Serfontein Dam (capacity of 25 million m3) supports town.

Historic yield analysis indicated significant shortages in supply which can be confirmed by

the water use restrictions on Kroonstad.

7.6.1 SURFACE WATER QUALITY

Naturally the quality of surface water in the water management area is good, but can be

of high turbidity. Wash-off and return flows from urban areas in the proximity of the Vaal

River and main tributes, such as at Klerksdorp, also impact on the areas water quality.

Water which enters the Middle Vaal water management area along the Vaal River

contains a large proportion of urban and industrial return flows from the Johannesburg

area with part of the water having been through more than one cycle of use. As a

consequence, salinity levels can be very high and need to be managed through

blending with fresh water in the Upper Vaal water management area, so as not to

exceed certain target concentrations. High nutrient concentrations also occur as a result

of the large domestic component of return flows which, together with the low turbidity of

the return flows, stimulates excessive algal growth. See Figure 7-3 for the graphical

representation of the Middle Vaal water management area.

The water quality in Rhenoster Vals Sub-area (specifically) is good with some localised

problems associated with the management and maintenance of the sanitation system in

Kroonstad, having a local impact on the water quality of the Vals River.

Correct water and waste management needs to occur on side to prevent any negative

impact of the abattoir and proposed waste-to-electricity plant on the areas water

sources.

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Figure 7-3 Middle Vaal Water Management Area

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7.7 GROUNDWATER

Although water restrictions have been effected in Kroonstad, there appears to be

adequate groundwater resources in this area (2–5 l/s per borehole according to

National Groundwater maps). Limited groundwater monitoring is being undertaken in the

area to assess groundwater quality trends. It was identified that in order to utilise these

groundwater resources, further monitoring and assessments need to be undertaken. The

intention is to focus these activities near the towns where groundwater can be utilised.

Correct water and waste management needs to occur on side to prevent any negative

impact of the abattoir and proposed waste-to-electricity plant on the areas water

sources.

7.7.1 AQUIFER CHARACTERISATION

Nearly the entire area covered by the Kroonstad Hydrogeological Map is situated in the

north-eastern part of the Central Karoo Basin. The thickness of the Karoo sediments

increases gradually from the pre-Karoo bedrock outcropping at the Vredefort and in the

northwest map corner towards south and close to the Lesotho border reaches over 2000

m. The age of the sediments decreases in the southerly direction.

Although groundwater is not the main source of water supply to many larger users in that

area, it can always be considered as an optional supplement to surface water in a

drought situation. Occurrences of the four recognised different types of aquifer in the

area covered by the sheet Kroonstad are to be discussed in this section.

Intergranular aquifers

This aquifer is weakly represented in the map area. The unconsolidated, water saturated

alluvium occurs sporadically along the Vaal, Wilge, Klip, Sand, Vet, Modder and Vals

Rivers. The thickness of the alluvial sediments that consist mainly of clay, sand and gravel

at the bottom is limited to a few metres. Two larger alluvial areas along the lower Vet and

Klip rivers are indicated on the map as Q. The alluvial aquifers there are thin and not

directly tapped by boreholes that usually bypass them. The two areas are therefore

characterised as “intergranular and fractured” type of aquifer that ignores the alluvium

reflecting only the water bearing character of the bedrock.

Fractured aquifers

The tectonic forces and to a lesser degree the weathering processes have produced a

network of fractures in the highly competent mainly quartzitic rock formations of Randian

age. Little, or no decomposition of the rock mass took place due to their predominantly

arenaceous and rudaceous nature. The storage volume of groundwater stored in this type

of aquifer is therefore limited, much lower than in other aquifer types. The groundwater

pumped from the Free State Goldfields mines is considered to be stored in the network of

interconnected fissures and fractures in the rocks of both the Witwatersrand and

Ventersdorp Supergroups. It is isolated form the shallow, subsurface Karoo rock aquifer by

the impermeable shales of the Ecca Group.

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Karstic aquifers

Karstic aquifers are formed by dissolution of a carbonate rock by circulating groundwater

containing carbonic acid. The process is taking place along the faults, fractures and joint

planes resulting in their enlargement. Channels, caves and other cavities are formed

which are often partially filled by permeable residual products of chert rubble, iron and

manganese oxides and hydroxides. Karstic aquifers are often characterized by high

storage and high yielding of boreholes, should the dissolved rock sections be penetrated.

Intergranular and Fractured aquifers

This aquifer system occurs practically in the entire map area. The action of tectonic forces

together with the subsequent processes of weathering, created two hydraulically

interconnected different zones that occur in a vertical profile namely:

A shallower, weathered zone, where the original rock structure has been changed

to a mass of more or less loose rock fragments, in a matrix of fine products of

weathering, mostly sand, silt and clay.

A fractured zone, down to a depth where the rock is becoming solid and fresh in

appearance. The transition to this deeper zone is usually gradual. The lateral

movement of groundwater in the top zone is very slow and boreholes tapping it

are weak.

Exploitable aquifers are found in four major Geological Supergroups: The Karoo

Supergroup, Transvaal Supergroup, Ventersdorp Supergroup and the Witwatersrand

Supergroup. There are also limited aquifers found in alluvial deposits along streams and

rivers. Karoo sediments of the Ecca and Beaufort Groups, which consist of mainly

sandstones, mudstones and shales, cover a large portion of the WMA. The aquifers are

secondary aquifers with water associated with fracturing of the porous medium.

Groundwater is often associated with dolerite intrusions and the yields are very variable

between 0.1 – 10l/s depending on the type and fracturing of the sediments

7.8 GROUNDWATER QUALITY

In Renoster/Vals catchment the only definite problem that was identified was the

localized groundwater pollution from food manufacturing factories however, the issues

relating to urban and agricultural activities may also apply here. Limited groundwater

monitoring is being done in the area to assess groundwater quality trends and the largest

gap on data for groundwater use and resources is in the Renoster/Vals sub-catchments.

There is little mining or industrial development in these catchments and the only data

available is from the WARMS database. No studies targeted at groundwater have been

initiated in this area. Correct water and waste management needs to occur on side to

prevent any negative impact of the abattoir and proposed waste-to-electricity plant on

the areas water sources

7.9 AMBIENT AIR QUALITY

The plant lies well away from the Highveld Priority Area and Vaal Triangle Priority Area

(VTPA). The Highveld area in South Africa is associated with poor air quality. Elevated

concentrations of criteria pollutants occur due to the high density of source emitters

including both industrial and non-industrial source operations. As a result, the Highveld

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Priority Area (HPA) was declared a priority area by the Minister on 23 November 2007

under NEMAQA.

Figure 7-4: Highveld and Vaal Triangle Priority Areas

.

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8. IMPACT ASSESSMENT METHODOLOGY

8.1 INTRODUCTION

Once a list of potential impacts has been developed (i.e. through the preceding scoping

process), the second major goal of the EIA process is to rate, rank and quantify, the many

impacts, so that the significant ones are emphasised in decision-making. There are many

techniques for doing this, but it must always be remembered that the technique should suit

the project.

There are very few cases where all potential impacts can be precisely quantified,

especially considering that the impacts cover such varying topics as employment effects

and groundwater quality, but a list of impacts with no indication of their ‘relative

significance’ would make decisions very difficult to reach and informed conclusions very

hard to make. In almost all situations, impact significance is done using semi-quantitative

methods. At this stage a few definitions are deemed necessary.

Significance: The concept of significance is at the core of impact identification, prediction,

evaluation and decision-making and the focus of EIA always narrows down to a decision

about whether the project is likely to cause significant/unacceptable adverse

environmental effects. Despite this, the concept remains largely undefined and there is no

international consensus on a single definition. Some examples of definitions or

interpretations from various authors are provided in Table 8-1 that follows:

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Table 8-1: Selected Definitions of Significance

Source Definition or interpretation

Haug et al.

(1984)

Determining significance is ultimately a judgement call. The

significance of a particular issue is determined by a threshold of

concern, a priority of that concern, and a probability that a

potential environmental impact may cross the threshold of concern.

Canter and

Canty (1993)

Significance can be considered on three levels: (1) significant and

not mitigatable, (2) significant but mitigatable, and (3) insignificant.

Significance is sometimes based on professional judgement,

executive authority, the importance of the project/issue, sensitivity

of the project/issue, and context, or by the controversy raised.

US

Environmental

Protection

Agency (1993)

Determination of significance requires predicting change. These

impact predictions are along with societal values, the major input to

significance determination. Ideally, change should be compared

against thresholds of concern, some of which may be legally

mandated and others, which may be levels or states of valued

components determined by the public, authorities or the EIA team.

Sadler (1996) The evaluation of significance is subjective, contingent upon values,

and dependent upon the environmental and community context.

Scientific disciplinary and professional perspectives frame

evaluations of significance. Scientists therefore evaluate

significance differently from one another and from local

communities.

Sippe (1999) Environmental significance is an anthropocentric concept, which

uses judgement and values to the same or greater extent than

science-based criteria and standards. The degree of significance

depends upon the nature (i.e. type, magnitude, intensity, etc.) of

impacts and the importance communities place on them.

Importantly, the NEMA EIA Regulations of 2010 (GN. R. 543 as amended by GN.R 1159 of

December 2010) states:

A “significant impact” means an impact that by its magnitude, duration, intensity or

probability of occurrence may have a notable effect on one or more aspects of the

environment;

Regulation 31(2)(l) states that an Environmental Impact Report must include:

“an assessment of each identified potentially significant impact, including—

(i) cumulative impacts

(ii) the nature of the impact

(iii) the extent and duration of the impact

(iv) the probability of the impact occurring

(v) the degree to which the impact can be reversed

(vi) the degree to which the impact may cause irreplaceable loss of resources

(vii) the degree to which the impact can be mitigated

Qualitative Methods/Assessment: This is done using statements, pictures or illustrations to

compare the impact of an activity versus the initial state of the receiving environment. For

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example, a social impact assessment makes use of interviews to find out how residents in

an area feel about a project proposal, whilst the visual assessment uses photomontage to

show how the views in the area will change.

Qualitative methods are typically used where the variables describing an impact are not

tangible and difficult to quantify. This method has the disadvantage of sometimes being

vague and is inherently based on the judgment of the assessor. However, these value-

based opinions are an important component of any EIA process and the challenge in the

EIA process is to balance value based input with scientific/technical information.

Quantitative Methods/Assessment: This is done using numerical methods where data is

directly comparable. However, scientific/technical information cannot always be

quantified – in many instances, ecological impacts are difficult to quantify. So, although

there is a component that can be precisely quantified, the more important biological

impacts will have to be semi-quantitative at best. Quantitative assessment is typically

applied for noise, air and other forms of pollution, where the direct physical changes may

be easily quantified and compared against regulatory limits, yet the indirect impacts

thereof on humans, plants and animals is not so easily calculated. It is important to note

that where quantitative models are used, they must as far as possible take into account the

existing environmental loading for the environmental aspect being assessed.

Semi-quantitative Methods/Assessment: This covers a range of methods that slot in-

between the two methods above. On the more qualitative side, an ordinal system can be

used where impacts are assigned a significance that is relative, but not precise, such as:

negligible, minor, major, severe, etc.

Baselines: Environmental impacts are measured against a baseline (i.e. the existing

conditions prior to the proposed development).

Thresholds: A threshold represents that point at which potential environmental effects are

considered significant. Thresholds are an analytical tool for judging significance. They can

be defined as a quantitative or qualitative standard or set of criteria against which the

significance of a given environmental effect may be determined. A threshold may be

based on aspects relating to:

Health-based standards, such as air pollutant emission standards, water pollutant

discharge standards, noise levels etc.

Service capacity standards, such as transportation service, water supply capacity or

waste treatment plant capacity

Ecological tolerance standards such as physical carrying capacity, impacts on

threatened or endangered species

8.2 TYPE OF IMPACTS Potential environmental impacts may either have a positive or negative effect on the

environment, and can in general be categorised as follows:

a) Direct/Primary Impacts

Primary impacts are caused directly due to the activity and generally occur at the same

time and at the place of the activity.

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b) Indirect/Secondary Impacts

Secondary impacts induce changes that may occur as a result of the activity. These types

of impacts include all the potential impacts that do not manifest immediately when the

activity is undertaken.

c) Cumulative Impacts

Cumulative impacts are those that result from the incremental impact of the proposed

activity on common resources when added to the impacts of the other past, present or

reasonably foreseeable future activities. Cumulative impacts can occur from the collective

impacts of individual minor actions over a period of time, and can include both direct and

indirect impacts.

8.3 DETERMINING SIGNIFICANCE

Impact significance assessment has been quantified to the greatest extent possible

throughout this EIA, with qualitative methods having been employed, together with

professional/specialist judgement, to assess the less tangible of the identified impacts.

The following criteria/method has also been used to, semi-quantitatively determine the

relative significance of the identified impacts, such that can at some level be

ranked/compared, so that the significant impacts are emphasised.

The scores associated with each of the levels within each criterion are indicated in brackets

after each description [like this].

8.3.1 NATURE

Nature (N) considers whether the impact is:

positive [- ¼ ]

negative [+1].

8.3.2 EXTENT

Extent (E) considers whether the impact will occur:

on site [1]

locally: within the vicinity of the site [2]

regionally: within the local municipality [3]

provincially: across the province [4]

nationally or internationally [5].

8.3.3 DURATION

Duration (D) considers whether the impact will be:

very short term: a matter of days or less [1]

short term: a matter of weeks to months [2]

medium term: up to a year or two [3]

long term: up to 10 years [4]

very long term, or permanent: 10 years or longer [5].

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8.3.4 INTENSITY

Intensity (I) considers whether the impact will be:

negligible: there is an impact on the environment, but it is negligible, having no

discernable effect [1]

minor: the impact alters the environment in such a way that the natural processes or

functions are hardly affected; the system does however, become more sensitive to

other impacts [2]

moderate: the environment is altered, but function and process continue, albeit in a

modified way; the system is stressed but manages to continue, although not with the

same strength as before [3]

major: the disturbance to the environment is enough to disrupt functions or

processes, resulting in reduced diversity; the system has been damaged and is no

longer what it used to be, but there are still remaining functions; the system will

probably decline further without positive intervention [4]

severe: the disturbance to the environment destroys certain aspects and damages

all others; the system is totally out of balance and will collapse without major

intervention or rehabilitation [5].

8.3.5 PROBABILITY

Probability (P) considers whether the impact will be:

unlikely: the possibility of the impact occurring is very low, due either to the

circumstances, design or experience [1]

likely: there is a possibility that the impact will occur, to the extent that provisions

must be made for it [2]

very likely: the impact will probably occur, but it is not certain [3]

definite: the impact will occur regardless of any prevention plans, and only

mitigation can be used to manage the impact [4].

8.3.6 MITIGATION OR ENHANCEMENT

Mitigation (M) is about eliminating, minimising or compensating for negative impacts,

whereas enhancement (H) magnifies project benefits. This factor considers whether –

A negative impact can be mitigated:

unmitigated: no mitigation is possible or planned [1]

slightly mitigated: a small reduction in the impact is likely [2]

moderately mitigated: the impact can be substantially mitigated, but the residual

impact is still noticeable or significant (relative to the original impact) [3]

well mitigated: the impact can be mostly mitigated and the residual impact is

negligible or minor [4]

A positive impact can be enhanced:

un-enhanced: no enhancement is possible or planned [1]

slightly enhanced: a small enhancement in the benefit is possible [2]

moderately enhanced: a noticeable enhancement is possible, which will increase

the quantity or quality of the benefit in a significant way [3]

well enhanced: the benefit can be substantially enhanced to reach a far greater

number of receptors or recipients and/or be of a much higher quality than the

original benefit [4].

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8.3.7 REVERSIBILITY

Reversibility (R) considers whether an impact is:

irreversible: no amount of time or money will allow the impact to be substantially

reversed [1]

slightly reversible: the impact is not easy to reverse and will require much effort,

taken immediately after the impact, and even then, the final result will not match

the original environment prior to the impact [2]

moderately reversible: much of the impact can be reversed, but action will have to

be taken within a certain time and the amount of effort will be significant in order to

achieve a fair degree of rehabilitation [3]

mostly reversible: the impact can mostly be reversed, although if the duration of the

impact is too long, it may make the rehabilitation less successful, but otherwise a

satisfactory degree of rehabilitation can generally be achieved quite easily [4].

8.4 CALCULATING IMPACT SIGNIFICANCE Significance is determined through the integration of impact characteristics in terms of the

above-mentioned variables, resulting in a rating of high, medium or low significance.

Impact significance is assigned both with and without mitigation, and the measures or

outcome of mitigation or optimisation of impacts highlighted. The table below summarises

the scoring for all the criteria.

Table 8-2: Scoring for Significance Criteria CRITERION SCORES

- ¼ 1 2 3 4 5

N-nature positive negative - - - -

E-extent - site local regional provinci

al

national

D-duration - very short short moderate long very long

I-intensity - negligible minor moderate major severe

P-probability - very unlikely unlikely likely very

likely

-

M-mitigation - none slight moderate good -

H-enhancement - none slight moderate good -

R-reversibility - none slight moderate good -

Impact significance is a net result of all the above criteria. The formula proposed to

calculate impact significance (S) is:

For a negative impact: S = N x (E+D) x I x P ÷ ½(M+R); and

For a positive impact: S = N x (E+D) x I x P x (H).

Negative impacts score from 2 to 200. Positive impacts score from – ½ to -200.

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8.5 UNDERSTANDING IMPACT SIGNIFICANCE The following is a guide to interpreting the final scores of an impact (for negative impacts):

Table 8-3: Final Significance Scoring Final score (S) Impact significance

0 – 10 negligible the impact should cause no real damage to the

environment, except where it has the opportunity to

contribute to cumulative impacts

10 – 20 Low the impact will be noticeable but should be localized or

occur over a limited time period and not cause

permanent or unacceptable changes; it should be

addressed in an EMP and managed appropriately

20 – 50 moderate the impact is significant and will affect the integrity of the

environment; effort must be made to mitigate and reverse

this impact; in addition the project benefits must be shown

to outweigh the impact

50 – 100 High the impact will affect the environment to such an extent

that permanent damage is likely and recovery will be slow

and difficult; the impact is unacceptable without real

mitigation or reversal plans; project benefits must be

proven to be very substantial; the approval of the project

will be in jeopardy if this impact cannot be addressed

100 – 200 severe the impact will result in large, permanent and severe

impacts, such as, local species extinctions, minor human

migrations or local economic collapses; even projects with

major benefits may not go ahead with this level of impact;

project alternatives that are substantially different should

be looked at, otherwise the project should not be

approved

Two examples will help illustrate this system:

SCENARIO 1 – An industrial facility proposes discharging effluent containing a high salt

content into a nearby stream. These salts will cause temporary problems for the ecosystem,

but are washed downstream, diluted and will have no long term effects. The short term

damage to the stream can be reversed fairly easily, but only if the ecosystem has not been

seriously damaged by the salts over a long time. A mitigation measure is also proposed

whereby during low flow periods (dry season) a pulse of clean water is discharged into the

stream after the saline effluent, diluting the salts and pushing them downstream faster, so

that the salts become so dilute as to have little or no effect.

From this scenario, the criteria are:

nature = negative = 1

extent = local = 2

duration = medium = 3

intensity = moderate = 3

probability = very likely = 4

mitigation = moderate = 3

reversibility = moderate = 3,

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and therefore impact significance is:

S = N x (E+D) x I x P ÷ ½(M+R)

= 1 x (2+3) x 3 x 4 ÷ ½(3+3)

= 60 ÷ 3

= 20.

Note that the impact prior to mitigation is major, but that due to the mitigation and the fact

that the ecosystem can recover easily from the effects of salt (high reversibility), the residual

impact becomes minor/moderate.

SCENARIO 2 – The above scenario applies, except that the effluent contains metals. These

metals become adsorbed onto clay and organic matter in the stream bed and are

accumulative toxins within the ecosystem, getting into the food chain and concentrating

upwards into predator species. Fresh water flushing will only very slightly mitigate this and

ecosystem recovery will not be easy or fast.

From this scenario, the criteria are:

nature = negative = 1

extent = local = 2

duration = very long = 5

intensity = moderate = 3

probability = very likely = 4

mitigation = slight = 2

reversibility = slight = 2,

and therefore impact significance is:

S = N x (E+D) x I x P ÷ ½(M+R)

= 1 x (2+5) x 3 x 4 ÷ ½(2+2)

= 84 ÷ 2

= 42.

Note that in this case, the original impact (of the metals) is more serious than the salt, but it

is the limited mitigation and reversibility that also act on the residual score and result in this

score being moderate.

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9. IMPACT SIGNIFICANCE ASSESSMENT/ANALYSIS

Impact analysis is, in a sense, the core of the EIA process. It is the phase where all relevant

project information that has been gathered is manipulated and distilled – it is the

‘Environmental Impact Assessment’. The impact analysis has two major goals, starting with

listing and describing all possible environmental impacts and then proceeding to give

some perspective on the relative significance of the various impacts. The predicted effects

of mitigation measures also need to be factored into the impact analysis.

Environmental impact analysis needs to take cognisance of the following issues that all fall

under the definition of the ‘environment’:

Physical natural environment: water, land, air

Biological natural environment: flora, fauna, ecosystems

Resources: land/space, minerals, water, rights of use

Economic: cost, profit, distribution of income, jobs, skills, permanence

Human health: occupational, environmental health, pollution, safety

Human cultural: religion, tradition, aesthetics, heritage, recreation

One needs to, however, bear in mind that the natural environment is the most threatened

and irreplaceable resource upon which all the other human aspects depend. The analysis

of impact significance assessment for potential project impacts furthermore needs to

consider impacts that may be realised through all project phases, as follows:

Construction/establishment

Operation

Decommissioning, closure and rehabilitation

Relative impact significance is semi-quantitatively assessed (Section 7.2) for relevant

aspects (e.g. water, air, biodiversity, noise, visual character, heritage resources, etc.) for

each respective phase of the project referred to above. Impact significance is however

also, to the greatest extent possible, quantified through comparison against legislated

thresholds (e.g. ambient air quality limits under NEM:AQA), or other applicable legal

limits/standards.

In addition, a brief description of mitigation to be implemented in order to minimise the

significance of the potential impacts is provided. The details of inter alia required

mitigation, monitoring and reporting are put forward in Appendix 9: Environmental

Management Programme Report

9.1 INDICATORS OF POTENTIAL IMPACT SIGNIFICANCE Some generic characteristics of impacts that point strongly towards significance include:

(EPA, 1998) -

violation of national laws or international protocols and norms

opportunity to contribute to cumulative impacts

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chance of irreversible damage occurring

amount of contradictory opinion or controversy

degree of uncertainty or number of unknowns

possibility of setting a precedent

More specific impact characteristics that will probably be included as significant are those

which (Adapted from DEA, 2002) -

conflict with environmental plans and frameworks

interfere with the movement of migratory wildlife

destroy wildlife habitat

exceed published environmental standards and limits e.g. water and air quality

standards

expose sensitive receptors to pollution

breach standards for transport, storage and handling of waste or hazardous goods

contaminate a public water supply

result in loss of prime agricultural land

terminate or substantially alter existing land uses

deface or devalue a cultural or heritage resource

cause changes in community or population dynamics

generate traffic beyond the design capacity of existing infrastructure

require resettlement of people

create a public health hazard

interfere with emergency response plans

As can be seen from the above lists, the determination of significance is far from being a

set method. In most cases, there is more than one aspect that will influence how significant

a particular impact is.

9.2 CONSTRUCTION PHASE

This phase of the project involves all those activities related to preparation of the site and

subsequent construction/establishment of the various project structures and associated

surface infrastructure thereon (earthworks/levelling/excavations/foundations, building

construction and engineering services installation, etc.). It is envisaged that the

construction period will last for approximately 3 months

Below is an assessment of environmental aspects and their associated impacts relating to

the proposed project. Differentiation is made between significance of impact and priority

for the management of an impact, which is determined by impact significance, and

existence of applicable legislation.

DRAFT EIA REPORT



9.2.1 NOISE

Introduction

The proponent must comply with the provisions of the Occupational Health and Safety Act,

1993 (Act No. 85 of 1993), as well as any other national norms and standards regarding

noise management. Predominant construction related noise impacts are anticipated from

the following sources:

Heavy vehicle movement and operation associated with ground works and

building activities (i.e. dump trucks, excavators, TLBs, cranes, graders, earth

compacters, etc.); and

Drilling (e.g. structural works).

The SRTS site is primarily surrounded by industrial areas. The nearest residential area to the

site is located approximately 1 km to the north-west of the SRTS plant, while the central

business district of Kroonstad is located approximately 1 km to the north-east of the SRTS

plant.

The Noise Control Regulations (R 154 GG 13717 of 10 January 1992) promulgated in terms

of ECA, defines:

Nuisance noise, as “any sound which disturbs or impairs or may disturb or impair

the convenience or peace of any person”; and

Disturbing noise, as “any noise level which exceeds the zone sound level or, if no

zone sound level has been designated, a noise level which exceeds the ambient

sound level at the same measuring point by 7 dBA or more”.

Regulation 4 states ‘No person shall make, produce or cause a disturbing noise, or allow it


combination thereof.’ In addition, Section 28 of NEMA imposes a ‘duty of care’ on every

person who may cause significant pollution to prevent such pollution or degradation from

occurring, continuing or recurring, or, in so far as such harm to the environment is

authorised by law or cannot reasonably be avoided or stopped, to minimise and rectify

such pollution or degradation of the environment. An increase of 7dB above current

ambient noise levels would thus be unacceptable, and the proponent would need to take

appropriate noise reduction measures to avoid creating ‘ disturbing noise’ during the

construction period; where construction phase noise monitoring may be required if

complaints arise from around noise during the construction phase.

Impact discussion and significance assessment

Two aspects are important when considering the potential noise impacts of a project and

these are as follows:

The anticipated increase in the ambient noise level; and

The overall ambient noise level produced.

DRAFT EIA REPORT



Table 9-1: Impacts on Ambient Noise Levels (Construction)

Nature (N) Negative impacts of construction related noise on

sensitive receptors 1

Extent (E) Locally: Within the vicinity of the site 2

Duration (D) Short term: Construction phase (bulk of work

conservatively anticipated for a matter of months) 2

Intensity (I) Moderate: Ambient noise levels would likely be

increased over the short-term, but function and

process would continue, albeit in a modified way. 2

Probability (P) Likely: There is a possibility that the impact will occur,

to the extent that provisions must be made for it. 3

Mitigation (M) Slightly mitigated: Limited avoidance and

minimisation techniques available 2

Enhancement (H) N/A -

Reversibility (R) Reversible with the cessation of the activity 4

Significance Rating

with Mitigation -

Negative Impact (S)

N x (E+D) x I x P ÷ ½(M+R)

negligible 8

Significance Rating

without Mitigation -

Negative Impact (S)

N x (E+D) x I x P ÷ ½(M+R)

Low 12

Significance Rating

-Positive Impact (S)

N x (E+D) x I x P x (H). -

Mitigation Management

The following measures must be considered by the Proponent prior to the acquisition of

earthmoving equipment:

Enclosure of engine bays;

Modification of radiator fan design and materials;

Installation of louvers on radiator and hydraulic cooling fans; and

Re-engineering of exhaust systems.

The following are the Environmental, Health and Safety Guidelines of the IFC of the World

Bank, which should be taken into consideration during the construction phases of the

project:

Selecting equipment with lower sound power levels;

Installing suitable mufflers on engine exhausts and compressor components;

Installing vibration isolation for mechanical equipment; and

Develop a mechanism to record and respond to complaints.

The proponent must also restrict construction activities to within 7:00am and 5:00pm on

weekdays, and 8:00am to 13:00pm on Saturdays.

DRAFT EIA REPORT



9.2.2 BIODIVERSITY

Impact Discussion and Significance Assessment

The proposed WTE plant will be on an already existing site therefore no biodiversity loss in

anticipated.

Mitigation/management

There can be very little to no mitigation of biodiversity loss, due to the fact that the

development area is completely transformed.

9.2.3 CONSTRUCTION AND INSTALLATION WASTE GENERATION (CONTRIBUTION TO

LANDFILL)

Introduction

Nominal volumes of construction and installation waste will be generated during the

construction of the proposed WTE plant. The waste would predominantly comprise of

building rubble, packaging and fabrication waste/s. Steel and electric cabling waste, and

packaging waste is also expected from installation. It is likely that most, if not all, of the

waste generated would be non-hazardous/general waste. The generation of such waste

could indirectly impact on the operational lifespan of the Disposal Facility, through the

permanent occupation of remaining available airspace at this facility. The same principle

Table 9-2: Impacts on biodiversity (Construction)

Nature (N) Negative: Indirect negative effect on biodiversity

occurring within the perimeter of the site. 1

Extent (E) Site: Fauna and flora occurring within the perimeter

of the site might be affected.

1

Duration (D) Very long: The fauna and flora will be affected for

the life of the plant and evaporation ponds. 5

Intensity (I) Negligible: The effect of fauna and flora will be

negligible due to the area already having been

completely disturbed therefore the status quo should

be maintained in terms of biodiversity.

1

Probability (P) Good: The probability of fauna and flora occurring

directly where construction activities take place is

very likely.

2

Mitigation (M) No mitigation is planned. 1


Reversibility (R) Slight: The chance of creating a habitable

environment for indiginous fauna and flora is slight. 4

Significance Rating

with Mitigation -

Negative Impact (S)

N x (E+D) x I x P ÷ ½(M+R)

negligible 4.8

Significance Rating


Negative Impact (S)

N x (E+D) x I x P ÷ ½(M+R)

negligible 6

Significance Rating


N x (E+D) x I x P x (H). -

DRAFT EIA REPORT



would apply to the applicable hazardous landfill facility/ies to which hazardous waste

generated during construction will be taken for disposal.


The intensity of the impact will be low relative to cumulative National and regional waste

generation volumes (general and hazardous waste generation).

Table 9-3: Impacts of Construction Waste Generation (Construction)

Nature (N) Indirect negative impact on landfill airspace

availability. 1

Extent (E) Provincial: Use of landfill in the province 4



Intensity (I) Negligible: The anticipated impact will be negligible,

with no discernable effect on relative airspace

availability.

1

Probability (P) Definite: The generated of waste during the

construction phase is largely unavoidable (the

amount generated can, however, be managed)

4

Mitigation (M) Slightly: A small reduction in the volumes of waste

generated can likely be effected during construction 2


Reversibility (R) Moderately reversible through reuse, recovery and/or

recycling initiatives: Where the impact relates to

contribution to landfill, any measure implemented to

reuse, recover, or recycle such waste would

constitute the reversal of the impact

3

Significance Rating

with Mitigation -

Negative Impact (S)

N x (E+D) x I x P ÷ ½(M+R)

negligible 9.6

Significance Rating


Negative Impact (S)

N x (E+D) x I x P ÷ ½(M+R)

Low 16

Significance Rating


N x (E+D) x I x P x (H). -

Mitigation/Management

All construction and installation waste will be stored temporarily in a way that protects

surface- and groundwater, and appropriately disposed of at a suitable,

permitted/licensed, disposal site (i.e. where the waste in question is classified as general

waste), or stored temporarily prior to collection by a suitably licensed waste disposal

contractor in the event that hazardous waste is generated. Temporary waste storage areas

will be sited under the guidance of site environmental personnel prior to the start of

construction activities. Construction personnel will be trained in their correct use and the

sites will be regularly inspected to ensure that they are being appropriately managed.

DRAFT EIA REPORT



9.2.4 GROUNDWATER AND SURFACE WATER QUALITY

Introduction

The inappropriate storage, management and handling of fuel, oil and other potentially

hazardous chemicals and substances during the construction period could result in

potentially negative impacts on surface- and ground water quality; where spillages of such

could enter the groundwater environment in particular, through the infiltration of

contaminated surface run-off into the groundwater environment. Contamination of this

nature, associated with the construction phase of a project of this magnitude, would

typically be hydrocarbon based (i.e. petrol, diesel and oil leaks and spillages to bare soil

surfaces). Temporary concrete batching plants can also impact negatively on ground- and

surface water resource quality if poorly managed.

Groundwater contamination would generally be restricted to the confines of the site, or in

severe cases the immediate surrounds of the site. In the absence of a significant,

continuous, point source of pollution, a groundwater pollution plume would likely develop

and extend (i.e. in terms of lateral geographic extent) slowly within the underlying alluvial

aquifer.

In addition, during construction, temporary stockpiles of building material, excavated soil,

overburden and rock, as well as waste, will be produced. It is important that these

stockpiles are located in a centralised area where temporary measures such as berms will

prevent sediment run-off, specifically during heavy rainfall episodes. These particular waste

streams are, however, not expected to be hazardous, or pose a significant contamination

risk to groundwater.


Table 9-4: Impacts on Water Resource Quality (Construction)

Nature (N) Negative impact on water resource quality 1

Extent (E) Locally: Localised to the site and immediate

surrounds

2

Duration (D) Long term: Only if a plume enters groundwater will it

be a long process to remediate contaminated

groundwater.

5

Intensity (I) Minor: The quantity of contaminants that have a

possibility of entering groundwater are small

2

Probability (P) Unlikely: The probability of a spill taking place during

construction is low

2

Mitigation (M) Good: There are many measures that can be

implemented in order to prevent water

contamination.

4


Reversibility (R) Slight: Groundwater remediation is possible but is a

lengthy and costly process.

2

Significance Rating

with Mitigation -

Negative Impact (S)

N x (E+D) x I x P ÷ ½(M+R)

Negligible 9.3

Significance Rating N x (E+D) x I x P ÷ ½(M+R) Low 18.6

DRAFT EIA REPORT



Table 9-4: Impacts on Water Resource Quality (Construction)


Negative Impact (S)

Significance Rating


N x (E+D) x I x P x (H). -


The remediation of contaminated groundwater is a long, arduous and costly process. Any

such remediation efforts may also likely leave significant residual contamination, despite

any such remediation attempts (dependant on the nature and extent of the

contamination itself). As such, the proponent’s management actions should focus on the

prevention of any such potential hydrocarbon contamination, rather than post impact

remediation thereof. A comprehensive range of effective, proven, mitigation measures will

be implemented in this regard, which are in principle as follows:

All hazardous substances to be stored within appropriately sized,

impermeable, bund walls;

Storm water control measures to be implemented that prevent the free

movement of ‘clean’ storm water run-off through the aforementioned

storage areas, as well as any service yards and wash bays;

Hazardous substances spill kits to be readily available at all points where

hazardous substances will be stored and/or transferred (e.g. refuelling points);

Vehicle and plant servicing to only take place in dedicated service yards on

impermeable surfaces coupled with appropriate ‘dirty’ water containment

systems/sumps and oil/water separators; and

Drip trays to be appropriately placed under vehicles and plant that over-

night on bare soil surfaces.

Contractors will also be required to provide a method statement in respect of how they

propose to manage fuel storage, concrete batching- and workshop areas to minimise the

potential for groundwater pollution. Such method statements would need to be signed off

by competent site environmental personnel / environmental control officer (ECO), prior to

the start of construction activities.

9.2.5 AIR QUALITY

Introduction

During construction, the undertaking of ground- and civil works would lead to the

generation of vehicle and wind entrained dust. Although the impact is likely to be localised

to the site, dust suppression techniques such as wetting roads, or application of dust

palliatives, would be required. Other emissions, such as construction vehicle and machinery

exhausts are not anticipated to be significant.

The nearest residential receptors to the development site are located approximately 1km

to the north-west of the SRTS plant. It must be noted that that the proponent would need to

ensure that dust fallout during construction does not exceed the limit for industrial land use

specified in SANS1929:2005 (i.e. < 600mg/m2/day – 30 day average).

DRAFT EIA REPORT




The impact will be of a low intensity and isolated to the site and its immediate surrounds.

Effective mitigation, in the form of accepted dust suppression techniques, can be applied,

but will not likely mitigate the potential occurrence of the impact in its entirety (i.e. residual

impacts may be noticeable, but will be negligible relative to the original impact). The

residual impacts will occur up until the point at which construction activities cease and

when concurrent rehabilitation of applicable affected areas has been completed.

Table 9-5: Impacts on Air Quality (Construction)

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


surrounds

2

Duration (D) Short Term: Construction phase (conservatively

anticipated for a matter of months) 2

Intensity (I) Minor: Natural processes or functions will hardly be

affected 2

Probability (P) Likely: Impact will likely occur, to the extent that

provisions must be made for the mitigation thereof 2

Mitigation (M) Well mitigated: Effective dust suppression methods

readily available 4


Reversibility (R) Irreversible: Not practical to reverse the impact once

it has occurred 1

Significance

Rating with

Mitigation -

Negative Impact

(S)

N x (E+D) x I x P ÷ ½(M+R)

Negligible 6.4

Significance

Rating without

Mitigation -

Negative Impact

(S)

N x (E+D) x I x P ÷ ½(M+R)

Moderate 32

Significance

Rating -Positive

Impact (S)

N x (E+D) x I x P x (H).

-


The Proponent will institute effective dust suppression measures on all un-surfaced access

and haul roads for the duration of the construction phase. Compliance thereto will be

measures against draft dust control standards (SANS1929:2005 – ‘industrial’) and associated

thresholds.

DRAFT EIA REPORT



9.3 OPERATIONAL PHASE The operational phase of the project encompasses all those aspects associated with the

actual treatment of waste at the sites, as well as those activities associated with the

management of secondary waste streams from that treatment processes .

All of the operational activities aforementioned in Section 3.1 have the potential to impact

on one, or more, environmental parameters, as evaluated and described in the following

sections.

9.3.1 NOISE

Introduction

The proponent must comply with the provisions of the Occupational Health and Safety Act,

1993 (Act No. 85 of 1993), as well as any other national norms and standards regarding

noise management. Noise impacts during operation are anticipated from the following

sources:

Combustions fans for the pyrolysis unit

The gas engine exhaust

The SRTS site is primarily surrounded by industrial areas. The nearest residential area to the

site is located approximately 1 km to the north-west of the SRTS plant, while the central

business district of Kroonstad is located approximately 1 km to the north-east of the SRTS

plant.

The Noise Control Regulations (R 154 GG 13717 of 10 January 1992) promulgated in terms

of ECA, defines:

Nuisance noise, as “any sound which disturbs or impairs or may disturb or impair

the convenience or peace of any person”; and

Disturbing noise, as “any noise level which exceeds the zone sound level or, if no

zone sound level has been designated, a noise level which exceeds the ambient

sound level at the same measuring point by 7 dBA or more”.

Regulation 4 states ‘No person shall make, produce or cause a disturbing noise, or allow it


combination thereof.’ In addition, Section 28 of NEMA imposes a ‘duty of care’ on every

person who may cause significant pollution to prevent such pollution or degradation from

occurring, continuing or recurring, or, in so far as such harm to the environment is

authorised by law or cannot reasonably be avoided or stopped, to minimise and rectify

such pollution or degradation of the environment. An increase of 7dB above current

ambient noise levels would thus be unacceptable, and the proponent would need to take

appropriate noise reduction measures to avoid creating ‘ disturbing noise’ during the

construction period; where construction phase noise monitoring may be required if

complaints arise from around noise during the construction phase.

DRAFT EIA REPORT



Impact discussion and significance assessment

Two aspects are important when considering the potential noise impacts of a project and

these are as follows:

The anticipated increase in the ambient noise level; and

The overall ambient noise level produced.

Table 9-6: Impacts on Ambient Noise Levels (Operation)

Nature (N) Negative impacts of construction related noise on

sensitive receptors 1

Extent (E) Locally: Within the vicinity of the site 2



Intensity (I) Moderate: Ambient noise levels would likely be

increased. 2

Probability (P) Likely: There is a possibility that the impact will occur,

to the extent that provisions must be made for it. 2

Mitigation (M) moderately mitigated: Viable avoidance and

minimisation techniques available 3


Reversibility (R) Reversible with the cessation of the activity 4

Significance Rating

with Mitigation -

Negative Impact (S)

N x (E+D) x I x P ÷ ½(M+R)

negligible 8

Significance Rating


Negative Impact (S)

N x (E+D) x I x P ÷ ½(M+R)

Low 14

Significance Rating


N x (E+D) x I x P x (H). -

Mitigation Management

The following are the Environmental, Health and Safety Guidelines of the IFC of the World

Bank, which should be taken into consideration:

Selecting equipment with lower sound power levels;

Installing suitable mufflers on engine exhausts and compressor components;

Installing vibration isolation for mechanical equipment; and

Develop a mechanism to record and respond to complaints.

Appropriate acoustic silencers need to be installed if the ambient noise levels are found to

be above the levels stipulated in The Noise Control Regulations (R 154 GG 13717 of 10

January 1992)

DRAFT EIA REPORT



9.3.2 GROUNDWATER POLLUTION

Introduction

The inappropriate storage, management and handling of fuel, oil and other potentially

hazardous chemicals and substances during the operational phase could result in

potentially negative impacts on surface and ground water quality; where spillages of such

could enter the groundwater environment in particular, through the infiltration of

contaminated surface run-off into the groundwater environment. Contamination of this

nature, associated with a project of this magnitude, would typically be hydrocarbon based

(i.e. petrol, diesel and oil leaks and spillages to bare soil surfaces). Temporary concrete

batching plants can also impact negatively on ground- and surface water resource quality

if poorly managed.

Groundwater contamination would generally be restricted to the confines of the site, or in

severe cases the immediate surrounds of the site. In the absence of a significant,

continuous, point source of pollution, a groundwater pollution plume would likely develop

and extend (i.e. in terms of lateral geographic extent) slowly within the underlying alluvial

aquifer.


The intensity of the impact will be low.

Table 9-7: Impacts on Water Resource Quality (operation)

Nature (N) Negative impact on water resource quality 1


surrounds

2

Duration (D) Long term: Only if a plume enters groundwater will it

be a long process to remediate contaminated

groundwater.

5

Intensity (I) Minor: The quantity of contaminants that have a

possibility of entering groundwater are small

2

Probability (P) Unlikely: The probability of a spill taking place during

operation is low

2

Mitigation (M) Good: There are many measures that can be

implemented in order to prevent water

contamination.

4


Reversibility (R) Slight: Groundwater remediation is possible but is a

lengthy and costly process.

2

Significance Rating

with Mitigation -

Negative Impact (S)

N x (E+D) x I x P ÷ ½(M+R)

Negligible 9.3

Significance Rating


Negative Impact (S)

N x (E+D) x I x P ÷ ½(M+R)

Low 18.6

Significance Rating


N x (E+D) x I x P x (H). -

DRAFT EIA REPORT




Since it is possible that the waste water will impact on the receiving hydrogeological

regime, mitigation/management measures will have to be put in place to negate any

potential contamination that may result. The following measures will have to be put in

place:

Store all potential sources in secure facilities with appropriate storm water

management, ensuring contaminants are not released into the environment.

Implement the EMP’s of other environmental related aspects, including

pollution prevention and impact minimisation.

DRAFT EIA REPORT



9.3.3 AIR QUALITY

Introduction

The proposed operations will produce emissions from the pyrolysis process as well as the

internal combustion engine. An emission inventory for operations was formulated based on

emission limits as stipulated in GN 893. Only sources of potential significance were

modelled. Emissions information was provided by the technology provider, based on the

guarantee that the emissions limits will be met. The proposed operations will have a single

stack combining all emissions.


The emission from the proposed SRTS site was modelled to show the impacts the waste to

energy operations would have on the local ambient air quality. As there are no significant

industrial background contributors to ambient emissions only the proposed operations were

modelled as a part of the Air Quality Impact Assessment (AQIA). The findings of the AQIA

are set out below, for more detail refer to Appendix 7: Air Quality Impact Assessment.

DRAFT EIA REPORT



Predicted concentrations for PM10 & PM2.5

Predicted maximum daily-averaged ambient concentrations of PM10 resulting from both

the site and the cumulative scenario are well within the NAAQS (75 µg/m3). As the total

PM10 ambient concentrations are below that of the PM2.5 ambient limits (25 µg/m3), the

PM2.5 ambient concentrations will automatically be met.

Figure 9-1: Predicted PM10 maximum 24-Hour average ambient concentration for the

Proposed Waste to Energy Project

DRAFT EIA REPORT



Predicted concentrations for SO2

Only the maximum hourly SO2 results are presented here. The impact from the proposed

operations as well as background emitters is well within the national ambient air quality

standards for all regulated averaging periods.

Figure 9-2: Predicted SO2 maximum hourly average ambient concentration for the

Proposed Waste to Energy Project

DRAFT EIA REPORT



Predicted Ambient NO2

Only the maximum hourly NO2 results are presented here. The impact from the proposed

operations is well within the national ambient air quality standards for all regulated

averaging periods.

Figure 9-3: Predicted NOx hourly maximum ambient concentration for the Proposed Waste

to Energy Project

DRAFT EIA REPORT



Predicted Concentrations AMBIENT CO

There is no predicted exceedance of the hourly CO ambient limit due to emissions from

the proposed waste to energy project.

Figure 9-4: Predicted CO hourly maximum ambient concentration for the Proposed

Waste to Energy Project

DRAFT EIA REPORT



Conclusion

The AQIA report shows that the impact on ambient air quality resulting from proposed

waste to energy process point sources is well within the ambient limits. Thus the impact

significance is considered to be low.


The technology provider has ensured that the emissions limits utilised for the emissions

modelling will be met. In order to ensure this a regenerative thermal oxidiser is proposed

as an abatement measure.

9.3.4 SOCIO ECONOMIC

Introduction

The proposed project would result in the employment of three technical operators. The

socio-economic impact of this is therefore not deemed to be of high significance


The proposed project will have a positive socio-economic impact.


N/A

DRAFT EIA REPORT



10. ASSESSMENTS OF CUMULATIVE IMPACTS

The NEMA 2010 Regulations states that a ‘cumulative impact’, in relation to an activity,

means the impact of an activity that in itself may not be significant but may become

significant when added to the existing and potential impacts eventuating from similar

or diverse activities or undertakings in the area. The outputs of a cumulative impact

assessment can be -

1. the identified sources of cumulative impacts;

2. the sequence of events from source to effect; or

3. the resultant effects.

Cumulative impact assessment methods are evolving and there is no single accepted

state of global practice. Key is to consider cumulative impacts as integral to the

assessment of impacts and that activity induced impacts not be seen in isolation but

considered using a wider systems based approach to consider both the assimilative

capacity to absorb cumulative impacts. This impact assessment considers all impacts in

a cumulative sense throughout. See list below for further details.

Potential cumulative impacts have been identified for the proposed project, as follows,

and have been intrinsically assessed in specialist studies utilising state of the art

modelling and also as part of the EIA itself and relevant supporting specialist

assessments:

The specialist air quality impact assessment undertaken in support of the EIA took

due consideration of the potential existence of other potentially significant

emission sources in the area (i.e. that may contribute toward cumulative

impacts on ambient air quality, together with the proposed plant’s emissions).

No such source was identified.

The air quality impact assessment further considered the cumulative impacts of

criteria pollutant emissions on ambient air quality resulting from all relevant onsite

sources.



11. CONCLUSIONS AND EAP RECOMMENDATIONS

11.1 IN SUMMARY In light of high cost of disposal and long distances of material transport to a licensed

disposal facility associated with the current disposal of the SRTS abattoir’s waste to landfill

a better solution was sought for to deal with the waste from the SRTS abattoir. EScience

Associates (ESA) was appointed by SRTS, as the independent Environmental Assessment

Practitioner (EAP), to facilitate the application for obtaining a Waste Management

License for a proposed power generation plant through pyrolysis of abattoir waste. The

aforementioned application was submitted to the National Department of Environmental

Affairs (DEA) on 14th November 2013, and acknowledged by the DEA on 22nd November

2013. The application was assigned the reference number 12/9/11/L1391/2. The final

scoping report, after having undergone public review, was submitted to the DEA on 29th

May 2014. The DEA accepted the scoping report on 4th July 2014 and a letter stating the

acceptance of the Scoping Report was received by the EAP on 7th July 2014

The main objective of this report was to identify and discuss issues of potential

environmental significance, and where possible, indicate the significance of those

impacts. The identification and assessment of environmental impacts, for every project

phase, revealed that there are some potential impacts. However the problems that have

been highlighted can be addressed through stringent and rigorous mitigation measures.

The need for the pyrolysis plant is strong and it will greatly reduce the amount of waste to

landfill, as well as the high cost associated with the transport of this waste. It is therefore

the opinion of the EAP that the project should go ahead as long as a strict EMPr is

formulated and adhered to from the construction all the way to decommissioning phase.

11.2 CONCLUSIONS

11.2.1 CONSTRUCTION

Potential construction phase impacts of significance include noise, dust, traffic and soil

and ground water contamination. With sufficient mitigation these impacts will be easily

managed and kept within legal limits.

No identified construction phase impacts are identified to pose a fatal flaw to the project,

provided that the mitigation put forward in this EIA and the attached EMPR are complied

with by the proponent during construction.

11.2.2 OPERATION

The operational phase too has the potential to result in impacts such as ground water

contamination, air emissions and noise. Provided sufficient containment infrastructure is in

place where storage of hazardous substances occurs the contamination of groundwater

can be prevented. The air emissions are to be within stipulated legal limits shown in Table

5-6.

Appendix 7: Air Quality Impact Assessment shows that the impact on ambient air quality

resulting from proposed waste to energy process point sources is well within the ambient

limits.



No fatal flaws have been identified for the project during the operational phase thereof,

provided that the full range of mitigation and monitoring requirements put forward in this

EIA and the attached EMPR are complied with by the proponent during operation.



12. REFERENCES

Department of Labour (2005), Explanatory Notes on the Major Hazard Installation

Regulations by Chief Directorate of Occupational Health and Safety in the Department of

Labour. April 2005.

DWAF (1998), Department of Water Affairs and Forestry Minimum Requirements for the

Handling, Classification and Disposal of Hazardous Waste, Edition 2 1998.

South African Weather Services: www.weathersa.co.za

http://www.weathersa.co.za/



APPENDIX 1: AUTHORITY CORRESPONDENCE



APPENDIX 2: WASTE MANAGEMENT LICENSE APPLICATION

FORM



APPENDIX 3: LAYOUT PLAN FOR PROPOSED STRUCTURES AND

INFRASTRUCTURE



APPENDIX 4: PUBLIC PARTICIPATION DOCUMENTATION



APPENDIX 5: SCOPING REPORT



APPENDIX 6: EAP CV’S



APPENDIX 7: AIR QUALITY IMPACT ASSESSMENT



APPENDIX 8: WASTE ASSESSMENT



APPENDIX 9: ENVIRONMENTAL MANAGEMENT PROGRAMME

REPORT

Documents

PROPOSED POWER GENERATION PLANT THROUGH THE … Draft EIA Report... · 2019-10-23 · proposed power generation plant through the pyrolysis of abattoir waste, kroonstad, free state