Cape Environmental Assessment Practitioners (Pty) Ltd

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1 Cape Environmental Assessment Practitioners (Pty) Ltd Reg. No. 2008/004627/07 Telephone: st Floor, Eagles View Building Facsimile: Progress Street, George Web: P.O. Box 2070, George, 6530 ENVIRONMENTAL AND MAINTENANCE MANAGEMENT PROGRAMME TURA KINA DAM UPGRADE & EXPANSION PORTION 1 OF 169, TURA KINA, HOEKWIL In terms of the National Environmental Management Act (NEMA, Act 107 of 1998 as amended) Prepared for Applicant: K.R.R. Trust By: Cape EAPrac Report Reference: GEO307/03 DEA&DP Reference: 14/2/1/3/D2/30/0035/14 Case Officer: Ziyaad Allie Date: 15 January 2015 D.J. Jeffery Directors L. van Zyl

2 APPOINTED ENVIRONMENTAL ASSESSMENT PRACTITIONER: Cape EAPrac Environmental Assessment Practitioners PO Box 2070 George 6530 Tel: Fax: Report written & compiled by: Melissa Mackay (BTech & ND Nature Conservation), who has eight years experience as an environmental practitioner. PURPOSE OF THIS REPORT: Application for Environmental Authorisation APPLICANT: K.R.R. Trust CAPE EAPRAC REFERENCE NO: GEO307/03 SUBMISSION DATE 15 January 2015

3 Portion 1 of 169, Tura Kina Ref: GEO307/03 ENVIRONMENTAL AND MAINTENANCE MANAGEMENT PROGRAMME Submitted in terms of: DEA&DP COMPLIANCE PORTION 1 OF 169, TURA KINA, HOEKWIL In terms of the National Environmental Management Act (NEMA, Act 107 of 1998) This report is the property of the Author/Company, who may publish it, in whole, provided that: That written approval is obtained from the Author and that CAPE EAPrac is acknowledged in the publication; That CAPE EAPrac is indemnified against any claim for damages that may result from any publication of specifications, recommendations or statements that is not administered or controlled by CAPE EAPrac; The contents of this report, including specialist/consultant reports, may not be used for purposes of sale or publicity or advertisement without the prior written approval of CAPE EAPrac. CAPE EAPrac accepts no responsibility by the Applicant/Client for failure to follow or comply with the recommended programme, specifications or recommendations contained in this report. CAPE EAPrac accepts no responsibility for deviation or non-compliance of any specifications or recommendations made by specialists or consultants who s input/reports are used to inform this report. All figures, plates and diagrams are copyrighted and may not be reproduced by any means, in any form, in part or whole without prior written approved from CAPE EAPrac. Report Issued by: Cape Environmental Assessment Practitioners Tel: PO Box 2070 Fax: Progress Street Web: George 6530 Cape EAPrac Environmental & Maintenance Management Programme

4 Portion 1 of 169, Tura Kina Ref: GEO307/03 ORDER OF REPORT Environmental Management Programme Appendix 1 : Environmental Poster Appendix 2 : Recycling Information Appendix 3 : Alien Invasive Vegetation Type and Controls Cape EAPrac Environmental & Maintenance Management Programme

5 Portion 1 of 169, Tura Kina Ref: GEO307/03 Table of Contents 1 INTRODUCTION Purpose of the EMMP Status of the EMMP PROJECT PHASING Construction Phase Operation Phase Closure and Decommission Phase DEVELOPMENT PROPOSAL LEGISLATIVE REQUIREMENTS National Environmental Management Act (NEMA, Act 107 OF 1998) Environment Conservation Act, 1989 (ECA) National Water Act (NWA) National Waste Management Strategy Conservation of Agricultural Resources Act (CARA, Act 43 of 1983) Occupational Health and Safety Act (Act 85 of 1993) RESPONSIBILITIES Project Proponent Engineers and Contractors Environmental Induction and Training CONSTRUCTION PHASE ENVIRONMENTAL MANAGEMENT REQUIREMENTS OPERATIONAL PHASE ENVIRONMENTAL MANAGEMENT REQUIREMENTS General Watercourse Access Routes Erosion Control Fire management and protection Soil Protection Cape EAPrac Environmental & Maintenance Management Programme

6 Portion 1 of 169, Tura Kina Ref: GEO307/ Water Management Rainwater Tanks Irrigation Water Management Waste Management Solid Waste Recycling Noise and Emission Control Alien Vegetation Management Health and Safety DECOMMISSIONING PHASE ENVIRONMENTAL MANAGEMENT REQUIREMENTS NON-COMPLIANCE Procedures MONITORING Water Quality Irrigation: CONCLUSION REFERENCES Figures Figure 1: Upgraded irrigation dam October 2014 (Google Earth Pro 2014)... 1 Figure 4: EMMP implementation organisational structure Tables Table 1: DWA Sludge Monitoring Guide (DWA, 2006) Table 2: Soil monitoring where sludge is used (DWA, 2006) Cape EAPrac Environmental & Maintenance Management Programme

7 Portion 1 of 169, Tura Kina Ref: GEO307/03 Glossary of Terms EMP Environmental Management Programme an environmental management tool used to ensure that undue or reasonably avoidable adverse impacts of the construction, operation and decommissioning of a project are prevented and that positive benefits of the projects are enhanced. MMP Maintenance Management Plan - an environmental management tool used to ensure that undue or reasonably avoidable adverse impacts of the operation and decommissioning of a project that is ongoing and regular, are prevented and that positive benefits of the projects are enhanced. DEA National Department of Environmental Affairs the national authority responsible for the sustainable environmental management and integrated planning. DEA&DP Department of Environmental Affairs and Development Planning the provincial authority for sustainable environmental management and integrated development planning. DWA Department of Water Affairs the provincial authority mandated to enforce the Forestry Act. Permits for the removal or pruning of protected tree species eg Milkwoods must be obtained from this entity. CARA Conservation of Agricultural Resources Act (Act 43 of 1983) - provides for control over the utilization of the natural agricultural resources of the Republic in order to promote the conservation of the soil, the water sources and the vegetation and the combating of weeds and invader plants; and for matters connected therewith. ECA Environment Conservation Act, To provide for the effective protection and controlled utilization of the environment and for matters incidental thereto. ECO Ecological Control Officer independent site agent appointed by a proponent to observe and enforce environmental policies and principles on a development site. HWC Heritage Western Cape Provincial body responsible for enforcing the National Heritage Resources Act in the Western Cape. NEMA National Environmental Management Act (Act 107 of 1998, as amended) national legislation that provides principles for decision-making on matters that affect the environment. Cape EAPrac Environmental Management Programme

8 Portion 1 of 169, Tura Kina Ref: GEO307/03 1 INTRODUCTION Cape Environmental Assessment Practitioners (Cape EAPrac) has been appointed by the proponent K.R.R. Trust as the independent Environmental Assessment Practitioner (EAP) responsible for ensuring compliance with Section 28 (General Duty of Care) of the National Environmental Management Amendment Act (NEMA), Act 107 of 1998, for the upgrade and expansion of an existing irrigation dam on Portion 1 of 169, Tura Kina near Hoekwil. An Application for a 24G Rectification process in terms of NEMA has been submitted to the provincial Department of Environmental Affairs and Development Planning (DEA&DP). This Environmental and Maintenance Management Programme (EMMP) is being drafted to ensure that the management activities continue with due diligence and consideration for the environment. The construction activities were completed in Portion 1 of 169 Tura Kina is located near Hoekwil in the southern Cape. This area is identified in the George Municipality Spatial Development Framework as an intensive agricultural zone. The property is one of several under the Trust that supports a dairy of approximately 1500 cattle. The applicant upgraded and expanded an existing irrigation dam to a capacity of approximately m³. Figure 1: Upgraded irrigation dam October 2014 (Google Earth Pro 2014) This EMMP contains management requirements and recommendations made by Cape EAPrac, as well as in terms of the regulations contained in the National Environmental Management Act (NEMA, Act 107 of 1998), specifically Section 24N and Best Practice principles. Cape EAPrac 1 Environmental & Maintenance Management Programme

9 Portion 1 of 169, Tura Kina Ref: GEO307/03 This version of the EMMP should be updated to include any conditions, additional recommendations or changes that may occur during the scope of the works, whichever is necessary. It is only considered to be a Final document once it has received approval from the competent authority. Section 28 of NEMA provides for the Duty of Care principle that obliges every person who causes, has caused or may cause significant environmental degradation to take reasonable measures to prevent such degradation from occurring, continuing or recurring. This clause forms the underpinning philosophy of this EMMP. This EMMr must be included in ALL tender and contract documents and is binding on the applicant, contractors, sub contractors, consultants, agents and employees associated with this project. 1.1 PURPOSE OF THE EMMP The purpose of this EMMP is to ensure that the environmental impacts of the activities associated with the upgrade and expansion of the irrigation dam, are managed, mitigated and kept to a minimum during the lifespan of the dam. In addition, maintenance activities required for the cleaning and upkeep of the dam in future should be considered with this EMMP. These activities will be ongoing and occur regularly over a period of years and this EMMP must ensure that spatial and temporal impacts are addressed. The EMMP must provide easily understood and clearly defined actions that should be implemented during each phase of the proposed development. The EMMP is a dynamic document that is flexible and responsive to new and changing circumstances. The document is binding on the Project Proponent, all contractors and sub-contractors and visitors to the site. It must be included as part of any tender documents as well as contractual documents between the Project Proponent and any contractors. Copies of this EMMP must be kept on site and all senior personnel are expected to familiarise themselves with the content of this EMMP. 1.2 STATUS OF THE EMMP The EMMP must form part of all contract documents including all tender and final documents. It must be read in conjunction with the contract documents including the Specifications and where applicable, the Bill of Quantities as drawn up for any contracts. Where a conflict exists between the Specifications and Bill of Quantities and the Maintenance Management Plan the matter shall be brought to the attention of the Proponent and Consulting Engineer. The approval of the EMMP by the Department of Environmental Affairs and Development Planning (DEA&DP) will confer a legal obligation to comply with the specifications of the EMMP Cape EAPrac 2 Environmental & Maintenance Management Programme

10 Portion 1 of 169, Tura Kina Ref: GEO307/03 on the project proponent and the appointed contractors. Any substantial changes, updates or upgrades to the EMMP must be submitted to and approved by the DEA&DP. 2 PROJECT PHASING 2.1 CONSTRUCTION PHASE The construction phase of the development refers to the actual construction associated with the expansion of the dam, including all earthworks. These activities were completed in The ongoing activity (cleaning out of silt / maintenance of dam wall) is an ongoing activity that is undertaken whenever required. The upgraded dam is an existing one, thus there is no real construction phase activities, rather an ongoing Operational Phase for the maintenance of these facilities. As such the information provided in this EMMP for this phase of the project is limited. 2.2 OPERATION PHASE The operational phase of the development will entail the following activities: 1. the cleaning out of silt and slurry from the in-stream irrigation dam and maintenance of the dam wall whenever necessary. The Operational Phase of this project includes the access of heavy machinery (excavator or diggers) onto the basin of the irrigation dam, the excavating of substrate and maintenance to the dam wall. 2.3 CLOSURE AND DECOMMISSION PHASE Decommissioning refers to the process of removing the operating assets of the project after completion of the operating life cycle. It is highly unlikely that the development will be decommissioned as irrigation for development of farmland is an ongoing activity, especially in an area designated for intensive agriculture. As such, specific management recommendations are not included with this EMMP. In the event that decommissioning is required, all relevant legal processes must be complied with. Cape EAPrac 3 Environmental & Maintenance Management Programme

11 Portion 1 of 169, Tura Kina Ref: GEO307/03 3 DEVELOPMENT PROPOSAL The activity comprises original construction to expand and upgrade the existing irritation dam on Portion 1 of 169, as well as the excavation of substrate (in the form of silt) from the in-stream irrigation dam and the maintenance of the irrigation dam wall in the future. The specifications of the new irrigation dam are as follows: Footprint: Storage / Irrigation Dam m² (3.34ha) Volume: Storage / irrigation Dam m³ Length of dam: Storage / irrigation Dam 428m Width of dam at widest point: Storage / irrigation Dam 116m Maximum wall height: Storage / irrigation Dam 8.5m Crest length dam wall: Storage / irrigation Dam 120m Maximum depth: Storage / irrigation Dam 10.7m 4 LEGISLATIVE REQUIREMENTS The Project Proponent is required to comply with all necessary legislation and policies applicable to the above mentioned development. These include but are not limited to: 4.1 NATIONAL ENVIRONMENTAL MANAGEMENT ACT (NEMA, ACT 107 OF 1998) The National Environmental Management Act (NEMA, Act No. 107 of 1998, as amended) embraces the notion of sustainable development as contained in the Constitution in that everyone has the right: - to an environment that is not harmful to their health or well-being; and Cape EAPrac 4 Environmental & Maintenance Management Programme

12 Portion 1 of 169, Tura Kina Ref: GEO307/03 - to have the environment protected for the benefit of present and future generations through reasonable legislative and other measures. NEMA aims to provide for cooperative environmental governance by establishing principles for decision-making on all matters relating to the environment and by means of Environmental Implementation Plans (EIP) and Environmental Management Programmes (EMP). The 24G Rectification process requires an EMP as a retrospective exercise but also to monitor operational impacts of the activity. As such it is necessary to consider maintenance activities as they are integral to the operation of the dam into the future. The excavation of silt from the in-stream dam and reconstruction of the wall will exceed the removal / moving of more than 5m³ from a watercourse and in terms of the NEMA and the 2010 and 2014 EIA Regulations, this will trigger a listed activity and requires authorisation from the competent authority. In terms of Circular 1 of 2013 issued by the Department of Environmental Affairs and Development Planning (DEA&DP), an applicant may submit a Maintenance Management Plan (MMP) for maintenance and reconstruction purposes if Activity 18 of Listing Notice 1 (R544) is triggered (or the equivalent in terms of the 2014 EIA Regulations). This is only applicable to Activity 18. Should any other activities also require authorisation, then an Environmental Impact Assessment must be undertaken. Activity 18 states The infilling or depositing of any material of more than 5m³ into, or the dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock of more than 5m³ from : (i) (ii) (iii) (iv) a watercourse; the sea; the seashore; the littoral active zone, an estuary or a distance of 100m inland of the highwater mark of the sea or an estuary, whichever distance is the greater excluding where such infilling, depositing, dredging, excavation, removal or moving; (a) (b) is for maintenance purposes undertaken in accordance with a management plan agreed to by the relevant environmental authority; or occurs behind the development setback line. An MMP must be informed by adequate information and an appropriate level of public participation. This EMMP is being submitted for both the retrospective activity as well as the maintenance of the activity into the future. Cape EAPrac 5 Environmental & Maintenance Management Programme

13 Portion 1 of 169, Tura Kina Ref: GEO307/ ENVIRONMENT CONSERVATION ACT, 1989 (ECA) The EIA regulations contained in the Environmental Conservation Act (ECA) have been replaced by NEMA. The contractor must, however, comply with the draft regulations pertaining to noise as published in the province of Western Cape Provincial Extraordinary Gazette as provision made in section 25 of the ECA), as well as Section 24 of the ECA regarding waste management and Section 20 of the ECA dealing with waste management under Part IV, Control of Environmental Pollution. The cleaning out of the in-stream irrigation dam is considered best practice in terms of reducing and minimizing the impact of nutrient rich water running into a natural drainage system and further contributing to eutrophication of downstream dams and the system. 4.1 NATIONAL WATER ACT (NWA) The National Water Act (NWA) gives effect to the constitutional right of access to water. The Act s overall purpose is to ensure that South Africa's water resources are protected, used and managed in ways which take into account a number of factors, including inter-generational equity, equitable access, redressing the results of past racial and gender discrimination, promoting sustainable and beneficial use, facilitating social and economic development, and providing for water quality and environmental protection. The NWA makes persons who own, control, occupy or use land responsible for taking measures to prevent pollution of water resources, and empowers Government authorities to take measures to enforce this obligation. A Catchment Agency may enforce these obligations and recover costs from those responsible or from those who benefited from the measures. In terms of the water use for the relevant properties under the NWA, Registration Certificates have been issued by DWA for the storage of water. The DWA have requested the submission of a Water Use License Application (WULA) in order to amend the existing Registration. The WULA has been submitted to DWA for consideration and is included in the documentation in the 24G Rectification Application. 4.2 NATIONAL WASTE MANAGEMENT STRATEGY The National Waste Management Strategy presents the South African government's strategy for integrated waste management for South Africa. It deals among others with: Integrated Waste Management Planning, Waste Information Systems, Waste Minimisation, Recycling, Waste Collection and Transportation, Waste Treatment, Waste Disposal and Implementing Instruments. Waste management as part of the General Duty of Care should be implemented on the property. Cape EAPrac 6 Environmental & Maintenance Management Programme

14 Portion 1 of 169, Tura Kina Ref: GEO307/ CONSERVATION OF AGRICULTURAL RESOURCES ACT (CARA, ACT 43 OF 1983) The Conservation of Agricultural Resources Act (CARA) aims to provide for the conservation of natural agricultural resources by maintaining the production potential of land, combating and preventing erosion and weakening or destruction of water resources, protecting vegetation and combating weeds and invader plant species. Its application for this EMMP applies to the protection of soil and water resources as well as the management of alien invasive vegetation. 4.4 OCCUPATIONAL HEALTH AND SAFETY ACT (ACT 85 OF 1993) The Act provides for the health and safety of persons at work and for the health and safety of persons in connection with the use of plant and machinery; the protection of persons other than persons at work against hazards to health and safety arising out of or in connection with the activities of persons at work. In terms of this Act, a Health and Safety Officer and Protocol must be implemented on the site during construction. 5 RESPONSIBILITIES Details of the organisational structure for the implementation of this EMMP are presented in Figure 4 below. The structure illustrates the reporting procedures for stakeholders in the implementation of this EMMP. Authority DEA&DP Project Proponent Environmental / Maintenance Management Plan Engineers / Contractors Figure 2: EMMP implementation organisational structure. Sub-Contractors Cape EAPrac 7 Environmental & Maintenance Management Programme

15 Portion 1 of 169, Tura Kina Ref: GEO307/ PROJECT PROPONENT The Project Proponent is the person or entity who is responsible for carrying out the Activity that is authorised in terms of NEMA and / or this EMMP. The responsibilities of the Project Proponent include but are not limited to the following: - Be conversant with the EMMP, any relevant Environmental Authorisation, Waste License, Permit or any other legally binding documentation; - Ensure that the senior site personnel are aware of and understand the conditions and recommendations contained in the EMMP, any relevant Environmental Authorisation, Waste License, Permits or any other legally binding documentation; - Order the removal of any person(s) and / or equipment found in contravention of any of the above mentioned authorisations. 5.2 ENGINEERS AND CONTRACTORS The Engineers and Contractors, where applicable, are responsible for physically carrying out the relevant activities. The responsibilities indicated here are also relevant to Sub-Contractors. The responsibilities of the Engineers and Contractors include but are not limited to the following: - Be conversant with the EMMP, any relevant Environmental Authorisation, Waste License, Permit or any other legally binding documentation; - Have a responsibility to adhering to any conditions and recommendations laid out in above mentioned documentation; - Prevent actions that may cause harm to the environment; - Be responsible for any remedial activities in response to an environmental incident within their scope of influence; - Liaise with the Project Proponent in the event that any industry regulated standards are in contradiction with the EMMP or any other authorisations; - Review and amend any construction activities to align with the EMMP and Best Practice Principles; - Ensure compliance of all site personnel and / or visitors to the EMMP and any other authorisations. 5.3 ENVIRONMENTAL INDUCTION AND TRAINING The Project Proponent shall ensure that adequate environmental awareness training of senior site personnel takes place and that all construction workers receive an induction presentation on the importance and implications of the EMMP. The presentation shall be conducted, as far as is possible, in the employees language of choice. The contractor should provide a translator from their staff for the purpose of translating should this be necessary. As a minimum, training should include: Cape EAPrac 8 Environmental & Maintenance Management Programme

16 Portion 1 of 169, Tura Kina Ref: GEO307/03 - Explanation of the importance of complying with the EMMP. - Discussion of the potential environmental impacts of operation activities. - The benefits of improved personal performance. - Employees roles and responsibilities, including emergency preparedness (this should be combined with this induction, but presented by the contractors Health and Safety Representative). - Explanation of the mitigation measures that must be implemented when carrying out their activities. - Explanation of the specifics of this EMMP and its specification (no-go areas, etc.) - Explanation of the management structure of individuals responsible for matters pertaining to the EMMP. Should the staff turnover be high and with additional appointment of sub-contractors, it may be necessary to do additional induction training sessions. 6 CONSTRUCTION PHASE ENVIRONMENTAL MANAGEMENT REQUIREMENTS Since construction activities are no longer applicable to this activity, there are no specific requirements effective. 7 OPERATIONAL PHASE ENVIRONMENTAL MANAGEMENT REQUIREMENTS The Operational Phase for the properties relates to the activities required for cleaning out of the dam and any maintenance to the irrigation dam wall. These activities will take place on an ad hoc basis whenever required. This Phase of the activity requires certain general management considerations which should be implemented in order to ensure the long term viability of the project. The impacts on the receiving environment associated with these activities are mostly those that will affect the integrity, status and nature of the watercourse, hence the association with this EMMP with Activity 18 of NEMA (or the similar listing in the 2014 EIA Regulations). These could include: Impacts on the water quality in the system from eutrophication, sedimentation, siltation, chemical imbalance and pollution; Impacts on water quantity from unlawful use and storage, unnecessary use, increased stormwater runoff and impeding water flow; Impacts on the physical characteristics of the watercourse from sedimentation, siltation, impeding water flow, increasing water flow, transfer of alien invasive vegetation, erosion. The existing dam will possibly be causing some or all of these impacts on the watercourse. In order to achieve these improvements, and to ensure future management of the watercourse, this Cape EAPrac 9 Environmental & Maintenance Management Programme

17 Portion 1 of 169, Tura Kina Ref: GEO307/03 EMMP includes management mitigations and requirements associated with all the proposed activities. The following items should be integrated into the management of the activity whenever required on the relevant properties: 7.1 GENERAL The final footprint of the irrigation dam may not exceed the existing disturbance footprint. Material removed from the dams must be inspected to determine what portion can be reused in the reconstruction of the dam wall while the remaining nutrient rich material should be used as organic fertilizer. 7.2 WATERCOURSE The irrigation dam is an instream storage dam. Overflow water released from the dam continues downstream onto other properties. The following must be undertaken to protect the integrity of the watercourse and the availability of water to downstream users: The area outside of the existing footprint on the downstream side of the dam must be clearly demarcated during maintenance periods. No vehicles may access nor associated activities take place downstream of the demarcation; None of the material removed from the irrigation dam may be disposed of in the watercourse; Should any additional material be required in the maintenance of the dam wall such material may not be excavated within 32m from a watercourse (with the exception of material coming out of the dam basin); 7.3 ACCESS ROUTES Access for heavy machinery into the dam is required on an ad hoc basis to remove slurry and silt. It is recommended that the same access point is used each time to minimise the impact on the watercourse edges and dam wall. This access should ensure the following: No access via steep banks; Only existing access points and roads may be used; Only single tracks may be used; Other than within the in-stream dam (i.e. along its banks and in the basin) no vehicles may be allowed within the watercourse downstream of the irrigation dam; Vehicles may not remain in the dams unattended when not in use; Drivers must adhere to the general recommendations included in this EMMP, with specific regard to waste management and air emissions; Cape EAPrac 10 Environmental & Maintenance Management Programme

18 Portion 1 of 169, Tura Kina Ref: GEO307/03 Access routes must be protected against bank erosion and stormwater damage once the vehicles have left the watercourse; Access into the dam may only be used for vehicles required for excavating material, and maintaining the dam wall; Vehicles leaking oil or diesel may not access the dams and must be repaired before continuing with the activity. 7.4 EROSION CONTROL During excavation periods, the Contractor shall protect all areas susceptible to erosion by installing necessary temporary and permanent drainage works as soon as possible and by taking any other measures necessary to prevent stormwater from concentrating in streams and scouring slopes, banks, etc. Any erosion channels developed during construction on steep slopes must be backfilled, compacted and restored to an acceptable condition. Stabilisation of cleared areas to prevent and control erosion and/or sedimentation shall be actively managed. Consideration and provision shall be made for the following methods (or combination thereof): brushcut packing, mulch or chip cover, straw stabilising, watering, planting/sodding, soil binders and anti-erosion compounds, mechanical cover or packing structures (including the use of geofabric, log/pole fencing, etc.). Traffic and movement over stabilised areas shall be restricted and controlled, and damage to stabilised areas shall be repaired and maintained. Please also refer to Section 7.6 regarding Soil Protection. 7.5 FIRE MANAGEMENT AND PROTECTION The property is located in an area that has the potential of being a high risk fire area and the utmost care must be taken to ensure that none of the activities result in wild fires. Precautions must be undertaken to protect habitation, biodiversity and against loss of life and infrastructure. Out of season, excessively hot and uncontrolled fires along watercourses can lead to erosion of the banks and edges, as well as the pollution of water with excessive ash and debris. The following points must be considered with regards to fire protection on site: - NO OPEN FIRES are allowed anywhere on site without adequate supervision in place, except for cooking purposes and then only under controlled conditions; - Cigarette butts may not be thrown in the veld, but must be disposed of correctly in suitable receptacles. These can be glass or plastic bottles half filled with sand; - In case of an emergency, the contact details of the local fire and emergency services must be readily available; Cape EAPrac 11 Environmental & Maintenance Management Programme

19 Portion 1 of 169, Tura Kina Ref: GEO307/03 - Contractors / labour teams must ensure that basic firefighting equipment is available on site. 7.6 SOIL PROTECTION The Department of Water Affairs (2006) supports the use of manure as an organic fertiliser for use on pastures. The slurry generated by the dairy is thus a valuable source of nutrients to improve the condition of soil. The major benefits of manure application are: Supply of major plant nutrients (calcium, magnesium, potassium, phosphorus, nitrogen); Supply of some essential micronutrients (zinc, copper, molybdenum and manganese) and; Improvement in soil physical properties, i.e. better soil structure, increased water retention capacity and improved soil water transmission. The WWF (2010) further supports the use of manure as an organic fertiliser, with implementation of conditions to prevent unnecessary overuse which can lead to environmental degradation. The following requirements should be considered when spreading slurry onto agricultural pastures and as general good practice for soil fertility and structure: Soil Fertility: o Analyse both soil and crop samples to determine the exact amount and type of fertiliser required, and aim to fill nutrient gaps rather than simply increasing total N and P. o Time and target fertiliser application to coincide with maximum plant uptake periods and apply fertiliser in regular smaller doses rather than few large doses. o Store synthetic fertilisers on an impermeable floor. Avoid interim storage in open fields, as this poses a high pollution risk. o Fertiliser spreading machines should never be washed in rivers, lakes or near drinking water wells and springs. o Where possible, use organic fertilisers that contain a carbon source (for example compost, manure and plant matter especially from legumes). o Maintain a permanent soil cover use either cover crops or mulch. o Avoid excessive irrigation and ensure good water quality. o Reduce the use of pesticides and herbicides that cause a decline in soil microorganisms. Livestock: o Prevent overgrazing, trampling and soil erosion. o Rehabilitate degraded veld. o Ensure that veld improvement techniques are well understood and well managed to avoid environmental damage and a long-term decrease in productivity. Cape EAPrac 12 Environmental & Maintenance Management Programme

20 Portion 1 of 169, Tura Kina Ref: GEO307/ WATER MANAGEMENT Water resources in the Southern Cape are under threat due to the changing weather patterns in the area. Although there is sufficient water allocated for agricultural activities on this property, it is highly recommended that every effort is made to minimise the unnecessary use of water Rainwater Tanks Rainwater harvesting can provide a sustainable source of water, not necessarily required for human consumption that minimises the usage of water from sources. Rain water harvesting should be implemented on every hard surface where possible. This water can be utilised for landscaping and other outdoor use, or alternatively used to feed into water mains providing for showers and other ablution functions Irrigation Water Management Irrigation infrastructure should be developed in such a way that the right amount of water is applied to the crop at the right time so that energy is used as efficiently as possible, production is optimized and as little water as possible is lost to non-beneficial consumption. Technology and good agricultural practices should be used to optimize irrigation water management. These include: Remove invasive alien plants and replace with indigenous vegetation. Invasive alien plants that establish in watercourse are spread downstream. Restore and protect watercourses (remove alien plants, control burning and grazing, do not cultivate). Build up soil organic matter to reduce evaporative water loss and maximise the soil s water-holding capacity. Use more efficient irrigation systems. Ensure efficient irrigation techniques that take into account soil type, crop type, soil water status and weather conditions. Implementing and monitoring soil moisture to determine correct irrigation schedules. Implementing and monitoring flow rates to provide correct and up to date data on water usage. Record actual water use to compare against registered use. Implement water-harvesting and water-recycling techniques where possible. Use drought-resistant crop and livestock varieties. Planting of crops in correct soil types to ensure optimal growth with efficient water usage. Implement and monitoring of water pressure in pipes. Cape EAPrac 13 Environmental & Maintenance Management Programme

21 Portion 1 of 169, Tura Kina Ref: GEO307/03 Ensuring that all equipment (pumps, pipes and irrigation mechanisms) are maintained and in good working order. This will minimise leaks and other water loss and ensure a longer life cycle for equipment. Use of cut off valves on storage facilities (where applicable) to prevent overflow. Efficient use of energy by means of timing and control devices. 7.8 WASTE MANAGEMENT Any waste materials generated during the undertaking of the activities must be dealt with appropriately Solid Waste The Project Proponent shall ensure that all facilities are maintained in a neat and tidy condition and the site shall be kept free of litter. Measures must be taken to reduce the potential for litter and negligent behavior with regard to the disposal of all refuse. At all places of work the Project Proponent shall provide litterbins, containers and refuse collection facilities for later disposal. Solid waste may be temporarily stored on site in a designated area prior to collection and disposal. Solid waste must be removed to an accepted waste disposal site. Recyclable waste should be recycled wherever possible. Waste storage containers shall be covered, tip-proof, weatherproof and scavenger proof. The waste storage area should be fenced off to prevent wind-blown litter Recycling Recycling on site is recommended in terms of the National Waste Strategy. Sufficient receptacles for all types of waste must be available at all times and must be suitably disposed of at registered waste sites or link in with an existing collection route. Staff and visitors must be encouraged to participate in recycling. By actively becoming involved in a recycling habit, the practice will educate and inform. The use of products manufactured with recycled materials should also be encouraged. Bins need to be adequately marked for ease of reference. Appendix 2 provides information on types of recyclable waste and the waste stream process. 7.9 NOISE AND EMISSION CONTROL It is recommended that noise generation be kept to a minimum; the following noise abatement (reduction of intensity and amount) measures should be implemented: - Provide baffle and noise screens to noisy machines as necessary; - Provide absorptive linings to the interior of engine compartments; Cape EAPrac 14 Environmental & Maintenance Management Programme

22 Portion 1 of 169, Tura Kina Ref: GEO307/03 - Ensure machinery is properly maintained (fasten loose panels, replace defective silencers); - Switch off machinery immediately when not in use; and - Reduce impact noise by careful handling. Emission control in vehicles will be reduced by implementing the above mentioned noise control methods. Furthermore the following should be taken into account: - All diesel vehicles should be correctly maintained and serviced to minimise unnecessary exhaust emissions; - Any vehicles with smoking exhausts should be tested for emissions and repaired immediately; - Speed limits must be adhered to; and, - Vehicles and other diesel driven machinery should be switched off when not in use ALIEN VEGETATION MANAGEMENT Alien invasive vegetation is identified as exotic (imported, not indigenous) plant material that is supremely adapted to local conditions. In most cases, these plant species have no natural predators and are able to out-compete indigenous vegetation. The impact of alien vegetation on biodiversity, water resources, aesthetics and fire management is very well documented. All alien invasive vegetation should be removed from the area in order to ensure restoration of the indigenous vegetation. Removal of alien vegetation can be undertaken using various methods. These include mechanical (cutting, chopping, pulling, ring barking), chemical (poisoning) or biological (bugs, beetles). Each species reacts differently and thus often requires specific actions or a combination of actions to effectively remove. The important thing is to first identify the species of plant and then to implement an effective removal plan. Most species require ongoing management, i.e. initial clearing then several follow up clearings of juvenile plants. In the event that herbicides are required for the removal of alien vegetation in a watercourse, it is important to obtain the details of acceptable products to use. Always read the instructions and follow the dilutions correctly. The status of the species identifies the threat and the management actions required to address the threat. The CARA categories are currently the effective categories, however, legislation is pending on NEM:BA and provides are more realistic identification of the threats of several species. The CARA categories currently are: Cape EAPrac 15 Environmental & Maintenance Management Programme

23 Portion 1 of 169, Tura Kina Ref: GEO307/03 Category 1: Category 2: Category 3: Invader plants must be removed & destroyed immediately. Invader plants may be grown under controlled conditions only. Invader plants may no longer be planted. Please see Appendix 3 for information on alien invasive vegetation controls as provided by Working for Water HEALTH AND SAFETY The Project Proponent must ensure compliance with the Occupational Health and Safety (No. 85 of 1993). Of key importance is the following (Section 8 of the aforesaid act); General duties of employers to their employees (1) Every employer shall provide and maintain, as far as is reasonably practicable, a working environment that is safe and without risk to the health of his employees. (2) Without derogating from the generality of an employer's duties under subsection (1), the matters to which those duties refer include in particular- (a) the provision and maintenance of systems of work, plant and machinery that, as far as is reasonably practicable, are safe and without risks to health; (b) taking such steps as may be reasonably practicable to eliminate or mitigate any hazard or potential hazard to the safety or health of employees, before resorting to personal protective equipment; (c) making arrangements for ensuring, as far as is reasonably practicable, the safety and absence of risks to health in connection with the production, processing, use, handling, storage or transport of articles or substances; (d) establishing, as far as is reasonably practicable, what hazards to the health or safety of persons are attached to any work which is performed, any article or substance which is produced, processed, used, handled, stored or transported and any plant or machinery which is used in his business, and he shall, as far as is reasonably practicable, further establish what precautionary measures should be taken with respect to such work, article, substance, plant or machinery in order to protect the health and safety of persons, and he shall provide the necessary means to apply such precautionary measures; (e) providing such information, instructions, training and supervision as may be necessary to ensure, as far as is reasonably practicable, the health and safety at work of his employees; (f) as far as is reasonably practicable, not permitting any employee to do any work or to produce, process, use, handle, store or transport any article or substance or to operate any plant or machinery, unless the precautionary measures contemplated Cape EAPrac 16 Environmental & Maintenance Management Programme

24 Portion 1 of 169, Tura Kina Ref: GEO307/03 in paragraphs (b) and (d), or any other precautionary measures which may be prescribed, have been taken; (g) taking all necessary measures to ensure that tire requirements of this Act are complied with by every person in his employment or on premises under his control where plant or machinery is used; (h) enforcing such measures as may be necessary in the interest of health and safety; (i) ensuring that work is performed and that plant or machinery is used under the general supervision of a person trained to understand the hazards associated with it and who have the authority to ensure that precautionary measures taken by the employer are implemented; and (j) causing all employees to be informed regarding the scope of their authority as contemplated in section 37 (1) (b). The Occupational Health and Safety Act aims to provide for the health and safety of persons at work and for the health and safety of persons in connection with the activities of persons at work and to establish an advisory council for occupational health and safety. 8 DECOMMISSIONING PHASE ENVIRONMENTAL MANAGEMENT REQUIREMENTS The activity of excavating substrate from the dam to ensure long term use along with the maintenance of the dam wall is likely to take place on an ad hoc basis. In addition there are no permanent physical structures in place to further this activity which could be removed during a decommissioning phase. The only management consideration applicable should this activity be stopped would be the following: Rehabilitation of the access routes used by the vehicles to enter the watercourse; Prevention of sedimentation and changes to watercourse banks during removal of the dam wall; Final removal of all silt from the in-stream dam as a safety precaution. 9 NON-COMPLIANCE Any person is liable on conviction of an offence in terms of regulation 49(a) of the National Environmental Laws Second Amendment Act (Act 30 of 2013) to imprisonment for a period not exceeding ten (10) years or to a fine not exceeding R10 million or an amount prescribed in terms of the Adjustment of Fines Act, 1991 (Act No. 101 of 1991). Cape EAPrac 17 Environmental & Maintenance Management Programme

25 Portion 1 of 169, Tura Kina Ref: GEO307/ PROCEDURES The Project Proponent shall comply with the environmental specifications and requirements of this EMMP, any EA issued and Section 28 of NEMA, on an on-going basis and any failure on his part to do so will entitle the authorities to impose a penalty. In the event of non-compliance the following recommended process shall be followed: - The relevant authority shall issue a Notice of Non-compliance to the Project Proponent, stating the nature and magnitude of the contravention. - The Project Proponent shall act to correct the transgression within the period specified in by the authority. - The Project Proponentshall provide the relevant authority with a written statement describing the actions to be taken to discontinue the non-conformance, the actions taken to mitigate its effects and the expected results of the actions. - In the case of the Project Proponent failing to remedy the situation within the predetermined time frame, the relevant authoritymay recommend halting the activity. - In the case of non-compliance giving rise to physical environmental damage or destruction, the relevant authority shall be entitled to undertake or to cause to be undertaken such remedial works as may be required to make good such damage at the cost of the Project Proponent. - In the event of a dispute, difference of opinion, etc. between any parties in regard to or arising out of interpretation of the conditions of the EMMP, disagreement regarding the implementation or method of implementation of conditions of the EMMP, etc. any party shall be entitled to require that the issue be referred to specialists and / or the competent authority for determination. - The relevant authority shall at all times have the right to stop work and/or certain activities on site in the case of non-compliance or failure to implement remediation measures. 10 MONITORING Monitoring of the Operational Phase should be undertaken by the Applicant by means of a photographic record during excavation periods, as they are undertaken. In addition it would be beneficial for the Proponent to implement a water and soil quality monitoring programme in line with the DWA guidelines for use of manure sludge in agricultural practices WATER QUALITY The Department of Water Affairs has provided comprehensive water quality guidelines and targets associated with all types of water. The water quality guideline is a set of information provided for Cape EAPrac 18 Environmental & Maintenance Management Programme

26 Portion 1 of 169, Tura Kina Ref: GEO307/03 a specific water quality constituent. It consists of the water quality criteria, including the Target Water Quality Range, for that constituent together with other support information such as the occurrence of the constituent in the aquatic environment, the norms used to assess its effects on water uses, how these effects may be mitigated, possible treatment options, etc. The South African Water Quality Guidelines consists of guidelines for domestic, recreational, industrial and agricultural water uses, guidelines for the protection of aquatic ecosystems as well as guidelines for the protection of the health and integrity of aquatic ecosystems and guidelines for the protection of the marine environment. Each of these guidelines provides scientific and technical information for a particular water quality constituent in the form of numerical data and/or narrative descriptions of its effects on the fitness of water for a particular use or on the health of aquatic ecosystems. The following guidelines are applicable to agricultural uses as recognised by the National Water Act: domestic purposes; and agricultural purposes. The target quality for each criteria must fall within the thresholds as identified in these guides. All registered laboratories will use the valued determined by DWA and should be utilised by industry role players Irrigation: Irrigation of 2000m³ of domestic or biodegradable industrial wastewater (manure slurry water) on any given day provided (DWA, 2013): (a) Faecal coliforms do not exceed 1000 per 100ml; (b) Chemical Oxygen Demand (COD) does not exceed 75mg/l; (c) ph is not less than 5.5 or more than 9.5 ph units; (d) Ammonia (ionised and un-ionised) as Nitrogen does not exceed 3mg/l; (e) Nitrate/Nitrite as Nitrogen does not exceed 15mg/l; (f) Chlorine as Free Chlorine does not exceed 0,25mg/l; (g) Suspended Solids does not exceed 25mg/l; (h) Electrical Conductivity does not exceed 70 millisiemens above intake to a maximum of 150 millisiemens per metre (ms/m); (i) Ortho-Phosphate as phosphorous does not exceed 10mg/l; (j) Fluoride does not exceed 1mg/l; and Cape EAPrac 19 Environmental & Maintenance Management Programme

27 Portion 1 of 169, Tura Kina Ref: GEO307/03 (k) Soap, oil or grease does not exceed 2.5mg;l. Irrigation of up to 500m³ of domestic or biodegradable industrial wastewater on any given day provided: (a) Electrical Conductivity does not exceed 200 millisiemens per metre (ms/m); (b) ph is not less than 6 or more than 9 ph units; (c) Chemical Oxygen Demand (COD) does not exceed 400mg/l after removal of algae; (d) Faecal coliforms do not exceed per 100ml; and (e) Sodium Adsorption Ratio (SAR) does not exceed 5 for biodegradable industrial wastewater. (f) Irrigation of up to 500m³ of domestic or biodegradable industrial wastewater on any given day provided: Irrigation of up to 50m³ of domestic or biodegradable industrial wastewater on any given day provided: (a) Electrical Conductivity does not exceed 200 millisiemens per metre (ms/m); (b) ph is not less than 6 or more than 9 ph units; (c) Chemical Oxygen Demand (COD) does not exceed 5 000mg/l after removal of algae; (d) Faecal coliforms do not exceed per 100ml; and (e) Sodium Adsorption Ratio (SAR) does not exceed 5 for biodegradable industrial wastewater, if the irrigation of wastewater a. Does not impact on a water resource or any other person s water use, property or land; and b. Is not detrimental to the health and safety of the public in the vicinity of the activity. Manure Sludge Quality The thresholds provided below can be used as a guideline for quality monitoring when manure slurry is used on agricultural lands. The DWA has provided the following guideline on sludge monitoring before and after use on land: Table 1: DWA Sludge Monitoring Guide (DWA, 2006) What should be monitored? Microbiological quality Physical characteristics Cape EAPrac 20 Environmental & Maintenance Management Programme

28 Portion 1 of 169, Tura Kina Ref: GEO307/03 Chemical characteristics How often should Amount of sludge produced (t dry weight ) Monitoring samples be taken? Daily average Yearly average frequency <1 <365 Once per year times per year times per year >45 > Monthly Type of samples How many samples? When to sample? Grab samples to constitute a representative composite At least 3 composite samples for each sludge stream Before use or disposal Where to collect samples? Anaerobically digested Collect from sampling valves on the discharge side of sludge pumps Aerobically digested Collect from sampling valves on discharge side of pumps Dewatered, dried, composted Collect from collection conveyors or bulk containers Compost piles Collect from product Sample sizes At least 500g dry mass The quantity of sludge produced must be reliably measured in order to confirm which sample collection period should be adhered to. Table 2: Soil monitoring where sludge is used (DWA, 2006) What should be Which soils to What to monitor Frequency monitored and how monitor often? All agricultural fields Soil nutrient content (N, P, K) Before each planting season Cape EAPrac 21 Environmental & Maintenance Management Programme

29 Portion 1 of 169, Tura Kina Ref: GEO307/03 receiving sludge Total metal content < TIL Total metals Once every 5 years TMT>Total metal content >TIL and Available metal content<mat Total and available metals Once every 2 years Type of samples How many samples? When to sample? Sample sizes Composite samples of total area where sludge is applied. Collect numerous samples, mix well and submit at least one composite sample for each field. After planting season, before next sludge application. 1kg dry mass. 11 CONCLUSION This EMMP deals mostly with the Operational Phase of the excavation of substrate to ensure the long term sustainability of an irrigation dam Portion 1 of 169, Tura Kina, as well as the maintenance of the existing dam wall. Although a retrospective process has been undertaken for the expansion and upgrade of the existing irrigation dam, the ongoing operation of the facility must also be considered and as such, this document should also be seen as a Maintenance Management Plan. The recommendations and mitigations proposed here are aimed at providing a Best Principle guideline for the Proponent to ensure sustainability and to improve their water and soil use management. Monitoring should play an important role in ensuring that any environmental damage is limited and/or alleviated. Cape EAPrac 22 Environmental & Maintenance Management Programme

30 Portion 1 of 169, Tura Kina Ref: GEO307/03 12 REFERENCES Agricultural Research Council Standards and Guidelines for the Improved Efficiency of Irrigation Water Use from Dam Wall Release to Root Zone Application; Volume 2 of 3: Guidelines. Water Research Commission, WRC REPORT NO.TT 466/10, Gezina, South Africa. Department of Water Affairs Guidelines for The Utilisation and Disposal Of Wastewater Sludge: Volume 2 of 5 (Requirements for the Agricultural Use of Wastewater Sludge). Pretoria, South Africa Eartheasy, Solutions for Sustainable Living. Lochner, P Guideline for Environmental Management Plans.CSIR Report No ENV-S-C H, Republic of South Africa, Provincial Government of the Western Cape, Department of Environmental Affairs and Development Planning, Cape Town. Water Accounts for South Africa, Discussion document: D Statistics South Africa Available online at WWF, Agriculture: Facts & Trends South Africa. WWF, South Africa. Cape EAPrac 23 Environmental & Maintenance Management Programme

31 APPENDIX 1: ENVIRONMENTAL REQUIREMENTS

32 ENVIRONMENTAL DO S ENVIRONMENTAL DON TS Work Site Workers and equipment to stay within site boundaries Do not enter no go areas Use drip trays Do not create dust Materials & Equipment Report spills Store in camp at night Check for leaks Ensure loads don t spill Do not drive too fast Do not wash machinery or tools on site Waste Management Use toilets provided Use bins provided for cigarette butts & waste Don t burn or bury waste No fires on site Report any other fires Eat in designated area Don t eat at dam or river Natural Environment Save water Use only drinking water provided Protect animals and archaeological remains Do not damage trees, flowers or rocks Do not swim or wash in the dam or river Danger & Emergencies Know emergency procedures & no s Report accidents Be careful when working with hazardous substances No smoking near gas or diesel Fines will be issued for non-compliance with environmental specifications

33 APPENDIX 2: RECYCLING INFORMATION

34 GUIDELINES ON RECYCLING OF SOLID WASTE Department of Environmental Affairs and Tourism METAL CANS GLASS PLASTIC WHAT CAN WE RECYCLE? PAPER COMMONLY RECYCLED MATERIALS CARDBOARD BIODEGRADABLE PLANT WASTES SCRAP METAL BATTERIES R 2A TEXTILES TYRES USED OIL OLD APPLIANCES CONSTRUCTION & DEMOLITION WASTE CAR BODIES LESS COMMONLY RECYCLED MATERIALS Department of Environmental Affairs and Tourism

35 WHAT CANNOT BE RECYCLED? CAR WINDSCREENS, MIRRORS GENERAL WASTE MIXED WITH HAZARDOUS WASTE (eg: HEALTH CARE WASTE) VERY DIRTY RECYCLABLES LAMINATES eg: PAPER AND PLASTIC R 2B GUIDELINES ON RECYCLING OF SOLID WASTE Department of Environmental Affairs and Tourism

36 SHRED & DIGEST PAPER RECYCLING USE PAPER PRODUCTS R 8B RECOVER USED PAPER MAKE NEW PRODUCTS PUT THROUGH ROLLERS AND CUT TO SIZE ROLL & SQUEEZE OUT LIQUID SPREAD OUT & DRY WASH DE-INK PULP GUIDELINES ON RECYCLING OF SOLID WASTE Department of Environmental Affairs and Tourism

37 GUIDELINES ON RECYCLING OF SOLID WASTE Department of Environmental Affairs and Tourism USE PLASTIC PRODUCTS RECOVER USED PLASTIC SORT INTO PLASTIC TYPES SHRED EACH TYPE OF PLASTIC PROCESSED SEPARATELY WASH SHREDDED PLASTIC MAKE NEW PRODUCTS PLASTIC RECYCLING DRY CHOP INTO PELLETS MELT Department of Environmental Affairs and Tourism R 8D COOL EXTRUDE

38 USE GLASS PRODUCTS GUIDELINES ON RECYCLING OF SOLID WASTE Department of Environmental Affairs and Tourism MAKE NEW PRODUCTS RECOVER USED GLASS (KEEP COLOURS SEPARATE) GLASS RECYCLING TRANSPORT TO FACTORY MOULD GLASS INTO NEW PRODUCTS BREAK UP GLASS R 9D MOLTEN GLASS MELT IN FURNACE WITH NEW PRODUCT

39 GUIDELINES ON RECYCLING OF SOLID WASTE Department of Environmental Affairs and Tourism USE COMPOST TO ENRICH SOIL FOR GARDENING GRASS CUTTINGS, GARDEN AND KITCHEN WASTE COMPOSTING OF BIODEGRADABLE PLANT WASTES COMPOST HEAP - TURN OVER TO AERATE! BACTERIA & FUNGI EARTHWORMS BREAKDOWN OF ORGANIC MATTER BAGGED COMPOST COMPOST R 10B SIEVE OUT THE FINER FRACTION

40 SHRED METAL RECYCLING POUR INGOTS USE METAL PRODUCTS R 9B RECOVER USED METAL SMELT WASH GUIDELINES ON RECYCLING OF SOLID WASTE Department of Environmental Affairs and Tourism MAKE NEW PRODUCTS

41 USE OIL PRODUCTS (MOTOR OIL, HYDRAULIC GUIDELINES ON RECYCLING OF SOLID WASTE Department of Environmental Affairs and Tourism OIL, MACHINE OIL, GEAR OIL) STORE OIL RECOVER USED OIL DEPOSIT IN ROSE MINI TANKER RECYCLING OF USED OIL HAZARDOUS LANDFILL SITE SLUDGE WASTE R 10A Department of Environmental Affairs and Tourism RECOVER OIL FRACTION FROM WASTE FRACTION TRANSPORT TO OIL RECYCLER ROSE - RECYCLING OIL SAVES THE ENVIRONMENT