Techno Asphalt Manufacture Facility

Transcription

1 DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME For Techno Asphalt Manufacture Facility on Portion 72 of the Farm Hartenbos 217 Prepared for the Applicant: Techno Asphalt (Pty) Ltd By: Cape EAPrac Report Reference: MOS214/06 DEA&DP Reference: EG16/3/1/1/D6/18/0037/13 D.J. Jeffery Directors L. van Zyl

2 EDM Reference: EDE032(A) Case Officer: Nicholas Kearns Date: 20 September 2013 D.J. Jeffery Directors L. van Zyl

3 MOS214/06 DRAFT Environmental Management Programme in terms of The National Environmental Management Amendment Act (Act 62 of 2008) For Techno Asphalt Manufacture Facility Compiled for: DEA&DP Compliance 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 whose 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 Cape EAPrac Environmental Management Programme

4 MOS214/06 Fax: Progress Street Web: George 6530 Cape EAPrac Environmental Management Programme

5 MOS214/06 TABLE OF CONTENTS 1 INTRODUCTION Purpose of the EMP Status of the EMP DESCRIPTION OF ACTIVITY PROJECT PHASING Construction Phase Operation Phase Closure and Decommission Phase ROLES & RESPONSIBILITIES LEGISLATIVE REQUIREMENTS National Environmental Management Act (NEMA, Act 107 of 1998, as amended in 2006 & 2010) National Environmental Management: Air Quality Act (Act 39 of 2004) Environment Conservation Act, 1989 (ECA) National Environmental Management: Biodiversity Act (NEM:BA) (Act 10 of 2004) Conservation of Agricultural Resources Act (Act 43 of 1983) (CARA) The National Forest Act (NFA, Act 84 of 1998) National Water Act (NWA, Act 36 of 1998) National Heritage Resources Act (Act 25 of 1999) National Waste Management Strategy Waste Minimisation Guideline Document for Environmental Impact Assessment Review (May 2003) SANS Application of the National Building Regulations National Building Regulations Other Guidelines considered PRE-CONSTRUCTION REQUIREMENTS...11 Cape EAPrac Environmental Management Programme

6 MOS214/ Design Considerations Energy Conservation Pre-Construction Environmental Compliance Workshop Environmental Induction / Awareness / Education Presentation & Training ENVIRONMENTAL CONTROL OFFICER (ECO) ECO competency ECO Site Visit Frequency BIOPHYSICAL ENVIRONMENTAL MANAGEMENT REQUIREMENTS Pre Earthworks Environmental Awareness and Training Establishment of Contractors Site Camp Fuel Storage Other Hazardous Substances Storage During Earthworks Demarcation of work and no-go areas Top Soil Handling Dust Management Concrete Batching Noise Control Waste Management Solid Waste Construction Rubble and Waste Scrap Metal Hazardous Waste Sanitation Fire Protection Cape EAPrac Environmental Management Programme

7 MOS214/ Erosion Control Temporary Stormwater Management Post - Earthworks Rehabilitation INDUSTRY SPECIFIC OPERATIONAL ENVIRONMENTAL MANAGEMENT REQUIREMENTS Use of reclaimed asphalt Dust and Particulate Cold feed unit Conveyors Gaseous emissions Emissions Verification Continuous Emissions Monitoring Stack Height Air Quality Management Plan Noise and Traffic Waste Water effluent & ground water preservation Raw Materials Handling and Storage Housekeeping Cleaning of delivery trucks SOCIAL & ECONOMIC ENVIRONMENTAL MANAGEMENT REQUIREMENTS Use of local labour Targets Record Keeping Site Security HERITAGE AND ARCHAEOLOGICAL REQUIREMENTS...27 Cape EAPrac Environmental Management Programme

8 MOS214/06 12 HEALTH AND SAFETY DECOMMISSIONING AND CLOSURE ENVIRONMENTAL REQUIREMENTS NON-COMPLIANCE Procedures Offences and Penalties METHOD STATEMENTS Method statements required: IMPLEMENTATION SCHEDULE REFERENCES...32 Cape EAPrac Environmental Management Programme

9 MOS214/06 GLOSSARY OF ACRYNYMS BEE BGIS LUDS Black Economic Empowerment Biodiversity GIS Land Use Decision Support CARA Conservation of Agricultural Resources Act (Act 43 of 1983) CBA CF DAFF DEA&DP DEA DEA&DP DWA EA EAP Critical Biodiversity Area Compact Fluorescent Department of Agriculture, Forestry & Fisheries Department of Environmental Affairs and Development Department of Environmental Affairs Department of Environmental Affairs & Development Planning Department of Water Affairs Environmental Authorisation Environmental Assessment Practitioner ECA Environment Conservation Act (1989) ECO ECR EIA EMP FBAR HPS HWC LED MH NEMA Ecological Control Officer Environmental Control Report Environmental Impact Assessment Environmental Management Programme Final Basic Assessment Report High Pressure Sodium Heritage Western Cape Light Emitting Diode Metal Halide National Environmental Management Act (Act 107 of 1998, as amended 2006 & 2010) NEMBA National Environmental Management: Biodiversity Act (10 of 2004) NEMWA National Environmental Management: Waste Act (59 of 2008) Cape EAPrac Environmental Management Programme

10 MOS214/06 NFA National Forest Act (84 of 1998) NSBA National Spatial Biodiversity Assessment NWA National Water Act (36 of 1998) SAHRA SANS STEP W.W.T.W. South African National Heritage Resources Agency South African National Standards Subtropical Thicket Ecological Planning Waste Water Treatment Works Cape EAPrac Environmental Management Programme

11 1 INTRODUCTION The applicant, Techno Asphalt (Pty) Ltd, intends to construct a hot mix drum asphalt plant on Portion 72 of the Farm Hartenbosch 217. The total footprint of this plant is to be 2500m2 Cape Environmental Assessment Practitioners (Cape EAPrac) has been appointed by the Techno Asphalt (Pty) Ltd, hereafter referred to as the Applicant, as independent environmental practitioner (EAP), to facilitate the Basic Assessment (BA) process required in terms of the National Environmental Management Act (NEMA, Act 107 of 1998) and the National Environmental Management: Air Quality Act for the proposed construction and operation of this facility. This EMP is submitted to ensure compliance with the Regulations contained in the Environmental Impact Assessment (EIA) Regulations of the National Environmental Management Act (NEMA) as well as the National Environmental Management: Air Quality Act for the proposed Techno Asphalt Manufacture Facility. 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 EMP. 1.1 Purpose of the EMP The purpose of this EMP is to ensure that the environmental impacts of the construction phase of the project on the environment are managed, mitigated and kept to a minimum. This includes ensuring that the mitigation measures described in the Basic Assessment Report (FBAR) are implemented. This EMP also includes recommendations made by the Air Quality Specialist and specific authority requirements provided as part of the environmental process for the Techno Asphalt manufacture facility. It is the aim of this EMP to provide clearly defined actions that should be implemented during the lifespan of the Techno Asphalt manufacture facility. The EMP is a dynamic document that is flexible and responsive to new and changing circumstances i.e. it should be updated as and when required. Any substantive changes to the EMP will require authorization from the competent authority. The document is binding on the Project Proponent (Techno Asphalt (Pty)Ltd), 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 EMP must be kept on-site and all senior personnel are expected to familiarize themselves with the content of this EMP. 1.2 Status of the EMP The EMP must form part of all contract documents including all tender and final documents. This programme must be read in conjunction with the contract documents, including the Specifications, and where applicable, the Bill of Quantities. Where a conflict exists between the Specifications and Bill of Quantities and the Environmental Management Programme the matter shall be brought to the attention of the Applicant, Consulting Engineer and the Environmental Control Officer (ECO) for Cape EAPrac 1 Environmental Management Programme

12 resolution. The rates included for each activity in the Bill of Quantities must allow for compliance with the Environmental Management Programme. It is of utmost importance that this EMP be read in conjunction with the Environmental Authorisation (EA), once issued. Should the Environmental Authorisation (EA) contain requirements (conditions) that contradict any points in this EMP, the requirements (conditions) in the Authorisation supersede those in this EMP. This final EMP may need to be updated once an Environmental Authorisation is obtained. As mentioned above, this EMP is viewed as a dynamic document that should be reviewed and updated should the need arise (any substantive changes to this document will require approval from the competent authority) It must be noted that there may be some minor amendments to the requirements of this EMP as a result of specialist recommendations that may take place throughout the remainder of the process. Therefore a contingency amount for additional Environmental Management must be included by perspective tenderers (should the construction take place on a tender basis). The acceptance of the EMP by the Department of Environmental Affairs and Development Planning (DEA&DP) will confer a legal obligation to comply with the specifications of the EMP on the Applicant. Should the Applicant fail to comply with the requirements of this EMP, it is deemed to be a contravention in terms of NEMA and as such is criminally prosecutable. This EMP includes all relevant documentation contained or referred to within it, along with any amendments, appendices or annexures to this document. Any substantial changes, updates or revisions to the EMP must be submitted to and approved by the DEA&DP and Eden District Municipality Air Quality Directorate. 2 DESCRIPTION OF ACTIVITY Techno Asphalt intend constructing and operating a hot mix asphalt facility on a 2500 square meter section of portion 72 of the Farm Hartenbos 217. Hot mix asphalt as proposed to be manufactured at Techno Asphalt. The product consists of a mixture of size-graded, high quality aggregate (which can include reclaimed asphalt pavement [RAP]), and bitumen, heated and mixed in measured quantities to produce Hot Mix Asphalt (EPA 2013). Aggregate and RAP (if used) constitute over 92 percent by weight of the total mixture. Aside from the amount and grade of bitumen used, mix characteristics are determined by the relative amounts and types of aggregate and RAP used. A certain percentage of fine aggregate (less than 74 micrometers in physical diameter) is required for the production of good quality Hot Mix Asphalt. Techno Asphalt intend installing a typical drum mix package plant. The nature of these package plants allows for installation and decommissioning in a relatively short period of time, with a relatively low impact. The total footprint of the plant will not exceed 2500m2 (50m x 50m). Cape EAPrac 2 Environmental Management Programme

13 Aggregate will be obtained from an existing source, the Transand quarry. The existing Transand quarry is located approximately 1.8 km north-east of the proposed Techno Asphalt's site and is accessible by means of existing road networks. Crushing of aggregate takes place within the existing quarry (crushing will thus not take place at the asphalt plant). Aggregate will be transported in trucks from the quarry to the site and stockpiled in feed bins. Aggregate will be transferred from feed bins to the drum mixer via a belt weighing system to ensure a correct and continuous feed into the mixer. Bitumen will be fed from a tank to the drum mixer via a heated line. Mixing will occur within the drum with heat energy being supplied by a diesel burner. Hot mixed asphalt will be transferred to a storage silo from where the hot mix can be transferred directly into trucks for delivery to various road construction and maintenance sites. 3 PROJECT PHASING The construction, operation and decommissioning phases of the project are described below. 3.1 Construction Phase This phase of the development refers to the actual construction of the facility, namely, the placing and assembly of the facility. Due to the nature of the facility, the construction phase of this project is limited. This construction phase EMP also includes various environmental design considerations as suggested by the specialists and stakeholders as well as considerations in terms of best practice. 3.2 Operation Phase The operational phase commences with the commissioning of the facility and continues for the duration of the lifespan of the facility. The operational phase requirements relate specifically to the manufacture aspects of this facility. 3.3 Closure and Decommission Phase Decommissioning refers to the process of removing the operating assets of the project after completion of the operating life cycle. This lifespan of this facility is deemed to be long term. Cape EAPrac 3 Environmental Management Programme

14 4 ROLES & RESPONSIBILITIES Details of the organizational structure are presented in Figure 1. The structure illustrates the reporting procedures for stakeholders in the implementation of this EMP. Authority DEA&DP & EDEN District Municipality Employer Techno Asphalt (Pty) Ltd. Employer s Representative Environmental Control Officer To be appointed To be appointed Contractor / Operator Techno Asphalt (Pty) Ltd Figure 1: EMP implementation organizational structure. Throughout the lifespan of this project, a number of individuals and entities will fulfill various roles and responsibilities to ensure the effective implementation of this EMP. The key roles and responsibilities are detailed in the table below. Table 1: Roles and responsibilities with regard to the implementation of this EMP Role Responsibility Environmental Authority National Department of Environmental Affairs & Development Planning The National Department of Environmental Affairs & Development Planning (DEA&DP) as well as Eden District Municipality is the competent Ensure overall compliance with the Environmental Authorisation (EA), Atmospheric Emissions Licence (AEL) & EMP. Review this document and any revisions thereof. Undertake site audits at their discretion. Cape EAPrac 4 Environmental Management Programme

15 Role authority responsible for compliance with the relevant environmental legislation. Responsibility Review ECO Reports. Review Audit Reports Review Incident Report. Enforce legal mechanisms for contraventions to this EMP, EA & AEL Holder of the Authorisation Techno Asphalt (Pty) Ltd The holder of the Authorisation is generally responsible for ensuring compliance with all statutory requirements relating to the Techno Asphalt manufacture facility. Ensuring compliance with the conditions set out in the Environmental Authorisation issued in terms of the NEMA. Ensuring compliance with the conditions set out in the Atmospheric Emissions License issued in terms of the NEMAQA. Compliance with the requirement set out in this EMP. Ensuring all other permits, permissions and licences from all other statutory departments are in place. Environmental Control Officer (ECO) To be appointed The ECO fulfills an advisory role to monitor and report compliance with the EMP. Revise, update and amend the EMP if necessary and submit the amendments to the competent authority for consideration. Ensure all relevant persons have a copy of the EMP and any amendments thereof. Advise the Employers Representative on any additional environmental authorisations & permits that may be required. Facilitate the Environmental Education / Induction Training with the contract staff. Review and comment on Method Statements relevant to environmental management and make recommendations to the Employer s representative. Report any non-compliance with the EMP or EA to the employer s representative and competent authority if necessary. Undertake regular site inspections in compliance with this EMP. Monitor, audit and verify that all works comply with the EA and the EMP. Keep record of EMP implementation, monitoring and audits, including a full photographic record of works. Comply and submit regular Environmental Control Reports. Report any environmental incidents or environmental impacts immediately to the employer s representative and the competent authority if necessary. Assist the contractor and employer s representative implementing environmentally sensitive problem solving. Maintain a photographic record of works on site Advise the Employer s representative on suggested stop work orders. The employer s representative role is likely to be fulfilled by a senior representative of Techno Asphalt and assumes overall responsibility for compliance with this EMP, the EA and all Employers Representative To Be Appointed Issue site instructions to the contractor based on the advice of the ECO. Ensure that all detailed design incorporates the requirements of the EMP EA, and AEL. Ensure that the EMP is included in all tender documents Cape EAPrac 5 Environmental Management Programme

16 Role applicable legislation (AEL) for the duration of the construction phase. Responsibility issued to prospective contractors and sub-contractors. Ensure the EMP is included in final contract documents. Ensure that the Tenderers/Contractors adequately provide for compliance with the EMP in their submissions. Ensure that the EMP is fully implemented by the relevant persons. Ensure the contractor provides the necessary method statements. Be accountable, to the competent authority for any contravention or non-compliance by the Contractor. Assist the contractor with input from the ECO in finding environmentally responsible solutions to problems. Undertake regular site audits, site visits and inspections to ensure that the requirements of the EMP are implemented Give instructions on any procedures and corrective actions on advice from the ECO. Report environmental incidents or non-compliance with the EA or EMP to the environmental authority. Issue spot fines, penalties or stop-work orders for contravention of the EMP and give instructions regarding corrective action. Contractor To be appointed The contractor (main contractor) is responsible for the implementation of all construction activities associated with the Asphalt facility. Overall project delivery for the construction of the asphalt facility to the satisfaction of the authorities and consultants Ensuring compliance with the Health & Safety requirements for the project. Ensuring compliance with this Environmental Management Programme. Promoting job safety and environmental awareness by employees. Ensure that all sub-contractors comply with this EMP and all other statutory requirements. The landowner is responsible for compliance with legislation applicable to the management of the property as a whole. Landowner E.g.: In terms of the National Veld & Forest Fires Act (101 of 1998) - an owner on whose land is subject to a risk of veldfire, must prepare and maintain a firebreak on his or her land as close as possible to the border etc. 5 LEGISLATIVE REQUIREMENTS The Applicant is required to comply with all necessary legislation and policies applicable to the above mentioned development. These include, but are not limited to: 5.1 National Environmental Management Act (NEMA, Act 107 of 1998, as amended in 2006 & 2010) Cape EAPrac 6 Environmental Management Programme

17 This Act 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 to have the environment protected for the benefit of present and future generations through reasonable legislative and other measures. It aims to provide for co-operative environmental governance by establishing principles for decisionmaking on all matters relating to the environment and by means of Environmental Implementation Programmes (EIP) and/or Environmental Management Programmes (EMP). 5.2 National Environmental Management: Air Quality Act (Act 39 of 2004). The key aim of this act is: to regulate air quality in order to protect the environment by providing reasonable measures for the prevention of pollution and ecological degradation to secure ecologically sustainable development while promoting justifiable economic and social development; to provide for national norms and standards regulating air quality monitoring, management and control by all spheres of government; for specific air quality measures; and for matters incidental thereto. The manufacture of asphalt is an activity listed in terms of this Act and as such, may not proceed without an Atmospheric Emissions Licence, in terms of the Act. The Eden District Municipality is the licencing authority in this regard. 5.3 Environment Conservation Act, 1989 (ECA) The EIA Regulations contained in the Environmental Conservation Act (ECA) have been replaced by the NEMA Regulations. The contractor must 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), 5.4 National Environmental Management: Biodiversity Act (NEM:BA) (Act 10 of 2004) This Act controls the management and conservation of South African biodiversity within the framework of NEMA. Amongst others, it deals with the protection of species and ecosystems that warrant national protection, as well as the sustainable use of indigenous biological resources. Sections 52 & 53 of this Act specifically make provision for the protection of critically endangered, endangered, vulnerable and protected ecosystems that have undergone, or have a risk of undergoing significant degradation of ecological structure, function or composition as a result of human intervention through threatening processes. Cape EAPrac 7 Environmental Management Programme

18 The Draft National List of Threatened Ecosystems (Notice 1477 of 2009, Government Gazette No , 6 November 2009) has been gazetted for public comment. The list of threatened terrestrial ecosystems supersedes the information regarding terrestrial ecosystem status in the NSBA In terms of the EIA regulations, an environmental management plan / report / method statement is required for the transformation or removal of indigenous vegetation in a critically endangered or endangered ecosystem regardless of the extent of transformation that will occur. The Act provides for listing of species as threatened or protected, under one of the following categories: Critically Endangered: any indigenous species facing an extremely high risk of extinction in the wild in the immediate future. Endangered: any indigenous species facing a high risk of extinction in the wild in the near future, although it is not a critically endangered species. Vulnerable: any indigenous species facing an extremely high risk of extinction in the wild in the medium-term future; although it is not a critically endangered species or an endangered species. Protected species: any species which is of such high conservation value or national importance that it requires national protection. Species listed in this category include, among others, species listed in terms of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). Since there is no remaining natural vegetation on site, this legislation is unlikely to be significantly relevant. 5.5 Conservation of Agricultural Resources Act (Act 43 of 1983) (CARA) 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. In the case of Techno Asphalt manufacture facility, the provisions regarding erosion control, must be considered (as there is no remnants of vegetation remaining on the site including invasive vegetation). 5.6 The National Forest Act (NFA, Act 84 of 1998) In terms of Regulation 15 of the aforesaid Act, no person may: (a) (b) cut, disturb, damage, destroy or remove any protected tree; or collect, remove, transport, export, purchase, sell, donate or in any other manner acquire or dispose of any protected tree. Cape EAPrac 8 Environmental Management Programme

19 Except under a license granted by the Minister (for which an application must be made to the Department Agriculture, Forestry & Fisheries (DAFF)). There is no protected trees or protected vegetation remaining on site and as such this legislation will not be applicable. 5.7 National Water Act (NWA, Act 36 of 1998) 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. Section 21c & i of the National Water Act (NWA) requires the Applicant to apply for authorisation from the Department of Water Affairs for an activity in, or in proximity to any watercourse. The proposal will not affect the banks and beds of a watercourse and as such, it is unlikely that the proposal will require authorization in terms of the National Water Act. 5.8 National Heritage Resources Act (Act 25 of 1999) The protection and management of South Africa s heritage resources are controlled by the National Heritage Resources Act (Act No. 25 of 1999). South African National Heritage Resources Agency (SAHRA) is the enforcing authority in the Northern Cape, and is registered as a Stakeholder for this environmental process. In terms of Section 38 of the National Heritage Resources Act, SAHRA will comment on the detailed Heritage Impact Assessment (HIA) where certain categories of development are proposed. Section 38(8) also makes provision for the assessment of heritage impacts as part of an EIA process. The National Heritage Resources Act requires relevant authorities to be notified regarding this proposed development, as the following activities are relevant: the construction of a road, wall, power line, facility, canal or other similar form of linear development or barrier exceeding 300m in length; any development or other activity which will change the character of a site exceeding m² in extent; the re-zoning of a site exceeding m ² in extent. This proposal will not exceed the thresholds defined by these activities. Furthermore, in terms of Section 34(1), no person may alter or demolish any structure or part of a structure, which is older than 60 years without a permit issued by the SAHRA, or the responsible Cape EAPrac 9 Environmental Management Programme

20 resources authority. No buildings older than 60 years and heritage significance will be affected by the proposed facility. Nor may anyone destroy, damage, alter, exhume or remove from its original position, or otherwise disturb, any grave or burial ground older than 60 years, which is situated outside a formal cemetery administered by a local authority, without a permit issued by the SAHRA, or a provincial heritage authority, in terms of Section 36 (3). No grave sites were found in proximity to the proposed facility. In terms of Section 35 (4), no person may destroy, damage, excavate, alter or remove from its original position, or collect, any archaeological material or object, without a permit issued by the SAHRA, or the responsible resources authority. No heritage related resources will be impacted by the proposed activity. 5.9 National Waste Management Strategy The National Waste Management Strategy presents the South African Government's strategy for integrated waste management for South Africa. It includes: Integrated Waste Management Planning, Waste Information Systems, Waste Minimisation, Recycling, Waste Collection and Transportation, Waste Treatment, Waste Disposal and Implementing Instruments. Waste management is dealt with in detail in Section below Waste Minimisation Guideline Document for Environmental Impact Assessment Review (May 2003) This guideline, compiled on a provincial level, is pertinent to this EMP. This Guideline raises awareness on waste minimisation issues and highlights waste and wastage minimization practices. Part B of this document is of particular importance, as it addresses issues of general waste and waste minimization during construction activities. The waste generated by this facility will be minimal SANS Application of the National Building Regulations The application of the National Building Regulations contains performance parameters relating to fire safety, sanitation systems, moisture penetration, structural safety, serviceability and durability. It also takes into account how the above can be established to reflect social expectations in a manner which supports sustainable development objectives National Building Regulations The National Building Regulations and Building Standards Act, as amended, must be complied with. This Act addresses, inter alia: - Specifications for draftsmen, plans, documents and diagrams; Cape EAPrac 10 Environmental Management Programme

21 - Approval by local authorities; - Appeal procedures; - Prohibition or conditions with regard to erection of buildings in certain conditions; - Demolition of buildings; - Access to building control officers; - Regulations and directives; and - Liability. These are particularly relevant with regards to the assembly of the facility and construction of the laboratory etc Other Guidelines considered In addition to those described above, the following guidelines were also considered during the compilation of this EMP. DEADP (2003). Waste Minimisation Guideline for Environmental Impact Assessment reviews. NEMA EIA Regulations Guideline & Information Series, Department Environmental Affairs & Development Planning. DEADP (2005). Guideline for environmental management plans. NEMA EIA Regulations Guideline & Information Document Series, Department of Environmental Affairs & Development Planning. DEAT (2004). Environmental Management Plans, Integrated Environmental management, Information Series 12, Department Environmental Affairs & Tourism DEADP (2010). Guideline for Environmental Management Plans. NEMA EIA Regulations Guideline & Information Document Series, Department of Environmental Affairs & Development Planning. 6 PRE-CONSTRUCTION REQUIREMENTS The requirements detailed below are those that require consideration and implementation prior to any form of establishment activities or construction on site. 6.1 Design Considerations The following design phase considerations need to be included in all relevant engineering drawings and specifications provided to the contractors. Cape EAPrac 11 Environmental Management Programme

22 6.1.1 Energy Conservation The applicant need to consider energy consumption as a factor influencing the final design of the internal layout of the facility specifically relevant to the optimization of the diesel heaters. It is also required that Light Emitting Diode (LED) or Compact Fluorescent (CF) lighting be used as opposed to incandescent lighting. This is required for all internal and external lighting at the facility (including the internal lighting in the laboratory). NO external High Pressure Sodium (HPS) or Metal Halide (MH) spot or floodlights are to be installed at the facility. It is recommended that the applicant consider retrofitting the existing office block with low energy lighting. 6.2 Pre-Construction Environmental Compliance Workshop It is required that a pre-construction environmental compliance workshop be undertaken before any construction commences on site. This workshop can be combined with a site handover meeting, but must take place before any activities take place on site and before any plant is moved onto site. The following people must be present at this Environmental Compliance Workshop: - The Environmental Control Officer (ECO); - The Mossel Bay Municipality technical / civil services representative; - The Main Civil Contractor (including contract manager, site agent and foreman); - Project Management. Provision should be made to attend a short workshop that will be chaired by the ECO. The provisions of this EMP will be discussed in detail at this workshop. This workshop can take place as part of the site handover meeting. 6.3 Environmental Induction / Awareness / Education Presentation & Training The ECO, in consultation with the contractor, 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, implications and requirements of the EMP prior to earthwork activities (see section below). 7 ENVIRONMENTAL CONTROL OFFICER (ECO) It is required that an Environmental Control Officer be appointed to oversee operations throughout the construction phase An ECO is still to be appointed for the Techno Asphalt manufacture facility. Cape EAPrac 12 Environmental Management Programme

23 The responsibilities of the ECO include, but are not limited to the following: - Assist with the demarcation of work areas and NO-GO areas; - Provide environmental induction presentation to contractors on-site prior to commencing of construction activities as well as on-going environmental awareness / education throughout the construction period; - Provide maintenance, update and review of this EMP; - Liaison between the Project Proponent, Contractors, Authorities and other stakeholders on all environmental concerns, including the implementation of this EMP; - Compilation of Environmental Control Reports (ECR) to ensure compliance with the EMP and authorisations. Reports should be submitted to the relevant authority on a 2 monthly basis during the construction period.; - Compilation of the Environmental Audit Report or Environmental Completion Statement, six months after completion of construction (or as otherwise defined in the Environmental Authorisation). Reports should be submitted to the relevant authority (DEA&DP & EDM) and the Project Proponent; - Monitoring compliance with this EMP; - Monitoring compliance with the Environmental Authorisation (EA); - Monitoring compliance with the Atmospheric Emissions License (AEL); - Ensure implementation of the mitigation and rehabilitation measures and recommendations referred to in the EA, the Final Basic Assessment Report (FBAR) and EMP; - Provide guidance and interpretation of the EA and EMP where necessary; - Recommend the issuing site instructions to the Contractor for corrective actions required (formal site instructions are to be issued by the Employers Representative with input from the ECO); - The ECO is required to conduct site visits during the construction period, in order to ensure the contractor receives the necessary induction and that all procedures are in place (see Section 7.2 for recommended site visit frequency); - The ECO must form part of the project management team and attend all relevant management meetings, including monthly site meetings; - Maintain a record of environmental incidents (e.g. spills, impacts, legal transgressions etc.) as well as corrective and preventative measures taken. This information must also be included in the ECR; - Maintain a public complaints register in which all complaints and action taken / responses must be recorded. This information must also be included in the ECR; and - Engineers Representative (with input from the ECO) has the authority to stop work on site if he / she consider that any actions of excessive non-compliance of the EMP, authorisations or General Duty of Care are taking place. 7.1 ECO competency The ECO must have a minimum of a tertiary level qualification in the natural sciences field, as well as at least 3 years experience and proven competency as an ECO. Cape EAPrac 13 Environmental Management Programme

24 7.2 ECO Site Visit Frequency It is recommended that the ECO undertake two weekly site inspections for the duration of the construction period. This frequency may be increased or decreased as deemed necessary by the ECO. 8 BIOPHYSICAL ENVIRONMENTAL MANAGEMENT REQUIREMENTS For ease of reference, the bio-physical environmental management requirements have been divided into pre-, during- and post earthworks (although earthworks on this project will be minimal). The items discussed under pre-earthworks are not to be disbanded during earthworks - they are merely dealt with under this section as it is a requirement that they be established or part implemented prior to commencement of any construction activities. 8.1 Pre Earthworks Environmental Awareness and Training The ECO, in consultation with the contractor, shall ensure that all construction workers receive an induction presentation, as well as on-going environmental education & awareness, on the importance and implications of the EMP and the environmental requirements it prescribes. 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: - Explanation of the importance of complying with the EMP; - Discussion of the potential environmental impacts of construction 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 EMP and its specification (no-go areas, etc.); and - Explanation of the management structure of individuals responsible for matters pertaining to the EMP. Furthermore, the induction training must ensure that construction workers/staff understand that no form of wildlife poaching, collecting or other form of disturbance will be permitted on the construction site or the adjacent areas. Should the staff turnover be high and with additional appointment of sub-contractors, it may be necessary to conduct additional induction training sessions. This is at the discretion of the ECO. Cape EAPrac 14 Environmental Management Programme

25 The contractor must keep records of all environmental training sessions, including names, dates and the information presented. Details of the environmental induction are also to be included in the Environmental Control Reports Establishment of Contractors Site Camp The Contractors Site Camp(s) must be established in consultation with the ECO. The site camp may not be erected on any areas considered sensitive and no indigenous vegetation may be removed, damaged or disturbed without consent from the ECO. Due to the nature of the construction, the site camp can be established within the 2500 square meter footprint: The following points are applicable: - The Contractors Site Camp(s) must be situated within the development footprint. No site camps will be allowed outside of the demarcated construction footprint. - The site camp(s) should be fenced off with green shade netting (60%) to a height of at least 2m. For the purpose of this project, it may be easier to fence off the entire construction footprint - All construction material must be stored in the site camp(s), unless otherwise approved by the ECO. - No personnel may overnight in the site camp, except in the case of a night watchman / security. - Fires for cooking and/or heating are only allowed within the site camp. - Fuel may only be stored in the camp site. - Storage of waste must take place within the site camp and must be removed on a regular basis. - The site camp must be provided with sufficient ablution facilities (toilets and potable water), which must be maintained in clean working order and emptied on a regular basis. 8.2 Fuel Storage Fuel may only be stored within the site camp in the manner defined below. No storage of fuel may take place in any other place on site. The above ground storage of fuel is subject to authorization in terms of the National Environmental Management Act (NEMA as amended 2006) if more than 30m³ is stored on-site at any one time. The current environmental application does not include an assessment for this volume of fuel and the contractor must ensure that fuel stored is below this volume. Should a temporary fuel storage facility be required, the Contractor must ensure that he/she complies with legislation and that the following measures are in place: - Temporary fuel storage must take place within the contractors site camp in an area approved by the ECO; - No storage of fuel may take place on any other portion of the site; - Mobile fuel units used to refuel plant on site must make use of drip trays when refueling; - Where possible, double lined storage tanks should be used; - All storage tanks must be ISO 9001 certified; - Storage facilities should not be located within 60m of a watercourse, within a watercourse flood plain, near a wetland area or where there is a potential for any spilled fuel to enter a watercourse or groundwater; Cape EAPrac 15 Environmental Management Programme

26 - Fuel storage facilities should be located on flat ground. No cut and fill should take place immediately on or adjacent to fuel storage areas; - Bund walls must be constructed to contain at least 110% of the total capacity of the storage tanks; - Bund walls must be constructed of impermeable material or lined to ensure that petroleum products cannot escape; - A suitable material should be placed in the base of the bund walls to soak up any accidental spillages; - The tanks should be locked and secured when not in use; - Automatic shut-off nozzles are required on all dispensing units; - Storage tanks should be drained within one week of completion of activities (unused fuel can be used by the contractor on other work sites or returned to the supplier). If the construction program extends over the Christmas shutdown, the contractor must ensure that storage tanks are emptied prior to this period; - All storage tanks, containers and related equipment should be regularly maintained to ensure the safe storage and dispensing of fuel. The Engineer is to sign off on the condition suitability of the storage tanks; - Defective hoses, valves and containment structures should be promptly repaired; - Vehicle and equipment fuelling should be undertaken on a hard impermeable surface or over drip pans to ensure spilled fuel is captured and cleaned up; and - The area must be totally rehabilitated on completion of the contract and all contaminated material must be taken to a registered dumping site for that purpose Other Hazardous Substances Storage With the exception of the above ground storage of diesel as described above, no storage of any other hazardous substances may take place on site during the construction phase. Should the contractor require the storage of any hazardous substance, it must be confirmed that there is no legislative procedure preventing them from doing so and the ECO must first approve such storage in writing. 8.3 During Earthworks Demarcation of work and no-go areas The demarcation of work and no-go areas is of utmost importance to ensure that potentially sensitive areas are not unnecessarily disturbed. The entire 2500 square meter footprint is to be demarcated and all areas outside of this footprint are considered to be no-go areas for construction. Demarcation must be clearly visible and access to No Go sites will be considered non-compliance of this EMP. Danger tape zigzagged on a two strand wire fence will provide a tangible barrier, however other materials such as shade netting may be used. Cape EAPrac 16 Environmental Management Programme

27 8.3.2 Top Soil Handling - There is no topsoil left on site and as such, topsoil separation and handling is not necessary Dust Management Every effort to minimize dust pollution on the site must be undertaken. Construction vehicles must be restricted to the existing road / street network and adhere to speed limits. The existing dust control programme that forms part of Transand s EMPR must be implemented with regards to haul roads and construction access roads. The management of dust during the operational phase is dealt with later on in this report Concrete Batching Cement powder has a high alkaline ph that may contaminate and adversely affect both soil ph and water ph negatively. A rapid change in ph can have consequences on the functioning of soil and water organisms as well as on the botanical component. Redimix concrete should be used as far as practical where access allows, and on-site batching should be kept to a minimum. Where on-site batching is required, the following must be implemented. Batching at satellite sites must be done on a batching plate i.e. wood or metal sheet, to prevent soil contamination. Bulk concrete batching may only take place in areas approved by the ECO. Concrete mixing areas must have bund walls or a settling pond in order to prevent cement run off. Once the settling ponds dry out, the concrete must be removed and dispatched to a suitable disposal site. Ideally, all concrete batching should take place on an area that is to be hard surfaced, such as a road or parking area, or as part of the development (e.g. footprint of Bunded storage areas). In order to avoid resource contamination, concrete batching should not be located within 60m of a watercourse, within a watercourse flood plain, near a wetland area or drainage line or where there is a potential for any spilled concrete to enter a watercourse or groundwater. No areas outside the 2500 square metre footprint may be considered for concrete batching Noise Control Noise generation must be kept to a minimum and construction activities must be confined to normal working hours (07h00-18h00 on workdays) Working hours are therefore restricted to: 07:00 18:00, Monday Friday; No work on Saturday or Sunday; No work on Public holidays. Cape EAPrac 17 Environmental Management Programme

28 Should the contractor require additional working hours, these hours must first be approved in consultation with the ECO. Apart from confining noise to the normal work hours as detailed above, 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; - Ensure machinery is properly maintained (fasten loose panels, replace defective silencers); - Operate the equipment at the minimal power required to undertake the required task; - Switch off machinery immediately when not in use; and - Reduce impact noise by careful handling. The Contractor shall be responsible for compliance with the relevant legislation with respect to noise inter alia Section 25 of ECA Waste Management Waste generation during construction will be minimal, the contractor must however ensure compliance with the National Environmental Management: Waste Act (NEM:WA, Act 59 of 2008). The management of waste on site must follow an integrated approach. Only approved waste disposal methods shall be allowed. The Contractor shall ensure that all site personnel are instructed in the proper disposal of all waste. The Contractor shall ensure that sufficient disposal facilities are available. Recycling must be encouraged on site and recycling bins must be provided and clearly marked. Disposal of all waste materials must be done at suitable facilities. No dumping of any waste material on or off site is permitted. The disposal of all general waste must take place at a landfill licensed in terms of Section 20 of the Environmental Conservation Act, 1989 (Act No. 73 of 1989) in terms of the National Environmental Management Waste Act (Act 59 of 2008) if required Solid Waste The Contractor shall ensure that all facilities are maintained in a neat and tidy condition and the site shall be kept free of litter. Measures shall 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 Contractor shall provide litterbins, containers and/or refuse collection facilities for later disposal. Solid waste may be temporarily stored on-site (within the site camp) in a designated area approved by the ECO prior to collection and disposal. Solid waste must be removed on a weekly basis to a licensed waste disposal site. Recyclable waste should be recycled if at all possible. Waste storage containers shall be covered, tip-proof, weatherproof and scavenger proof. The waste storage area shall be fenced off to prevent wind-blown litter. Cape EAPrac 18 Environmental Management Programme

29 No burning, on-site burying or dumping of waste shall occur. Used (empty) cement bags shall be collected and stored in weatherproof containers to prevent windblown cement dust and water contamination. Used cement bags may not be used for any other purpose and shall be disposed of on a weekly basis via the solid waste management system. All solid waste shall be disposed of offsite at an approved landfill site. The Contractor shall supply the Project Proponent and ECO with certificates of disposal Construction Rubble and Waste All construction waste must be disposed of at an approved rubble disposal site (no construction rubble may be spoiled anywhere on site). No illegal dumping of construction material may take place Scrap Metal Recycling of scrap metal is recommended. Scrap metal must be disposed of offsite at suitable facilities Hazardous Waste All hazardous waste (including bitumen, fuel, oils, paints etc.) shall be disposed of at an approved hazardous landfill site. The Contractor shall provide disposal certificates to the ECO. Used oil and grease must be removed from site to an approved used-oil recycling company. Under NO circumstances may any hazardous waste be spoiled on the site. The maintenance of construction vehicles should take place off site Sanitation Portable chemical ablution facilities must be available for the use by construction staff for the duration of the construction period. The following must therefore be implemented: - Toilet and washing facilities must be available to the site personnel at all times. - One toilet for every 15 personnel is required. - The facilities must be serviced on a regular basis to prevent any spillage. The ECO must be provided with the service providers details and the service schedule for the site. These must all be put in place prior to the commencement of earthworks and be present throughout the construction phase. - The toilets should be secured to ensure that they do not blow over in windy conditions. - All toilet facilities must be removed from site on completion of the contract period; and - Should the construction period be interrupted by a builders break, the toilets should be emptied prior to the break Fire Protection No fires are permitted anywhere on the development site. The following is required: Cape EAPrac 19 Environmental Management Programme

30 - Cigarette butts may not be thrown in the veld, but must be disposed of correctly into designated containers. - In case of an emergency, the contact details of the local fire and emergency services must be readily available as per requirements of an approved health and safety plan. - Contractors must ensure that basic firefighting equipment is available on site Erosion Control This section must be read in conjunction with the section on storm-water management detailed below, as the two go hand in hand. Due to the flat nature of the site, the erosion potential is considered to be low. Any areas that are identified by the ECO as being possible erosion areas must be suitably protected. During construction, the Contractor shall protect all areas susceptible to erosion by installing necessary temporary and permanent drainage works as soon as 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 within a reasonable time during the construction phase of the development. It is recommended that a silt screen be installed along the entire Southern border of the development footprint to ensure that potential silt run off does not enter the off site vegetated buffer and stormwater channel. The proposed location of this silt screen is indicated in figure 1 below. Cape EAPrac 20 Environmental Management Programme

31 Figure 1: Proposed location of temporary silt screen during the construction period Temporary Stormwater Management Temporary stormwater management is required throughout the construction phase until the suitable vegetation cover is established on all disturbed areas. Contaminated runoff generated on the construction site should not be discharged directly into the off site drainage line. The permanent stormwater control measures must be constructed as per the engineers specifications with input from the ECO. 8.4 Post - Earthworks Rehabilitation The contractor is responsible for ensuring the site is adequately rehabilitated on completion of the works in any particular area. The rehabilitation opportunities for this site will however be limited, as the construction will be limited to the future operating area (development footprint) Cape EAPrac 21 Environmental Management Programme