ROELIEN DU PLESSIS WILLEM DE BRUYN LIFE4ALL ENVIRONMENTAL CONSULTANCY CC

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1 ROELIEN DU PLESSIS WILLEM DE BRUYN LIFE4ALL ENVIRONMENTAL CONSULTANCY CC

2 SUSTAINABLE PLASTICS RECYCLING? Waste Licenses and Waste Classification 27 JULY 2016

3 HISTORY:ECA Environment Conservation Act, 1989 (Act 73 of 1989)(ECA) ECA Section 20 permit: DWA (landfills, ground water) No person may dispose of waste unless under the authority of a permit issued in terms of section 20 of the ECA.

4 HISTORY:ECA Definition:..disposal site means a site used for the accumulation of waste with the purpose of disposing or treatment of such waste. The facilities are seen as disposal sites because of the continuous storage of waste on the premises of these plants or sites before disposal, removal or handling thereof.

5 HISTORY:ECA Definition applied to: -waste recycling plants -transfer stations -storage areas -treatment plants Incinerators Vacuum pyrolysis plants Compost plants

6 HISTORY:ECA Guiding document: Minimum Requirements for Waste Disposal by Landfill Scoping Report

7 HISTORY:NEMA National Environmental Management Act, 1998, (Act No. 107 of 1998) (NEMA) The requirements include compliance to the Environmental Impact Assessment (EIA) Regulations of April 1998 Activity 8: The disposal of waste as required in terms of Section 20 of the Environmental Conservation Act, 1989.

8 HISTORY:NEMA EIA Regulations 2006 GN 386 Activity 1(o) The construction of facilities or infrastructure, including associated structures or infrastructure, for the recycling, re-use, handling, temporary storage or treatment of general waste with a throughput capacity of 20 cubic metres or more daily average measured over a period of 30 days, but less than 50 tons daily average measured over a period of 30 days; Waste activities was removed from 2010 and 2014 Regulations

9 HISTORY:SEMA SEMA s (1) National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) GN R. 718 of 3 July 2009 GN R. 921 of 29 November 2013 Require a Waste Management License

10 WML DEA: Once a waste product is re-used, recycled or recovered, it cease to be waste any more. It is therefore only after the action of re-used, recycled or recovered that it is not waste any more. Before this action it is still regarded as waste.

11 HISTORICAL Section 29 rulings for recyclers that have been around from prior to NEMWA -Voluntary -DEA (discussions) -DEA (accept and process historical applications) -GDARD (expansion)

12 WML Waste Management License: BAR General waste: Hazardous waste: < 500 kg/per day Scoping and EIA All other hazardous waste General waste > 10 ton per day for recovery and treatment Emergency response plan Health and Safety Plan Operational plan

13 WML Listed activities (applicable): GN R. 921 of 29 November 2013

14 WML GN R. 921 of 29 November 2013 Category A 3 (2) The sorting, shredding, grinding or bailing of general waste at a facility that has an operational area in excess of 1000m 2 ; 3 (3) The recycling of general waste at a facility that has an operational area in excess of 500m 2, excluding recycling that takes place as an integral part of an internal manufacturing process within the same premises;

15 WML 3 (4) the recycling of hazardous waste in excess of 500 kg but less than 1 ton per day calculated as a monthly average, excluding recycling that takes place as an integral part of an internal manufacturing process within the same premises. 3 (5) The recovery of waste including the refining, utilization, or co-processing of waste in excess of 10 tons but less than 100 tons of general waste per day or in excess of 500kg but less than 1 ton of hazardous waste per day, excluding recovery that takes place as an internal manufacturing process within the same premises;

16 WML 3 (6) The treatment of general waste using any form of treatment at a facility that has the capacity to process in excess of 10 tons but less than 100 tons; 3 (13) the expansion of a waste management activity listed in category A or B of this schedule which does not trigger an additional waste management activity in terms of this schedule.

17 WML Category C 5 (1) The storage of general waste at a facility that has the capacity to store in excess of 100m 3 of general waste at any one time, excluding the storage of waste in lagoons or temporary storage of such waste;

18 ITEM SUMMARY Pre-consultation with authorities, background information TIME-FRAME 1 week Prepare Draft Basic Assessment 3 weeks to compile Report and associated documents Public participation & site visit 1 week to arrange, 30 days to wait for comments from I&AP s Application form and landowner s Prepared during the 30 days consent prepared Draft Basic Assessment Report and associated documents finalised Submission of documentation (Application form and draft BAR) Submit within 1 week after the 30 days Acknowledgement (10 days but usually much longer) Finalise and submit final BAR Review period 107 days + Follow-up and additional information Regularly and tasks

19 N&S Norms and Standards for the Storage of Waste, 2013 Set of rules similar to a WML requiring some commitment: -registration -access control -signage -training -Emergency Response Plan (CTMM) -yearly audits -reporting (SAWIS/GWIS) -decommissioning

20 N&S General waste storage facility: Capacity to store in excess of 100m 3 of general waste continuously

21 NEMAQA SEMA s (2) National Environmental Management: Air Quality Act, 2008 (Act No. 39 of 2004) 22 Nov 2013 Air Emissions License (AEL) Category 8, Subcategory 8.1, Thermal Treatment of General and Hazardous Waste

22 BYLAWS Municipal Waste Bylaws (Normally a permit is needed) GDARD: General Waste Management Facility Standards (Guide only) Zoning

23 CLASSIFICATION NATIONAL ENVIRONMENTAL MANAGEMENT: WASTE ACT, 2008 (ACT NO. 59 OF 2008) Waste Classification and Management Regulations GN R. 634 of 23 August 2013

24 SUMMARY -NEMA Section 28: DUTY OF CARE -NEMWA: Listed activities GN R Norms and Standards for the Storage of Waste, 2013 GN R Reporting on government system -Municipal Waste Bylaws, Permit, Fire plan -Transport permit -H&S -NEMAQA -Zoning

25 CLASSIFICATION GW01 GW10 GW13 GW14 GW15 GW16 GW17 GW18 GW20 GW21 GW30 GW50 GW51 GW52 GW53 GW54 GW99 General Waste Municipal waste Commercial and industrial waste Brine Fly ash and dust from miscellaneous filter sources Bottom ash Slag Mineral waste Waste of Electric and Electronic Equipment (WEEE) Organic waste Sewage sludge Construction and demolition waste Paper Plastic Glass Metals Tyres Other

26 CLASSIFICATION HW01 HW02 HW03 HW04 HW05 HW06 HW07 HW08 HW09 HW10 HW11 HW12 HW13 & GW13 HW14 & GW14 HW15 & GW15 HW16 & GW16 HW17 & GW 17 HW18 & GW18 HW19 HW20 & GW 21 HW99 Hazardous and unclassified waste Gaseous waste Mercury containing waste Batteries POP Waste Inorganic waste Asbestos containing waste Waste Oils Organic halogenated and /or sulphur containing solvents Organic halogenated and/or sulphur containing waste Organic solvents without halogens and sulphur Other organic waste without halogen or sulphur Tarry and Bituminous waste Brine Fly ash and dust from miscellaneous filter sources Bottom ash Slag Mineral waste Waste of Electric and Electronic Equipment (WEEE) Health Care Risk Waste Sewage sludge Miscellaneous Total Hazardous and Classificed waste

27 CLASSIFICATION "Waste" means - (a) any substance, material or object, that is unwanted, rejected, abandoned, discarded or disposed of, by the holder of the substance, material or object, whether or not such substance, material or object can be re-used, recycled or recovered and includes all wastes as defined in Schedule 3 to this Act; or (b) any substance, material or object that is not included in Schedule 3 that may be defined as a waste by the Minister by notice in the Gazette,

28 CLASSIFICATION but any waste or portion of waste, referred to in paragraph (a) and (b) ceases to be a waste - (i) once an application for its re-use, recycling or recovery has been approved or, after such approval, once it is, or has been re-used, recycled or recovered; (ii) where approval is not required, once a waste is or has been re-used, recycled or recovered;

29 CLASSIFICATION (iii) where the Minister has, in terms of section 74, exempted any waste or a portion of waste generated by a particular process from the definition of waste; or (iv) where the Minister has, in the prescribed manner, excluded any waste stream or a portion of a waste stream from the definition of waste.

30 ESCAPE? What small guys need to do to get exemption and what storage really means Stay under the limits Compulsory: Report volumes Register with municipality Register storage facility Register transport vehicles

31 THANK YOU! ANY QUESTIONS?

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