PROPOSED E/F SLAB EXPANSION, PORT OF RICHARDS BAY. Revised Environmental Management Programme. September 2013 Revised: 2015/09/30 Public

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1 Image Property of Transnet SOC Ltd PROPOSED E/F SLAB EXPANSION, PORT OF RICHARDS BAY Revised Environmental Management Programme September 2013 Revised: 2015/09/30 Public

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3 Quality Management Issue/revision Issue 1 Revision 1 Revision 2 Revision 3 Remarks Draft Final Draft Revised Date September 2012 September 2013 September 2015 Prepared by Kelly Taylor Danielle Michel Danielle Michel Signature Checked by Hilary Konigkramer Transnet Signature Authorised by Hilary Konigkramer Danielle Michel Signature Project number Report number Draft Draft Draft File reference G://Projects/Live Projects/27959 G://Projects/Live Projects/27959 G://Projects/Live Projects/

4 PROPOSED E/F SLAB EXPANSION, PORT OF RICHARDS BAY Revised Environmental Management Programme 2015/09/11 Client Transnet Port Terminals Raymond van Rooyen Transnet Port Terminals Head Office Kingsmead Office Park Stalwart Simelane / Stanger Street Durban 4001 Tel: Fax: raymond.vanrooyen@transnet.net Consultant WSP Environment & Energy (Pty) Ltd Block A, 1 on Langford Langford Road, Westville Durban 3629 South Africa Tel: Fax: Registered Address WSP Environment & Energy South Africa 1995/008790/07 WSP House, Bryanston Place, 199 Bryanston Drive, Bryanston, 2191, South Africa WSP Contacts Danielle Michel Project number: Dated: 2015/09/ Revised: T00:00:00

5 Table of Contents 1 INTRODUCTION PROJECT DESCRIPTION SITE DESCRIPTION AIM OF THIS DOCUMENT ENVIRONMENTAL AWARENESS AND COMPLIANCE RESPONSIBILITIES FOR ENVIRONMENTAL MANAGEMENT TRAINING AND INDUCTION OF EMPLOYEES COMPLAINTS REGISTER AND ENVIRONMENTAL INCIDENT BOOK ENVIRONMENTAL MONITORING NON-COMPLIANCE WITH THE EMPR (PENALTIES / INCENTIVES FOR STAFF) EMPR AMENDMENTS / EMPR INSTRUCTIONS MACRO LEGISLATIVE FRAMEWORK MITIGATION MEASURES PROJECT LAYOUT AND ACCESS PLAN SITE ESTABLISHMENT MANAGEMENT OF CONSTRUCTION ACTIVITIES AND WORKFORCE TRAFFIC, ACCESSIBILITY & SAFETY AESTHETICS CULTURAL AND HERITAGE RESOURCES SURFACE & GROUNDWATER CHEMICAL STORAGE AND SPILL MANAGEMENT STORMWATER MANAGEMENT AIR QUALITY NOISE SOIL EROSION AND SEDIMENT CONTROL WASTE MANAGEMENT STRATEGY FAUNA & FLORA POST-CONSTRUCTION ACTIVITIES INFRASTRUCTURE POLLUTION CONTROL STRUCTURES RE-VEGETATION/REHABILITATION OF CONSTRUCTION AREA WASTE COLLECTION SUMPS STORMWATER MANAGEMENT AIR QUALITY GENERAL HEALTH, SAFETY AND ENVIRONMENTAL RECOMMENDATIONS SITE MANAGEMENT CONSIDERATIONS ENVIRONMENTAL EDUCATION AND AWARENESS WORKER CONDUCT ON SITE COMMUNICATION WITH STAKEHOLDERS CONCLUSION AND RECOMMENDATIONS

6 1 Introduction 1.1 PROJECT DESCRIPTION Transnet Port Terminals Richards Bay Terminal is located within the umhlathuze Local Municipality (uthungulu District Municipality). To facilitate South Africa s growing economy and the associated increase in demand for a vast range of commodities, Transnet Port Terminals (TPT) wish to ensure that their operational capacity meets this demand by expanding on storage areas within the Dry Bulk Terminal (DBT). This requires the construction of a new storage slab to be called Slab E & F East in the currently vacant piece of land immediately south of storage Slab C & D East. The proposed slab will be used for the storage of dry bulk cargo such as chrome, magnetite and coal, and will be suitably engineered with the use of G-blocks, or similar material, underlain by an impervious membrane. The proposed slab is proposed to be m 2 in size, and will have a maximum stockpile capacity of approximately 200 kt. The estimated throughput capacity is 2 million tons per annum, dependent on the density of the cargo. Cargo is proposed to be brought in via road truck and conveyor and stacked by payloader onto the storage slab until transfer via conveyor belts onto ships for export. Associated infrastructure includes a stormwater management system, dust suppression mechanisms, high mast lighting and conveyors. The proposed construction is subject to environmental authorisation by the Department of Environmental Affairs (DEA) in terms of the Environmental Impact Assessment Regulations, 2010, promulgated in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998), as amended. In addition, the project requires an amendment to the existing Air Emissions License in terms of the National Environmental Management: Air Quality Act (Act No. 39 of 2004). 1.2 SITE DESCRIPTION The selected site (Figure 1) for the proposed activity is located at the E/F Slab within the DBT at the Port of Richards Bay, umhlathuze Local Municipality. The site is bordered by the existing C/D open storage slabs to the north; and sheds, offices and the quayside to the south. The DBT extends west and east of the proposed site. The site has been historically disturbed and no longer represents natural conditions. The vegetation present on site comprises predominantly of secondary (alien or pioneering) species. No other site alternatives exist for this project at this stage. This portion of land is currently undeveloped within the Port boundary. It is ideally situated in terms of serving the surrounding cargo owners and complementing the surrounding land use within the Port. 1.3 AIM OF THIS DOCUMENT The aim of this Environmental Management Programme (EMPr) is to identify and minimise, as far as possible, potential impacts that the proposed slab expansion may have on the surrounding biophysical and socioeconomic environment. The EMPr will serve as the environmental input to the contractors tender in order to ensure that the selected contractor complies with all necessary environmental management actions and incorporates this into the proposed budget. The purpose of the EMPr is to: Encourage good management practices through planning and commitment to environmental issues; Define how the management of the environment is reported and performance evaluated; Provide rational and practical environmental guidelines to: - Minimise disturbance of the natural environment; - Prevent or minimise all forms of pollution; Project number: Dated: 2015/09/ Revised: T00:00:00

7 - Protect indigenous flora and fauna; - Comply with all applicable laws, regulations, standards and guidelines for the protection of the environment; and, - Adopt the best practicable means available to prevent or minimise adverse environmental impacts. Develop waste management practices based on prevention, minimisation, recycling, treatment or disposal of wastes; Describe all monitoring procedures required to identify impacts on the environment; and, Train employees and contractors with regard to environmental obligations. Figure 1: Project Locality (SA Topographical Maps, 2832CC, 1997). 2 Environmental Awareness and Compliance 2.1 RESPONSIBILITIES FOR ENVIRONMENTAL MANAGEMENT The Contractor and / or its agents will be responsible for environmental management on site during the installation period. A pre-construction meeting is recommended in order to reach agreement on specific roles of the various parties and penalties for non-compliances with the EMPr. In addition surrounding residents, tenants or land owners must be notified in advance of any potentially disturbing activities. An independent environmental consultant will need to act as the Environmental Compliance Officer (ECO) and conduct inspections of the construction activities and EMPr implementation throughout the duration of 5 30

8 construction. It is recommended that inspections are undertaken on a monthly basis, and that monthly reports are submitted to the site manager and the National Department of Environmental Affairs (DEA). Relevant sections of the minutes of site meetings will be attached to the monitoring report. Table 1 below outlines the various roles, responsibilities of the applicant, subcontractors, the ECO and authorities. Table 1: EMPr Responsibilities EMP Designation TPT DEA All Contractors and Sub-contractors ECO Responsibilities Review and approve the EMPr prior to authorisation by DEA; Ensure that the EMPr is included in the tender document; Ensure that the latest EMPr documents are filed and readily accessible at the contract area; Review and authorise updates to the EMPr made by the ECO; and Ensure that the contractor has reflected and provided sufficient resources (cost, and personnel) for implementation of the EMPr requirements. Authorise the EMPr prior to commencement of the project; Authorise any substantive amendments to the EMPr should these be required; and Undertake compliance monitoring should this become warranted, or to verify the ECO s reports. Review management actions stipulated in the EMPr and ensure that adequate financial and resource provisions are made; Provide TPT with written confirmation of intent to comply (indirectly by way of contractual agreement will suffice); Timeously advise the ECO of any intended deviations to the work procedures on which this EMPr is based, such that the need for amendment of environmental management actions can be assessed; and Ensure that all staff involved in the project is familiar with the EMPr requirements. Update the EMPr to include conditions included in the environmental authorisation (EA) and ensure that all relevant parties are in possession of an up to date EMPr; Provide support and advice to the contractor and all subcontractors in the implementation of environmental management procedures; Undertake regular EMPr compliance audits (in line with the EA) and compile monthly reports. Provision of reports to TPT, along with submission to the DEA; and Attend project meetings (if required) to discuss and resolve environmental concerns and non-compliances. 2.2 TRAINING AND INDUCTION OF EMPLOYEES The Contractor has a responsibility to ensure that every person involved in the project is aware of, and is familiar with the environmental requirements of the project. The EMPr shall be part of the Terms of Reference (ToR) for all Contractors, Sub-contractors and Suppliers. All Contractors have to give some assurance that they understand the EMPr and that they will undertake to comply with the conditions therein. All senior and Project number: Dated: 2015/09/ Revised: T00:00:00

9 supervisory staff members shall familiarise themselves with the full contents of the EMPr. They shall know and understand the specifications o f the EMPr and be able to assist other staff members in matters relating to the EMPr. It is recommended that an environmental awareness training programme for all staff members should be arranged by the Contractor and facilitated by the ECO. Before commencing with any work, all staff members shall be appropriately briefed about the EMPr and relevant occupational health and safety issues. 2.3 COMPLAINTS REGISTER AND ENVIRONMENTAL INCIDENT BOOK Any complaints received from the community, neighbours and other land users must be registered and recorded by the contractor on site. The complaint must be brought to the attention of the site manager and ECO, who will respond accordingly. The following information will be recorded: Time, date and nature of the complaint; Response and investigation undertaken; and Actions taken and by whom. All complaints received will be investigated and a response (even if pending further investigation) is to be given to the complainant within 7 days. All environmental incidents occurring on the site will be recorded. The following information must be provided: Time, date, location and nature of the incident; as well as, Actions taken and by whom. 2.4 ENVIRONMENTAL MONITORING Environmental monitoring of the proposed construction must be undertaken by the ECO at a frequency set out within the EA (monthly basis recommended). Monitoring is to be undertaken so as to ensure compliance with all aspects of the EMPr. In order to facilitate communication between the ECO, Resident Engineer (RE) and Contractor, it is important that a suitable chain of command is structured that will ensure that the ECO s recommendations have the full backing of the project team before being conveyed to the Contractor. In this way, penalties as a result of noncompliances with the EMPr may be justified as failure to comply with instruction from the highest authority. 2.5 NON-COMPLIANCE WITH THE EMPR (PENALTIES / INCENTIVES FOR STAFF) Difficulties may be encountered with carrying out mitigation measures that could result in future noncompliance. The Contractor may put in place procedures to motivate staff members to comply with the EMPr, and to deal with acts of non-compliance, or malicious damage to the environment by any staff member, agent, contractor or sub-contractor. Should rehabilitation be required as a consequence of the contractor s noncompliance with the EMPr, it is suggested that fines / penalties be set according to the cost required to rehabilitate an area. Penalties for non-compliance need to be discussed with the Contractor at the earliest stage (during the pre-construction meeting). 2.6 EMPR AMENDMENTS / EMPR INSTRUCTIONS EMPr amendments (relaxation or revision of any mitigation measure) shall not be allowed without approval from the relevant authority (DEA). Motivations for amendments to the EMPr must be discussed with the ECO. WSP may propose EMPr amendments on behalf of the proponent or issue EMPr instructions (corrective actions, remediation and rehabilitation). These amendments or instructions issued by the ECO shall be implemented within the specified timeframe. 7 30

10 3 Macro Legislative Framework The EMPr has been developed in line with South Africa s environmental legislation so as to ensure that reasonable measures are taken to warrant environmental protection and to promote sustainable development. The adherence of the contractors to the stipulations outlined in this EMPr will ensure compliance with the applicable legislation outlined in Table 2. Table 2: Applicable National Environmental Legislation Act / Regulation The Constitution of the Republic of South Africa Act (No. 108 of 1996) National Environmental Management Act (NEMA) (No. 107 of 1998) as amended Relevant Clause S. 24(a): Everyone has the right to an environment that is not harmful to the health and well-being of individuals and to have the environment protected by reasonable protective measures. S. 24(b): Protection of the environment for present and future generations. Any person/organization is responsible for preventing pollution and ecological degradation, promoting conservation and securing ecologically sustainable development or resources in their day-to-day activities. S28 (1) and (2): Duty of care and remediation of environmental damage - Every person/company who causes, has caused or may cause significant pollution or degradation of the environment must take reasonable measures to prevent such pollution or degradation or minimise and rectify such pollution if not avoidable. National Water Act (No. 36 of 1998) Chapter 3 and 4 and Section 19 (1) and (2): Any person/company who owns/controls/occupies/uses land in question is responsible for taking measures to prevent pollution of the water. Reasonable measures to be taken to prevent pollution of water resources from occurring, continuing or recurring. Polluters may be required to cease operations, contain, eliminate and/or remedy effects of pollution. National Environmental Management: Air Quality Act (NEM:AQA) (No. 39 of 2004) The NEMAQA introduces a system based on ambient air quality standards and corresponding emission limits to achieve them. Two significant regulations stemming from NEMAQA are: GNR 1210 on 24 December 2009 (Government Gazette 32816) National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) National Ambient Air Quality Standards. GNR 248 on 31 June 2010 (Government Gazette 33064) National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) List of Activities Which Result in Atmospheric Emissions Which Have or May Have a Significant Detrimental Effect on the Environment, Including Health, Social Conditions, Economic Conditions, Ecological Conditions or Cultural Heritage. Project number: Dated: 2015/09/ Revised: T00:00:00

11 National Environmental Management Waste Act (NEM:WA) (No. 59 of 2008) South African National Standards (SANS 10103:2008) Section 16: General duty in respect of waste management (1) A holder of waste must, within the holder's power, take all reasonable measures to: (d) Manage the waste in such a manner that it does not endanger health or the environment or cause a nuisance through noise, odour or visual impacts. Acceptable noise levels are prescribed by SANS 10103: SANS has been superseded by SANS 10103:2008 (The Measurement and Rating of Environmental Noise with Respect to Annoyance and to Speech Communication). It is the most relevant code of practice for environmental noise impact assessment in South Africa. 4 Mitigation Measures This EMPr divides activities associated with the project into a number of components. The environmental management controls for these various components are discussed under the following headings: Background Objectives Actions - Provides background information on the site specific issues. - Describes what the strategy is aiming to achieve. - Describes the steps to be taken to implement the strategy. Performance indicators - Specifies the parameters which may be used to assess the level of EMPr implementation. Monitoring Programme - Describes the monitoring, reporting and review arrangement for each task, to include frequency, personnel responsible etc. 4.1 PROJECT LAYOUT AND ACCESS PLAN A project layout and access plan must be developed to show the intended use of the construction area. The plan must clearly indicate and/or describe the location and details of: Service lines and servitudes; Areas and routes to be reworked, including the size (dimensions) of the stripped areas; The construction camp site and rest areas to be used during construction; Temporary on-site waste disposal areas to be used during construction; Designated areas for on-site storage of construction materials; Designated areas for portable latrines (beyond 100m from quayside / harbour waters); Sources for water provision on site; 9 30

12 Areas designated for power supply during construction; Existing roads and tracks to be used as transportation routes, and routes to gain access to construction areas; and The footprint area of construction area. The layout plan must be provided to the ECO prior to the commencement of construction activities on site. The ECO should be consulted when the contractor is unsure of the placement of any of the items listed above. 4.2 SITE ESTABLISHMENT Background The aim of site establishment in terms of this document is to reduce unnecessary damage to the site, potentially affecting biophysical aspects of the site and surrounding land uses. Sources of Potential Impacts Removal of vegetation; Heavy vehicles delivering materials; Heavy construction vehicles operating on the site; Contractors and the general workforce; Ablution facilities; On-site waste management facilities; Water storage and supply; Power supply; and Storage areas and stockpiles. Objectives Actions To minimise disturbance of the land; To minimise impacts on fauna and flora; To minimise impacts on cultural and heritage resources; To minimise erosion and sediment transport from the site; To prevent sedimentation and contamination of surface and groundwater; To minimise visual intrusion; To maximise the use of the soils on the site for rehabilitation; and To prevent the proliferation of alien invasive plant species. a) Water source: Water may NOT be abstracted from harbour waters nor any river, dam lake or stream. The only water source that may be used for construction activities, including concrete mixing, cleaning of equipment, etc. must be obtained from the municipal water supply. b) Vegetation clearing: Only clear vegetation that is absolutely necessary immediately before site establishment commences. This minimises the project footprint by disturbing the smallest possible area for the least amount of time; Manage cleared areas and residual material from clearing in order to minimise Project number: Dated: 2015/09/ Revised: T00:00:00

13 degradation of the site; Areas outside of the development footprint must be clearly demarcated where feasible; and, Removal of all alien vegetation must be undertaken on site in consultation with the ECO. c) Construction camp A construction camp site plan must be provided with a description of the site and shall show, on an appropriately-scaled map, the intended use of the site; and d) Waste management Specially demarcated areas must be indicated for areas to be utilised by heavy machinery. These areas must be monitored by a designated individual on site, so as to ensure that sensitive areas outside of the construction area are not damaged. All waste (including rubble and excess hard standing) must be removed from site and appropriately disposed of and safe disposal certificates obtained where necessary. e) Access routes In order to avoid vegetation loss and prevent soil erosion, no unnecessary access routes should be cleared. The ECO should be consulted prior to the development of any additional access routes. f) Materials stockpiling Any embankments/stockpiles created must be immediately stabilised using shade cloth or if to be left for a period longer than eight weeks by seeding; and Soil storage areas must be located further than 50 meters from any water body or water source (Section 1 (24 and 29) of National Water Act (Act 36 of 1998)). g) Ablutions Toilets must be no closer than 100m from any watercourses, wetland or harbour waters. The ECO should be consulted on the location of toilet facilities throughout the construction phase of the project. The need for a clean site policy needs to be explained to everyone working on site. Performance Indicators Minimal erosion evident; No areas unnecessarily disturbed; Amount of litter around the site camp; and Correct placement of soil storage, waste and toilet facilities. Monitoring Programme Visual assessment supported by photographic records of the site. 4.3 MANAGEMENT OF CONSTRUCTION ACTIVITIES AND WORKFORCE Most environmental impacts of developments occur in the construction phase of the project. As a result, the regulation of construction activities and the general conduct of the workforce is an essential component of this EMPr and must be carried out in conjunction with the ECO. The construction phase is anticipated to have a duration of 12 months Traffic, Accessibility & Safety Background The presence of construction vehicles and slow moving traffic may cause safety issues and congestion within and around the Port. The mitigation measures stipulated below must be followed in order to reduce this impact

14 Sources of Potential Impacts Traffic and access related disturbance is associated with the undertaking of construction activities, specifically relating to: The location and development of the site camp; Importing of materials and machinery to the site; Construction activities, including excavation and layering; and Handling/transporting of materials. Objectives Actions To minimise interruption to normal traffic flow and access to industries within the Port, as well as to surrounding residential and business/commercial areas; and, To minimise the potential for traffic incidents and safety issues. a) Location of the site camp and storage of machinery and materials b) Construction activities on site Monitoring Procedure The site camp and storage of machinery and materials must be located so as to ensure that it does not block access to adjacent properties or facilities; The location of the site camp and storage facilities should be carried out in conjunction with the ECO, through providing him/her with a layout plan of the site camp; and, Any complaint of inhibited access must be recorded in the complaints register. Signage must be placed at relevant points along the roads to caution motorists and pedestrians of the activities and closed roads where applicable; If appropriate, alternative routes should be indicated, demarcated and monitored to divert traffic around the site; Standard traffic calming should be maintained where necessary; The transport of machinery or materials onto the site should be done at off peak traffic hours, so as to prevent unnecessary interruption of traffic flow and access along roads within the Port of Richards Bay; and, Construction activities and storage facilities must not obstruct roads or traffic flow as far as possible. Visual assessment of the site layout, storage facilities and safety measures; and No complaints received from community or road users within the Port Aesthetics Background Visual disturbances are likely to arise from construction activities. Potential receptors include adjacent landusers and those within the viewshed of the site. Sources of Potential Impacts Vegetation clearing; Excavation and soil stockpiling; Presence of construction vehicles; and Activities associated with site excavation, clearing, and construction. Project number: Dated: 2015/09/ Revised: T00:00:00

15 Objectives Actions To prevent visual intrusion. The working area must be cordoned off with 1.8m bonnox (or equivalent fencing) and 30% shade cloth. This fencing would be situated between the working area and the property boundaries, where instructed by the ECO; and, The site must be maintained in a neat and orderly manner. Performance Indicators Complaints received from surrounding landusers relating to visual intrusion or disturbance; and The site environmental officer to ensure that the inspections undertaken on site include assessment of housekeeping on site. Monitoring Programme Visual assessment of the site and inspection of: - Implementation of recommended screening Cultural and Heritage Resources Background All heritage resources are protected by the National Heritage Resources Act (Act No. 25 of 1999), and may not be altered or destroyed, or removed from its place of storage without a permit. Amafa is the provincial heritage conservation agency for KwaZulu-Natal. There is potential for construction activities to impact on heritage and cultural resources should these be found on the proposed site. Sources of Potential Impacts Activities associated with site excavation, clearing, and construction; Handling / transporting of materials on site; Operation of construction vehicles and machinery on site; and Presence of workers on site and in the site camp. Objectives Actions To prevent any impacts to cultural and heritage resources that may be present on site. Any heritage resources identified during the construction phase must be appropriately dealt with. It is imperative that the following conditions are followed: Amafa must be contacted if any heritage objects are identified during earthmoving activities and all development should cease until further notice; Amafa must be contacted if any graves are encountered that have not already been identified during construction and the following procedure is to be followed: - stop construction; - report finding to local police station; and - report to Amafa to investigate. Should the contractor be unsure of the any of the above aspects, the ECO should be contacted 13 30

16 immediately. Contact details for Amafa are as follows: Pietermaritzburg Office Ms Bernadet Pawandiwa Tel: Surface & Groundwater Background There is potential for construction activities to impact on surface and groundwater quality, in terms of contamination by eroded soils, construction materials, hydrocarbon waste and chemicals. This will require careful management to mitigate any potential impacts on water quality. Sources of Potential Impacts The handling of hazardous substances; and Accidental spillages / leaks from construction machinery and vehicles. Objectives Actions To minimise the impact of construction activities on natural water resources (marine) and surface water; and Prevent contamination of the surface and groundwater by cement, hydraulic fluid, oil, diesel or solvent chemicals etc. stored and transported on and around site. Any mixing of concrete must take place on an impermeable surface; Waste concrete must then be removed to an approved landfill site; Vehicles and machinery are to be well maintained. All servicing must be done at a workshop and not on site; A spill kit must be available in the event of a hydrocarbon or chemical spill. If an incident occurs, ensure that the appropriate corrective actions are undertaken as described in Box 1 (Section 4.3.5). Decanting and storage of solvents must take place within a bunded area (designed for 110% capacity) on an impermeable surface (e.g. concrete slab); and A dedicate re-fuelling station to be demarcated, and a drip tray to be placed here. Re-fuelling shall only take place at the dedicated area. Performance Indicators No incidences of hazardous substance spillage or mixing of concrete on permeable surfaces. Monitoring Programme Visual assessment of the site; and Examinations of the Environmental Incident Register for record of spill incidents Chemical Storage and Spill Management Background Minor amounts of fuel, oil, grease, paints and solvents (e.g. cement; epoxies; lime and other stabilizing agents; tar products, and paint) will be stored on the site for use during the construction phase. Contamination of the biophysical environment by substances must be avoided. These substances should be kept within either of the following: Project number: Dated: 2015/09/ Revised: T00:00:00

17 A concrete base surrounded by a low brick wall; or, A shallow excavation lined with two layers of thick plastic sheeting, weighted down with rocks in the base and sandbags on the edge. Sources of Potential Impacts Maintenance materials and chemicals used for construction could be hazardous, and if spilled will result in soil and potentially water contamination; or, Construction machinery leaking oil and diesel. Objectives Actions To prevent uncontrolled release of chemicals to the environment; and, To minimize the potential for contamination of land or water. a) Storage and handling of hazardous substances TPT, as well as the principle contractor, will ensure that all employees and contractors who are responsible for handling chemicals or dangerous substances undergo relevant training. The same applies to the section of the workforce who will be responsible for the maintenance of equipment, to prevent the accidental discharge or spill of fuel, oil, lubricants and other chemicals; Chemicals must be stored in labelled, closed containers within designated areas, preferably sheltered, with sealed floors away from drains, watercourses or harbour waters; MSDSs for all chemicals kept on site must be available at the point of use or storage; Chemicals must not be stored within 100 meters of any water body or drains. The ECO should be consulted when locating the chemical stores; Unauthorized access to the chemical stores must be controlled; Vehicles and machinery are to be well maintained. All servicing must be done at a workshop and not on site; Do not bury material from bunded areas (this should be treated as hazardous material); Mixing of cement to take place on an impervious surface (i.e. plastic sheeting); and, Store waste oil and grease away from drains or watercourses in bunded roofed and sealed areas and ensure collection by a licensed waste contractor. A spill kit/s must be kept on site for responding to chemical/oil spills. b) Ablutions Portable ablution facilities must not be located within 100m of drains, watercourses or harbour waters; and, c) Spill procedures Waste from ablution facilities will be regularly removed and care will be taken to ensure that there is no spillage, resulting in possible environmental contamination. Provide for spillage control by bunding or collecting spills to a sump for disposal or controlling by absorbent material on standby (e.g. Drizit); and, If an incident occurs, ensure that the appropriate corrective actions are undertaken as described in Box 1. Contractor employees to be trained on spill procedures, and emergency response. Box 1. Actions to be taken in the event of a major spill of hazardous substances: 15 30

18 1) Stop the source of the spill; 2) Contain and clean up the spill immediately and remediate or appropriately dispose of the contaminated material; 3) The affected area should be scraped off to the depth of contamination using a spade (small area) or a front-end loader or scoop (large area), absorbent materials such as sawdust or sand will be used to absorb and clean up any fuel or oil spills; The contaminated substrate will be stored in a suitable container for further appropriate disposal to an accredited landfill site. Hazardous waste disposal must be accompanied by a safe disposal certificate. 4) Report all spills in the onsite environmental incident book, including: the date, time and location, quantity and type of material spilled, circumstances that caused the spill, damage caused, description of the clean-up. 5) All significant spills must be reported to the Department (DEA) (Waste Management) and other relevant authorities. If remedial action is required, this must be taken in consultation with the Department of Water Affairs (DWA). 6) In the event that the spill cannot be contained the following departments must be informed of the incident within 48 hours: - Local Municipality; - DWA; - DEA; - Local Fire Department; and - Any other affected departments. Performance Indicators No significant chemical spills; and, No release of chemicals into the environment. Monitoring Programme 1 Chemical storage areas will be visually inspected; Adequacy of bunding will be assessed; and, Records of spills will be examined in the environmental incident book Stormwater Management Background The National Water Act (36 of 1999) provides for the control of water pollution. Stormwater management focuses on the avoidance of contamination of natural water bodies together with the prevention of erosion and downstream flood events. The majority of stormwater emanating from the site will flow naturally to low-points of the site. In addition to this, the proponent is responsible for the adequate management of stormwater on site. Sources of Potential Impacts 1 Note: The responsibility rests with the applicant to identify any sources or potential sources of pollution from his undertaking and to take appropriate measures to prevent any pollution of the environment. Failure to comply with the requirements of the National Water Act (Act 36 of 1998) could lead to legal action being instituted against the applicant (Department of Water Affairs) Project number: Dated: 2015/09/ Revised: T00:00:00

19 Potential deterioration of surface water quality in the event of runoff associated with the accidental releases of small volumes of construction chemicals (e.g. diesel and oil) whilst developing the site camp and during construction; Potential for the deterioration of groundwater quality as a result of the spillage and seepage of construction chemicals (e.g. diesel and oil) onto bare soil; and Potential downstream impacts as a result of cumulative contamination within river, mangrove or ocean systems that may result from site-generated contaminants. Objectives Actions To minimise the effects of stormwater flow on the downstream catchment, harbour waters and mangrove swamps; To manage any potentially contaminated stormwater (suspended solids) from the site during construction; and, To ensure that the long term discharge of stormwater will not lead to erosion or downstream flooding. a) Spillage & Contamination b) Ponding & Erosion Prevent stormwater runoff from coming into contact with wastes or contaminants on the site; Divert clean water around the construction site using defined drainage corridors protected against erosion; Direct contaminated run-off through sediment ponds to remove suspended solids; If a spill of any description occurs, appropriate corrective action will be taken (Box 1); All potential contaminants (oil, diesel etc) will be stored in bunded areas which have a capacity of more than 110% of the substances being contained therein; All machinery should be re-fuelled and serviced offsite. If on-site re-fuelling is required, machinery will be re-fuelled and serviced in a designated area with an impermeable layer; Vehicles will be carefully maintained to ensure that they do not leak (oil, hydraulic fluids, and diesel). Drip trays or fuel sumps are to be placed under machinery that are being refuelled; or that are parked overnight; Adequate ablutions (such as chemical toilets) must be located in an area 100m or more from stormwater drainage systems and water bodies; and, Any pollution spills must be reported to DWA on the following number (031) Ensure that permanent drainage and ponding infrastructure are designed by suitably qualified engineers; Ensure that stormwater discharge points are protected against erosion; Increase water infiltration on the site by the use of grass blocks or other infiltration enhancing mechanisms wherever possible; and, Stormwater drainage must not damage properties or infrastructure downstream. Monitoring Procedure Visual assessment supported by photographic records of the site

20 4.3.7 Air Quality Background There is potential for construction activities to generate airborne dust and vehicular emissions leading to a deterioration of local air quality. Sources of Potential Impacts Vehicle emissions; Vehicular movement on the un-tarred sections of the road network, or on gravel access roads; Land clearing and removal of topsoil as well as from the layer works; Loading and unloading of material on site and transport from site; Excavations; and Wind action on stockpiles and exposed areas of the site. Objectives Actions To minimize the release of fugitive emissions from the site during construction; and Minimise disturbance to neighbouring businesses and operations. Seed topsoil stockpiles and exposed areas of the site within 8 weeks of completing construction of a specific site or part thereof; Spray water on unsealed surfaces in high winds to reduce dust. A dedicated source of water for dust suppression purposes must be determined during site establishment and be approved by the ECO; Ensure that vehicles are well maintained to reduce emissions; and Do not use open fires for cooking or for the burning of refuse. Performance Indicators No dust plumes on site and surrounding vegetation remains dust free; and No complaints in the Environmental Incident Register. Monitoring Programme Visual assessment of site and adjacent vegetation Noise Background The South African National Standards (SANS) have published environmental noise limits for different zones (e.g. rural and industrial). These limits have been incorporated into By-Laws by some municipalities. Disturbance to the landusers in the vicinity of the construction areas will have to be taken into account during the construction phase. Unwarranted noise levels due to construction activities should be maintained within the satisfactory standards. Sources of Potential Impacts Earth moving machinery; Other construction machinery such as cranes; Power tools and compressors; Project number: Dated: 2015/09/ Revised: T00:00:00

21 Vehicle movements; and, General construction and operational activities. Objectives Actions To minimise the noise generated by construction activities. As far as possible, construction activities must be limited to weekdays (Monday Friday) during working hours (7:30am 5pm); Construction vehicles are to be well maintained and fitted with silencers prior to the construction phase; All servicing must be done at a workshop and not on site; and, Investigate all instances of excessive noise and assess possibilities for mitigation. Performance Indicators The number of complaints received from the surrounding landusers regarding noise. Monitoring Programme Disturbances to landusers in the vicinity of the construction areas Soil Erosion and Sediment Control Background There is the potential for soil erosion during site clearing activities, excavation and construction. Sources of Potential Impacts Sediment transport through stormwater run-off. Objective Actions To minimise disturbance of the land; To minimise erosion and sediment transport from the site; and To minimise contamination of harbour waters. Where excavations occur, backfill and rehabilitation must occur promptly (i.e. within 4 weeks); Use a level area for storage of construction materials; Where temporary stockpiling of soil is necessary, standing time must be kept to a minimum (i.e. temporary storage - not more than 8 weeks); Install temporary erosion and sediment control devices e.g. sand bags and ponding berms, along the site low points prior to commencing with earthworks; Clear vegetation immediately before earthworks commence (i.e. do not leave soils exposed for long periods); Minimise the size of the project footprint; Ensure that any embankments created by the earthworks are stable and immediately planted to ensure their long term stability; Avoid contamination of the soil by cement, hydraulic fluid, oil, diesel etc., and 19 30

22 Stockpiles must be positioned away from the harbour waters, steep slopes or stormwater drains to prevent soil from eroding directly into the sea. Performance Indicators Erosion avoided or minimised, the implementation of standard erosion and sediment control techniques. Monitoring Programme Inspection of all erosion and sediment control devices on a monthly basis, particularly after heavy rains; and, Inspection of all steep slopes created Waste Management Strategy Background NEMA makes provision that waste should be avoided, recycled or at least disposed of in an acceptable manner. Waste generated from construction activities on site may include: Excavated material; Concrete; Scrap metal/pipe segments; General construction and office refuse; Waste construction materials; Residual vegetative material from clearing activities; and, Oil and diesel contaminated materials disposed of as hazardous waste. Sources of Potential Impacts Litter and waste from construction; and, Waste distributed by the wind, water or by scavengers. Objectives Actions To prevent the contamination of soils and water as well as pollution in general; To minimise the generation of wastes; To maximise re-use and recycling of waste material; and, To contain, control and dispose of waste in accordance with the required waste management practices. a) General Waste Implement appropriate training and induction procedures to ensure all sub-contractors adopt best practice waste minimisation procedures; Minimise littering. Provision of suitable waste disposal containers at the temporary construction camp. These receptacles will be clearly marked as general waste in both English and Zulu. The bins will be emptied on a daily basis into a waste skip stored at the permanent site camp. The contractor will be responsible for the weekly removal of the general waste from the collection area to a registered landfill; and Project number: Dated: 2015/09/ Revised: T00:00:00

23 b) Non- Hazardous Waste c) Hazardous Waste Waybills certificates for all waste loads removed from the site must be kept on file. No waste must be burnt; Ensure that green waste does not contain any seeds of alien plants or weeds; The working areas and storage sites must be cleared of litter on daily basis; Store timber, metal, oil, paper, bricks, tyres, batteries and any other major recyclable wastes in bunded areas away from drains or water courses prior to re-use or collection for recycling; Litter bins must be marked for separate types of waste e.g. glass, paper, plastic, etc.; Rubble must be disposed of in a demarcated area within the site camp or at an approved alternate site, before being reused or disposed of to the nearest landfill; Collect maintenance and domestic refuse (scrap metal, packaging materials etc.) in appropriate bins for recycling or send to landfill for disposal in an approved manner; and, Waste from ablution facilities must be regularly removed and care must be taken to ensure that there is no spillage, resulting in possible soil or water contamination. Load and unload any solid hazardous materials in a manner that reduces potential spills; Any mixing of concrete must take place on an impermeable surface and a sump for concrete waste must be created. This waste must then be removed to an approved landfill site; Designated and labelled receptacles must be provided for hazardous waste; Hazardous waste disposal must be undertaken by an approved waste contractor; The hazardous substance containers, contaminated soil, clean-up materials, etc., must be transferred to an appropriate disposal site on a regular basis; and, Safe disposal certificates for any hazardous waste removed from the site must be kept on file. Performance Indicators No breaches associated with transport, collection, storage, and disposal/re-use of wastes. Monitoring Programme Regular visual assessment of all storage containers and areas for capacity, potential for recycling, and evidence of spillage etc.; and General housekeeping of the site will be examined to ensure stormwater runoff does not contain refuse or contaminants Fauna & Flora Background Vegetation will have to be cleared within the construction footprint in order to accommodate for movement of vehicles or machinery and laying of the storage slab. Potential disturbances to fauna and flora may occur during site clearing, and due care must be taken to avoid biodiversity loss and the spread of alien vegetation. Sources of Potential Impacts Potential disturbance to indigenous vegetation by trampling during walkover surveys and localised removal; 21 30

24 Potential disturbance of fauna through careless clearing and disposal of vegetation; Removal of indigenous floral species without prior consent from the ECO; Potential for further alien vegetation encroachment in cleared and disturbed areas; and The use of herbicides in site clearing. Objectives Avoid removing vegetation that does not need to be removed; Minimise the proliferation of alien vegetation; Minimise the destruction/degradation of the indigenous vegetation; and Minimise the effects to fauna due to habitat loss. Actions Herbicides may not be used for site clearing; Methods for controlling alien vegetation must be agreed upon with the ECO; Alien vegetation must be correctly disposed of to avoid proliferation beyond the site boundaries; Fauna found on site during site clearing (such as reptiles or small mammals) must be removed to an appropriate vegetated area by a relevant specialist, in consultation with the ECO; Keep additional vehicular and worker access routes to a minimum; Avoid the removal of vegetation outside of site area; and On-going communication with ECO regarding vegetation removal and disposal. Performance Indicators No encroachment of alien invader species on the disturbed cleared areas (and beyond project site as result of construction activities); and No disturbance to endangered floral or faunal species. Monitoring Programme The ECO will provide the Contractor with the most appropriate, species-specific methods for eradicating problem plants; and No disturbance of vegetation outside the construction area. 4.4 POST-CONSTRUCTION ACTIVITIES The operational phase is an essential component of this EMPr and must be carried out in conjunction with the ECO. These recommendations apply most specifically to the storage and handling requirements, as well as ongoing equipment maintenance and monitoring of operational processes. The requirements for the control of soil, water, air and noise pollution stipulated in this EMPr still apply during the site rehabilitation phase of the project. Similarly, the requirements for alien vegetation removal and traffic impacts also apply Infrastructure All infrastructure units will be disassembled; and components from the working and storage areas will also be removed. This will include temporary office and storage structures and containers, water storage containers, temporary stormwater control structures and power supply, etc. All portable chemical toilets will be drained, Project number: Dated: 2015/09/ Revised: T00:00:00

25 with no spillage of the contents. The contents will be transferred to an appropriate disposal site. All wastewater and sewage associated with the temporary ablution facilities will be drained and the waste transferred to an appropriate sewage treatment works Pollution Control Structures Responsibility for the identification of any sources of pollution from the construction activities on site rests on the applicant, and contractors. All areas of contaminated substrate will be removed; the contaminated substrate will be transferred to an appropriate disposal site. All plastic linings used for pollution/contamination control will be removed and transferred to an appropriate disposal site. All temporary concrete structures that have been created will be broken up and the concrete removed to an appropriate disposal site. In all instances where hazardous waste is removed from site and disposed of during this process, a safe disposal certificate will be obtained Re-vegetation/Rehabilitation of Construction Area Any areas that are disturbed by the construction of the facility will need to be rehabilitated as soon as possible, including the contouring of the site to ensure free flow of run-off sand to prevent ponding of water. All re-vegetated areas will need to be watered to ensure plant growth and development. The volume and frequency of watering will be left to the discretion of the Rehabilitation Contractor and ECO. All areas within the camp and construction site, where soil has been stripped, disturbed and replaced will need to be revegetated. This may include: - Contractor s Camp; - Additional infrastructure; - Access routes; and - Other areas disturbed during the construction phase. Landscaping in the area should be done with indigenous species Waste Any left-over non-hazardous construction materials will be used within the port for port-related construction or disposed of at an appropriate permitted landfill site, with safe disposal certificates being obtained for hazardous waste disposal. Do not burn or bury any waste at the construction site all waste is to be transferred to a permitted disposal site Collection Sumps Drain all collection sumps and dispose of the contaminated liquid and solids at an appropriate disposal site; and Remove the tanks or plastic linings or similar and transfer to a permitted site for disposal Stormwater Management An increase in hardened surfacing (i.e. construction of the storage slab) will result in an increase in surface water runoff especially during precipitation events and if uncontrolled will potentially entrain suspended and dissolved sediments from the stockpiles, hydrocarbons, and other maintenance chemicals, potentially affecting water quality in the harbour. The Stormwater Management Plan (SWMP), produced as part of the environmental authorisation application, is included as a Specialist Report in Appendix D of the Basic Assessment Report (BAR). The following stormwater management controls must be implemented, as per the SWMP: 23 30

26 The Conceptual Stormwater Management Plan must be put in place as per Section 4 and Appendix B of the SWMP. To determine if the magnetite and chrome ore is expected to pose a contamination risk to surface and groundwater resources, leachate testing should be conducted on these materials. Should leachable concentrations be elevated, runoff leaving the sediment traps may require appropriate containment and disposal. The containment volume is dependent on contamination concentration attenuation, and should be determined based on USEPA NPDES methodologies. In order to prevent ponding of rain water on the slab areas, the cargo should be placed in such a manner so as to allow for free drainage around the stockpiles. This will reduce the retention time of stormwater on site thereby minimising the contact period between the cargo and water discharging off site. Depending on the material characteristics, this may limit the generation of dissolved phase contamination. Stockpiles of cargo should be placed in a manner that prevents the direct spill of raw materials to the stormwater management system. Should there be a contamination risk to the underlying groundwater, the paving should be underlain by an impervious membrane, or potential subsurface impacts should be monitored through an appropriate groundwater monitoring plan. The capacity of the pipeline located west of the proposed E/F Slab, and currently routing water from the A/B East and C/D East Slabs, should be determined to ensure it can route the stormwater volumes expected from the slab. Should it prove insufficient, an additional pipeline will be required to prevent flooding. On-going housekeeping on the slabs should be maintained, this should include regular sweeping of the open areas where traffic occurs in order to minimise off site transportation of material associated with vehicle movement. Sediment accumulation within channels and retention facilities (i.e. sediment traps) needs to be monitored and removed as and when required to ensure the design capacity is maintained. All channels, pipes, grids and manholes should be checked monthly and after any major rainfall events to ensure that there are no blockages and that the water will not be restricted in any way Air Quality During the operational phase the key source of emissions is anticipated to be dust generated from operations undertaken at active stockpiles. Increased cumulative PM 10 has potential to deteriorate local air quality which may result in health concerns for residents and employees, damage to equipment, and a nuisance to local land users and industries. An Air Quality Impact Assessment (AQIA) was conducted as part of this environmental authorisation application (WSP, ).The average PM 10 concentration measured in 2013 at the RBCAA CBD monitoring station was µg/m 3 and has been summed (as a blanket background concentration) with modelled concentrations at each receptor. Period average percentage increase in PM 10 concentrations and their P99 24-hour concentrations have been compared with the relevant NAAQS. It is critical that Transnet adheres to the mitigation measures outlined in their internal Air Quality Management Plan (AQMP) 3, updated on an annual basis, in order to minimise the environmental impact of operations at the terminal. Key mitigation measures stipulated in the AQMP include: 2 WSP Environmental (2015) Air Quality Impact Assessment for the Proposed Storage Area Expansion Slab E & F East: Draft Report, 2015/09/11 3 Dust Monitoring and Mitigation Strategy, Transnet Port Terminals Richards Bay, December Project number: Dated: 2015/09/ Revised: T00:00:00

27 Implementation of the TPT cargo-specific Standard and Safe Operating Procedures, which are designed to ensure that each cargo type is handled so as to minimise dust. The environmental and monitoring requirements of the ISO Environmental Management System must be adhered to. On-going maintenance and operation of dust extraction and control units along conveyor routes. Dust management and control at the bottom discharge and tippler. Operation of dust-free loading chutes during vessel loading. On-going monitoring of PM10 and dust fallout concentrations. Stockpile height must be managed and kept below the partition block height (wind scour zone). Dust suppression sprinkler systems must be installed and operational within and around the storage slab in order to control dust. The frequency of spraying must be determined in consultation with the resident environmental officer on site. Where operation of sprinklers is not feasible or possible, stockpiles should be covered with tarpaulins. General housekeeping to reduce potential dust emissions, such as: Prevent overflowing of waste (cargo) skips and cover with tarpaulins; Ensure maintenance and replacement of covers on conveyors; Regular sweeping of spilled waste cargo on the quayside and on roadways by means of vacuum sweeper trucks; Implement road traffic control to reduce dust entrainment by movement of vehicles; and, On-going deployment of housekeeping teams to clean up and dispose of / return to stockpile any spilled cargo in the appropriate manner to prevent wind entrainment or further disturbance by vehicles. 5 General Health, Safety and Environmental Recommendations 5.1 SITE MANAGEMENT CONSIDERATIONS Environmental Education and Awareness It must be ensured that all site personnel have a basic level of environmental awareness training. This should include: What is meant by environment ; Why the environment needs to be protected and conserved; How construction activities can impact on the environment; What can be done to mitigate against such impacts; Awareness of emergency spill response provisions; Social responsibility during construction (being considerate to residents etc.); 25 30

28 Translators are to be used if necessary, to ensure that all staff understands what is required of them in terms of the EMPr; A copy of the EA must be kept at the site where the activity will be carried on. The EA must be produced to any authorised official of the department who requests to see it and must be made available for inspection by any employee or agent of the holder of the EA who works or undertakes work at the premises; The client must be on hand to explain any technical issues and to answer questions; Use should be made of environmental awareness posters on site; and The need for a clean site policy needs to be explained to everyone working on site Worker Conduct on Site A general regard for the social and ecological well-being of the site and surrounding areas is expected of the site staff. Workers need to be made aware of the following rules: No alcohol / drugs to be allowed on site; No firearms allowed on site or in vehicles transporting staff to / from the site; Prevent excessive noise; Construction staffs are to make use of the facilities provided for them, as opposed to ad hoc alternatives; All staff will wear relevant PPE whilst on site; Trespassing on private / commercial properties adjoining the site is forbidden; and Driving under the influence of alcohol is prohibited Communication with Stakeholders The Resident Engineer (RE) and client are responsible for on-going communication with all stakeholders. A complaints register is to be located at the site office. The client must account for any missing pages. This register is to be tabled during monthly site meetings. Stakeholders need to be made aware of the existence of the complaints register, along with the methods of communication available to them. Queries and complaints are to be handled by: Documenting details of such communications; Submitting these for inclusion into the complaints register; Bringing issues to the immediate attention of the RE; and, Taking remedial action as per the RE and / or the clients instructions. Selected staff are to be made available to consult with stakeholders in order to explain the construction process and to answer any questions. Project number: Dated: 2015/09/ Revised: T00:00:00

29 6 Conclusion and Recommendations In terms of NEMA, everyone is required to take reasonable measures to prevent or mitigate any significant pollution or environmental degradation. Reasonable measures include informing and educating employees about the environmental risks of their work and training them to operate in an environmentally responsible manner. Furthermore, in terms of NEMA, the cost to repair any environmental damage shall be borne by the person responsible for the damage. If the above-mentioned management recommendations are adopted it is anticipated that any negative environmental impacts will be capable of being prevented or adequately mitigated. An appointed ECO will need to monitor the site throughout construction to ensure that the required environmental controls are in place and working effectively

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