ethekwini Environment al Health Department.

Transcription

1 E12.2 Response to Comments received on DRAFT BAR Licensing of existing waste facilities within the South African National Blood Service (SANBS) Pinetown Campus, Pinetown, Durban, KwaZulu-Natal Department of Environmental Affairs (DEA) Reference Number: 12/9/11/L825/4 (Based on comments received on the DRAFT Basic Assessment Report during review period ending 17 September 2012). Issue I&AP Response 1. Issue: Waste management 1.1 No objection provided Waste Management Policy be adopted by the Applicant (SANBS) and its tenant (NBI). Environment al Health Reference is made to the initial comment received from the Environmental Health Department dated 12 March 2012 and meeting notes from the meeting with Phumzile Vezi of the Department on 19 April The Waste Management Policy guidelines provided by the Department and updated as discussed during the meeting on 19 April 2012, are contained in Section 2.2.3: Waste Transfer Facilities of the Environmental Management Programme (EMP). In addition, Section of the EMP has been updated to specify that the hand sanitizer must be anti-microbial. As per Section 1.2 of the EMP, the commitments contained in the EMP, including the above requirements, are binding on all facilities operated by both the Applicant (SANBS) and its tenant (NBI), within the Pinetown Campus. 1.2 Durban Solid Waste issues well Durban Solid covered. 1.3 No secondary pollution to arise from transportation of Health Care Risk Waste / Health Care General Waste streams and / or disposal of sewage and refuse. Waste. Department of Water Affairs (DWA). Secondary pollution from transportation of Health Care Risk Waste / Health Care General Waste streams and / or disposal of sewage and refuse is managed through Tracking and Traceability of Health Care Risk Waste procedures (SOP-HSE-015 Rev0) and Transportation Safety Procedures (CP-TRA-002) as detailed in the EMP contained in Appendix F of the Final BAR documentation. Sewage is disposed of via the municipal sewage system. It is further noted that a Water Audit has been commissioned that will investigate, amongst other factors, the effluent discharge streams and stormwater drainage within the Campus, as well as inspection of operational areas, washbays and waste transfer facilities. Potential pollution pathways will be identified and mitigation measures recommended through this process. 59

2 1.4 Any pollution problems that arise must be immediately addressed by Applicant, and any significant spillages of chemicals / fuels etc. be reported to authorities. Section 2.5 of the EMP details the SANBS Incident Management Procedures, including the implementation of spill control protocol and an incident investigation, as detailed in Appendix G of the EMP. It is recognised that pollution problems must be immediately addressed by the Applicant. In this regard, the requirement for significant spillage events to be reported to DWA and other relevant authorities, as well as the determination of soil / groundwater or other environmental impacts and implementation of remedial actions as necessary, following such a significant spill event, are included in Section 2.5 of the EMP. 2. Issue: Wastewater and stormwater management 2.1 Loading / off-loading areas to be concreted to prevent infiltration (i.e. areas to be impermeable so that runoff is captured). It is noted that a Water Audit has been commissioned that will investigate, amongst other factors, the effluent discharge streams and stormwater drainage within the Campus, as well as inspection of operational areas, washbays and waste transfer facilities. This requirement for the impermeable surfacing of loading / off-loading areas to prevent infiltration and capture run-off is included in Section of the EMP and is thus a binding 2.2 All wastewater / surface runoff / washdown effluent from waste transfer facilities and loading / off-loading areas must be directed for safe collection and disposal. 2.3 Contaminated stormwater may not be channelled directly through stormwater system. 2.4 Effluent from vehicle workshop to be channelled, collected and disposed of as detailed in DRAFT EMP. condition of any authorisations granted by the competent authorities in respect of the Final BAR. It is noted that a Water Audit has been commissioned. A commitment to the safe collection and disposal of wastewater / surface runoff / washdown effluent from waste transfer facilities and loading / off-loading areas is included in Section 2.2 of the EMP and is thus a binding condition of any authorisations granted by the competent authorities in respect of the Final BAR. In line with the EMP commitments contained in Sections and of the EMP, contaminated stormwater will be kept separate from clean storm water run-off. This requirement has been retained in the EMP (Section of the EMP). 60

3 2.5 Wastewater system (water containing waste) to be kept separate from stormwater system. It is noted that a Water Audit has been commissioned. As per Sections 2.2.5, and of the EMP, wastewater will be kept separate from stormwater. 2.6 Stormwater drainage must be managed and controlled to ensure runoff will not result in off-site pollution or damage to downstream properties. 3. Issue: Fill platform management 3.1 Assessment of structural capacity of fill platform (i.e. max. potential weight supported by gabions) to be carried out prior to further depositing of material into fill platform. 3.2 Adequate measures must be implemented to prevent operation and maintenance Fill platform from impacting Umbilo River and associated riparian zone / wetland areas (i.e. erosion and / or pollution impacts for instance). 3.3 Decommissioning Plan for the Fill Platform. Geotechnical Engineering Environment al Planning and Climate Protection As per Sections 2.2.5, and of the EMP, wastewater will be kept separate from stormwater. As per Section A.1. of the Final BAR and Section of the EMP, a geotechnical investigation of structural capacity of the fill platform (i.e. max. potential weight supported by gabions) will be carried out prior to further depositing of material into fill platform. Management measures for the use as well as for the care and maintenance of the fill platform are included in Section of the EMP. At this stage it is not proposed to decommission the fill platform. Nevertheless, care and maintenance measures for the fill platform are included in Section of the EMP. 61

4 4. Issue: Erosion control 4.1 General erosion control on-site. Regular inspection and addressing of general site erosion (particularly in areas sensitive to erosion, such as the fill platform, exposed surfaces, edges of slopes etc.) during both the Operational Phase and potential future Construction / Maintenance activities have been included in the recommendations of the Final BAR and EMP. In particular: Section of the EMP addresses the prevention and management of erosion at the fill platform; and Sections and of EMP, detail measures that will be implemented to prevent and control erosion during earthworks and material stockpiling, respectively. Furthermore, areas disturbed during construction will be stabilised and rehabilitated as detailed in Section of the EMP. These areas will be monitored for erosion and actions will be taken as necessary should erosion be observed. The recommended erosion control measures of sand bags, hessian sheets and retention or replacement of vegetation, for instance, are noted in Section of the EMP. 5. Issue: Protection of natural water features 5.1 Potential negative impacts on the Umbilo River and associated riparian / wetland areas must be monitored and mitigated during Operation Phase of the Pinetown Campus. 6. Issue: Water use registration / authorisation 6.1 Borehole(s) must be registered with Department of Water Affairs. DWA 6.2 Should borehole water be used solely for washdown of waste transfer facilities, water abstraction must be registered for industrial use. 6.3 Fill platform does not require water use authorisation as it is an existing facility. Refer to sections on Waste management, Wastewater and stormwater management, as well as Fill platform management in this RtC Report for specific detail and mitigation measures. A Water Audit has been commissioned and will report on, amongst other details, the volume of water used per annum, co-ordinates of boreholes, as well as what the borehole water is used for. This information will be used in the registration of the boreholes and to consult further with DWA regarding the potential need for water use licensing of the boreholes. As detailed above, the Water Audit will determine the usage of the abstracted water. The requirement for registration as industrial use will be met, if applicable. 62

5 7. Issue: Bulk electricity services infrastructure 7.1 Applicant to consult Mains Records to identify location of underground electrical services. Electricity 7.2 Permission required from Head: Electricity if any overhead line / servitude be affected by the proposed development, or future proposed development. 7.3 Relocation of MV/LV electrical services, if required, will be conducted at Applicant s expense. 8. Issue: Planning 8.1 No objection provided Environmental Health Department requirement are Electricity Electricity Framework Planning Branch. fulfilled. 8.2 No objection Land Use Management Branch 9. Issue: Heritage resource 9.1 If heritage resources are identified during earthmoving activities, or if unidentified graves are revealed during construction activities, work to be immediately halted and findings reported. 9.2 No structures older than 60 years, or parts thereof, are allowed to be demolished, altered or extended without a Heritage KZN (Amafa KZN). Heritage KZN (Amafa KZN). This requirement has been included in Section of the EMP and as such is a binding condition of any authorisations granted on the basis of the Final BAR documentation. This requirement has been included in Section of the EMP and as such is a binding condition of any authorisations granted on the basis of the Final BAR documentation. This requirement has been included in Section of the EMP and as such is a binding condition of any authorisations granted on the basis of the Final BAR documentation. See above response to Environmental Health Department in section 1.1 of this RtC Report. As detailed in Section of the EMP, should heritage resource be discovered during earthworks, work will immediately be halted and the finding will be reported to Heritage KZN. Work will only commence once the situation has been assessed and management measures put in place by a suitably qualified heritage specialist and in consultation with Heritage KZN. This requirement has been included in the specific recommendations of the EMP (Section 5.5.3). 63

6 permit from Amafa KZN. 9.3 No activities allowed within 50m of a site which contains rock art. Heritage KZN (Amafa KZN). 10. Issue: General 10.1 Compliance auditing of conditions of environmental authorisation and EMP DWA to be informed in writing of all future construction / expansion activities proposed for the Pinetown Campus, prior to commencement of such activities Applicant holds ultimate responsibility to identify any sources or potential sources of pollution from the Applicant s undertaking, and to take appropriate measures to prevent pollution of the environment. No rock art sites have been identified at present. Section of the EMP provides detail on internal auditing, inspection and monitoring procedures. Any additional compliance auditing as a condition of environmental authorisations will be upheld as per the requests of the competent authority. This requirement to inform DWA of all future construction / expansion activities proposed for the Pinetown Campus, prior to commencement of such activities, has been included in Section 5.4 of EMP. SANBS currently implements significant environmental management protocols, as well as proposed to implement further environmental controls, as detailed in the EMP. The EMP also makes allowance for performing a NEMA Duty of Care assessment with regard to operational activities as well as potential future maintenance / construction / expansion activities. 64