Lead and Solder Sales cc Section 22A Environmental Impact Report October 2018

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1 EXECUTIVE SUMMARY 1. INTRODUCTION Lead and Solder Sales cc (LASS), situated within Saxon Industrial Park in Bellville South, City of Cape Town (CoCT) (see Figure 1 below), produces a range of products, including lead billets, solder bars, sash weights for windows, pewter bars for the jewellery industry, and lead wheel balancing weights. The operation entails the melting of various raw materials in paraffin-fired or electrically-heated melting pots, and the casting of the melted alloy into product moulds. Figure 1: Locality map (Google Earth image) showing the location of the Lead and Solder Sales plant in relation to the surrounding area. The operation, which commenced in 1992, was authorised by means of a Registration Certificate for lead processing in terms of the repealed Air Pollution and Prevention Act (Act No. 45 of 1965) (APPA) (Registration Certificate Number 1830 dated 27 November 1992). for the conversion of the Registration Certificate to an Atmospheric Emissions Licence (AEL) in terms of the National Environmental Management: Air Quality Act (Act No. 39 of 2004), as amended (NEMAQA), was not made by 31 March In July 2016, LASS received a directive from the CoCT Air Quality Management Unit regarding the unlawful conduct of a listed activity in terms of NEMAQA and the requirement to undertake a rectification process in terms of Section 22A of NEMAQA in order to apply for an AEL. SLR Consulting (South Africa) (Pty) Ltd (SLR) has been appointed as the independent environmental assessment practitioner responsible for undertaking the required environmental authorisation process. This Executive Summary provides a synopsis of the Section 22A Environmental Impact Assessment Report (EIR) which has been compiled in support of LASS s application for an AEL in terms of Section iii

2 22A of NEMAQA. In particular, the EIR has been compiled in accordance with the specific content requirements of Section 22A(f) of NEMAQA. The Section 22A EIR, including the AEL, has been distributed for a 30-day public review and comment period from 4 October 2018 to 5 November Copies of the report have been made available at the Bellville South Public Library, SLR offices (Cape Town) and on the SLR website ( After the conclusion of the comment period, all comments received in response to the EIR will be collated and responded to in a Comments and Responses Report, which will be appended to the Final EIR. The comments will be duly taken into account in the process of updating the EIR. Once the CoCT Air Quality Management Unit has reached a decision, all registered I&APs will be notified of the outcome of the application. A statutory Appeal Period in terms of the National Appeal Regulations, 2014 will follow the issuing of the decision. 2. APPROACH AND METHODOLOGY NEMAQA regulates all aspects of air quality, including the prevention of pollution and environmental degradation; providing for national norms and standards regulating air quality monitoring, management and control; and licensing of activities that result in atmospheric emissions and have or may have a significant detrimental effect on the environment. In terms of Section 22 of NEMAQA, no person may conduct a listed activity (as per GN No. 893, 22 November 2013) without an AEL. Sections 21 and 22 of NEMAQA came into force on 1 April 2010 with the publishing of the Minimum Emissions Standards (MESs). In terms of MESs, read together with Sections 21 and 22 of NEMAQA, LASS operates the following listed activities: Category 4: Metallurgical Industry Subcategory 4.2 combustion installations; Subcategory 4.13 lead smelting; and Subcategory 4.15 the processing of arsenic, antimony, beryllium, chromium and silicon (antimony only for this ). On 22 November 2013 the 2010 list of MESs was updated. MESs in terms of Section 21 of the Act, for listed activities 4.2, 4.13 and 4.15 are provided in Tables 1 to 3 below. Both existing and new plant MESs are relevant as compliance with existing plant MESs was required from 1 April 2015 for existing facilities and existing facilities will have to comply with new plant MESs by 1 April 2020, unless otherwise specified. Table 1: MES for subcategory 4.2: Combustion installations Combustion installations not primarily used for steam raising and electricity generation (except drying). All combustion installations (except test or experimental). conditions of 273 Kelvin (K) and kpa Particulate matter Not applicable New 50 Existing 100 Sulphur dioxide SO 2 New 500 Existing 500 Oxides of nitrogen NOx expressed as NO 2 New 500 Existing The following special arrangement applies to subcategory 4.2: i. Reference oxygen content appropriate to fuel type must be used iv

3 Table 2: MES for subcategory 4.13: Lead smelting The extraction, processing and use of lead in production by the application of heat. The production of lead-containing electric batteries. All installations using more than 20 kg of lead per month; and All installations producing lead-containing electric batteries. conditions of 273 K and kpa Particulate matter Not applicable New 30 Existing 30 Lead Pb (as fraction of Total Suspended Particles) New 2 Existing 2 Table 3: MES for subcategory 4.15: Processing of arsenic, antimony, beryllium, chromium, and silicon The metallurgical production and processing of arsenic, antimony, beryllium, chromium, and silicon and their compounds by the application of heat. All installations. conditions of 273 K and kpa Particulate matter Not applicable (N/A) New 20 Existing 30 In terms of the provisions of the MESs, LASS had to apply for the conversion of the APPA registration certificate to an AEL in terms of NEMAQA by 31 March LASS missed this deadline and thus the APPA registration certificate lapsed. LASS is now applying for an AEL in terms of Section 22A of NEMAQA, which is a provision of the Act applicable to the conducting, without a licence, of an activity resulting in atmospheric emissions. The Section 22A EIA study process undertaken in support of the AEL comprises the following main tasks: Undertaking an air quality specialist study and compiling an Atmospheric Impact Report (AIR); Compiling the AEL Form; Compiling the EIR; Undertaking a public participation process; and Compiling and submitting the Final EIR and AEL. 3. DESCRIPTION OF THE ACTIVITY As mentioned above, LASS produces a range of products, including lead billets, solder bars, sash weights for windows, pewter bars for the jewellery industry and lead wheel balancing weights. These procedures are described in more detail below. Lead billets for wire and shot: Lead wire and shot are produced by melting lead and antimony ingots in two six (6) tonne capacity melting pots (Subcategory 4.13 and 4.15 listed activities), which are heated by paraffin burners (Subcategory 4.2 listed activity). The molten alloy is manually cast into moulds and cooled using a soluble oil and water mixture. Cooled bars from the moulds are sent to the extruder or tumbler to manufacture lead wire and shot. The final products resulting from this process include spooled lead wire and lead shot packed in boxes. The product can also be sold as lead billets if requested by the client. An extraction hood covers each melting pot in order to evacuate fumes generated by the melting process from the factory. Fumes are released to atmosphere through vents in the factory roof. Solder, pewter and sash weights: Solder bars and sticks are produced by melting lead, antimony and tin in melting pots (Subcategory 4.13 and 4.15 listed activities), which are heated by paraffin burners (Subcategory 4.2 listed activity). The molten alloy is manually cast into trays and the solder bars cooled with a soluble oil and water mixture. Solder bars are either sold as is, or extruded to form solder sticks v

4 and wire. Pewter is produced by melting tin and copper. The molten alloy is cast and cooled to form pewter bars for the jewellery industry by a similar process as described for solder bars. Lead sash weights are manufactured by melting lead, casting it into moulds and cooling it using the soluble oil and water mixture. An extraction hood covers each melting pot in order to evacuate fumes generated by the melting process from the factory. Fumes are released to atmosphere through a vent in the factory roof. Wheel balancing weights: Lead billets are melted in seven electric melting pots and automated casting machines in order to manufacture different sized wheel balancing weights. A fume extraction hood is positioned above each machine. Fumes from four of the machines are extracted to a common duct and vented through the wall of the factory near roof level, while a further three machines each have a dedicated duct and vent. Metal recovery: LASS also operates a scrap metal separation and reclamation process on their premises. Wastes such as old municipal street lamps are disassembled to extract copper and other metals that are bagged and sent to a factory in Gauteng for recycling. Only mechanical separation methods are used. Emissions from this process are limited to dust and exhaust emissions from the three forklifts used to move materials. These emissions are considered negligible. 4. RECEIVING ENVIRONMENT The LASS plant is located at Unit 6A within the Saxon Industrial Park in Mimosa, a general industrial area of Bellville South, an established suburb comprising middle to lower middle class residential areas in close proximity to light and medium industrial areas. The closest residential suburbs, within 1 km of the facility, are Bellville Lot 6 (Horstmandale), approximately 170 m to the west; Bellville Lot 3 (Octovale), approximately 560 m to the south-west; Belrail, approximately 550 m to the north-west; and Bellville South Ext. 13, approximately 600 m to the south-east. A number of schools, a tertiary education facility and medical facilities are located within 5 km of LASS. The closest school and hospital are the Bellville South Secondary School (1 km to the south-west) and Bellville Medical Centre (1.5 km to the north-west). The site is located within a paved/surfaced industrial park comprising various built units. The natural vegetation on the site was completely transformed when the industrial park was developed. No watercourses exist on the property where the site is located. The site is thus not included in the City of Cape Town s Biodiversity Network as an area that needs to be conserved. The site is located within the Cape Mediterranean climate region. According to the South African weather service, the area receives an average of approximately 700 millimetres (mm) of rain per year. The lowest average rainfall month is November (approximately 14 mm per month) whilst the highest average rainfall month is June (approximately 93 mm per month). In terms of temperature, the average midday temperature for the area ranges from 17.5 C in July to 26.5 C in February. Available ambient monitoring data for the area was sourced with respect to the relevant regulated pollutants, namely emissions of lead (Pb), particulate matter (PM), sulphur dioxide (SO 2 ) and oxides of nitrogen (NO x ). The CoCT owns and operates several ambient air quality stations. The closest stations to the site include Bellville South (approximately 500 m south of LASS) and Goodwood (approximately 5.5 km west of LASS). Data availability was generally found to be poor. No data on ambient lead concentration or nitrogen could be obtained, while data for PM and SO 2 was available for a few months in Records for 2015 show 24-hour average PM 10 concentrations between 5 and 65 µg/m 3 within the area, with slightly higher concentrations at Goodwood, and an average estimated at approximately 30 µg/m 3. One-hour average and 24-hour average SO 2 concentrations within the area during the 2015 period were low at an average concentration of approximately 5 to 10 ppb. SO 2 concentrations were slightly higher at Bellville South than Goodwood. vi

5 5. IMPACT DESCRIPTION AND ASSESSMENT The impact of any activity on the receiving environment depends on the nature of the activity, on the one hand, and the nature of the receiving environment, on the other. The production processes which LASS undertakes are associated with emissions Pb, PM, SO 2 and NO x. The emission sources of these regulated pollutants are as follows: PM, SO 2 and NO x from the combustion of paraffin by burners situated below melting pots to provide the heat needed for the melting process; PM and Pb emissions from the surface of all melting pots, including the wheel balancing weight machines, as a result of volatilization; and Fugitive PM and Pb emissions from the manual casting of products. These emissions could impact adversely on ambient air quality, which could, in turn, present negative impact on human health and on the surrounding environment, namely on the physical and socioeconomic environment. Given the fact that the surrounding physical environment has been largely transformed and that no natural vegetation or watercourses exist on the site or in the surrounding environment, the focus of the impact assessment was on human health. The potential impact of the activity on human health has been assessed to be of LOW significance, while the potential impact on other environmental aspects are considered to be immaterial due to the transformed status of the surrounding environment. 6. CONCLUSIONS AND RECOMMENDATIONS The AIR, which guided the impact assessment process, concluded that, if 2015 data from the CoCT Bellville South and Goodwood ambient air quality monitoring stations can be assumed to be representative of current PM 10 and SO 2 levels in the area, LASS s contribution to cumulative pollutant concentrations is, at less than 1%, immaterial at the most affected residential receptor. In the absence of Pb and NO 2 ambient air quality data it is not possible to comment on cumulative impacts of these pollutants. Appropriate air quality management measures and monitoring requirements have been recommended to ensure compliance with relevant legislative requirements. These measures are fully described in an Environmental Management Programme (EMP) compiled for the activity and appended to the Section 22A EIR. The key recommendation is thus compliance with the provisions of the EMP. The key items addressed in the EMP include the following: Management measures and monitoring requirements, namely o Engineering methods; o Compliance timeframes; o Compliance monitoring; o Emissions reporting requirements; o National Atmospheric Emissions Inventory System (NAEIS) reporting; and o Personal exposure monitoring; Implementation of the EMP, which provides details regarding the roles and responsibilities of role players and the administration of the EMP. vii