ENVIRONMENTAL MANAGEMENT PLAN. Developed for National Asphalt (Pty) Ltd. Generic Requirements

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ENVIRONMENTAL MANAGEMENT PLAN Developed for National Asphalt (Pty) Ltd Generic Requirements November 2013

GENERIC ENVIRONMENTAL MANAGEMENT PLAN NATIONAL ASPHALT (Pty) Ltd PO Box 1657 Hillcrest 3650 Tel: +27(0) 12 562 9534 Fax: +27(0) 86 588 4526 E-mail: johannp@nationalasphalt.co.za ENVIRONMENTAL CONSULTANT ENVIRO-NAMIC cc PO Box 2644 Montana Park 0159 Tel: +27(0)82 781 9454 Fax: +27(0)86 52 51 007 E-Mail: info@environamic.co.za Page 2 of 19

Document Status Title GENERIC ENVIRONMENTAL MANAGEMENT PLAN Author Etienne van der Lith Status 1 First Draft Document Date 30 November 2013 Reason for Circulation For information purposes Draft document. Circulation List National Asphalt (Pty) Ltd. Additional Parties as required By National Asphalt (Pty) Ltd. Nature of Comments Required This is a living document. Any changes, alterations or additional information should be included in the updated document. Date of Receipt of Comments Continual process

GENERIC ENVIRONMENTAL MANAGEMENT PLAN CONTENTS INTRODUCTION... 5 1.1 Introduction... 5 1.2 Objective of the Environmental Management Plan... 5 1.3 Environmental Policy... 6 1.4 Method Statement... 7 ENVIRONMENTAL MANAGEMENT PLAN... 7 2.1 Soil Management including Borrow Pits, Quarries and Spoil areas.... 7 2.2 Waste Management and Control... 8 2.3 Noise Management... 10 2.4 Air Quality Management... 11 2.5 Water Management... 13 2.5.1 Surface Water... 13 2.5.2 Ground Water... 14 2.6 Emergency Management... 14 2.7 Social aspects safety of the public... 15 2.8 Stockpiles... 16 2.9 Rehabilitation after Closure... 16 2.10 Environmental Monitoring and Auditing... 17 ***

INTRODUCTION Environmental Management Plan 1.1 Introduction The South African National Roads Agency (Pty) Ltd (SANRAL) has been created by the National Department of Transport and is responsible for the maintenance, repair and upgrading of the National Roads in South Africa. Various provincial roads have been in poor condition for many years and budgets in recent years did not allow for the required funding to repair and rehabilitate this important road. These roads have now been transferred to SANRAL to ensure that the required maintenance, upgrading and repairs are undertaken as required. The poor condition has been a continuous risk for the average motorist and the repair and rehabilitation of this road has become an urgently required needs. Monies have now been allocated to repair and rehabilitate these roads. A tendering process was followed and National Asphalt (Pty) Ltd has been appointed to manufacture and apply the Asphalt required to complete the repair and rehabilitation process on some of these road. Asphalt has been chosen since it is the most durable road construction material and produces an end product of the highest quality. A Temporary Mobile Asphalt Plant will be used for the manufacturing of the required Asphalt. This plant is equipped with a modern wet scrubber to remove emissions and dust from the stack, preventing pollution. This document has been developed as a generic Environmental Management Plan for this Asphalt Plants under National Asphalt s control. This document should be viewed as a generic document subject to continual improvement. National Asphalt is committed to implement this Environmental Management Plan on all sites where the Asphalt Plant is operated. 1.2 Objective of the Environmental Management Plan The objective of this is to address environmental issues on site and during normal operation and maintenance activities

for all of National Asphalt (Pty) Ltd s activities and operating divisions. The plan will therefore have as a main objective the reduction or mitigation of environmental consequences resulting from the operations and actions of National Asphalt (Pty) Ltd. Due to the different site locations where National Asphalt (Pty) Ltd operates and the fact that the mobile Asphalt Plant often changes its location, the Environmental Management Plan has been developed as a generic document to try and include all environmental aspects that should be considered during any operation or project. The generic nature of this Environmental Management Plan should be noted for sitespecific aspects, specifically sensitive environmental issues, which need to be identified before work commence and should be addressed in the specific Environmental Management Plan for that site to ensure adequate mitigation. This forms part of the Environmental Management System of National Asphalt (Pty) Ltd. This document will form the basis of Environmental Management for National Asphalt (Pty) Ltd. 1.3 Environmental Policy The Environmental Policy of National Asphalt (Pty) Ltd reads as follow: National Asphalt s personnel are committed to environmental management principles and to conduct all operations in such a way as to minimize the impact upon the natural environment, to ensure the compliance with all applicable laws and to aim for continuous improvements. This will be achieved through the understanding by all personnel of National Asphalt s Environmental Management System and their role in it, coupled with effective monitoring and control systems. The Environmental Management System will be audited on a regular basis to assess compliance. The target will be reviewed and updated where necessary in order to comply with the requirements of the International Standard SABS ISO 14001: 1996

1.4 Method Statement Environmental Management Plan As a result of the investigation on expected environmental issues, the following aspects need to be focused upon and actions be taken in the EMP. Soil Management including possible borrow pits, quarries and spoil areas. Waste Management and Control. Noise Management. Air Quality Management. Water Management. Emergency Management. Social aspects safety of the public. Stockpiles. Rehabilitation after closure. Environmental Monitoring and Auditing. The appointed person must ensure and monitor the implementation of these management steps. On an overall framework, the effectiveness of all environmental management measures will have to be monitored and audited on a regular basis. ENVIRONMENTAL MANAGEMENT PLAN The environmental management measures described in this Generic Environmental Management Plan are applicable to each site of National Asphalt (Pty) Ltd. The following actions need to be implemented in order to reduce or mitigate the anticipated impact on environmental conditions resulting from activities undertaken by the National Asphalt (Pty) Ltd. 2.1 Soil Management including Borrow Pits, Quarries and Spoil areas. During the utilisation of an Asphalt Plant it might be required to open and operate a borrow pit, quarry or spoil site. In terms of the Mineral Act (Act 50 of 1991) all borrow pits and quarries must have a valid mining permit and an approved rehabilitation plan. The local mining authorities must issue the mining permit. Blasting at borrow pits and quarries are also governed

in terms of the Mineral Act. A blasting permits needs to be obtained from the Chief Mining Inspector appointed by the Department of Mineral and Energy Affairs.. After the utilisation of any borrow pits or quarries a closure certificate must be obtained through the local mining authorities. Rehabilitation of the borrow pit must be done in accordance with the approved rehabilitation plan. It should be noted that a rehabilitation guarantee is required from the Department of Mineral and Energy Affairs if a new borrow pit and or quarry is exploited for the first time. This money should be deposited with the Department and will be refunded back to the contractor after completion of the ecological rehabilitation of the disturbed areas and a closure permit is issued. If material is purchased form a private individual or commercial quarry, National Asphalt (Pty) Ltd must ensure that the required mining permits are in the possession of the owner of the material. Areas where erosion occurs at any Asphalt Plant facility or storage area should immediately be addressed. Erosion could lead to soil stability problems and excessive siltation. Appropriate mitigation measures must be implemented to ensure that minimal erosion takes place. Spoil areas must be approved before any spoiling of material takes place. Written approval must be obtained from the landowner before spoiling starts. After completion of the spoiling activities the landowner must sign off the areas indicating his approval of the final trimming and rehabilitation. 2.2 Waste Management and Control The management and proper handling of solid and liquid waste is essential. This aspect needs proper control and monitoring during the full duration of the existence of the Asphalt site. Waste is not allowed to burn on site. Asphalt Plants are associated with bitumen, fuel oil and diesel. It is important to control any waste products that might be generated during normal operating activities.

The following steps should be implemented: Solids - Accessible waste disposal bins must be distributed over the site and it is suggested that 10 large waste bins be put out on various places within each site. - A skip or similar should be placed centrally in every Asphalt site. All waste disposal bins should be emptied in this skip and the skip should be emptied at least on a weekly basis. - A maintenance contract must be signed with an approved contractor and the waste must be disposed of at an approved waste site. Site personnel could consider moving the waste to the local municipal refuse site themselves if they have the means to do this. - General hygiene conditions should be kept at the waste bins and skips throughout the period of occupation. It is recommended that the areas be disinfected on a regular basis by using JIK or granular chlorine. Liquid Liquid waste, other than sewage waste, must be collected in closed containers. Waste to be collected includes: Mechanical oil, Hydraulic fluid, Grease Used cooking oil, Paint and resins. Used oil must be recycled through a recognized recycler. Construction Construction waste (wood, steel and concrete) should be collected and placed in specially designated areas on the site for removal by the contractor to the disposal

site. If possible, construction waste should be made available to local people for usage. 2.3 Noise Management Standards and guidelines for the control of noise, vibration and shock which are of relevance to National Asphalt (Pty) Ltd are primarily controlled under the following legislation: - the Occupational Health and Safety Act (No 85 of 1993) in terms of the workplace in industry; - the Minerals Act (No 50 of 1991) and the Mine Health and Safety Act (No 29 of 1996) in terms of the workplace at borrow pits; quarries and spoil areas and - the Environment Conservation Act (No 73 of 1989) - outside the work environment. Work activities should be planned not to generate more noise than the 65dB level stipulated. Noise levels above 65dB would require mitigation measures. This is especially important if an Asphalt Plant is erected and operated within or close to a residential area or other sensitive cultural or public places. If an Asphalt Plant is erected and operated in rural areas a relaxation on the above could be applied for. Having due regard for the proximity of the operational facility or site to local communities and dwellings, National Asphalt (Pty) Ltd shall restrict all of its operation and maintenance operations which result in undue noise disturbance to the hours of 06:00 to 18:00. Any work outside of these hours should be agreed in writing with the affected parties. Personnel shall equip noisy machinery with standard silencers and take care not to increase ambient noise levels unreasonably bearing in mind the construction action and the machinery required. Personnel working in conditions with high noise levels shall be equipped with the required safety equipment to reduce the exposure of the individual to the noise. Regular monitoring of workers conditions should be undertaken.

Specific attention should be given to the impact of generated noise on churches, schools, institutions and noise sensitive businesses. Records of all noise level measurements shall be kept for the duration of any contract or operation. 2.4 Air Quality Management In terms of the Atmospheric Pollution Prevention Act (No 45 of 1965) the McAdams Process (Manufacturing of Asphalt) should receive a permit before it is allowed to proceed. The following sources of air pollution should be managed: - An Asphalt Plant is scheduled process and specific care should be taken to prevent the formation of noxious gasses. The correct fuel oil should be used at all times and the temperature of the burners should be adjusted to ensure optimum combustibility. No waste oils should be used as fuel since this can cause excessive air pollution and could cause blockages in the burners. - When the Asphalt Plant is started up the burners should be set to burn at higher temperatures to prevent the normal startup smoke usually associated with older Asphalt Plants. - The correct grade of bitumen should also be used to ensure optimum product utilization and to prevent the formation of unwanted odour and gasses. - Dust is another major air pollution contributor with regard to Asphalt Plants. The Asphalt Plant utilized should have a bag house capable of handling the volume of dust generated during the manufacturing process. The bag filters should be cleaned on a regular basis and during each cleaning it should be thoroughly inspected. Holes or any other damage in the bag filters should immediately be reported and repaired. - Covered dust collection pits should be constructed to prevent dust from being blown away after being removed from the bag house. The collected dust should be regularly removed from site and the possibility of re-use of the dust as a pigment could be investigated.

- The dust collected poses a health risk to workers working in the immediate area of the storage area in terms of the small particle size. Workers working with and in the immediate vicinity of the collected dust should be equipped with the necessary protective clothing. - Open fires for domestic purposes should be strictly controlled. Occasional fire for domestic cooking or heating purposes should be in contained areas, which are specially designed and built for this purpose. The provision of electricity, gas or smokeless fuels must also be considered for cooking/heating purposes. - The correct maintenance of especially heavy vehicles to reduce emissions from exhausts systems. - Regular control of dust along the access road and on the entrance roads by means of wetting when dust becomes liberated by pedestrian or vehicle traffic. Odours and offensive emissions should also be limited as not to result in nuisance. A suitable watering management programme (using water tankers or irrigation equipment and sprayers) to suppress fugitive dust emissions should be devised to achieve a dust suppression efficiency of approximately 75%. Dust is mainly generated from material stockpiles, unpaved access roads and loading operations. This may need to be increased on windy days. If required dust measurements can be conducted according to the following formula: M Fallout = A x d where, M = mass of dust sample A = area of opening of dust collector d = number of days over which sample was collected. Fallout shall not exceed 0.50 g/m 2 per day. If alternative volumetric measurements are undertaken, the DEAT guideline of 180 µg/m 3 can be used.

Dust levels should preferable be taken at potential problem areas, for example nearby residential areas, sensitive crop areas adjacent to the working site, access roads, etc. The Environmental Authorities might require high volume iso-kinetic gas measurements. These measurements would have to be conducted by a specialist operating in this field of expertise. Records of all dust level and gas measurements shall be kept for the duration of any contract or life of an Asphalt Plant. 2.5 Water Management 2.5.1 Surface Water Surface water should not be present at any of the fixed or the mobile Asphalt Plant. The quality of surface run-off water is governed in term so of the Water Act and minimum quality requirements are applicable. It is important to obtain permits for the discharge of industrial water effluent from an Asphalt Plant. Unpaved surface areas must be covered with a 100mm layer of gravel material where necessary. This will ensure that water from the surroundings will not flow through the Asphalt Plant sites, causing erosion and siltation. Proper surface drainage on the site should prevent the formation of stagnant water pools long after rain events. Holes and areas where water collect should be paved or filled with soil or gravel to prevent stagnant water. Because of the possibility of disease, standing water must be eliminated as far as possible. The entrance of Asphalt Plant sites must be closely monitored since it would encounter high traffic by loaded trucks. The monitoring should continue on the entire road up to the surfaced road. Waste asphalt could be spread over the hardwearing areas to prevent dust and mud formation.

Surface water Maintenance and wash-bays If a workshop or washing bay is constructed at the Asphalt Plant the effluent must pass though an oil trap before being released into the natural environment. 2.5.2 Ground Water Sanitation is important at all Asphalt Plant sites. Sanitation systems should be linked to the municipal sewer system if possible. If no municipal sewer system is available a septic tank should be installed. The septic tank should be placed in an area where the soils are permeable and allows for sufficient soak away of water. A soak away test should be performed before construction starts. If a septic tank is installed the volume of generated wastewater should be kept as low as possible. To obtain this it is recommended that wastewater from offices and kitchens are to be contained in a separate, isolated system. No contaminated water shall be released on site. This water may be pumped from the containing system and disposed off in an approved manner. Chemical toilets seem to be the most cost effective way to provide sanitation facilities at a mobile Asphalt Plant. Chemical toilets must be regularly maintained and a service contract must be signed with an approved service agent. Boreholes need to be identified before any activities are started and the method statement on sealing of boreholes should be followed if the possibility of pollution exists. 2.6 Emergency Management National Asphalt (Pty) Ltd shall comply with the requirements of the Environmental Conservation Act (Act 73 of 1989) with regard to environmental emergencies or incidents. All accidents that result in a chemical or hazardous substance spill, these are typical incidents of 50 litres and higher, must be reported to the local Environmental Authority within 24 hours after the incident.

In the case of a bitumen/fuel oil spillage or tank failure the following steps should be followed: The heating source of the bitumen should immediately be terminated, The spill should immediately be contained to prevent excessive spreading of the bitumen, The incident site should immediately be cordoned off to prevent access and possible spread of the spilled material, Any recoverable material should immediately be removed and placed in separate containers, The spilled bitumen should be picked up and removed from the road reserve, All smaller pieces of bitumen should be picked up by hand, If required the rehabilitated area should be seeded with an appropriate indigenous seed mixture to facilitate the growth of vegetation cover in this area, The disposal of the spilled bitumen should be done according to the requirements of the local authorities. Any chemical or hazardous substance spill should be treated with the highest urgency and importance. A qualified contractor should be contacted to assist if National Asphalt (Pty) Ltd s emergency and maintenance teams cannot cope with cleanup of the area. In all cases the following criteria should be followed: Containment of substance, Prevention of contamination by substance, Recovery of substance, Recycling of substance, Removal of substance, Rehabilitation of area. 2.7 Social aspects safety of the public During any project the public should be closely managed. Social issues have become entrenched in everyday environmental management and should treated with the respect it requires. Public safety is of vital importance and every effort should be made to ensure public safety.

2.8 Stockpiles Should stockpiling become necessary during any operation the areas for the stockpiling of material shall be indicated and demarcated on a site plan. The areas chosen for stockpiling shall have no indigenous trees and shrubs present that may be damaged during operations. In determining the location of these temporary stockpile areas, cognisance must be taken of sensitive and no-go areas, and should be located within the construction site, where feasible. Care shall be taken to preserve all vegetation in the immediate area of these temporary stockpiles. During the life of these temporary stockpiles, National Asphalt (Pty) Ltd shall at all times ensure that they are: Positioned and sloped to create the least visual impact. Constructed and maintained so as to avoid erosion of the material and contamination of the surrounding environment. Kept free from all alien/undesirable vegetation. Ensure that no excessive dust is generated from these stockpiles. After the stockpiled material has been removed, the site shall be re-instated to its original condition. No foreign material generated/deposited during construction shall remain on-site. Areas affected by stockpiling shall be landscaped, top soiled, grassed and maintained. Stockpiling of potential hazardous material like milled bitumen material or industrial waste is subject to obtaining the required permits from the relevant authorities. 2.9 Rehabilitation after Closure After the completion of work for mobile asphalt plant the site must be relocated to the following project or contract. All site facilities that were utilised during operation of the mobile Asphalt Plant needs to be removed and the site needs to be rehabilitated. Where rehabilitation is required, the following steps are essential: - Hard and compacted surfaces including walk and driveways should be ripped properly, preferably after some rain and re-vegetated with indigenous grass species.

- Weed control should form part of the exercise. - All structures and concrete slabs, which will not be used in future, should be removed and disposed of at the local waste site. Whenever such concrete can be crushed and re-used, it should be encouraged and practiced as far as possible. - Seeding of natural grass species according to an appropriately harvested seed mixture for the area. Grass mixture suitable for these rather hot and dry conditions should be harvested from the local grassland areas for rehabilitation purposes. The site must be thoroughly cleaned up from pollutants and debris prior to decommissioning, and monitored for recovery for at least 12 months (1 rainy season) thereafter. If the landowner requests that facilities are not removed and the area not rehabilitated, this must be done in writing on the standard Land Return Form, available to site. 2.10 Environmental Monitoring and Auditing Proper monitoring on a firmly based program ensures the correct and successful implementation of environmental management measures, to reduce negative impact on environmental conditions. Monitoring on site should be on a regular basis and be included as a responsibility of the Site Manager or designated person. Monitoring should be focused on on-site conditions during the day-to-day activities and specifically when sub-contractors enter an area for scheduled work or emergency repairs. An annual environmental monitoring and auditing program will be followed The following Environmental Monitoring Program should be implemented:

ISSUE Environmental Management Plan FREQUENCIES OF MONITORING RESPONSIBLE. BODY/PERSON WATER Storm water Management. Weekly in rainy season Site Manager Prevention of stagnant water on site. Weekly in rainy season Site Manager Proper functioning of sanitation systems. Weekly Site Manager SOIL Surface or gully erosion on site. Weekly in rainy season Site Manager Soil contamination with oils. If small, clean up. If large, appoint a suitable contractor for clean up. Monthly Site Manager Condition of paving in walk or drive areas. Monthly Site Manager AIR Emissions Control Daily inspection Site Manager Control of domestic fires. Weekly Site Manager Heavy vehicle emission control. Monthly Site Manager Dust control wetting when required. Daily inspection Site Manager WASTE Efficiency of domestic waste collection i.e. number of collection bins and placement and removal by the municipality or contractor. Two weekly Site Manager Prevention of burning of solid/liquid wastes on site. Weekly Site Manager Proper collection, containment and removal of liquid wastes (petroleum, oils, paints, resins & cooking oils) and hazardous Monthly Site Manager wastes The recycling and/or disposal thereof. Two weekly Site Manager The collection and disposal of construction waste (concrete, wood, steel, industrial waste). WILDLIFE Weed control. Monthly Site Manager Control of illegal hunting or snaring of game, birds or other wild animals. Monthly Site Manager Monitoring of vegetation establishment. Monthly Site Manager SOCIAL Inspect overall appearances of site. (Paint work, cleanliness & housekeeping) Weekly Site Manager SAFETY Inspect road, safety and warning At least once a week Site Manager AUDITING Environmental Monitoring Program. Annually Site Manager Environmental Management Program. Quarterly Head office

Note: The Site Manager should manage the implementation and findings of the Environmental Monitoring Program. Quarterly all aspects will be audited by the head office for compliance to the Environmental Management Plan for the site. Auditing will serve to assess the following: The implementation of the plan in full; The assessment of the effectiveness of mitigation measures; The implementation of recommended corrective actions; The effectiveness of communication and record keeping. The records of audits must be kept for submission to and for review by National Asphalt (Pty) Ltd s management. ***