New Appendix E: Environmental Management Programme (EMPr) … RE050216_163/Appendix E... · 2017....

Appendix E: Environmental Management Programme (EMPr)

Clariter Pilot Scale Waste Plastics Refining Facility

ENVIRONMENTAL MANAGEMENT PROGRAMME

DEDEAT REF: AM/A/5, 6, 12/L24/15

Prepared for:

Prepared by:

Clariter ZA (Pty) Ltd EOH Coastal & Environmental Services 16 Wrench Road

Isando, Gauteng 1609 PO Box 506

Tel: +27 11 977 5003 Fax: +27 11 392 5885

P.O. Box 8145, Nahoon

East London 5210

October 2016

DRAFT Environmental Management Programme – October 2016

TABLE OF CONTENTS LIST OF FIGURES ......................................................................................................................... II 1 INTRODUCTION ..................................................................................................................... 1 1.1 DETAILS OF THE PROJECT TEAM ...................................................................................... 1

1.1.1 The Proponent: .......................................................................................................... 1 1.1.2 The Environmental Assessment Practitioners ............................................................ 1

2 ENVIRONMENTAL MANAGEMENT PROGRAMME: OVERVIEWERROR! BOOKMARK NOT DEFINED. 1.1 FORM AND FUNCTION OF AN EMPR .................................................................................. 3 1.2 SCOPE OF THE EMPR .......................................................................................................... 3

1.2.1. Layout of the EMPR ................................................................................................... 3 1.3 OBJECTIVES OF AN EMPR .................................................................................................. 3 1.4 EMPR REVISIONS AND AUTHORISATION .......................................................................... 4 1.5 LEGAL REQUIREMENTS ...................................................................................................... 5 2 PROPOSED ACTIVITY ........................................................................................................... 6 2.1 DESCRIPTION OF PROPOSED ACTIVITY ............................................................................ 6 3 ROLES AND RESPONSIBILITIES ......................................................................................... 8 3.1 MANAGEMENT STRUCTURE ............................................................................................... 8 3.2 ROLES AND RESPONSIBILITIES ......................................................................................... 8

3.2.1. Operations Manager (OM) ......................................................................................... 8 4 IMPACT MANAGEMENT ACTIONS ..................................................................................... 10 5 ADMINISTRATION ............................................................................................................... 13 5.1 GOOD HOUSEKEEPING ..................................................................................................... 13 5.2 RECORD KEEPING.............................................................................................................. 13 5.3 DOCUMENT CONTROL ....................................................................................................... 13 5.4 EMERGENCY PREPAREDNESS ......................................................................................... 14 6 ENVIRONMENTAL MONITORING ....................................................................................... 15 6.1 GENERAL ENVIRONMENTAL MONITORING ..................................................................... 15 6.2 NON-COMPLIANCE ............................................................................................................. 15 6.3 INCIDENT REPORTING AND REMEDY .............................................................................. 16 6.4 AMENDMENT TO THE EMPR .............................................................................................. 16 7 ENVIRONMENTAL AWARENESS ....................................................................................... 17 8 CONCLUSIONS .................................................................................................................... 18

LIST OF FIGURES Figure 1.1 Locality of Erf 60843 in Zone 1B. 6 Figure 3.1: Final layout 7

1


1 INTRODUCTION Clariter Recycling and Refining Centre Ltd (Clariter) has developed a technology for converting different types of polyolefin plastics into hydrocarbon liquid materials. The Company proposes to establish a pilot-scale Industrial Scale Plant (ISP) in the East London Industrial Development Zone (ELIDZ) as a precursor to the establishment of a Full Scale Plant (FSP) at a location not yet determined. EOH Coastal and Environmental Services (CES) has been appointed by Clariter as the Environmental Assessment Practitioner (EAP) to secure the necessary environmental authorisations.

1.1 Details of the Project Team This section provides details on the planning team that was involved in the development of the EMPr. The team includes the proponent organisation and Environmental Assessment Practitioner (EAP). Details of the contact persons are provided.

1.1.1 The Proponent:

Name: Clariter (Pty) Ltd

Contact Person: Alan da Costa

Postal Address:

Tel:

Fax:

E-mail:

1.1.2 The Environmental Assessment Practitioners

According to Appendix 4 of GN R 982, an environmental management programme must include: (a) details of – (i) the EAP who prepared the EMPr; and (ii) the expertise of that EAP to prepare an EMPr, including a curriculum vitae (abridged CV attached as Appendix D);

Name: EOH Coastal & Environmental Services

Contact Person: Cherie-Lynn Mack

Physical Address: 25 Tecoma Street Berea East London 5210

Postal Address: PO Box 8145 Nahoon 5210

Tel: 043 726 7809

Fax: 043 726 8352

E-mail: [email protected]

EOH Coastal & Environmental Services (CES), established in 1990, is a specialist environmental consulting company based in Grahamstown, with offices in East London, Port Elizabeth, Cape Town, Johannesburg, and Maputo. CES has considerable experience in terrestrial, marine and freshwater ecology, the Social Impact Assessment (SIA) process, and state of environment reporting (SOER), Integrated Waste Management Plans (IWMP), Spatial Development Frameworks (SDF), public participation, as


well as the management and co-ordination of all aspects of the Environmental Impact Assessment (EIA) and Strategic Environmental Assessment (SEA) processes. CES has been active in all of the above fields, and in so doing have made a positive contribution to towards environmental management and sustainable development in the Eastern Cape, South Africa and many other African countries.

CES project team

Project Leader Dr Alan Carter

As Executive of the East London Office, Alan has extensive training and experience in both financial accounting and environmental science disciplines with international accounting firms in South Africa and the USA. He is a member of the American Institute of Certified Public Accountants and holds a PhD in Plant Sciences. He is also a certified ISO14001 EMS auditor with the American National Standards Institute and the British Standards Institute. Alan is also registered with SACNASP and EAPSA.

Project Manager Dr Cherie-Lynn Mack

As a Senior Environmental Consultant, Cherie-Lynn has project managed numerous EIAs for renewable energy facilities (both solar PV and wind energy), and has detailed experience in the sector. Cherie-Lynn holds a PhD in Environmental Biotechnology, and is registered with SACNASP.


2 ENVIRONMENTAL MANAGEMENT PROGRAMME: OVERVIEW

2.1 Form and function of an EMPR An EMPr is focused on sound environmental management practices, which will be undertaken to minimise adverse impacts on the environment through the lifetime of a development. In addition, an EMPr identifies what measures will be in place or will be actioned to manage any incidents and emergencies that may occur during operation of the facility. As such the EMPr provides specifications that must be adhered to, in order to minimise adverse environmental impacts associated with the operations of the facility. The content of the EMPr is consistent with the requirements as set out in Appendix 4 of GN R 982 of the EIA regulations stated below, for the construction and operation phases.

2.2 Scope of the EMPr In order to ensure a holistic approach to the management of environmental impacts during the construction and operation of the proposed wind farm, this EMPr sets out the methods by which proper environmental controls are to be implemented by the Contractor and all other parties involved. The EMPr is a dynamic document subject to influences and changes as a result of variations to the provisions of the project specification.

2.2..1. Layout of the EMPR The EMPR is divided into two phases of development. Each phase has specific issues unique to that period of the planning and design and operation of the Clariter facility. The impacts are identified and given a brief description. The two phases of the development are identified as: Planning and Design Phase and Pre-Construction Phase This section of the EMPr provides guidance in terms of aspects of project design and planning that may impact on the surrounding environment once implemented. Mitigations in this phase attempt to minimise negative impacts and accentuate positive impacts by pre-emptive methods such as identifying no-go areas, etc. Operational Phase This section of the EMPr provides management principles for the operation and maintenance phase of the project. Environmental actions, procedures and responsibilities as required from the operator during the operation phase are specified. THE EMPr DOES NOT COVER THE CONSTRUCTION PHASE, AS THE ELIDZ EA AND ASSOCIATED EMPr IS SUFFICENT TO COVER ANY CONSTRUCTION-RELATED IMPACTS THAT MAY OCCUR DURING THAT PHASE OF THE DEVELOPMENT.

2.3 Objectives of an EMPr It is of the utmost importance that the mitigation measures recommended in the EIA and the conditions included in the Environmental Authorisation are given adequate effect in the construction and operation phase of any project. The EMPr is a key tool used to ensure that these recommendations and conditions are implemented in order to ensure consistent and effective environmental management of the project.


This EMPr aims to:

Ensure compliance with regulatory authority stipulations and guidelines which may be local, provincial, national and/or international;

Ensure that there is sufficient allocation of resources on the project budget so that the scale of EMPr-related activities is consistent with the significance of project impacts;

Verify environmental performance through information on impacts as they occur;

Identify and define the roles, functions and responsibilities of various parties involved in the project to ensure effective environmental management;

Respond to unforeseen events;

Provide feedback for continual improvement in environmental performance;

Identify a range of mitigation measures which could reduce and mitigate the potential impacts to minimal or insignificant levels;

Identify areas where detailed Method Statements and Safe Operating Procedures (SOPs) will be required in order to ensure that the environment is protected from accidental or unintentional impact;

Detail specific actions deemed necessary to assist in mitigating the environmental impact of the project;

Identify measures that could optimize beneficial impacts;

Create management structures that address the concerns and complaints of I&APs with regards to the development;

Establish a method of monitoring and auditing environmental management practices during all phases of the activity;

Ensure that safety recommendations are complied with;

Specify time periods within which the measures contemplated in the final environmental management programme must be implemented, where appropriate;

2.4 EMPr Revisions and Authorisation The objectives and EMPr tables are required to be reviewed and possibly modified whenever changes, such as the following, occur:

Planned activities change (i.e. in terms of the components of the facility).

Modification to or addition to environmental objectives and targets.

Additional or unforeseen environmental impacts are identified.

Relevant legal or other requirements are changed or introduced.

Significant progress has been made on achieving an objective or target such that it should be re-examined to determine if it is still relevant, should be modified, etc.

The Environmental Impact Assessment Regulations (Regulation 36(1) and 36(2) of GN R. 982) as contemplated in the National Environmental Management Act (no 107 of 1998; NEMA) state that: Regulation 36(1): “Where an amendment is required to the impact management actions of an EMPr, such amendments may immediately be effected by the holder and reflected in the next environmental audit report submitted as contemplated in the environmental authorisation and regulation 34.” Regulation 36(2): “Where an amendment to the impact management outcomes or objectives of an EMPr or an amendment of the closure objectives of a closure plan is required before an audit is required in terms of the environmental authorisation, an EMPr or closure plan may be amended on application by the holder of the environmental authorisation.”


2.5 Legal requirements Operation must be according to the best industry practices, as identified in the project documents. This EMPr informs the Operator as to his duties in the fulfilment of the project objectives, with particular reference to the prevention and mitigation of environmental impacts caused by operational activities associated with the project. The Operator should note that obligations imposed by the approved EMPr (including associated management plans) are legally binding in terms of environmental statutory legislation. In the event that any rights and obligations contained in this document contradict those specified in the standard or project specifications then the latter shall prevail. The Operator shall comply with all South African national and provincial environmental legislation, including associated regulations and all local by-laws relevant to the project. Key legislation currently applicable to the design and implementation phases of the project must be complied with. The list of applicable legislation provided below is intended to serve as a guideline only and is not exhaustive:-

The Constitution of the Republic of South Africa Act 108 of 1996

National Environmental Management Act 107 of 1998

Hazardous Substances Act 15 of 1973

Atmospheric Pollution Prevention Act 45 of 1965

National Environmental Management: Air Quality Act 39 of 2004

National Environmental Management: Waste Management Act 59 of 2008

Health Act 63 of 1977

Occupational Health and Safety Act 85 of 1993

All relevant provincial legislation, municipal by-laws and ordinances.


3 PROPOSED ACTIVITY

According to Appendix 4 of GN R 982, an environmental management programme must include: (b) a detailed description of the aspects of the activity that are covered by the environmental management

programme as identified by the project description;

(c) a map at an appropriate scale which superimposes the proposed activity, its associated structures, and

infrastructure on the environmental sensitivities of the preferred site, indicating any areas that should

be avoided, including buffers;

3.1 Description of proposed activity

Clariter has developed a technology for converting different types of polyolefin plastics into hydrocarbon liquid materials. The Company proposes to establish a pilot-scale Industrial Scale Plant (ISP) in the East London Industrial Development Zone (ELIDZ) as a precursor to the establishment of a Full Scale Plant (FSP) at a location not yet determined. The facility is proposed to be constructed on erf number 60843 in ELIDZ Zone 1 B.

Figure 1.1 Locality of Erf 60843 in Zone 1B.

A primarily research and development (R&D) facility, the facility will accept pre-sorted and cleaned mixed plastic waste from specific industries, and refine these to produce up to nine pure hydrocarbon compounds for sale to organic chemicals consumers. The construction and operation of the facility triggers activities listed under the EIA regulations (2014), the Waste Act regulations (2013) and the Air Quality Act (AQA) regulations (2013). As such, an integrated application form for authorisation of both the waste and EIA activities has been submitted to the Department of Economic Development, Environmental Affairs and Tourism. An additional application has been made to the Air Quality Officer at the Buffalo City Municipality for authorisation of the activities listed under the AQA regulations.

60843


Figure 3.1: Final layout

Flare 33° 03’ 22.46”S; 27° 50’03.50”E

Process Plant (enclosed)

End product


4 ROLES AND RESPONSIBILITIES

According to Appendix 4 of GN R 982, an environmental management programme must include:

(i) An indication of the persons who will be responsible for the implementation of the impact management actions;

4.1 Management structure In order to ensure sound development and effective implementation of the EMPr, it is necessary to identify and define the responsibilities and authority of the various persons and organisations that will be involved in the project. The EMPr will be an item of the monthly operations meetings in order to provide input with respect to compliance with the EMPr. Key roles and responsibilities of each party are outlined in more detail in Section 4.2. It is important to note that, while parties are assigned various environmental roles and responsibilities, parties are severally and jointly responsible to ensure compliance with all environmental legislation and best practice.

4.2 Roles and Responsibilities

4.2..1. Operations Manager (OM) The OM assumes overall responsibility for the environmental aspects and management of the facility. This includes compliance to all environmental regulatory and good management practice requirements for the duration of the project, in order to ensure effective minimisation of all environmental impacts. The OM is also responsible for the overall management and implementation, administration and enforcement of the EMPr. The OM responsibilities include:

Ensure that all designs appropriately incorporate the required environmental provisions as discussed in the Environmental Impact Report (EIR) and EMPr.

Ensure that the EMPr is finalised and adequately describes the minimum environmental regulatory requirements at the time operation commences.

Ensure that the final EMPr is approved by all relevant authorities.

Ensure that the EMPr specifications are included in all tender documents issued to prospective engineering consultants/contractors for the development works and activities on site.

Ensure that the EMPr is fully implemented and remains so, and when necessary is revised and updated.

Give instructions regarding the development and implementation of Method Statements.

Be liable / accountable, to the relevant authority, DEA, for any contravention/non-compliance by any person under their supervision.

Liaise with the environmental authorities and Clariter Senior Management as and when necessary.

Undertake periodic audits and inspections to ensure that the environmental requirements are implemented.

Review and comment on environmental compliance assessments and/or reports.

Review the complaints register.

Give instructions on any procedures and corrective actions.

Report any significant environmental incidents or impacts to the relevant environmental authorities.


Deal with policing, fining, penalties and discrepancies.

Issue fines, penalties or ‟work suspend‟ orders for contravention of the EMPr and give instructions regarding corrective action.


5 IMPACT MANAGEMENT ACTIONS

According to Appendix 4 of GN R 982, an environmental management programme must include: (f) a description of proposed management actions, identifying the manner in which the impact

management objectives and outcomes contemplated in paragraphs (d) and € will be achieved, and must, where applicable, include actions to –

(i) avoid, modify, remedy, control or stop any action, activity or process which causes pollution or environmental degradation;

(ii) comply with any prescribed environmental management standards or practices:

(iii) comply with any applicable provisions of the Act regarding closure where applicable; and

(v) comply with any provisions of the Act regarding financial provisions for rehabilitation, where applicable;

(i) an indication of the persons who will be responsible for the implementation of the impact management actions;

(j) the time periods within which the impact management actions contemplated in paragraph (f) must be implemented;

Planning and Design Phase.

Issue Dust Management

Impact Unloading of 500kg bags of pelletized plastic into the automatic feeders may result in the release of dust particles into the atmosphere, creating a potentially hazardous environment for workers, and potential nuisance dust for surrounding land users.

Management Action Locate the feedstock unloading are within an enclosed warehouse, with appropriate dust collection/mitigation.

Issue General Waste Management

Impact At a capacity of 9 tons every three days, there is the potential for disposal of 180 0.5 ton empty feed bags per month. Improper management of this general waste could lead to nuisance pollution of the surrounding areas, or worse.

Management Action Provide suitable enclosed and demarcated storage areas for empty feed bags.

Investigate the potential for re-use of feedbags by the supplier.

If re-use is not possible, potential for recycling the bags in other ways should be investigated.

Issue Recycling of Plastic

Impact Specific plastic types will be diverted from landfill to provide feedstock for the facility. This will impact the landfill positively in that non-biodegradable waste inflow will decrease, and more space will be available for other waste types.

Management Action Identify appropriate suppliers of feedstock and ensure security of supply

Issue Production of valuable products

Impact The beneficiation of plastic waste to produce valuable products will potentially drive a renewed interest in recycling plastic, as waste plastic providers will be paid for their stock, and as the market for the valuable products increase, the need for feedstock will increase. This will have a knock-on effect of decreasing the volumes of specific plastics sent to landfill.

Management Action Investigate the market for valuable products. If possible enter into supply


contracts that will ensure sustainability of the business concept.

Issue Waste Water Quality

Impact The quality of the process wastewater streams is influenced by the efficiency of the plastic beneficiation process. Process failures and emergency conditions may result in decreased wastewater quality. This could result in negative impacts on the ELIDZ sewerage infrastructure, and further, on the BCMM sewerage infrastructure, and at worst, on the marine environment to which the Hood Point Sea outfall discharges.

Management Action Include in the design of the facility, a water sampling port on the water discharge pipeline at a point BEFORE it reaches the ELIDZ sewer.

Include in the design of the facility, a cut-off valve at a point BEFORE the pipeline reaches the EILDZ sewer.

Include in the design of the facility, an emergency waste water retention tank to collect low quality waste water to prevent it from being discharged into the sewers.

Issue Air Quality

Impact Priority pollutants including carbon monoxide, SOx and NOx, HCL, H2S, ammonia and volatile organic compounds (VOCs) will be released as a result of the processing of plastic waste into valuable products. These pollutants have the potential to significantly decrease the quality of the air in the general area.

Management Action Suitable emission control devices such as scrubbers, condensers, quenching columns, etc. must be incorporated into the design of the facility.

Design emission data should be incorporated into a model to predict the potential for release of pollutants and their possible impacts on the environment taking into account the prevailing climatic conditions at the site.

Operation

Issue Dust Management

Impact Unloading of 500kg bags of pelletized plastic into the automatic feeders may result in the release of dust particles into the atmosphere, creating a potentially hazardous environment for workers, and potential nuisance dust for surrounding land users.

Management Action All employees involved in unloading of plastic feedstock must be in possession of appropriate PPE.

Issue General Waste Management

Impact At a capacity of 9 tons every three days, there is the potential for disposal of 180 0.5 ton empty feed bags per month. Improper management of this general waste could lead to nuisance pollution of the surrounding areas, or worse.

Management Action Ensure that empty feedstock bags are securely stored and reused/recycled wherever possible

Issue Waste Water Quality

Impact The quality of the process wastewater streams is influenced by the efficiency of the plastic beneficiation process. Process failures and emergency conditions may result in decreased wastewater quality. This could result in negative impacts on the ELIDZ sewerage infrastructure, and further, on the BCMM sewerage infrastructure, and at worst, on the marine environment to which the Hood Point Sea outfall discharges.

Management Action Monitor and record the quality of the waste water discharging from the facility regularly.

In the event of an emergency or process failure, ensure that the valve is closed


to prevent the discharge of low quality waste water into the ELIDZ sewer system.

Ensure that any water retained in retention tanks is treated to acceptable standards before being released into the sewers.

Issue Air Quality

Impact Priority pollutants including carbon monoxide, SOx and NOx, HCL, H2S, ammonia and volatile organic compounds (VOCs) will be released as a result of the processing of plastic waste into valuable products. These pollutants have the potential to significantly decrease the quality of the air in the general area.

Management Action Installed emission control devices should be regularly inspected and maintained in order to ensure efficient operation.

A stack emissions monitoring regime should be initiated to ensure compliance with the conditions of the AEL, and to ensure that the emission conditions predicted during the planning and design phase by the modelling exercise closely resemble the actual emissions.

Ensure compliance with the conditions of the AEL issued by BCMM.


6 ADMINISTRATION A copy of the EMPr must be kept on site at all times during operations. The EMPr will be binding on Clariter and all sub-contractors operating on the site and must be included within any contracts.

6.1 Good Housekeeping The Operator shall undertake “good housekeeping” practices during operations. This will help avoid disputes on responsibility and allow for the smooth running of the operation as a whole. Good housekeeping extends beyond the wise practice of construction methods that leaves production in a safe state from the ravages of weather to include the care for and preservation of the environment within which the site is situated.

6.2 Record Keeping The PM and the ECO will continuously monitor the Contractor‟s adherence to the approved impact prevention procedures and the RPM shall issue to the Contractor a notice of non-compliance whenever transgressions are observed. The ECO should document the nature and magnitude of the non-compliance in a designated register, the action taken to discontinue the non-compliance, the action taken to mitigate its effects and the results of the actions. The non-compliance shall be documented and reported to the engineer in the monthly report. These reports shall be made available to DEA when requested. The Contractor shall ensure that an electronic filing system identifying all documentation related to the EMPr is established. A list of reports likely to be generated during all phases of the Riverbank Wind Energy Project is provided below, and all applicable documentation must be included in the environmental filing system catalogue or document retrieval index.

Final Environmental Impact Assessment Report.

Environmental Management Programme.

Final design documents and diagrams issued to and by the Contractor.

All communications detailing changes of design/scope that may have environmental implications.

Daily, weekly and monthly site monitoring reports.

Complaints register.

Medical reports.

Training manual.

Training attendance registers.

Incident and accident reports.

Emergency preparedness and response plans.

Copies of all relevant environmental legislation.

Permits and legal documents, including letters authorising specific personnel of their duties as part of emergency preparedness teams e.g. fire teams, etc.

Crisis communication manual.

Disciplinary procedures.

Monthly site meeting minutes during construction.

All relevant permits.

Environmental Authorisation on the EIA from the DEA.

All method statements from the Contractor for all phases of the project.

6.3 Document Control The Operator and OM shall be responsible for establishing a procedure for electronic document control. The document control procedure should comply with the following requirements:


Documents must be identifiable by organisation, division, function, activity and contact person.

Every document should identify the personnel and their positions, who drafted and compiled the document, who reviewed and recommended approval, and who finally approved the document for distribution.

All documents should be dated, provided with a revision number and reference number, filed systematically, and retained for a five year period.

The Operator shall ensure that documents are periodically reviewed and revised, where necessary, and that current versions are available at all locations where operations essential to the functioning of the EMPr are performed. All documents shall be made available to the independent external auditor.

6.4 Emergency Preparedness The Operator shall compile and maintain environmental emergency procedures to ensure that there will be an appropriate response to unexpected or accidental actions or incidents that will cause environmental impacts, throughout the construction period. Such activities may include, inter alia:

Accidental discharges to water and land. Accidental exposure of employees to hazardous substances. Accidental fires. Accidental spillage of hazardous substances. Accidental toxic emissions into the air. Specific environmental and ecosystem effects from accidental releases or incidents.

These plans shall include:

Emergency organisation (manpower) and responsibilities, accountability and liability. A list of key personnel and contact details. Details of emergency services available (e.g. the fire department, spill clean-up services,

etc.). Internal and external communication plans, including prescribed reporting procedures

where required by legislation. Actions to be taken in the event of different types of emergencies. Incident recording, progress reporting and remediation measures required to be

implemented. Information on hazardous materials, including the potential impact associated with each,

and measures to be taken in the event of accidental release. Training plans, testing exercises and schedules for effectiveness.

The Operator shall comply with the emergency preparedness and incident and accident-reporting requirements, as required by the Occupational Health and Safety Act, 1993 (Act No 85 of 1993), the NEMA, 1998 (Act No 107 of 1998), the National Water Act, 1998 (Act No 36 of 1998) and the National Veld and Forest Fire Act, 1998 (Act No 101 of 1998) as amended and/or any other relevant legislation.


7 ENVIRONMENTAL MONITORING

According to Appendix 4 of GN R 982, an environmental management programme must include: (g) the method of monitoring the implementation of the impact management actions

contemplated in paragraph (f); (h) the frequency of monitoring the implementation of the impact management actions

contemplated in paragraph (f) (k) the mechanism for monitoring compliance with the impact management actions

contemplated in paragraph (f); (l) a program for reporting on compliance, taking into account the requirements as prescribed

by the Regulations;

7.1 General Environmental Monitoring A monitoring programme will be implemented for the duration of the operation of the facility. This programme will include: Establishing a baseline through the taking of photographs of identified environmental aspects

and potential impact sites within the Clariter property boundary. Bi-weekly (fortnightly) monitoring will be conducted by the OM to ensure compliance to the EMPr

conditions, and where necessary make recommendations for corrective action. These audits can be conducted randomly and do not require prior arrangement with the OM.

The OM shall keep a photographic record of any damage to areas within the Clariter property boundary. The date, time of damage, type of damage and reason for the damage shall be recorded in full to ensure the responsible party is held liable. All claims for compensation emanating from damage should be directed to the OM for appraisal.

7.2 Non-compliance It should be noted that in terms of the National Environmental Management Act No 107 of 1998 (Section 28) those responsible for environmental damage must pay the repair costs both to the environment and human health and the preventative measures to reduce or prevent further pollution and/or environmental damage (The „polluter pays‟ principle). The OM shall act immediately when notice of non-compliance is received and correct whatever is the cause for the issuing of the notice. Complaints received regarding activities on the site pertaining to the environment shall be recorded in a dedicated register and the response noted with the date and action taken. The OM should be made aware of any complaints. Any non-compliance with the agreed procedures of the EMPr is a transgression of the various statutes and laws that define the manner by which the environment is managed. Failure to redress the cause shall be reported to the relevant authority for them to deal with the transgression, as it deems fit. The OM is deemed not to have complied with the EMPr if, inter alia:

there is evidence of contravention of the EMP specifications within the boundaries of the site, site extensions and roads;

there is contravention of the EMP specifications which relate to activities outside the boundaries of the site.

environmental damage ensues due to negligence.


7.3 Incident Reporting and Remedy If a leakage or spillage of hazardous substances occurs on site, the local emergency services must be immediately notified of the incident. The following information must be provided:

the location; the nature of the load; the extent of the impact; and the status at the site of the accident itself (i.e. whether further leakage is still taking place,

whether the vehicle or the load is on fire). Written records must be kept on the corrective and remedial measures decided upon and the progress achieved therewith over time. Such progress reporting is important for monitoring and auditing purposes. The written reports may be used for training purposes in an effort to prevent similar future occurrences.

7.4 Amendment to the EMPr Changes to the EMPr should be handled as described in Section 35-37 of GN R 982.


8 ENVIRONMENTAL AWARENESS The Operator shall ensure that its employees and any third party who carries out all or part of the Operator‟s obligations are adequately trained with regard to the implementation of the EMPr, as well as regarding environmental legal requirements and obligations. The OM shall ensure that adequate environmental training takes place. All employees shall have been given an induction presentation on environmental awareness and the content of the EMPr. The presentation needs to be conducted in the language of the employees to ensure it is understood. The environmental training shall, as a minimum, include the following:

The importance of conformance with all environmental policies. The environmental impacts, actual or potential, of their work activities. The environmental benefits of improved personal performance. Their roles and responsibilities in achieving conformance with the environmental policy

and procedures, including emergency preparedness and response requirements. The potential consequences of departure from specified operating procedures; The mitigation measures required to be implemented when carrying out their work

activities. Environmental legal requirements and obligations. The importance of not littering. The need to use water sparingly. Details of and encouragement to minimise the production of waste and re-use, recover

and recycle waste where possible.

According to Appendix 4 of GN R 982, an environmental management programme must include: (m) An environmental awareness plan describing the manner in which –

(i) the applicant intends to inform his or her employees of any environmental risk which may result from their work; and (ii) risks must be dealt with in order to avoid pollution or the degradation of the environment;


9 CONCLUSIONS Although all foreseeable actions and potential mitigations or management actions are contained in this document, the EMPr should be seen as a day-to-day management document. The EMPr thus sets out the environmental and social standards, which would be required to minimise the negative impacts and maximise the positive benefits of the Clariter Project as detailed in the EIR and specialist reports. The EMPr could thus change daily, and if managed correctly lead to a successful operational phase.

New Appendix E: Environmental Management Programme (EMPr) … RE050216_163/Appendix E... · 2017....

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