BAIC SA Autoplant, Coega Draft Environmental …...vehicle assembly facility, which will subsequently be upgraded to allow for full manufacture of up to 100 000 vehicles p/a. Phase

spet/garr 542855_BAIC_EMPr_20190417_final July 2019

BAIC SA Autoplant, Coega

Draft Environmental Management Programme (EMPr)

Report Prepared for

Report Number: 542855/2

Report Prepared by

July 2019

SRK Consulting: 542855: BAIC SA Autoplant, Coega – Draft EMPr


BAIC SA Autoplant, Coega

Draft Environmental Management Programme (EMPr)

Report Prepared for

BAIC Automobile SA (Pty) Ltd.

1010 Lwandle Road, Zone 1 South, Coega, Port Elizabeth South Africa

SRK Consulting (South Africa) (Pty) Ltd.

Ground Floor Bay Suites 1a Humewood Rd. Humerail Port Elizabeth 6001 South Africa e-mail: [email protected] website: www.srk.co.za Tel: +27 (0) 41 509 4800 Fax:+27 (0) 41 509 4850

SRK Project Number 539528

July 2019

Compiled by: Peer Reviewed by:

Nicola Rump Principal Environmental Scientist Tanya Speyers Environmental Scientist

Rob Gardiner Partner, Principal Environmental Scientist

Email: [email protected]

Authors:

T Speyers, N Rump

http://www.srk.co.za/

mailto:[email protected]



Table of Contents

1 Introduction and Scope of Report .............................................................................. 1

2 Project Description ...................................................................................................... 1

3 Environmental Impacts and Management Objectives ............................................... 4

3.1 Heritage............................................................................................................................................... 4

3.2 Air Quality............................................................................................................................................ 4

3.3 Noise ................................................................................................................................................... 4

3.4 Soil and Groundwater Contamination ................................................................................................. 5

3.5 Traffic Flow and Safety ....................................................................................................................... 5

3.6 Waste Management ............................................................................................................................ 5

3.7 Socio-economic .................................................................................................................................. 6

3.8 Safety Impacts .................................................................................................................................... 6

4 Impact Management ..................................................................................................... 6

5 Monitoring, Reporting and Auditing ......................................................................... 16

6 Environmental Awareness Plan ................................................................................ 16

7 Organisational Structure ........................................................................................... 16

7.1 The Developer: BAIC ........................................................................................................................ 16

7.2 The Contractor .................................................................................................................................. 16

7.3 The Environmental Representative/ Dedicated Environmental Officer (DEO) ................................. 17

7.4 The Environmental Control Officer (ECO) ........................................................................................ 17

Appendices ...................................................................................................................... 19

8 SRK Report Distribution Record ............................................................................... 21



Acronyms

AST Aboveground Storage Tank

BAR Basic Assessment Report

BID Background Information Document

CBA Critical Biodiversity Area

CKD Complete Knock-Down

CSEZ Coega Special Economic Zone

DBAR Draft Basic Assessment Report

DEA Department of Environmental Affairs

EA Environmental Authorisation

EAP Environmental Assessment Practitioner

ECO Environmental Control Officer

EMPr Environmental Management Programme

IAP Interested and Affected Party

LPG Liquid Petroleum Gas

MHI Major Hazard Installation

NEMA National Environmental Management Act

NMBM Nelson Mandela Bay Municipality

PPP Public Participation Process

QRS Quantitative Risk Assessment

RP Responsible Person

SABS South African Bureau of Standards

SKD Semi Knock-Down

SRK SRK Consulting

ULP Unleaded Petrol

UST Underground Storage Tank

SRK Consulting: 542855: BAIC SA Autoplant, Coega – Draft EMPr 1


1 Introduction and Scope of Report BAIC SA Automobile (Pty) Ltd (BAIC) proposes to construct an automobile manufacturing plant on a

78 Ha site in Zone 1 of the Coega Special Economic Zone (CSEZ).

SRK Consulting has been appointed to conduct a Basic Assessment process according to the National

Environmental Management Act (Act 107 of 1998) (NEMA) 2014 EIA regulations (GNR 982, of 14

December 2014), as amended. This Environmental Management Programme (EMPr) has been

prepared as part of the Basic Assessment process to Department of Economic Development,

Environmental Affairs and Tourism (DEDEAT).

The style of writing is aimed at making the Draft EMPr easier to read and convert into a practical

management tool should the application be approved. SRK has exercised all due care in reviewing

the supplied information provided. The appropriateness and practicality of the management measures

presented in this Draft EMPr has been considered in terms of the facility and the surrounding areas.

BAIC is fully responsible for the implementation of the Draft EMPr.

The aim of this Draft EMPr is to ensure that construction activities are conducted such that potential

negative environmental impacts are minimised and positive impacts are enhanced. This Draft EMPr

is not a health and safety plan and this Draft EMPr makes no attempt to satisfy the requirements of

the Occupational Health and Safety Act.

2 Project Description The site is bounded to the north and east by the SEZ, to the west by the N2 and to the South

undeveloped land (thicket vegetation) with the residential area of St Georges Strand located

approximately 280 m away (Figure 1).

Construction of the initial stages of the facility commenced in February 2017, however subsequent

changes to the project description to accommodate storage of dangerous goods required for future

expansion of the plant have triggered the need for an Environmental Authorisation. The project is

divided into two phases and various subphases. Phase 1 of the project initially involves establishing a

vehicle assembly facility, which will subsequently be upgraded to allow for full manufacture of up to

100 000 vehicles p/a. Phase 2 entails expansion to include component manufacturing, details of which

are not yet known and is therefore outside the scope of this assessment. It is anticipated that the plant

will manufacture up to 50, 000 vehicles p/a during Phase 1, and to up to 100, 000 vehicles p/a once

Phase 2 is operational.

The development is inclusive of the following components:

LPG Storage Facility (Final capacity of 180 m³);

Oil and chemical store (Final capacity of 80 m³);

Effluent treatment Plant (Capacity of 500 m³/day) for the treatment of industrial effluent;

Waste storage area for general and hazardous waste (stored in drums until collection);

Body Shop;

Assembly shop for body & chassis assembly, safety performance testing and repairs;

Paint Shop, for full vehicle manufacture only;

Energy Centre including compressed air station, and power distribution; and

Fuel Storage Facility including a final capacity of up to 50 m³ each of diesel in above ground storage vessels and petrol in underground storage vessels.

The mitigation and management measures in Section 4 have been developed based on the above

project description and to address the NEMA listed activity of storage and handling of a dangerous

SRK Consulting: 542855: BAIC SA Autoplant, Coega – Draft EMPr 2


goods. Any additional measures identified in the authorisation (if it is granted) for these components

will be addressed via an update to this Draft EMPr.

The aim of this Draft EMPr is to assist BAIC in understanding the management measures they are

required to implement. This will allow these measures to be incorporated into all future decisions that

will be made to ensure that the impacts associated with this development will be minimised.

SRK Consulting: 542855: BAIC SA Autoplant, Coega – Draft EMPr Page 3


Figure 1: Site locality map for BAIC SA Autoplant in Coega



3 Environmental Impacts and Management Objectives This section specifies the impact management objectives and outcomes used to determine the extent

of management action(s) required to mitigate the impacts identified during the impact assessment

process. Descriptions and environmental objectives are listed below for each of the relevant impact

categories as identified in the Basic Assessment Report for the construction and operational phase of

the project. There are no intentions to decommission the tanks in the foreseeable future and as such

this EMPr does not cover decommissioning activities.

The impacts described below have been identified in the Draft Basic Assessment Report (DBAR) for

the design, construction and operational phases.

3.1 Heritage

Archaeological and palaeontological assessments were carried out for the Coega SEZ in 2010 for the

rezoning of the CSEZ. These studies identified areas of importance and management measures. As

most of the BAIC site has already been cleared and developed (and therefore monitored with regard

to heritage sensitivities) it is considered highly unlikely that any archaeological or palaeontological

resources will be discovered with the development of the remaining components of the facility.

The impact management objective for this impact is to prevent the destruction of heritage resources.

3.2 Air Quality

Air quality impacts during construction are generally related to the generation of dust, smoke and

exhaust emissions resulting from activities such as the removal of vegetation, earthworks, increased

vehicular traffic, topsoil stockpiles, etc. Sensitive air quality receptors are those in close proximity to

the site and include traffic along the N2 (may cause visibility issues), the residential area of St Georges

Strand (nuisance issue) and nearby factories such as PE Cold Storage and Isuzu where excessive

dust could interfere with production quality.

The facility will produce the following air emissions during operation:

Dust and noxious gas exhausted from body shop;

Paint mist and dimethylbenzene gas exhausted from paint shop;

Fumes hazardous substances stored in the waste centre; and

Emissions from the burning of LPG gas (NOx, CO, particulate matter, SOx and TOC) in the boilers.

The management objective for this impact is to minimise air pollution. The facility does not trigger the

requirement for an Air Emissions License.

3.3 Noise

Noise from construction activities (such as plant, machinery, vehicles and hammering) will be

temporary and as the site is located within a developing SEZ it is expected that there are few sensitive

receptors. Noise and vibration during operation will mainly be produced by devices such as air

compressor’s, ventilation system in the paint shop, circulation pumps etc. As the facility is located

within a SEZ, it is not anticipated that there are any sensitive receptors in close proximity to the plant

The management objectives for this impact are:

Minimise noise impacts; and

Legal compliance with regard to noise generation



3.4 Soil and Groundwater Contamination

The potential impact on groundwater has been assessed by a hydrogeologist. Spillage of

contaminants (such as cement-mix, oil, lubricants and fuel) from vehicles and construction activities

(such as cement mixing, plant and vehicles maintenance, and other machinery) could potentially

impact on soils and groundwater. Several substances will be stored on site which have the potential

to contaminate soil and groundwater if a loss of containment occurs. This includes paints (xylene,

NMHC), industrial wastewater and fuels including diesel and petrol. According to the Hydrogeological

(groundwater) Investigation the risk to pollution of groundwater is considered to be high for this area

and groundwater setting. It is noted however that according to the facility design all potential

contaminants will be stored on sealed surfaces or in underground tanks (in the case of petrol) and a

stormwater management plan will be in place.

The impact management objectives for this impact are:

Prevent negative impacts on surrounding groundwater users; and

Prevent the potential of contamination surrounding soil.

3.5 Traffic Flow and Safety

Traffic will increase along the N2 and along the internal SEZ routes to the BAIC plant. Slow moving

vehicles and large equipment may cause congestion and present a safety concern however the impact

will be temporary and as the SEZ is a development zone it is assumed that the road infrastructure is

able to handle this increased load. The facility will generate the following additional traffic flows:

Traffic to and from Zone 1 of the SEZ will increase with the delivery of the SKD/CKD components

from the port to the BAIC site and distribution of the completed vehicles from the site to the South

African market;

LPG will be delivered to the site via road tankers seven/eight times a week; and

A proportion of employees will access the site by means of public transport services. In the short

term, these services are likely to be on a contract basis with operators (both bus and minibus-taxi)

dropping off and picking up employees at shift changes. Based on information supplied by BAIC

the number of employees making use of public transport services will range from 280 during 2018

increasing to 492 during 2020;

The impact management objective for this impact is to minimise safety hazards.

3.6 Waste Management

General construction waste will be generated during the construction period. Lack of proper

management of the waste on the site may lead to dumping and wind-blown litter creating a negative

visual impact as well as impacting on the surrounding natural ecosystems.

The facility will generate both hazardous and domestic waste. Solid waste will be stored in the waste

centre and removed daily by a registered waste removal company for appropriate disposal/ Liquid

waste will be directed to an onsite effluent treatment plant for processing until it meets the municipal

discharge standards at which time it will be released into the municipal waste stream. If the waste is

not properly disposed of at registered landfills/if untreated effluent is allowed to enter into the municipal

network this could result in dumping, environmental pollution, contamination of groundwater and

problems in the municipal sewer network.


Prevent pollution of the surrounding areas; and



Legally compliant management of solid waste.

3.7 Socio-economic

Construction activities will result in direct creation of job opportunities as well as indirect job

opportunities (industries that provide construction materials and services for the project). BAIC

anticipates that approximately 1480 direct job opportunities will be created during construction. The

operation of the BAIC plant will result in the creation of approximately 784 direct employment

opportunities during operation. Operation of the plant will also result in many indirect benefits through

associated industries such as components manufacturing, material supply, energy and logistics etc

and by encouraging further investment within the SEZ and the local vehicle industry.


Maximise employment of local labour; and

Maximise skills transfer.

3.8 Safety Impacts

The safety impacts for operation have been assessed and through a Quantitative Risk Assessment

Study conducted by Riskom (A copy of the specialist report can be found in Appendix D of the DBAR).

According to the specialist, the introduction of flammable fuel storages (LPG, diesel, and ULP) and

other flammable storages, as part of the ramping up of production at BAIC introduces the following

potential incidents to the site:

pool fires (LPG, ULP and diesel);

flash fires (LPG and ULP);

vapour cloud explosions (LPG and ULP);

warehouse type fires e.g. at the chemical/oil store;

losses of containment (ULP, diesel, paint sludge) with the potential to enter the ground and surface water.

The impact management objective for this impact is:

Reduce the risk of potential catastrophic failures to the public.

4 Impact Management This section specifies the impact management outcomes and impact management actions required

for the aspects and potential impacts related to the proposed development. The manner in which the

impact management objectives and outcomes, identified above, will be achieved through mitigation

measures. Where applicable actions will include activities 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

(iv) comply with any provisions of the Act regarding financial provisions for rehabilitation, where

applicable

The above are detailed in Table 1 for the design phase, Table 2 for the construction phase and Table

3 for the operational phase. Decommissioning of the plant is not planned for the foreseeable future.



Table 1: Mitigation and management measures for the design phase

Environmental Aspect Potential Environmental Impact

Management and mitigation measure Time-frame Responsibility

Design of facilities for storage

and handling of

environmentally hazardous

materials/dangerous goods

Leaks and spills of


materials (e.g. oils and fuels)

has the potential to impact on

the groundwater.

Groundwater monitoring boreholes must be established and sampled at least three months before the plant is operational, prior to, during and after site operations. These boreholes must be scientifically placed to intersect preferential flow paths. Scientific Siting is recommended.

Design Phase BAIC,

Hydrogeologist

Fires/Explosion risk affecting

public safety

All designs should be in full compliance with (but not limited to) the Occupational Health and Safety Act 85 of 1993 and its regulations, the National Buildings Regulations and the Buildings Standards Act 107 of 1977 as well as local bylaws;

No windows to be installed in the paint storage area to prevent the propagation of glass projectiles in the event of an explosion;

The flammable store areas to be bunded to capture any spillage and fire water runoff from activation of the sprinkler systems. Runoff from the bunds are to captured prior to disposal;

The flammable store is to be constructed in accordance with the National Building Regulations, SANS 10400, SANS 10263. National Building Regulations and SANS 10400 shall take precedence in the event of any conflicting codes and standards;

LPG storage tanks are required to be unbunded (SANS 10087 Part 3);

Complete an MHI quantitative risk assessment based on finalised design information prior to construction of the facilities;

Completion of an emergency preparedness and response document for on-site and off-site scenarios prior to initiating the MHI risk assessment (with input from local authorities)

Completion of a recognised process hazard analysis (such as a HAZOP study, FMEA, etc.) on the proposed facility prior to construction to ensure design and operational

Design Phase BAIC,

Engineers,

MHI





hazards have been identified and adequate mitigation put in place;

Preparation and issue of a safety document detailing safety and design features reducing the impacts from fires, explosions and flammable atmospheres to the MHI assessment body at the time of the MHI assessment;

A suitable resolution of the land planning requirements for the area to be achieved, that satisfies the required risk criteria for such use

Table 2: Mitigation and management measures for the construction phase



Construction machinery and

excavation activities Noise disturbance Construction activities should be limited to the municipal by-

law and the Noise Control Regulations in terms of the Environmental Conservation Act (Act 73 of 1989) to reduce the noise impact to an acceptable level;

No sound amplification equipment such as sirens, loud hailers or hooters are to be used on site except in emergencies and no amplified music is to be permitted on site;

Equipment must be used as per operating instructions and maintained properly during site operations;

Duration of construction

Contractor

Impacts on ambient air quality

of the surrounding area, such as

the generation of dust, and

exhaust emissions

All loads of loose material transported to and from site to be covered;

Ensure that any material spilled from trucks during transport to or from the site is cleaned up immediately;

Dust suppression techniques, such as wetting or covering potential dust sources, should be implemented to minimise the dust impact. The regular application of water or a biodegradable soil stabilisation agent can be used;

Topsoil/ sand stockpiles are to be covered with appropriate material (e.g. hessian, shade cloth or plastic);


Contractor





Disturbed areas should be rehabilitated immediately after construction in the relevant area (with indigenous vegetation or using topsoil).

Impacts on traffic safety and

flow

Implementation of strict traffic safety measures and speed limits for all construction related traffic; and

Appropriate traffic warning signage to be in place.


Damage or destruction of

palaeontological or

archaeological resources

The construction managers/ foremen and workers should be informed before construction starts on the possible types of heritage sites and cultural material they may encounter and the procedures to follow when they find sites (refer to appendix G); and

If concentrations of archaeological, palaeontological and/ or historical heritage material, marine shells, and/ or human remains are uncovered during construction, all work must cease immediately and be reported to the Albany Museum (046 622 2312) and/ or ECPHRA (043 745 0888) so that systematic and professional investigation/ excavation can be undertaken


Contractor

Construction Waste polluting

the surrounding environment

All personnel shall be instructed to dispose of all waste in the proper manner;

Skips to be provided for the storage of construction waste until such time as this can be removed and disposed of at a registered waste facility;

Skips to be regularly emptied and not allowed to overflow;

Waste disposal slips shall be kept for auditing purposes

All construction plant equipment, general waste, surplus rock, and other foreign materials must be completely removed from site once construction has been completed.


Contractor





Workers on site Presence of construction

workers on site may lead to

various impacts on the

surrounding area and

disturbance of neighbouring

companies as a result of

ablutions, fires, noise, waste

etc.

Implementation of localization strategy which must include:

o Employment of local labour as far as possible,

o Use of local suppliers; and

o Local labour to be considered for permanent employment during the operational phase, where possible.

Provide toilet facilities at a ratio of 1 toilet per 25 workers;

Chemical toilets to be regularly serviced and slips to be kept on site for auditing purposes;

Standard waste management practices should be implemented;

All waste generated on site shall be collected in waste receptacles fitted with lids and appropriately and regularly disposed of at a registered municipal landfill site;

The Contractor must identify and separate materials that can be reused or recycled to minimise waste, e.g. metals, packaging and plastics, and provide separate marked bins/ skips for these items. These wastes must then be sent for recycling and records kept of recycling;

Weekly litter inspections should be conducted and general housekeeping maintained

Smoking shall only be permitted in designated smoking areas;

Appropriate signage and receptacles for the containment of cigarette butts to be placed in these designated areas;

No fires are permitted on site;

A fire officer shall be appointed by the contractor who shall be responsible for co-ordinating rapid, appropriate responses in the event of a fire;

Sufficient fire-fighting equipment shall be maintained and accessible on site at all times;

A complaints record must be kept to record any complaints lodged and how they are addressed.


BAIC

Contractor





Storage and handling of


materials/dangerous goods

Leaks and spills of




the groundwater.

All holding areas of the potential pollutants and waste products should be contained and lined so that it cannot come into contact with the underlying soils or geology; -and

Groundwater monitoring boreholes must be established and sampled at least three months before the plant is operational, prior to, during and after site operations. These boreholes must be scientifically placed to intersect preferential flow paths. Scientific Siting is recommended.


Contractor

Concrete Works Concrete spills can contaminate

stormwater, soil and ultimately

groundwater

Place cement bags in bins and dispose of bags as waste to a licensed waste disposal facility;

Cement batching activities to be conducted on an impermeable surface and not on bare ground;

All concrete mixers are to be placed on sealed trays;

Any spills to be collected and disposed of at a registered disposal facility;

In the event that cement truck delivery chutes are cleaned on site this is to take place in a designated area. A suitable washing facility is to be developed on site in consultation with the ECO.


Contractor

ECO

Table 3: Mitigation and management measures for operational phase



Operation of machinery Noise generated by as air

compressor’s, ventilation

system in the paint shop,

circulation pumps etc, causing a

nuisance to neighbours

No sound amplification equipment such as sirens, loud hailers or hooters are to be used on site except in emergencies and no amplified music is to be permitted on site;

Equipment must be used as per operating instructions and maintained properly during site operations;

Duration of operation

BAIC





Noise levels shall be kept within acceptable limits, and all staff must abide by the relevant Noise Control Regulations and the NMBM Noise Pollution by-laws; and

All equipment shall be in a good state of maintenance;

Fans with noise over 75 dB shall be fitted with mufflers;

The blowers and exhaust fans on the pumps used for pre-treatment in the paint shop are to be equipped with sound insulation and shock absorption;

Preference shall be given to the use of lower noise generating tools; and

Where possible equipment is to be fitted with noise eliminating/reducing measures

Impacts on traffic safety and

flow

Implementation of strict traffic safety measures and speed limits for all operation related traffic; and

Appropriate traffic warning signage to be in place.


BAIC

Manufacturing process Pollution of the surrounding

environment resulting from poor

waste management

Registration of the waste storage facility with the relevant authority (DEA/DEDEAT) is to be completed 3 months prior to commissioning of the facility

Waste to be removed on a regular basis by a registered waste removal company;

Discharged effluent to be treated to meet the standards of the NMBM Water & Sanitation By-Law for discharge to sewer;

Ensure that service providers dispose of waste properly by requesting and retaining receipts for disposal;

An internal inspection of the effluent treatment plant should be conducted quarterly and findings of inspection recorded. Records of inspections need to be maintained for auditing purposes;

Emergency plans and procedures must be in place in case of any spills or leaks from the effluent plant


BAIC

Leaks and spills of


The correct chemical MSDS must be available on site at all times;


BAIC





Storage and handling of

dangerous goods including

LPG, diesel, ULP and paints



the stormwater and

groundwater.

Hazardous liquids shall be stored in a designated area with appropriate signage with a minimum bund containment capacity equal to 110% of the largest container;

Generators must be placed on drip trays;

Plant to be regularly maintained and inspected for potential leaks;

Appropriate spill kits must be readily available at all areas where hazardous materials are handled or stored;

Any material that is used to soak up spills (and is therefore contaminated) must be disposed of at a registered hazardous waste disposal facility, and the proof of disposal retained for auditing purposes;

Spilled hazardous material within secondary containment areas shall either be recovered (if possible), or disposed of at a suitable hazardous waste disposal facility, and the proof of disposal retained for auditing purposes;

Under no circumstances shall spills be allowed to enter surface or groundwater resources, including stormwater;

All holding areas of the potential pollutants and waste products should be contained and lined so that it cannot come into contact with the underlying soils or groundwater;

Groundwater monitoring boreholes must be established and sampled at least three months before the plant is operational, prior to, during and after site operations. These boreholes must be scientifically placed to intersect preferential flow paths. Scientific Siting is recommended;

Implementation of well-designed stormwater management measures in accordance with a stormwater management plan;

Staff must be trained to prevent spillages during fuel dispensing and refuelling as well as how to clean an area in the event of a spillage; and

Strict procedures for the management of the site must be developed and adhered to.





Fires/explosion risk affecting

the public safety

An on-site emergency plan must be compiled and implemented. The plan is to include input from the relevant local government parties;

The on-site emergency plan must be reviewed and where necessary updated, in consultation with the relevant local government, at least once every three years;

The on-site emergency plan must be readily available at all times for implementation and use;

Investigate and record all near misses in a register kept on the premises;

All employees must be conversant with the on-site emergency plan;

The on-site emergency plan must be tested in practice (drills) at least once a year and a record must be kept of such testing;

Water sprays at the LPG facility are to be operational and working to the design flow rates;

Extensive use of excess flow valves (EFVs) in preventing pipe or hose breaks from becoming more serious incidents;

Hazardous area classification to be developed as required in in accordance with SANS 10108 with all associated electrical equipment and instrumentation within the being area compliant to the code;

Hazardous wastes (paint sludge) is to be removed daily which limit inventories. The waste centre would be provided with natural ventilation (mesh walls) which would prevent the accumulation of flammable vapours;

Hazardous areas should be reviewed using a detailed process hazard analysis (PHA) such as a HAZOP study. Such an analysis should be completed to identify potential hazards and suggest further mitigation for safer operations;

Ignition sources near the propane storage and pipeline must be minimised as far as possible. This is particularly relevant with propane offloading. Applicable codes should be


BAIC





consulted for the safety distances of other vehicles to the offloading propane truck;

A hazardous area classification as per SANS 10108 must be developed for the propane installation. Only suitable instrumentation and electrical equipment should be installed in accordance to the requirement of the code;

The design has indicated that the applicable standard for the design would be SANS 10087 part 3. This is an acceptable standard and full compliance with this standard would be expected. It would also be mandatory for full compliance with SANS 10108 covering the types of electrical instrumentation;

Develop emergency procedures (in relation to fire, spills, contamination of the ground, accidents to employees, use of hazardous substances, etc.);

Appropriate firefighting measures have been put in place for the mitigation of fire risk;

Operation of LPG fired boilers,

body shop, paint shop

activities

Impacts on the air quality of the

surrounding area, such as the

generation of gases and

exhaust emissions

A mechanical ventilation system to be in place to ensure general ventilation in the factory;

The exhaust from the body shop is to meet the relevant standards;

Stand alone de-dusters are to be installed


BAIC

Workers on site Socio- economic benefits to

local communities

Implementation of a localization strategy which must include:

o Employment of local labour as far as possible,

o Maximise transfer of skills to local communities; and

o Maximise use of local suppliers.


BAIC


Spet/garr 542855_BAIC_EMPr_20190417_final July 2019

5 Monitoring, Reporting and Auditing Site inspections by an Environmental Control Officer (ECO) must be conducted on a monthly basis

during construction to ensure continued compliance with the conditions of the environmental

authorisation and the measures contained in the approved EMPr.

Monitoring measures during the operational phase are to include the following:

The condition of the above and underground storage tanks, pipes and dispensing pumps should be checked on an annual basis using approved methodologies;

Monthly monitoring of groundwater quality upstream and downstream of the potential sources of contamination on the site; and

Compliance with all MHI reporting and monitoring requirements.

6 Environmental Awareness Plan On-site training must be provided for all employees for the construction and operational phases of the

project. No personnel may be allowed to work onsite without having been instructed on the

requirements of the approved EMPr and the Environmental Authorisation conditions.

The training must deal specifically with triggers that would require the implementation of mitigation

measures contained in the EMPr. These include, but are not limited to:

Materials handling practices;

Emergency response plans; and

Waste management practices.

It is incumbent upon the Developer to convey the sentiments of the EMPr to all personnel involved in

operational phase (including sub-contractors) and the specific provisions of the EMPr. This should be

done via regular toolbox talks as well as more formal training sessions, and attendance registers

maintained for auditing purposes.

7 Organisational Structure The general roles and responsibilities of various parties are outlined below.

7.1 The Developer: BAIC

BAIC shall ultimately be responsible for the implementation of the Draft EMPr and shall appoint a

representative, the Responsible Person (RP), who shall:

Ensure that the Employees are duly informed of the Draft EMPr and associated responsibilities and implications of this Draft EMPr;

Monitor the activities with regard to the requirements outlined in the Draft EMPr;

Act as a point of contact for local residents and community members;

Ensure that problems are remedied in a timely manner and to the satisfaction of the authorities; and

Notify the authorities and the Environmental Control Officer (ECO) should problems arise that are not remedied effectively, or of any change in the development or changes in project specification that could significantly impact negatively on the environment.

7.2 The Contractor

The contractor will be responsible for:

Ensuring all activities on the site are undertaken in accordance with the EMPr;



Informing all employees and sub-contractors of their roles and responsibilities in terms of the EMPr;

Ensuring that all employees and sub-contractors comply with this EMPr; and

The Contractor has a duty to demonstrate respect and care for the environment in which they are operating. They will be responsible for the cost of rehabilitation, to the satisfaction of the ECO, of any environmental damage that may result from non-compliance with the EMPr, environmental regulations and relevant legislation.

7.3 The Environmental Representative/ Dedicated Environmental Officer (DEO)

The Contractor’s Environmental Representative shall be responsible for implementation of this EMPr

and any other environmental requirements that may be identified by the ECO, and agreed to by the

developer, during the course of the contract. The DEO shall have received basic environmental

awareness training, either as part of this contract, or previously. In addition to any other

responsibilities, the general duties of the DEO are as follows:

Ensuring that all personnel (including sub-contractors) are duly informed of the requirements contained in this EMPr, and the associated responsibilities and implications of this EMPr;

Ensuring that all records needed to demonstrate compliance with the EMPr requirements are obtained, safely stored, and are readily available for inspection by the ECO and/ or the developer. These records are detailed in this EMPr;

Consulting with the ECO regarding interpretation of the EMPr and any other aspects of the contract that may impact significantly on the environment;

Ensuring that all personnel (including sub-contracted personnel) demonstrate respect and care for the environment in which they are operating;

Acting as a point of contact for local residents and community members; and

Ensuring that a reporting system is in place and that community representatives can be informed of the correct procedures to lodge complaints.

It is anticipated that these ER duties would be assigned to a member of the on-site personnel that

would ordinarily be appointed for the duration of construction related activities by the Contractor, and

that these ER duties would be in addition to the other (possibly primary) responsibilities of that person.

7.4 The Environmental Control Officer (ECO)

An Environmental Control Officer (ECO) who is a qualified environmental professional with the

relevant environmental expertise, and independent of the RP, shall be appointed for the duration of

the construction activities. The ECO’s duties are as follows:

Being familiar with the environmental management requirements contained in this EMPr.

Undertaking the pre-construction and post-construction inspection, which may result in recommendations for additional clean-up and rehabilitation measures;

Monitor the Contractor’s activities with regard to the requirements outlined in the EMPr;

Undertake monthly audits on the implementation of the EMPr and submit audit reports to BAIC and the environmental authorities on request; and

A post-construction Final Audit Report to fulfil the conditions of the post-construction recommendations. The Final Audit Report will be submitted to DEDEAT.



Prepared by

Tanya Speyers

Environmental Scientist

Reviewed by

Rob Gardiner

Partner, Principal Environmental Scientist



Appendices



Appendix A: Guidelines for the identification of archaeological and historical material



Guidelines for the identification of archaeological and historical material

1. Human Skeletal material

Human remains, whether the complete remains of an individual buried during the past, or scattered

human remains resulting from disturbance of the grave, should be reported. In general the remains are

buried in a flexed position on their sides, but are also found buried in a sitting position with a flat stone

capping and developers are requested to be on the alert for this.

2. Freshwater mussel middens

Freshwater mussels are found in the muddy banks of rivers and streams and were collected by people

in the past as a food resource. Freshwater mussel shell middens are accumulations of mussel shell and

are usually found close to rivers and streams. These shell middens frequently contain stone tools,

pottery, bone, and occasionally human remains. Shell middens may be of various sizes and depths, but

an accumulation which exceeds 1 m² in extent, should be reported to an archaeologist.

3. Stone artefacts

These are difficult for the layman to identify. However, large accumulations of flaked stones which do

not appear to have been distributed naturally should be reported. If the stone tools are associated with

bone remains, development should be halted immediately and archaeologists notified

4. Fossil bone

Fossil bones may be found embedded in geological deposits. Any concentrations of bones, whether

fossilized or not, should be reported.

5. Large stone features

They come in different forms and sizes, but are easy to identify. The most common are roughly circular

stone walls (mostly collapsed) and may represent stock enclosures, remains of wind breaks or cooking

shelters. Others consist of large piles of stones of different sizes and heights and are known as isisivane.

They are usually near river and mountain crossings. Their purpose and meaning is not fully understood,

however, some are thought to represent burial cairns while others may have symbolic value.

6. Historical artefacts or features

These are easy to identify and include foundations of buildings or other construction features and items

from domestic and military activities



SRK Report Distribution Record

Report No. 542855/2

Name/Title Company Copy File type Date Authorised by

Mr Jeff Govender DEDEAT 1 Hard & electronic

11 July 2019 R Gardiner

Ms Jill Miller NMBM: Environmental Management

2 Hard & electronic

11 July 2019 R Gardiner

Mr Johan Potgieter NMBM: Fire & Emergency Services

3 Electronic 11 July 2019 R Gardiner

Mr Schalk Potgieter NMBM: Land Use Planning

4 Electronic 11 July 2019 R Gardiner

Mr Bethuel Kgobane IDC 5 Electronic 11 July 2019 R Gardiner

Ms Andrea Shirley CDC 6 Electronic 11 July 2019 R Gardiner

Mr Tian Jinhai BAIC SA 7 Electronic 11 July 2019 R Gardiner

Ms Bei Thackeray BAIC SA 8 Electronic 11 July 2019 R Gardiner

SRK Library SRK Port Elizabeth 9 Electronic 11 July 2019 R Gardiner

Approval Signature:

This report is protected by copyright vested in SRK Consulting. It may not be reproduced or

transmitted in any form or by any means whatsoever to any person without the written permission of

the copyright holder, SRK.

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