INTERWASTE (PTY) LTDP160778 - FG Waste Disposal Site Audit 1 Interwaste (Pty) Ltd December 2016 1 INTRODUCTION The FG Waste Disposal Site is a large-sized landfill facility owned and

INTERWASTE (PTY) LTD

ENVIRONMENTAL COMPLIANCE AUDIT AND WATER QUALITY

MONITORING REPORT - FG WASTE DISPOSAL SITE,

OLIFANTSFONTEIN, GAUTENG

WML. No. Gaut: 002/10-11/W0030

Amendment Ref. No. Gaut: 006/12-13/W0003

DECEMBER 2016

Prepared for:

Interwaste (Pty) Ltd

P.O. Box 382

Germiston

1400

P160778 - FG Waste Disposal Site Audit i Interwaste (Pty) Ltd December 2016

TABLE OF CONTENTS

1 INTRODUCTION .................................................................................................................... 1

2 NOVEMBER 2016 AUDIT ........................................................................................................ 1

2.1 Rationale for Scoring System ................................................................................................ 2

2.2 Review of Issues Arising at Previous Audit .............................................................................. 3

2.3 Correspondence with Authorities ........................................................................................... 5

2.4 Audit Findings ..................................................................................................................... 5

2.4.1 Minimum Requirements .................................................................................................. 5

2.4.2 Norms and Standards Checklist ....................................................................................... 5

2.4.3 Waste Management Licence Compliance Checklist .............................................................. 6

3 AIR QUALITY MONITORING .................................................................................................. 8

4 WATER QUALITY MONITORING ............................................................................................. 9

4.1 Background ........................................................................................................................ 9

4.2 Boreholes Utilised in the Groundwater Monitoring Network ..................................................... 10

4.3 Suitability of Boreholes / Monitoring System ......................................................................... 10

4.4 Surface Water Runoff and Potable Water Monitoring .............................................................. 11

4.5 Results of Water Quality Monitoring ..................................................................................... 13

4.6 Discussion of Monitoring Results .......................................................................................... 22

5 CONCLUSION ...................................................................................................................... 30

TABLES

Table 1: Audit Personnel and Site Information ................................................................................... 1

Table 2: Summary of results obtained for borehole and surface water samples taken from the FG Waste

Disposal Site, November 2016 ....................................................................................................... 14

Table 3: Results obtained from monitoring of FG Borehole 1 from 2012 – 2016 ................................... 15



Table 6: Results obtained from monitoring of FG Upstream Borehole 1 from 2014 – 2016 .................... 18

Table 7: Results obtained from monitoring of FG Upstream Borehole 2 from 2014 – 2016 .................... 19

Table 8: Results obtained from monitoring of Surface Water from 2014 – 2016 .................................... 20

Table 9: Results obtained from monitoring of FG Potable Water from 2014 – 2016 ............................... 21

APPENDICES

Appendix 1: Minimum Requirements and Norms and Standards Checklist

Appendix 2: Waste Management Licence Checklist

Appendix 3: Sheet of Photos from Audit

Appendix 4: Latest tonnages landfilled

Appendix 5: Bi-annual Water Quality Monitoring Laboratory Results

Appendix 6: Latest Monitoring Committee Meeting Minutes

P160778 - FG Waste Disposal Site Audit 1 Interwaste (Pty) Ltd December 2016

1 INTRODUCTION

The FG Waste Disposal Site is a large-sized landfill facility owned and operated by Interwaste. The site is

located on Portion 15 of the Farm Olifantsfontein 410 JR in Kempton Park at 28° 11” 04’ longitude and 25°

57” 35’ latitude and is approximately 90 ha in extent. The site is situated on land previously disturbed by

opencast mining activities and surrounded by mixed agricultural- and undeveloped land.

The site is operated in terms of a Waste Management Licence (WML) (to operate as a class G:L:B+

Landfill Site) in terms of the National Environmental Management: Waste Act, No. 59 of 2008

(NEM:WA), WML Registration No: Gaut: 002/10-11/W0030 and amended by an addendum to the WML

No: Gaut: 006/12-13/W0003.

2 NOVEMBER 2016 AUDIT

Prime Resources was appointed to conduct an external, independent audit of the FG Waste Disposal Site in

terms of compliance with the conditions of the WML. The audit report will be submitted to the Competent

Authority (GDARD) by Interwaste.

Table 1: Audit Personnel and Site Information

Permit Holder Interwaste (Pty) Ltd

Responsible Person/s Mr Marius Conradie

Site Classification G:L:B+

Authorisation No. Gaut: 002/10-11/W0030

Gaut 006/12-13/W0003

Principal Auditor/s Mrs Louise Jones and Mr Jonathan van de Wouw

(Prime Resources)

Date of Audit Wednesday 23 November 2016

This document serves to comply with condition 3.5.2 of the WML (as amended), which stipulates that an

independent external auditor must be appointed to audit the site annually. The conditions of the WML, the

Department of Water Affairs Minimum Requirements for Waste Disposal by Landfill (Second Edition, 1998)

and the National Environmental Management: Waste Act 59 of 2008- National Norms and Standards for

Disposal of Waste to Landfill (GNR636 of 2013) form the measures against which performance in terms of

the audit was measured.

Now that the Landfill Gas Project is operational, the site should also be audited in term of the National

Standards for Extraction, Flaring or Recovery of Landfill Gas (GNR924 of 2013) and the Environmental

Management Programme (EMP) needs to be revised to include the gas management and monitoring

system.


2.1 Rationale for Scoring System

The site is audited in terms of a scoring system, with the final score presented as a percentage. No

minimum-required audit percentage target has as yet been decided on by the Permit holder. The scoring

system utilised has been adapted from an existing system employed by the Auditor which was designed

for waste disposal sites. The scores attributed to individual permit items are based on the fact that some

aspects of a waste disposal are deemed more important than others (e.g. the working face and covering of

waste are more important than gardens and signage) and thus items considered more important are

assigned scores of 1 - 2 points, while items considered less important are assigned half point scores (0.5).

Where an item is in full compliance, the maximum score is awarded, i.e. 1 / 1. When the site only

partially complies with a condition, half of the maximum score is awarded, e.g. 0.5 / 1. When the site

does not comply with a condition at all, zero points are awarded, regardless of the maximum possible

score. An item is generally scored as non-compliant if it has not been addressed since the previous audit,

and still remains a problem. The scoring system is illustrated below.

Maximum possible score Compliance Resultant score

1 Fully compliant 1

1 Partial compliance 0.5

1 Non-compliant 0

0.5 Fully compliant 0.5

0.5 Partial compliance 0.25

0.5 Non-compliant 0

The site scored a total of 90.5 out of a possible 91 (99.5 %) for compliance with the Minimum

Requirements, and scored a total of 92.3 out of a possible 95 (97.1%) in terms of compliance with the

WML. The aggregate score is thus: 98.3 %, which is similar to the previous audit. The individual scores

forming the total as well as detailed commentary on each aspect are indicated in the checklists of

Appendix 1. The FG Waste Disposal Site is well run and management has endeavoured to correct previous

partial and non-compliances.


2.2 Review of Issues Arising at Previous Audit

ISSUE NOTED

LEVEL OF

COMPLIANCE AT

PREVIOUS AUDIT

(JUNE 2016)

LEVEL OF

COMPLIANCE AT

CURRENT AUDIT

(NOVEMBER 2016)

COMMENTS

Minimum Requirements Checklist

Dust Control

The site officer confirmed that water carts were in

operation on the day of the audit. Borehole water is

currently being pumped into the stormwater dam and

used for dust suppression as there is no stormwater. The

road leading up to the general waste cell at the back of

the site is too steep to be reached by the water cart, and

therefore dust is not controlled in this area.

PC C

A water cart was in operation at the time of the audit

(Appendix 3, Photo 3) and dust levels were acceptable.

Stormwater is used for dust suppression and little mud was

noted.

Drainage

Concrete lined drains on-site serve to drain clean

stormwater run-off arising in areas of the site

downstream of the waste disposal activities off-site. The

flow in these drains is very limited and intermittent. A

small volume of water present in the V-drain at the site

boundary was found to have elevated electrical

conductivity and concentrations of iron, manganese, COD

and phenols. Considering the total capacity for

stormwater storage on-site, it is recommended that this

intermittent runoff is captured and retained in the

existing facilities on-site and used in dust suppression or

is otherwise further tested prior to discharge.

PC C

Subsequent to the June 2016 audit having taken place, a

new stormwater dam has been constructed. Any water from

the stormwater drains on site is now directed to the new

stormwater dam. No water will leave the site without it first

being tested. The plan is to use this water for additional

dust suppression.

Protection of unsafe excavations

During the previous audit the stormwater dam next to

Phase 3 had not been fenced off.

PC PC

The dam was fenced off.

However there was an unsafe excavation at Phase 3 (See

finding below).

Uncontaminated water to flow into natural

drainage system

A small volume of water present in the V-drain at the site

boundary was found to have elevated electrical

conductivity and concentrations of iron, manganese, COD

and phenols. Considering the total capacity for

PC C

Any water from the stormwater drains on site is now

directed to the new stormwater dam. No water will leave the

site without it first being tested. The plan is to use this

water for additional dust suppression.


ISSUE NOTED

LEVEL OF

COMPLIANCE AT

PREVIOUS AUDIT

(JUNE 2016)

LEVEL OF

COMPLIANCE AT

CURRENT AUDIT

(NOVEMBER 2016)

COMMENTS

stormwater storage on-site, it is recommended that this

intermittent runoff is captured and retained in the

existing facilities on-site and used in dust suppression or

is otherwise further tested prior to discharge.

Dust kept to a minimum (watering)

The road leading up to the general waste cell (Phase 1)

at the back of the site is too steep to be reached by the

water cart, and therefore dust was not being controlled in

this area.

PC C A water cart is used to control dust on site (Appendix 3,

Photo 3). Dust levels were minimal at the time of the audit.

Waste Management Licence Compliance Checklist

Section 3 (Runoff water)

No stormwater arising at the working face is discharged

from site. As described above, a sample was taken from

the intermittent and limited amount of water present in

the V-drain at the site boundary as it was the only

position from which stormwater was available (the

stormwater dams were filled with groundwater pumped

for dust suppression purposes and were therefore not

representative). The electrical conductivity and

concentrations of iron, manganese, COD and phenols of

this water did not comply with the General Standard. See

water quality monitoring section for the result of this

monitoring.

PC C

No water was discharged for the reporting period. Any water

from the stormwater drains on site is now directed to the

new stormwater dam. No water will leave the site without it

first being tested. The plan is to use this water for additional

dust suppression.


2.3 Correspondence with Authorities

The WML (Gaut: 002/10-11/W0030) for the FG Waste Disposal Site states that: The Waste Management

Licence must be renewed within a period of 4 years from the date of issue. The licence has not yet been

renewed.

A compliance notice was received from GDARD regarding the above and stating that the WML had not

been renewed. This was objected to in writing by Interwaste. The High Court issued an order suspending

the compliance notice and setting timeframes for the delivery of court papers by the parties. The

application for the urgent interdict was heard on 12 July 2016. The High Court has suspended the notice

until the court review has been completed.

The Department of Environmental Affairs (DEA) issued Interwaste with a pre-directive in October 2016 and

an addendum thereto in November 2016. The pre-directive relates to relates to alleged impacts on air and

groundwater quality from the FG Waste Disposal Site. Interwaste disputes the allegations. Interwaste has

appointed various specialists and the findings of these studies will be submitted to the DEA.

2.4 Audit Findings

The weather on the day of the audit was warm and sunny with a slight breeze. The audit was undertaken

at 10 am on 23 November 2016 and was attended by representatives of both Interwaste (site team) and

Prime Resources (auditor’s team). At the time of the audit, the site was functioning effectively and was

generally neat and tidy.

The findings in terms of audit compliance are summarised below, with full details described in the audit

checklists of Appendix 1 and 2.

2.4.1 Minimum Requirements

In addition to the above findings (Section 2.2), the following partial- or non-compliances were noted

during the audit regarding compliance to the Minimum Requirements for Waste Disposal to Landfill, 2nd

Edition, 1998:

D. Landfill Operation

1. Compaction and daily cover of waste

Condition (1.7): Protection of unsafe excavations

Finding: PC

Cover material is being excavated from Phase 3 and safety in this area was a concern as the

excavation has not been barricaded and the side slopes are very steep. The area should be

barricaded and the angle of repose checked by a suitably qualified person.

2.4.2 Norms and Standards Checklist

The site was also assessed in terms of the Norms and Standards for the disposal of waste to landfill

(GN636 of 2013). In terms of the Phase 1 cells Interwaste is not obliged to comply with the Norms and


Standards as these cells were operating lawfully in terms of the Act prior to the Regulations coming into

operation. In terms of the containment barriers for Phases 2-4, the site is compliant. The site is also

compliant in terms of the waste types accepted and Interwaste is aware of the waste disposal restrictions.

2.4.3 Waste Management Licence Compliance Checklist

In addition to the above findings (Section 2.2), the following areas of partial- or non-compliances were

noted during the audit:

3.1 Scope of Licence

Condition (3.1d): Interwaste shall be responsible for ensuring compliance with the conditions.

Finding: PC

This external compliance audit serves to evaluate such compliance and some partial- and non-

compliances were noted. The site is therefore not being operated in complete accordance the

Minimum Requirements and the conditions of the WML. The corrective actions should be

implemented by Interwaste to achieve compliance.

3.3.4. Commissioning and Construction of the activity

Condition (j): The slope of the sides of the Site shall be constructed in such a manner that little or

no erosion occurs.

Finding: PC

Soil saver and hydro-seeding has been implemented on portions of the outer slopes of Phase 2

(Appendix 3, Photo 9) to minimise erosion, however signs of erosion were noted on portions of the

outer slopes of Phase 2 at the time of the audit (Appendix 3, Photo 10). The angle of repose of the

outer berms of the waste cells is approximately 1:3 and the completed berms are being re-

vegetated.

3.3.7. Impact Management

Condition (c): Interwaste must ensure that emissions from the activities are free from odour at

levels likely to cause annoyance outside the site.

Finding: NC

Sporadic complaints are being received regarding odours perceived to emanate from the landfill

site.

From the Ambient Air Quality Assessment report dated October 2016 (by Geozone Environmental),

with the exception of the South-west corner, average ambient concentrations of Hydrogen

sulphide at all of the on-site monitoring locations were lower than those recorded during the

previous sampling period (August 2016). Despite this, average ambient Hydrogen sulphide

concentrations at all of the on-site monitoring locations remained in excess of the odour detection

threshold. From the Ambient Air Quality Assessment report dated November 2016 (by Geozone

Environmental) no exceedance of Hydrogen sulphide health limits were found and a substantial

reduction of Hydrogen sulphide was noted since August 2016. Average ambient Hydrogen sulphide

concentrations at the Leachate dam, W. Boundary and SW corner remain in excess of the odour

detection threshold.


Based on the evidence collected to date, emissions of hydrogen sulphide gas from the FG Waste

Disposal Site may impact intermittently on individuals/ communities located nearby, leading to

complaints about malodour. Average ambient concentrations of the measured contaminant

compounds at the off-site sampling locations were below the relevant South African long term

ambient air quality standard and Environmental Assessment Levels.

3.3.8. Operation

Condition (e): Interwaste must ensure that the Site is operated in such a manner that nuisance

conditions or health hazards, or the potential creation of nuisance conditions or health hazards are

prevented.

Finding: NC

The site is regularly inspected for signs of nuisance conditions. At the time of the audit, no such

conditions were noted. However, sporadic complaints are being received regarding odours

perceived to emanate from the landfill site. The gas flaring trial started in April/May 2015 and was

upgraded to a 2000 m³/hour flare which was commissioned September 2016. Together with the

bigger flare, the gas collection pipe system was also upgraded to a 400 mm ring main. The

upgraded gas flaring system and the leachate management system should aid in further reducing

gaseous odours.

3.9. Recording and reporting to the Department

Condition (a): Internal audits must be conducted quarterly in accordance with the attached EMP.

Each of the quarterly internal audit reports must be made available to the external auditor referred

below and to all relevant authorities if requested.

Finding: PC

Internal audits are conducted quarterly by Interwaste, proof of these reports were given to Prime

Resources. The internal audits are conducted in terms of the DWAF Minimum Requirements for

Waste Disposal to Landfill, 2008, the WML Gaut: 002/10-11/W0030 and the GDACE RoD Ref.

Gaut: 002/04-05/0492. As per this condition, the internal audits should also be in accordance with

the EMP.

3.13. General

Condition (c of WML and 1.4 of addendum): Interwaste must notify the Department in writing

within 24 hours (initial WML) and within 7 days (addendum), if any of the licence conditions cannot

be adhered to. Reasons for non-compliance must be attached of such written notice.

Finding: PC

The Department is not notified within 24 hours or 7 days if any condition of the WML or addendum

is not adhered to but rather after each external audit. The partial and non-compliances are

reported in the external audit report and each external audit report is submitted to the

Department within 30 days of the audit report being finalised. Any significant non-

compliances/incidents are reported as per Condition 3.7 of the WML and the conditions and

provisions of NEMA.


3 AIR QUALITY MONITORING

A gas management and monitoring system has been installed at the site. The gas flaring trial was started

in April/May 2015 and was upgraded to a 2000 m³/hour flare which was commissioned September 2016.

The gas flaring system consists of horizontal extraction wells which are connected to a 400 mm main ring

pipe that feeds into the flare. The system also contains knock out pods where landfill gas condensate is

collected and drained to the leachate dam.

The following information was made available by Interwaste. An Ambient Air Quality Assessment, including

air quality monitoring and a health risk assessment, was conducted in August 2016 with a follow up

assessment conducted in October 2016 (by GeoZone Environmental). Sampling was undertaken at 4

locations around the site and at 1 location in Midstream (Southern boundary of the Midstream Estate), for

a period of 15 days.

The results from the October 2016 sampling period revealed the following at all of the on-site monitoring

locations:

That the average ambient concentrations of Volatile Organic Compounds were below the South

African long term ambient air quality standard. Average ambient Benzene concentrations were

lower than those recorded during the previous sampling period (August 2016).

Average ambient concentrations of Ammonia were below the relevant long term Environmental

Assessment Levels (EAL).

Average ambient concentrations of Formaldehyde, Acetaldehyde, Acrolein, Propionaldehyde, n-

Butyraldehyde and Benzaldehyde were below the relevant ambient air quality reference guidelines.

The average ambient concentration of Butyraldehyde at Location 4: Northern boundary was in

excess of the long-term EAL. This may be as a result of emissions from off-site combustion

sources (vehicles) as none of the other on-site locations yielded excessive results for

Butyraldehyde.

Average ambient concentrations of Sulphur dioxide were below the South African long term

ambient air quality standard.

With the exception of Location 3: South-west corner, average ambient concentrations of Hydrogen

sulphide at all of the on-site monitoring locations were lower than those recorded during the

previous sampling period. Despite this, average ambient Hydrogen sulphide concentrations at all of

the on-site monitoring locations remained in excess of the odour detection threshold. Average

ambient concentrations of Hydrogen sulphide at Locations 1 and 2 (Leachate dam and Western site

boundary) also remain in excess of the long-term (annual) UK EAL.

The site posed a low non-cancer health risk to exposed individuals and the increased cancer risks

with chronic inhalation exposure to ambient benzene concentrations on the site were low.

Average ambient concentrations of the measured contaminant compounds at the off-site sampling

location were below the relevant long term South African ambient air quality standard and EAL. Chronic

inhalation exposure to average ambient concentrations of measured contaminants at the Southern

boundary of Midstream Estate continues to pose a low non-cancer health risk and a minimal increased

cancer risk to exposed individuals/ communities.


The study concluded that any assessment of the human health risks associated with ambient air quality

must include not only potential physiological impacts but also potential psycho-social impacts, including

odour impacts. Cognisance must therefore continue to be taken of the elevated average ambient Hydrogen

sulphide results recorded at the monitoring stations on the FG Waste Disposal Site and the potential

impacts of Hydrogen sulphide on off-site receptors. Based on the evidence collected to date, emissions of

hydrogen sulphide gas from the FG Waste Disposal Site may impact intermittently on

individuals/communities located nearby, leading to complaints about malodour.

Further to the above, additional monitoring was conducted in November 2016 by GeoZone Environmental.

No exceedance of the Hydrogen sulphide health limit was found and a substantial reduction of Hydrogen

sulphide was noted since August 2016. Average ambient Hydrogen sulphide concentrations at the

Leachate dam, W. Boundary and SW corner remain in excess of the odour detection threshold.

4 WATER QUALITY MONITORING

The objective of the ground- and surface water quality monitoring process is to monitor the composition of

these resources on an on-going basis and thereby establish whether waste disposal activities at the FG

Waste Disposal Site are exerting an impact thereon.

This section serves to satisfy condition 3.4.2, 3.4.3 and 3.4.4 of the WML to conduct bi-annual water

monitoring and is based on the requirements stipulated in the WML in terms of NEM:WA.

This section thus aims to provide the following information:

Analysis of data as compared to the South African National Standard (SANS) 241-1: 2015 Drinking

Water Standards, the Department of Water and Sanitation General Standard Limits for the

discharge of wastewater to water resources 2010, historical data and values obtained for the on-

site background boreholes;

Provide recommendations of further measures by which to maintain or improve the groundwater

quality; and

Act as an early warning system with regards to mitigating future problems and thereby assist

Interwaste with future planning.

4.1 Background

The WML indicates two types of analysis which are required for groundwater monitoring, background

(condition 3.4.3) and detection analysis (condition 3.4.4).

Baseline analysis is generally undertaken the first time a borehole is drilled at a new site and involves the

monitoring of as wide a range of chemical- macro and trace elements as possible. These constituent

concentrations then serve as a baseline (i.e. no impact from the site as yet) against which all future

constituents are compared.

Once baseline analyses has been completed, detection and background analysis is performed in order to

minimise analytical costs while still providing sufficient information upon which to initiate any further


action which may be required. For detection monitoring, emphasis will be placed on those constituents

that, according to the Minimum Requirements for Water Monitoring at Waste Management Facilities (2nd

edition, 1998), are considered to be pollution indicators for general waste disposal sites, namely

Chemical Oxygen Demand (COD), Chloride (Cl-), Nitrates (NO3- as N), Potassium (K+) and Ammonium

(NH4+ as N). In addition to this, groundwater contamination from waste disposal is typically characterised

by an enrichment of various inorganic ions i.e. SO42-,Ca2+, Mg2+, Na+, pH, Electrical Conductivity (EC).

4.2 Boreholes Utilised in the Groundwater Monitoring Network

The WML issued for the FG Waste Disposal Site indicates that groundwater monitoring should be

conducted at boreholes BH1, BH2, Dam 1, Dam 2 and Dam 3. This arrangement, however, does not

currently exist on the waste disposal site due to the continued development of the site since the WML was

issued; subsequently samples were obtained from detection monitoring boreholes: FG BH1, FG BH2, FG

BH3 (previously FG BH5) and background monitoring boreholes: FG Upstream BH1 and FG Upstream BH2.

For the locations of these boreholes refer to Figure 1.

The current borehole conditions were as follows:

FG BH1 is located within the site in close proximity to the containerised offices; the borehole is

fitted with a lockable cap (Appendix 3, Photo 11).

FG BH2 is located outside the site; the borehole is clearly demarcated, with the collar seated in

concrete and the lid is fitted with a lockable cap (Appendix 3, Photo 12).

FG BH3 is located outside the site. The borehole collar is seated in concrete and the borehole lid is

fitted with a lockable cap (Appendix 3, Photo 13).

FG Upstream BH1 is located toward the south-western corner just outside the boundary of the site.

The borehole is clearly demarcated and fitted with a lockable cap (Appendix 3, Photo 14).

FG Upstream BH2 is located toward the south-western corner just outside the boundary of the site.

The borehole is clearly demarcated and constructed with the collar capped and locked (Appendix 3,

Photo 15).

4.3 Suitability of Boreholes / Monitoring System

From the Geophysical Investigation undertaken for the FG Waste Disposal Site (by EHC (Pty) Ltd in August

2005) it was found that:

Surface drainage takes place towards the north;

The site is underlain by granite, granite-gneiss, migmatite, migmatitic gneiss and pegmatite with a

zone in which homogenous and porphyritic granodiorite also occurs; and

The geophysical investigation indicated an anomaly approximately 400 m east of the site with a

north south strike.

From the Engineering Geological Reconnaissance Investigation of portion 15 and 49 of farm Olifanstfontein

410 JR (by Knight Hall Hendry and Associates in 1993) it was found that:

A widespread occurrence of hardpan ferricrete at shallow depth indicates a perched watertable

could occur;


The relatively high watertable is in agreement with the tight rock conditions observed at the sand

quarry; and

The occurrence of ponding water in the abandoned sand quarry indicates that the granitic rock

mass is relatively impervious.

The groundwater levels on the FG Waste Disposal Site generally mimic topography and the boreholes have

not been impacted by dewatering activities from surrounding areas. Using cross sections derived from

Google Earth imagery, it is evident that the topography is more elevated in the south-west corner when

compared with the north-east corner of the site, dropping from an elevation of 1 573 metres to an

elevation of 1 551 metres. With this in mind, FG BH2 and FG BH3 are ideally positioned to be indicative of

groundwater that has migrated along a path occupied by the waste disposal cells. Boreholes FG Upstream

BH1 and FG Upstream BH2 sufficiently represent baseline groundwater quality emanating upstream of the

disposal activities. These boreholes also serve as a basis against which to compare the results from other

boreholes on-site and thus for the assessment of impacts accordingly.

4.4 Surface Water Runoff and Potable Water Monitoring

Surface water runoff on-site is monitored from a sample obtained from one of the stormwater dams; the

sample was taken from the stormwater dam to the west of the site (Appendix 3, Photo 8). A potable water

sample was also obtained from the tap at the change house.


Figure 1: Google Earth Image of the site showing the sampling points (Imagery from June 2016)


4.5 Results of Water Quality Monitoring

The samples obtained from the FG Waste Disposal Site were submitted to Aquatico Laboratories (Pty) Ltd,

a SANAS-accredited laboratory (TO374), for analysis. The results obtained are presented in the tables and

graphs to follow (Laboratory results attached as Appendix 5). SANS 241 specifies the quality of

acceptable drinking water at the point of delivery. The concentrations in the SANS 241-1: 2015 (Ed. 2)

Drinking water Part 1: Microbiological, physical, aesthetic and chemical determinants are indicated as a

standard basis for comparison, however, it should be noted that non-compliance thereto does not indicate

contamination, but rather that compliance thereto indicates water of a good quality. In addition, the limits

serve as point of reference to determine whether any pollution (i.e. significant change compared with the

baseline) is/has been occurring.

As per the conditions of the WML, the quality of the ‘Runoff’ shall comply with the quality requirements of

the General Standard, as published in Government Notice 991 of 18 may 1984, or with such quality

requirements as may from time to time be determined by the Minister. The quality of the ‘Runoff’ was thus

compared to the latest Department of Water Affairs General Standard Limits for the discharge of

wastewater to water resources, dated 2010. No water is being discharged from site; however a

representative runoff sample was taken the stormwater dam.


Table 2: Summary of results obtained for borehole and surface water samples taken from the FG Waste Disposal Site, November 2016

Site Name

Sample Season

Sample Date

Table Description

FG BH 1 FG BH 2 FG BH 3 FG Upstream

BH 1

FG Upstream

BH 2FG Potable

Water level m RWL 16.6 7.8 14.3 12.2 12.2 NA No guideline value NA No guideline value

pH pH pH 6.51 8.1 7.2 6.64 6.24 7.18 5 - 9.7 7.65 5.5-9.5

Electrical Conductivity mS/m EC 10.50 11.9 14.1 9.38 22.6 13.1 ≤ 170 134 70 above intake to a maximum of 150

Total Dissolved Solids mg/l TDS 119 95 95 73 172 107 ≤ 1200 987 No guideline value

Total Alkalinity (as CaCO3) mg CaCO3/l T.Alk 19.8 50 82.5 17 93.5 58.3 No guideline value 184.0 No guideline value

Chloride mg/l Cl- 0.996 7.07 <0.557 <0.557 2.18 <0.557 ≤ 300 75.3 No guideline value

Sulphate mg/l SO42- 8.35 15.7 <0.141 <0.141 <0.141 <0.141 ≤ 500 (health) 477.0 No guideline value

Nitrate (as N) mg/l NO3-N 3.69 0.43 0.392 1.160 0.458 1.1 ≤ 11 1.1 15

Ammonium (as N) mg/l NH4-N 0.617 0.97 3.26 0.090 0.564 0.074 ≤ 1.5 2.96 3

Calcium mg/l Ca2+ 3.41 4.38 8.56 0.616 10.8 8.61 No guideline value 120 No guideline value

Magnesium mg/l Mg2+ 1.58 2.21 4.17 0.449 5.100 2.09 No guideline value 26.3 No guideline value

Sodium mg/l Na+ 10.4 27.5 10.40 7.9 22.70 14.9 ≤ 200 139 No guideline value

Potassium mg/l K+ 2.11 1.48 2.75 1.26 5.33 1.05 No guideline value 16.5 No guideline value

Aluminium mg/l Al³⁺ <0.002 <0.002 <0.002 <0.002 <0.002 <0.002 ≤ 0.3 <0.002 No guideline value

Iron mg/l Fe²⁺ <0.004 <0.004 0.31 <0.004 0.058 <0.004 ≤ 2 (health) <0.004 0.3

Manganese mg/l Mn 1.44 0.826 0.632 <0.001 0.053 <0.001 ≤ 0.4 (health) 2.44 0.1

Total Chromium mg/l Cr- <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 ≤ 0.05 <0.003 No guideline value

Hexavalent Chromium mg/l Cr⁶⁺ <0.002 <0.002 <0.002 <0.002 <0.002 <0.002 No guideline value <0.002 0.05

Cadmium mg/l Cd <0.002 <0.002 <0.002 <0.002 <0.002 <0.002 ≤ 0.003 <0.002 0.005

Lead mg/l Pb <0.004 <0.004 <0.004 <0.004 <0.004 <0.004 ≤ 0.01 <0.004 0.01

Chemical Oxygen Demand mg/l COD 12.9 25.1 32.2 28.2 25.1 6.07 No guideline value 149 75 after removal of algae

Free Cyanide mg/l CN- <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 ≤ 0.2 <0.01 0.02

Phenols mg/l Phen <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 ≤ 0.01 0.077 0.1

Mercury mg/l Hg <0.004 <0.004 <0.004 <0.004 <0.004 <0.004 ≤ 0.006 <0.004 0.005

Boron mg/l B <0.013 <0.013 <0.013 <0.013 <0.013 <0.013 ≤ 2.4 0.155 1

Acidity (as CaCO3) mg CaCO3/l 3.54 4.42 8.46 7.82 40.3 7.82 No guideline value 11 No guideline value

Faecal Coliform Bacteria CFU/100 ml <1 Not Detected 1000

Total Coliform Bacteria CFU/100 ml <1 <10 No guideline value

Ammonia Cal mg/l NH₃ <0.005 0.052 0.023 <0.005 <0.005 <0.005 ≤ 1.5 0.053 3

Fluoride mg/l Fˉ <0.263 <0.263 <0.263 <0.263 <0.263 <0.263 ≤ 1.5 0.407 No guideline value

Storm Water

SANS 241: 2015

Target Water

Quality Range

Values highlighted in yellow exceed the SANS 241 target and values highlighted in orange exceed the National Water Act DWA 2010 guidelines- Wastewater limit applicable to discharge of

wastewater into a water resource

National Water Act General Waste

Discharge General Standards DWA 2010

Guidelines

Parameter Symbol

FG Waste Disposal Site

Sampling Points

Wet season

Nov-16

Readings for physical and chemical constituents for all samples

Unit


Table 3: Results obtained from monitoring of FG Borehole 1 from 2012 – 2016

Sampling Point

Sample Season

Sample Date

Table Description

Oct-12 May-13 Nov-13 May-14 Oct-14 May-15 Nov-15 May-16 Nov-16

Water level RWL 18.3 20 18 16.8 17 17 17 16.7 16.6 No guideline value

pH pH 6.6 6.18 6 7.29 6.54 6.15 6.76 6.06 6.51 5 - 9.7

Electrical Conductivity (mS/m) EC 9.04 8.93 7.6 9.76 7.02 8.7 8.08 10.6 10.5 ≤ 170

Total Dissolved Solids TDS 98 164 45 97 60 64 64 127 119 ≤ 1200

Total Alkalinity (as CaCO3) T.Alk 27 23 20 15.5 14.1 10.6 11 22.7 19.8 No guideline value

Chloride Cl- 2.8 4 5 0.423 4.78 1.87 7.49 3.09 0.996 ≤ 300

Sulphate SO42- 2.76 2.8 5.00 0.04 0.04 7.91 <0.287 <0,162 8.35 ≤ 500 (health)

Nitrate (as N) NO3-N 4.9 4.62 4 3.82 3.8 3.94 3.87 4.84 3.69 ≤ 11

Ammonium (as N) NH4-N 0.2 0.2 0.2 0.014 0.017 0.045 0.047 0.225 0.617 ≤ 1.5

Calcium Ca2+ 2.67 3.42 2 2.03 2.05 2.18 2.11 2.77 3.41 No guideline value

Magnesium Mg2+ 0.28 1.72 2 1.61 1.08 1.21 1.21 1.31 1.58 No guideline value

Sodium Na+ 14.6 16.6 10 6.65 10 10.5 11 13 10.4 ≤ 200

Potassium K+ 1.68 1.78 1.7 1.73 2.26 2.23 2 2.32 2.11 No guideline value

Aluminium Al³⁺ <0.003 <0.002 <0.002 <0,002 <0.002 ≤ 0.3

Iron Fe²⁺ <0.003 <0.004 <0.004 <0,004 <0.004 ≤ 2 (health)

Manganese Mn <0.001 <0.002 <0.002 <0,001 1.44 ≤ 0.4 (health)

Total Chromium Cr- 0.01 0.01 0.025 <0.001 <0.001 <0.003 <0.003 <0,003 <0.003 ≤ 0.05

Hexavalent Chromium Cr⁶⁺ 0.01 0.01 0.01 <0.002 <0.002 <0.002 <0.002 <0,002 <0.002 No guideline value

Cadmium Cd <0.003 <0.003 <0.005 <0.001 <0.001 <0.002 <0.002 <0,002 <0.002 ≤ 0.003

Lead Pb 0.01 0.01 0.02 <0.004 <0.004 <0.003 <0.003 <0,004 <0.004 ≤ 0.01

Chemical Oxygen Demand COD 16 4 10 10.6 0.082 <5.1 11.6 6.14 12.9 No guideline value

Free Cyanide CN- 0.07 0.07 0.05 <0.01 <0.01 <0.01 <0.01 <0,01 <0.01 ≤ 0.2

Phenols Phen 0.005 0.005 0.01 0.02 0.02 0.059 <0.02 0.064 <0.02 ≤ 0.01

Mercury Hg <0.003 <0.001 <0.001 <0.007 <0.007 <0.007 <0.004 <0,004 <0.004 ≤ 0.006

Boron B 0.01 0.01 0.025 0.003 0.003 0.009 0.02 <0,003 <0.013 ≤ 2.4

Acidity (as CaCO3) 9.17 33.5 30.4 12.2 51.5 3.54 No guideline value

Ammonia Cal NH₃ <0.005 ≤ 1.5

Fluoride Fˉ <0.263 ≤ 1.5

SANS 241: 2015

Target Water

Quality Range

Values highlighted in yellow exceed the SANS 241 target

FG BH 1

Wet Season

Nov-16

Readings for physical and chemical constituents since 2012

Parameter (measured in mg/l

unless otherwise specified)Symbol

Sampling Date (Results in mg/l)



Sampling Point

Sample Season

Sample Date

Table Description


Water level RWL 18.1 40 20 10.4 9 9 8.9 6.9 7.8 No guideline value

pH pH 8.08 7.13 7.4 8.1 7.93 7.59 7.46 8.51 8.1 5 - 9.7

Electrical Conductivity (mS/m) EC 14.8 14.4 13.9 14.1 13.5 15.5 15.1 14.3 11.9 ≤ 170

Total Dissolved Solids TDS 118 86 83 80 82 87 81 95 ≤ 1200

Total Alkalinity (as CaCO3) T.Alk 84 76 72 81.6 68.2 72.5 73.5 68.1 50 No guideline value

Chloride Cl- 3.4 4 5 0.423 5.24 1.68 7.39 4.27 7.07 ≤ 300

Sulphate SO42- 2.64 2.7 5.00 0.04 0.04 2.01 <0.287 0.821 15.7 ≤ 500 (health)

Nitrate (as N) NO3-N 0.1 0.2 0.20 0.289 0.252 <0.118 0.289 0.391 0.43 ≤ 11

Ammonium (as N) NH4-N 0.65 0.5 0.989 0.826 1.09 0.984 1.32 0.97 ≤ 1.5



Sodium Na+ 21.6 25.3 17 17.2 19 18.1 19.1 23.7 27.5 ≤ 200

Potassium K+ 1.46 1.64 1.4 1.99 2.3 2.12 1.95 2.2 1.48 No guideline value

Aluminium Al³⁺ <0.003 <0.002 <0.002 <0,002 <0.002 ≤ 0.3

Iron Fe²⁺ <0.003 <0.004 <0.004 <0,004 <0.004 ≤ 2 (health)

Manganese Mn 0.297 0.267 0.317 <0,001 0.826 ≤ 0.4 (health)

Total Chromium Cr- 0.01 0.025 <0.001 <0.001 <0.003 <0.003 <0,003 <0.003 ≤ 0.05

Hexavalent Chromium Cr⁶⁺ 0.01 0.01 <0.002 <0.002 <0.002 <0.002 <0,002 <0.002 No guideline value

Cadmium Cd <0.003 <0.005 <0.001 <0.001 <0.002 <0.002 <0,002 <0.002 ≤ 0.003

Lead Pb 0.01 0.02 <0.004 <0.004 <0.003 <0.003 <0,004 <0.004 ≤ 0.01

Chemical Oxygen Demand COD 12 16 10 15.1 0.082 21.1 21.5 21.7 25.1 No guideline value

Free Cyanide CN- 0.07 0.05 <0.01 <0.01 <0.01 <0.01 <0,01 <0.01 ≤ 0.2

Phenols Phen 0.005 0.01 0.02 0.022 0.093 <0.02 0.046 <0.02 ≤ 0.01

Mercury Hg 0.001 0.001 <0.007 <0.004 <0.007 <0.004 <0,004 <0.004 ≤ 0.006

Boron B 0.01 0.025 0.025 0.003 0.027 0.036 <0,003 <0.013 ≤ 2.4

Acidity (as CaCO3) 7.14 7.54 8.58 18.4 <0,001 4.42 No guideline value

Ammonia Cal NH₃ 0.052 ≤ 1.5




SANS 241: 2015

Target Water

Quality Range

Sampling Date (Results in mg/l)


FG BH 2

Wet Season

Nov-16




Sampling Point

Sample Season

Sample Date

Table Description


Water level RWL 14.2 30 15 12.6 13 13 13.7 14.03 14.3 No guideline value

pH pH 7.39 6.78 6.9 6.85 7.07 6.89 7.02 6.9 7.2 5 - 9.7

Electrical Conductivity (mS/m) EC 32.5 23.4 21.1 14.9 13 13.4 14.2 15.4 14.1 ≤ 170

Total Dissolved Solids TDS 162 168 96 98 104 95 90 96 95 ≤ 1200

Total Alkalinity (as CaCO3) T.Alk 167 119 108 80.3 82.7 76.4 70.8 80.4 82.5 No guideline value

Chloride Cl- 5.4 5 5 0.423 4.62 2.31 8.23 1.87 <0.557 ≤ 300

Sulphate SO42- 2.32 3.2 5 0.04 0.04 1.69 <0.287 <0,162 <0.141 ≤ 500 (health)

Nitrate (as N) NO3-N 0.1 0.11 0.2 0.29 0.224 <0.118 0.146 0.437 0.392 ≤ 11

Ammonium (as N) NH4-N 7.12 7.9 1.94 1.62 1.47 2.36 2.8 3.26 ≤ 1.5



Sodium Na+ 13.6 15.1 10 5.79 7.59 8.6 9.27 10.2 10.4 ≤ 200

Potassium K+ 5.19 4.73 4.1 3.62 2.89 2.8 3.14 2.81 2.75 No guideline value

Aluminium Al³⁺ <0.003 <0.002 <0.002 <0,002 <0.002 ≤ 0.3

Iron Fe²⁺ 7.88 0.517 5.75 5.97 0.31 ≤ 2 (health)

Manganese Mn 1.01 0.953 0.893 0.948 0.632 ≤ 0.4 (health)

Total Chromium Cr- 0.01 0.01 0.025 <0.001 <0.001 <0.003 <0.003 <0,003 <0.003 ≤ 0.05

Hexavalent Chromium Cr⁶⁺ 0.01 0.01 0.01 <0.002 <0.002 <0.002 <0.002 <0,002 <0.002 No guideline value

Cadmium Cd <0.003 <0.003 <0.005 <0.001 <0.001 <0.002 <0.002 <0,002 <0.002 ≤ 0.003

Lead Pb 0.01 0.01 0.02 <0.004 <0.004 <0.003 <0.003 <0,004 <0.004 ≤ 0.01

Chemical Oxygen Demand COD 152 36 10 26 0.082 <5.1 13 9.19 32.2 No guideline value

Free Cyanide CN- 0.07 0.07 0.05 0.01 0.01 <0.01 <0.01 <0,01 <0.01 ≤ 0.2

Phenols Phen 0.005 0.005 0.01 0.02 0.154 0.038 <0.02 0.039 <0.02 ≤ 0.01

Mercury Hg <0.001 <0.001 <0.001 <0.007 <0.007 <0.007 <0.004 <0,004 <0.004 ≤ 0.006

Boron B 0.01 0.01 0.025 0.009 0.003 0.01 0.02 <0,003 <0.013 ≤ 2.4


Ammonia Cal NH₃ 0.023 ≤ 1.5



FG BH 3

Wet Season

Nov-16


Sampling Date Parameter (measured in mg/l

unless otherwise specified)

SANS 241: 2015

Target Water

Quality Range

Symbol


Table 6: Results obtained from monitoring of FG Upstream Borehole 1 from 2014 – 2016

Sampling Point

Sample Season

Sample Date

Table Description

May-14 Oct-14 May-15 Nov-15 May-16 Nov-16

Water level RWL 11.5 15.8 15.8 12.1 11.9 12.2 No guideline value

pH pH 6.68 7.47 6.44 6.52 6.68 6.64 5 - 9.7

Electrical Conductivity (mS/m) EC 7.11 4.08 4.99 3.95 5.05 9.38 ≤ 170

Total Dissolved Solids TDS 66 24 37 33 70 73 ≤ 1200

Total Alkalinity (as CaCO3) T.Alk 15.1 12.6 17.1 6.66 14.9 17 No guideline value

Chloride Cl- 0.423 4.48 <0.233 5.05 3.54 <0.557 ≤ 300

Sulphate SO42- 0.04 0.04 1.89 <0.287 0.495 <0.141 ≤ 500 (health)

Nitrate (as N) NO3-N 0.81 0.434 0.428 0.462 0.943 1.16 ≤ 11

Ammonium (as N) NH4-N 0.021 0.025 0.096 0.091 0.119 0.09 ≤ 1.5

Calcium Ca2+ 0.973 0.558 0.604 0.335 0.479 0.616 No guideline value

Magnesium Mg2+ 0.546 0.37 0.471 0.264 0.371 0.449 No guideline value

Sodium Na+ 5.85 6.96 7.14 6.2 7.45 7.87 ≤ 200

Potassium K+ 1.48 1.38 1.46 1.29 1.33 1.26 No guideline value

Aluminium Al³⁺ <0.003 <0.002 <0.002 <0,002 <0.002 ≤ 0.3

Iron Fe²⁺ <0.003 <0.004 <0.004 0.402 <0.004 ≤ 2 (health)

Manganese Mn <0.001 <0.002 <0.002 <0,001 <0.001 ≤ 0.4 (health)

Total Chromium Cr- <0.001 <0.001 <0.003 <0.003 <0,003 <0.003 ≤ 0.05

Hexavalent Chromium Cr⁶⁺ <0.002 <0.002 <0.002 <0.002 <0,002 <0.002 No guideline value

Cadmium Cd <0.001 <0.001 <0.002 <0.002 <0,002 <0.002 ≤ 0.003

Lead Pb <0.004 <0.004 <0.003 <0.003 <0,004 <0.004 ≤ 0.01

Chemical Oxygen Demand COD 64.2 0.082 <5.1 11.6 <5,1 28.2 No guideline value

Free Cyanide CN- <0.01 <0.01 <0.01 <0.01 <0,01 <0.01 ≤ 0.2

Phenols Phen 0.020 0.020 0.078 <0.02 0.038 <0.02 ≤ 0.01

Mercury Hg <0.007 <0.007 <0.007 <0.004 <0,004 <0.004 ≤ 0.006

Boron B 0.003 0.003 0.006 0.015 <0,003 <0.013 ≤ 2.4





Sampling Date

FG Upstream BH1

Wet Season

Nov-16




SANS 241: 2015

Target Water

Quality Range


Table 7: Results obtained from monitoring of FG Upstream Borehole 2 from 2014 – 2016

Sampling Point

Sample Season

Sample Date

Table Description


Water level RWL 10.8 11 11 12.2 11.77 12.2 No guideline value

pH pH 6.37 7.84 6.19 6.12 6.11 6.24 5 - 9.7

Electrical Conductivity (mS/m) EC 15.7 14.7 18.4 19.1 20.5 22.6 ≤ 170

Total Dissolved Solids TDS 146 90 126 145 195 172 ≤ 1200

Total Alkalinity (as CaCO3) T.Alk 73.1 75.4 92.2 90.9 108 93.5 No guideline value

Chloride Cl- 0.423 5.02 1.45 7.91 3.31 2.18 ≤ 300

Sulphate SO42- 0.04 0.04 1.94 <0.287 <0,162 <0.141 ≤ 500 (health)

Nitrate (as N) NO3-N 0.261 0.427 0.73 0.216 0.535 0.458 ≤ 11

Ammonium (as N) NH4-N 0.068 0.02 0.03 0.059 0.16 0.564 ≤ 1.5

Calcium Ca2+ 8.36 8.86 10.4 9.95 11.5 10.8 No guideline value

Magnesium Mg2+ 3.65 3.86 5.01 4.62 5.14 5.1 No guideline value

Sodium Na+ 16.4 19.4 19.7 20.8 23.2 22.7 ≤ 200

Potassium K+ 4.16 5.28 5.11 4.93 5.05 5.33 No guideline value

Aluminium Al³⁺ <0.003 <0.002 <0.002 <0,002 <0.002 ≤ 0.3

Iron Fe²⁺ <0.003 <0.004 <0.004 <0,004 0.058 ≤ 2 (health)

Manganese Mn 0.021 <0.002 <0.002 0.038 0.053 ≤ 0.4 (health)

Total Chromium Cr- <0.001 <0.001 <0.003 <0.003 <0,003 <0.003 ≤ 0.05

Hexavalent Chromium Cr⁶⁺ <0.002 <0.002 <0.002 <0.002 <0,002 <0.002 No guideline value

Cadmium Cd <0.001 <0.001 <0.002 <0.002 <0,002 <0.002 ≤ 0.003

Lead Pb <0.004 <0.004 <0.003 <0.003 <0,004 <0.004 ≤ 0.01

Chemical Oxygen Demand COD 19.1 9.78 <5.1 12.3 28.5 25.1 No guideline value

Free Cyanide CN- <0.01 <0.01 <0.01 <0.01 <0,01 <0.01 ≤ 0.2

Phenols Phen 0.020 0.020 0.126 <0.02 0.035 <0.02 ≤ 0.01

Mercury Hg <0.004 <0.004 <0.007 <0.004 <0,004 <0.004 ≤ 0.006

Boron B <0.003 <0.003 0.006 0.016 <0,003 <0.013 ≤ 2.4

Acidity (as CaCO3) 32.6 27.2 55.1 138 265 40.3 No guideline value




unless otherwise specified)

Sampling Date


FG Upstream BH2

Wet Season

Nov-16


Symbol

SANS 241: 2015

Target Water

Quality Range


Table 8: Results obtained from monitoring of Surface Water from 2014 – 2016

Sampling Point

Sample Season

Sample Date

Table Description

Stormwater

Dam

Stormwater

Dam

Stormwater

Dam

Stormwater

drain

leaving site

Stormwater

drain that leaves

the site

Stormwater

Dam


pH pH 8.08 8.81 7.83 7.17 7.27 7.65 5.5-9.5

Electrical Conductivity (mS/m) EC (mS/m) 142 212 32 131 551 134 70 above intake to a maximum of 150

Total Dissolved Solids TDS 844 1487 205 1056 4302 987 No guideline value

Total Alkalinity (as CaCO3) T.Alk 701 512 86 101 276 184 No guideline value

Chloride Cl- 66.4 314 12.4 33 355 75.3 No guideline value

Sulphate SO42- (mg/l) 3.66 323 69 593 2465 477 No guideline value

Nitrate (as N) NO3-N 0.248 0.324 0.816 2.18 1.38 1.1 15

Ammonium (as N) NH4-N 14.4 0.104 0.408 0.104 0.217 2.96 3

Calcium Ca2+ 121 51.1 36.1 152 448 120 No guideline value

Magnesium Mg2+ 38.4 82.3 9.67 11.6 116 26.3 No guideline value

Sodium Na+ 97.2 275 13.2 128 670 139 No guideline value

Potassium K+ 52.8 123 5.87 14.5 47.4 16.5 No guideline value

Aluminium Al³⁺ <0.015 <0.002 <0.002 0.302 <0.002 No guideline value

Iron Fe²⁺ <0.003 <0.004 <0.004 0.854 <0.004 0.3

Manganese Mn 0.022 0.417 0.783 1.97 2.44 0.1

Total Chromium Cr- <0.001 <0.001 <0.003 <0.003 <0,003 <0.003 No guideline value

Hexavalent Chromium Cr⁶⁺ <0.002 <0.002 <0.002 <0.002 <0,002 <0.002 0.05

Cadmium Cd <0.001 <0.001 <0.002 <0.002 <0,002 <0.002 0.005

Lead Pb <0.004 <0.004 <0.003 <0.003 <0,004 <0.004 0.01

Chemical Oxygen Demand COD (mg/l) 385 264 58.5 76.3 4603 149 75 after removal of algae

Free Cyanide CN- <0.01 <0.01 <0.01 <0.01 <0,01 <0.01 0.02

Phenols Phen 0.46 0.090 0.107 0.04 0.317 0.077 0.1

Mercury Hg <0.007 <0.007 <0.007 <0.004 <0,004 <0.004 0.005

Boron B 0.964 2.26 0.085 0.145 0.305 0.155 1

Acidity (as CaCO3) 19.9 0.001 4.55 16.1 105 11 No guideline value

Ammonia Cal NH₃ 0.053 3

Fluoride Fˉ 0.407 No guideline value

NWA General Waste Discharge

General Standards DWA 2010

Guidelines

Sampling Date

Values highlighted in orange exceed the National Water Act DWA 2010 guidelines- Wastewater limit applicable to discharge of wastewater into a water resource

Stormwater Dam / Stormwater drain that leaves the site

Wet Season

Nov-16





Table 9: Results obtained from monitoring of FG Potable Water from 2014 – 2016

Sampling Point

Sample Season

Sample Date

Table Description

Oct-14 May-15 Nov-15 May-16 Nov-16

pH pH 7.43 7.51 7.27 7.71 7.18 5 - 9.7

Electrical Conductivity (mS/m) EC 9.76 11.8 11.8 13.9 13.1 ≤ 170

Total Dissolved Solids TDS 60 90 87 159 107 ≤ 1200

Total Alkalinity (as CaCO3) T.Alk 44.7 54.2 40.8 54 58.3 No guideline value

Chloride Cl- 4.55 0.668 5.88 6.08 <0.557 ≤ 300

Sulphate SO42-

0.04 2.23 <0.287 11.2 <0.141 ≤ 250 (aesthetic)

Nitrate (as N) NO3-N 1.04 1.11 1.06 1.39 1.1 ≤ 11

Ammonium (as N) NH4-N 0.013 0.023 0.024 0.086 0.074 ≤ 1.5

Calcium Ca2+7.64 8.7 7.48 12.5 8.61 No guideline value

Magnesium Mg2+1.7 2.45 1.67 2.71 2.09 No guideline value

Sodium Na+12.7 11.6 12.9 13.5 14.9 ≤ 200

Potassium K+1.12 2.19 0.957 1.94 1.05 No guideline value

Aluminium Al³⁺ <0.003 <0.002 <0.002 <0,002 <0.002 ≤ 0.3

Iron Fe²⁺ <0.003 <0.004 <0.004 <0,004 <0.004 ≤ 0.3

Manganese Mn <0.001 <0.002 <0.002 <0,001 <0.001 ≤ 0.1

Total Chromium Cr-<0.001 <0.003 <0.003 <0,003 <0.003 ≤ 0.05

Hexavalent Chromium Cr⁶⁺ <0.002 <0.002 <0.002 <0,002 <0.002 No guideline value

Cadmium Cd <0.001 <0.002 <0.002 <0,002 <0.002 ≤ 0.003

Lead Pb <0.004 <0.003 <0.003 <0,004 <0.004 ≤ 0.01

Chemical Oxygen Demand COD 25.6 <5.1 <5.1 20.6 6.07 No guideline value

Free Cyanide CN-<0.01 <0.01 <0.01 <0,01 <0.01 ≤ 0.2

Phenols Phen 0.023 0.041 <0.02 0.035 <0.02 ≤ 0.01

Mercury Hg <0.007 <0.007 <0.004 <0,004 <0.004 ≤ 0.006

Boron B 0.003 0.005 0.013 <0,003 <0.013 ≤ 2.4

Acidity (as CaCO3) 16.7 3.06 9.47 13.5 7.82 No guideline value

Faecal Coliform Bacteria (CFU/100 ml) <1 <1 <1 <1 <1 Not detected

Total Coliform Bacteria (CFU/100 ml) <1 <1 <1 1 <1 ≤10



Potable Water

Wet Season

Nov-16





Sampling Date SANS 241: 2015

Target Water Quality Range


4.6 Discussion of Monitoring Results

Graphs illustrating the trends noted for individual constituents at each borehole since monitoring began

are presented below:







The majority of the constituents monitored for the background, as well as the monitoring boreholes

recorded concentrations that are compliant with the SANS 241 Standard Limits. The indicators of pollution

due to waste disposal activities (such as excessive levels of COD, Cl-, NO3 as N, K+, NH4+ as N, SO4

2-,

Ca2+, Mg2+, Na+ and increased pH and EC) for the detection monitoring boreholes compared favourably

with those noted for the background monitoring boreholes and the SANS 241 Standard Limits.

The sulphate, ammonium and manganese concentrations are higher in the monitoring boreholes than in

the background monitoring boreholes. The concentration of manganese and sulphate in boreholes FG BH1

and FG BH 2 has increased since May 2016 and the manganese concentration exceeds the SANS 241

Standard Limit in boreholes FG BH1, FG BH 2, and FG BH3. Elevated concentrations were not noted in the

background monitoring boreholes (FG Upstream BH1 and FG Upstream BH 2), but were found in the

stormwater dam (runoff water from the site) and in the leachate and leakage detection sump. Manganese

is commonly found in gravels and rocks, principally in an insoluble form and there is a potential that the

sand washing plant adjacent to the site may be having an impact on the borehole quality. However, since

the concentrations of sulphate, ammonium and manganese in FG BH1, FG BH2, and FG BH3 are higher

than the background monitoring boreholes, it is recommended that a cross check is done for these

samples using two laboratories during the next monitoring period. The sulphate, ammonium and

manganese must be noted and checked and if the concentrations remain elevated and higher than the

background boreholes, additional investigations should be undertaken in order to identify the potential

cause. Purging of the boreholes will also be investigated during the next monitoring season.

The monitoring results for borehole FG BH 3 showed concentrations of ammonium (3.26 mg/l in November

2016 which increased slightly from 2.8 mg/l in May 2016), iron (0.31 mg/l in November 2016 which

decreased from 5.97 mg/l in May 2016) and manganese (0.632 mg/l in November 2016 which decreased

from 0.948 mg/l in May 2016), extending above the SANS 241 Standard Limits, however, this has been

noted over the long-term. The concentration of ammonium has been increasing gradually since May 2015.

Borehole FG BH 1 again displayed a higher nitrate concentration than the other boreholes; however the

concentration did not show much deviation from the historical results recorded.

During the May 2016 monitoring period the iron concentration recorded for FG Upstream BH1 was high

and considered irregular, as FG Upstream BH1 and FG Upstream BH2 are located in close proximity to one

another and FG Upstream BH2 did not reflect any increase in iron concentration. The concentration of iron

recorded for FG Upstream BH1 during this monitoring period has now decreased and falls below the SANS

241 Standard Limits.

The concentrations of phenols have decreased since May 2016, and phenol concentrations for all boreholes

are now below the SANS 241 Standard Limits.

From the conditions of the Waste Management Licence for the FG Waste Disposal Site, condition 3.3.4.

“Commissioning and construction of the activity”, states that:

e) Works shall be constructed and maintained on a continuous basis by Interwaste (Pty) Ltd to

divert and drain from the working face of the site, all runoff water arising on the site, which could

be expected as a result of the estimated maximum precipitation and to prevent such runoff water


from coming into contact with leachate from the site. Such works shall, under the said rainfall

event, maintain a freeboard of half a metre.

f) Runoff water referred to in condition 3.3.4(e) shall comply with the quality requirements of the

General Standard, as published in Government Notice 991 of 18 May 1984, or with such quality

requirements as may from time to time be determined by the Minister and must be drained from

the site in a legal manner.

g) Runoff water referred to in condition 3.3.4 (f) which does not comply with the quality requirements

as set by DWA and all sporadic leachate from the site must: (i) be treated to comply with the

aforementioned standard and discharged in a legal manner, and/ or (ii) with the written approval

of the Responsible Authority be evaporated in dams and/ or be evaporated by spraying over those

portions of the site which comply with the requirements set in condition 3.3.4(b).

Any water from the stormwater drains on site is now directed to the new stormwater dam. No water will

leave the site without it first being tested. The plan is to use this water for additional dust suppression. A

sample was collected from the stormwater dam near Phase 2. The quality of the stormwater was

compared to the latest Department of Water and Sanitation General Standard Limits for the discharge of

wastewater to water resources, dated 2010. The following parameters exceed the general standard limit:

manganese (2.44 mg/l vs 0.1 mg/l) and chemical oxygen demand (149 mg/l vs 75 mg/l).

The concentrations for faecal coliform bacteria and total coliform bacteria in the potable water sampled

both fell below the detection limits of 1, where the SANS 241 Standard Limit for faecal coliform bacteria is

0 and for total coliform bacteria is ≤10. The other parameters analysed in the potable water fell below the

SANS 241 Standard Limit. The filtration system is thus functioning effectively and the water is considered

safe for potable use.


5 CONCLUSION

The FG Waste Disposal Site is generally well managed and obtained an overall score of 98.3 % which is

similar to the previous audit score (98%). The majority of issues raised at the previous audit have been

addressed. The upgrades to the leachate management system have reduced the odours on site and the

upgraded gas management and monitoring system is also now operational which should aid in further

reducing gaseous odours.

The issues identified during this audit relate to the unsafe excavation where cover material is being

removed from Phase 3. This excavation has not been barricaded and the side slopes are very steep. It is

recommended that the area be barricaded and the angle of repose checked by a suitably qualified person.

Signs of erosion were noted on portions of the outer slopes of Phase 2 and soil saver and hydroseeding

should be implemented. Sporadic complaints are being received regarding odours perceived to emanate

from the landfill site.

The groundwater qualities on-site are largely compliant with the SANS 241 Standard Limits. The current

results however show an increase in the concentration of manganese and sulphate in boreholes FG BH 1

and FG BH2. It is recommended that a cross check is done on for the monitoring borehole samples using

two laboratories during the next monitoring period. The sulphate, ammonium and manganese must be

noted and checked and if the concentrations remain elevated and higher than the background boreholes,

additional investigations should be undertaken in order to identify the potential cause. Purging of the

boreholes will also be investigated during the next monitoring season.

Now that the Landfill Gas Project is operational, the site should also be audited in term of the National

Standards for Extraction, Flaring or Recovery of Landfill Gas (GNR924 of 2013) and the Environmental

Management Programme (EMP) needs to be revised to include the gas management and monitoring

system.

[Electronic signatures omitted for security purposes]

Compiled by: Reviewed by:

Louise Jones Jonathan van de Wouw

Environmental Scientist Principal Environmental Scientist

Prime Resources (Pty) Ltd Prime Resources (Pty) Ltd

APPENDIX 1

MINIMUM REQUIREMENTS/

NORMS AND STANDARDS CHECKLIST

PA Previous Audit

C Compliant

NC Non-compliant

PC Partial Compliance

No. Item PA C/NC/PC Comment Audit Score Total Score

1 Signposting

1.1Signs in appropriate official languages indicating Route and distance to the

landfill site from nearest main roadC C There is sufficient signage available in English, on each side of the Olifantsfontein road at the site entrance. 1 1

1.2 Sign at entrance indicating in appropriate official languages: C CThere is a large site notice board at the main entrance, this notice board details information in two appropriate official

languages. (Appendix 3, Photo 1).0.5 0.5

1.2.1 Contact details of Permit holder and Responsible person C CThe large sign at the entrance states the name and contact details of the permit holder, and the responsible person, Mr

Marius Conradie. Mr P. Pretorius, who is the site supervisor, is now listed under "contact person" (Appendix 3, Photo 1).1 1

1.2.2 Hours of operation C CThe site is operated 24 hours a day although the operating hours as per the site notice board are between 07h00-17h00 Mon-

Fri and 07h00-17h00 on Saturdays, Sundays and public holidays (Appendix 3, Photo 1).1 1

1.2.3 Emergency telephone number C C The contact persons number is indicated on the site notice board at the entrance of the landfill site. (Appendix 3, Photo 1). 2 2

1.2.4 Class of landfill C C The class of the landfill is indicated on the notice board at the entrance (GLB+ landfill) (Appendix 3, Photo 1). 2 2

1.2.5 Types of permissible and non-permissible waste C C The site notice board indicates the non-permissible waste types (Appendix 3, Photo 1). 2 2

1.2.6 Disposal of non-permissible waste is illegal and can lead to prosecution C C No illegal loads were reported since the previous audit 1 1

2 Road access

2.1Road access maintained to accommodate vehicles that normally utilise the

facilityC C

The entrance to the site at the D2543 intersection has been paved (Appendix 3, Photo 2). Interwaste intends to tar the

remaining section of the access road from the intersection at Olifantsfontein Road to the entrance of the landfill site. This will

be beneficial in terms of ease of access and dust control. The gravel public access road was in a good condition and had

recently been watered.

1 1

2.2 Roads to be surfaced, enabling waste disposal in all weather conditions C CInternal roads were in a good condition and had recently been watered. The road surfaces have been stabilised and are

suitable to enable waste disposal in all weather conditions.1.5 1.5

2.3 Two way traffic possible in all weather conditions C CThe roads currently being utilised within the landfill site are wide enough for bi-directional traffic flow, however vehicles

entering the site now follow a one directional ring road.1 1

2.4 Roads watered in aid of dust control, with no mud formation PC CA water cart was in operation at the time of the audit (Appendix 3, Photo 3). Stormwater is used for dust suppression and little

mud was noted. 2 2

Sub-Total for Section 16.0 16.0

Landfill Site: Interwaste, FG Landfill Site

CHECKLIST - MINIMUM REQUIREMENTS/ NORMS AND STANDARDS

Audit Date: Wednesday 23 November 2016

Department of Water Affairs & Forestry, Second Edition, 1998. Waste

Management Series. Minimum Requirements for Waste Disposal by Landfill -

Section 10 "Landfill Operation"

National Environmental Management: Waste Act 59 of 2008- National Norms

and Standards for Disposal of Waste to Landfill (GNR636 of 2013)

Ref.

A. FACILITY


1 Waste acceptance procedure

1.1 Waste inspected prior to acceptance by qualified staff C C

Weighbridge operators inspect the trucks entering the site for waste that is not permitted to be disposed of on the site. The

weighbridge operators are adequately trained to identify non-permissible waste loads. Additionally, spotters on the working

face are trained to identify illegal waste loads.

2 2

1.2 Hazardous waste diverted to appropriate landfill site C COnly general and delisted hazardous waste are allowed to be discarded at this landfill, hazardous waste is not accepted and

no instances of non-permissible disposal occurred for the reporting period.2 2

1.3 Waste disposal tariffs displayed on notice board C CUp to date waste disposal tariffs, valid until the 30th June 2017, are displayed on the site notice board at the main entrance of

the landfill (Appendix 3, Photo 4). .1 1

2 Fencing

2.1 Fences - 1.8m high with an overhang C C There is a precast concrete wall in place that is taller than 1.8m. The wall surrounds the entire perimeter of the landfill site. 1 1

2.2 Site boundary adequately fenced and clearly marked C C A wall surrounds the entire perimeter of the landfill site. 1 1

3 Control of vehicle access

3.1 Single vehicle controlled entrance C C

The main entrance to the landfill is access controlled with a boom which is manned by security personnel (Appendix 3, Photo

5); other entrances were identified at the workshop, the visitors parking, the Midrand Logistics facility and near the leachate

dam. The other entrances are not for general use and are kept locked. There is also a gate at the main entrance which is

closed at night to further enhance access control.

1 1

3.2 Security staff at gate C CThere is a security tower on site, four armed guards and a supervisor are present 24 hours a day. PRSS Security is the

security company employed at the site.1 1

3.3 Lockable gate, manned during operating hours C C

The main access gate is lockable and is manned by a security guard throughout operating hours, additionally there is a boom

present. The site is operated 24 hours a day although the operating hours as per the site notice board are between 07h00-

17h00 Mon-Fri and 07h00-17h00 on Saturdays, Sundays and public holidays. (Appendix 3, Photo 1).

1 1

4 Operating plan

4.1 Copy on site C CThe plans are dynamic, a copy of the current operational plan is available in the office on site and the copy of the latest survey

was provided to the auditors.1 1



1 Services

1.1 Water C C Potable water is supplied from boreholes located on site, with water being filtered before use. 1 1

1.2 Sewerage C C A Biological Waste Treatment Plant is used to treat the sewage arising on-site (Appendix 3, Photo 6). 1 1

1.3 Electricity C C The site has electricity supplied by Eskom. 1 1

1.4 Telephone services C C Neotel is used as a service provider, otherwise cellphones are used. 1 1

1.5 Site office C C There are containerised offices which are neat and tidy. 1 1

2 Weighbridge

2.1 Signpost: Waste disposal tariffs C C There is a sign at the weighbridge which indicates the waste disposal tariffs. 1 1

2.2 Collection of waste disposal tariffs C C Small loads are paid in cash or by account. 1 1

C. RESOURCES

B. CONTROLS

3 Plant and Equipment

3.1 Purpose-built landfill compactors, bulldozer and front-end loader. C COne compactor was noted at the time of the audit on the Phase 2 working face (Appendix 3, Photo 7). An excavator was also

in use.2 2

3.2 Vehicle to transport cover material C C Cover material is transported around site using an Articulated Dump Truck. 1 1

3.3 Storage facilities C CThere is a general workshop as well as various containers used for storage throughout the yard area. All hydrocarbon

containers are being stored in bunded areas at the workshop.1 1

3.4 Back-up equipment and operating staff C CInterwaste own their plant. If backup equipment is required it is supplied by an external company that rents plant and

equipment to the landfill site. There are internal back-up staff and backup managers, when required.2 2

3.5 Equipment in good repair, not causing noise and air pollution C CAll equipment appears to be in an acceptable condition. Repairs and routine maintenance regularly conducted by an external

plant hiring company. Service dates and records were viewed by the auditors.1 1

4 Staff

4.1 Responsible/ managerial person on duty C C Mr Marius Conradie (responsible site manager) and P Pretorius (site supervisor) were present. 1 1

4.2 Support staff C C Mr Marius Conradie indicated that there a 25 - 38 staff members on site at any given time. 1 1

4.2.1 Suitably qualified C CMr Marius Conradie indicated that the staff members have received adequate training. Training includes fire fighting, spill

response, environmental awareness, PPE usage and weekly Toolbox talks on various topics.1 1

4.2.2 Back-up staff C C There are internal back-up staff and backup managers. 1 1

4.2.3 Occupational Health & Safety measures in place C C A copy of the Healthy and Safety policy is available in the office. 1 1

4.2.4 Protective clothing (PPE) C C Staff are issued with PPE, staff members were seen wearing PPE such as: safety boots, safety vests and overalls . 1 1



1 Compaction and daily cover of waste

1.2Purpose built compactor in use- Compaction is best achieved if the waste is

spread in thin layers and compacted by a purpose-built landfill compactor.C C One compactor was noted at the time of the audit on the Phase 2 working face (Appendix 3, Photo 7). 1 1

1.3

Waste should be fully covered at the end of each working day (A minimum

thickness equivalent to the effective covering of 150mm of compacted soil is

required).

C CWaste is covered at 3pm daily or immediately for special loads. Only Phase 2 was in use at the time of the audit. The cover

thickness of previously covered areas was considered adequately and wind blown litter was not an issue.2 2

1.4 Three days cover stockpile available, close to working face C CCurrently there is sufficient cover material from the building rubble that is brought to site as well as from material excavated

from future cell developments.1 1

1.5 Two week cell capacity C C The current working phase has sufficient capacity for well over two weeks. 1 1

1.6 End tipping prohibited C C Noted and compliant 1 1

1.7 Protection of unsafe excavations PC PC

Cover material is being excavated from Phase 3 and safety in this area was a concern as the excavation has not been

barricaded and the side slopes are very steep. The area should be barricaded and the angle of repose checked by a suitably

qualified person.

0.5 1

2 Wet weather cell

2.1 Location close to entrance and all weather roads C C 1 1

2.2 One week capacity C C 1 1

D. LANDFILL OPERATION

Phase 2 is currently being utilised as the wet weather cell as it is near the site entrance and easily accessible in all weather

conditions. The cell has sufficient capacity as required.

3 Leachate

3.1

Limit leachate generation to 200 mm/year over the area of the waste body, or

to a figure for which the leachate treatment capacity may be designed, which

will ensure socially and environmentally acceptable conditions. It may only be

exceeded if it can be shown that the overall design of the landfill, the leachate

management system and the leachate treatment system can easily

accommodate this flow.

C C

Leachate is contained in the leachate dam, which is covered by an HDPE liner to limit bad odours emanating off the dam.

Leachate is then pumped from the dam through a treatment system, where it is dosed with hydrogen peroxide and ferrous

sulphate. The treated leachate is then pumped into a truck and taken to ERWAT for further treatment and discharge.

Approximately 90 000 L are pumped and treated per day.

1 1

3.2 Sporadic leachate reporting NA NAA permanent leachate drainage, collection and management system is in place as described above. Leachate is sampled and

analysed weekly by the on site laboratory.- -

3.3

Co-disposal (Solid and liquid waste)- Co-disposal of solid and liquid waste

must only occur at sites with a leachate management system which can

contain, extract and preferably treat the resultant leachate flow.

C CA permanent leachate drainage, collection and management system is in place. Co-disposal is happening on Phase 2

(acceptable considering the lining requirements), waste is covered at 3 pm daily or immediately for special loads.1 1

3.3.1 Cells appropriately lined C C

The cell that is utilised for the disposal of general waste only (Phase 1), has not been lined because it was constructed prior to

the implementation of such requirements. Phase 1 is currently not in use. The cells utilised for the disposal of delisted

hazardous waste have been lined with appropriate non-permeable geomembranes. Phase 2 is currently in use and Phase 4 is

being constructed. Refer to the National Norms and Standards below, which describe the specific liner requirements for each

cell

2 2

3.3.2Leachate management system to collect and drain leachate to a point where it

can be extracted for treatment.C C

The leachate management system has improved since the previous audit. Leachate is contained in the leachate dam, which

is covered by a HDPE liner to limit the nuisance odours emanating off the dam. Leachate is then pumped from the dam

through a treatment system, where it is dosed with hydrogen peroxide and ferrous sulphate. The treated leachate is then

pumped into a truck and taken to ERWAT for further treatment and discharge. Approximately 90 000 L are pumped and

treated per day.

2 2

4 Gas Management

4.1

Gas management and gas and air quality monitoring systems are required if

landfill gas migration and accumulation are found to represent a potential

safety hazard or odour problem, or if an operating or closed site is situated

within 250 m of residential or other structures.

NA C

A gas management and monitoring system has been installed at the site. The gas flaring trial started in April/May 2015 and

was upgraded to a 2000 m³/hour flare which was commissioned September 2016. Together with the bigger flare, the gas

collection pipe system was also upgraded to a 400mm ring main. The system also contains knock out pods where landfill gas

condensate is collected and drained to the leachate dam.

Air quality monitoring is conducted on a bi-annual basis by GeoZone Environmental. The site should be audited in terms of the

National Standards for Extraction, Flaring or Recovery of Landfill Gas (GNR924 of 2013).

1 1

4.2

Gas monitoring systems could comprise gas monitoring boreholes or other

monitoring devices approved by the Department. Their positions must be

indicated on the layout plan.

NA C Gas pipes have been laid and are connected to a flaring system. Gas wells are monitored internally. 1 1

4.3

These must be monitored at three monthly intervals during the operation of the

landfill. If the soil gas concentrations exceed 1% by volume at Standard

Temperature and Pressure (STP), the department must be informed.

NA C Monthly reports are compiled by Envitech Projects, who are currently operating the LFG project. 1 1

4.4If the collected gas is not used for energy or chemical feedstock, it must be

flared off.NA C

The gas extraction facility is now operational and the flare combusts methane and other gases such as Hydrogen sulfide.

Stack emission monitoring of the flare will be conducted once the system is stable.2 2

5 Excavation for cover

5.1Excavation floor sufficiently separated from the wet season high elevation of

ground waterC C Site is compliant in this regard. 1 1

6 Drainage

6.1 Run-off and storm water diverted around waste body C C

Any water from the stormwater drains on site is now directed to the new stormwater dam. No water will leave the site without

it first being tested. The plan is to use this water for additional dust suppression. Stormwater which comes into contact with

waste is drained in concrete channels into a series of stormwater dams. A third stormwater dam for Phases 3 and 4 has been

constructed. Freeboard in the stormwater dams for Phase 1 and 2 was sufficient (Appendix 3, Photo 8).

2 2

6.2 Contaminated water and leachate contained on site C C 2 2

6.3 Contaminated water and leachate contained stored in retention sump or dam C C 1 1

6.40.5 meter freeboard for contaminated water impoundments and drainage

trenches.C C

There was sufficient freeboard in the leachate dam at the time of the audit, as described above, water is being pumped out of

the dam, treated and take to ERWAT with the intention of keeping the dam as empty as possible to reduce bad odours.

Freeboard in the stormwater dams for Phase 1 and 2 was sufficient (Appendix 3, Photo 8).

2 2

6.5Finally covered areas promote run-off with minimum erosion and/ or ponding

of water.N/A C

Soil saver and hydro-seeding has been implemented on portions of the outer slopes of Phase 2 (Appendix 3, Photo 9) to

minimise erosion, however signs of erosion were noted on portions of the outer slopes of Phase 2 at the time of the audit

(Appendix 3, Photo 10). The soil saver and hydroseeding should be implemented on all of the outer slopes showing signs of

erosion.

1 1

6.6 Uncontaminated water to flow into natural drainage system PC CAny water from the stormwater drains on site is now directed to the new stormwater dam. No water will leave the site without

it first being tested. The plan is to use this water for additional dust suppression.1 1

7 Waste reclamation

7.1 Waste reclamation prohibited (licence condition) N/A N/A No waste reclamation takes place on this landfill. 0 0

7.2 Any reclamation operation formalised in Operating plan N/A N/A There is no formal reclamation and no recycling. 0 0


8 Control of nuisances

8.1 Waste burning prohibited C C Waste is not burned. 1 1

8.2 Litter fences present and cleaned daily C C

Litter fences are not utilised but the entire perimeter of the site is fenced. Pickers are present on the landfill site to collect

scatter. Additionally there are berms on the working face that intercept windblown litter. Very little windblown litter was noted

around the site.

1 1

8.3 Malodorous waste covered immediately C C

Waste is covered at 3pm daily or immediately for special loads. Sporadic complaints are being received regarding odours

perceived to emanate from the landfill site. However, the upgrades to the leachate management system have significantly

reduced the odours and the gas flaring system is also now operational which should aid in further reducing gaseous odours.

1 1

8.4 Equipment to comply with local authority by-laws on noise levels. C C

A Baseline Noise Survey was conducted in August 2014. The survey showed that the noise levels from the landfill were

typical for such an area and fell within the recommended levels for the area. The survey recommended that the reverse signal

be switched off or a different low frequency signal be used during the night. The noise levels weren't excessive at the time of

the audit and no complaints of this nature had been received.

1 1

8.5 Vermin management measures in place C CThe site has a contract with the Owl Rescue Centre and there are 10 rat cages present around the site. No vermin were

noted at the time of the audit. Fly traps are present around the site and these are emptied every 2 weeks.1 1

8.6 Dust kept to a minimum (watering) PC C A water cart is used to control dust on site (Appendix 3, Photo 3). Dust levels were minimal at the time of the audit. 1 1

D. LANDFILL OPERATION CONT.

Leachate and contaminated water are contained in the leachate and stormwater dams. The stormwater contained in the dams

evaporates or is used in dust control.

9 Rehabilitation and vegetation

9.1 Capping on completed areas N/A Not yet applicable to this landfill site. 0 0

9.2 Vegetation establishment on completed areas N/A Not yet applicable to this landfill site. 0 0

9.3 Vegetation on screening berms N/A Not yet applicable to this landfill site. 0 0

9.4 Max slope,1 in 2.5 (21.08 degrees) N/A Not yet applicable to this landfill site. 0 0

10 Final cover

10.1 Surfaces graded, promote run-off N/A Not yet applicable to this landfill site. 0 0

10.2 Surfaces revegetated N/A Not yet applicable to this landfill site. 0 0

11 Landfill Monitoring Committee

11.1Landfill Monitoring Committees are a Minimum Requirement at all Hazardous

and Large landfills. N/A C

A Landfill Monitoring Committee has been established. The most recent monitoring committee meetings were held on 7

September 2016 and 17 November 2016 at the FG Landfill Site, Visitors Centre. The next meeting is scheduled for the 16

February 2017.

0.5 0.5

11.2

It is compulsory that the Permit Holder and officials representing the relevant

state, provincial, regional and local government departments be members of

the Landfill Monitoring Committee.

N/A C

Grant Walters from the DEA Enforcement Department attended the meeting on the 17 November 2016. Despite being invited

GDARD did not attend the monitoring committee meetings. It is compulsory that the officials representing the relevant state,

provincial, regional and local government departments be members of the Landfill Monitoring Committee.

1 1

11.3

The Landfill Monitoring Committee has the following functions:

-Monitoring the establishment, operation, rehabilitation and closure of the

landfill site.

-Reviewing audit results and have it demonstrated that audit

recommendations have been implemented within an agreed time frame.

-Reviewing monitoring results from on-going monitoring programmes.

-Making recommendations to the Department, the Responsible Person, or any

other relevant authority.

-Meeting with local, provincial and national government officials, to discuss

such issues as nuisances, complaints, landfill conditions or permit compliance.

-Requiring that officials provide answers regarding actions taken to address

identified problems.

-Recommending that conditions be written into the Permit or that changes be

made to Permit conditions.

-Ensuring that such recommendations are incorporated into the Permit or

addressed at the Monitoring Committee meetings.

-Holding meetings at which the Permit Holder, the Department, and the IAPs

can report back.

-Ensuring that report back meetings end in action.

-Requesting that special meetings be held for a specific purpose.

-Conducting site visits, at least twice a year, and participating in external

audits.

-Conducting workshops for reporting back to community and re-election of

members.

-Delegating investigations or discussions to subcommittees - who would then

report back.

-Receiving information on such issues as environmental impacts or waste

disposal practices, so that members are empowered to make decisions

regarding the Committee matters.

N/A C

This should be noted by the Landfill Monitoring Committee.

The minutes of the previous meeting and matters arising were discussed.

The FG Landfill Monitoring Committee Terms of Reference are being finalised.

1 1

11.4

Amongst others, the Landfill Monitoring Committee has the duty to:

- Formulate a Terms of Reference and Code of Conduct, under which the

Committee can operate. This would address such issues as conduct at

meetings or conflict resolution

- Inform the Department of any irregularities and/or problems.

- Inform IAPs of the activities of the Landfill Monitoring Committee at a public

information workshop, held at least once a year.

-Disseminate information regarding the site and the proceedings of the

Committee to the communities they represent.

-Keep a record of proceedings and decisions.

N/A CA new communication strategy and structure will be developed and implemented by the committee and must have a

complaints, incident reporting and response function. 1 1

11.5

The terms of reference should be determined by the committee, but could

include the following:

- The monitoring of operations on the site, including hours of operation, gate

controls, types of waste disposed of, at the site, leachate management, air

and water quality complaints about the site, any investigations and remedial

action required on the site and the quality of life of people affected by the site.

- The identification, investigation and remediation of problems on site.

- Keeping the public informed of activities/developments on the site and

disseminating consensus information.

N/A CThe FG Landfill Monitoring Committee Terms of Reference are being finalised and will be sent to the committee for

finalisation..0.5 0.5

11.6

The quorum for a meeting should be at least six participants, comprising three

from the compulsory member organisations (i.e. the Department, Permit

Holder, other) and three from the voluntary membership. If there is no

quorum, the meeting should be adjourned for at least 30 days, and notice

regarding the details of the meeting should be given to all members of the

Landfill Monitoring Committee. In the event that there is no quorum at the

adjourned meeting, those present could constitute a quorum.

N/A C

This is noted by Interwaste.

The attendees at the meeting held on 7 September 2016 were: 4 Interwaste representatives, 1 Envitech representative, 1

Glen Austin Residents Association representative, 3 residents, 2 Groundwork representatives, 1 South African Waste Pickers

Association representative and 1 Midstream Environmental Consultant representative.

The attendees at the meeting held on 17 November 2016 were: 3 Interwaste representatives, 1 Envitech representative,

1DEA representative, 1 Glen Austin Residents Association representative, 3 residents, 1 Midstream Estate Manager and 1

Midstream Environmental Consultant representative.

0.5 0.5

11.7

Minutes should be taken at all meetings. These should be written up and

circulated to all members. A record of complaints received and actions taken,

must also be maintained.

N/A CMinutes were taken during the meetings and the party responsible for the various actions to be taken were noted, together

with the way forward (Appendix 6).0.5 0.5



1 Landfill Classification and Containment Barrier Design

1.1

Class B Landfill liner design requirements from top to bottom: geotextile,

150mm stone leachate collection system, 100mm protection layer of silty sand

or geotextile of equivalent performance, 1.5mm HDPE geomembrane,

600mm compacted clay liner, under drainage and monitoring system and

150mm base preparation layer, in situ soil.

C C

FG Landfill is a GLB+ landfill and has an existing waste management licence (Gaut: 006/12-13/W0003).

Phase 1: Unlined (cells operating lawfully in terms of the Act prior to GNR 636 coming into operation).

Phase 2: Two cells prepared with Class B liner as specified in GNR 636 of 2013, both cells are connected to the leachate

management system.

Phase 3: Will be developed in the future and will be comprised of 2 cells to be prepared with Class B liner as specified in

GNR 636 of 2013 and will be connected to a leachate management system.

Phase 4: Currently being developed, comprised of 3 cells to be prepared with Class B liner as specified in GNR 636 of 2013

and will be connected to a leachate management system.

0.5 0.5

1.2

The classification and containment barrier design of all new landfills, as well as

new working cells at existing landfills, must be implemented in accordance

with section 1.1 above.

C CApplicable to Phase 3 and Phase 4 which will be prepared as per Class B Landfill liner design requirements. No new cells will

be developed on Phase 1. 0.5 0.5

NATIONAL NORMS AND STANDARDS FOR DISPOSAL OF WASTE TO LANDFILL

2 Waste Acceptance Criteria for Disposal to Landfill

2.2

Delisted hazardous waste and general waste that has been classified in terms

of the Minimum Requirements for the Handling, Classification and Disposal of

Hazardous Waste (2nd Edition, 1998; Department of Water Affairs and

Forestry) prior to the Regulations coming into operation, may be accepted and

disposed at a Class B landfill.

C C 0.5 0.5

3 Waste Disposal Restrictions

The following prohibitions and restrictions on the disposal of waste to landfill

comes into effect after the timeframes indicated for each waste from 2013-

Immediate

Waste which, in the conditions of a landfill, is explosive, corrosive, oxidizing

(according to SANS 10234 or SANS10228).

Waste with a pH value of <6 or >12.

Flammable waste with a closed cup flashpoint lower than 61° Celsius.

Reactive waste that may react with water, air, acids or components of the

waste, or that could generate unacceptable amounts of toxic gases within the

landfill.

Waste compressed gases (according to SANS 10234 or SANS 10228).

Lead acid batteries.

Waste tyres: Whole.

Infectious animal carcasses and animal waste.

Three (3) years (2016)

Hazardous Waste Electric and Electronic Equipment (WEEE) - Lamps.


TOTALS

Score Out of

90.5 91

99.5

Percentage

1C C

0.5 0.5Any portion of the site which has been constructed or developed according to condition 3.3.4 of the Licence, must be used for

the disposal of all waste types which are classified according to the latest edition of the "Minimum Requirements", excluding

those waste types listed in Annexure I.

Annexure 1 of the WML indicates that no Hazardous Group Wastes can be disposed of unless an application for delisting has

been approved by the Department of Environmental Affairs. Interwaste received an approval letter for the disposal of delisted

hazardous waste on 20/03/2012.

The non-permissible waste as listed on the site notice board at the main entrance are: Hazardous waste, medical waste, oils

and fuels, chemicals and chemical waste, earth moving tyres, solid tyres, fluorescent tubes, liquids and burning waste. The

Waste Management Licence lists the following non-permissible waste: waste where specific control has been has been

established in terms of the Nuclear Energy Act (Act 46 of 1999); waste types controlled in terms of the MPRDA (Act 28 of

2002) and Electricity Act (Act 41 of 1987); waste which is defined as an extreme hazard or Hazard Group 1 (HG1), high

hazard or Hazard Group 2 (HG2), moderate hazard or Hazard Group 3 (HG3) and low hazard or Hazard Group 4 (HG4)

unless an application for delisting has been successfully submitted to the DEA and written approval was obtain from the DEA;

flammable wastes; corrosive substances; oxidising substances and organic peroxides; any waste which is a Group A and/or

Group B carcinogen/mutagen; any waste at a concentration greater than 1% where the substance is a Group C and/or Group

D carcinogen/mutagen; any infectious waste, unless it has been incinerated at 800 degreaser higher for at least 1 second; all

materials which fall in Class 1 (explosives), Class 2 (compressed gases) and Class 7 (radioactive materials); any waste with

a pH less than 6 or greater than 12; any waste which is difficult to analyse or classify; any complexes of heavy metal cations,

paint and paint sludges, or laboratory chemicals.

13.1

2.1

Type 2 waste (Domestic waste, Business waste not containing hazardous

waste or hazardous chemicals, Non-infectious animal carcasses and garden

waste) may only be disposed of at a Class B landfill.

C C

APPENDIX 2

WASTE MANAGEMENT LICENCE CHECKLIST

PA Previous Audit

NC Non-compliant

PA C/NC/PCComments/Implementation dates for

non complianceAudit Score Total Score

3.1

aLicensing of the activity is subject to the conditions contained in this licence which

form part of the WML and are binding on Interwaste.C C Noted. Noted. Marius Conradie is the responsible person for the site. 0.5 0.5

b and e

This licence is for the construction and operation of FG Waste Disposal site on

Portion 15 of the farm Olifantsfontein 410 JR, (hereinafter referred to as "the

Site"). The activities which are licenced must only be carried out at this property.

C C

The waste disposal site has been constructed and is operated within the indicated site

boundary. The leachate dam was developed on a portion of the adjacent property

contiguous with the site as negotiated with the neighbouring landowner.

0.5 0.5

[Amended Nov. 12] The site will receive up to a maximum of 500 tons of general

waste per day. NA NA

This licence amendment condition contradicts itself with respect to the tonnages

allowed, as per the below condition. The landfill class has been amended from medium

GMB- to large GLB+ .i.e. more than 500 tons of general waste per day is allowed.

Interwaste's application for amendment also clearly stated that the amendment to

GLB+ was sought due to the disposal of more than 500 tons of general waste per day.

A total of approximately 847 tons of municipal waste was received per day between the

current audit (November 2016) and the previous audit (June 2016).

- -

[Amended Nov. 12] The landfill class has been amended from medium GMB- to

large GLB+ as the classification maximum rate of deposition (MRD) waste of more

than 500 tons per day is classified as large landfill size class.

C C

From the latest monthly records 58946 tons were received for June 2016, 58773 tons

were received for August 2016, 51350 tons were received for September 2016 and

46721 tons were received for October 2016.

A total of approximately 1770 tons of waste was received per day between the current

audit (November 2016) and the previous audit (June 2016).

1 1

d Interwaste shall be responsible for ensuring compliance with the conditions. PC PC

This external compliance audit serves to evaluate such compliance and some partial-

and non-compliances were noted. The site is therefore not being operated in complete

accordance the Minimum Requirements and the conditions of the WML. The corrective

actions should be implemented by Interwaste to achieve compliance.

0.5 1

f

Any changes to, or deviations from, the project description must be approved by

the Department before such changes or deviations may be effected. In accessing

whether to grant such approval or not, the Department may request such

information as it deems necessary to evaluate the significance and impacts of such

changes or deviations and it may be necessary for Interwaste to apply for further

authorisation.

C C


The landfill gas extraction facility was registered with the DEA (Registration No.

12/9/11/LGE04/3) on 15 April 2015. The gas lines have been installed and the gas

extraction facility is now operational.

New detection sumps (From Phase 2 and 4) were constructed on a portion of the

adjacent property contiguous with the site.

0.5 0.5

WASTE MANAGEMENT LICENCE CHECKLIST

Ref.

SCOPE OF LICENCE

C Compliant

c

PC Partial Compliance

Landfill Site: Interwaste, FG Landfill Site, Class G:L:B+

Audit Date: Wednesday 23 November 2016

Gauteng Department of Agriculture and Rural Development: Waste Management Licence for the FG Waste Disposal Site on Portion 15 of the farm Olifantsfontein 410 JR, Ekurhuleni Metropolitan

Municipality.

Reference: Gaut: 002/10-11/W0030

Date of Issue: 25/11/2011

Licence Validity period: Licence must be renewed within a period of 4 years from the date of issue.

Gauteng Department of Agriculture and Rural Development: Amendment of a Waste Management Licence for proposed development of FG Disposal Site on Portion 15 of the Farm Olifantsfontein

410 JR.

Reference: Gaut: 006/12-13/W0003

Date of Issue: 12/12/2012

h This WML must be renewed within a period of four(4) years from the date of issue. NA NA

The validity of the licence and the matter regarding the renewal of the WML for the site

is currently the subject of a High Court review and thus compliance in this regard will

be evaluated once the High Court has presented its findings.

- -

iThe licence does not negate Interwaste's responsibility to comply with any other

statutory requirements that may be applicable.C C This is noted by Interwaste. 0.5 0.5

Sub-total 3.5 4.0

3.3

3.3.1 a,

3.3.4 v

The activities must be managed and operated according to the Minimum

Requirements, in accordance with the conditions of this licence, in accordance with

the site operational plan, by sufficient persons who are competent and any other

written instruction from the Department.

C C

Activities are managed in accordance with the Minimum Requirements, the conditions

of the WML and the site operational plan. The site operational plans are dynamic, a

copy of the current operational plan is available in the office on site. The activities are

managed in accordance with the site operational plan and by sufficient persons who are

competent.

As noted in condition 3.1 d above, some partial- and non-compliances were noted

during this external audit and the corrective actions should be implemented by

Interwaste to achieve compliance.

1 1

3.3.1 b

(1.3 of

addendum)

Any persons having duties that are or may be affected by the matters set out in

this licence must have convenient access to a copy of the licence. A copy must be

kept at the site.

C C A copy of the Waste Management License is available in the site office. 1 1

3.3.2

A Waste Management Control officer must be appointed to monitor and ensure

compliance and correct implementation of all mitigation measures and provisions

as stipulated in the licence and Environmental Management Plan.

C C

There is a waste management control officer on site who assumes this responsibility.

This is currently Mr P Pretorius. Some partial and non-compliances were noted during

the external audit and the corrective actions should be implemented by Interwaste to

achieve compliance.

1 1

3.3.3

Interwaste must maintain and implement an emergency preparedness plan

(including natural disasters, vehicle malfunction, site fires, industrial action), which

should be reviewed after every emergency and/or major incident and annually

when conducting an audit. Waste deposited on site must not be allowed to burn.

The Department must be notified of any significant/ major environmental incident.

C CThe landfill has implemented an emergency preparedness plan. No major incidents

have been reported since the previous audit.1 1

3.3.4

a

The construction and further development within the Site shall be accordance with

the drawings numbered H6953-201, H6953-202, H6953-203, H6953-204, H6953-

205, H6953-206, dated November 2009 by SKCM Engineers.

C C

Phase 1 development was done as per the original drawing (H6953-102). The drawings

for Phase 2, 3 and 4 were prepared by SKCM Engineers. DWA provided comment in

July 2014 on the preliminary Design Report for Phase 4 with the recommendation that

the temperature of leachate from Phase 2 be measured and that the post construction

CQA record confirming design implementation is lodged by the Pr Eng. with the

authority.

0.5 0.5

b

The Site or any portion thereof may only be used for the disposal of permissible

waste if the Site or any such portion has been constructed or developed according

to condition 3.3.4 (a) of this licence.

C C

Phase 1: General and non-hazardous industrial wastes are disposed of to this cell,

which is unlined. Phase 2: Two cells prepared with geomembrane lining, both cells are

connected to the leachate management system. Phase 3: Will be developed in the

future and will be comprised of 2 cells which are to be prepared with a geomembrane

lining and will be connected to a leachate management system. Phase 4: Currently

being developed, comprises of 3 cells which are to be prepared with a geomembrane

lining and will be connected to a leachate management system.

0.5 0.5

Commissioning and Construction of the activity

Management of the activity

cConstruction and further development within the Site be carried out under the

supervision of a suitably qualified person.C C

This is noted by Interwaste. There are no construction activities currently being

undertaken at the site. The gas lines have been installed and the gas extraction facility

is now operational. New detection sumps (From Phase 2 and 4) were constructed on a

portion of the adjacent property contiguous with the site.

1 1

d, r, t

Works shall be constructed and maintained on a continuous basis by Interwaste to

divert and drain from the Site in a legal manner, all runoff water arising on and

adjacent to the Site, which could be expected as a result of the estimated

maximum precipitation during a period of 24 hours with an average frequency of

once in fifty years (hereinafter referred to as the "estimated maximum

precipitation"). Such works shall, under the said rainfall event, maintain a

freeboard of half a meter. Interwaste must ensure runoff on land adjacent to the

site does not come into contact with the waste.

C C

Stormwater which comes into contact with waste disposal areas is drained in concrete

channels into a series of stormwater dams.

Any water from the stormwater drains on site is now directed to the new stormwater

dam. No water will leave the site without it first being tested. The plan is to use this


1 1

e

Works shall be constructed and maintained on a continuous basis by Interwaste to

divert and drain from the working face of the Site, all runoff water arising on the

Site, which could be expected as a result of the estimated maximum precipitation

and to prevent such runoff water from coming into contact with leachate from the

Site. Such works shall, under the said rainfall event, maintain a freeboard of half a

meter.

C C

Stormwater from the working face is drained in concrete channels into a series of

stormwater dams. This water does not come into contact with leachate. Freeboard in

the stormwater dams for Phase 1 and 2 was sufficient (Appendix 3, Photo 8). A

representative runoff sample was taken the Stormwater dam.

1 1

f

Runoff water referred to in condition 3.3.4 (e) shall comply with the quality

requirements of the General Standard, as published in Government Notice 991 of

18 May 1984, or with such quality requirements as may from time to time be

determined by the Minister and shall be drained from the Site in a legal manner.

PC C

No water was discharged for the reporting period. Any water from the stormwater

drains on site is now directed to the new stormwater dam. No water will leave the site

without it first being tested. The plan is to use this water for additional dust

suppression.

- -

g, s

Runoff water referred to in condition 3.3.4 (f) above which does not comply with

the quality requirements as set out by DWA and all sporadic leachate from the site

must: 1) be treated to comply with the aforementioned standard and discharged in

a legal manner, and / or 2) with the written approval of the Responsible authority

be evaporated in dams and / or evaporated by spraying over those portions of the

site which comply with the requirements as set out in condition 3.3.4 (b)

C C

Waste cells that are are lined and connected to a leachate dam. Leachate is then

pumped from the dam through a treatment system, where it is dosed with hydrogen

peroxide and ferrous sulphate. The treated leachate is then pumped into a truck and

taken to ERWAT for further treatment and discharge. Approximately 90 000 L are

pumped and treated per day.

1 1

h

Works constructed in compliance with condition 3.3.4 e must be of such a capacity

as to accommodate all runoff and leachate which could be expected as a result of

the estimated maximum precipitation. Such works must under the said rainfall

event, maintain a freeboard of half a metre.

C C

There was sufficient freeboard in the leachate dam at the time of the audit, as

described above, water is being pumped out of the dam, treated and take to ERWAT

with the intention of keeping the dam as empty as possible to reduce bad odours.

Freeboard in the stormwater dams for Phase 1 and 2 was sufficient (Appendix 3, Photo

8).

1 1

iThe Site shall be constructed in accordance with recognised civil engineering

practice to ensure that it remains stable.C C

Construction has been done as per SKCM Engineering's proposed plans and designs, no

deviations have been made from these designs. 1 1

jThe slope of the sides of the Site shall be constructed in such a manner that little

or no erosion occurs.C PC

Soil saver and hydro-seeding has been implemented on portions of the outer slopes of

Phase 2 (Appendix 3, Photo 9) to minimise erosion, however signs of erosion were

noted on portions of the outer slopes of Phase 2 at the time of the audit (Appendix 3,

Photo 10). The angle of repose of the outer berms of the waste cells is approximately

1:3 and the completed berms are being re-vegetated.

0.5 1

kInterwaste (Pty) Ltd shall make provision for adequate sanitation facilities on the

Site.C C

This was addressed in the minimum requirements checklist, the site is compliant in

terms of sanitation facilities these facilities are in a good condition.1 1

l.Expansion of the current landfill site towards the shallow dolomite (east of Phase 1)

must be avoided.C C This is noted by Interwaste. 1 1

m. The waste disposal site must be used for disposal of permissible waste. C C

This is noted by Interwaste and no instances of disposal of non-permissible waste loads

were noted for the period under review. The site notice board indicates the non-

permissible waste types (hazardous waste, medical waste, oils and fuels, chemicals and

chemical waste, earth moving tyres, solid tyres, fluorescent tubes, liquids and burning

waste).

Weighbridge operators inspect the trucks entering the site for waste that is not

permitted to be disposed of on the site. The weighbridge operators are adequately

trained to identify non-permissible waste loads. Additionally, spotters on the working


1 1

n.

Construction at the site must be carried out under supervision of a WMCO who

must submit a declaration to the Department upon completion what all possible

mitigation measures have been put in place and highlight likely deficiencies before

commencement of the receiving of waste.

C NA

There are no construction activities currently being undertaken at the site. The gas

lines have been installed and the gas extraction facility is now operational. New

detection sumps (From Phase 2 and 4) were constructed on a portion of the adjacent

property contiguous with the site.

0 0

o.Construction and further development within the site shall be carried out under the

supervision of a suitably qualified person.C NA There are no construction activities currently being undertaken at the site. 0 0

u.[Amended Nov. 12] The maximum height of the site must not exceed 20 m above

natural ground.C C

The latest site survey was received (November 2016), the landfill site is compliant in

this regard. The highest point is at an elevation of 1583 mamsl and the maximum

height is 20 m at Phase 1.

2 2

w.The entire site must have suitable engineered surfaces which will be maintained

and enable effective site housekeeping.C C

Internal roads were in a good condition and had recently been watered. The road

surfaces have been stabilised and are suitable to enable waste disposal in all weather

conditions. There is a general workshop as well as various containers used for storage

throughout the concrete lined yard area. All hydrocarbon containers are being stored in

bunded areas at the workshop.

1 1

x.

Construction activities must be restricted between the following hours: 07h00 to

18h00 on Weekdays, 07h00 to 13h00 on Saturdays. No construction activities must

take place on Sundays or on Public Holidays.

C CCover material is being excavated from Phase 3 (only during operating hours),

however no other construction activities are taking place.0.5 0.5

3.3.5

a

Weatherproof, durable and legible notice in three official languages applicable in

the area, shall be displayed at each entrance to the Site. These notices shall

prohibit unauthorised entry and state the hours of operation, the name, address

and contact details of Interwaste and the person responsible for the operation of

the Site.

C C

There is a weatherproof durable sign at the entrance to the site, the sign indicates that

unauthorised entry is prohibited, the hours of operation are indicated, Interwaste

contact details are given, and the contact details are given for the person responsible in

charge of the site. All of the information presented on the sign is available in two

prevalent local languages, if it is found to be necessary then a third language could be

added (Appendix 3, Photo 1).

1 1

b The Site shall be fenced and secured to reasonably prevent unauthorised entry C CThere is a precast concrete wall in place that is taller than 1.8m. The wall surrounds the

entire perimeter of the landfill site.1 1

c

Interwaste shall take all reasonable steps to maintain roads in a condition which

ensures unimpeded access to the Site for vehicles transporting waste and to keep

the roads free of waste.

C C The roads within the site are in a good condition and free of waste / litter. 1 1

dInterwaste must ensure that all entrance gates are manned during the hours of

operation and locked outside the hours of operation.C C 0.5 0.5

e Interwaste must ensure effective access control. C C 0.5 0.5

fInterwaste must take all reasonable steps to prevent the disposal of unauthorised

waste.C C

Weighbridge operators inspect the trucks entering the site for waste that is not

permitted to be disposed of on the site. The weighbridge operators are adequately

trained to identify non-permissible waste loads. Additionally, spotters on the working


1 1

Access Control

PRSS Security company is in charge of manning the entrance gates, gates are lockable

and security guards are present on site after hours

3.3.6

a

Any portion of the site must be used for the disposal of all waste types which are

classified according to the Minimum Requirements for waste disposal or any later

versions

C C

Refer to the Minimum Requirements Checklist.

The site notice board indicates the non-permissible waste types (hazardous waste,

medical waste, oils and fuels, chemicals and chemical waste, earth moving tyres, solid

tyres, fluorescent tubes, liquids and burning waste).

1 1

b Disposal must exclude waste types listed in Annexure I. C C


The non-permissible waste as listed on the site notice board at the main entrance are:

Hazardous waste, medical waste, oils and fuels, chemicals and chemical waste, earth

moving tyres, solid tyres, fluorescent tubes, liquids and burning waste.

The WML lists the following non-permissible waste: waste where specific control has

been has been established in terms of the Nuclear Energy Act (Act 46 of 1999); waste

types controlled in terms of the MPRDA (Act 28 of 2002) and Electricity Act (Act 41 of

1987); waste which is defined as an extreme hazard or Hazard Group 1 (HG1), high

hazard or Hazard Group 2 (HG2), moderate hazard or Hazard Group 3 (HG3) and low

hazard or Hazard Group 4 (HG4) unless an application for delisting has been

successfully submitted to the DEA and written approval was obtain from the DEA;

flammable wastes; corrosive substances; oxidising substances and organic peroxides;

any waste which is a Group A and/or Group B carcinogen/mutagen; any waste at a

concentration greater than 1% where the substance is a Group C and/or Group D

carcinogen/mutagen; any infectious waste, unless it has been incinerated at 800

degreaser higher for at least 1 second; all materials which fall in Class 1 (explosives),

Class 2 (compressed gases) and Class 7 (radioactive materials); any waste with a pH

less than 6 or greater than 12; any waste which is difficult to analyse or classify; any

complexes of heavy metal cations, paint and paint sludges, or laboratory chemicals.

None of these waste streams have been disposed of for the period under review.

1 1

c Interwaste must take all reasonable steps to ensure that -

i

no organic or inorganic element or compound which may have a definite acute or

chronic negative effect on human health and/or the environment, due to its toxic,

corresponds with the UNEP definition of hazardous waste ;

C C 0.5 0.5

ii no medical waste may be disposed of on the site; and C C 0.5 0.5

iii

no scheduled pharmaceutical products registered in terms of the Medicines and

Related Substances Control Act, 1965 (Act 101 of 1965) or associated containers

be disposed of on the Site.

C C 0.5 0.5

3.3.7

aInterwaste must ensure that litter or mud arising from the activities does not cause

pollution and is cleared from affected areas outside the site as soon as is practical.C C

Very little windblown litter was noted around the site. Some mud was noted at the

wheel wash area on site, however no mud was noted outside of the site. 1 1

b, e

Wind blown waste and litter must be picked up and removed from fences and

vegetation on a daily basis. Interwaste must control wind blown waste through

appropriate measures including but no limited to applying the sanitary landfill

principles of compaction and cover.

C C

Moveable fences are not used, however inner berms are present and pickers collect

wind-blown waste. Very little windblown litter was noted around the site. Waste is

compacted and covered.

1 1

No incidents of non-permissible waste disposal since previous audit.

Permissible Waste

Impact Management

cInterwaste must ensure that emissions from the activities are free from odour at

levels likely to cause annoyance outside the site.NC NC

Sporadic complaints are being received regarding odours perceived to emanate from

the landfill site.

From the Ambient Air Quality Assessment report dated October 2016 (by Geozone

Environmental), with the exception of the South-west corner, average ambient

concentrations of Hydrogen sulphide at all of the on-site monitoring locations were

lower than those recorded during the previous sampling period (August 2016). Despite

this, average ambient Hydrogen sulphide concentrations at all of the on-site monitoring

locations remained in excess of the odour detection threshold.

From the Ambient Air Quality Assessment report dated November 2016 (by Geozone

Environmental) no exceedance of the Hydrogen sulphide health limit was found and a

substantial reduction of Hydrogen sulphide was noted since August 2016. Average

ambient Hydrogen sulphide concentrations at the Leachate dam, W. Boundary and SW

corner remain in excess of the odour detection threshold.

Based on the evidence collected to date, emissions of hydrogen sulphide gas from the

FG Waste Disposal Site may impact intermittently on individuals/ communities located

nearby, leading to complaints about malodour. Average ambient concentrations of the

measured contaminant compounds at the off-site sampling locations were below the

relevant South African long term ambient air quality standard and Environmental

Assessment Levels.

2 2

dRe-usable or recyclable waste must be reclaimed by Interwaste before they are

taken to site.C C

Noted. Where possible, recycling occurs at the Interwaste Hub in Germiston. Public

loads, however, are not checked for re-usable or recyclable waste.1 1

f

Run-off water which does not comply with the DWAF National Water Quality

Guidelines for the natural environment must be channelled to the sewer provided

written permission is granted by the relevant section of the municipality.

NA NA




Leachate is pumped from the leachate dam through a treatment system, where it is

dosed with hydrogen peroxide and ferrous sulphate. The treated leachate is then

pumped into a truck and taken to ERWAT for further treatment and discharge.

Approximately 90 000 L are pumped and treated per day.

NA NA

g Waste within and outside the site must be collected on a weekly basis. C C Pickers collect wind-blown waste on a weekly basis. 0.5 0.5

3.3.8

aWaste disposal must be done in accordance with the site operational plan, the

condition of this licence and any other written instruction by the Department.C C

Waste disposal is done in accordance with the Minimum Requirements, the conditions

of the WML and the site operational plan.

As noted in condition 3.1 d above, some partial- and non-compliances were noted

during this external audit and the corrective actions should be implemented by

Interwaste to achieve compliance.

1 1

bInterwaste must ensure that records in terms of volume, source and the nature of

all wastes received and transferred are maintained and reported.C C

Full records of volumes, sources and the nature of waste are available in the office.

These volumes were also reported in the waste manifests viewed by the auditors.1 1

cWaste that is not permissible must be dealt with according to the relevant

legislation or the Department's policies and practices.C C No such non-permissible waste was encountered for the period under review. 1 1

d, g

In order to prevent nuisance, pollution and/or littering incidents, waste disposed on

Site must be compacted and covered on a daily basis with a minimum of 150

millimetres of soil.

C CAreas of intermediate cover were noted to be compliant in this regard. Waste is

covered at 3pm daily.1 1

Operation

e

Interwaste must ensure that the Site is operated in such a manner that nuisance

conditions or health hazards, or the potential creation of nuisance conditions or

health hazards are prevented.

C NC

The site is regularly inspected for signs of nuisance conditions. At the time of the

audit, no such conditions were noted. However, sporadic complaints are being received

regarding odours perceived to emanate from the landfill site.

The gas flaring trial was started in April/May 2015 and was upgraded to a 2000

m³/hour flare which was commissioned September 2016. Together with the bigger

flare, the gas collection pipe system was also upgraded to a 400mm ring main. The

upgraded gas flaring system and the leachate management system should aid in

further reducing gaseous odours.

0 1

f

Interwaste (Pty) Ltd must ensure the health and safety of workers and employees

on site, in terms of the Occupational Health and Safety Act, 1993 (Act no. 85 of

1993)

C CThere is a copy of the Occupational Health and Safety Act in the site office. Workers are

supplied with PPE and it was evident that workers were wearing PPE.1 1

h

Interwaste must prioritize implementation of the waste hierarchy objectives by

ensuring re-use, recovery and recycling of waste prior to disposal, provided that

the environment is not impacted upon.

C CNoted. Where possible, recycling occurs at the Interwaste Hub in Germiston. Public

loads, however, are not checked for re-usable or recyclable waste.1 1

i Waste disposed of on the Site must not be reclaimed. C C No reclamation occurs on-site. 1 1

Sub-total 39 40.5

3.4

3.4.1

a

Interwaste must carry out all tests required in terms of this licence in accordance

with methods prescribed by and obtainable from the South African Bureau of

Standards (SABS, referred to in the Standards Act, 1982 (Act 30 of 1982), should

testing be deemed necessary.

C C

External water quality analysis is undertaken at a SANAS accredited laboratory. Air

quality samples are analysed in accordance with the ISO 16200-2: Standard for the

sampling and analysis of volatile organics. Leachate samples are sent to M&L Labs (a

SANAS accredited laboratory) for analysis.

1 1

b

Interwaste (Pty) Ltd must put in place a monitoring and measurement plan that

must amongst others include:

i)Tonnage received, reclaimed and transferred;

ii)Waste storage duration;

iii)Waste types and source;

iv)Community complaints and compliments;

v)Air quality monitoring;

vi)Storm water and leachate monitoring; and

vii)Ground water quality monitoring.

C C

Tonnages, waste types and sources are documented at the weighbridge, a complaints

line is now operational and all complaints are recorded. Air quality monitoring is

conducted on a bi-annual basis by GeoZone Environmental. The auditors were provided

with a copy of the monthly tonnages received and the leachate currently being

removed per month. Water from the detection sumps is also sampled weekly.

Groundwater monitoring is performed by Prime Resources.

1 1

3.4.2

a

Water quality monitoring system for the site shall be established and maintained by

Interwaste according to section 6.7.1 page 28 of the Environmental Management

Plan for licensing of FG Waste Disposal site prepared by Environmental assurance

(Pty) Ltd dated July 2007 to the satisfaction of DWA so that the unobstructed

sampling, as required in terms of this licence, can be undertaken.

C C 1 1

b

Interwaste must establish a monitoring borehole network, as indicated in the FG

Waste Disposal site amended permit application report dated July 2011 compiled

by SKCM Engineers (Pty) Ltd, to the satisfaction of the Responsible Authority, so

that unobstructed sampling can be undertaken.

C C 1 1

c

Ground water quality monitoring should be conducted at boreholes BH1, BH2, Dam

1, Dam 2 and Dam 3, for Ca, Mg, Na, K, Total alkalinity, Cl, SO4, NO3, Al, Mn, Fe,

EC, pH and COD.

C C

Development has taken place on-site since the inception of monitoring - the

aforementioned dams were filled in areas where additional waste cells were

subsequently developed and are thus no longer existent, groundwater samples were

obtained from the following boreholes: FGBH1, FGBH2, FGBH3 (formerly 5), Upstream

boreholes 1 and 2. A sample was also collected from the stormwater dam near Phase

2.

1 1

d Ground water level must be recorded during groundwater sampling. C C The ground water level is recorded during groundwater sampling. 1 1

Monitoring

Monitoring methods and parameters

A monitoring borehole network has been established on the landfill site. Water

monitoring is undertaken by Prime Resources. Unobstructed groundwater monitoring

was conducted.

Water monitoring

e

Monitoring boreholes shall be equipped with lockable caps. The Department

reserves the right to take water samples at any time and to analyse these samples

or have them analysed.

C C Noted. All boreholes were fitted with lockable caps. 1 1

f

Surface water monitoring shall be performed in all storm water drains on and

adjacent to the Site at locations selected in conjunction with the DWA and at a

frequency as determined by the DWA.

C C



water for additional dust suppression. Water from the leachate dam and leakage

detection sumps is sampled weekly by Interwaste.

1 1

gSurface water quality monitoring should be conducted in the non-perennial stream

during rainy periods to manage the surface water quality.N/A This is N/A due to the fact that no non-perennial stream has been located on site. 0 0

3.4.3

Samples from the upstream borehole where the ground water in the borehole is at

an expected higher hydraulic pressure level than the hydraulic pressure level of the

ground water under the Site, shall be considered as background monitoring.

Background groundwater monitoring shall be conducted during each monitoring

occasion listed in conditions 3.4.4 and 3.4.5 for the water quality variables listed in

Annexure II.

C C Two upstream boreholes have been drilled and are sampled for background monitoring. 1 1

3.4.4

Detection monitoring must be conducted every six months for the water quality

variables listed in Annexure III and reported to the Department within 30 days

from the date of sampling.

C C

Prime Resources conducts groundwater quality monitoring on a bi-annual basis. The

quality variables as listed in Annexure III are analysed. The data is made available to

the department as specified.

1 1

3.4.5

If, in the opinion of the Department or Chief Director, a water quality variable listed

under the detection monitoring programme, as referred to in condition 3.4.3 (a),

shows an increasing trend, Interwaste (Pty) Ltd must initiate a monthly monitoring

programme for the water quality variables listed in Annexure II.

N/A The auditors have not been made aware of any such findings of the Department. 0 0

3.4.6

Ground water monitoring by Interwaste, in accordance with condition 3.3 or 3.4,

shall commence immediately upon closure of the Site and be maintained for a

period of 30 years, or such lesser period as may be determined by the Chief

Director: Resource Protection and Waste (RPW).

N/A This will commence post-closure. 0 0

3.4.7

3.4.7.1

If, in the opinion of the Chief Director, RPW, ground water and surface water

pollution have occurred or possibly may occur, Interwaste shall conduct and or

appoint specialists to conduct the necessary investigations and implement

additional monitoring and rehabilitation measures to the satisfaction of the Chief

Director: RPW.

N/A C

The Department of Environmental Affairs (DEA) issued Interwaste with a pre-directive

on the 13th October 2016, to undertake a groundwater study, including a hydrocensus

and water quality sampling of a 1.5 km radius around the site in order to determine if

there is any potential groundwater pollution emanating from the site. This study

commenced in November 2016 and has not yet been completed.

1 1

3.4.8

a

Interwaste shall carry out all tests in accordance with methods prescribed by and

obtainable from the South African Bureau of Standards (SABS), referred to in the

Standards Act, 1982 (Act 30 of 1982), to analyse the samples taken under the

monitoring programmes specified in condition 3.4.

C C

External water quality analysis is undertaken at a SANAS accredited laboratory. Air

quality samples are analysed in accordance with the ISO 16200-2: Standard for the

sampling and analysis of volatile organics. Leachate samples are sent to M&L Labs (a

SANAS accredited laboratory) for analysis.

1 1

bInterwaste shall only use another method of analysis if written proof that the

method is equivalent to the SABS method, is submitted to the Chief Director: RPW.C C Noted but no such deviation from specified protocols has occurred. 1 1

Background monitoring

Detection monitoring

Investigative monitoring

Post-closure Investigations

Further investigations

Methods of analysis

Water pollution

3.4.8.1

a

If, in the opinion of the Department, environmental pollution, nuisances or health

risks may or is occurring, Interwaste must initiate an investigation into the cause of

the problem or suspected problem. Such investigation must include the monitoring

of relevant environmental pollution, nuisance and health risk variables, at those

monitoring points and such frequency to be determined in consultation with the

Department.

N/A C

The DEA issued Interwaste with a pre-directive on the 13th October 2016. The pre-

directive relates to potential harmful air emissions and groundwater pollution

emanating from the site. Interwaste has appointed various specialists and the findings

of these studies will be submitted to the DEA upon completion.

1 1

Sub-total 14 14

3.5

3.5.1

a

Internal audits must be conducted quarterly by Interwaste and on each audit

occasion an official report must be complied by the relevant auditor to report the

findings of the audits, which must be made available to the external auditor

specified in condition 3.5.2(a).

C C

Internal audits are conducted by Interwaste in accordance with ISO14001, proof of

these audits were given to Prime Resources. The most recent internal audit was

conducted on 19 October 2016 and the audit score was 88.28%.

The major findings included the following: erosion on the outer slopes of the cells, the

lack of storm water channels on the exterior slopes, unsafe excavations, exposed and

windblown waste, dust on the site access road, a gap in the perimeter wall was noted,

the drain near the wash-bay was clogged with silt and malodorous conditions were

noted at the time of the audit and may have been due to the gas line excavation

activities taking place.

The non compliances are addressed through a non conformance report which details

the corrective action/s taken in order for the issue to be closed out.

2 2

3.5.2

a

Interwaste must appoint an independent external auditor to audit the Site annually

and this auditor must compile an audit report documenting the findings of his/her

audit, which must be submitted by Interwaste according to condition 3.5.2(b).

C CPrime Resources have been appointed as the independent external auditor and this

external audit satisfies these requirements.1 1

b (i-iii)

The audit report must specifically state whether conditions of this licence are

adhered to and must include an interpretation of all available data and test results

regarding the operation of the Site and all its impacts on the environment.

C C 0.5 0.5

b (iv)

The audit report must contain recommendations regarding non-compliance or

potential non-compliance and must specify target dates for the implementation of

the recommendations by Interwaste and whether corrective action taken for the

previous non conformities was adequate.

C C 0.5 0.5

b (v) The audit report must show results graphically and a trend analysis conducted. C C 0.5 0.5

3.5.3

aThe Department reserves the right to audit and/or inspect the Site without prior

notification at any time and frequency as may be determined by the Department.C C

On the 29 June 2016 the DEA conducted a site visit and on the 7th November 2016 an

Environmental Management Inspection with GDARD and DEA was conducted.0.5 0.5

bInterwaste must make any records or documentation available to the Department

upon request, as well as any other information it may require.C C This was noted by Interwaste. 0.5 0.5

c

The findings of these audits or inspections shall be made available to Interwaste

within 30 days of the end of the audit or inspection. Information form the audits

must be treated in accordance with the Promotion of Access to Information Act,

2000 (Act 2 of 2000).

C C This was noted by Interwaste. 0.5 0.5

Sub-total for Section 6 6

Environmental Pollution

External Audits

AUDITING

This external audit report and accompanying checklists serve to fulfil this requirement.

Internal Audits

Departmental audits and inspections

3.6

a, b

Interwaste must keep records and update all the information and submit this

information to the Department on an annual basis. Records in terms of volume,

source and the nature of all waste received and transferred must be maintained

and reported.

C CThis information is kept on-file by Interwaste and is submitted annually to the

Department.1 1

c

All records required or resulting from activities required by this licence must:

i) be legible;

ii) be made as soon as reasonable practicable and should form part of the external

audit report;

iii) if amended, be amended so that the original remain legible and retrievable.

C C Noted and compliant. 1 1

c Interwaste (Pty) Ltd must record all borehole data and chemical analysis. C C The results of all groundwater monitoring studies are retained on-site. 1 1

dRecords demonstrating compliance with conditions 3.3.1 must be maintained and

made available to the Department upon written request.C C

This was noted by Interwaste, however no such requests have been made by the

Department.1 1

Sub-total 4 4

3.7

a

Interwaste must, within 30 days, notify the Department of the occurrence or

detection of any incident on the Site, or incidental to the operation of the Site,

which has the potential to cause, or has caused water pollution, pollution of the

environment, health risk or nuisance conditions.

C C This is noted by Interwaste, however no such incident has occurred on-site. 1 1

b

Interwaste must keep a record of- and update all the information referred to in

Annexure IV within a period of one year from the date of this licence and annually

thereafter.

C C Noted and compliant. 1 1

c

Interwaste must within 30 days, or a shorter period of time, if specified by the

Regional Director, from the occurrence or detection of any incident referred to in

condition 3.7(a), submit an action plan, which must include a detailed time

schedule, to the satisfaction of the Department and/or the Director: RPW of

measures taken to :

C C Noted. 1 1

i correct the impact resulting from the incident; C C No incident occurred since the previous audit. 0.5 0.5

ii prevent the incident from causing any further impact; and C C 0.5 0.5

iii prevent a recurrence of a similar incident. C C 0.5 0.5

dInterwaste (Pty) Ltd shall, within 24 hours, notify the Department of any sporadic

leachate generated on account of unusual circumstances on the Site.NA NA A permanent leachate drainage, collection and management system is in place. 1 1

e

In the event that measures have not been implemented within 21 days of the

incident to address impacts caused by the incident referred to in condition 3.7(a) or

measures which have been implemented are inadequate, the Department may

implement the necessary measures at the cost and risk of Interwaste.


fInterwaste must keep an incident report and complaints register, which must be

made available to both external and Department for the purpose of their audits.C C

An incidents register was shown to the auditors at the time of the audit. No recent

incidents have occurred.

The latest complaints were made available to the auditors.

1 1

g

The Department must be notified without delay in the case of the following:

i) any malfunction, breakdown or failure of equipment, significant pollution caused

by accidental emissions;

ii) breach of this permit;

iii) any significant adverse environmental and health affects.


Reporting

No incident occurred since the previous audit.

Records

h

Prior written notification must be given to the Department of the following events

and in the specified timescales:

i) As soon as practicable prior to the permanent cessation of any operational

activities;

ii) Full or partial cessation of the operational activities for a period likely to exceed

3 month;

iii) Full or partial resumption of the operation of all or part of the activities after a

cessation notified under ii above; and

iv) The professional engineer appointed by Interwaste in ,line with condition 3.3.4

(a) must make a signed declaration that condition 3.3.4 (e) has been adhered to.


i

The Department must be notified within 7 days of any changes to the management

of the site and supply particulars of the new appointment. The Department must be

notified within 14 days of any changes made to the particulars of Interwaste (Pty)

Ltd and/ or the ultimate holding company.

C C Noted. 1 1

3.7.1

aInterwaste must establish a functional monitoring committee for as long as disposal

of waste takes place until after at least two years after cessation of such activities.C C A Landfill Monitoring Committee has been established. 1 1

b The Monitoring Committee must formulate terms of reference and code of conduct. C C

The FG Landfill Monitoring Committee Terms of Reference are being finalised. A new

communication strategy and structure will be developed and implemented by the

committee and must have a complaints, incident reporting and response function.

1 1

c

The Monitoring Committee must be representative of relevant and affected parties

and must include a representative of the communities in the vicinity, authorities

and Interwaste.

C C

Grant Walters from the DEA Enforcement Department attended the meeting on the 17

November 2016. Despite being invited GDARD did not attend the monitoring

committee meetings. It is compulsory that the officials representing the relevant state,

provincial, regional and local government departments be members of the Landfill

Monitoring Committee.

The attendees at the meeting held on 7 September 2016 were: 4 Interwaste

representatives, 1 Envitech representative, 1 Glen Austin Residents Association

representative, 3 residents, 2 Groundwork representatives, 1 South African Waste

Pickers Association representative and 1 Midstream Environmental Consultant

representative.

The attendees at the meeting held on 17 November 2016 were: 3 Interwaste

representatives, 1 Envitech representative, 1DEA representative, 1 Glen Austin

Residents Association representative, 3 residents, 1 Midstream Estate Manager and 1

Midstream Environmental Consultant representative.

1 1

d

The Monitoring Committee must meet at least twice per year and no later than 30

days after the external audit report specified in condition 3.5.2 has been submitted

according to condition 3.5.2 (a).

C C

This is noted by Interwaste. The last external audit was submitted in August 2016. The

most recent monitoring committee meetings were held on 7 September 2016 and 17

November 2016 at the FG Landfill Site, Visitors Centre. The next meeting is scheduled

for the 16 February 2017.

1 1

Monitoring Committee

eInterwaste must keep minutes of the Monitoring Committee and distribute these

top all members within 14 days after the meeting.C C

Minutes are taken during the meetings and the party responsible for the various actions

to be taken were noted, together with the way forward (Appendix 6).

From the meeting on 7 September 2016: The general issues discussed included the

odour around the site, air quality monitoring and the landfill gas project. Midstream is

assisting the DEA with the air quality monitoring, which is continuous monitoring at

different sites. It was suggested that real time sampling and monitoring is needed and

that a system should be set up to report and map the complaints and odours and setup

passive and spot sampling to check the gases when the complaint occurs. It was also

suggested that the waybills and waste going into the site be correlated with the

complaints. It was requested the Interwaste make the source, type and tons of waste

accepted at the site available for the community to view.

From the meeting on 17 November 2016: The general issues discussed included stack

emission monitoring, feedback regarding complaints, the terms of reference for the

committee, the Landfill Management Report, air quality monitoring in the region.

1 1

Sub-total 15.5 15.5

3.8

3.8.1

a

Interwaste shall, at least 180 days prior to the intended closure of the Site, notify

the Department by registered mail of such closure and submit final rehabilitation

plans for his approval.

N/A This will only be applicable post-closure. N/A 0

i

Interwaste must rehabilitate the Site in accordance with a closure report and

rehabilitation plan which shall be submitted to the Department for approval at least

one year prior to the closure of the site or a portion thereof.

N/A See point 3.8.1a. N/A 0

3.8.2

aImmediately following the cessation of operations with the intention to close the

Site, the surface of the Site shall be covered in such a way that :N/A See point 3.8.1a.. N/A 0

i the formation of pools due to rain is prevented; N/A See point 3.8.1a.. N/A 0

ii free surface runoff of rain-water is ensured; N/A See point 3.8.1a.. N/A 0

iii contamination of stormwater is prevented; N/A See point 3.8.1a.. N/A 0

ivno objects or material which may hamper the rehabilitation of the Site are present;

andN/A See point 3.8.1a.. N/A 0

vlittle or no erosion occurs, until the approved rehabilitation (and end use) plan

referred to in condition 3.8.1 (a) is completely implemented.N/A See point 3.8.1a.. N/A 0

bInterwaste will remain responsible for the site, or any of its impacts on the

environment, after operations on the site have ceased.N/A See point 3.8.1a.. N/A 0

3.8.3

a

Groundwater monitoring by Interwaste, in accordance with condition 3.4.3 and

3.4.4 must continue beyond closure of the site and be maintained for a period of

thirty years, or such lesser period as deemed adequate by the Department.

N/A See point 3.8.1a.. N/A 0

Sub-total 0 0

Site rehabilitation

Rehabilitation of the site

Closure plan

Post closure monitoring

3.9

a

Internal audits must be conducted quarterly in accordance with the attached EMP.

Each of the quarterly internal audit reports must be made available to the external

auditor referred below and to all relevant authorities if requested.

C PC

Internal reports are conducted quarterly by Interwaste, proof of these reports were

given to Prime Resources. The internal audits are conducted in terms of the DWAF

Minimum Requirements for Waste Disposal to Landfill, 2008, the Waste Management

License Gaut: 002/10-11/W0030 and the GDACE RoD Ref. Gaut: 002/04-05/0492. As

per this condition, the internal audits should also be in accordance with the EMP.

0.5 1

b

Interwaste must appoint an independent external auditor to audit the Site annually.

The auditor must compile an audit report documenting the findings of his/her audit.

The audit report must:

C C

Prime Resources is appointed as the independent external auditor, audit reports done

by Prime Resources contain all the necessary information. This audit serves to fulfil this

requirement.

1 1

i Specifically state whether the conditions of this authorisation are being adhered to; C C

The external audit checklists were compiled based on the conditions stipulated in the

Waste Management licence issued by the Gauteng Department of Agriculture and Rural

Development.

0.5 0.5

iiContain recommendations regarding non-compliance or potential non-compliance

and must specify target dates for the implementations of recommendations; and C C

Recommendations are made in both the audit checklists and in the cover report that

summarises partial and non-compliances.0.5 0.5

iiiInclude an interpretation of all available data and test results regarding the

operation and all its impacts on the environment.C C

See point 3.9b. The results of the groundwater monitoring are analysed and

commented on as part of the audit report. The air quality monitoring report analyses

and comments on the air quality data.

0.5 0.5

c The external audit report must be submitted to all relevant authorities. C C 1 1

dThe annual audit report must be submitted to this Department on an annual basis

thereafter.C C 1 1

c

A general water use authorization issued by DWAF in terms of section 21 (g) of the

National water Act, (Act 36 of 1998) must be forwarded to GDARD no later than

two months after it becomes available.

C C

The Department indicated that this is not currently a requirement but may be

applicable in future (should additional leachate dams be developed). A letter dated 15

July 2014 from DWS Chief Director: Regulation recommends that the design of Phase 4

only be approved on condition that the temperature of leachate in Phase 2 is measured

to aid the determination of suitability of the geotextile specified for the separation of

the waste body from LCS as well as the depth and spacing of the under drains beneath

the GCL, and that the post construction CQA record confirming design implementation

is lodged by the Pr Eng. with the authority.

The capacity of the leachate dam was increased in 2015 by adding 1 m of lining to the

walls of the basin, however, since May 2016 the leachate is being removed from site

and taken to ERWAT with the aim of keeping the leachate dam empty.

1 1

Sub-total 6 6.5

3.10

a Ground water monitoring must continue even after the closure of the site. N/A This will only apply after closure of the site. N/A 0

b Interwaste must ensure the maintenance of the site after closure N/A This will only apply after closure of the site. N/A 0

Sub-total 0 0

3.11

a, b

Should Interwaste want to alienate or lease the Site, he shall notify the Department

in writing of such an intention at least 120 days prior to the said transaction.

Should the approval be granted, the subsequent licence holder shall remain liable

to compliance with all licence conditions. Any subsequent licence holder shall be

bound by the conditions of this licence.

N/A There is currently no intention of alienating or leasing any portion of the site. N/A N/A

Sub-total 0 0

Leasing and alienation of the site

The November 2015 external audit was submitted to GDARD in December 2015 and

this audit will be submitted after it is finalised

Recording and reporting to the Department

Site closure and decommissioning

3.12

a, 3.13eShould Interwaste want to transfer holder-ship of this licence, it must apply in

terms of section 52 of the NEM: WA, Act 2008 (59 of 2008).N/A Noted, does not apply. N/A N/A

Sub-total for Section 0 0

3.13

a, 1.3

(addendum)

A copy of the addendum together with the copy of the initial WML must be kept at

the site. It must be produced to any authorised official of the Department who

requests to see it. In addition, the licence must be made available for inspection by

any employee or agent of Interwaste who works or undertakes work at the

property.

C CA copy of the initial WML and addendum are kept on the property and are available for

inspection at the site office.0.5 0.5

b The Department must be notified of any change to the applicant's contact details. C C Noted, these have currently not changed. 0.5 0.5

c, 1.4

(addendum)

Interwaste must notify the Department in writing within 24 hours (initial WML) and

within 7 days (addendum), if any of the licence conditions cannot be adhered to.

Reasons for non-compliance must be attached of such written notice.

PC PC

The Department is not notified within 24 hours or 7 days if any condition of the WML or

addendum is not adhered to but rather after each external audit. The partial and non-

compliances are reported in the external audit report and each external audit report is

submitted to the Department within 30 days of the audit report being finalised. Any

significant non-compliances/incidents are reported as per Condition 3.7 of the WML and

the conditions and provisions of NEMA.

0.25 0.5

d, 1.5

(addendum) Non- compliance with a condition of this licence may result in criminal prosecution. C C This is noted by Interwaste. 1 1

f

This licence must not be construed as exempting Interwaste from compliance with

the provisions of the National and Provincial Legislation and any relevant

Ordinance, Regulation, By-laws and relevant national Standards and Norms.

C C This is noted by Interwaste. 0.5 0.5

gTransgression of any condition of this licence could result in the validity of the

licence being terminated by the Department.C C This is noted by Interwaste. 0.5 0.5

h

Any committees appointed in terms of the application or any other public authority

or organisation will not be held responsible for any damage or losses suffered by

Interwaste in any instance where construction or operation is to be temporarily or

permanently stopped for reasons of non-compliance.

C C This is noted by Interwaste. 0.5 0.5

i

It is the responsibility of Interwaste to take reasonable measures which include

informing and educating contractors and employees about environmental risks of

their work and training them to operate in environmental acceptable manner.

C C An environmental awareness plan has been formalised. 0.5 0.5

Sub-total 4.25 4.5

Score Out of

92.25 95.00

97.1

Transfer of waste management licence

General

TOTALS

Percentage

APPENDIX 3

SHEET OF PHOTOS FROM AUDIT

P160778 - FG Waste Disposal Site Audit- Photo Sheet 1 Interwaste (Pty) Ltd December 2016

Photo 2: The entrance to the site at the D2543 intersection has been paved.

Photo 3: A water cart was in operation.

Photo 6: A Biological Waste Treatment Plant is used to treat the sewage.

Photo 5: The main entrance to the landfill is access controlled with booms which are manned by security personnel.

Photo 4: Up to date waste disposal tariffs are displayed at the site entrance.

Photo 1: Site notice board at the main entrance detailing the responsible person, permit holder, hours of operation, emergency numbers and class of the landfill site.


Photo 7: Compactor on the Phase 2 working face. Photo 8: Freeboard in the stormwater dams for Phase 1 and 2 was sufficient.

Photo 9: Soil saver and hydro-seeding has been implemented on portions of the outer slopes of Phase 2.

Photo 10: Signs of erosion were noted on portions of the outer slopes of Phase 2 at the time of the audit.

Photo 11: BH1 is located within the site. The borehole is fitted with a lockable cap.

Photo 12: BH2 is located outside the site; the borehole is clearly demarcated, with the collar seated in concrete and the lid is fitted with a lockable cap.


Photo 13: BH3 is located outside the site. The borehole

collar is seated in concrete and the borehole lid is fitted with a lockable cap.

Photo 14: Upstream BH1 is located outside of the site; the borehole is fitted with a lockable cap.

Photo 15: Upstream BH2 is located outside of the site; the borehole is fitted with a lockable cap.

APPENDIX 4

LATEST TONNAGES LANDFILLED

Waste Category Waste Code Transactions Total Mass

Municipal Waste GW0101 4305 26,899,716

Commercial/industrial Waste GW1001 194 2,329,980

Fly ash and dust GW1401 36 141,160

Bottom Ash GW1501 76 295,780

Mineral Waste-Others GW1703 20 184,080

Organic Waste-Garden Waste GW2001 208 516,060

Organic Waste-Food Waste GW2002 313 1,754,800

Organic Waste-Wood Waste GW2003 64 145,320

Sewerage Sludge GW2101 28 352,610

Construction/Demolition waste GW3001 1224 13,428,092

Glass GW5201 2 3,540

Others GW9901 42 1,136,640

Liquid/Sludge inorganic waste HW0501 229 4,568,960

Solid inorganic waste HW0502 181 4,733,380

Waste Oils_Waste Oil HW0701 147 2,137,260

Solids with halogens/sulphur HW0902 1 2,420

Liquids/Sludge organic waste HW1101 15 207,760

Solid organic waste HW1102 1 3,880

Fly ash / dust HW1401 4 18,920

Bottom_Ash HW1501 1 3,780

Slag_Other HW1603 1 4,360

Mineral Waste_Foundry Sand HW1701 1 6,760

Mineral Waste_Others HW1703 3 23,940

Miscellaneous HW9901 13 46,860

Total mass kg 7109 58,946,058

Total tons 58,946

Delisted Waste 11,758,160

Waste Category Report of FG between 2016-06-01 and 2016-06-30

1




Commercial/industrial_Waste GW1001 2 3,020


Bottom Ash GW1501 67 335,620







Glass GW5201 1 700

Tyres GW5401 6 7,740

Others GW9901 6 164,740


Solid inorganic waste HW0502 95 2,407,720

Waste Oils_Waste Oil HW0701 119 1,741,140

Liquids/Sludge organic waste HW1101 6 148,400





Total 7516 58,773,296

Total tons 58,773



2





Bottom Ash GW1501 72 283,440







Tyres GW5401 7 8,500

Others GW9901 10 98,160


Solid inorganic waste HW0502 14 261,920

Waste Oils_Waste Oil HW0701 11 238,980







Total 7047 51,350,162

Total tons 51,350



3




Commercial/industrial_Waste GW1001 5 3,980


Bottom Ash GW1501 26 103,880







Glass GW5201 2 4,420

Tyres GW5401 3 18,960

Others GW9901 18 181,100

Solid waste with Mercury HW0202 1 26,020


Solid inorganic waste HW0502 14 247,920

Waste Oils_Waste Oil HW0701 3 16,860






Total 6325 46,721,363

Total tons 46,721



4

APPENDIX 5

BI-ANNUAL WATER QUALITY MONITORING

LABORATORY RESULTS

Test Report Page 1 of 1

Client:

Address:

Report no:

Project:

Prime Resources Pty Ltd

The Workshop, 70 - 7th Ave, Parktown North, 2193

35133

Prime Resources

Date of certificate:

Date accepted:

Date completed:

Revision:

02 December 2016

24 November 2016

02 December 2016

0

Lab no:

Date sampled:

Sample type:

Locality description:

Analyses Unit Method

The results relates only to the test item tested.

Results reported against the limit of detection.

A = Accredited N = Non accredited O = Outsourced S = Sub-contracted NR = Not requested RTF = Results to follow NATD = Not able to determine

Results marked 'Not SANAS Accredited' in this report are not included in the SANAS Schedule of Accreditation for this laboratory.

Uncertainty of measurement available on request for all methods included in the SANAS Schedule of Accreditation.

www.aquatico.co.za 89 Regency Drive, R21 Corporate Park, Centurion, South Africa Tel: +27 12 450 3800 Fax: +27 12 450 3851

25680

23-Nov-

2016

Water

FG Borehole

1

25681

23-Nov-

2016

Water

FG Borehole

2

25682

23-Nov-

2016

Water

FG Borehole

3

25683

23-Nov-

2016

Water

FG

Upstream

Borehole 1

25684

23-Nov-

2016

Water

FG

Upstream

Borehole 2

25685

23-Nov-

2016

Water

FG Potable

25686

23-Nov-

2016

Water

FG

Stormwater

A pH @ 25°C pH ALM 20 6.51 8.10 7.20 6.64 6.24 7.18 7.65

A Electrical conductivity (EC) @ 25°C mS/m ALM 20 10.5 11.9 14.1 9.38 22.6 13.1 134

A Total dissolved solids (TDS) mg/l ALM 26 119 95 95 73 172 107 987

A Total alkalinity mg CaCO3/l ALM 01 19.8 50.0 82.5 17.0 93.5 58.3 184

A Chloride (Cl) mg/l ALM 02 0.996 7.07 <0.557 <0.557 2.18 <0.557 75.3

A Sulphate (SO₄) mg/l ALM 03 8.35 15.7 <0.141 <0.141 <0.141 <0.141 477

A Nitrate (NO₃) as N mg/l ALM 06 3.69 0.430 0.392 1.16 0.458 1.10 1.10

A Ammonium (NH₄) as N mg/l ALM 05 0.617 0.970 3.26 0.090 0.564 0.074 2.96

N Ammonia (NH₃) as N mg/l ALM 26 <0.005 0.052 0.023 <0.005 <0.005 <0.005 0.053

A Fluoride (F) mg/l ALM 08 <0.263 <0.263 <0.263 <0.263 <0.263 <0.263 0.407

A Calcium (Ca) mg/l ALM 30 3.41 4.38 8.56 0.616 10.8 8.61 120

A Magnesium (Mg) mg/l ALM 30 1.58 2.21 4.17 0.449 5.10 2.09 26.3

A Sodium (Na) mg/l ALM 30 10.4 27.5 10.4 7.87 22.7 14.9 139

A Potassium (K) mg/l ALM 30 2.11 1.48 2.75 1.26 5.33 1.05 16.5

A Aluminium (Al) mg/l ALM 31 <0.002 <0.002 <0.002 <0.002 <0.002 <0.002 <0.002

A Iron (Fe) mg/l ALM 31 <0.004 <0.004 0.310 <0.004 0.058 <0.004 <0.004

A Manganese (Mn) mg/l ALM 31 1.44 0.826 0.632 <0.001 0.053 <0.001 2.44

A Chromium (Cr) mg/l ALM 31 <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 <0.003

A Hexavalent chromium (Cr⁶⁺ ) mg/l ALM 09 <0.002 <0.002 <0.002 <0.002 <0.002 <0.002 <0.002

A Cadmium (Cd) mg/l ALM 31 <0.002 <0.002 <0.002 <0.002 <0.002 <0.002 <0.002

A Lead (Pb) mg/l ALM 31 <0.004 <0.004 <0.004 <0.004 <0.004 <0.004 <0.004

A E.coli CFU/100ml ALM 40 NR NR NR NR NR <1 NR

A Total coliform CFU/100ml ALM 40 NR NR NR NR NR <1 NR

A Chemical oxygen demand (COD) mg/l ALM 10 12.9 25.1 32.2 28.2 25.1 6.07 149

N Free cyanide (CN) mg/l ALM 14 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010

N Phenol mg/l ALM 15 <0.020 <0.020 <0.020 <0.020 <0.020 <0.020 0.077

N Mercury (Hg) mg/l ALM 35 <0.004 <0.004 <0.004 <0.004 <0.004 <0.004 <0.004

A Boron (B) mg/l ALM 33 <0.013 <0.013 <0.013 <0.013 <0.013 <0.013 0.155

N Acidity mg CaCO3/l ALM 60 3.54 4.42 8.46 7.82 40.3 7.82 11.0

APPENDIX 6

LATEST MONITORING COMMITTEE MEETING

MINUTES

1

MINUTES OF THE FG LANDFILL MONITORING COMMITTEE (LMC) –

FG Landfill Visitors Centre; Thursday 17 November @ 17H00

Attendees:

Leon Grobbelaar (LG) Interwaste – Landfill Director

Marius Conradie (MC) Interwaste – FG Landfill Manager

Hanré Crous (HC) Interwaste – Environmental Compliance Manager

Ettiene de Jager (EJ) Envitech – LFG Project Consultant

Grant Walters (GW) DEA – Enforcement

Michael Kapp (MK) Estate Manager – Midstream

Paul Claassen (PC) Environomics – Midstream Environmental Consultant

Sharon Tiepelt (ST) Resident

Noleen Wilson-Taylor (NWT) Resident

Christine Robinson (CR) Secretary – Glen Austin Residents’ Association (GARA)

Christelle James (CJ) Resident (left after site visit)

Apologies:

Rico Euripidou (RE) Groundwork – Environmental NGO

Musa Chamane (MCh) Groundwork – Environmental NGO

Ithumeleng Mogatutsi (IM) Groundwork – Environmental NGO

Stephen Pretorius (SP) Resident

Note:

⋅ Minutes were compiled integrating notes taken by S Tiepelt (supplemented by P Claassen) and Interwaste.

⋅ The meeting was preceded by a site visit attended by everyone to inspect the newly installed gas extraction

and flare infrastructure.

Item Discussion Action

1.

Welcome & Introductions

LG welcomed everyone present to the FG Landfill Monitoring Committee meeting. Those in

attendance were given the opportunity to introduce themselves.

-

2.

Attendance Register & Apologies

The attendance register was circulated for signature. Four apologies were received.

-

2


3.

Minutes of Previous Meeting & Matters Arising

[3.2] Stack emission monitoring of the flare will be conducted once the system is stable. A quote

has been obtained from an air quality consultant for the monitoring of SO2, CO, H2S and VOC

concentrations, as well as the H2S and VOC destruction efficiency. Particulates are excluded as

it is not relevant to gas combustion.

[3.5] Interwaste still to explain how they are going to feedback info regarding complaints and

tonnages, and where the waste is coming from, and days what waste is delivered. The frequency

is to be determined of feedback. Health issues also need to be recorded and correlated with the

complaints info. Committee need to see this solution in action, and to see the complaints

register.

[3.17] Comments on Terms of Reference:

Point 1.5 - Needs to be put under point 2.5

Point 2.4 - Ward councillor is allowed to attend the MC meetings.

Point 2.5(b) - Change the word “shall” to “should”.

Point 3.4 - Two thirds of the committee members should be available to make a quorum.

Point 5.5 - Change the word “recommending” to “recommendations”.

[3.24] Interwaste to send out communication to explain their understanding of the license.

Est. early

2017

Next LMC

Meeting

(16/02/2017)

ToR

Amended

To be

discussed

(16/02/2017)

4.

FGLMC Terms of Reference Finalisation

See point 3.17 above. Interwaste to send a copy of all the changes to committee for finalisation.

If any other comments are to be submitted they must be in by 30/12/2016.

Final

attached

5.

5.1

5.2

5.3

Landfill Management Report

(Authority Interaction, LFG Management, Ambient Air Quality, Environmental Monitoring)

GW suggested that the MC committee needs a black representative. IW to contact councillor

on Tembisa side. ANC youth league details to be sent to IW to invite them to the meeting. GW

to send ANC Youth league contact details to IW.

The 2000 m3 flare was installed within the planned time-frames and has been operational for 3

weeks. Organics UK came to SA to supervise the installation of the flare, and compiled a

construction completion report. They are considered experts and have created a guideline of

landfill gases management for the UK EPA. Envitech was also present.

The flare is currently operating at approximately 1000 m3/h, and steadily increasing. Up and

down times are checked and monthly reports on gas flow compiled. Once the extraction and

flare is stable (reduced positive pressure from landfill), monitoring will be conducted and the

scope / requirements for online monitoring investigated. Landfill gas cannot be abstracted at

uncontrolled rates due to risk of fire.

GW/HC -

Next LMC

Meeting

(16/02/2017

-

-

3


5.4

5.5

5.6

5.7

5.8

5.9

5.10

5.11

5.12

Interwaste is considering various beneficial use options for the landfill gas over the long term,

including electricity genartion (proposals have been received). 1000 m3/h of gas can deliver

approximately 1 megawatt of power. Power generation, will not be done in next year

The previous smaller flares were rented, and have been removed after commissioning of the

new flare.

Generally. maximum gas generation is reached in approximately 2 to 4 years. Landfill gas builds

up over 10 years and then reduces in volume.

What is happening with the license? Norms and standards for landfill gas extraction regulate

the project. An external audit has been done. The EMP needs to be revised as required for the

new flare which has different specifications. Although the Minimum Requirements (1998) do

contain some information on landfill gas, any requirements have been superseded by the Norms

and Standards (2013).

PC stated that he looked at 22 industries in Olifantsfontein area. He checked license conditions

at most sites. Brickworks, for example, create waste and emit gasses and have a mining licence,

but don’t have an atmospheric emissions licence (AEL) or a waste licence. The FG Landfill has a

waste licence but don’t have an AEL even if it emits atmospheric emissions. Most of the other

industries (those that qualify) have AELs but don’t have other licences (the exception is A-

Thermal Retort Technologies that have both AEL and waste licences). The different licences and

authorisations required are also managed by different authorities across the spheres of

government. This uncoordinated regulatory system makes it extremely difficult to figure out

what licences/authorisation each facility should or shouldn’t have.

Why doesn’t the site have water use license - new sites need one? Air quality legislation too.

Not allowed to release pollutants into water or rivers. Stack doesn’t need an emissions license,

and a water use licence is also not required.

Boilers e.g. Thermopower release a lot of SO2. A proper dispersion model is needed to

determine influence on ambient air. Now that there is a stable system to measure, estimates

are not required. There aren’t emission standards for a flare. A model that is not questionable

is required.

IW has more emissions than autoclaves used for sterilisation of medical waste that use heavy

oil boilers with low SO2 emissions to create steam. Most boilers in the area is small and use

heavy oil instead of coal.

PC indicated that at the request of and in consultation with DEA, the Home Owners Association

of Midstream monitored SO2 for 4 months, against the NAAQS with 10-minute, 1-hour and a

24-hour standard. The 1-year standard or annual average has fallen away. PC handed out the

preliminary results of the measurements (attached) for the period of 4 August to 1 September

2016 together with a graph compiled by the CSIR to the members of the committee. This

information was requested at the previous meeting and should be appended to the minutes.

Acquisition of the Dräger X-am 7000 monitor was requested by DEA.

-

-

-

Interwaste

-

-

-

-

Attached

4


5.13

5.14

5.15

5.16

5.17

5.18

5.19

5.20

5.21

5.22

MK wants the intervals etc. from IW for their testing of gases.

Dr van Niekerk (Infotox) compiled a draft report on the monitoring which was supplied to DEA.

The DEA issued a Pre-Directive to IW based on the results of the monitoring, and a second

Addendum notice based on the draft Infotox Report. It is an administrative step, and IW now

for the first time can review the information, and have time to respond to DEA on the two

notices and to Willie Van Niekerk’s report.

It would be more desirable from an IW perspective to get measurement information directly

from PC. IW struggled to get info on air quality in the region, but obtained some for the area

from the South African Air Quality Information System (SAAQIS - www.saaqis.org.za). This was

used in the response to DEA (some extracts from website given to PC by HC).

GW indicated that DEA received responses on the notices. Extensive discussions between IW

and Dr Willie Van Niekerk took place, and some of the findings are not conclusive (e.g.

measurement units – ppm vs. ppmv). A review of these issues is required. PC indicated that

ppmv stands for parts per million per volume measured. Realised IW may have an issue with

the way the gas is measured.

The Midstream monitoring included HCN, SO2 and H2S, and constitutes a significant amount of

raw data that IW had to consider. SO2 levels were above ambient standards. IW checked

ambient SO2 regionally and internationally and don’t believe the results can be as high as the

SO2 results presented by PC. Ambient monitoring by GeoZone will provide further information,

particularly SO2.

The DEA also raised issues related to water quality. An off-site hydro census would be done for

a 1,5km radius on boreholes. Letters are going out on 18/11/2016 to home owners. Prime

Resources have been appoints to check the boreholes. MC handed out a map to show the

properties affected.

Further chemical analysis of leachate, storm water run-offs and soil have also been conducted.

Parameters were check if anything can be linked to on-site activities, e.g. manganese in soil

sampled at 12 points from the fence to the road, shows 50% higher Mn than leachate, thus

naturally occurring in the soil.

PC stated that FG site is located on granite, with a perched water table above a plintic layer in

the soil (ouklip). This may result in H2O in near surface water flow at a depth of 1m to 2m above

the plintic layer that may not be detected in borehole monitoring.

NWT that the Water Ski Park also be tested. IW will contact surrounding landowners for contact

details and other surface water areas.

IW wants a co-operative approach w.r.t. air quality monitoring in the region. MK indicated he

will have discussion of giving info to IW, and asked where would IW feel comfortable about

putting the equipment? HC replied that a single monitoring point does not provide any

conclusive evidence.

?

Interwaste

-

-

-

-

-

-

IW

MK

5


5.23

5.24

5.25

5.26

5.27

5.28

5.29

PC disagreed – Two weather stations were given to the DEA, which can measure the wind speed,

air pressure, temperature etc. and see definitive trends coming out from the data. Measures in

1 direction, doesn’t make 1 direction invalid. Pick up different pollutants at the same time. SO2

peaks, H2S peaks, HNS peak, therefore coming from the same source. Otherwise wouldn’t have

the same peaks. Measured at Christelle’s place in the yard, under thatch roof, next to their

room. 44 people staying there. Children and adults. Some with pre-existing issues and other

people don’t have issues. It represents a good sample of people that can be monitored for

health conditions. MK said an expert was consulted on this. PC said the monitor is located as

close to ground level as possible.

HC stated that a lot of peaks in the late evening and early morning were noticed, which doesn’t

correlate with consistent flare operation. Further, one wouldn’t expect the correlation of H2S

and SO2, it shouldn’t be both gases, rather one or the other.

ST experienced burning skin between 9pm and 10:30pm, and a bad sulphur smell on Monday.

PC indicated waking up at 1am due to an acid smell. Worse smell on weekends, Saturday and

Sundays in the evenings, and Monday mornings. Do you remove leachate on a weekend or not?

It is a pattern. MK queried whether the stack was off-line at any time? HC said no. NWT said

that Monday was really bad - feeling nauseous. Smell also hit Midlands according to whatsapp

group. Headache, chest constrictions. Feint smell in Centurion. RCE brain fuzz and headaches.

CR expressed unhappiness about email incident regarding mails bouncing back and being told

by HC that the residents are lying. HC clarified that he accepted emails being returned, but said

CR was incorrect in implying that emails are blocked on purpose. LG said IW check emails. HC

says IT Department went to the service provider to check. Test the alternative email address

[email protected]. GW said DEA senior people want a complaints record to

make a decision. DEA will deal with facts as soon as deputy general is back on Monday/ Tuesday.

21/11/2016 or 22/11/2016.

IW was aware of odours on-site when the gas extraction system was installed and trenching

occurred in August. The previous ambient air sampling is at the laboratory for analysis, and the

latest ambient air samplers were placed yesterday, 16/11/2016. IW to distribute air quality

results to MC committee.

PC said SO2 doesn’t correspond to what Midstream are getting. Measuring periods over 2 week

periods doesn’t measure the peaks, like the continuous measuring that Midstream is doing.

Midstream picks up the peaks as this is the nuisance factor. HC replied that SO2 is similar all over

the area and corresponds to Ekurhuleni amounts. Measuring of the gases has been discussed.

If IW have to look at the peaks this will be done separately.

NWT asked why can’t IW do continuous monitoring? HC/LG replied that IW can put to

management and motivate for this, and could sponsor a probe. Government is responsible for

air quality measuring though. Other significant sources of SO2 in the area include airports,

traffic, coal burning, Clayville industries. Need a comparative analysis, can’t have a single point.

IW can work with Midstream. Project at Robinson at City Deep, has a caravan setup to monitor

gas. If IW and Midstream can work together, we may get answers. If all goes as planned, the

new flare would make a notable difference within 8 months.

-

-

-

All

HC

-

IW

6


5.30

5.31

5.32

5.33

5.34

5.35

CR stated she was sent to optician eye hospital as her eyes were streaming. Unitas results say

she has no cataracts, but corneas are pitted. They put dye in and cornea absorbed all the dye.

NWT added that the community is feeling sick and need to have this issue sorted out.

Olifantsfontein and Tembisa monitoring stations are down, so getting data from elsewhere. MK

is speaking to Stewart (EMM) who said the stations are down, and that not all the equipment

has been delivered. GW will contact Stewart and find out where they getting their air quality

data from. HC indicated SAAQIS has data. There are big gaps for Ekurhuleni and Tshwane, and

Buccleuch data stopped around April 2016. PC said that the Gauteng Provincial Environmental

Management Framework determined that most municipal air quality measurement stations are

not working. Funds etc. are low or non-existent. PC will follow up re data on the SAAQIS site.

H2S converts to SO2. H2S can’t be more than 6% of LFG. At a flow rate 1,000 cubes per hour,

compared to industry, the flare is very small. PC stated Consol down the road have high stacks

and would rather affect people 15km away than close to the site. They make use of Sasol natural

gas and electricity for their furnaces. HC said IW will undertake SO2 monitoring and can scrub

going forward if it is necessary. Electricity generation and other beneficiation projects are being

reviewed - it is a step-wise process. PC replied that the problem is communities are being

affected on a daily basis. IW will not be able to resolve the problem if it is “step-wise”. People

can’t put up with it any longer.

ST said reporting needs to be simpler for the complaints. People won’t be able to do the

reporting if it is too complicated. Need health side effects as well, and to report if there is no

smell. IW will make the reporting system simpler. Will try a whatsapp group and an email

address.

PC said Conditions with no wind and cold weather seems to make the smell conditions worse.

ST asked that methane is monitored. HC said it is odourless. Before monitoring methane, HC

will send the health side effects to the committee. MK said that you don’t pick up methane in

the measurements at all. The last Environmental Audit was conducted on 14/11/2016 and the

report should be ready mid-January. Will be distributed to MC committee.

-

GW

PC

-

HC

-

HC

6.

General - None

7.

7.1

7.2

Way Forward & Closure

The following resolutions/tasks were identified for attention:

i. Water testing results at Water Ski Park and the Hydrocensus results need to be distributed

to the MC committee, and the actual results per borehole included in the findings.

ii. Interwaste employees have been tested in terms of Occupational Health and Safety. Results

to be distributed - Have not received results yet.

LG thanked everybody for their time and inputs, and closed the meeting around 19:30. The next

Monitoring Committee Meeting will be held at the beginning 2017. IW to confirm date.

HC

HC

ooOoo

7

Documents

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