Scaw South Africa Pty Ltd Gaut 002/13 -14/E0162rhdhv.co.za/media/201210/Gas Fired Furnace at Scaw Metals...Scaw South Africa Pty Ltd (“Scaw Metals”) is proposing to install a gas

Draft Environmental Management Programme the Proposed Installation of Metals’ High Chrome Ball Plant

A Report For: Scaw South Africa Pty Ltd

GDARD Reference No: Gaut 002/13

Date: January 2014

Draft Environmental Management Programme (EMPr) the Proposed Installation of a Gas Fired Furnace at Scaw Metals’ High Chrome Ball Plant in Germiston

South Africa Pty Ltd

Gaut 002/13-14/E0162

(EMPr) for Gas Fired Furnace at Scaw

© Royal HaskoningDHV All rights reserved No part of this publication may be reproduced or transmitted in any form or by any means, electronic or mechanical, without tpermission from Royal Haskoning.DHV

DOCUMENT DESCRIPTION

Client:

Scaw South Africa Pty Ltd

Report Name:

Draft Environmental Management Programme (EMPr) for the Proposed Installation of a Gas Fired Furnace at Scaw Metal's High Chrome Ball Plant i

Royal HaskoningDHV Reference Number

T01.JNB.000531

GDARD Reference No:

Gaut 002/13-14/E0162

Compiled by:

Sibongile Gumbi

Reviewer and Approver:

Mark Freeman

No part of this publication may be reproduced or transmitted in any form or by any means, electronic or mechanical, without t

DOCUMENT DESCRIPTION

Draft Environmental Management Programme (EMPr) for the Proposed Installation of a Gas Fired Furnace at Scaw Metal's High Chrome Ball Plant in Germiston.

ference Number:

No part of this publication may be reproduced or transmitted in any form or by any means, electronic or mechanical, without the written

1 PROJECT DESCRIPTION

1.1 Context and Background

2 LEGAL REQUIREMENTS

3 MANAGEMENT AND MONITORING PROCEDURES

3.1. Roles and Responsibilities

3.2. Training and Environmental Awareness

3.3. Monitoring

3.4. Checking and Corrective Action

4 ENVIRONMENTAL MANAGEMENT PROGRAMME

4.1. Purpose and Objectives of the EMPr

5 CONSTRUCTION PHASE

6 POST CONSTRUCTION PHASE

7 OPERATIONAL PHASE

TABLE 1: APPLICABLE LEGISLATION

TABLE 2:ROLES AND RESPONSIBILITIES

TABLE 3:ENVIRONMENTAL EDUCATION AND TRAINING

TABLE 4:SITE CAMP ESTABLISHMENT

TABLE 5:CONSTRUCTION TRAFFIC AN

TABLE 6:AIR QUALITY MANAGEMENT

TABLE 7:GROUND AND SURFACE WATER MANAGEMENT

TABLE 8:WASTE MANAGEMENT

TABLE 9:REHABILITATION

TABLE 10:OPERATIONAL

FIGURE 1: LOCATION OF THE STUDY AREA WITHIN JOHANNESBURG

FIGURE 2: SCAW METAL GROUP PROPERTY BOUNDARY

FIGURE 3: LOCATION OF SCAW METAL HIGH CHROME BALL PLANT

TABLE OF CONTENTS

MANAGEMENT AND MONITORING PROCEDURES

Training and Environmental Awareness

Checking and Corrective Action

ENVIRONMENTAL MANAGEMENT PROGRAMME

Purpose and Objectives of the EMPr

CONSTRUCTION PHASE

LIST OF TABLES


TABLE 2:ROLES AND RESPONSIBILITIES

TABLE 3:ENVIRONMENTAL EDUCATION AND TRAINING

TABLE 4:SITE CAMP ESTABLISHMENT

TABLE 5:CONSTRUCTION TRAFFIC AND SITE ACCESS

TABLE 6:AIR QUALITY MANAGEMENT

D SURFACE WATER MANAGEMENT

LIST OF FIGURES




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DEFINITIONS

Environment In terms of the National Environmental Management Act (NEMA) (No 107 of

1998), “environment” means the surroundings within which humans exist and that

are made up of:

(i) The land, water and atmosphere of the earth;

(ii) Micro

Any part or combination of (i) of (ii) and the interrelationships among and between

them; and the physical, chemical, aesthetic and cultural properties and conditions

of the foregoing that influence human health and wellbeing.

Environmental Management Programme

A detailed plan of action prepared to ensure that recommendations for enhancing

or ensuring positive impacts and limiting or preventing negative environmental

impacts are implemented during the life

Management Programme

Environmental Management System and ISO 14001 standard compliance

system.

Scaw Project Manager The person appointed by

notified, by name and in writing by

the Contract.

Environmental Site Agent An individual appointed by the Contractor to be present on site to act on behalf of

the Contractor in matters concerning the implementation and day to day

monitoring of the EMPr.

Environmental Control Officer

An individual nominated through the Project Manager to be present periodically

on site to act on behalf of the Project Manager in matters concerning the

implementation and monitoring of the EMPr.

Contractor A person or company appointed by Scaw to carry ou

Incident An undesired event which may result in significant environmental impacts but can

be managed through internal response

Environmental Impact A change to the environment, whether adverse or beneficial, wholly or partially

resulting from an organisation’s activities, products or services.

Mitigation Measure Measures designed to avoid, reduce or remedy adverse impacts.

Rehabilitation Rehabilitation is the return of a disturbed area to a state which approximates the

state (where possible) which it was in before construction.

In terms of the National Environmental Management Act (NEMA) (No 107 of


are made up of:

The land, water and atmosphere of the earth;

Micro-organisms, plant and animal life, and






impacts are implemented during the life-cycle of a project. T

Management Programme (EMPr) should preferably form part of S


system.

The person appointed by Scaw from time to time to act in the capacity and

notified, by name and in writing by Scaw to the Contractor, to act as required in

ontract.

An individual appointed by the Contractor to be present on site to act on behalf of

ontractor in matters concerning the implementation and day to day

monitoring of the EMPr.

individual nominated through the Project Manager to be present periodically


implementation and monitoring of the EMPr.

A person or company appointed by Scaw to carry out stipulated activities.

An undesired event which may result in significant environmental impacts but can

be managed through internal response.

A change to the environment, whether adverse or beneficial, wholly or partially


Measures designed to avoid, reduce or remedy adverse impacts.

Rehabilitation is the return of a disturbed area to a state which approximates the

state (where possible) which it was in before construction.

In terms of the National Environmental Management Act (NEMA) (No 107 of







cycle of a project. This Environmental

form part of Scaw’s


from time to time to act in the capacity and

to the Contractor, to act as required in

An individual appointed by the Contractor to be present on site to act on behalf of

ontractor in matters concerning the implementation and day to day

individual nominated through the Project Manager to be present periodically


t stipulated activities.

An undesired event which may result in significant environmental impacts but can

A change to the environment, whether adverse or beneficial, wholly or partially


Measures designed to avoid, reduce or remedy adverse impacts.

Rehabilitation is the return of a disturbed area to a state which approximates the

Page | 1

1 PROJECT DESCRIPTION

1.1 Context and Background

Scaw South Africa Pty Ltd (“Scaw Metals”) is proposing to install a gas fired heat treatment furnace at their

High Chrome Ball Plant (HCBP) in their Union Junction facility located in Germiston, Gauteng Province. The

heat treatment furnace will be a gas-fired furnace as opposed to the electric furnace currently installed. The

new furnace will be installed within the current heat treatment section of the HCBP adjacent to the existing heat

treatment furnace. Heat treatment of chrome balls is undertaken after casting in order to alter the internal

structure and make it more suitable for its further purpose as a grinding agent.

Scaw Metals manufactures a diverse range of steel products. The Grinding Media Division at Union Junction is

the largest producer of cast high chrome grinding media in the southern hemisphere and has an opportunity to

increase its production volume as a result of an increased market demand. Therefore, an additional heat

treatment furnace will be required to meet this demand.

Electrical supply is a limited resource both at Scaw Metals and in the entire country. From a strategic point of

view, installing a gas-fired furnace utilising natural gas will reduce Scaw’s demand on the electrical grid. In

addition, the utilisation of natural gas as a fuel source will realise a reduction in energy costs when compared to

electricity as a fuel source.

The proposed project is located in the HCBP plant at Union Junction along Dekema and Centime Roads in the

Wadeville industrial area, Germiston South, which falls within the jurisdiction of Ekurhuleni Metropolitan

Municipality (refer to Figures 1 to 3). The study area is surrounded by industries, commercial businesses,

residential houses (Dinwiddie) and Provincial Roads (M37, R103 and R554), as well as National Roads (N3

and N17).

Page | 2

Extent of the Study Area in

Johannesburg East Rand


Page | 3


Page | 4


Page | 5

2 LEGAL REQUIREMENTS

Table 1 below lists the relevant policies and legislation which are applicable to the proposed project.


LEGISLATION INTERPRETATION

The Constitution ( Act No 108 of 1996) This relates to the environmental rights to a pollution

free environment for the surrounding community,

industries and commercial businesses.

National Environmental Management Act ( Act No 107

of 1998)

The developer has a general duty to care for the

environment and to establish measures as may be

needed to demonstrate such care.

National Environmental Management: Air Quality Act

(Act No 39 of 2004).

This relates to the control of dust, emissions, odour

and noise.

National Water Act (Act 36 of 1998). This relates to the use and management of water

resources, including pollution prevention and remedy

of incidents.

National Environmental Management: Waste Act (No

59 of 2008)

It is the responsibility of the developer, and its

contractors generating waste, to ensure that any

waste (solid or liquid) is stored appropriately

(containers) and safely, treated where required and

then disposed of in an environmentally sound manner.

Ekurhuleni Metropolitan Municipality By Laws

Page | 6

3 MANAGEMENT AND MONITORING PROCEDURES

3.1. Roles and Responsibilities

It is anticipated that several key professionals will need to form part of the project execution team and their

responsibilities in respect of the environment are outlined in Table 2 below.

TABLE 2: ROLES AND RESPONSIBILITIES

ROLES RESPONSIBILITIES

Project Manager The Project Manager is responsible for overall management of the project, including the

EMPr implementation. The following tasks will fall within his / her responsibilities:

� Be familiar with the recommendations and mitigation measures of this EMPr, and

ensure implementation of these measures on site;

� Monitor site activities on a regular basis for compliance;

� Conduct internal audits of the construction site against the EMPr;

� Confine the construction site and construction activities to the demarcated area; and

� Rectify transgressions through the implementation of corrective action.

Environmental

Control Officer

The responsibilities of the Environmental Control Officer are to:

� Monitor the implementation of the EMPr during the construction phase;

� Be familiar with the recommendations and mitigation measures of the site-specific

EMPr for the project;

� Ensure protection measures are implemented on site;

� Monitor all site activities on a monthly basis for compliance;

� Conduct monthly audits of the site according to the EMPr, and report findings to the

Project Manager/Contractor;

� Recommend corrective action for any environmental non-compliance noted on site;

� Compile a monthly report highlighting any non-compliance issues as well as progress

and compliance with the EMPr prescriptions; and

� Conduct once-off training with the Contractor on the EMPr and general environmental

awareness.

It must be noted that the responsibility of the ECO is to monitor compliance and give

advice on the implementation of the EMPr, and not to enforce compliance. Ensuring

compliance is the responsibility the Site Agent appointed by the Contractor.

Contractor The Contractor and its sub-constructors are responsible for overall execution of the

activities envisioned in the construction phase, including implementation and compliance

with the recommendations and conditions of the EMPr. The Contractor shall therefore

ensure compliance with the EMPr at all times during construction activities and maintain

an environmental register which keeps a record of all environmental incidents which occur

on site during construction. The incidents may include:

� Public involvement /complaints;

� Health and Safety incidents

� Incidents involving hazardous materials stored on site; and

� Non-compliances with the EMPr

� The Contractor is responsible for the implementation of corrective actions issued by

the ECO and Project Manager within a reasonable or agreed period time.

Environmental

Site Agent

The Environmental Site Agent (ESA) should:

� Be fully conversant with the content of the EMPr;

� Be fully conversant with all relevant environmental legislation applicable to the project,

and ensure compliance with any legal obligations;

� Compile the construction Method Statements together with the Contractor that will

Page | 7

ROLES RESPONSIBILITIES

specify how potential environmental impacts in line with the requirements of the EMPr

will be managed and how they will practically ensure that the objectives of the EMPr

are achieved;

� Convey the contents of this EMPr to the construction site staff and discuss the

contents in detail with the Contractor;

� Undertake regular and comprehensive daily inspections of the site and surrounding

areas in order to monitor compliance with the EMPr;

� Take appropriate action if the specifications contained in the EMPr are not followed;

� Monitor and verify that environmental impacts are kept to a minimum, as far as

practically possible;

� Order the removal from the construction site of any person(s) and/or equipment in

contravention of the specifications of the EMPr;

� Maintain the following documents on site:

o EMPr;

o Construction layout plan (showing storage areas etc)

o Construction method statements;

o A site diary;

o Environmental incidents register; and

o Update Material Safety Data Sheets (MSDS) when necessary.

3.2. Training and Environmental Awareness

It is important to ensure that the Contractor and their sub-contractors have the appropriate level of

environmental awareness and competence to ensure continued environmental due diligence and ongoing

minimisation of environmental harm during construction. Training needs should be identified based on the

available and existing capacity of site personnel (including for all Contractors and sub-contractors) to undertake

the required EMPr management actions and monitoring activities. It is vital that all personnel are adequately

trained to perform their designated tasks to an acceptable standard.

The environmental training is aimed at:

� Promoting environmental awareness;

� Informing the Contractor of all environmental procedures, policies and programmes applicable;

� Providing generic training on the implementation of environmental management specifications; and

� Providing job-specific environmental training in order to understand the key environmental features of the

construction site and the surrounding environment.

In addition to training, general environmental awareness must be fostered among the project’s workforce to

encourage the implementation of environmentally sound practices throughout the duration of the construction

phase through regular toolbox information talks.

3.3. Monitoring

A monitoring programme should be in place to ensure compliance with the EMPr and to monitor any

environmental issues and impacts which could result in significant environmental impacts for which corrective

action is required. A monitoring programme should be implemented for the duration of the construction phase

of the project. This programme must include:

Page | 8

� Monthly site audits that will be conducted by the independent Environmental Control Officer

� Compilation of a monthly audit report which will document findings and recommend corrective action to be

taken where required. Subsequent reports will provide feedback on whether previous non conformances

raised have been resolved, thereby ensuring continual improvement of the site’s environmental

performance; and

� Daily site inspections will be conducted by the Environmental Site Agent to ensure daily implementation of

the EMPr conditions and provide corrective actions.

3.4. Checking and Corrective Action Checking and corrective action forms part of the environmental management function and is aimed at ensuring

that the necessary environmental management activities are being implemented according to the EMPr and

that the desired outcomes are achieved.

4 ENVIRONMENTAL MANAGEMENT PROGRAMME

4.1. Purpose and Objectives of the EMPr

The Environmental Management Programme (EMPr) has been compiled to provide recommendations and

guidelines according to which construction activities at HCBP must be undertaken, as well as to ensure that all

relevant factors are considered for implementing an environmentally responsible development.

This EMPr informs all relevant parties, including the Project Manager, Contractor and all other staff employed

by the Scaw Metals Group on site, as to their duties in the fulfilment of the environmental legal requirements for

the construction of the gas fired heat treatment plant and its associated infrastructure, and with particular

reference to the prevention and mitigation of anticipated potential environmental impacts.

The objectives of the EMPr are to:

� Identify a range of mitigation measures which could reduce and mitigate the potential environmental

impacts to minimal or insignificant levels;

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

� Identify measures that could optimize beneficial impacts;

� To create management structures that address the concerns and complaints of the public with regards to

the development;

� To establish a method of monitoring and auditing environmental management practices during all

implementation phases of the project;

� Ensure that the final design, construction and operational phases of the project follow the principles of

Integrated Environmental Management (IEM);

� Specify time periods within which the measures contemplated in the EMPr shall be implemented where

appropriate.

The emphasis of the EMPr is to:

� Avoid impacts by not performing certain actions;

� Minimise impacts by limiting aspects of an action;

Page | 9

� Rectify impacts through consideration of the affected environment;

� Compensate for impacts by providing substitute resources or environments;

� Minimise impacts by optimising processes, structural elements and other design features;

� Maximise benefits accruing from the project and

� Provide ongoing monitoring and management of the environmental impacts of the development by

documenting any EMPr digressions / good performances.

Page | 10

5 CONSTRUCTION PHASE

TABLE 3: ENVIRONMENTAL EDUCATION AND TRAINING

PHASE CONSTRUCTION CONTRACTOR & ESA WEEKLY

ENVIRONMENTAL EDUCATION AND TRAINING

(This section deals with the environmental training of employees)

RESPONSIBILITY FREQUENCY / MONITORING

REQUIREMENTS

Environmental Training

1. The Environmental Site Agent (ESA) must ensure that all site

personnel have a basic level of environmental awareness training.

Topics covered should include;

• What is meant by “Environment”;

• Why the environment needs to be protected and conserved;

• How construction activities can impact on the environment;

• What can be done to mitigate against such impacts;

• Awareness of emergency and spills response provisions; and

2. Environmental Training should be provided to the employees

through toolbox information talks. These should be relevant to

specific construction work or activities.

3. Staff operating equipment (such as excavators, loaders, etc.) shall

be adequately trained and sensitised to any potential hazards

associated with their tasks. Proof of training to be kept in an

environmental file.

4. The ESA must be conversant with all legislation pertaining to the

environment applicable to this contract and must be appropriately

trained in environmental management and must possess the skills

necessary to impart environmental management skills to all

personnel involved in the contract.

Page | 11

TABLE 4: SITE CAMP ESTABLISHMENT

PHASE CONSTRUCTION DAILY CONTRACTOR & ESA

IMPACT SOURCE MITIGATION MEASURE MONITORING ACTIONS & FREQUENCY

RESPONSIBILITY FOR IMPLEMENTATION

Disturbance to neighbouring landowners.

Location of construction camp close to neighbouring land owners.

1. Site construction camp location and the layout

plans must be approved by the Project

Manager.

2. The location must take into account the

proximity to neighbouring landowners.

3. The Contractor must obtain consent from the

Project Manager and the landowners prior to

erecting any construction camp infrastructure.

Stormwater discharge to neighbouring properties.

Poor management of stormwater and drainage at the construction site.

1. The Contractor must attend to stormwater

drainage of the site to avoid standing water and

/ or sheet erosion by installing diversion berms

where needed.

Unauthorised access and theft at the site camp.

Unauthorised access of the public to the site.

1. The site camp must be secure at all times to

prevent unauthorised access at the construction

site.

Site contamination/ pollution.

Improper storage and use of equipment and hazardous substances (chemicals, paint and cement).

1. Hazardous substances need to be kept in a

secured storage area which is bunded and/or

has an impermeable floor layer that is able to

contain spillages.

2. The hazardous substance storage area needs

to be locked at all times.

3. Spill kits must be kept at the hazardous

substance storage facility to treat and manage

any spills immediately. All contaminated

soil/clothing/material must be disposed of at a

licensed hazardous landfill site.

4. The hazardous material storage facility should

be sited away from stormwater drainage lines.

5. Clear warning signage must be placed at all

storage areas containing hazardous substances

/ materials.

6. Staff dealing with these materials / substances

must be aware of their potential hazard and

Page | 12




follow the appropriate safety measures.

Air and soil pollution and site contamination.

Improper handling of cement, fuel, paint and other chemicals on site.

1. Used paint tins/brushes must be disposed of at

hazardous landfill sites.

Use of Scaw Metals equipment and services.

Misuse of Scaw Metals equipment and services.

1. The Contractor must engage with the Project

Manager regarding the temporary access to and

usage of services located within the Scaw

Metals premises e.g. electricity and water.

TABLE 5: CONSTRUCTION TRAFFIC AND SITE ACCESS




Disturbance to the

neighbouring

landowners.

Construction vehicles 1. Appropriate traffic signage must be erected on

site by the Contractor to alert other road users

to construction activities.

2. The Contractor should strategically position the

site entry and exit points to ensure that there is

minimum impact to the traffic flow on

neighbouring streets.

3. The Contractor must ensure that local access

roads are not damaged by construction

vehicles. If damage does occur, it needs to be

attended to immediately to avoid long term

problems.

Page | 13

TABLE 6: AIR QUALITY MANAGEMENT




Generation of dust. Vehicles driving at a high speed and construction activities which result in dust generation.

1. The Contractor shall be responsible for dust

control (water spraying) on site to ensure no

nuisance is caused to the neighbouring

landowners.

Air emissions. Un-serviced construction vehicles and the servicing of vehicles on site.

1. The Contractor must regularly service the

construction vehicles and machinery used on site

at an approved off site service station.

TABLE 7: GROUND AND SURFACE WATER MANAGEMENT




Water contamination. Improper storage and use of hazardous substances including cement, paints and other chemicals.

1. The Contractor must remove contaminated

wastewater resulting from construction activities

and dispose of it at a licensed commercial

wastewater treatment facility.

2. Used oil on site must be managed accordingly.

3. Accidental spillages of hazardous substances

(i.e. cement, paints and other chemicals) that

occur on site must be contained and remediated

as soon as possible.

4. On site ablution facilities need to be placed in a

bunded area and serviced regularly.

Water wastage. Misuse of water. 1. The Contractor and workers need to use water

responsibly and avoid unnecessary wastage.

Taps should not be left open and leaking taps

should be repaired immediately.

Disruption of Scaw Metals operational

The Contractor and its workers accessing water

1. The Contractor must liaise with the Project

Page | 14




activities and services. and other services from Scaw Metals’ municipal supply.

Manager with regards to accessing potable water

and other services from the Scaw Metals’ supply,

monitor the amounts utilised and pay Scaw

Metals accordingly.

TABLE 8: WASTE MANAGEMENT




Ground and water pollution and aesthetic impact.

Insufficient waste bins, incorrect labelling of waste bins, mixing of general, construction rubble and hazardous waste and storage of waste on site.

1. Sufficient waste bins shall be provided on site to

encourage waste separation and for recycling

purposes.

2. Refuse bins shall be placed at strategic

positions to ensure that litter does not

accumulate on site.

3. Construction workers need to be encouraged to

use the waste bins provided at all times, and

littering should be prohibited.

4. Skip waste containers should be kept on site to

dispose of construction rubble. Containers must

be removed when they fill up to maintain a clean

site.

5. Waste disposal certificates need to be obtained

by the Contractor from the waste disposal

facility.

6. Hazardous waste may not be stored on site in

excess of a 90 calendar day period.

Page | 15

6 POST CONSTRUCTION PHASE

TABLE 9: REHABILITATION

PHASE POST CONSTRUCTION CONTRACTOR & ESA DAILY

IMPACT REHABILITATION

(This section deals with the rehabilitation of construction sites)


REQUIREMENTS

MITIGATION STATEMENT

1. The construction site and camp is to be checked for spills of

substances such as oil, paint, etc, and these shall be cleaned up.

2. Surfaces are to be checked for waste products from activities such

as concreting and cleared accordingly.

3. All construction waste and rubble is to be removed from the site

and disposed of to the landfill site.

4. The site is to be cleared of all litter.

5. Fences, barriers and demarcations associated with the

construction footprint are to be removed from the site.

Page | 16

7 OPERATIONAL PHASE TABLE 10: OPERATIONAL

PHASE OPERATIONAL PHASE PLANT MANAGER ANNUALLY /CONTINUOUSLY

IMPACT AIR QUALITY EMISSIONS , ENERGY CONSUMPTION AND

SAVINGS

(This section deals with the air quality impacts, energy consumption

and savings at the HCBP)


REQUIREMENTS

MITIGATION

STATEMENT

1. HCBP will need to comply with the conditions that will be set by the

Municipal Council for Air Emissions and conditions of the

AEL/APPA certificate applicable at the time.

Documents

Scaw South Africa Pty Ltd Gaut 002/13 -14/E0162rhdhv.co.za/media/201210/Gas Fired Furnace at Scaw Metals...Scaw South Africa Pty Ltd (“Scaw Metals”) is proposing to install a gas