Professional Documents
Culture Documents
2015/08/04
Quality Management
Issue/revision Issue 1 Revision 1 Revision 2 Revision 3
Remarks Operational Phase EMPr
Date August 2015
Prepared by Luca Afonso
Signature
2015/08/04
Client
Atlantis Foundries (Pty) Ltd
1 William Gourlay Street,
Atlantis Industrial
Atlantis
7349
Consultant
WSP Environmental (Pty) Ltd
3rd Floor
35 Wale Street
Cape Town
8001
South Africa
www.wspgroup.co.za
Registered Address
WSP Environmental (Pty) Ltd
1995/008790/07
WSP House, Bryanston Place, 199 Bryanston Drive,
Bryanston, 2191, South Africa
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Table of Contents
1. Introduction ................................................................................................................... 5
1.1. Background ................................................................................................................ 5
1.2. Project Location.......................................................................................................... 5
1.3. Process Description ................................................................................................... 7
1.4. Aim of this Document ................................................................................................. 7
1.5. Legal Framework........................................................................................................ 8
1.6. Project Proponent....................................................................................................... 8
1.7. Environmental Assessment Practitioner (EAP) .......................................................... 8
1.8. Summary of the Main Potential Impacts ..................................................................... 9
2. Environmental Management Programme ...................................................................... 9
2.1. EMPr Terminology...................................................................................................... 9
2.2. Assigned Responsibility ........................................................................................... 10
2.3. EMPr for Operation Phase ....................................................................................... 11
3. Environmental Awareness Plan .................................................................................. 15
4. Monitoring and Reporting ............................................................................................ 15
5. Complaints Register and Environmental Incidence Register ....................................... 15
6. EMPr Amendments ..................................................................................................... 16
7. Conclusion .................................................................................................................. 16
Appendices
Appendix A: Atlantis Foundries Atmospheric Emission Licence (WCCT018)
1.1. Background
This Environmental Management Programme (EMPr) document has been compiled in conjunction with the EIA
Reports required for Authorisation as per the National Environmental Management Act (Act 107 of 1998)
(NEMA) and has been submitted to the Department of Environmental Affairs and Development Planning
(DEADP) as an appendix to the Environmental Impact Report (EIR). The EMPr has been developed in
accordance with the legal requirements of Section 33 of the NEMA Environmental Impact Assessment (EIA)
Regulations (2014) for the storage and handling of scrap metal by Atlantis Foundries (Pty) Ltd (hereafter
Atlantis Foundries); at their facility in Atlantis Industrial, Atlantis.
As the activity is already taking place EMPr has been developed for the operational phase of the facility as no
construction activities are required. The aim of the EMPr is to identify and minimise, as far as possible, potential
impacts that the activity may have/has on the surrounding biophysical and socio-economic environment during
the operational phase.
The EMPr includes the following:
Details and expertise of the person who prepared the EMPr;
Information on any proposed management or mitigation measures that will be taken to address the
potential environmental impacts that have been identified, including environmental impacts or objectives in
respect of the operation activities;
A detailed description of the aspects of the activities that are covered by the EMPr;
An identification of the people who will be responsible for the implementation of the mitigation measures;
Where appropriate, time periods within which the mitigation measures contemplated in the EMPr must be
implemented;
Proposed mechanisms for monitoring compliance with the EMPr and reporting thereon;
A description of the manner in which it is intended to modify, remedy or control any activity which causes
pollution, degradation or migration of pollutants;
The process for managing any degradation or damage to the environment; and
An environmental awareness plan detailing the manner in which employees will be managed in terms of
informing them of inherent risks which may result from the proposed activities.
5
Figure 1: Locality of the site within the Cape Town Metropolitan Municipality
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their roles and responsibilities concerning environmental management on site, and it provides a framework for
environmental monitoring throughout the construction period. The purpose of the EMPr is to:
Encourage good management practices through planning and commitment to environmental issues;
Define how the management of the environment is reported and performance evaluated;
Provide rational and practical environmental guidelines to:
Minimise disturbance to the environment and surrounding receptors;
Prevent pollution of land, air and water;
Comply with all applicable laws, regulations, standards and guidelines for the protection of the
environment;
Adopt the best practicable means available to prevent or minimise adverse environmental impacts;
Describe all monitoring procedures required to identify impacts on the environment; and
Train employees and contractors with regard to environmental obligations.
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Environmental Manager (EM): For the purposes of this document, the EM refers to the individual appointed
by Atlantis Foundries to oversee the implementation of the operational phase of the project this person may
also serve the function of Designated Environmental Officer (see below).
Project Manager (PM): The individual representing the operator during the operation phase of the facility.
Environmental Consultant (or EAP) - Environmental Assessment Practitioner: The individual or company
responsible for the development of the EMPr. The Environmental Consultant can also fulfil a role in the
monitoring and auditing of the implementation of the EMPr. For the purposes of this document, the term
Environmental Consultant refers to WSP Environment and Energy.
1. Administrative Requirements
Roles and The environmental management and costs associated with the implementation of the EMPr for the operation Atlantis Foundries
Responsibilities for phase;
Environmental Appointing an Environmental Manager (EM) to oversee the implementation of the EMPr throughout the
Management operation phase of the facility.
The implementation of the EMPr SHEM
Ensuring that all contractor(s) and members of the workforce are aware of the requirements of the EMPr.
Implementing preventative and corrective actions in accordance with the requirements of the EMPr.
Reporting of environmental incidents that may occur on-site within the environmental incidents register, in
accordance with the requirements of the EMPr and relevant environmental legislation.
To maintain on-site environmental file/document systems
Environmental In terms of Section 24N(3)(c) of the NEMA and Section 22(j) of the EIA Regulations, all personnel involved in SHEM
Training and Induction the project are to be made aware of and familiar with the EMPr, the key environmental issues associated with
the activities, as well as consequences of non-compliance to the EMPr;
The induction training will, as a minimum, include the following:
The importance of conformance with all environmental policies;
The environmental impacts, actual or potential, associated with the activities;
The environmental benefits of improved personal performance;
Their roles and responsibilities in achieving conformance with the companys existing environmental
policy and procedures;
The mitigation measures required to be implemented when carrying out work activities; and
The potential consequences of defying specified operating procedures
No alcohol or drugs, and no workers influenced by alcohol or drugs shall be allowed on site
Staff must be trained in the relevant Atlantis Foundries safety, emergency procedures.
Ensure all employees are supplied with the correct personal protective equipment (PPE)
Ensure compliance to the Occupational Health and Safety Act (85 of 1993) requirements.
Duty of Care Reasonable measures must be taken to prevent pollution or degradation of the environment from Atlantis Foundries
occurring, continuing or recurring, or, in so far as such harm to the environment is authorised by law
or cannot reasonably be avoided or stopped, to minimise and rectify such pollution or degradation of
the environment.
Indicator / Induction training and register.
Compliance Environmental incidents register.
Mechanism Close-out on incidents received.
Biannual independent audit report assessing compliance with the WML.
2. Surface, Groundwater and Stormwater System Impacts
Objectives Ensure sound environmental management regarding surface and ground water; and
Ensure the prevention of stormwater pollution during the operation phase of the project
Scrap metals are to be stored within a semi-enclosed, covered structure on an impermeable concrete surface. SHEM
Spillages of oils or wastes are to be cleaned up timeously and disposed of in an appropriate manner.
All waste skips must be within bunded areas. These bunded areas must be regularly inspected to ensure that
there are no leaks or cracks within the bund walls.
A drip tray must be placed under any vehicles or machinery on site that has the potential to leak oil.
The oil separator at the retention pond outlet is to be cleaned on a weekly basis;
A sluice gate is to be installed prior to the retention pond to ensure that if a large oil spill occurs on site, the
stormwater channel can be closed to ensure no oil enters the retention pond; and
Indicator / Electronic or hard copy of complaints/incidents/non-conformance register.
Compliance Close-out on incidents received.
Mechanism Groundwater monitoring reports.
Objectives Ensure sound environmental management regarding air quality during the operation phase
Air Quality Scrap metals stockpile area to be protected from wind when necessary. SHEM
Objectives A complaints register must be maintained at the premises noting all complaints made and management
measures implemented to prevent recurrence.
Adhere to the fugitive dust management developed in line with the requirements of the AEL.
Trucks delivering scrap metal to site are to remain on hardsurfacing.
Implement vehicle speed and access restrictions within the site (approximately 10 20km/hour).
Objectives To manage the noise that may arise from the activities during operation.
To adhere to the South African National Standards (SANS) 10103:2008 noise limits.
Noise Management Offloading of scrap metals to be undertaken within the semi-enclosed scrap metal storage area. SHEM
Objectives Restricted areas to be defined where it is not reasonably practicable, or economic, to reduce the noise level
below the work area limit.
Provision of PPE equipment.
Regular training of staff on use of PPE and danger of excessive noise exposure.
Employees who work in high noise areas should also undergo audiometric testing according to requirements
of the Occupational Health and Safety Act no. 85 of 1993 (OHS Act).
Indicator / Electronic or hard copy of complaints/incidents/non-conformance register.
Compliance Close-out on incidents received.
Mechanism Training Records.
Staff wearing appropriate PPE.
5. Waste Management
Objectives To manage waste in a manner that prevents detrimental impacts on the environment.
Waste management Waste must be disposed of at an appropriate landfill site by an approved contractor. SHEM
objectives A waste disposal certificate must be obtained for any hazardous waste and kept on record.
Separation of wastes for recycling must be encouraged throughout the operation period.
Suitably covered receptacles must be available at all times and conveniently placed for the disposal of waste.
These receptacles must be emptied on a regular basis. While being stored on-site, the receptacles should be
placed within designated areas on an impermeable surface and must be correctly labelled and/or adequately
colour coded.
Train staff in waste management procedures.
Indicator / Electronic or hard copy of complaints/incidents/non-conformance register.
Compliance Close-out on incidents received.
Mechanism Training Records.
Safe disposal certificates.
Ongoing research and development to reduce waste.
Develop an Industry Waste Management Plan (IWMP) for the facility with associated Action Plan.
6. Emergency Response
Objectives To ensure that staff are aware of emergency procedures on site and to provide staff with the
necessary training.
All staff must be regularly trained in Atlantis Foundries existing emergency response procedures. SHEM
Annual emergency drills to be undertaken.
All staff to be provided with appropriate PPE and signage must be placed to remind staff to wear PPE.
Emergency phone numbers and responsible persons must be indicated.
Indicator / Electronic or hard copy of complaints/incidents/non-conformance register.
Compliance Close-out on incidents received.
Mechanism Training Records.
Evidence of emergency drills having been undertaken.
6. EMPr Amendments
No EMPr amendment (relaxation or revision of any EMPr mitigation measure) shall be allowed without
consultation with WSP or without approval from the DEADP.
7. Conclusion
In terms of NEMA, all parties associated with the activities are required to take reasonable measures to ensure
that they do not pollute the environment. Reasonable measures include informing and educating employees
about the environmental risks of their work and training them to operate in an environmentally responsible
manner. Furthermore, in terms of NEMA, the cost to repair any environmental damage shall be borne by the
person responsible for the damage.
If the above-mentioned management recommendations are adopted it is anticipated that most of the negative
environmental impacts of the proposed activities at the Atlantis Foundries site can be mitigated. The appointed
EM will need to monitor the site throughout the operation of the facility (as identified above) to ensure that the
required environmental controls are in place and working effectively.