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ATLANTIS FOUNDRIES (PTY) LTD: RECOVERY AND

RECYCLING OF SCRAP METALS FOR THE


FERROUS METAL CASTING PROCESS
Environmental Management Programme

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

Checked by Robert Els


Signature

Authorised by Jacqui Fincham


Signature

Project number 45196


Report number 4
File reference

Project number: 45196


Dated: 2015/08/04 2
Revised:
ATLANTIS FOUNDRIES (PTY) LTD: RECOVERY AND
RECYCLING OF SCRAP METALS FOR THE FERROUS
METAL CASTING PROCESS
Environmental Management Programme

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

Tel: +27 21 481 8794


Fax: +27 21 481 8799

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)

Project number: 45196


Dated: 2015/08/04 4
Revised:
1. Introduction

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.

1.2. Project Location


Atlantis Foundries is situated within the Atlantis Industrial area which was established as an industrial growth
point in the mid 1970s and is located 7km inland of the Cape West Coast, approximately 40km north of Cape
Town, in the Western Cape (Figure 1). The Atlantis Industrial area is located immediately to the south of the
residential area of Atlantis with the Atlantis Foundries site being located in the less developed southern section
of the industrial area, approximately 2.5km from Atlantis. The site occupies Portion 202 of Farm 1183 and is
located approximately 1.5km east of the R307, which joins the R27 West Coast Road 6km to the southwest of
the site (Figure 2). The scrap metal storage area is located on the western side of the foundry facility as shown
in Figure 3 below.

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Figure 1: Locality of the site within the Cape Town Metropolitan Municipality

Figure 2: Locality map of Atlantis Foundries

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Figure 3: General layout of the facility showing the scrap storage area (green) and melting area (Red)

1.3. Process Description


The primary input is high quality scrap ferrous metal which is delivered to Atlantis Foundries (via trucks) by
various suppliers and stored in separate silos within the storage warehouse. Atlantis Foundries apply stringent
specification requirements to the scrap metal purchased; as a result the scrap metal delivered and processed
at the site is deemed non-hazardous (i.e. general waste) as it has been pre-processed before being received at
the foundry.
An electro-magnetic crane lifts the scrap metal from the silos, thereby ensuring no contamination of non-ferrous
metals. The scrap metals are loaded into bins located at the top of each of the silos which are weighed on the
load cells and then taken to the induction furnaces where it is melted to be used in the manufacturing process.

1.4. Aim of this Document


This EMPr outlines measures to be implemented in order to minimise adverse environmental impacts
associated with the proposed facilities. It serves as a guide for the proponent, contractor and the workforce on

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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.

1.5. Legal Framework


As per GN 921 of the National Environmental Management Waste Act (No. 59 of 2008) (NEM:WA) the use of
scrap metal in the manufacturing process triggers Activity 3 of Category B (i.e. the recovery of waste including
the refining, co-processing of the waste at a facility that processes in excess of 100 tons of general waste per
day or in excess of 1 ton of hazardous waste per day, excluding the recovery that takes place as an integral
part of the an internal manufacturing process within the same premises). As such a Waste Management
License (WML) application is to be submitted to the competent authority, DEADP, for the authorisation of the
activity. In order for the DEADP to make a decision regarding the application for a WML an environmental
assessment as per the full Scoping and EIA process must be undertaken and submitted for consideration.
The EMPr has been developed in accordance with the legal requirements stipulated in Section 33 of the NEMA
EIA Regulations.

1.6. Project Proponent


Table 1: Details of the Project Proponent

Project Proponent Details


Proponent: Atlantis Foundries (Pty) Ltd
Contact person: Roger Addison
Postal Address: William Gourlay Road, Atlantis Industrial
Telephone: 021 573 7269
Fax: 021 573 7296
E-mail: roger.addison@atlantisfoundries.com

1.7. Environmental Assessment Practitioner (EAP)


WSP Environmental (Pty) Ltd (hereafter referred to as WSP) was appointed by FPT to undertake the function
of Environmental Assessment Practitioner (EAP) to develop this EMPr. WSP is a leading international
environmental consultancy with a broad range of expertise in the environmental industry. Relevant details of
the EAP are presented in Table 2 below.

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Table 2: Environmental Assessment Practitioner for the proposed Atlantis Foundries facility

Environmental Assessment Practitioner Details


Environmental Assessment Practitioner: WSP Environmental
Contact person: Jacqui Fincham
Qualification/ Associations: BSc (Hons) Biotech, Registered EAP with the ICB
Physical address: 3rd Floor, 35 Wale street, Cape Town, 8001
Postal address: P.O. Box 2613, Cape Town, 8000
Telephone: 021 481 8700
Fax: 021 481 8799
E-mail: Jacqui.Fincham@wspgroup.co.za

1.8. Summary of the Main Potential Impacts


The existing activities have potential impacts which need to be managed to ensure that the environment is not
degraded during the operation activities.
Table 3: Summary of the main potential Impacts
Impact Description of impact
Surface, ground & Risk of contaminated runoff and accidental spills of fuels and oils from
Stormwater vehicles, machinery and improperly stored materials or wastes.
Air Quality Dust emissions and particulate fallout from transfer and handling of
materials (ferrous scrap metal); during the delivery and offloading
processes.
The smelting of scrap metal results in the release of emissions to the
atmosphere; includes Particulate Matters, Sulphur Dioxide (SO X) and
Oxides of Nitrogen (NOX).
Noise Noise emissions from delivery and offloading activities.

2. Environmental Management Programme


This section of the EMPr forms the core of the EMPr and outlines specific issues related to the proposed
project during the operation phases, outlining required mitigation measures.
This document is project specific and the proposed environmental management and mitigation measures have
been captured within Table 5, below. As the proposed activity takes place in an existing facility only the
operational phase will be addressed in Table 5. The tables present the potential impacts and associated
management and mitigation measures and the responsible person for the implementation of these measures.
The following sections provide an indication of EMPr terminology and required responsibilities.

2.1. EMPr Terminology


Proponent: For the purposes of this document, the Proponent refers to the Atlantis Foundries (Pty) Ltd.
Operator: The company responsible for the operation and management of the facility. For the purposes of this
document, the term Operator refers to Atlantis Foundries (Pty) Ltd.

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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.

2.2. Assigned Responsibility


Roles, responsibility and authority shall be defined, documented and communicated in order to facilitate
effective environmental management through implementation of the EMPr. Management shall provide
resources essential to the implementation and control of the EMPr including: human resources, technology,
and financial resources.
The sections below provide more specific responsibilities related to each position.
Table 4: Roles and Responsibility
EMPr Roles and Responsibilities

Atlantis Foundries (Pty) Ltd


Appointing a Safety, Health and Environment Manager (SHEM) to oversee the implementation of the
operational phase of the recovery and recycling of scrap metals for the ferrous metal casting process
associated with the Atlantis Foundries automotive castings production facility (This role can be undertaken
by the .
Undertake training and induction of employees regarding the EMPr as well as relevant occupational health
and safety issues.

Safety, Health and Environmental Manager (SHEM)


Ensure resource allocation for implementation of the EMPr requirements.
Ensuring that engineers and contractors comply with the approved EMPr.
Undertake environmental system reviews, site inspections, audits and other verification activities to assure
that the EMPr implementation is at an optimal level.
Participate in environmental performance verification activities to verify the level of compliance with the
EMPr in delivering the legal and environmental obligations.
Assess the efficacy of the EMPr and identify possible areas of improvement or amendment required within
the EMPr.
Participate in incident investigations (as required).
Ensuring compliance with the provisions for duty of care and remediation damage in accordance with
Section 28 in terms of NEMA (no 107 of 1998) and its obligations regarding the control of emergency
incidents in terms of Section 30 of NEMA.
Notifying the DEADP of any incident as defined in section 30(1) (a) of NEMA (Control of Emergency
Incident).

Contractors, Sub-Contractors and Service Providers


Managing and undertaking required activities with due care and diligence.
Complying with all elements of the EMPr.
Maintaining relevant documentation for review by the SHEM.

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2.3. EMPr for Operation Phase
This EMPr document is site specific and the proposed environmental management and mitigation measures proposed for the operation phase have
been captured within the Table 5 below.
Table 5: Environmental Management Plan Operation Phase

Environmental Environmental Management and Mitigation Measures Responsible Person(s)


Aspect

1. Administrative Requirements

Objectives To define roles and responsibilities for environmental management;


To ensure suitable environmental training and induction to all employees; and
To promote environmental awareness.

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.

3. Air Quality Impacts

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).

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Appropriately designed vehicles should be used for materials handling.
Ensuring that all equipment and vehicles are maintained in good working order and not left running when not
in use.
Comply with all conditions contained within the AEL (Ref Number: WCCT018) attached as Appendix A.
General Training of driver staff to reduce emissions whilst driving (e.g. maintaining appropriate speed limits, switching SHEM
off engines when stationary).
Ensure that loading weights comply with manufacturers recommendations to avoid engine working
excessively hard.
Continued requirement of use of personal protective equipment (PPE) such as ventilation masks and goggles
where appropriate.
A complaints register must be maintained on site.
Indicator / Electronic or hard copy of complaints/incidents/non-conformance register.
Compliance Close-out on incidents received.
Mechanism Monthly dustfall monitoring reports submitted to the Air Quality Officer as per condition 7.5.1.4 of the
AEL.
Annual emission report submitted to the Air Quality Officer as per condition 7.4.3 as well condition
9.2 of the AEL.
Occupational hygiene survey reports.
4. Noise Impacts

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.

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3. Environmental Awareness Plan
Atlantis Foundries have a responsibility to ensure that all individuals involved in the activities are aware of and
familiar with the environmental requirements for the facility (this includes sub-contractors, casual labour, etc.).
All contractors, sub-contractors and suppliers have to assure that they understand the EMPr and that they will
comply with the conditions herein. All senior and supervisory staff members shall familiarise themselves with
the full contents of the EMPr, understand the specifications of the EMPr and shall be able to assist other staff
members in matters relating to the EMPr.
An environmental awareness training programme for all staff members is to be put in place by Atlantis
Foundries and all staff members shall be appropriately briefed about the EMPr and relevant occupational health
and safety issues.

4. Monitoring and Reporting


Atlantis Foundries are required to undertake monitoring and reporting through the operation phase of the
facility; these include (but are not limited to) the following:
Item Description Frequency
Air Quality Report The annual report must be submitted to the air quality Annual
officer and include, amongst others, the following
items:
a) Pollutant emission trend;
b) Compliance audit report(s);
c) Major upgrades projects (i.e. abatement
equipment or process equipment); and
d) Greenhouse gas emissions.
Dustfall monitoring The report must be submitted to the air quality officer Monthly
reports and must comply with section 5(a) (f) of the National
Dust Regulations
Waste Management Audit Audits are to undertaken to assess the compliance Biannual (unless
Reports against the conditions of the Waste Management otherwise indicated)
Licence, the results of which are to be issued to the
waste management authority.
Occupational Hygiene Compliance with the Occupational Health and Safety As per requirements.
Act and Regulations.

5. Complaints Register and Environmental Incidence


Register
Any complaints received from the community or surrounding land owners must be recorded. The complaint
should be brought to the attention of the EM who will respond accordingly.
The following information will be recorded:
Time, date and nature of the complaint;
Weather conditions during the time of the complaint (e.g. wind direction and strength, sunny / overcast /
raining, hot mild temperature etc.);
Response and investigation undertaken; and
Actions taken and by whom.
All complaints received will be investigated and a response (even if pending further investigation) should be
given to the complainant within 14 days.

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.

Project number: 45196


Dated: 2015/08/04
Revised:
Appendices
Appendix A Atmospheric Emission Licence (WCCT018)

Project number: 45196


Dated: 2015/08/04
Revised:
WSP Environmental (Pty) Ltd
3rd Floor
35 Wale Street
Cape Town
8001
South Africa
Tel: +27 21 481 8794
Fax: +27 21 481 8799
www.wspgroup.co.za

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