Draft EIA Report, NiRoVe Paint Stripping April 2011 Public Process Consultants 8.1 CHAPTER EIGHT: WASTE MANAGEMENT AND DISPOSAL 8.1 INTRODUCTION Poltech EC was appointed by Public Process Consultants to undertake a review of the specialist study with regards to Waste Management and Disposal at the proposed Nirove paint stripping plant. The management of waste water, wastes and by-products was raised as an issue of concern in the scoping phase of the proposed project. Therefore, as part of the detailed EIA Phase for the proposed facility, it was necessary to conduct a specialist waste management study. During the review process the report has been restructured to adequately address the key issues as requested by the Environmental Practitioner. This report therefore aims to address waste water, waste and by-product management issues raised during scoping. The terms of reference for this specialist study and its review are detailed in section 8.2 that follows. This report includes the identification and quantification of process and non-process waste streams at the proposed plant, the detailed characterization of the process wastes and recommendations for their management. The main objective of this study was to assess the potential significance of environmental impacts associated with the management (handling, storage and disposal) of solid and liquid process and non-process wastes and by-products from the proposed Nirove paint stripping plant. 8.1.1 Terms of Reference The following provides the terms of reference for the specialist study as approved in the Plan of Study for EIA, Final Scoping Report, December 2010. i. Using desk top information and in consultation with the applicant, identify and classify, all waste streams generated. ii. An analysis of the waste ash from the oven in order to determine whether this is to be classified as hazardous waste. The analysis to be done by Wastetech Enviroserv utilising an imported sample from a similar process in a German owned NiRoVe facility. iii. Identify applicable waste management legislation (National, provincial and local) as well as permitting and licensing requirements iv. Identify opportunities for waste minimization, re-use and recycling (Include the potential disposal of hazardous waste if applicable) to include, but not limited to: a. Neutralisation of the waste acid b. Delisting of the gypsum from the thermal paint stripping process c. Wastewater treatment plant and disposal to municipal sewer d. Identify and quantify (if possible) wastewater streams to be treated in the wastewater treatment plant and potentially harmful constituents e. Identify potential sources of contamination, constituents of concern, their expected concentrations and the potential impacts thereof f. Include an assessment of the potential accidental release of contaminated wastewater. v. Identify waste disposal options and /or sites that have the correct permits to accept waste from the project.
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Draft EIA Report, NiRoVe Paint Stripping April 2011
Public Process Consultants 8.1
CHAPTER EIGHT: WASTE MANAGEMENT AND DISPOSAL
8.1 INTRODUCTION
Poltech EC was appointed by Public Process Consultants to undertake a review of the specialist
study with regards to Waste Management and Disposal at the proposed Nirove paint stripping
plant. The management of waste water, wastes and by-products was raised as an issue of
concern in the scoping phase of the proposed project. Therefore, as part of the detailed EIA Phase
for the proposed facility, it was necessary to conduct a specialist waste management study.
During the review process the report has been restructured to adequately address the key issues
as requested by the Environmental Practitioner. This report therefore aims to address waste water,
waste and by-product management issues raised during scoping. The terms of reference for this
specialist study and its review are detailed in section 8.2 that follows.
This report includes the identification and quantification of process and non-process waste streams
at the proposed plant, the detailed characterization of the process wastes and recommendations
for their management.
The main objective of this study was to assess the potential significance of environmental impacts
associated with the management (handling, storage and disposal) of solid and liquid process and
non-process wastes and by-products from the proposed Nirove paint stripping plant.
8.1.1 Terms of Reference The following provides the terms of reference for the specialist study as approved in the Plan of
Study for EIA, Final Scoping Report, December 2010.
i. Using desk top information and in consultation with the applicant, identify and classify, all waste
streams generated.
ii. An analysis of the waste ash from the oven in order to determine whether this is to be classified
as hazardous waste. The analysis to be done by Wastetech Enviroserv utilising an imported
sample from a similar process in a German owned NiRoVe facility.
iii. Identify applicable waste management legislation (National, provincial and local) as well as
permitting and licensing requirements
iv. Identify opportunities for waste minimization, re-use and recycling (Include the potential disposal
of hazardous waste if applicable) to include, but not limited to:
a. Neutralisation of the waste acid
b. Delisting of the gypsum from the thermal paint stripping process
c. Wastewater treatment plant and disposal to municipal sewer
d. Identify and quantify (if possible) wastewater streams to be treated in the wastewater
treatment plant and potentially harmful constituents
e. Identify potential sources of contamination, constituents of concern, their expected
concentrations and the potential impacts thereof
f. Include an assessment of the potential accidental release of contaminated wastewater.
v. Identify waste disposal options and /or sites that have the correct permits to accept waste from
the project.
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vi. Identify and assess project related impacts as per the prescribed methodology.
vii. Make recommendations for appropriate mitigatory measures in order to address the impacts
identified.
viii. Provide an Environmental Management Plan including, but not limited to, a spill contingency
plan
The Environmental Practitioner requested the following key issues of the Waste Management
Specialist Study to be reviewed:
A waste flow diagram showing all outputs and disposal methods
Review the classification of the waste streams and disposal recommendations
Review the NEM Waste Act and the waste streams generated and clearly indicate what is a
hazardous waste based on SA legislation
Indicate whether the pyrolysis oven for the removal of the paint from the skids is considered
the treatment of a hazardous waste
Review the independent German Laboratory results for the waste ash from the pyrolysis
oven in line with SA legislation and provide a clear expert opinion on whether the waste ash
is considered hazardous
Review the waste water treatment plant and provide a clear indication in line with SA
legislation whether the treatment of the wastewater from the wash bay area containing
waste acid is considered the treatment of hazardous waste
Review the discharge of the wastewater to the municipal sewer in line with the municipal
requirements for disposal
8.1.2 Layout of the Report
The structure of this Chapter of the Report is as follows:
Section 8.1 – Introduction
Provides background information on the current study and the review, outlines the Terms of
Reference for this specialist study and the review, and the structure of this specialist report. It
furthermore details the assumptions and limitations under which this report was prepared.
Section 8.2 – Methodology and Approach
Provides a detailed description of the methodology used to collect and analyse the necessary data
on which to assess the significance and severity of environmental impacts.
Section 8.3 – Legislative Requirements
Provides a detailed description of the legislation, policies and standards applicable to the proposed
development in terms of waste management.
Section 8.4 Waste Generation : Process Waste
Provides a detailed description of the proposed processes to be employed in the paint stripping
plant, the waste generated from each process and the management of the waste. Non-process
waste streams associated with auxiliary services are also discussed.
The leachabilities of the metals are an indication of the ecotoxicity. The results are promising,
indicating that metals are not readily leached from the gypsum solids. It should be kept in mind that
the heavy metals in the gypsum, specifically lead and chrome, will not be present in the gypsum
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from Nirove, Port Elizabeth (the automotive industry prohibits lead and chrome in paint systems).
Based on the above results the gypsum by-product is most probably not a hazardous waste.
To delist the gypsum a representative sample from the current gypsum production needs to be
characterized. In addition a gypsum sample from the spent acid neutralized by lime must be
obtained to also characterize it. This is currently underway. The process of delisting of the
Gypsum involves the following:
The analysis of a representative sample of gypsum (both from the waste water treatment plant
and a lab sample from the spent sulphuric acid treatment)
The leaching of the gypsum solid in an acid rainwater mixture (TCLP or acid rain testing)
The analysis of the leachate to determine key metal constituents
A determination if the metal concentrations in the leachate are lower than the Estimated
Environmental Concentration (EEC).
Submission of a report outlining the delisting request and required documentation.
Due to the low metal leaching from the Italian sample it is anticipated that gypsum will be able to
be delisted and used as an agricultural product. Testing the gypsum for agricultural application
such as a fertilizer for growing plants will need to be done. The tests should include, but are not
limited to soil testing, leaf testing and fruit or vegetable tests. An accredited agricultural laboratory
must be used to perform these tests.
8.9 IDENTIFICATION OF WASTE MANAGEMENT ACTIVITIES
The National Environmental Management: Waste Act makes provision for waste licences for
defined activities. These activities are contained in GN 718 of 3 July 2009: List of waste
management activities that have, or are likely to have a detrimental effect on the environment
(Government Gazette No. 32368). The activities that are applicable to Nirove are summarised in
Table 8.10 below:
Table 8.10: List of waste management activities
Activity Description of Activity
Category A.
(2) The storage including the
temporary storage of hazardous
waste at a facility that has the
capacity to store in excess of 35m3
of hazardous waste at any one time,
excluding the storage of hazardous
waste in lagoons.
The treatment of waste is excluded from the storage
definition. Therefore the storage of hazardous waste will
possibly not exceed 35m3 under any one time. Collection
of waste is done on a daily basis.
This activity is not applicable
Category A.
(11) The treatment of effluent,
wastewater or sewage with an
annual throughput capacity of more
than 2000 cubic metres but less than
15 000 cubic metres.
The Wastewater Treatment Plant has an estimated
annual throughput capacity of 7 800m3. This will require a
waste licence.
This activity is applicable
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Activity Description of Activity
Category A.
(18) The construction1 of facilities for
activities listed in Category A of this
Schedule (not in isolation to
associated activity).
The new premises contain an existing building in which
the majority of the facilities and equipment will be
installed and operated. The infrastructure for the Waste
Water treatment plant will need to be established, minor
alterations will be made to the existing factory and the
entrance to the site. Additional construction activities will
include the plinth for the LPG gas and the dangerous
goods as well as waste storage area.
This activity is applicable
Category A.
(20) The decommissioning of
activities listed in this schedule.
The waste water treatment facility will be
decommissioned at 29 Kurland Road (erf 975),
Perseverance.
This activity is applicable.
Category B.
(4) The biological, physical, or
physico-chemical treatment of
hazardous waste at a facility that has
the capacity to receive in excess of
500kg of hazardous waste per day
The treatment of spent acid is classified as a physico-
chemical treatment of waste. The acid to be treated is
30m3 per month, thus ~ 1 m3 per day, possibly more than
500kg per day. The spent acid will be collected by a
registered waste disposal company. The treatment of
the spent acid on site requires further investigation in
order to determine the feasibility thereof.
This activity is applicable if and when the proponent
decides to implement this treatment process.
Category B.
(5) The treatment of hazardous
waste using any form of treatment
regardless of the size or capacity of
such a facility to treat such waste.
Physico-chemical treatment at Activity (B.4) has been
triggered already.
This activity is applicable if and when the proponent
decides to implement the treatment outlined above.
Category B. (8) The incineration of
waste regardless of the capacity of
such a facility.
The thermal removal of the paint from the skids is not
considered incineration. Incineration involves the
combustion of organic substances, whereas pyrolysis
does not involve combustion.
This activity is not applicable
Category B. (11) The construction1
of facilities for activities listed in
Category B of this schedule (not in
The new facility will require environmental authorization
and a waste license from the National Department of
Environmental Affairs if and when the proponent decides
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Activity Description of Activity
isolation to associated activity). to treat the spent acid waste on-site. 1 „construction’ means the building, erection or establishment of a facility, structure or infrastructure that is necessary for
the under taking of a listed activity but excludes any modification, alteration or expansion of such a facility, structure or
infrastructure and excluding the reconstruction of the same facility in the same location, with the same capacity and
footprint. (NEMA EIA Regulation 2010: GN R544)
8.10 POTENTIAL ENVIRONMENTAL IMPACTS
8.10.1 Methodology for Assessment of Impacts
The environmental aspects identified were systematically evaluated through application of a
methodology for the evaluation of significance as per the DEAT Guideline Document nr 5, June
2006, Assessment of Alternatives and Impacts. The methodology the identification, assessment
and rating of impacts are contained in Chapter Four of this report and are in line with the Approval
for the Plan of Study for EIA.
Table 8.11: Assessment criteria for the impact analysis
Assessment criteria Rating
Spatial extent The size of the area that will be affected by the impact
Site specific 2
Local (<2 km from site) 3
Regional (within 30 km of site) 5
National 10
Duration –The timeframe during which the impact will be experienced
Temporary (less than 1 year) 2
Short term (1 to 6 years) 3
Medium term (6 to 15 years) 4
Long term (the impact will cease after the operational life of the activity) 10
Permanent (mitigation will not occur in such a way or in such a time
span that the impact can be considered transient)
10
Intensity –The anticipated severity of the impact
Low (negligible alteration of natural systems, patterns or processes) 2
Medium (notable alteration of natural systems, patterns or processes) 5
High (severe alteration of natural systems, patterns or processes) 10
Probability –The probability of the impact occurring
Improbable (little or no chance of occurring) 2
Probable (<50% chance of occurring) 3
Highly probable (50 – 90% chance of occurring) 5
Definite (>90% chance of occurring) 10
Significance – Will the impact cause a notable alteration of the environment?
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Low to very low (the impact may result in minor alterations of the
environment and can be easily avoided by implementing appropriate
mitigation measures, and will not have an influence on decision-making)
Low
<500
Significance
score
Medium (the impact will result in moderate alteration of the environment
and can be reduced or avoided by implementing the appropriate mitigation
measures, and will only have an influence on the decision-making if not
mitigated).
Medium
500 – 1000
significance
score
High (the impacts will result in major alteration to the environment even
with the implementation of the appropriate mitigation measures and will have
an influence on decision-making)
High
> 1000
significance
score
Status - Whether the impact on the overall environment will be positive, negative or neutral
Positive - environment overall will benefit from the impact +
Negative - environment overall will be adversely affected by the impact -
Neutral - environment overall will not be affected O
Confidence – The degree of confidence in predictions based on available information and
specialist knowledge
Low L
Medium M
High H
8.10.2. Assessment of Potential Environmental Impacts
The purpose of this section of the report is to provide details regarding the potential environmental
impacts associated with the management of the waste streams arising from the proposed Nirove
Paint stripping plant. Potential impacts, including potential cumulative impacts, of process and non-
process wastes were assessed.
The identified environmental impacts are listed and evaluated in Table 8.12. The Significant
Impacts, those that have been labelled as High and Very High Significance, require controls to be
mitigated to an acceptable Medium or Low level. The Significant Impacts have therefore been
assessed in detail, firstly considering the effect on the environment if No Mitigation or controls will
be in place, to identify the intrinsic significance of the impact. Methods of lowering the impacts are
proposed and a re-evaluation assessment has then been done of the significance of the impact
With Mitigation in place. The difference between the significant rating of the impact without and
with controls / mitigation is a measure of how essential the control/mitigation measures are: the
higher the difference the more critical the control measures and management of the impact.
Concise mitigation measures are listed in Table 8.12, while detail control and mitigation
mechanisms are given in the write-up of the impact. The discussion of the impacts occurs under
the main causes from which the impacts are derived.
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i) IMPACTS ASSOCIATED WITH THE STORAGE AND DISPOSAL OF WASTE DURING
CONSTRUCTION AND OPERATIONAL PHASES
Impacts 1.1 and 2.1- Pollution of land and water
Impact 1.4 and 2.7 – Attraction of vermin to the site
Impacts 1.5 and 2.6 - Odour generation from waste storage activities
Impact 2.8 - Pollution from wind-blown litter
Impact 3.2 Disposal of general and hazardous waste to landfill site
Cause and comment
Inappropriate storage and disposal of wastes on-site, particularly hazardous waste, can result in
the contamination of soil and water resources. Uncontrolled dumping of waste using inappropriate
bins that are open at the bottom, rusted or not designed to take the specific waste type can cause
pollution to the environment. As a result of rainfall events, leachate may be formed as water
percolates through the solid waste and this leachate may contain nutrients and a variety of toxic
compounds, including metals. As such, it could result in the contamination of water sources and
land. Open and overflowing containers, especially in the Port Elizabeth region, can result in the
generation of wind-blown litter, especially paper and light plastic waste. This will be visually
unpleasant and can pollute soil.
Uncontrolled dumping of solid waste and the infrequent disposal of the waste can attract vermin
and can result in the release of unpleasant odours. The vermin, including birds and rodents, and
unpleasant odours may pose a nuisance to adjacent land-users. Rodents may also be vectors for
diseases.
Possible Mitigation Measures
A sound waste management plant must be established and must make application of the waste
management hierarchy wherever possible. Recycling must be encouraged to minimize the
waste in the waste bins.
Recycling should be encouraged by strategic placement of bins for recyclable materials (glass,
paper, cardboard etc). If recycling of general waste is to be successful, then management must
ensure that recyclable wastes are stored in such a manner that they do not become
contaminated.
All general and hazardous wastes that cannot be reused or recycled should be stored
temporarily in a designated area.
Frequent collection of the stored waste to the nearest registered sanitary landfill facility for
responsible disposal must be established.
The temporary storage area must be located on an impermeable surface and measures should
be taken to ensure that any leachate that may be generated within the facility will not be able to
leave the area. Some form of low bunding around the facility would be appropriate. If waste
skips are used, then these should be in good working order (i.e. free of holes) and separate
skips should be provided for general and hazardous wastes.
Skips for plastic and paper waste should be covered to prevent waste from leaving the facility
during windy periods.
The storage area should be fenced and kept tidy at all times.
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Monitoring Requirements
Environmental officer to perform frequent audits in the waste storage area.
Monthly waste disposal record must be kept of all waste disposed, including recycled, general
and hazardous waste.
Significance statement
Impacts associated with the management of general and hazardous solid waste may occur and the
impacts are potentially long-term. However, as the quantity of solid waste is likely to be limited and
the proposed facility is located in an area with a well-developed waste management infrastructure,
the extent of the impacts were considered to be limited. Without mitigation the impacts will
definitely occur and should be regarded as low and medium. With appropriate mitigation the
severity could be reduced and the overall significance of the impact with mitigation would be low.
ii) IMPACTS ASSOCIATED WITH THE DISPOSAL OF HAZARDOUS WASTES DURING THE
CONSTRUCTION AND OPERATIONAL PHASES
Impact 1.2 and 2.2: Water, soil and groundwater pollution from incorrect disposal of hazardous
waste
Impact 2.5: Reduction of hazardous waste to landfill site
Cause and comment
Hazardous wastes are likely to be produced during all phases of the proposed development.
During the construction phase, empty containers for solvents, paints etc and oily rags are
commonly produced. During the operational phase, the auxiliary services are likely to produce at
least limited quantities of hazardous solid and liquid wastes. In addition the paint stripping
processes will produce hazardous waste. During the relocation of the waste water treatment plant,
the waste stream might include obsolete machinery and construction materials.
Many of the hazardous compounds, such as heavy metals, may have the capacity to bio-
accumulate and could therefore have long-lasting negative impacts on ecological systems should
they be discarded to a landfill site not permitted for that type of hazardous waste. If hazardous
waste can be re-used, recycled or treated to a lower hazard waste, waste amounts to the
hazardous landfill sites are reduced. The number of properly designed and managed landfill sites
in South Africa, in general, and in the Eastern Cape in particular, is limited. Due to the high costs
and long lead-time associated with the development of new landfill facilities, it is vitally important
that available landfill space is conserved. Spent acid will be treated on-site and will be used in the
agricultural industry, thereby having a positive impact on the environment.
Mitigation and management
A full characterization (including the quality and quantity) of the hazardous wastes must form a
key component of the waste management plan for the facility. Such a plan should be prepared
for the facility to ensure that all hazardous wastes are identified, quantified and managed
correctly.
All dry waste generated during the paint stripping processes (dry paint residue, shotblast ash
and pyrolysis ash) must be classified upon commencing of the plant.
All hazardous wastes that cannot be reused or recycled should be labelled correctly and stored
in a secure area until collected for correct disposal.
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If hazardous waste has to be disposed, it must be at a registered hazardous waste disposal
facility with the correct hazard rating i.e. correctly engineered to contain the specific waste types
of the different hazard classes. Safe disposal certificates must be obtained indicating the
collection and ultimate safe disposal of the hazardous waste. Only registered transporters of
hazardous waste should be used. Cradle-to-grave responsibility is required.
No hazardous wastes should be disposed off into drains as this may impact negatively on the
performance of the local sewage treatment facility or contaminate the environment.
Monitoring Requirements
Environmental officer to perform frequent audits in the waste storage area.
Waste collection and disposal certificates must be kept of all hazardous waste that are collected
from the site.
Registered certificates to be obtained from all transporters of hazardous waste
Significance statement
Based on the most likely nature of hazardous wastes, impacts may occur and, due to the potential
for certain hazardous substances to accumulate in the environment. If the waste is disposed off
incorrectly the hazardous substances in the waste can be transported and the extent of the impact
on the environment can be regional. Without mitigation the impacts will definitely occur and would
probably be regarded as Medium significance. However, with mitigation the severity could be
reduced and the overall significance of the impact would be low.
iii) IMPACTS ASSOCIATED WITH THE DISPOSAL OF SEWAGE AND TREATED INDUSTRIAL
WASTE WATER
Impact 1.3: Water pollution from increase in sewerage waste
Impact 2.3: Pollution of effluent and downstream municipal sewerage treatment works
Impact 3.1: Discharge of effluent to the municipal sewerage system
Cause and comment
Sewage and industrial waste water will be produced during the construction and the operational
phase and will need to be managed in order to avoid impacts on the environment and human
health. During the construction phase management of sewerage generated from the workers on-
site is required. Portable toilets are often used during construction. The contractor has to indicate
the sewerage treatment plan during construction. However, Nirove will have to audit the contractor
for conformance to the construction plans.
During the operational phase a Waste Water Treatment Plant will be in operation to treat industrial
effluent to the standard required for discharging to the municipal sewerage system. An application
for a permit from the NMBM should be made once the plant is in operation. Monitoring of the
outgoing waste water is required on a frequent basis to ensure that the quality of effluent satisfies
the requirements of the permit conditions. No stormwater must be allowed to run into the effluent
system.
Mitigation and management
During the construction phase, a sufficient number of toilets must be provided for construction
workers and use of the natural environment for ablutions must be prohibited.
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A permit for the disposal of industrial waste must be applied for prior to the discharging of waste
water into the municipal sewerage system
During the operational phase of the plant all sewage and process effluent must be disposed of
in a manner that complies with the permit conditions.
Waste water must be kept separated from sewerage water. A detailed layout indicating the flow
and piping of industrial waste, sewerage water and stormwater should be mapped. Colour-
coding of the pipes and manholes is suggested for the instant recognition of the water type.
The equipment of the Waste Water Treatment plant shall be maintained on a regular basis to
treat industrial effluent to the relevant standard as required in the permit. A contingency plan
shall be designed to address any breakdowns in the operations of the waste water treatment
unit, pumps, or piping.
Monitoring Requirements
Environmental audits to be performed during the Construction phase to ensure that adequate
ablution facilities are provided to the construction workers
The quality of the outgoing effluent shall be monitored regularly to ensure that it meets the
specifications of local by-laws. Prior to each release key parameters should be measured. At
least annually all the parameters as stipulated in the permit conditions must be monitored for
compliance.
Water usage (or water discharge) must be monitored on a monthly basis and be correlated to
the water discharge permitted by the NMBM as part of the permit conditions
Significance statement
The disposal of sewage during the construction phase, if not controlled, will have a significant
negative impact on the environment. If controlled correctly the impact will reduce to a low
significance.
Industrial waste water could potentially have a negative impact on the environment. Considering
the life of the plant, the impacts are potentially long-term and may affect the region. Without
mitigation the impacts on water may occur and would probably be regarded of Medium
significance. However, with appropriate mitigation the impacts would probably be of low
significance.
iv) IMPACTS ASSOCIATED WITH THE OCCURRENCE OF HEAVY METALS IN THE BY-
PRODUCT GYPSUM AND DRY PAINT WASTES
Impact 2.4: Occurrence of heavy metals in gypsum and dry process wastes
Cause and comment
Most of the paint stripping that will be done by the proposed Nirove plant will be for the automotive
industry and its subsidiaries. The current paint systems used in the automotive industry regulates
the use of heavy metals in the paint, for example lead- and chromium-containing paint systems are
not allowed in this industry. Thus, residues from paint systems, either of mechanical, physical or
thermal removal, should be free from these and other heavy metals. For the utilization of these
residues, either in the building industry, cement industry, or for ash-blending on a landfill site, it is
important not to contain these metals. In general, heavy metals may leach into the environment
and bio-accumulate over time.
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The situation for the gypsum by-product from the spent sulphuric acid, where the product will be
used in the agricultural industry, is more pertinent. If heavy metals occur in the gypsum and it is
used as a fertilizer where food production occurs, then the heavy metals can leach out into the soil
and can be taken up by plants. This can result in catastrophic consequences to the farmers, both
for the local and the export market.
Mitigation and management
An accurate classification of the dry process wastes and the gypsum should be done as soon as
the plant commences with its operation.
In the case where other paint products (not from the automotive industry) are being treated, it
shall be tested to ensure that no heavy metals are induced at the plant.
Care must be taken to ensure that all paint systems from products to be treated are free of
heavy metals.
Monitoring Requirements
Detailed analyses of the metals in the dry process waste and from a leachate sample of the
waste is required to accurately classify the waste. The requirements as stipulated in the
Minimum Requirement shall be followed.
Frequent monitoring of the dry process waste and the gypsum by-products to ensure that no
unwanted metals and other constituents of concern are present.
Trial runs must be conducted prior to utilization of the dry process waste in the brick and cement
industries and the gypsum waste in the agricultural industry.
Stipulations on the correct management and intended utilization of the dry process waste and
the gypsum by-product should be compiled by Nirove.
Significance statement
The utilization of dry process waste and gypsum by-product is good environmental practice.
However, if heavy metals are present in these wastes it will have a significant negative impact on
the environment. The impacts will be of a long duration and will affect the region. Without
mitigation the impacts of utilizing contaminated waste in the building and agricultural industries are
regarded of Medium significance. However, with appropriate mitigation the impacts would be of
Low significance.
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Table 8.12: Summary of environmental impacts associated with Waste Management at the Nirove proposed paint stripping plant
Impact/Nature of impact Extent Duration Intensity Probability Conf Sign before
mitigation
Mitigation Sign after
mitigation
1. Direct Impacts during the Construction phase of the proposed development
Impact 1.1: Water and soil pollution from poor waste management practices
Spills & leaks from waste skips 3 2 2 3 M 36
- low
Contractor Audit
Bunding
12
- low Impact after Mitigation 3 2 2 1 M
Impact 1.2: Water, soil and groundwater pollution from incorrect disposal of hazardous waste
Hazardous waste dispose to
general waste or sewerage system
5 2 10 5 M 500
- medium
Bins
Contractor Audit
200
- low Impact after Mitigation 5 2 10 2 M
Impact 1.3: Water pollution from increase in sewerage waste
Increase in sewerage waste 5 2 5 10 H 500
- medium
Portable toilets
Contractor Audit
60
- low Impact after Mitigation 3 2 5 2 H
Impact 1.4: Attraction of vermin to the site
Waste is accumulating and not
disposed of frequently
2 2 5 5 H 100
- low
Frequent
disposals
Contractor Audit
40
- low Impact after Mitigation 2 2 5 2 H
Impact 1.5: Odour generation from waste storage activities
Waste is left to degrade and not
disposed frequently
2 2 2 5 H 40
- low
Frequent
disposals
Contractor Audit
16
- low Impact after Mitigation 2 2 2 2 H
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Impact/Nature of impact Extent Duration Intensity Probability Conf Sign before
mitigation Mitigation Sign after mitigation
2. Impacts during the Operational Phase of the proposed development
Impact 2.1 Water and soil pollution from poor waste management practices
Spills from waste container, leaks. 5 3 5 5 H 375
- low
Designated area
Bunding
150
- low Impact after Mitigation 5 3 5 2 H
Impact 2.2: Water, soil and groundwater pollution from incorrect disposal of hazardous waste
Hazardous waste dispose to
general waste
5 5 5 5 H
625
- medium
Classification of
waste types
Safe disposal
certificates
250
- low Impact after Mitigation 5 5 5 2 H
Impact 2.3: Pollution of effluent and downstream municipal sewerage treatment works
Poor management of effluent
treatment plant
5 5 3 5 H 375
- low
Regular
maintenance
Monitoring
225
- low Impact after Mitigation 5 5 3 3 H
Impact 2.4: Occurrence of heavy metals in dry process waste and gypsum by-product
Soil degradation in agricultural land 10 3 10 3 H 900
- medium
Analyze paint
systems
Classify waste
400
- low
Impact after Mitigation 10 2 10 2 H
Impact 2.5: Reduction of hazardous waste to landfill site
Treating of hazardous waste to
minimize disposal to landfill site
5 5 5 10 H 1250
+ High
Investigate
further waste
minimizations
-
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Impact/Nature of impact Extent Duration Intensity Probability Conf Sign before
mitigation Mitigation Sign after mitigation
Impact 2.6: Odour generation from waste storage activities
Waste is left to degrade and not
disposed frequently
2 2 2 5 H 40
- Low
Frequent
disposal of
waste
Waste audits
16
- low Impact after Mitigation 2 2 2 2 H
Impact 2.7: Pollution from windblown litter
Visual impact from wind-blown litter 2 2 2 5 H 40
- low
Caged areas
Covers on
waste bins
16
- low
Impact after Mitigation 2 2 2 2 H
Impact 2.8: Attraction of vermin to the site
General waste is accumulating and
not disposed of frequently
2 5 5 5 H 250
- low
Frequent
disposal of
waste
Waste audits
100
- low Impact after Mitigation
2 5 5 2 H
3. Cumulative impacts for the proposed development
Impact 3.1: Discharge of effluent to the municipal sewerage system
Increase loading to the municipal
sewerage treatment plant
5 10 2 5 M 500
- Medium
Waste
Hierarchy
Treated in
Waste Water
plant
200
- Low Impact after Mitigation 5 10 2 2 M
Impact 3.2: Disposal of general and hazardous to landfill site
Filling of disposal sites, using
landfill space
5 10 5 10 M 2500
- High
Minimize,
Reuse Recycle
750
- low
Impact after Mitigation 5 10 5 3 M
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8.11 RECOMMENDATIONS
8.11.1 Waste Management Philosophy
All waste streams that will be generated by the propose paint stripping plant should be
managed according to the waste management hierarchy. This specifies that wherever possible,
production of wastes should be prevented or minimised at source. Where prevention or further
minimization is not possible, wastes should be re-used, recycled and then disposed of
responsibly so as to minimise impacts to the environment. In order to ensure best practice with
respect to waste management, a formalized waste management system should be implemented
and include regular qualitative and quantitative monitoring of all waste streams.
8.11.2 General
The implementation of an Environmental Management System, such as ISO14001, is
recommended to assist in the appropriate management of waste streams so as to minimize
negative impacts to the environment;
The principles of the waste management hierarchy (prevention at sources, minimisation, reuse,
recycling and disposal) must be applied to all waste streams;
An accurate classification of all waste types must be performed so as to ensure the correct
disposal of the waste type and in the case of utilization of the waste, to ensure that the
environment is not impacted on.
An Integrated Waste Management Plan covering all aspects of the proposed project must be
implemented to facilitate correct identification, quantification, management, disposal and
monitoring of waste streams;
Where waste streams have the potential to contaminate water or soil, measures should be
introduced to minimise contamination (e.g. oil traps);
All wastes should be stored in such a manner so as to minimise potential contamination of
storm water, soil and groundwater;
Monitoring of waste amounts is required on a frequent basis.
Regular audits by suitably trained personnel should be performed on all waste management
activities.
Spill response plans and equipment should be available to deal with emergency situations that
can arise during the management of waste.
8.11.3 Process and Hazardous Wastes
The feasibility of utilization of dry process waste in the building industry should be confirmed as
soon as possible, preferably prior to construction of the facility;
A waste license for the treatment of hazardous waste in terms of the National Environmental
Management Waste Act should be applied for
All waste streams must be handled according to international best practice;
A designated area should be established for the temporary storage of wastes. This area must
be designed and managed in such as way so as to minimise potential negative environmental
impacts. Prevention of contamination of water resources can be achieved by locating the
storage area away from drains, ensuring that the area is on an impermeable surface and that it
is appropriately bunded.
Where waste skips are used, their integrity must be checked regularly;
Sufficient bins must be located throughout the facility;
General and hazardous wastes should be separated at source;
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Where temporary storage of hazardous wastes is required, this should be in a secure area;
All waste streams must be handled and disposed of by authorised personnel;
Removal of any waste from site by unauthorised individuals must be prevented;
All staff should be trained in the correct handling, storage and disposal of hazardous wastes.
8.11.4. Sewage and Industrial Waste Water Treatment
It is recommended that:-
A Waste license must be applied for the treatment of industrial effluent in terms of the National
Environmental Management Waste Act
Effluent quality must be monitored.
REFERENCES:
REFERNCE
1. DEAT (Department of Environmental Affairs and Tourism), 2000a. White Paper on Integrated
Pollution and Waste Management for South Africa. Pretoria, South Africa.
2. DEAT (Department of Environmental Affairs and Tourism), 2000b. Programme for the
implementation of the National Waste Management Strategy: starter document for guidelines
for the compilation of Integrated Waste Management Plans. Pretoria, South Africa.
3. DWAF (Department of Water Affairs and Forestry), 1998a. Waste Management Series
(second edition): Minimum Requirements for the Handling, Classification and Disposal of
Hazardous Waste. Pretoria, South Africa.
4. DWAF (Department of Water Affairs and Forestry), 1998b. Waste Management Series
(second edition): Minimum Requirements for Waste Disposal by Landfill. Pretoria, South
Africa.
5. DWAF (Department of Water Affairs and Forestry), 1998c. Waste Management Series
(second edition): Minimum Requirements for Water Monitoring at Waste Management