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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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Public Process Consultants 8.2
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.
Section 8.5 – Waste Generation : Non-Process Waste
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Public Process Consultants 8.3
Provides a detailed description of non-process waste generation, the management and disposal
thereof.
Section 8.6 – Waste Characterization
Provides a detailed description of the types and, where possible, quantities of waste likely to be
produced by the proposed development in the construction, operation and decommissioning
phases.
Section 8.7 – Temporary Storage of Waste
Provides a description on the temporary storage requirements for the different types of waste and
the storage volumes for the different hazard types.
Section 8.8 – Delisting of Gypsum
Provides details regarding the characterization of Gypsum and the delisting process
Section 8.9– Identification of Waste Management Activities
Possible Waste Management Activities are evaluated for applicability to the processes at the
proposed paint stripping plant
Section 8.10 - Assessment of the Potential Environmental Impacts
Potential environmental impacts that might occur as a result of the proposed Nirove paint stripping
plant and associated activities are assessed in detail in this section.
Section 8.11 – Recommendations
Provides conclusions and makes recommendations in terms of this specialist study.
Section 8.12 – References
Cites any texts referred to during preparation of this report.
Appendices
8.2 METHODOLOGY AND APPROACH
8.2.1 Introduction
The approach to this specialist assessment was guided by the statutory requirements relating to
the identification, classification and handling of waste for both General and Hazardous waste. Data
for the identification of the waste streams were provided by Ms N Coke from Nirove, based on
information from the existing Nirove plant in Port Elizabeth and from their plants in Germany and
Italy. This information was used to identify and classify the sources of waste, the various types of
waste and the waste streams. Where the testing results were unavailable or incomplete a
precautionary approach was taken in the classification of the waste. Where possible, the
quantification of waste streams from the proposed Nirove paint stripping plant was attempted. The
handling, storage, transportation and disposal of all waste types have been described.
8.2.2 Classification of wastes
Identification of general and hazardous wastes were done in accordance with the Department of
Water Affairs and Forestry‟s Minimum Requirements for the Handling, Classification and Disposal
of Hazardous Wastes, the Minimum Requirements for Waste Disposal by Landfill, the National
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Public Process Consultants 8.4
Waste Management Strategy of 2000 and the National Environmental Management: Waste Act
(Act 59 of 2008).
Formal definitions of general and hazardous wastes have been based on the National Waste
Management Strategy which defines these wastes as follows:
General Waste is, “a generic term for waste that, because of its composition and characteristics
does not pose a significant threat to public health or the environment if properly managed.
Examples include: domestic, commercial, certain industrial waste and builders’ rubble. General
waste may have insignificant quantities of hazardous substances dispersed within it, for example,
batteries, insecticides, weed-killers and medicinal waste discarded on domestic and commercial
premises”. General waste may be disposed of at any permitted landfill.
Hazardous waste is, “waste which can even in low concentrations, have a significant adverse
effect on public health and/or the environment. This would be because of its inherent chemical and
physical characteristics, such as toxic, ignitable, corrosive, carcinogenic or other properties”.
Hazardous wastes are grouped into nine classes, based on international danger groups. The
waste is furthermore classed according to its hazard rating (1 = Extreme, 2 = High, 3 = Moderate, 4
= Low) based on acute mammalian toxicity, ecotoxicity, environmental fate, chronic toxicity and
other criteria. The hazard ratings have different treatment and disposal requirements. Hazardous
waste landfills are therefore divided into two types; H:H landfills can accept all hazard ratings of
waste, while H:h landfills can only accept hazard rating 3 and 4 and general waste.
General waste may be sub-divided into six subcategories, and hazardous waste into the nine
danger groups as shown in Table 8.1.
A hazardous waste can be treated in order to lower its hazard rating. If the concentration of a
certain compound in the environment is within an acceptable risk, that compound must be able to
'move out', i.e. delist from its primary classification rating to a lower rating, or to a situation where it
can be regarded as 'non-hazardous'. Delisting of the gypsum waste will be attempted in Section
8.6.2.
Table 8.1: Waste categories relevant to the proposed plant.
Source Waste
Paper
Metals
Glass
Plastic
Organic waste
Inerts and builders rubble
General
Industrial
Waste
Source Waste
Class 1 Explosives
Class 2 Gases
Class 3 Flammable liquids
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Public Process Consultants 8.5
Class 4 Flammable solids/substances
Class 5 Oxidising substances
Class 6 Toxic and infectious substances
Class 7 Radioactive substances
Class 8 Corrosive substances
Class 9 Other
Hazardous
Industrial
Waste
Non-toxic hazardous waste
Delisted hazardous waste
The different process wastes and the combined waste streams from the various processes must
be classified in this study. The Minimum Requirements for the Handling, Classification and
Disposal of Hazardous Waste identifies four steps in the classification of a Hazardous Waste:
Step 1 - Identification of the waste or waste stream as probably hazardous.
Step 2 - Testing and analysis to determine the hazardous properties, characteristics and
components of a waste.
Step 3 - Classification and treatment in accordance with SANS 10228:2003 - The Identification and
Classification of Dangerous Goods for Transport. This standard contains 9 danger group classes.
Step 4 – Analysis and Hazard Rating of the waste or its residue, in order to determine the
treatment and disposal method.
Step 5 - An additional step would be re-examination of an existing classification with the objective
of possible delisting and reclassification. This would apply in cases where, because of pre-
treatment, low concentration, low mobility or other applicable factors, waste can delist to a lower
Hazard Rating.
8.2.3 Impact Assessment
The impact assessment and the identification of mitigatory recommendations were done according
to the approval of the Plan of Study for EIA. The method for the identification, assessment and
rating of impacts is outlined in Chapter Four of this report.
8.3 WASTE MANAGEMENT LEGISLATION
The section below provides a brief overview of the legislation governing waste classification and
transport, in particularly with regards to dangerous goods and thus hazardous waste, as well as the
statutory requirements related to the management and disposal of waste.
8.3.1 National Legislation
A) National Environmental Management: Waste Act, Act 59 of 2008
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The main legislation pertaining to waste management is the National Environmental Management:
Waste Act. For a study on waste management, it will be advisable to start to investigate the
definitions as provided with this legislation on waste:
“waste” means any substance, whether or not that substance can be reduced, re-used, recycled
and recovered—
(a) that is surplus, unwanted, rejected, discarded, abandoned or disposed of;
(b) which the generator has no further use of for the purposes of production;
(c) that must be treated or disposed of; or
(d) that is identified as a waste by the Minister by notice in the Gazette,
and includes waste generated by the mining, medical or other sector, but excludes —
(i) a by-product is not considered waste; and
(ii) any portion of waste, once re-used, recycled and recovered.
This act makes provision for waste licences for defined activities. These activities are contained in
GN 718 of 2009: List of waste management activities that have, or are likely to have a detrimental
effect on the environment). The activities that are applicable to Nirove are investigated in Section
8.9.
Chapter 4 of the Waste Act deals with specific requirements for the storage, collection and
transportation and disposal of waste. These requirements have been incorporated in the
recommendations to the study.
B) Minimum Requirements for the Handling, Classification and Disposal of Hazardous Wastes,
DWAF, 1998
The general requirements for the handling, classification and disposal of hazardous waste, and the
temporary storage thereof, is outlined in the Department of Water Affairs and Forestry‟s series of
publications. The legislation provides the means of assessing the waste type and to classify it in
order to plan a strategy for its safe disposal. Furthermore, it promotes environmentally acceptable
technologies whereby waste can be prevented, minimized and recovered.
The main objectives of hazardous waste management, outlined in this legislation, are to:
• ensure the correct identification and classification of a Hazardous Waste;
• keep Hazardous Waste from entering the environment illegally;
• implement "cradle-to-grave" principles by means of planned waste management strategies;
• control a Hazardous Waste until it is safely disposed of, by setting Minimum Requirements at
crucial points in its management.
C) Environmental Conservation Act of 1989
The Environment Conservation Act (ECA) promulgated prior to the National Environmental
Management Act (NEMA), was the main piece of legislation in dealing with environmental issues in
South Africa. The ECA has largely been repealed and replaced with NEMA and the Waste Act.
The control of waste disposal sites in South Africa was conducted under the auspices of the
Department of Water Affairs and Forestry until 2006, when the responsibility was transferred to the
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Public Process Consultants 8.7
Department of Environmental Affairs and Tourism. Although Section 20 of the ECA has been
repealed, any waste sites with licences issued under the ECA remain valid.
D) National Water Act
The National Water Act (NWA) contains two provisions regarding the protection of water resources
in South Africa from pollution. There are no rivers in the immediate vicinity of the area under this
study that qualify as a declared water resource, but it is feasible that underground water resources
in the area could be polluted through surface pollution (aquifers are included in the definition of a
water resource in Section 1 of the NWA).
In terms of Section 19 of the NWA, the owner or user of land must “prevent and remedy” the
effects of any pollution which causes, or is likely to cause, pollution of a water resource. If pollution
does occur, the person responsible for the pollution has to report the incident to the Department of
Water Affairs, the South African Police Services, as well as the relevant Catchment Management
Agency. The costs for remediation of the pollution are the responsibility of the polluter. A similar
requirement for reporting of environmental emergency incidents is contained in the NEMA Section
30.
8.3.2 Provincial and Local Legislation
The following provides an overview of Provincial and Local legislation relevant to the proposed
project.
A) Nelson Mandela Bay Metropolitan Municipality - Water and Sanitation Services By-law LAN 57,
2010
This by-law contains the requirements regarding the discharge of effluent into the municipal
sewerage system. In terms of Section 93 of this by-law a permit is required from the NMBM prior to
discharging any effluent into the municipal sewerage system. Permit conditions are stipulated to
control the quality of the effluent that is being discharged. The parameters are listed in Section 129
and 130 of this by-law.
B) Nelson Mandela Bay Metropolitan Municipality - Waste Management By-Laws, LAN 40, 2010
In Section 5 the by-law states the following regarding the categorisation of waste:
(1) For the purposes of this By-law, waste is categorised as either:-
(a) general waste, which consists of one or more of the following:-
(i) paper;
(ii) metals;
(iii) glass;
(iv) plastic;
(v) organic materials; and
(vi) inert materials, which includes building waste; or
(b) hazardous waste; as described in the DWAF Minimum Requirements documents or more
recent guidelines.
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(2) Within these two categories, waste is categorised according to its source namely:
(a) domestic,
(b) commercial; or
(c) industrial.
Section 29 of the Waste Management By-Law requires the waste transporter to be registered with
the local authority.
8.3.3 Implications for the proposed Nirove Paint stripping plant
The underlying goal of South Africa‟s environmental legislation is the protection of human and
environmental health and, importantly, the legislation promotes the governing of Duty of Care,
Polluter Pays Principle and the Precautionary Principle.
Due to the potentially significant negative impacts that waste, both liquid and solid, may have on
the environment, legislation prescribes that all wastes must be prevented wherever possible.
Waste generated must be managed in such a way so as to minimise any negative impacts.
Disposal of waste to landfill must be the last resort. Waste must be minimized, reused and recycled
before resorting to disposal.
The National Environmental Management Waste Act has significant implications for the day-to-day
management of waste streams, including the storage of waste. It also outlines the activities that
require a waste license to operate.
All of the above legislation was considered when assessing the potential impacts of waste streams
and when preparing a list of recommendations for sound waste management at the plant.
8.4 WASTE GENERATION: PROCESS WASTE
The various processes, activities and sources of waste at the proposed development are outlined
and discussed below. The project details are contained in Chapter 2 of the Draft EIA report.
8.4.1 Chemical stripping – Sulphuric Acid treatment
The chemical stripping treatment consists of a process whereby products are dipped into a bath of
sulphuric acid at 98% concentration, heated to a temperature of 80-900C. After the acid treatment
the parts are rinsed in the dipping tank with a final rinse in a wash bay.
During the paint stripping process the concentration of the acid in the bath decreases, thereby
reducing the stripping activity of the acid. The acid bath is replaced when the sulphuric acid
concentration drops to 85%, roughly every 8 – 10 days. This results in approximately 30 x 1 000
litre of spent acid per month.
The spent acid has been analysed and shown to be highly acidic, with very low concentrations of
dissolved metals (Table 8.2 - Innoventon test reports, Nirove/07/386 and EClabs /07/383, 2007).
Based on the very high acidity, thus very high corrosivity, the spent acid is classified as a Class 8
(II) Corrosive Hazardous Waste, with a Hazard Rating of 4.
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Table 8.2: Characteristics of spent acid
Parameter Analysis
pH <0.5
Viscosity 1.72 g/cm3
Assay Concentration 84%
Al 830 ppm
Ca 887 ppm
Fe 781 ppm
Ti 318 ppm
Currently the spent acid is contained and collected for disposal by a registered waste disposal
company. Due to the financial impact and the environmental unacceptability of disposal of the
spent acid waste, the neutralization of this waste is currently being considered. Landfilling of acid
waste without treatment is prohibited (DWAF, 1998a). Currently the waste disposal contractor
performs neutralization prior to the disposal of the spent acid to the landfill site.
The proposed treatment process for the spent acid will be to neutralize it in a designated area by
the addition of lime to produce a by-product of commercial value, i.e. gypsum. The water that is
generated in the neutralization process will most probably be of a neutral pH and can be
discharged to the municipal sewerage system. Fumes generated during the neutralization process
will require control, possibly through a scrubbing process. The treatment of spent acid on site is a
long-term project that the company has embarked on. Only after research has been completed and
the legal implications have been assessed, will the company implement this treatment if financially
feasible and environmentally sustainable. More details on the gypsum process are given in Section
8.8.
Sulphur dioxide emissions occur during acid paint stripping. The emissions are controlled by
filtration of the air through a gas scrubber. The gas scrubber uses water at an approximate rate of
120L/h (recycled). Overflow wastewater from the gas scrubbing process contains dissolved salts,
mainly sulphate. Test results from the gas scrubbing waste water at Nirove, Germany is shown in
Table 8.3. The waste water is reused by feeding it into a dipping tank in the acid bath process.
Table 8.3: Analysis of the gas scrubber water
Parameter Analysis (mg/L)
Calcium 120
Magnesium 33
Chloride 120
Sulfate 350
Conductivity 1600
8.4.2 Chemical stripping – Alkaline treatment
Two options for the chemical alkaline stripping process will be provided for: Option 1 – ethylene
glycol and option 2 using caustic potash, glycol and water in equal amounts. The specific
operations are outlined in Chapter 2, Section 2.5.2. As the products are stripped in the spraying
process, the activities of the alkaline solutions decrease and have to be replaced.
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Spent liquid from the glycol process will be generated at a rate of 5m3 per month. It will be stored in
the designated chemical storage area prior to collection from a registered waste company. An
analysis of this material has not been done, but it is anticipated to be similar to the starting
material, i.e. a glycol-based organic chemical. Ethylene glycol is a known Teratogen1, classified as
a Class 6 toxic chemical. However, its ecotoxicity is relatively low and it is biodegradable. This
spent liquid is therefore classified as a Hazardous waste, with a hazard rating of H4. Disposal to a
landfill site (H:H or H:h) without treatment is not allowed, while landfilling with ash-blending is
allowed.
The waste product from Option 2 will be a caustic waste liquid solution basic in nature (pH 7). The
spent solution will be directed to the WWT, approximately at a volume of 5 m3 per month. It will be
used to assist in the neutralization of the acidic waste water from the chemical acid treatment
process, as outlined above.
8.4.3 Mechanical stripping – High-pressure water treatment
High pressure water spraying is a current mechanical stripping treatment for painted products. The
products are bombarded with a water jet from a high-pressure system, thereby mechanically
removing paint from the metal surfaces. Water in the HP cleaning is used at a rate of 16L/h,
150kL/month. The waste water from the HP stripping area is expected to contain mostly the
stripped paint fragments. No chemicals are added, thus the water, once filtered, should be at a
neutral pH without any metallic contaminants.
The waste water from the HP striping treatment runs through a filter system prior to be discharged
to the municipal sewerage system. The paint residues are concentrated in the filter and collected
as a paint residue. The paint residue has not been analyzed, but is estimated to consist mostly of
the paint flakes, thus dried organic paint without any metallic components. Approximately 10 tons
of paint residues are produced annually. The residue will be stored in containers in the designated
waste storage area prior to collection. Due to the low amount of paint residue produced and the
inert nature of it, this waste can possibly be used in the brick-making industry. As a last resort it
can be used for ash-blending in a landfill site.
8.4.4 Mechanical stripping – Shot Blast treatment
Shot blasting is a mechanical stripping treatment that is proposed for the new stripping plant. This
treatment will be primarily used to clean residual ash from parts after treatment in the thermal
pyrolysis oven. In some cases painted parts will be treated as well. The parts are fed into a
chamber and then bombarded with small metal shots to mechanically strip the ash or paint from
the metal surface.
The pyrolysis ash residue and the used shot are extracted from the chamber and collected in a
bag filtration system. Spent shot that is collected at the bottom of the chamber is reused as far as
possible. Shot fragments, pyrolysis ash, rust and paint flakes are collected from the filtration
system in bags, amounting to 2.5 tons per month.
An analysis of the shotblast waste is not available, but it is proposed to contain the fine steel
fragments from the metal shots, ash from the pyrolysis process, rust particles and fine paint flakes.
1 Any agent that can disturb the development of an embryo or foetus.
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As such the shotblast waste can possibly be classified as a general waste and can be used as an
additive to the brick industry or the cement industry. The very fine nature of the ash can, however,
render it difficult to handle. This will be investigated during the operation of the plant. Alternatively,
as a last resort, the waste can be utilized for ash-blending on a landfill site.
8.4.5 Heat Stripping – Pyrolysis Treatment
A new heat stripping process proposed for the stripping plant is pyrolysis. Pyrolysis is a
thermochemical decomposition of organic material at elevated temperatures in the absence of
oxygen, while under pressure.
The result from treating painted products in the pyrolysis oven is the disintegration of the paint
layer. In effect the organic chemicals in the paint systems decompose or degrade thermally to form
new, lower-molecular weight chemical species, which are combusted in a combustion chamber at
7000C. The fillers and inorganic substances in the paint will remain as an ash. At the end of the
pyrolysis process water is sprayed into the chamber to ensure all gasses are routed to the
combustion chamber. Pyrolysis ash will be generated at a rate of 2.4 tons per month. It will be
collected in bags and stored in the designated storage area.
The current use of the ash in Germany is in an ash-recycling process as a carrier along with
soil/building waste and slag to condition slurry waste (Letter from ABL Technic, 2011). An analysis
of the pyrolysis ash from Nirove Germany is shown in Table 8.4 (Obermeyer test report). Sample 1
represents the ash “as is” (solid), while Sample 2 is a leachate of the ash, eluate. While the ash
contained heavy metals, the leachate sample indicated that very low amounts of the metals
leached out form the ash into the water. It must be noted that the paint systems used in South
Africa, i.e. specifically automotive paint systems, prohibits the use of lead containing paints (IDMS
requirements).
It is anticipated that the waste ash from the proposed Nirove plant will have low concentrations of
heavy metals and probably will be classified as a hazardous waste with a low hazard rating (H4),
or a non-hazardous waste. This needs to be determined once operations commence. Due to the
low leachability of the metals in the ash, the ash can probably be used in the brick-making industry,
alternatively as a source of ash for ash-blending on a H:H or H:h landfill site. If confirmed as a non-
hazardous waste, it can be used for ash-blending on a general waste site.
Table 8.4: Analysis of Pyrolysis ash
PARAMETER
SAMPLE 1 SAMPLE 2
Ash - solid
Eluate -
extracted
into water
pH 9.4 9.2
Hydrocarbon Index
mg/kg 520
Conductivity mS/cm 932
Chloride mg/L 88
Sulphate mg/L 90
mg/kg mg/L
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Metals
Arsenic 3 <5
Lead 720 <5
Cadmium 0.3 <1
Chrome 460 <10
Copper 240 <10
Nickel 170 <10
Mercury <0.2 <0.2
Thallium <0.5 <1
Zinc 13000 <50
8.4.6 Waste Water Treatment plant
All process water used for washing and rinsing purposes will be routed to the Waste Water
Treatment (WWT) plant. In general, the waste water entering the plant is extremely acidic. Analysis
from the Nirove plant in Italy indicated that the incoming water has a pH value of less than 3 (Table
8.5). The main aim of treating this waste water is to reduce the acidity of the water to acceptable
levels for discharging to the municipal sewerage system. This is achieved by neutralizing the acidic
waste water with lime.
Table 8.5: Waste water before and after treatment (Cat Group Labortoria Analisi Italy)
PARAMETER BEFORE AFTER
Day 1 – measurements
pH 1.19 7.27
Conductivity mS/cm 11.19 477
Aluminium mg/L 19.5 0.2
Cadmium mg/L BDL BDL
Chrome VI mg/L 1.0 BDL
Chrome Total mg/L 119.3 0.23
Nickel mg/L 64.6 0.13
Copper mg/L 0.09 BDL
Sulphate mg/L 2669 268.3
PARAMETER BEFORE AFTER
Daily Measurements
Day 2 - pH 0.87 7.39
Day 3 - pH 1.05 7.49
Day 4 - pH 1.22 7.07
Day 5 - pH 2.23 7.54
Incoming process water will be stored in a storage tank, after which it will be pumped to the
treatment tank. Thereafter lime and flocculant are added to neutralize the acidic water. This
creates a slurry which is pumped to the slurry tank for settling. A filtration system will dewater the
slurry and will produce a filter cake from the solids. The solid filter cake consists mainly of calcium
sulphate and is known as gypsum. Any metals occurring in the waste water will precipitated out in
the solids. A pH correction is done prior to the final release of the treated water to the municipal
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sewer. The estimated throughput at the treatment plant will be 30m3 a day, with an annual
throughput of 7 800m3
Analyses from the Nirove Italy plant before and after treatment of the waste water indicate the
complete neutralization of the acidic waste water in the plant. In addition, the metal constituents
also have been reduced to acceptable levels (Table 8.5).
A permit has been issued by the Nelson Mandela Bay Municipality for the discharge of industrial
effluent into the municipal sewerage system (Permit number 1939/Temp) for the existing NiRoVe
facility. The permit conditions for the quality of effluent that can be discharged are contained in the
permit. An analysis of key characteristics of the effluent at the current Nirove plant in Port Elizabeth
indicates that the effluent complies with the standard requirements. (Appendix 1). Sulphate
concentrations are high and exceed the standard by-law limits in the test report. This will be
addressed in quality control procedures of the new WWT plant. In addition to an annual testing of
the quality of the waste water against all the stipulated parameters as contained in the permit, key
parameters will be controlled on a monthly and daily basis. TDS measurements will be proposed
together with pH analysis as a control prior to releasing of the effluent to the municipal sewerage
system.
A new permit application will be made upon commencing of the proposed plant. The current
permitted discharge rate is 450 kL/month. This will be increased to 625 kL/month for the new
proposed plant, since more processes will be in operation.
8.5 WASTE GENERATION: NON-PROCESS AUXILIARY SERVICES
8.5.1 Construction and Relocation Phase
During the construction and relocation phase a significant amount of solid waste and sewage will
be produced. The quantity of waste (solid and liquid, including sewage), will depend on the
duration of the construction phase.
Waste streams likely to be produced during the construction and relocation phase will include both
general and hazardous wastes. Typical waste types will be vegetation waste generated from the
clearing of the site, scrubs, tree and grass. Packaging waste from building processes, off cuts of
wood and metal waste will also be produced. Metal and plastic wastes are also expected to be
generated during the relocation of sections of the plant. Hazardous waste can be generated during
the construction phase from empty tins, paint and paint cleaning liquids, oils, and chemicals.
During the construction phase additional workforce will be employed or contracted and some
sewage will also be generated. Often, chemical toilets are used on construction sites in which case
these would need to be emptied periodically and the waste disposed off at a municipal sewage
treatment facility. One can assume a volume of 100L of wash water and sewage per individual
during a work shift. This sewerage waste will be handled by the existing facilities at the plant.
Other operations such as washing of machinery will also generate waste water.
8.5.2 General (non-hazardous) Solid Waste
It is expected that the proposed operation will result in the production of general waste from
auxiliary services such as the:
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Administration and office block
Workshops / maintenance
Change rooms and ablution facilities
Process waste water treatment facility
It is likely that a relatively small quantity of general solid waste will also be produced within the
facility. General wastes could include vegetable waste, paper, cardboard, plastic, rubber, glass,
metal and a variety of synthetic compounds.
The staffing component for the proposed development is estimated at 30. With an estimated
production rate of 0.25kg solid waste/person/day during the working day (primarily from food
containers, bottles etc), it is expected that the facility will produce 8 kg of general solid waste per
day that will require disposal. It would be important to monitor and record volumes of general waste
produced at the facility as part of the facility‟s waste management plan.
Any general waste that is stored temporarily on site will be contained within a designated area on a
hard surface to minimise the risk of pollution. The waste will be removed from site regularly and the
total quantity being stored will not exceed 90m3.
According to the waste management hierarchy, attempts should be made to prevent the production
of waste wherever possible. Thereafter, wherever possible or economically viable, general solid
wastes should be separated and recycled/reused (table 8.6). Recyclers are well established in the
Port Elizabeth region. Waste management infrastructure and institutional capacity is already well
developed. Where recycling is not possible, general solid waste should be transported to the
nearest licensed sanitary landfill site for disposal.
The eventual transport of the waste off-site for re-cycling or disposal poses unique challenges as
this is when most legal requirements become applicable. The waste must be transported by a
registered reputable contractor to a registered waste site. The contractor needs to be approved by
the Nelson Mandela Metropolitan Municipality. The current waste sites that are available to Nirove
to dispose of waste are as follows:
Table 8.6: Identification of potential wastes to be recycled
# Types of waste Source Destination Strategy
1.
Packaging waste
(uncontaminated paper,
glass, cardboard, plastic,
aluminium cans etc.)
Administration Specialist Recycler Recovery or Recycle
2. Hazardous waste (Oils,
lubricants etc) Maintenance Specialist Recycler Recovery or Recycle
3. Metals and wood (scrap) Maintenance Specialist Recycler Recovery or Recycle
Site Type Operator Permit Number
Aloes II Hazardous Waste (H:H) EnviroServ 16/2/7/M100//Y1/P271
Arlington General Waste (GLB:minus) NMBM 16/2/7/M200/D1/Z1/P278
Koedoeskloof General Waste (GLB:minus and h:h) NMBM B33/2/1200/7/P37
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# Types of waste Source Destination Strategy
4. IBC Containers Process
Department Specialist Recycler Recovery or Recycle
8.5.3 Hazardous Wastes (liquid and solid)
Due to the nature of the proposed operation, it is likely that all of the auxiliary services that produce
general waste will also produce a range of hazardous liquid and solid wastes. Typical hazardous
wastes produced by the various auxiliary services are summarised in Table 8.7. At this stage it is
not possible to quantify the various waste streams but accurate recording of hazardous waste
volumes produced by the facility should form part of the waste management system/integrated
waste management plan.
Table 8.7: Summary of typical hazardous wastes (solid and liquid) likely to be produced by
auxiliary services.
Service Area Hazardous waste
Waste water treatment plant Chemical containers, used chemicals, gloves, electronic equipment
Workshops / maintenance Chemical containers, solvents, paints, hydrocarbon products, oily
rags and vehicle parts and machinery, batteries
Administration and office blocks Electronic equipment, fluorescent tubing, solvent-based cleaning
agents, pesticide cans
Where disposal is unavoidable, this should be done responsibly to a registered waste disposal
facility. In terms of the precautionary principle, where all wastes should be considered hazardous
unless proven otherwise, it is essential to separate hazardous and general wastes and correctly
label all wastes. Unknown wastes must be regarded as hazardous and managed and disposed as
such.
8.6 CLASSIFICATION OF WASTE
The waste types, classification, volumes, management and disposal of the waste generated at the
proposed Nirove paint stripping plant are listed in Table 8.8.
Table 8.8: Summary of the waste management at Nirove paint stripping plant
WASTE TYPE CLASSIFICATION VOLUME\ MANAGEMENT & DISPOSAL
Phase 1: Construction
General solid waste Non-Hazardous Variable Minimise, reuse, recycle and then
dispose of remaining waste at
licensed disposal facility
Hazardous solid Hazardous Variable
Hazardous liquid Hazardous Variable
Sewage / wash water Sewage 100L / individual
shift
Discharge to municipal sewerage
system
Shrubs, trees, clearing
of site Non-Hazardous Variable Composting
Phase 2: Operation: Process Waste
Spent acid Hazardous: Class 8
Corrosive pH<1; H4 30m
3/m
H:H of H:h disposal or minimize by
producing gypsum by-product
Scrubber water Hazardous acidic
waste water Continuous Recycled to dipping tanks
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Spent glycol Hazardous: Class 6
Toxic; H4 5m
3/m H:H or H:h disposal
Spent caustic Hazardous: Class 8
pH>10 5m
3/m
Treated in the Waste Water
Treatment Plant
Pyrolysis ash Possibly General
waste 2.4 t/m
Brick ore cement industry, or use
for ash-blending in landfill Dust shot blast
Possibly General
waste 2.5 t/m
Dry paint residue Possibly General
waste 1 t/m
Waste water from
various processes
Hazardous: Class 8
Corrosive pH<3 H4 900m
3/m
Treated in Waste Water Treatment
Plant
Effluent Non-Hazardous
Industrial waste water 650m
3/m
Permitted to discharge to municipal
sewer
Gypsum by-product to
WWT plant
Hazardous, H4.
Possibly Non-
hazardous
30m3 Currently attempting to delist
Phase 2: Operation: Non-process Waste
General solid waste Non-Hazardous < 1t/m
Minimise, reuse, recycle and then
dispose of remaining waste at
licensed disposal facility
Hazardous solid Hazardous: various
classes < 1t/m
Hazardous liquid Hazardous: various
classes < 1t/m
Sewage / wash water Hazardous: Class 6 100 L / individual Discharge to sewer
Phase 3: Decommissioning
General solid waste Non-Hazardous Variable
Minimise, reuse, recycle and then
dispose of remaining waste at
licensed disposal facility
Hazardous solid
Hazardous: various
classes Variable
Hazardous liquid
Hazardous: various
classes Variable
8.7 TEMPORARY STORAGE OF WASTE
Waste that is generated in the paint stripping plant will inevitably need to be stored on a temporary
basis prior to collection for recycling, re-use, or disposal. Two areas are envisaged for the storage
of waste:
8.7.1 General Waste Storage Area
This waste storage area is designated for the storage of general and recyclable wastes only. Due
to the small labour component of the proposed plant, the volume of general non-process waste
generated will be very low and is estimated to be less than 1 ton per month. Non-hazardous
process waste will possibly be the dry pyrolysis ash, the shot blast ash and the dry paint residues.
The volumes of these wastes vary, but are estimated at 6 tons per month. Collection of the dry
waste will take place during the month. It is estimated that at any time less than half of the total
monthly amount produced will require storage, thus 3 tons or ~4m3. An estimated total volume of
non-hazardous waste for storage during a month will be approximately 5 m3. Bins will be provided
for specific recyclables by the selected waste contractor based on the volumes generated at the
plant. Collection will be done at frequent intervals or when the containers are nearly full, at the
same time ensuring that the waste will not exceed a 90 day storage period.
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8.7.2 Hazardous Goods Storage Area
Hazardous waste will be stored in a designated area, the Hazardous Goods storage area. Care
must be taken to separate incompatible chemicals and wastes from one another. Ethylene glycol
must not be stored in close proximity with sulphuric acid or other acids. In the case of spills waste
will be contained since the Hazardous Goods storage area will be bunded for protection. Collection
of hazardous waste will be upon filling of waste bins (mostly IBC‟s).
The on-site storage of waste has to comply with the DWAF Minimum Requirements. Hazardous
waste can be stored on site for a maximum of 90 days in the following quantities:
Hazard Rating 1 = 10 kgs
Hazard Rating 2 = 100 kgs
Hazard Rating 3 = 1 000 kgs
Hazard Rating 4 = 10 000 kgs
It is anticipated that hazardous waste storage will not exceed the volume or the storage period as
stipulated. Hazardous waste will be collected by a reputable registered waste collector and will be
disposed at a landfill site registered to take the specific waste type. In the Port Elizabeth region
three main landfill sites are in operation:
8.7.3 Volume of temporary stored hazardous waste
The definitions from the National Environmental Management Waste Act of storage and treatment
are required to accurately determine the volumes of waste that will be stored, i.e.
“storage” means the accumulation of waste in a manner that does not constitute treatment or
disposal of that waste;
“treatment” means any method, technique or process that is designed to—
(a) change the physical, biological or chemical character or composition of a waste; or
(b) remove, separate, concentrate or recover a hazardous or toxic component of a
waste; or
(c) destroy or reduce the toxicity of a waste,
in order to minimise the impact of the waste on the environment prior to further use or disposal;
In view of the above, the treatment of waste does fall under the storage of waste. This means that
the volumes of waste that is in the process of being treated, such as in the waste water treatment
plant are not considered when volumes of stored hazardous waste are being determined. This is
important when waste licence applications are considered (Section 8.9).
From Section 8.5 the hazardous waste that will need to be stored on site in a temporary storage
area will be the ethylene glycol waste, at an estimated volume of 5m3 per month. In addition, spent
sulphuric acid waste will require storage prior to collection. After the emptying of an acid tank, 6m3
of spent acid waste will need to be collected / treated. The spent acid will be collected in 1m3
containers and will need to be stored temporary in a storage area. The waste water from the wash
bay and rinsing tanks will be treated in the waste water treatment plant and will not be stored.
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Spent liquid from the caustic treatment and from the hydrochloric acid baths will be directed to the
waste water treatment plant for neutralization. Gypsum from the WWT plant is produced in
volumes of 30m3 per month. An estimated volume of one weeks production will need to be stored
on-site prior to collection, thus ~ 8 m3.
The final classification of the dry process wastes (ash, paint residue, and shotblast waste) will
indicate their storage requirements. It is however estimated that all the dry waste can be classified
as non-hazardous and will therefore not be stored in the hazardous goods area. At the estimated
volumes of 6 tons per month the storage area required is relatively small, specifically since
collection of the ash will take place during the month. It is estimated that at any time less than half
of the total monthly amount produce will require storage, 3 tons or ~4m3.
If a precautionary principle is being adhered to and the dry waste is classed as hazardous, then the
maximum amount of hazardous waste requiring temporary storage prior to collection or treatment
at any time will be approximately 24m3:
Spent ethylene glycol: 5m3,
Spent acid waste: 6m3
Gypsum by-product 8m3
Non-process hazardous waste: 1m3,
Dry waste 4m3
Total hazardous waste storage: 24m3
This is less than the waste licence requirements of more than 35 m3 storage of hazardous waste
and thus a waste licence will not be required (see Section 8.9). However, adequate provision must
be made available in the Hazardous Goods storage area for the temporary storage of this quantity
of hazardous waste. Care must be taken not to store incompatible chemicals and waste together
(for example ethylene glycol and sulphuric acid).
8.8 DELISTING OF GYPSUM WASTE
8.8.1 Gypsum Production
Gypsum is produced in the current paint stripping plant as a by-product of the Waste Water
Treatment Plant. 30m3 of gypsum waste is produced in a month. The waste is currently being
disposed to a H:H site at Aloes II, operated by Enviroserv. In addition, 30m3 of the spent acid is
also disposed to the landfill site.
As already indicated the disposal of waste to landfill should be the last resort option. Thus Nirove is
investigating the neutralization of the spent acid by lime to also produce more gypsum. Spent acid
will be added to the lime or hydrated lime in a spray method to convert it to a solid powder, called
gypsum. Hydrated limes are only slightly soluble in water. The lime that is in solution will ionize to
form Ca++, Mg++ and OH-. In the presence of an acid the metal ions react with their
corresponding acid ions to form calcium or calcium-magnesium salts and water. As the ions react,
the lime that is in suspension dissolves, ionizes and reacts with the acid. The process continues
until all the acid is neutralized or all the lime is consumed. Water is produced at a neutral pH
according to the following formula:
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Ca(Mg)O(s) + H2SO4(l) -> Ca(Mg)SO4(s) + H2O(l)
The gypsum will be in a slurry format and will require a filtration system. This reaction is an
exothermic reaction, meaning that it will generate heat. Care will therefore be taken to add acid in a
very controlled rate to the lime, and to house the treatment facility in a vessel that can resist the
heat build-up (not plastic). Sulphuric acid fumes that will be generated in the neutralization
process, will need to be scrubbed.
The anticipated use of the gypsum will be in the agricultural industry as a fertilizer and a soil
conditioner. It can also be used in the building industry, and it can be an additive in the cement
industry. The avenues for the utilization of the gypsum will need to be researched thoroughly prior
to its implementation.
The leaching characteristics, metal concentration and stability of the gypsum will determine its
classification. The precautionary approach has been taken and the waste has been classified by
the existing plant as a hazardous waste.
8.8.2 Delisting of Gypsum By-product
Since gypsum is a sought after natural occurring mineral that finds application in the agricultural
and building industry, the gypsum that is produced at Nirove can possibly be utilized. This will
lower the impact on the environment, and be in line with the waste management strategy to
minimize and utilize waste, rather than disposal to landfill. Analysis done in Italy on the gypsum
from Nirove, Italy, indicates that very low metal concentrations are leaching from the gypsum solids
(Table 8.9)
Table 8.9: Gypsum characterization (Catillolab, Italy)
PARAMETER
SAMPLE 1 SAMPLE 2
Solid
(mg/kg) Eluate (mg/L)
Antimony <2 <0.01
Arsenic 1 <0.01
Cadmium <1 <0.01
Chrome Total 64 <0.01
Mercury <1 <0.001
Molybdenum <2 <0.01
Nickel 8 0.02
Lead 5 <0.01
Copper Total 10 <0.01
Selenium <2 <0.01
Zinc 91 <0.01
pH 6.9
DOC 28
TDS 2 400
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
Facilities. Pretoria, South Africa.
Recommended