CHAPTER EIGHT: WASTE MANAGEMENT AND DISPOSAL

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.



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



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



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



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



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



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.



(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.



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.



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.



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



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



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:



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



# 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



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



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



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.



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.



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:



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



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




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




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?



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.



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.



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.



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.


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


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.


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.



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.


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


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.



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.


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.


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.


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.



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


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





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


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


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


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

-




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


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

Draft EIA, NiRoVe Paint Stripping April 2011


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;



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.



APPENDIX 1:





Documents

CHAPTER EIGHT: WASTE MANAGEMENT AND DISPOSAL