Lonmin Platinum Process Division - jaws.co.za · Mandy Jubileus Reviewer 1 by: SHEQ Manager Willem...

Lonmin Platinum

Process Division General and Hazardous Waste Management

DOCUMENT NO. REVISION PRINT DATE PAGE

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THIS DOCUMENT IS NOT CONTROLLED IF PRINTED

Revision Number 19 Date July 2014

Reference Number PD_ENV_001

Document Title General and Hazardous Waste Management

REVIEW AND APPROVAL SIGNATURE RECORD

ROLE NAME AND SURNAME SIGNATURE DATE

Originator: Environmental Specialist

Mandy Jubileus

Reviewer 1 by: SHEQ Manager

Willem Welmans Automatic Approval

Reviewer 2 by: Senior Manager Smelter

Bennie du Toit Automatic Approval

Reviewer 3 by: Senior Manager BMR

Lindani Ntombela Automatic Approval

Reviewer 4 by: Senior Manager Concentrators

Kiran Chaitram Automatic Approval


Selwyn Green Automatic Approval


Alex Horne Automatic Approval

Approved by: VP Processing Frans de Beer

Approved by: VP Concentrators

Riaan Blignaut


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RECORD OF REVISION

REVISION NO. DESCRIPTION DATE

16 Reviewed Management of Salvageable Waste Oct 2013

17 Addition of PMR requirements Nov 2013

18 Addition of Waste Management By-Law (Rustenburg Municipality)

Jan 2014

19 Addition of Ekurhuleni, Madibeng and Rustenburg Waste By-Laws as well as addition of Changes to National Legislation (Norms and Standards for the storage of waste, Waste Classification and Management Regulations, List of Waste Management Activities that have, or are likely to have, a detrimental effect on the environment; National Norms and Standards for the assessment of waste for landfill disposal

July 2014


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TABLE OF CONTENTS

REVIEW AND APPROVAL SIGNATURE RECORD 2

RECORD OF REVISION 3

SCOPE 5

PURPOSE 5

DEFINITIONS & ABBREVIATIONS 5

RESPONSIBILITIES 6

PROCEDURE 7

RECORDS 25

FLOW CHART 26

REFERENCES 27

APPENDICES 28


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SCOPE

This procedure includes the sorting, storage, handling, transportation, recycling and disposal

of hazardous and general wastes generated from all activities, products and services of

Process Division.

PURPOSE

This procedure serves to provide guidance to all Process Division employees on the

management of hazardous and non-hazardous (general) wastes to ensure all wastes are

responsibly handled, contained, controlled, recycled and / or disposed of at all operations.

DEFINITIONS & ABBREVIATIONS

TERM DESCRIPTION

Hazardous waste

Section 1 of the National Environmental Management: Waste Act, 2008 defines Hazardous Waste: means any waste that contains organic or inorganic elements or compounds that may, owing to the inherent physical, chemical or toxicological characteristics of that waste, have a detrimental impact on health and the environment;

AIA Approved Inspection Authority

ASH Andrew Saffy Hospital

BMR Base Metal Refinery

Building and demolition waste

Section 1 of the National Environmental Management: Waste Act, 2008 defines building and demolition waste: means waste, excluding hazardous waste, produced during the construction, alteration, repair or demolition of any structure, and includes rubble, earth, rock and wood displaced during that construction, alteration, repair or demolition

Business Waste

Section 1 of the National Environmental Management: Waste Act, 2008 defines Business Waste: means waste that emanates from premises that are used wholly or mainly for commercial, retail, wholesale, entertainment or government administration purposes;

Domestic Waste

Section 1 of the National Environmental Management: Waste Act, 2008 defines Domestic Waste: means waste, excluding hazardous waste, that emanates from premises that are used wholly or mainly for residential, educational, health care, sport or recreation purposes;

General Waste

Section 1 of the National Environmental Management: Waste Act, 2008 defines General Waste: means waste that does not pose an immediate hazard or threat to health or to the environment, and includes— (a) domestic waste;


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TERM DESCRIPTION

(b) building and demolition waste; (c) business waste: and (d) inert waste;

HAZMAT Hazardous Materials Substances

Health Care Risk Waste

Means that portion of health care waste which is hazardous and includes infectious waste, pathological waste, genotoxic waste, chemical waste, waste containing heavy metals, radioactive waste, and any other waste which is considered hazardous in terms of the Waste Management Series: Document 1: Minimum requirements for the handling, classification and disposal of Hazardous Waste, 2nd edition as published by the Department of Water Affairs and Forestry

Inert Waste

Section 1 of the National Environmental Management: Waste Act, 2008 defines Inert Waste: means waste that— (a) does not undergo any significant physical, chemical or biological transformation after disposal; (b) does not burn, react physically or chemically biodegrade or otherwise adversely affect any other matter or environment with which it may come into contact; and (c) does not impact negatively on the environment, because of its pollutant content and because the toxicity of its leachate is insignificant;

MSDS Material Safety Data Sheet

PMR Precious Metals Refinery

PPE Personal Protective Equipment

PVC A synthetic thermoplastic material made by polymerizing vinyl chloride. The properties depend on the added plasticizer. Rigid PVC is used for moulded articles

SBS Shared Business Services

SFP Sulphur Fixation plant

SHEQ Safety, Health, Environment and Quality

SHEQMS Safety Health Environment and Quality Management System

RESPONSIBILITIES

POSITION TITLE ROLE / DESCRIPTION OF TASK

SHEQ Department Compliance awareness, auditing and development of

training material

Departmental heads Communicate the procedure to employees and enforce it.

All employees Waste sorting according to this procedure and undergo Waste

Training.


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PROCEDURE

1. Waste Generation

The waste sorting and management of waste streams remains the responsibility and

accountability of the waste generator. Waste generators shall comply with the following

requirements:

Damaged drums and wheelie bins will be replaced.

All hazardous waste containers will remain closed when not being loaded with waste.

Standardized signs will be displayed and will be visible. Wheelie bins, waste drums, plastic

bags will be labeled as per PD_OPG_076 - Waste Signage PMR / PD_OPG_023 - Waste

Signage Marikana.

The waste temporary storage area (general and hazardous) must be cemented

The waste contractors will not remove waste from a site if the waste is not sorted as per this

procedure. The objective of sorting is to ensure:

the segregation of hazardous waste from general waste

the responsible transportation and disposal of all waste types (SANS 10228:2012)

reduce generation of waste and the costs associated therewith.

the optimisation, re-use, or recycling of wastes

2. PPE to be used with Handling Waste

Personnel involved in the handling, sorting and disposing of waste must wear the correct PPE at

all times. For example:

Gloves and dust masks must be worn by personnel sorting general waste.

Hazardous waste, especially chemical waste, may require acid resistant overalls, acid

resistant gloves, dust mask, safety glasses and if necessary a gas mask. FFP3 dust masks,

PVC gloves and standardised plant PPE must be worn when crushing fluorescent tubes.

3. Fluorescent Tubes

Fluorescent tubes must be disposed of in the designated fluorescent tube drums. The fluorescent

tube must be placed in the chute on top of the drum. The chute must be closed with the lid and the

handle on the drum turned to crush the tube. The fluorescent tube drum must be sealed at the point

where the crusher is attached to the lid and the lid of the drum must also be sealed. Drums must be

sealed before they are taken away for disposal by the relevant hazardous waste service provider.

Drums must be replaced (can be obtained from the Lonmin salvage yard in Marikana or ordered


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from the stores at PMR). Gasses released from fluorescent tubes are carcinogenic; therefore special

precaution should be taken to prevent inhalation of these fumes. Mercury bulbs are to be placed in

a clean 210L drum as per relevant colour coding. Care must be taken to prevent the mercury bulbs

from breaking when they are disposed in the drums.

4. Asbestos Waste

Asbestos has been identified and has been listed in an asbestos inventory. Future arising asbestos

waste must be placed in containers that will prevent the likelihood of exposure during handling. All

containers or articles that have been in contact with asbestos must be cleaned and decontaminated

after use. Asbestos waste must be disposed of in double plastic bags which is sealed, thereafter the

bags will be stored in a safe place (roofed, cemented and dry area separated from other hazardous

waste/materials) until the relevant waste service provider has collected it for disposal. All personnel

collecting, handling, transporting and disposing of asbestos waste should wear the correct PPE

including gloves, dust masks (FFP3)/ respirators and safety glasses.

5. Explosive Waste Management

In terms of regulation 3.4.2 and 3.9 of the Explosives Act Regulations, permission has been granted

to Lonmin Platinum Marikana to dispose of fuses and detonators at Chicane who collects this waste

from the concentrators. See PD_OPG_051 - Handling of Explosive Wastes.

6. Disposal of Computer Hardware

Computer hardware is collected by Lonmin Information Management team for disposal by a

competent, external contractor.


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7. Disposal of Radioactive Waste

Radioactive waste is to be disposed of to a radioactive waste disposal facility. Safe disposal

certificates must be kept for all sources disposed.

8. Electronic waste

All electronic waste (excluding computer hardware) must be disposed of in the designated bins

provided. The waste collection contractor will empty the wheelie bin on site and remove the

electronic waste to the salvage yard where it will be recycled. Waste contractor must not remove the

plant wheelie bins from the site.

9. First Aid Medical Waste

Medical waste could be generated during the treatment of injuries on site. This waste must be

placed in waste bags, which will be transported to the relevant medical facility (ASM at Marikana and

PMR medical centers) where it will be placed inside a bio hazardous receptacle that is appropriately

labeled. All medical waste should be treated with a cautionary approach and personnel handling this

waste shall wear the appropriate PPE.

Health Care Waste at the PMR must be managed according to the following requirements

Generators, transporters and disposers must register and obtain written approval with the

Council

Minimize generation of Health Care Risk Waste

Separate health care waste into health care risk waste and health care general waste at

point of generation.

Red and yellow sharps containers for needles, must be made up of materials that cannot be

pierced. The container must be fitted with a safe and hygienic lid, which must be sealed after

use.

Cardboard container with red plastic liner marked as bio- hazardous for medical waste.

All employees are to be trained in the identification, separation, handling, storing of health

care risk waste

All health care risk containers are to be labeled with the following information:

o Name, address and contact telephone number of the generator


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o The words: DANGER; HEALTH CARE RISK WASTE; GEVAAR –

GESONDHEIDSAFVAL, and INGOZI:INKUNKUMA YEZAMAYEZA and the

international bio-hazard logo

o The date on which the health care risk waste is removed from the premises of the

generator.

Prevent public access to the health care risk waste containers.

Store filled health care risk waste containers in controlled, secure areas which are reserved

for the storage of health care risk waste

Make arrangements for the removal of health care risk waste from the PMR’s premises by a

registered transporter of heath care risk waste (Compass)

Disposal of health care risk waste by a company permitted to do so (Compass)

Maintain an up-to-date written record of all health care risk waste generated and removed

from the PMR.

Obtain records of safe disposal of health care risk waste at a permitted landfill site.

Provide records of the safe disposal certificates on a six-monthly basis to the Council.

Compass will be audited according to legal requirements including those set out in the sections on

Transporters and Disposal in the Ekurhuleni Health Care Waste By-Laws (2004).

10. Special Industrial, hazardous, medical and infectious refuse (Applicable to PMR)

The PMR must inform the Council of the composition, quantity, method of storage, proposed

duration of storage and manner of removal of Industrial, Hazardous and Infectious waste.

Analysis of such waste must accompany the notification.

The Council must be notified of any changes in the composition of the waste generated.

This waste must be stored in a manner to ensure that it will not become a nuisance, safety

hazard or pollute the environment.

This waste must be removed within a reasonable time.

This waste must be stored in a container approved by the Council

Written approval must be obtained from the Council for the company removing such waste

from the premises.


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11. Contaminated PPE

Contaminated PPE (gloves, welding aprons, damaged hard hats etc.) are treated as hazardous

waste.

12. Materials Containing PCB’s

Materials containing PCB’s shall be handled and disposed of as per the requirements below

(SANS290)

Any dielectric fluid of unknown PCB concentration shall be assumed to be a PCB item and shall

be stored in a container which shall be:

labelled

may not leak or distort when filled with PCB contaminated material

the container shall not be filled to capacity, but shall allow for sufficient room for expansion of

the transformer oil under abnormal conditions (temperatures higher than 55 °C)

All transformer oils containing PCB’s shall be stored separately in the hazardous temporary

waste storage area. PCB waste shall be classified for transport purposes in accordance with

SANS 10228 and the packaging shall comply with the requirements of SANS 10229-1.

13. Building Waste

Building waste must be stored separately from all other waste types

Building waste may be temporarily stored on soil in designated areas, provided that there is no

contamination or other wastes stored with the building rubble. The number of designated areas

for temporary storage of building rubble must be limited per plant/area.

Building rubble may not be stored for a period exceeding 7 days after completion of a project.

The land or premises on which building waste is generated may not become unsightly or a

source of nuisance as a result of accumulation of building waste or dust.

Building rubble shall be disposed of at a reputable landfill site (Mooinooi Landfill site or

Municipal Landfill site).


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Building rubble that is to be used for reclamation of land can be deposited at a place other

than a reputable landfill site, provided written consent is obtained from the Municipality /

Council (applicable to Madibeng and Ekurhuleni)

Building rubble may not be dumped on sidewalks, roads, parks, public places or any other

place not designated for waste disposal.

Proof of safe disposal to be made available for submission to the Council (only applicable to

PMR)

The PMR may only make use of a person authorised by the Council to remove building refuse.

14. Garden Refuse

Garden refuse is to be disposed of within a reasonable time after the generation thereof.

Garden refuse must be disposed of at a site designated therefore (Mooinooi Landfill Site or

one designated by the Municipality)

Garden refuse may not be dumped on sidewalks, roads, parks, public places or any other

place not designated for waste disposal.

Proof of safe disposal to be made available for submission to the Council (only applicable to

PMR)

The PMR may only make use of a person authorised by the Council to remove garden

refuse.

15. Security

15.1 Smelter

The storage area will be locked and keys will be kept by Security who will always be available

at the Matte yard at telephone 014 571 3429 (Mill & Leach Control Room). Security personnel

will accompany all persons entering the hazardous waste storage area. The gate will only be

opened after inspection of waste. Bins will be removed by a certified hazardous waste

contractor, Interwaste / Enviroserv, and will be escorted to the main gate by Smelter security.

Waste containers must be intact and lids closed/covered.


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15.2 BMR

Bins are emptied on a daily basis and waste bags are taken to the airlock where Security

officers have to search through the bags. Security officers search these waste bags manually.

A separate hazardous waste bin is provided for broken glass at the Laboratory because it

creates a safety hazard for security personnel when mixed with general waste.

After leaving the airlock the waste bags are removed by the Production team to the different

waste telecon bins at the central waste facility area. If waste has to be sorted, appropriate PPE

must be used e.g. gloves and dust masks.

15.3 PMR

Management and control of the Waste Management Centre (WMC) remains the responsibility

of the Security Superintendent. No person is allowed to enter the area and remove any item

without permission of the Security Superintendent. Security standards shall be adhered to at

all times. No waste material will enter the Freight Centre after normal working hours or on

weekends except by prior arrangement. Only waste will be stored at the Skip Area. The

generator is responsible to separate all scrap before it will be collected by the Waste

Collectors to be transported to the Freight Centre, if waste is not separated correctly it will not

be removed. The person sealing the waste bag in the plant will conduct a visual check to

ensure no PGM’s are discarded into the waste bag / bin. The person sealing the bag should

capture the seal number, as well as his own details in the Seal Register. The seal is an

indication that the bag is full, a visual check has been conducted and is ready for collection. If

not sorted according to procedure, an environmental incident will be raised. Mop heads and

filter cloths from Level 2 (core production plants) must be separated from other contaminated

waste, and sealed in a separate waste bag as it is sent directly to MHD and not to the Freight

Centre. Mop heads and filter cloths from Level 3 (outside / services) are separated and sent to

the Freight Centre. All Level 2 waste is sent to the Central Plant Airlock (CPA) where it will go

through a goods scanner in order to ensure the waste is PGM free. Should any PGM’s be

recovered from the waste a sample will be taken for analysis and depending on the size of the

parcel, the rest will be returned to production. A security incident will be raised.

Security, in conjunction with the cleaners are responsible to remove all waste from the CPA to

the Freight Centre via forklift. All Level 3 waste is also separated according to the various


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waste streams and transported to the Freight Centre via forklift. At the Freight Centre the

waste will once again go through a goods scanner to ensure the waste is PGM free. As a

return on investment items have been identified which could contain traces of PGM’s. These

are delivered to a Service Provider whereby the waste is reprocessed and the ash returned to

the PMR. All waste streams identified as possible PGM waste containing waste, is stored

within a dedicated storage area.

Items which cannot be washed out within the respective plants shall be escorted by a Security

Official to the Freight Centre whereby these items must be decontaminated within the

Decontamination Bay by the respective plant personnel under surveillance. The waste

generated from the washing activities within the Decontamination Bay will be returned to the

process, solid material is transferred to MHD and the liquor is pumped to RDD.

Items entering the Freight Centre should be of a reasonable size so that they can easily be

decontaminated (if need be) and placed into the respective waste skip. If there is a need to

dispose of items of a greater size, this will be done via prior arrangement with the Security

Superintendent who will be responsible for safe disposal. Where possible all recycle material

i.e. pvc, polypropylene pipe and lengths of steel, should be stockpiled for re-use where

possible.

Disposal of hazardous waste i.e. H/F containers etc. will continue as is current practice. These

containers shall be placed in clear plastic bag when empty; the bags are then sealed and

taken directly to the hazardous waste bin for safe disposal. Under no circumstance must the

cleaning of these containers be attempted.

16. Temporary Waste Storage Areas

Each site shall have waste storage bay/s, consisting of:

A cement slab for the temporary storage of general waste skips. Hazardous waste skips will be

fitted with a bund wall or an oil trap, which is designed to contain any spillage (except for the

hazardous waste storage area at the PMR where potential spillages and storm water is

contained in a closed system).


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Standardized signs will be displayed and will be visible. Waste containers will be labeled and

colour coded as per PD_OPG_076 - Waste Signage PMR, PD_OPG_023 - Waste Signage

Marikana.

Spill kits must be available at all areas where HAZMAT is stored or handled; if spills occur they

must be cleaned up immediately by following the Spill Procedure – PD_ENV_003. All storage

areas must be kept clean, neat and tidy.

All waste is to be sorted correctly according to the waste signage displayed.

Waste may not be burnt, except at an incinerator permitted to accept such waste.

Hazardous waste storage facility must have impermeable and chemical resistant floors (Only

applicable to Smelter).

Waste storage facilities must have a drainage and containment system to collect and store all

runoff water arising from the storage facility in the event of a flood. The system must maintain

a freeboard of 0.5m. All plant areas and waste storage areas at the Process Division drain into

a storm water dam / system, where the freeboard is monitored on a regular basis (Only

applicable to Smelter)

Waste storage facilities must have effective access control. Access to the plant areas is

controlled by security and fencing / walls.

Legible, durable, weatherproof signs in at least 3 official languages applicable in the area must

be displayed at each entrance to the facility (Only Applicable to the Smelter/BMR Complex).

The signs must include the following:

o Risks involved in entering the site

o Hours of operation

o The name

o Address

o Telephone number

o The person responsible for the operation of the facility

All Lonmin Employees have access to the hazardous waste storage facility as they have

been trained in emergency response procedures.

Waste storage facilities must be free from odour or emissions

Waste storage facility must be operated within its design capacity and the waste storage

container must not be overfilled.


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Waste that is spilled or blown by wind during opening, handling or storage must be

contained.

Hazardous waste skips must be closed at all times except when waste is added or emptied

Any container or storage impoundment holding waste must be labeled, or where labeling is

not possible, records must be kept, reflecting the following:

o Date on which waste was first placed in the container

o Date of which waste was placed in the container for the last time when the

container was filled, closed, sealed or covered.

o Dates when, and quantities of, waste added and waste removed from

containers or storage impoundments

o The specific category or categories of waste in the container or storage

impoundment as identified in terms of the National Waste Information

Regulations 2012.

16.1 New Waste Storage Facilities (Only Applicable to Smelter)

A new waste storage facility must be registered with the competent authority within 90 days

prior to construction taking place

The following must be taken into account for the location of a new waste storage facility:

o Public health and environmental protection

o Located in a manner that can provide optimum handling and transportation of waste

material

o Hazardous waste facilities must take into consideration the flammability and toxicity of

waste stored

o Areas must be accessible by emergency response personnel and equipment

Construction and development of the waste storage facility must be carried out under the

supervision of a registered professional engineer and must be in accordance with the

approved civil engineering designs.

16.2 Decommissioning of a waste storage facility (Only Applicable to Smelter)

When a waste storage site is discontinued, the site must be rehabilitated to the satisfaction of

the relevant authority

A rehabilitation plan as well as the end use of the area must be submitted to the DEA for

approval not more than 1 year prior to the intended closure of the facility.


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16.3 Storage of Liquid Hazardous Waste

Hazardous waste storage facility (as per the definition in the National Norms and Standards for the

storage of waste) is only applicable to the PMR, however a Waste License was obtained for this

facility prior to the promulgation of the Norms and Standards, therefore this facility will be assessed

against the permit conditions until the License has expired.

17. Littering and dumping

No person may litter or cause the littering of waste

Littering includes:

o Throwing, dropping or discarding of litter onto any place other than a place or

container that has been specifically provided for that purpose

o Sweeping of waste into an area other than a waste container

o Removing litter from a container and causing the litter to be spilled.

Dumping

o No person may abandon anything at a place not designated for waste disposal

o A person who abandons anything at a place not designated for waste disposal will be

liable to a fine or imprisonment.

o Waste may not be dumped / deposited upon any land (other than licensed landfill

sites registered for the disposal of the particular waste type), sewer, storm water,

drainage system or watercourse.

18. Landfill Facilities

18.1 Landfill Site Facility (General Wastes)

Marikana Operations’ general waste will be disposed of at the Mooinooi landfill site and the

PMR’s general waste will be disposed of at the Weltenvreden landfill site. Rietfontein Landfill

site will be used for general waste disposal by both areas on occasion, when required.


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18.2 Landfill Site Facility (Hazardous Wastes)

Rosslyn, Holfontein or Rietfontein (FG) landfill sites will be utilised for the disposal of

hazardous wastes. The site selection will be based on the classification of the waste to be

disposed. High hazard wastes will be disposed of at the Holfontein landfill while low hazard

and de-listed wastes will be disposed of at the Holfontein Landfill, Rietfontein (FG) or

Olifantsfontein waste disposal facilities respectively.

Lonmin Plc. (Eastern Platinum Limited, Western Platinum Limited and Western Platinum Refinery)

are registered hazardous waste generators. The transportation of waste will comply with the South

African National Standard – SANS 10228: 2012.


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19. Waste Collection / Transportation

All general and hazardous wastes to be collected by the relevant waste contractor.

Salvageable items to be collected within 1-2 days by the salvage yard after a SAP notification

has been generated by the relevant area where the items need to be collected. The relevant

waste contractor is to ensure that the collection rate is adequate to prevent the containers

from overflowing and subsequent littering (applicable to Marikana). Waste Manifest

Documents will be issued to all business units where waste collection has taken place by

both hazardous waste contractor, the general waste contractor, and any recycling contractor

(applicable to Concentrators).

All medical waste is to be collected as per agreement. Records of waste collected, by whom,

when and quantities should be documented. Waste is to be collected when required. Refer

to the waste inventory for waste classifications and disposal methods.

Any waste that is accidentally spilled during transportation must be retrieved or cleaned up

promptly.

No person will operate as a waste removal contractor unless written authority has been

obtained from the Municipality (Applicable to Marikana).

The PMR are required to obtain permission from the Council (Ekurhuleni) to make use of

private companies to remove business, domestic waste, industrial and trade waste. The

Council shall determine the type and frequency of such a service and permission shall be

given thereof.

Private contractors removing waste from the PMR premises shall register with the Council.

Hazardous, medical or infectious refuse may only be transported in accordance with the

requirements of the Council (type of vehicle, markings, safety procedures, hygiene, and

documentation).


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20. Hazardous Waste Classification (According To SANS 10228):

Hazardous waste will be classified by means of the SANS10228 requirements, as indicated

below. The hazardous waste service provider will classify the hazardous waste generated on

site by means of sampling and analysis. The waste class will be indicated on the safe

disposal certificate as well as in the waste inventory for the site/s. The following hazardous

classifications will be used (as per SANS10228)

Class 1: explosives

Class 2: gases

This class is subdivided as follows:

a) division 2.1: flammable gasses;

b) division 2.2: non-flammable, non-toxic gasses; and

c) division 2.3: toxic gasses.

Class 3: flammable liquids

Class 4: flammable solids; substances liable to spontaneous combustion;

substances that, on contact with water, emit flammable gases


a) division 4.1: flammable solids, self-reactive substances and solid desensitized explosives;

b) division 4.2: substances liable to spontaneous combustion; and

c) division 4.3: substances that, on contact with water, emit flammable gases

Class 5: oxidizing substances and organic peroxides


a) division 5.1: oxidizing substances; and

b) division 5.2: organic peroxides

Class 6: toxic and infectious substances


a) division 6.1: toxic substances; and


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b) division 6.2: infectious substances

Class 7: radioactive material

Class 8: corrosives

Class 9: miscellaneous dangerous substances and goods

Disposal Method

AB 1:1 - Ash blend ratio 1:1

AB 10:1 - Ash blend ratio 10:1

TWA 1:1 - Trench with ash ratio 1:1

TWSS + S - Treat with Sodium sulphate and sulfur

T + CI - Trench and cover immediately

TWL - Trench with lime

TWFS + L - Trench with ferrous sulphate and lime

The waste inventory is stored on the Lonmin network for each site and indicates the various

waste streams generated by the Process Division as well as the classifications and

disposal/re-use/recycling methodology.

*Waste Classifications will be conducted according to GNR 634 Waste Classification and

Management Regulations as well as GNR 635 National Norms and Standards for the Assessment of

Waste for Landfill Disposal Regulations of the National Environmental Management: Waste Act, No

59 of 2008) by August 2016.

21. Record Keeping

21.1 Hazardous Waste

At the end of each month, the responsible hazardous waste removal contractor and the

relevant responsible person at Lonmin will check the safe disposal certificates against the

waste manifest documents to ensure Lonmin has received a safe disposal certificate for each


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manifest generated. This is done prior to billing for hazardous waste removed from site. Safe

disposal certificates are stored with the responsible persons on site or on the Lonmin network.

Waste Manifest Documents:

Waste manifest documents must be completed for each consignment containing

hazardous waste.

Provide the information to the generator before the waste is transported from the

premises of the generator

Provide the information to the waste manager at the time of delivery of the waste to the

facility for a waste management activity.

Waste Manifest Documents should comply with Annexure 2: Waste Manifest System Information

Requirements of GN 634 Waste Classification and Management Regulations of the National

Environmental Management: Waste Act No. 59 of 2008.

21.2 Landfill Site / General Waste

The following records are to be maintained by the general waste contractor at the Mooinooi Landfill

site (only applicable to Marikana):

All waste entering into the site, in terms of quantity, and origin of waste. Copies maintained

with Group Environment.

Applicable to the PMR: The PMR general waste weighbridge tickets are consolidated on a monthly

basis. Private waste contractors are to submit proof of safe disposal at an approved landfill site to

the Council on a monthly basis.

Waste generators must keep accurate and up to date records of the management of the waste they

generate. Records must reflect:


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Classification of wastes (refer to the Waste Inventories)

Quantity of each waste generated (tons or m3 per month) – Monthly Environmental

Summaries

Quantities of each waste that has either been re-used, recycled, recovered, treated or

disposed of – Monthly Environmental Summaries

By whom the waste was managed – Safe Disposals / Manifest Documents

Records are to be maintained by waste generators, transporters and managers for a period of 5

Years and make the documentation available to the Department upon request.

22. Waste Information Systems

The Waste Manager at Group Environment is responsible for uploading waste information onto the

South African Waste Information System.

23. Waste Activities Triggering Environmental Authorizations:

Should you wish to undertake any one or combination of the following activities, the Management of

Change Process must be followed and depending on the criteria an environmental authorization

obtained before such an activity may commence.

I. Recycling and recovery of waste (General and Hazardous Waste)

II. Treatment of Waste (General and Hazardous Waste)

III. Construction, expansion or decommissioning of facilities and associated structures and

infrastructure for I and II.

24. Training

Training must be provided continuously to all employees working with waste and to all

contract workers what might be exposed to the waste

Training records will be kept by the Training Department.


PD_ENV_001 19 2017/03/24 24 of 28


25. Emergency Preparedness Plan

The emergency preparedness plan for the waste storage facilities will be dealt with as per

PD_SHEQ_SYS_011 - Emergency Preparedness and Response.

26. Monitoring and Inspection (Only Applicable to Smelter)

Containers, tanks, valves and piping containing hazardous waste must be inspected for

leaks, structural integrity and any sign of deterioration on a weekly basis.

Impermeability of the bund wall and the bund wall floor of a hazardous waste storage facility

is to be inspected once per annum.

The secondary containment system must be examined at least weekly or after each

significant precipitation event to ensure that the containment is free of debris, rainwater and

other materials that would compromise the capacity and integrity of the system.

Inspection must include the review of the adequacy and accessibility of spill response

equipment

If environmental pollution is suspected or is occurring from the waste storage facility, an

investigation must be initiated into the cause of the problem or suspected problem and

remedial action taken. This will be dealt with as per the PD_SHEQ_SYS_014 - Non

Conformity Corrective and Preventive Action.

27. Auditing (Only Applicable to Smelter)

Internal audits will be conducted bi-annually and an official report must be compiled to

report the findings of the audits. These audit reports will be made available to the

external auditor.

External audits will be undertaken by an independent external auditor appointed to

audit the waste storage facility. These audits will take place every two years. The audit

report will be submitted to the relevant authority within 30 days from the date on which

the external auditor finalized the audit.

RECORDS

Refer to PD_SHEQ_SYS_013 - Control of records procedure for records applicable to this

procedure


PD_ENV_001 19 2017/03/24 26 of 28


FLOW CHART

Hazardous Waste Removal and Record Keeping Process Flow

Waste identification: Lonmin supervisor notifies the service provider of the waste to be collected

Waste assessment & sampling: has waste previously been classified?

Datasheet capturing: Service Provider captures information and submits to the laboratory

Datasheet number and results: Datasheet number is issued for the specific waste stream. After analysis has been conducted a datasheet is sent to service provider (datasheet available for 6 months)

Quotation & order: Quotation is received by Lonmin from Service Provider for disposal of waste. Order is generated by Lonmin.

Manifest: Manifest document is generated. Single Page Perforated Manifest/Safe Disposal 1.Signed by waste generator & transporter

2.Signed and kept by treatment/disposal Facility (Holftontein)

3.Client invoice copy

4.Administration

5.Sent back to waste generator (serves as a safe disposal certificate)

Safe disposal certificates are sent to Lonmin. Safe Disposal Certificates are distributed by the waste contractor to the relevant waste generators. Shared Services confirm volume removed and volume disposed No

Monthly reporting: Monthly volume report sent to generator monthly

No

Yes


PD_ENV_001 19 2017/03/24 27 of 28


REFERENCES

REFERRING DOCUMENTS

AUTHOR TITLE

Dig ilex Green gain Legal register

HSA Government The Hazardous Substances Act, 1973 (Act 15 of 1973)

OHSA Government The Occupational Health and Safety Act, (OHS Act), 1993 (Act 85 of 1993) and regulations

ECA Government The Environment Conservation Act, 1989 (Act 73 of 1989), and regulations

NWA Government The National Water Act, 1956 (Act 54 of 1956), and regulations

EA Government Explosives Act, 1956 (Act No 26 of 1956)

NEMA Government The National Environmental Management Act:(Act 107 of 1998)

NEMAWA Government The National Environmental Management: Waste Act 59 0f 2008

NRTA Government National Road Traffic Act (Act No. 93 of 1996)

SANS10228 South African National Standards

The identification and classification of dangerous goods for transport

PD_OPG_023 SHEQ Waste Signage Marikana

PD_OPG_076 SHEQ Waste Signage PMR

PD_OPG_051 SHEQ Handling of Explosive Wastes

PD_ENV_003 Environmental Specialist

Spill Procedure

Waste Management By-Law

Rustenburg Local Municipality

Rustenburg Local Municipality Waste Management By-Law

Waste Management By-Law

Madibeng Local Municipality

Madibeng Local Municipality Waste Management By-Law

Waste Classification and Management Regulations

Department of Environmental Affairs

GNR 634 Waste Classification and Management Regulations of the National Environmental Management: Waste Act No. 59 of 2008

National Norms and Standards for the Assessment of Waste for Landfill Disposal


GNR 635 National Norms and Standards for the Assessment of Waste for Landfill Disposal of the National Environmental Management: Waste Act No. 59 of 2008

List of Waste Management Activities that have, or are likely to have a detrimental effect on the Environment


No 921 List of Waste Management Activities that have, or are likely to have a detrimental effect on the Environment of the National Environmental Management: Waste Act No. 59 of 2008

Ekurhuleni Metropolitan Ekurhuleni Ekurhuleni Metropolitan Municipality Solid


PD_ENV_001 19 2017/03/24 28 of 28


REFERRING DOCUMENTS

AUTHOR TITLE

Municipality Solid Waste By-Laws

Metropolitan Municipality

Waste By-Laws

Health Care Waste Ekurhuleni Metropolitan Municipality

Ekurhuleni Metropolitan Municipality Health Care Waste

National Norms and Standards for the Storage of Waste


National Norms and Standards for the Storage of Waste of the National Environmental Management: Waste Act No. 59 of 2008

APPENDICES

None

Reference Number PD_OPG_076

Revision Number 03 Date May 2014

Document Title Waste Signage PMR

1

Hazardous waste - Other Examples:

Chemical bags

Chemical containers such as Sodium

Bromate drums and Hydrochloric

bottles

AA batteries

Asbestos

Contaminated building rubble

Hazardous waste – Golden Pond Examples:

Gloves (all types)

Concentrate bags

Filter paper / cloths and filters

Plastic sample bottles

All PPE

Contaminated paper towel

Contaminated mop heads

General waste Examples:

Only clean (uncontaminated) waste

such as –

PVC pipes

Scrap wood

Building rubble




2

Paper waste

Examples:

Office paper

Cardboard boxes

Steel waste

Examples:

Bolts and nuts

Steel off-cuts

Dried out or pressed paint tins

Food waste

Examples:

Leftover food from Canteens




3

Process Glass

Examples:

Process Glass are separated and

transacted to RDD for crushing and

send for Toll Refining –

Glass tubing

Glass sample bottles

Non-Process Glass

Examples:

Glass containers from Kitchen /

Canteens

Cool drink bottles

Recyclables

Examples:

Plastic Cool Drink Bottles / Milk

Containers

Soda Cans




4

Hazardous Liquid Waste

Examples:

Redundant Paint / Thinners

Redundant Industrial / Cooking Oil

Diesel

Fluorescent Tubes

Examples:

Used Fluorescent Tubes

Used Mercury Vapour Lamps

Used Light Bulbs

Medical Waste

Examples:

Contaminated Swabs / Body Tissue /

Sharps / Expired Medicines /

Contaminated Gloves / Bandages /

Medical Waste from applying First

Aid

1

Western Platinum Refinery

Storm Water Management Plan

August 2014

Mandy Jubileus

Environmental Specialist

Lonmin Process Division

2

TABLE OF CONTENTS 1. Introduction .......................................................................................................................... 3

2. Objectives of the storm water management plan ................................................................. 5

3. Technical situation and evaluation ....................................................................................... 9

3.1 Identification of clean and dirty areas ................................................................................ 9

3.2 Existing water management infrastructure ....................................................................... 10

4. Conceptual Design, Review, Changes required and suitability of existing infrastructure .... 13

5. Operational, management and monitoring systems ........................................................... 16

6. Revision of this document .................................................................................................. 17

7. References ........................................................................................................................ 17

LIST OF FIGURES Figure 1.Location of the Western Platinum Refinery ................................................................... 3

Figure 2. Division of Western Platinum Refinery areas into clean and dirty areas. .................... 11

Figure 3. Identification of Clean, Moderately Dirty and Dirty areas as well as flow to receiving

environment .............................................................................................................................. 12

LIST OF TABLES

Table 1. Western Platinum Storm Water Management objectives prior to 2014. ......................... 5

Table 2. Calculations of current storage capacity vs. capacity required to store the 1:50 year

flood event .................................................................................................................................. 7

Table 3. Western Platinum Refinery Objectives post 2014 .......................................................... 8

3

1. Introduction The Western Platinum Refinery is located in Platinum Road, Vulcania, Brakpan Gauteng district

South Africa (Figure 1), approximately 1 km north of the N17 highway. The site lies at an

elevation of approximately 1640 m above mean sea level (ERM, 2008). The area is zoned

heavy industrial with the Refinery surrounded by a number of industrial complexes, informal and

formal residential establishments. The site drains in a south easterly direction towards a

tributary of the Klein Blesbokspruit. This tributary is characteristically a shallow reed and

bulrush-dominated non-perennial stream. The most prominent drainage in the area is the non-

perennial Klein Blesbokspruit which has its source approximately 2 km south east of the site

and drains in an easterly direction before joining the Blesbokspruit at a point roughly 10 km from

the site. The spruit is fed by a number of non-perennial streams which drain the residential

suburbs, agricultural lands and mining areas (ERM, 2008).

Figure 1.Location of the Western Platinum Refinery

The Western Platinum Refinery started operations in 1970, although it was officially opened in

1974, and has been substantially redeveloped in certain areas since then. The storm water

system has been added to and upgraded at various intervals during the life of the facility and is

4

constantly upgraded to comply with ever changing legal requirements and to reduce the impact

on the environment.

The four primary principles of storm water management as set out in DWAF’s Best Practice

Guideline for Storm Water Management (G1) (DWAF, 2006) is as follows:

1. Clean water must be kept clean and routed to a natural watercourse by a stream

separate from the dirty water system while preventing or minimising the risk of spillage of

clean water into the dirty water systems.

2. Dirty water must be collected and contained in a system separate from the clean water

system and the risk of spillage or seepage into the clean water systems must be

minimised.

3. The SWMP must be sustainable over the life cycle of the operation and over different

hydrological cycles and must incorporate principles of risk management.

4. The statutory requirements of various regulatory agencies and the interests of

stakeholders must be considered and incorporated.

These principles form the basis of the Western Platinum Refinery’s Storm Water Management

Plan.

This Storm Water Management Plan is outlined according to DWAF’s Best Practice Guideline

for Storm Water Management (G1) (DWAF, 2006):

Define the objectives of the storm water management plan (SWMP)

Technical situation analysis and evaluation

Conceptual design and review

Assess the suitability of the existing infrastructure

Define the infrastructure changes that are required

Undertake detailed design of all required infrastructure

Define operational, management and monitoring systems and responsibilities

Document the SWMP

Implement, manage and monitor the SWMP

Formally review/ audit the SWMP and systems at regular intervals.

5

2. Objectives of the storm water management plan The objectives of the storm water management plan are set out below, with an action plan to

address these objectives as well as the principles of the Best Practice Guideline.

• Prevent contamination of ground and surface water resources in the regions where we

operate; and

• Reduce our environmental liability

• To monitor and manage potential impacts from our operations

• Identify opportunities to reduce, recycle and reuse water sources

Prior to 2014, the following actions were taken to improve the storm water management system.

Table 1: Western Platinum Storm Water Management objectives prior to 2014

Action No

Action Plan Responsible

Person Review Date

Completion Date

1.

Chemical / Storm Water Contamination Assessment by Service Provider in order to determine source/s of contamination and the extent thereof.

N. Manonyane / P. Thugwana

31/03/2012 18/04/2012

2.

Additional monitoring borehole/s drilled in the vicinity of the old effluent dams to determine the extent of the contaminated ground water plume and for monitoring purposes.

R. Booysen 31/03/2012 18/04/2012

3. Receipt of above-mentioned Contamination Assessment Report.

R. Booysen 30/09/2012 18/10/2012

4.

Existing underground storm water pipelines to be investigated to determine the condition thereof (Phase 1 of Storm Water Upgrade Project).

S. Lengana 31/10/2012 02/11/2012

5.

Production in level 3 areas to report leaks and spillages immediately to prevent water and soil contamination as far possible.

P. Thugwana On-going On-going

6.

Daily inspections conducted by production and engineering personnel on chemical pipelines and leaks repaired as and when it occurs. Planned maintenance in place as preventative measure.

T. Morapedi On-going On-going

7.

Phase 2 of Storm Water Upgrade Project – new underground pipelines installed to capture and route site run-off / spillage to a 60m3 sump where pH and conductivity checks are done before discharge to effluent tanks / municipal storm water system.

S. Lengana 30/09/2013 07/10/2013

8. HAZOP on Storm Water Upgrade project.

G. Henry 31/05/2013 Complete

9. Control Philosophy on the Storm Water Management System.

G. Henry 31/05/2013 Complete

6

10.

Installation of flow meters at the storm water catchment sump on the discharge line to municipal system and D TF, linked to SCADA to enable monthly quantification of overflow into the municipal storm water system.

G. Henry 30/09/2013 08/10/2013

11. Re-introduce quarterly analysis to determine quality of discharged water.

R. Booysen 28/02/2013 04/04/2013

12.

Investigate a suitable inline composite sampler for installation at the municipal discharge point. Introduce monthly analysis in order to monitor the quality of the discharged water.

R. Booysen / G. Henry

31/05/2013 On hold

13. Damaged monitoring borehole at old D TF (BH5) to be repaired.

S. Lengana 31/05/2013 No longer required

14. Ball float to be replaced with an actuator valve on RWB supply to OPM cooling tower to be installed.

B. Similane / N. Manonyane

20/12/2013

(Not necessary) We have installed a mag flow

Meeting legislative requirements

15. Determine whether the storage area can contain a 1 in 50 year flood.

R. Booysen / M. Jubileus

31/01/2014 31/01/2014

16.

Determine the necessity to obtain a Water Use License as per NWA Section 21 (f) for the discharging of water containing waste into a water course from the storm water holding tank overflow. To be discussed with DWA.

R. Booysen / K. Chetty

TBA Cancelled

17.

Determine the necessity to obtain a Water Use License as per NWA Section 21 (f) since not all water run-off is contained on site and could potentially be contaminated. To be discussed with DWA.

R. Booysen / K. Chetty

TBA Cancelled

Meeting Industrial Effluent Discharge Permit conditions

18. Submission of Industrial Effluent Discharge Permit application.

R. Booysen 31/05/2013 10/07/2013

19. Submission on calibration certificates (flow meters).

R. Booysen 31/09/2013 10/07/2013

20. Submitting quarterly water quality results.

R. Booysen 31/03/2013 On-going

Local Municipality Approval

21.

Confirm whether the Storm Water system is in line with the Ekurhuleni Metropolitan Municipality’s engineering standards.

J. Meyer 15/02/2014 15/02/2014

Green Scorpion Inspection

22.

Following the Green Scorpion Inspection during November 2013, storm water discharged from site indicated to be investigated and a plan of action needs to be compiled.

R. Booysen / M. Jubileus

31/03/2014 15/02/2014

The Government Inspectorate visit conducted in November 2013 raised a number of concerns

surrounding the adequacy of the storm water management system, hence the need to revise

7

the storm water management plan. The following information was gathered and new objectives

were set:

During September 2008 ERM submitted a storm water design report. The existing storm water

system design was analysed to identify deficiencies and to evaluate the design compliance with

current legislation. The existing storm water system was analysed based on the design

requirements of the 1:50 year rainfall event and to evaluate the design compliance with GN704

legislation. Although this legislation is only applicable to mining, it was used for the purposes of

this evaluation as a best practice guideline. GN704 stipulates that clean and dirty water systems

must be separated and that one must not spill to the other more than once in 50 years. The

design approach adopted focuses on retaining the “first flush” of rainfall (usually the most

contaminated runoff from site) in a first flush retention dam. Further retention of storm water

on site will depend on the concentrations of contaminants within the storm water following the

first flush. The worst case design approach incorporates a second dam of equal capacity as

the first flush dam, to retain further contaminated discharge, and a final third dam of sufficient

capacity to retain the remainder of the runoff from the 24 hour 1:50 year flood event. Therefore

the first flush dam should be used as a temporary monitoring system to assess the quality and

quantity of the storm water leaving the facility. The total cost for the proposed design was

calculated at R 6 784240-32 (executed in a phased approach).

Table 2 (A & B): Calculations of current storage capacity vs. capacity required to store the 1:50 year flood event

Table 2A: Proposed design as follows:

First flush retention dam 600 m3

Second dam 600 m3

Third dam 4 500 m3

Total 5 700 m3

Table 2B: The current design is as follows:

Total bund & sump (55 m3) capacity 1 000 m3

Tank capacity (acid) 200 m3

Tank capacity (alkaline) 200 m3

Total 1 400 m3

Deficit 4 300 m3

8

The design report was not totally disregarded. During 2010/2011 the corroded concrete

pipelines were replaced with HDPE piping and HDPE welding. During 2013 the 20 m3 holding

tank for site run-off was removed and site run-off is now channelled to old D-Tank Farm (Table

2B). Although improvements were made, clean and dirty water are not separated and the

storage capacity to contain a 1:50 year flood is not adequate. During the investigation of an

uncontrolled discharge incident during December 2013, it was confirmed that the current design

(Table 2B above) is inadequate. In order to prevent future occurrences and to improve on the

overall storm water management on site the need to investigate and implement additional

measures was identified.

Table 3: Western Platinum Refinery Objectives post 2014 Item Description Owner Target Date Status

1.1.

Applying for an Industrial Effluent Discharge

Permit in order to route the run-off to the

municipal sewer system. Billing are then done

on volume and quality of water discharged from

this point.

RB 31/05/14 15/05/14

1.2. Confirm accuracy of measuring devices

(conductivity meter) and unit of measurement. NM 28/03/14 28/03/14

1.3.

Confirmation required in terms of the

Blesbokspruit In-Stream Water Quality

Guideline requirements (e.g. units of measure

and acceptable quality)

RB 28/03/14 20/03/14

1.4.

Audit level 3 area in order to determine sources

of contamination. Action plan to be drawn-up

to address problem areas.

Team 11/04/14 28/05/14

1.5.

Production staff to start taking daily pH

readings of all the level 3 bunds and record.

To be initiated ASAP.

NM Ongoing Ongoing

1.6.

Reuse of condensate which is discharged to

sewer. Project launched, pipes and tank are

required.

BN

Funding

required

FY15

1.7. Investigate suitable technology for storm water

treatment. NM

On hold –

WULA to be

addressed

first

EMP to be

established

following

meeting with

Consultant

1.8. Buckman was requested to investigate

possible treatment solutions. NM 30/09/14

30/09/14 -

Complete

9

1.9.

Water Analysis:

(1) Awaiting feedback from A. Mangaru

regarding the possibility to have water

analysis done on site.

(2) CSIR could possibly be an option.

(3) Discuss quicker turnaround times with

Aquatico.

(4) Find out whether Marikana laboratory

could do water analysis.

AM

NM

RB

MJ

Under

investigation

26/05/14

20/05/14

Not

recommended

26/05/14

20/05/14

Cancelled

1.10.

Discussions with Interwaste should include the

possibility for storm water collections (waste

disposal removal).

NM Under

investigation

High cost

implications –

on hold

1.11.

In order to achieve adequate storage capacity

as per Table 2A above, a project shall be

launched to evaluate and assess

reconstruction of the old dams as storm water

dams.

RB FY16

3. Technical situation and evaluation 3.1 Identification of clean and dirty areas Figure 2 indicates the areas identified as clean, moderately dirty and dirty. The Administration

block (including main Kitchen and Admin Canteen), Car Parks and Security area are classified

as clean. The Main Store, Projects and Rotable Stores, Security Offices, Training Centre,

Training Centre Canteen and Laundry are classified as moderately dirty. The Level 3 plant area

is classified as dirty. The Western Platinum Refinery is currently undergoing further studies

(Table 3, Item 1.4) inside the Level 3 plant area to determine the areas that have the most

significant effect on the quality of the storm water. These areas will be identified and mitigation

measures put in place to prevent contamination from entering the storm water system.

Figure 3 indicates the relationship between the clean, moderately dirty and dirty areas as well

as the flow of water into the receiving environment (in the event of an uncontrolled overflow).

The Klein Blesbokspruit is to the south east of the Western Platinum Refinery.

10

3.2 Existing water management infrastructure

Figure 2 indicates the current storm water flow and drainage from the Western Platinum

Refinery premises. The following areas drain into the storm water drains indicated in Figure 2

below:

Drain 1, 2 and 3: Runoff from MHD, Primary Separation plant and Main Change Houses,

(mostly drain 3).

Drain 4, 5 and 6: Runoff from the Laboratory, area for the new Incinerator, Freight

Centre, PM plant, Ignition (PMD), OPM plant, B/C Tank Farms, Bulk Chemical Storage

and partial Effluent Storage area. Run-off from the Main Stores / Training Centre reports

to drain 6 as well.

Drain 7: Runoff from the Chlorine Bay, Weighbridge and partial Effluent Storage area.

Drain 9: Runoff from the Training Centre Laundry (minor washing taking place), Training

Centre Canteen, Change House and Car Park.

Drain 10: Runoff from Project Store and Car Park in front of Main Stores and Training

Centre buildings.

11

Figure 2: Division of Western Platinum Refinery areas into clean and dirty areas.

12

Figure 3: Identification of Clean, Moderately Dirty and Dirty areas as well as flow to receiving environment

Storm water bund and tanks

13

The Western Platinum Refinery has identified and classified the old effluent dams (between

drains 6 and 7) as contaminated land and is currently waiting on a Remediation Order.

Runoff from drains 1-7 report to a 1000m3 concrete sump where the pH and electrical

conductivity of the water is tested. Runoff from drains 9 and 10 is considered moderately dirty

water and pumped to the effluent storage tanks for disposal to landfill.

The physical characteristics of the storm water management infrastructure are as such:

Storm Water Drains: 525mm and 700mm concrete drains as indicated in Figure 2

(drains 1-10) located inside Level 3 and the Training centre. The majority of these

pipelines were replaced in 2013 (Table 1).

Ekurhuleni storm water system: Located to the south east of the Western Platinum

Refinery. This storm water system transports storm water from upstream and in the

event of an uncontrolled overflow from the Refinery, towards the Klein Blesbokspruit.

Bunded areas: Areas storing chemicals or tanks containing chemicals in Level 3

(indicated as the “Dirty” area in Figure 3) are bunded. These bunded areas require

upgrading as there are signs of corrosion and cracking.

Storm water sump and water quality monitoring equipment: A 1000m3 storm water sump

receives all storm water from the storm water drains in Level 3 (dirty water area) as well

as a portion of storm water from the Training Centre (moderately dirty). The quality of the

water (electrical conductivity and pH) is tested. The water is pumped to the two 200m3

contaminated run-off tanks. From these tanks the contaminated water is pumped to D

Tank Farm for removal by a contractor for disposal to landfill.

The majority of the surface area of the Western Platinum Refinery is covered by paving, cement

or grass, therefore the contribution to erosion is minimised.

4. Conceptual Design, Review, Changes required and suitability of existing infrastructure

ERM (2008) conducted a Storm Water Management assessment on the design of the Storm

Water Management infrastructure in 2008 which highlighted the following issues (ERM, 2008):

14

The existing storm water system design was analysed to identify deficiencies in the system, and

to evaluate the design compliance with current legislation. The existing storm water system was

analysed based on the design requirements of the 1:50 year rainfall event, and to evaluate the

design compliance with current Government Notice 704 (GN704) legislation. The proposed

revised storm water system layout and design was discussed with Lonmin and the system

layout and design was revised to incorporate these comments. Details of the design are

discussed more fully in Section 6.

An analysis and a design check were performed on the existing system to determine the

deficiencies in the current system. The peak flows at each sub-catchment for both storm water

channels and storm water pipes were calculated using the rational runoff modelling program.

This design check was done using the 1:50 year flood event as prescribed by the Red Book

guideline document for industrial areas. The analysis indicated that some of the pipes are

inadequately sized to accommodate the 1:50 year flood event, and the pipes require increased

diameters in order to accommodate the design flows (discussed in more detail in Section 6).

The analysis also indicated that the existing channels can accommodate the 1:50 year flood

event. The existing channels only require upgrading where corrosion has occurred. The design

calculations also indicated that storm water may pond during rainfall events in the area of

manhole MH3 and manhole MH4. This known ponding problem was confirmed by Lonmin’s

PMR staff. GN704 stipulates that clean and dirty water systems must be separated, and that

one must not spill to the other more than once in 50 years.

The PMR facility does not have separate clean and dirty storm water systems, and the

separation of these two systems will require substantial investment from Lonmin to re-engineer

the facility’s bunded areas, dust collection and mitigation measures, road, plant, and building

drainage systems, etc. Therefore the design has assumed the entire facility contains dirty water.

It is good practice to design future upgrades to the facility with the ability to separate dirty water

from the clean water system. The storm water must be treated if required to ensure the

concentrations of contaminants present in the storm water discharge off site complies with the

screening levels for contaminants specified by Ekurhuleni Municipality (included in Annex E).

Best practice storm water management principles advocate the inclusion of treatment of

contaminated storm water before off site discharge because sites should retain their wastes

close to the source rather than discharging to the receiving water body downstream. ERM

understand that Lonmin are currently underway with a water treatment project which should

15

include the ability to treat contaminated storm water stored on site, prior to discharge to the

municipal storm water system. South African legislation requires that the industrial discharge of

storm water off site to the municipal storm water system must occur under the conditions

stipulated in a Water Use License. Therefore a Water Use Licence will be required for the

discharge of storm water off site, and the permit would be issued subject to the facilities storm

water quality meeting the stipulated water quality standards. The application for the Water Use

Licence must be submitted by Lonmin. The application can be supported by the following

documents:

Drawing number PGT421/804/5/2 (Annex B); and

Design analysis results (Annex C).

The following clarifications and assumptions apply to the work performed:

The upgrade to the storm water infrastructure considers the current layout of the

PMR facility only, and does not include future planned upgrades to the facility

(such as the D tank farm relocation, or any projects to control dust generation on

site).

ERM understand that there is currently little control of contaminated dust

generation and dispersion on site, therefore limiting the ability to declare areas of

the site as “clean” storm water areas. Should Lonmin undertake a project in the

future to prevent contaminated dust dispersion on site, this will materially impact

the design of the storm water system (note that the effect of Lonmin undertaking

a dust control project will not render the storm water system ineffective, it will

merely result in the storm water system design being conservative and the

system will process more storm water than would be required).

As indicated in section 2, the Western Platinum Refinery has implemented changes to deal with

some of the issues identified above. The 2014 objectives address the upgrading of the Storm

Water Management infrastructure as the current infrastructure it is not adequate to store the

1:50 year flood event (Table 2B) and is also not compliant to all legal requirements (GN704 and

Section 21 of NWA). Table 3 outlines the actions / objectives in order to get Western Platinum

Refinery to a point where it will achieve both goals.

A number of alternatives (identified in Table 3) are currently being considered such as treatment

of storm water for re-use in the process. Should additional storage for storm water be required

after these studies have been completed, the re-instatement of the old effluent dams for storage

of storm water should be considered. An audit has also been conducted inside Level 3 (dirty

water area) in order to determine possible sources of pollution, which impacts on the quality of

16

the storm water. The outcome of this audit will determine mitigation measures required in order

to isolate these areas from the storm water management system, hence improving on the water

quality of the storm water runoff.

The current infrastructure has proven inadequate to store storm water during extreme rainfall

events such as that of December 2013 and January 2014 where discharge incidents were

reported to the Department of Water Affairs.

The other inadequacy identified is that contaminated areas in Level 3 could be contributing to

events where storm water is not within the specifications of the Klein Blesbokspruit Catchment

guideline. The accuracy of the automatic water quality monitoring system will also be assessed

(pH and electrical conductivity).

Table 2A&B indicates the volumes of storage capacity required versus the capacity required in

order to contain a 1:50 year flood. This calculation indicates a 4300m3 deficit of storm water

storage capacity on site.

Once these studies have been completed, the Western Platinum Refinery will obtain detailed

designs of the required infrastructure.

5. Operational, management and monitoring systems

The existing storm water system is inspected daily for any irregularities such as issues with

pumps, the electronic water quality monitoring system and the level of the storm water sump.

These inspections are conducted by the relevant operational personnel. Quarterly storm water

quality monitoring takes place by a third party consultant in order to determine compliance with

the Klein Blesbokspruit Catchment Guideline. Rainfall monitoring also takes place on site.

Monthly Environmental Officer inspections are conducted to ensure that the storm water

management system complies with legal and ISO14001 standards.

Emergencies are dealt with as per Lonmin’s ISO14001 procedure PD_SHEQ_SYS_011 -

Emergency Preparedness and Response.

Any irregularities reported during these inspections or during emergency events are reported

and tracked as per PD_SHEQ_SYS_014 - Non Conformity Corrective and Preventive Action.

17

6. Revision of this document

Revision of the Storm Water Management Plan should take place at least annually after an

audit of the Storm Water Management Infrastructure has been conducted. This will take place

for the first three years, where after such revision will take place every two years. If significant

changes occur on site, a revision of the SWMP will also be required.

7. References 1. Environmental Resources Management South Africa, 2008. Precious Metals Refinery,

Stormwater System Upgrade – Design Report.

2. Department of Water Affairs and Forestry, 2006. Best Practice Guideline G1 Storm Water

Management

3. Process Division SHEQ Department, 2014. PD_SHEQ_SYS_011 - Emergency

Preparedness and Response.

4. Process Division SHEQ Department, 2014. PD_SHEQ_SYS_014 - Non Conformity

Corrective and Preventive Action.

FY2014 Avg

excl Feb - May 2014

Ounces 99 911 61 057 124 909 79 163 265 128

Electricity Consumption kWh kWhr 1 426 947 1 220 841 1 457 946 1 241 324 3 920 111

Electricity Consumption Efficiency kWh kWhr/oz. 14.3 20.00 11.67 15.68 14.79

SD Target Electricity Efficiency (kWh/oz.) kWhr/oz. 13.1 13.1 13.1 13.1 13.1 13.1 13.1 13.1 13.1 13.1 13.1 13.1 13.1 13.1

Diesel Lt 6054 0 3940 4000 7940

Gasses: Sasol Gas - Natural Gj 3191 2698 3261 2507 8466

Sasol Gas Consumption Efficiency Gj Gj/oz. 0.03 0.04 0.03 0.03 0.03

Gasses: Acetylene Kg 0.00 0.00 0.00 0

Gasses: Oxygen Kg 27 0.00 0.00 27

Gasses: Medical Oxygen Kg 0.00 0.00 0.00 0

Gasses: LPG Kg 0.00 0.00 96.00 96

Gasses: Chlorine Kg 21600 21600 9900 53100

Gasses: Argon Kg 0.00 0.00 0.00 0

Gasses: Nitrogen Kg 0.00 0.00 0.00 0

Gasses: Hydrogen Kg 103 257 217.26 577

Recycling / Re-use

Food Waste Kg 1903 1613 3458 1723 6793

Steel Waste Kg 3625 620 8020 6600 15240

Plastic & Paper to Service Provider Kg 408 600 340 760 1700

Glass Kg 0 0 0 0 0

Drums Returned to Supplier - Recycling Kg 0 115 0 115

Hazardous - PGM Waste to Golden Pond Kg 1255 2668 1449 0 4117

Used Oil Recycled Kg 0 0 0 0 0

Hazardous - Effluent Waste Treated/Recycled Kl 333 306 269 907

Disposal to Landfill

General Waste to Landfill Kg 2680 3200 3860 9740

General Building Rubble to Landfill Kg 5180 18780 7820 31780

Garden Waste Kg 545 640 620 460 1720

Hazardous - Medical Waste Kg 13 0 0 25 25

Hazardous - Fluorescent Tubes Kg 424 0 0 0 0

Hazardous - Redundant Chemicals to Landfill Tons 0 0 0 0

Hazardous - Other Liquids

(contaminated oil/diesel/paints to landfill)Lt 0 0 2940 2940

Hazardous - Solid Waste to Landfill Tons 1.05 0 2.10 3

Hazardous - Effluent Waste Removed (total) Kl 1912 2464 2551 6927

Hazardous - Effluent to Landfill Kl 1473 1579 2158 2283 6020

Storm Water Kl 438 1095 919 2452

Disposed Hazardous Liquid Waste EfficiencyKl/Ounce

Produced0.01 0.03 0.02 0.03 0.02

SD Target Efficiency (Hazardous Liquid Waste to

Landfill)

Kl/Ounce

Produced0.28 0.28 0.28 0.28 0.28 0.28 0.28 0.28 0.28 0.28 0.28 0.28 0.28 0.28

Rainfall mm 64 71 92 105 268

Condensate to Sewer Kl 686 604 648 449 1701

Rand Water Board Consumed Kl 3649 3653 3793 2725 10171

Rand Water Board Consumed Efficiency Kl/Tons 0.04 0.06 0.03 0.03 0.04

SD Target Efficiency (Rand Water Board) Kl/Tons 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05

FY2015Dec-14 Feb-15 May-15Apr-15Jan-15

WA

TE

R

Unit Oct-14 Nov-14

WA

ST

EE

NE

RG

Y

Ounces Produced

Sep-15

Process Division - Environmental Monitoring & Measurement

PMR

Jun-15 Jul-15 Aug-15Mar-15

Date post:	30-Jul-2018
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