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TRIGEN GROUP (PTY) LTD FINAL ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED ADAPTATION OF AN EFFLUENT WASTE-TO-VALUE PLANT AT THE RCL FOODS FACILITY, MCALISTER ROAD, WORCESTER March 2018 SEC Reference number: 0151011 To be read together with the EMPr authorised in terms of Environmental Authorisation reference number 16/3/3/1/B2/32/1010/15, dated 6th January 2016. PO Box 30134, Tokai, 7966 Telephone: 021 712 5060, Fax: 021 712 5061 Email: [email protected]
Transcript
Page 1: TRIGEN GROUP (PTY) LTD FINAL ENVIRONMENTAL … · Please refer to EAP Curriculum Vitae’s contained in Appendix F. 2. INTRODUCTION 1.1 Project Description Introduction The development

TRIGEN GROUP (PTY) LTD

FINAL ENVIRONMENTAL MANAGEMENT PROGRAMME FOR THE PROPOSED ADAPTATION OF AN EFFLUENT WASTE-TO-VALUE PLANT AT THE RCL FOODS FACILITY, MCALISTER ROAD,

WORCESTER

March 2018

SEC Reference number: 0151011

To be read together with the EMPr authorised in terms of Environmental Authorisation reference number 16/3/3/1/B2/32/1010/15, dated 6th January 2016.

PO Box 30134, Tokai, 7966

Telephone: 021 712 5060, Fax: 021 712 5061 Email: [email protected]

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TABLE OF CONTENTS

1. DETAIL AND EXPERIENCE OF THE EAP WHO PREPARED THE EMPR ................................................................ 4

2. INTRODUCTION..................................................................................................................................................................... 4

1.1 PROJECT DESCRIPTION......................................................................................................................................................... 4

3. STATUTORY OBLIGATIONS ............................................................................................................................................ 10

4. OBJECTIVES, TARGETS AND MEASURES .................................................................................................................... 10

4.1. DESIGN PHASE IMPACTS ............................................................................................................................................ 11 4.1.1. Groundwater and Stormwater System Contamination .............................................................................................. 11 4.1.2. Fire, Health and Safety Risk ..................................................................................................................................... 12 4.1.3. Health and Safety Risks and Nuisance Odours – Emissions from Manure Transport and Storage and Digestate

Handling 13 4.1.4. Health Risks due to Pests .......................................................................................................................................... 16

4.2. PRE-CONSTRUCTION PHASE IMPACTS .................................................................................................................... 16 4.2.1. Bulk Services Identification ....................................................................................................................................... 16 4.2.2. Permits ...................................................................................................................................................................... 17 4.2.3. Training..................................................................................................................................................................... 17 4.2.4. Construction phase site layout .................................................................................................................................. 17 4.2.5. Working Hours .......................................................................................................................................................... 17

4.3. CONSTRUCTION PHASE IMPACTS ............................................................................................................................ 17 4.3.1. Social Considerations ............................................................................................................................................... 18 4.3.2. Appropriate Machinery ............................................................................................................................................. 18 4.3.3. Waste Management ................................................................................................................................................... 18 4.3.4. Storm water ............................................................................................................................................................... 19 4.3.5. Fire Safety ................................................................................................................................................................. 20 4.3.6. Safety and First Aid ................................................................................................................................................... 20 4.3.7. Air Quality ................................................................................................................................................................ 20 4.3.8. Water Quality ............................................................................................................................................................ 20 4.3.9. Noise and Vibration .................................................................................................................................................. 21 4.3.10. Light Pollution .......................................................................................................................................................... 21 4.3.11. Traffic Control .......................................................................................................................................................... 21

4.4. OPERATIONAL PHASE MITIGATION MEASURES ................................................................................................... 22 4.4.1. Fire, Health and Safety Risk ..................................................................................................................................... 22 4.4.2. Groundwater and stormwater system contamination................................................................................................ 23 4.4.3. Nuisance Impacts on Neighbours .............................................................................................................................. 24 4.4.4. Hygiene ..................................................................................................................................................................... 24 4.4.5. Additional design, management and mitigation measures to prevent failure of the system and minimise all impacts

24 4.5. DECOMMISSIONING PHASE IMPACTS ..................................................................................................................... 26

5. IMPLEMENTATION OF THE EMP ................................................................................................................................... 26

5.1. ROLES AND RESPONSIBILITIES, INCLUDING MONITORING, AUDITING AND REPORTING ..................................................... 26 5.2. DOCUMENTATION AND RECORD KEEPING ......................................................................................................................... 27 5.3. ENVIRONMENTAL AWARENESS AND TRAINING ................................................................................................................. 28 5.4. MATTERS PERTAINING TO NON-CONFORMANCE ONSITE ................................................................................................... 29

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- 3 - List of Annexures

Annexure A Glossary

Annexure B Possible Method Statement Template

Annexure C Role of the Environmental Control Officer (ECO)

Annexure D 1) Site Layout Plan (see Appendix B of BAR. Will be inserted into EMP for final approval)

Annexure E 1) Incident Register and Basic Accident Register Templates 2) Complaints Register Template

Annexure F Curriculum Vitae’s of EAP’s

Annexure G 1) Emergency Response Plan (for effluent Biodigester. To be updated for the manure Biodigester prior to plant commissioning)

2) Draft Pest Control Plan (see Appendix G of BAR. Will be inserted into EMP for final approval) 3) Stormwater Management Plan (see Appendix G of BAR. Will be inserted into EMP for final

approval) 4) Daily Equipment and Infrastructure Inspection Schedule – to be compiled prior to plant

commissioning 5) Plant Preventative Maintenance Plan– to be compiled prior to plant commissioning

IMPORTANT NOTE: ALL READERS TO PLEASE FAMILIARISE THEMSELVES WITH THE RELEVANT TERMINOLOGY

CONTAINED IN THE GLOSSARY (APPENDIX A) PRIOR TO READING THIS DOCUMENT.

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1. DETAIL AND EXPERIENCE OF THE EAP WHO PREPARED THE EMPR

Sillito Environmental Consulting (SEC) has been appointed as the independent Environmental Assessment Practitioner (EAP) to apply for a Waste Licence for the proposed adaptation of an effluent Biodigester plant at the RCL Foods chicken processing facility, McAlister Road, Worcester. This report was prepared by Colleen McCreadie of SEC, and reviewed by Adrian Sillito. Adrian Sillito is a certified environmental assessment practitioner (CEAPSA), Professional Natural Scientist (Pr.Sci.Nat.) and a member of the International Association for Impact Assessment (IAIA). Adrian has over twenty years’ experience in the field of environmental management and impact assessment. Colleen has an Economics Honours degree from UCT and has ten years’ experience in environmental management and impact assessment. She is also a member of IAIA. Please refer to EAP Curriculum Vitae’s contained in Appendix F.

2. INTRODUCTION 1.1 Project Description Introduction The development proposal is for the adaptation of an existing waste-to-value plant, which is situated at the RCL Foods chicken processing plant on Erf 4396, McAlister Road, Worcester Industria. Currently, the waste-to-value plant generates biogas through a process of anaerobic digestion of the effluent sourced from the chicken processing plant. The biogas is then burnt to generate electricity for use by the RCL plant, and the treated effluent is discharged to municipal sewer. This EMPr is therefore to be read together with the EMPr authorised in terms of Environmental Authorisation reference number 16/3/3/1/B2/32/1010/15, dated 6

th January 2016.

Figure 1. Site Locality

Expanded Biodigester footprint

RCL Foods site

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- 5 - It is now proposed to include animal manure from nearby RCL Foods poultry farms and other farms as a feedstock for the waste-to-value plant. This will entail the installation of additional digester tanks and associated infrastructure. The design of the adapted waste-to-value plant will allow for up to 10MW of electricity to be generated, which is expected to power a large majority of the RCL Foods processing facility, including the waste-to-value plant itself. This is an expansion from the approximately 1.5MW currently generated by the effluent digestion plant. Waste heat generated during biogas combustion will also be used to generate steam and hot water for integration back into the processing plant. In addition to this, the manure digestion process generates as a by-product a digestate. The digestate provides a high quality agricultural fertilizer, which will be sold to nearby farms. The development proposal is aimed at valorising waste from RCL activities in the Worcester region, in order to: reduce RCL’s natural resource consumption for power and water purposes; provide a stable source of power and treated water to the RCL plant; and produce a biologically stable, high-quality fertilizer for sale by RCL. Please refer to a detailed process description contained in Appendix J. This includes a description of inputs, outputs, emissions and waste; infrastructure required; potential impacts identified with the process; and recommended mitigation to reduce identified impacts to acceptable levels. A summary of the key elements of the process is included here: Anaerobic digestion process Manure will be blended with dilution water from the downstream digestate dewatering process (see “Digestate” below) and added to digestion tanks. The manure digestion tanks are designed to maximise the conversion of the organic matter in the waste through various exothermic reactions to energy-rich biogas for conversion into useful energy. The digestion process will take some 55 days. The manure digesters will have the capacity to convert up to 100 ton per day of manure feedstock. A digestate will be produced as a product of the waste digestion process. This digestate is suitable for use as an agricultural fertilizer. Biogas combustion process The Biodigester will have the capacity to produce approximately 2000m

3/hour of biogas

1, comprising 50-75%

methane; 25-50% carbon dioxide; 0-10% nitrogen; 0-1% hydrogen; 0-3% hydrogen sulphide; and 0-2% oxygen. Compounds in the biogas can cause corrosion and precipitation leading to premature equipment failure. The biogas will be conditioned in a gas treatment unit that employs a process of cooling and filtering to remove these problematic compounds prior to combustion. The biogas will be combusted in combined heat and power engines (CHP’s), which have the capacity to combust all of the biogas produced by the digesters. The electricity produced – up to 10MW - is expected to be sufficient to power the majority of the RCL plant. The waste heat produced will supplement some of the coal energy supply currently used at the coal fired boilers on the site. The plant is anticipated at this stage to include at least five CHP engines. Digestate The biodigestion process will produce approximately 80 tonnes per day of digestate as a by-product. The digestate is biologically stable, resisting further breakdown under normal storage conditions. The digestate comprises about 30% solids and 70% moisture. The digestate is free of pathogens and is a high quality agricultural fertilizer. The digestate will be sold to agricultural users. Digestate exiting the digester tanks will be dewatered using decanter centrifuges. The digestate will be stored in a weatherproof unit for controlled storage and loading. The liquid fraction from the dewatering process will be treated and returned as dilution water to the manure digestion process. Manure and digestate transport and conveyance

1 The biogas is continuously piped to the CHP engine so that at any one time, only up to 500m

3 of storage capacity for the biogas

is required.

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- 6 - The manure and digestate (fertilizer) will be transported to and from site in fully enclosed, moving-floor trucks. These deliveries will take place daily. Manure will be offloaded in a dedicated storage unit. Digestate will be loaded at a dedicated area of the plant. In terms of conveyance of manure and digestate within the plant, this all takes place within a closed system: all pipelines, conveyer belts, screw presses, etc. are enclosed. Water recovery process An additional adaptation to the current waste-to-value plant is the installation of a water recovery plant. A portion of the treated effluent discharged from the effluent digesters (i.e. RCL effluent) will be used to feed the water recovery plant. This plant will treat the treated effluent using a specialised Reverse Osmosis (RO) membrane system designed for high fouling applications. The feed will be separated into a high quality permeate stream and high strength brine stream. The brine, about 200m3/day, will be blended into the remaining final effluent discharged to municipal sewer. The RO plant will consist of the following steps: gravity settling, sand filtration, cartridge filtration and RO. The process will take place in a series of bulk tanks. Recovered water produced will be returned to the factory to reuse at suitable points and applications (filling cooling towers, boilers, cleaning of exterior working areas and crate washing). This represents a reduction in the quantity of effluent currently being discharged to municipal sewer; as well as a reduction in water usage at the chicken processing plant. Infrastructure Infrastructure required will be as follows:

1) Digestion tanks for the anaerobic digestion of the manure to produce biogas 2) An enclosed, purpose-designed structure for the offloading and storage of the manure for up to three days.

The unit will include a receiving bay in which the doors will only be opened during a manure delivery. 3) The manure storage structure will operate under negative pressure, with air extracted to a filtration system for

removing odorous emissions prior to exhausting to atmosphere. 4) The filtration system will be a two-stage chemical scrubber aimed at scrubbing ammonia and hydrogen

sulphide from the air exhausting from the storage unit. 5) Decanter centrifuges for dewatering the digestate. 6) An ammonia stripper (heat exchangers and ammonia scrubber), for stripping ammonia from the liquid fraction

of the digestate. 7) A weatherproof unit for the controlled storage and loading of digestate. 8) A gas train comprising desulphurisation, dehumidification and pressure upgrading stages. 9) At least five Combined Heat and Power (CHP) engines. 10) A series of tanks for water recovery – for gravity settling, filtration, RO and treated water storage prior to return

to the RCL plant. 11) Pipelines for the conveyance of manure; digestate; treated effluent; hot water; processed water; biogas and

steam. 12) Distribution lines for electricity.

There will be no need for additional connections to the municipal water or electricity supply network; or to the municipal sewerage or stormwater systems. The plant will utilise the existing site access off McAlister Street, with the traffic generated by the delivery of manure expected to be up to 5 trucks per day, i.e. a negligible increase in traffic given activities taking place in the surrounding industrial area. It is expected that these same delivery trucks once empty will be loaded with the dried digestate to transport the fertilizer to agricultural users. In terms of standby electricity, the plant will draw power from RCL’s electricity mains only during ramp up and until adequate electricity has been generated by the Biodigester to start the CHP engines. This will entail about 400kW over a period of about two weeks. Also, in the unlikely event of substantial maintenance, where the plant would need to be recommissioned, RCL mains electricity will be used. Waste and effluent disposal and discharge Waste: the manure is conveyed from the storage structure in a closed system to a blending tank, where effluent is added. This floats out the bedding material present in the manure, and settles out the grit (soil), which are unwanted in the Biodigesters. The optimised manure mixture is then conveyed to the Biodigesters. The bedding material is conveyed to the digestate tank via a screw press for dewatering purposes. The grit is discharged to a covered skip, which is emptied periodically and the grit disposed of to landfill.

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- 7 - There is no other waste associated with the Biodigester plant. Effluent: A portion of the outflow from the effluent Biodigester (i.e. treated RCL effluent), which is currently all discharged to the municipal sewerage system, will be diverted to the RO plant. The high strength brine stream from the RO process (about 200m

3/day) will be blended into the remaining effluent stream discharged to sewer. The treated

water from the RO plant will be utilised in the boilers, cooling towers, to wash crates, etc. The RO plant therefore represents a nett reduction in effluent outflows to the municipal system. With regards to spent scrubber solution from the emissions scrubbers, this will also be blended into the remaining effluent stream that discharges to sewer. The volumes are very small (<4m

3/day). Any change in the composition of

the effluent being discharged, will be reflected in an amendment of the RCL plant’s effluent discharge permit, if required

2.

2 The applicant is investigating valorising the spent scrubber solution, ammonium sulphate, for sale to the agricultural industry.

Ammonium sulphate is a valuable fertilizer.

Page 8: TRIGEN GROUP (PTY) LTD FINAL ENVIRONMENTAL … · Please refer to EAP Curriculum Vitae’s contained in Appendix F. 2. INTRODUCTION 1.1 Project Description Introduction The development

- 8 - Figure 2, Process Flow Diagram

Manure transport

Manure offloading

Manure storage

Manure &

effluent blending

Odorous emissions scrubbing

Waste management

(grit skip)

Landfill

Biogas scrubbing

Biogas flaring (safety and emergency)

CHP’s (biogas combustion

for electricity generation)

RCL plant and Biodigester

plant

Effluent discharge to

sewer

Digestate dewatering

Digestate loading

Digestate transport

Farms

Digestate liquid

fraction treatment

10

11

2

3

4

1 1 1 8

12

12

11

3

7

7

Trigen Worcester Waste-to-Value Plant: Key Process Steps

9

Manure digestion

Reverse osmosisRCL effluent digestion 5 RCL plant 6

13

7

Digestate storage

7

Key:

1) Manure 2) Manure (corrected consistency) 3) Biogas 4) Electricity 5) Treated effluent 6) Recovered water 7) Digestate 8) Digestate liquid fraction 9) Treated digestate liquid fraction 10) Odorous emissions 11) Waste (grit) 12) Spent scrubber solution

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- 9 - 13) RO brine

______ Key process steps ______Waste / unwanted / discarded ______Treatment of emissions / effluent / digestate liquid fraction ______Contingency / safety / emergency

2.1. Aspects Covered by this EMP The development proposal entails the construction and operation of additional Biodigesters and associated infrastructure as described above. The potentially significant impacts identified during the EIA process as being associated with the facility are as follows: Construction and decommissioning phases:

1) Natural stormwater drainage channel contamination from contaminated liquid surface spillages 2) Dust 3) Traffic and access 4) Fire, health and safety risk 5) Noise

Operational phase:

1) Groundwater and stormwater system contamination 2) Fire, health and safety risk 3) Health and safety risks and impacts on wellbeing from emissions from manure transport and storage and

digestate handling 4) Health risks from pests (flies), which can spread pathogens associated with manure storage and handling

In order to minimise any negative impacts associated with the facility, therefore, it is imperative that the lifecycle of the facility, as well as all aspects of the facility’s development (infrastructure) and operation (processing, storage, and handling) are subject the conditions set out in this EMP. The conditions directly address the identified potential impacts, in order to ensure that the health, safety and environmental risks associated with the plant can be avoided or minimised. 2.2. Map of Environmental Sensitivities Erf 4396, where the effluent digester plant is situated which is proposed for adaptation, is a heavily transformed site which has been used for industrial purposes for decades. There are therefore no sensitive areas on the site which need to be avoided. The site layout plan contained in Appendix D shows the proposed layout of the plant on the site. 2.3. Legal Framework

This Environmental Management Programme (EMP) has been compiled in fulfilment of the requirements of Section 24N of the National Environmental Management Act, Act No. 107 of 1998 (as amended) (NEMA).The contents of this EMP comply with the requirements for EMP’s as contained in Appendix 4 to the 2014 EIA Regulations. The EMP should also adhere to the local authority by-law requirements as well as any other obligatory environmental and other legal requirements (see Section 3 of this EMP). Changes to this Environmental Management Programme can only occur with the written approval of the DEA&DP and an updated version should also be forwarded to all parties once the amended EMP has been approved by the DEA&DP. It is understood that the Trigen Group (Pty) Ltd or any future development entity (where transfer of ownership occurs) will be fully responsible for this EMP and its requirements including any environmental rehabilitation that may be needed. This is required in terms of Section 28 (Duty of Care and Remediation of Damage) of the National Environmental Management Act, (Act No. 107 of 1998), as amended.

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- 10 - 3. STATUTORY OBLIGATIONS The applicant should adhere to any statutory requirements which may be relevant to the lifecycle of the biodigester

facility, contained in:

The National Environmental Management Act, Act 107 of 1998, as amended (NEMA).

National Water Act, Act 36 of 1998, as amended.

National Environmental Management Waste Act, Act 59 of 2008

The National Environmental Management Air Quality Act, Act No. 39 of 2004

All relevant by laws and building regulations of the Breede Valley Local Municipality

All relevant by laws and building regulations of the Cape Winelands District Municipality

Relevant SANS codes

The Operational Health and Safety Act, Act 85 of 1993.

4. OBJECTIVES, TARGETS AND MEASURES A variety of potential impacts are associated with the operation of the biodigestion facility. A number of mitigatory measures are proposed to minimise impacts during the operational phase. It is understood that the applicant, the Trigen Group (Pty) Ltd, is responsible for any environmental rehabilitation as identified. It is understood that the applicant, the Trigen Group (Pty) Ltd, is responsible for the implementation of the recommended impact management measures throughout the lifecycle of the development; as well as being responsible for any environmental rehabilitation as identified.

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- 11 - 4.1. DESIGN PHASE IMPACTS Timeframe for implementation of design phase measures: The design of the development proposal is aimed at minimisation of health, safety and environmental risks associated with the plant. These design-phase measures must therefore be implemented at the earliest stages so that construction works can proceed in line with these measures.

4.1.1. Groundwater and Stormwater System Contamination Objectives: To prevent contamination of groundwater or stormwater as a result of a spillage, tank or line leak and surface runoff of untreated effluent or acids from the nutrient dosing tank farm; or from manure storage on bare soil or uncontrolled rainwater runoff from manure. Targets: To comply with relevant codes of practice and applicable legislation with respect to prevention of pollution of natural resources. Measures: The Biodigester plant must be designed with the following measures in place:

(a) All process tanks and pipework, and the chemical (nutrient dosing) tank farm to be designed and constructed according to the relevant codes of practice, including:

i. API STD 620 – recommended rules for design and construction of low pressure tanks ii. AWWA D103 – design, construction, inspection and testing of factory coated steel bolted

tanks iii. AWWA D100 - design, manufacture and procurement of welded carbon steel tanks iv. BS2594 - specification for carbon steel welded horizontal cylindrical storage tanks v. BS2654 - manufacture of vertical steel welded storage tanks with butt welded shells vi. SANS 1476 - Fabricated flanged steel pipework, pipe and fittingsSANS310 - storage tank

facilities for hazardous chemicals) vii. BS 8007 - design of concrete structures for retaining aqueous liquids viii. SANS 10100 - the structural use of concrete ix. SANS 10162 - the structural use of steel x. SANS 10108 - the classification of hazardous locations and the selection of equipment for

use in such locations xi. SANS 62305 – protection against lightning

(b) Construction joints will be fitted with appropriate waterproof joints.

(c) Control of surface runoff in such a manner that spillages can be contained and so prevent access to the stormwater system. Please see the Stormwater Management Plan contained in Appendix G. The SWMP should be approved by the Breede Gouritz Catchment Management Agency prior to construction commencing.

(d) Leak detection: All pipework will be designed according to relevant SANS codes, and will be aboveground.

(e) Isolation valves at regular points along the system’s pipework will isolate and minimise any leaks.

(f) A daily infrastructure and equipment inspection schedule will be compiled prior to commissioning for inclusion in the EMP.

(g) The nature of the effluent and manure reticulation system through the plant, and of the various buffer and digester tanks, is that leaks will be detected on the pressure gauges and flow instrumentation.

(h) The digestion mix is slurry and therefore off-site migration is not a risk. Prompt localised leak or spill response will be adequate to prevent contamination.

(i) The manure storage unit should be purpose designed to provide adequate containment of the manure –

to prevent contact with soil and to prevent rainfall ingress. Offloading of the manure should take place within the controlled receiving bay of the storage unit.

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(j) The storage unit design is to include reinforced concrete floors.

(k) The hard standing surrounding the manure storage unit will be designed in such a way that rainwater will be diverted away from the unit. Please see the Stormwater Management Plan contained in Appendix G.

(l) Any liquids from the manure storage unit (e.g. wash water) will flow down the sloped floor to a sump within the unit, and from there will be pumped to the Biodigester system

(m) The manure storage facility must be designed, operated and registered in accordance with the requirements of the National Norms and Standards for the Storage of Waste.

(n) In the unlikely event that the rate of delivery of manure to the storage unit exceeds the rate at which the manure is fed to the digester system, deliveries of manure will cease until the unit has adequate capacity to accept more manure.

(o) As best practice and for quality control purposes, the digestate storage area must be designed to avoid

rainwater ingress. This includes a roof, side walls and cladding, and a concrete floor.

4.1.2. Fire, Health and Safety Risk Potential health and safety impacts associated with the risk of fire and explosion are associated with methane gas storage. Associated smoke and disturbance related to with the evacuation of the site and surrounding area; risk to life and property. Objectives: To minimise risk through adequate design and operational measures. Targets: To meet best practice design and operational measures

(a) SANS10108: Classification of hazardous locations and SANS 60079-14: Explosive atmospheres electrical installations design, selection and erection must be adhered to in the design and construction of the plant.

(b) An Emergency Response Plan must be compiled for the plant. This will be developed once the final installation plan has been developed, a HAZOP study has been undertaken and all risk management issues addressed and adopted into the final scheme.

(c) The RCL facility is currently a Major Hazard Installation. Once the manure Biodigester has been

commissioned, the MHI for the plant should be updated. (d) Sufficient & suitable storage of flammables must be provided (e) Sources of ignition must be avoided wherever flammable or highly combustible material is present in the

workplace e.g.: i. Notices prohibiting smoking is displayed and enforced ii. Welding and flame cutting is only allowed under controlled conditions that includes written

hot work permits iii. Only spark-free hand and power tools are used iv. No grinding, cutting and shaping of ferrous metals are allowed using electrically driven

power tools that produces sparks

(f) Flameproof switches & fittings are to be used in the flammable atmosphere

(g) In the event of a breakdown of the CHP engines, there is an emergency flare in place. The biogas is diverted from the CHP engines to the flare.

(h) The biogas flare is designed to combust 150% of the peak biogas flow rate to avoid over pressure in the digester and biogas discharge to atmosphere.

(i) Biogas analysis and pressure monitors, together with automated flow control valves and a slam-shut safety valve, are included in the design to ensure minimal risk associated with flaring.

(j) During plant commissioning and ramp-up, RCL mains electricity will be used.

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- 13 -

4.1.3. Health and Safety Risks and Nuisance Odours – Emissions from Manure Transport and Storage and Digestate Handling

Objectives: To avoid nuisance odorous emissions impacting on people’s wellbeing; and to minimise health and safety risks for workers due to harmful emissions. Targets: To comply with relevant ambient air quality standards and occupational exposure limits for compounds of concern. Measures: 1. Fully enclosed, moving-bed trucks should be used to transport the manure and digestate to and from site.

2. The service contract between the applicant and the logistics provider must stipulate that the provider maintains the

trucks in a sanitary condition.

3. The service contract between the applicant and the logistics provider must stipulate that incidences with the potential for road safety or nuisance impacts, such as a truck overturning, must be responded to promptly. The truck drivers should be trained in emergency response, and the logistics provider must follow an adequate spill clean-up protocol.

4. A purpose designed, fully enclosed manure storage unit is proposed.

5. Manure should be stored for a period of up to 3 days to prevent anaerobic and aerobic breakdown of the manure.

6. All surfaces of the storage unit will be cleaned regularly according to a cleaning schedule and work instruction. This will prevent leftover residue that is older than 3 days.

7. Offloading of the manure should take place within the controlled receiving bay of the storage unit. Receiving bay doors to remain closed except during a manure delivery.

8. The manure storage unit is designed to store triple the daily quantity of manure delivered: 300T storage capacity;

up to 100T daily quantity delivered.

9. There will be 2 storage lanes for redundancy. This allows for 3 days of storage time (i.e. 300T, or 600m3), so that the digester can be fed over weekends. The additional lane can also serve as redundancy if there are mechanical issues, servicing or cleaning requirements.

10. Air flow in the manure storage unit will be designed to create negative pressure to prevent fugitive emissions escaping from the open receiving bay doors.

11. PVC strip curtains will be installed at the receiving bay entrance to assist in retaining fugitive emissions when the receiving bay doors are open.

12. A standard operating procedure must be compiled and adhered to in order to ensure that opening times for the

doors are kept to a minimum. It is noted that the design means that the manure storage area where offloading is to take place is under a negative pressure so air will flow into the storage area rather than out during loading.

13. A preventative maintenance plan for the loading doors must be compiled to ensure that they operate as designed at all times.

14. An emission scrubbing system must be installed at the manure storage unit, with the manure blending tank, which

is also a potential odour source, tied in. The scrubber is to be designed as follows (please see the design schematic contained in Appendix B):

The scrubber design capacity is 150%. This has been calculated based on the volume of air to be treated; the

number of air changes required; and the air flow rate.

The air entering the scrubber system is known to be NH4-rich, and may also contain H2S.

The scrubber removes NH4 from the air with a sulphuric acid solution; and H2S- with a sodium hydroxide and sodium hypochlorite solution.

The first scrubber stage treats NH4. The treated air is then directed to second scrubber for H2S treatment.

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- 14 - The scrubbing solution for each stage is sprayed into the top of a chamber, with the air entering

towards the bottom of the scrubber. The chamber contains pall rings to maximise the contact surface area between the air and the scrubber solution.

The scrubber solution collects at the bottom of the chamber and is recirculated through the chamber until

spent. The recirculation solution will be topped up with chemicals in proportion to H2S and NH4 concentrations detected in the off-gas.

The spent NH4 scrubber solution is an ammonium sulphate solution. This comprises <0.5m

3/day and

discharges to sewer, or can be sold as a fertilizer.

The spent H2S scrubber solution comprises sodium sulphate, sodium chloride and elemental sulphur. This comprises <0.05m

3/day and discharges to sewer.

With the available, conservative emissions concentrations from the manure storage unit, the air quality

specialist has indicated recommended that the scrubber system stack is to have a height of 20m to allow for adequate emissions dispersion to ensure low odour impact. During detailed design, more data, including modelling of emissions dispersion if required, should be presented to the CWDM to motivate the required stack height.

Redundancy is built in with: duty and standby pumps; and design capacity of 150%.

Maintenance and repair time is minimised using locally sourced and standardised parts.

Critical spare parts will be stored on site.

The Biodigester plant includes a repair station for all critical mechanical components, such as pumps. The plant is designed so that critical mechanical components can be removed by chain block and gantry to the repair station.

Factoring in maintenance and repair, the scrubber system is expected to have 96% utilisation (i.e. 15 days of downtime per annum).

Pressure monitoring on the gas lines in and out of the scrubbers will detect blockages in the scrubber solution delivery and sprayer system (low pressure on discharge indicates a blockage).

Access manways to scrubber chambers for easy inspection and maintenance.

Scrubber solution dosing pumps will be on a timer and manually adjusted in accordance with off-gas concentrations.

In-line and portable gas monitors to be used downstream of the scrubber chambers to intermittently check H2S and NH4 concentrations. This will assist the operator to monitor and manage dosing of the scrubber solution.

The gas monitors must be fit for purpose, i.e. must be able to operate at the emission gas temperature, moisture content and pressure; and must be regularly calibrated.

The system will be under constant CCTV surveillance, which will assist Trigen to ensure that the system is being operated correctly.

There will be an operator at the plant at all times.

A detailed SCADA system will be in place for remote system supervision.

15. The scrubber design is to allow for possible future adaptations or upgrades that may be required in order to ensure that odours are minimised.

16. The detailed design of the scrubber is to be submitted to the Cape Winelands District Municipality’s air quality officer for approval prior to plant commissioning

17. Operators at the manure storage unit must wear personal gas monitors to detect dangerous gas concentrations.

18. Breathing apparatus will be positioned at critical points in the manure storage facility.

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- 15 - 19. An ammonia stripper will be installed for the treatment of the liquid fraction separated out from the

digestate during dewatering. This will enable the liquid fraction to be reused in the Biodigester system as dilution water:

The liquid fraction is heated up using heat exchangers and waste heat from the CHP’s.

Heating the liquid fraction strips the ammonia from the liquid and the nitrogen lean liquid fraction is returned

as dilution water to the Biodigester system.

The ammonia off-gas is sent to an ammonia scrubber utilising acid wash solution (sulphuric acid) in counter-current to the off-gas flow to remove the ammonia and produce ammonium sulphate as a by-product.

The ammonium sulphate is discharged to sewer.

A diagram showing the basic principles of the scrubber is included in Appendix B.

To ensure that the scrubber system operates as designed, the following design and management measures will be implemented:

20. Duty and standby pumps will be in place for redundancy. Pumps will be used alternately to ensure that a single

pump is not overworked: operating hours will be balanced by the operator.

21. Pressure monitoring on the gas lines in and out of the scrubbers will detect blockages in the scrubber solution delivery and sprayer system (low pressure on discharge indicates a blockage).

22. Access manways to scrubber chambers for easy inspection and maintenance.

23. Scrubber solution dosing pumps will be on a timer and manually adjusted in accordance with off-gas

concentrations.

24. In-line and portable gas monitors to be used downstream of the scrubber chambers to intermittently check H2S and NH4 concentrations. This will assist the operator to monitor and manage dosing of the scrubber solution.

25. The gas monitors must be fit for purpose, i.e. must be able to operate at the emission gas temperature, moisture

content and pressure; and must be regularly calibrated.

26. The scrubber design capacity is 150%. This has been calculated based on the volume of air to be treated and the air flow rate.

27. Mechanical components will be locally sourced and will be standardised for ease of replacement.

28. The system will be under constant CCTV surveillance, which will assist Trigen to ensure that the system is being operated correctly.

29. There will be an operator at the plant at all times.

30. A detailed SCADA system will be in place for remote system supervision.

31. Redundancy is built in with: duty and standby pumps; and design capacity of 150%.

32. Maintenance and repair time is minimised using locally sourced and standardised parts.

33. Critical spare parts will be stored on site.

34. The Biodigester plant includes a repair station for all critical mechanical components, such as pumps. The plant is designed so that critical mechanical components can be removed by chain block and gantry to the repair station.

35. Factoring in maintenance and repair, the scrubber system is expected to have 96% utilisation (i.e. 15 days of downtime per annum).

36. The grit skip at the manure and effluent blending tank must be kept closed, regularly emptied and the contents

disposed of to landfill. The skip must be regularly cleaned.

37. The Biodigester plant must be maintained and operated according to the design specification.

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38. The effluent discharge permit currently in place at the RCL facility must be amended accordingly in consultation with the local authority.

4.1.4. Health Risks due to Pests Objectives: To avoid spread of disease from pests attracted to manure storage and handling. Targets: To implement adequate pest control measures at the manure storage unit. Measures:

(a) Please refer to measures under Section 4.1.3

(b) In addition, the manure storage unit floors will be designed so as to prevent pooling of wash water. (c) The storage unit will be cleaned regularly according to a cleaning schedule and work instruction. (d) The Draft Pest Control Plan attached to this EMP should be implemented. This is a working document

and should be adapted as required on the advice of the pest control service provider. 4.2. PRE-CONSTRUCTION PHASE IMPACTS Timeframe for implementation of pre-construction phase measures: Prior to any construction activities taking place, the following measures will need to be complied with:

4.2.1. Bulk Services Identification Objectives: To minimise any possible damage to existing bulk services as a result of pre-construction and construction related activities. Targets: To comply with any local authority by-laws regarding bulk services and to avoid additional costs and potential project delays due to damage to these services Measures:

If any bulk services are required to be relocated and/or rerouted then the appropriate permits/approvals must be sought.

The location of existing bulk services must be determined to prevent accidental damage to these facilities.

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4.2.2. Permits Objectives: To ensure that the necessary permits regarding any activities related to construction activities are in place prior to construction starting. Targets: To ensure that the construction works can proceed without possible delays and/or legal repercussions during building works as a result of outstanding permits and/or non-compliance with permits. Measures:

The client shall issue a list of applicable permitting conditions together with the respective permits/authorisations to the ECO prior to the start of construction works.

4.2.3. Training

Objectives: To ensure that all staff working on site are adequately trained on the requirements of this EMP and are legally compliant with relevant legislation. Targets: To ensure that the requirements of this EMP are understood and implemented by all staff (as and when required) on site. Measures:

The ECO will provide for site contractor management training sessions (as required), who will in turn ensure that all staff working on site are familiar with the workings and requirements of this EMP

An interpreter should be provided as required.

4.2.4. Construction phase site layout Objectives: To designate areas on site for various types of construction related activities. Targets: To ensure an efficient and orderly layout that promotes safe access Measures:

The location of storage areas for any construction materials must be agreed to by the ECO, Principal Agent and Contractor prior to the commencement of work at the site.

A sketch diagram of the above is required by the ECO.

This area must all be kept tidy, sanitary and in good condition throughout the project.

4.2.5. Working Hours Objectives: To designate working hours for construction related activities. Targets: To ensure that the hours of operation shall be restricted to those stipulated by the local authority. Measures:

The contractor shall at all times ensure that working hours are restricted to those stipulated by the local authority.

Modifications to the above may only take place through the local authority and the ECO must be notified in writing.

4.3. CONSTRUCTION PHASE IMPACTS

Timeframe for implementation of construction phase measures: The construction phase measures for minimisation of any health, safety and environmental risks need to be adhered to throughout the construction phase of the project.

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4.3.1. Social Considerations Objective: To minimise social impacts (e.g. nuisance factors) related to the construction of the site through effective communications with abutting neighbours. Targets: To ensure compliance with the local authority by-laws and any other statutory requirements relating to site construction and demolition impacts. Measures:

All abutting neighbours (or as required) must be notified of the proposed construction phase activities at least two weeks before they commence.

The Contractor must record and repair any damage that the construction works may cause to neighbouring properties.

The ECO must be notified in writing of any incidents relating to the above.

4.3.2. Appropriate Machinery Objectives: To minimise possible nuisance affects and environmental damage through the use of appropriate machinery during the construction works. Targets: To ensure that impacts and damage to the environment are minimised via the responsible use of appropriate machinery on site. Measures:

The Contractor shall at all times carefully consider what machinery is appropriate to the task in the context of this EMP while minimising the extent of environmental impact.

A dedicated parking area must be defined with drip trays beneath any potentially leaking equipment and fuel/lubricant absorbing media (peat/moss type products) within these drip trays must be used to contain any spilled liquids.

These materials must be replaced regularly to prevent over-saturation and potential spillage of free phase product. This material must be disposed of as hazardous waste and be collected by an approved Contractor/delivered to a suitable landfill site.

Chain of custody documentation must be provided as proof of final end recipient.

All spills are to be recorded in the Environmental Register, including any clean-up actions taken to remediate the spillage. Such actions are to be agreed with the ECO prior to taking place.

4.3.3. Waste Management

Objectives: To minimise possible environmental damage through inappropriate waste management on site or related to the site. Targets: To ensure that the handling of waste is in accordance with the statutory requirements of the local authority by-laws and the National Environmental Management Waste Act, Act 59 of 2008. Measures: 1) Liquid Waste:

Liquid dispensing receptacles (e.g. lubricants, diesel, shutter oil etc.) must have drip trays beneath them/beneath the nozzle fixtures.

A spill management protocol must be produced by the Contractor and approved by the ECO prior to works commencing on site.

Material safety data sheets (MSDS) must be available on site where products are stored, so that in the event of an incident, the correct action can be taken.

Depending on the types of materials stored on site, suitable product recovery materials (such as Spillsorb or Drizit products) must be readily available.

Cement contaminated water must be fed to a container, neutralised and suitably disposed of (e.g. sent to a suitable landfill site). In the latter case, chain of custody documentation must be provided to ensure a suitable end recipient. The latter must be kept with the environmental register.

The Contractor shall ensure that any wastewater generated during construction activities feeds to a suitable containment area such as a container or lined sedimentation pond prior to disposal. This pond or ponds must be allowed to dry out on a regular basis to allow for solid material removal. The wastewater must be disposed of in a suitable manner (possibly to the sewer system following local authority approval) and must not be directed to a storm water drain.

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Storm water must be managed in such a way that no overland flow is possible onto any area of the site which could contain potential contaminants (such as concrete mixing areas, material and hazardous storage areas from any adjacent area).

2) Solid Waste:

Waste must be categorised by the Contractor and disposed of in a suitable manner into separate waste streams (this includes general, hazardous and recyclable waste) only at authorised waste disposal facilities.

The Contractor must provide an adequate number of waste receptacles for general waste at points around the construction site as well as for hazardous and recyclable waste.

Waste is to be collected either by the Municipality or via a licensed waste disposal Contractor.

The frequency of collections/emptying of waste receptacles will be of such a frequency that waste receptacles do not overflow.

Particular care shall be taken with the disposal of materials that could be wind-borne or waterborne to ensure that the release of these materials is minimised (the latter is a requirement for hazardous waste).

The use of netting covers or similar sealed containers must be implemented as and when required by the ECO.

All material used by the Contractor during the construction phase shall be managed in such a way that it does not cause pollution, or that it minimises pollution. In the event of a spillage, the Contractor should have suitably trained personnel who can correctly clean up any spillage in an efficient and environmentally sound manner.

3) Hazardous Waste:

Storage areas that contain hazardous substances must be covered and bunded with an approved impermeable liner or have some form of secondary containment.

The Contractor shall keep MSDS on-site for all potentially hazardous materials used.

Suitably trained personnel shall be available on the site during working hours so that in the event of human exposure to any hazardous materials that the correct first aid actions are taken. This training should also include environmental spill containment procedures

Spills in bunded areas must be cleaned up, removed and disposed of safely from the bunded area as soon after detection as possible to minimize pollution risk and reduced bunding capacity.

Chain of Custody documentation must be provided for any hazardous substances disposed of as proof of end recipient and disposal at an authorised hazardous waste disposal facility.

4) Cement/concrete mixing areas:

Cement powder has a high alkalinity, which can contaminate and dramatically affect both soil and groundwater. The following recommendations are made:

Mixing areas must be defined on site and approved by the ECO.

No mixing of cement is allowed on bare soil and a lined bund or bunded portable mixer must be used. The use of ready mix concrete must be considered.

Cement bags must be disposed of in demarcated hazardous waste receptacles and the used bags disposed of via the hazardous substances waste stream.

Excess or spilled concrete must be disposed of to a suitable landfill site, with chain of custody documentation provided.

4.3.4. Storm water

Objectives: To minimise potential impacts arising out of improper management of storm water originating on site. Targets: To ensure that storm water on site is managed according to the local authority by-laws and in accordance with any other statutory requirements and that no negative impacts occur to the storm water services around the site. Measures:

Storm water outfalls should be designed to reduce flow velocity and avoid downstream erosion.

Soil erosion on site must be prevented at all times.

If the storm water is of such a quality that suspended solids are present then detention ponds for removal of suspended solids must be considered.

During construction, all material excavated must be protected, screened or covered to prevent off site movement (primarily wind-blown soil or surface runoff) and the surplus material must be removed from site weekly to a licensed waste disposal site or re-used if appropriate.

All storm water channels around the outside of the site should be inspected regularly to ensure that they are not blocked and/or obstructed to ensure their efficient operation.

Storm water runoff must be controlled to ensure that on-site activities do not result in off-site pollution.

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4.3.5. Fire Safety Objectives: To prevent any potential impacts related to fires originating on site. Targets: To ensure compliance with the local fire department and local authority by-laws and any other statutory requirements relating to fire safety. Measures:

All hot work will take place in accordance with the health and safety procedures currently in place at the Biodigester plant.

Adequate training in emergency response situations of the contractor and construction personnel undertaking the construction activities will be carried out.

Firefighting facilities which will include hand-held fire extinguishers and a hose reel. These facilities must be approved by the local fire department.

Minimisation of hot work by using alternative methods and equipment such as air driven tools, cold cutting and pre-fabrication off site.

The use of appropriate shielding and screening such as blanketing with firefighting foam and water screens to minimise fire risk.

Minimisation of spark quenching by wetting down and/or using construction power tools such as jack hammers under running water.

A fire attendant will be on stand-by during the construction process.

4.3.6. Safety and First Aid Objectives: To minimise any potential safety or health related incidents on site. Targets: To ensure compliance with the local authority by-laws and any other statutory requirements relating to health and safety on a construction site. Measures:

All people working on site are responsible for their own safety on site. Contractors and Principal Agent/s shall at all times comply with the relevant statutory requirements including the Occupational Health and Safety Act, Act No.85 of 1993.

A comprehensive site specific first aid kit must be available on site at all times.

At least one person trained in safety and first aid and familiar with the first aid equipment on site must be present on the site at all times.

Emergency procedures must also be established prior to the start of construction operations on site and appended to this EMP.

4.3.7. Air Quality

Objectives: To minimise potential air quality impacts during construction related activities. Targets: To ensure compliance with the local authority by-laws and any other statutory requirements relating to air quality. Measures:

Wind-blown dust and sand may generate considerable negative impacts (e.g. reduced visibility for vehicles travelling along adjacent roads and nuisance to neighbours/adjacent erven).

The erection of shade netting screens to prevent off-site movement of dust is required and/or other appropriate action to minimise this impact; e.g. chemical surface stabilisers, straw stabilisation or mulching.

The use of water bowsers and wetting down of loose soil areas must be avoided due to the drought. Alternative measures as suggested should be implemented.

If water is required for dust suppression, non-potable sources must be used, e.g. the contractor can erect a rainwater harvesting tank on the site; and/or if there is a settlement pond on the site for excess cement mixing water runoff, the top layer of mixing water – where the fines have settled out – can be utilised for dust suppression.

The contractor must adhere to the National Dust Control Regulations.

4.3.8. Water Quality

Objectives: To minimise any potential impacts on the groundwater quality at and off site through indirect impacts.

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- 21 - Targets: To ensure compliance with the local authority by-laws and any other statutory requirements relating to water quality. Measures:

Site staff shall not be permitted to use any stream, river, open water body or natural water source adjacent to or within the designated site for the purposes of bathing, washing of clothing, or for any construction or related activities.

Measures to control illegal dumping of construction waste must be implemented to prevent pollution to surface water run-off.

4.3.9. Noise and Vibration

Objectives: To minimise any potential noise impacts related to the construction operations on site. Targets: To ensure compliance with all legal requirements, including the local authority by-laws and any other statutory requirements relating to noise impacts. Measures:

The Contractor must use appropriate, modern equipment, which produces the least noise.

The use of noise shielding screens should be considered by the project team as and when required.

The provisions of SABS 1200A Sub clause 4.1 regarding "built-up areas" shall apply to all areas within audible distance of residents whether in urban, peri-urban or rural areas.

No amplified music shall be allowed on site. The use of radios, tape recorders, compact disc players, television sets etc. shall not be permitted unless the volume is kept sufficiently low as to avoid any intrusion on members of the public within range.

The Contractor shall not use sound amplification equipment on site unless for the purposes of site safety and communications and in emergency situations.

Construction activities shall be confined to the hours stipulated by the local authority.

The Contractor will issue ear protection for any noise activities with a noise output of 85 dB or more.

The Contractor must notify all adjacent property owners/occupants of the proposed development and that noise impacts above 85 dB may occur as a result of the above.

No noise generating work is to be conducted outside of approved working hours unless in consultation with the local authority and advised to the adjacent property owners/occupants prior to works taking place.

4.3.10. Light Pollution

Objectives: To minimise light impacts associated with construction related activities. Targets: To ensure that light pollution is minimised such that no complaints are received from the public. Measures:

All legal requirements will be complied with to ensure that impacts are minimised.

Any lighting required by the Contractor shall be aimed at the area to be lit on site and the over spillage must be kept to a minimum.

4.3.11. Traffic Control Objectives: To ensure that traffic impacts as a result of the construction related activities are minimized. Targets: To ensure compliance with the local authority by-laws and any other statutory requirements relating to construction traffic. To ensure that the impacts on current traffic flows in the vicinity of the site are minimised and that complaints relating to traffic associated with the site’s activities are minimised. Measures:

Appropriate traffic routing and scheduling of construction related vehicles will be carried out in consultation with a competent traffic engineer.

The contractor must provide a competent traffic marshal for situations where heavy construction traffic may impede normal traffic flows on any roads adjacent to the site.

All vehicles will be legally compliant.

All drivers will be competent and in possession of an appropriate valid driver’s license.

All vehicles travelling on site will adhere to the specified speed limits.

The movement of all vehicles will be controlled such that they remain on designated routes.

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No member of the workforce will be permitted to drive a vehicle under the influence of alcohol or narcotic substances.

4.4. OPERATIONAL PHASE MITIGATION MEASURES Timeframe for implementation of operational phase measures: The measures for minimising health, safety and environmental risk associated with operations at the new plant, will need to be implemented on an on-going basis throughout the operational lifespan of the development.

4.4.1. Fire, Health and Safety Risk Potential health and safety impacts associated with the risk of fire and explosion are associated with methane gas storage and acid storage. Associated smoke and disturbance related to with the evacuation of the site and surrounding area; risk to life and property. Objectives: To minimise risk through adequate design and operational measures. Targets: To meet best practice design and operational measures. Measures:

(a) The safety of workers is of paramount importance. All workers and managers on site must be sensitised about the safety risks that exist at the plant in terms of fires, vapour cloud explosions and the release of toxic vapours. Workers and management must be trained in the safety and emergency response procedures that apply to the factory and its premises. Regular breathalyser tests must be conducted on site among all workers and management to ensure that no worker consumed alcohol before entering the site or while present on the site. If any worker or manager fails the breathalyser test, he/she must be dismissed with immediate effect.

(b) A specific person must be appointed in accordance with Section 16 (2) of the Occupational Health and Safety Act to take responsibility, together with the appointed Chief Executive Officer, for the health and safety of all workers on site. This safety officer must have the authority to stop any work or action that may pose a health and safety threat to other workers on site.

(c) All fire extinguishers on the premises must be tested at least once every six months by a certified equipment supplier.

(d) All drums and flow bins that contain flammable liquids must be stored in a bunded area. (e) Trigen must ensure that sufficient people are employed to ensure the safe and reliable operation of the

proposed biodigester plant and to have adequate human resources available to manage any emergency situation that may occur at the chemical plant.

(f) Sources of ignition must be avoided wherever flammable or highly combustible material is present in the

workplace e.g.: i. Notices prohibiting smoking is displayed and enforced ii. Welding and flame cutting is only allowed under controlled conditions that includes written

hot work permits iii. Only spark-free hand and power tools are used iv. No grinding, cutting and shaping of ferrous metals are allowed using electrically driven

power tools that produces sparks (g) Good housekeeping must be maintained to prevent the accumulation of unnecessary combustibles.

(h) Adequate ventilation must be maintained. (i) Gas flow to be shut off immediately at source (if safe to do so) during incident. (j) Adequate and suitable fixed and portable fire appliances must be provided and maintained in good

working order. Maintenance must include:

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- 23 - i. Regular inspection by a competent person appointed in writing and keeping a

register ii. Annual inspection and service by an accredited service provider

(k) Emergency escape routes must be kept clear at all times.

(l) Evacuation must be practised to ensure that all are evacuated timeously. (m) Roll call must be held after evacuation to account for all personnel and ensure that no one has been left

behind. (n) Adequate training of management and employees in emergency response situations must be carried out. (o) Preventative maintenance must be done on equipment on a regular basis.

(p) Disciplinary action must be instituted immediately against any worker or member of management that

contravenes the safety rules applicable to the premises. (q) The management of RCL Foods must report all safety incidents, including near misses, to the Chief of the

Fire Department as well as to the Provincial Director of the Department of Labour. (r) An Incident and Accident Register must be kept at the site. Please refer to Annexure G for example

templates. (s) A Health and Safety Committee must be instituted at the factory. The Committee must meet at least once

per month for a review of the safety conditions and status at the premises.

4.4.2. Groundwater and stormwater system contamination

Contamination of groundwater and stormwater as a result of a spillage, tank or line leak and surface runoff of untreated effluent into the stormwater system. Objectives: To ensure that any spills or leaks at the site from an incident or from day-to-day storage and handling activities, are not able to reach groundwater or the stormwater system. And in the event of an incident, that prompt action is taken to remedy the cause of the spill or leak and to address any potential contamination. Targets: To comply with best practice and legislative requirements. Measures: (a) A groundwater and surface water monitoring programme should be compiled in detail in conjunction with the

Breede-Gouritz Catchment Management Agency. Based on preliminary feedback from the BGCMA, for the first two years after plant commissioning, the programme may include monitoring of nearby drainage channels during the high flow season; and sampling for the following parameters should be undertaken: pH; electrical conductivity; COD; ammonia; nitrates and nitrites; phosphates. In addition, the programme may include the requirement to sample at the existing borehole on Erf 4396.

(b) Any incident that results in ingress of untreated effluent or similar into the soil, groundwater or stormwater system must be reported to all relevant authorities, including DEA&DP and the Breede Gouritz Catchment Management Agency on behalf of the Department of Water Affairs, within 14 days. This is in compliance with Section 30 (10) of the NEMA and Section 20 (3) of the Water Act. The incident report must include the containment and clean-up procedure and the remediation procedure for the impacted area. Containment, clean-up and remediation must commence immediately.

(c) In the event of a leak, prompt response to repair the leak is required. Effluent and manure are non-hazardous. A leak should be rapidly detected and should be small in scale, given the design and monitoring measures in place. Therefore spill response media are not considered necessary. A spill should be cleaned up and returned to the relevant step of the digestion process. If this is not possible, the spill should be disposed of to landfill.

(d) There is an Emergency Response Plan in place for the existing effluent Biodigester plant. This should be updated where required to accommodate the manure Biodigester prior to plant commissioning, and should include spill and leak response procedures, as well as response to tank, line or bund failure.

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- 24 - (e) Hazardous and general waste must be separated. All hazardous waste must be disposed of at

a licensed hazardous waste disposal site, with chain of custody documentation retained in the Environmental Register as proof of end recipient.

(f) A spill response kit appropriate to any chemicals stored, handled and processed at the site must be kept at the site at all times.

(g) In the event of a spill or leak, spill response according to the Emergency Response Plan must be implemented.

(h) An Environmental Register must be kept on site. The Incident and Accident Registers may be kept in the Environmental Register. Details of any incidences which may occur, as well as details on how the incident was rectified and / or remediated, must be included in the register. The register should also include chain-of custody receipts from disposal of hazardous waste; copies of any Section 30 Incident Form which may need to be sent to the authorities in the event of an incident; results of any on-going monitoring; details of complaints from neighbouring parties with respect to nuisance impacts such as noise or odours; etc. The Environmental Register should be kept updated by the designated site Safety Officer.

4.4.3. Nuisance Impacts on Neighbours Objectives: To ensure that adjacent occupants and owners are not impacted negatively by nuisance impacts such as noise and odours. Targets: To comply with authority requirements with respect to minimising and managing nuisance impacts on neighbours. Measures: (a) All windblown litter must be collected on site and may not cause a nuisance to neighbours.

(b) Any incident that causes noise, odours or any other nuisance must be rectified within 24 hours from the time

the incident has occurred.

(c) Relevant legislation pertaining to allowable noise levels in an industrial area must be adhered to, including the Western Cape Noise Control Regulations.

(d) Noise proof containers must be utilised for the noisiest equipment to ensure compliance with relevant legislation pertaining to noise disturbance.

(e) Manure and digestate transport trucks shall be cleaned and sanitised regularly by the service provider. This stipulation must be included in the service contract between Trigen and the service provider.

(f) Service contracts with manure suppliers must stipulate that only fresh manure may be delivered to the Biodigester plant.

(g) Operations at the plant must adhere to the National Dust Control Regulations.

4.4.4. Hygiene (h) No recovered water is to be used in any food handling area or activity at the plant.

4.4.5. Additional design, management and mitigation measures to prevent failure of the system and minimise all impacts

Digester failure and associated impacts: 1. There will be two smaller reactors operating in parallel instead of one large reactor. This adds an element of

redundancy. Also, the plug-flow operation of the digesters means that feedstock is fed in batches which is further risk mitigation against toxicity, which could lead to biomass death.

2. The mix in the digester tanks is agitated by means of compressed biogas recycled through an intricate distribution network. This is an efficient system with minimal risk of mechanical failure.

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3. The temperature in the digester tanks is monitored continuously. The reactions in the digester tanks are exothermic, and waste heat from the CHP’s is used to keep the digester contents at the desired temperature.

4. The design and management measures included are adequate for preventing failure of the digesters. In the highly

unlikely event that a digester tank fails, an Emergency Response Plan will be implemented. The Emergency Response Plan for the effluent Biodigester should be updated prior to commissioning to include response to tank failure.

5. There is an H2S scrubbing system installed on the gas line downstream of the Biodigester. This is already in place associated with the effluent Biodigester. The scrubber removes H2S from the gas stream before the biogas is piped to infrastructure which can be corroded, which could lead to failure over time (e.g. the CHP engines, which include steel mechanical parts). To ensure that the scrubber system operates as designed, the following design and management measures have been implemented:

Duty and standby pumps are in place for redundancy. Pumps are used alternately to ensure that a single pump is not overworked: operating hours are balanced by the operator.

Pressure monitoring on the gas lines in and out of the scrubbers detects blockages in the scrubber solution delivery and sprayer system (low pressure on discharge indicates a blockage).

Access manways to scrubber chambers for easy inspection and maintenance.

Scrubber solution dosing pumps will be on a timer and manually adjusted in accordance with off-gas concentrations.

In-line and portable gas monitors are used downstream of the scrubber chambers to intermittently check H2S concentrations. This assists the operator to monitor and manage dosing of the scrubber solution.

The scrubber design capacity is 150%.

Mechanical components have been locally sourced and are standardised for ease of replacement.

The system is under constant CCTV surveillance, which assists Trigen to ensure that the system is being operated correctly.

There is an operator at the plant at all times.

A detailed SCADA system is in place for remote system supervision.

Redundancy is built in with: duty and standby pumps; and design capacity of 150%.

Maintenance and repair time is minimised using locally sourced and standardised parts.

Critical spare parts are stored on site.

The Biodigester plant includes a repair station for all critical mechanical components, such as pumps. The plant is designed so that critical mechanical components can be removed by chain block and gantry to the repair station.

Factoring in maintenance and repair, the scrubber system has about 96% utilisation (i.e. 15 days of downtime per annum).

The digestate dewatering stage will also be designed with duty and standby pumps and locally sourced,

standardised components; and will be overseen by a plant operator at all times, as well as supervised by the SCADA system.

6. The pH of the mix inside the digester tanks is continuously monitored by means of pH probes. If the pH drops, an alarm is activated and steps will be taken to correct the pH. This prevents the pH dropping to acidic levels, which results in inefficient biogas production.

7. There will be an on-site laboratory for the regular analysis of the digestate, digestion water and waste water. Independent analysis will also be undertaken periodically.

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General:

8. The Biodigester plant must be maintained and operated according to the design specification.

9. The effluent discharge permit currently in place at the RCL facility must be amended accordingly in consultation with the local authority.

10. The grit waste skip must be kept closed, and must be emptied regularly with the contents disposed of to landfill. 4.5. DECOMMISSIONING PHASE IMPACTS

Timeframe for implementation of decommissioning-phase measures: The measures recommended for minimising health, safety and environmental risk associated with the decommissioning of the plant, need to be implemented during the practical decommissioning of the plant. Any rehabilitation measures required will take place for the duration recommended by the specialists compiling the rehabilitation action plan. In the unlikely event that the facility is decommissioned, the construction phase management measures contained in Section 4.3 of this EMP must be implemented.

In addition, the following measures should also be implemented to minimise the health, safety and environmental risks associated with the decommissioning of the infrastructure: (a) Adequate training in emergency response situations of the contractor and construction personnel undertaking

the decommissioning activities will be carried out.

(b) Fire fighting facilities which will include hand-held fire extinguishers and a hose reel. These facilities must be approved by the local fire department.

(c) Minimisation of hot work by using alternative methods and equipment such as air driven tools, cold cutting and pre-fabrication off site.

(d) The use of appropriate shielding and screening such as blanketing with fire fighting foam and water screens to minimise fire risk.

(e) Minimisation of spark quenching by wetting down and/or using construction power tools such as jack hammers under running water.

(f) Use of gas testing at methane gas and acid storage area to ensure there are no residual emissions.

(g) A fire attendant will be on stand-by during the decommissioning process 5. IMPLEMENTATION OF THE EMP 5.1. Roles and Responsibilities, including Monitoring, Auditing and Reporting

Environmental Control Officer (“ECO”) (a) The ECO must be appointed immediately after licensing of the facility and prior to commencement of any

construction required in order to implement the design requirements for the site.

(b) The responsibilities of the ECO will include monitoring of compliance with the EMP by the applicant and any sub-contractors.

(c) The ECO has the authority to recommend the cessation of works or any portion of construction related activity to the applicant during the tank installation phase. This will be triggered if in his/her opinion the activity has caused or will imminently cause significant damage and/or harm to the environment or is in contravention of the relevant environmental legislation/permits/authorisations applicable to the site and/or activity/ies.

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(d) If the applicant fails to show adequate consideration to the EMP or the recommendations of the ECO, then the ECO may recommend to the authorities that the aspect of operations to which non-compliance relates, ceases until the non-compliance is adequately rectified.

(e) At the frequency determined by the licensing authority, the site should be audited against the conditions of the EMP and the Waste Licence by an independent ECO. The audit reports should be submitted to the DEA&DP and both the Local and District Municipality for their records.

(f) Recommended frequency of auditing: The EAP recommends biennial auditing during the operational phase, with the first audit to be conducted within six months of commissioning of the plant. The EAP recommends weekly construction phase compliance monitoring site inspections for the first two weeks of construction, with monthly site inspections thereafter. Reporting to be submitted to the authorities on a monthly basis.

(g) Audit reports must contain monitoring laboratory results, chain-of-custody receipts to show safe disposal of hazardous waste, incident reports from the environmental register, etc.

(h) Should modifications to this document be required, these must be agreed to by all parties concerned.

The Client The Client – the client is responsible for employing the ECO, Contractor and any Sub-contractors for the lifecycle of the facility. It is the client responsibility to ensure that all appointed parties fulfil their obligations in terms of this EMP, i.e. the implementation of this EMP is the Client’s responsibility, and the Client must ensure that all activities taking place on the site are conducted in an environmentally responsible manner and in accordance with the requirements of this EMP. Council Representative The Council Representative will be an appropriately qualified environmental officer of the local municipality. This representative will monitor compliance of this EMP by the client through the ECO. 5.2. Documentation and Record Keeping (a) List of onsite documentation

An environmental register must be kept at the site, which must include the following:

An accident and incident register;

Complaints register;

Emergency Response Plan

Site evacuation plan/maps; and

Method statements

In addition, this EMP, the Emergency Response Plan, as well as the Waste Licence must be kept at the site. The right of the public to information shall be respected in accordance with relevant legislation.

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- 28 - (b) Environmental Register The environmental register should be used to record any relevant daily information related to the operations and current status of the site, including the following information:

Details of audits and inspections carried out by the ECO and/or as detailed in this EMP and follow-ups

Instances of non-conformances found in the EMP, the date of their occurrence, date of corrective action, and date of completion of preventive action

Details of chain of custody documentation

Any other relevant/pertinent daily events

The environmental register should also contain the accident and incident register and/or the complaints register.

(c) Accident and Incident Register An accident and incident register must be kept and should include the following information:

Time, date and place of the accident and/or incident

Who and what was involved

A detailed description of the accident or incident.

(d) Complaints register

A complaints register must be kept for the recording of all complaints lodged regarding the proposed biodigester plant. It is important that the complainant feels that their concerns have been listened to and that appropriate action (within reason) has been taken to address these. The complaints register must include: Detail of the complaint in clear, well-structured language Time and date of complaint and details of complainant for follow-up purposes. Name of the person who received the complaint. Description of action that was taken to address the complaint, including date and time of action. (e) Method statements Method Statements (a template for these purposes is appended to this EMP) will be required for activities that may result in significant impacts according to the ECO. These must address the following aspects:

What – a brief description of the work to be undertaken

How – a detailed description of the process of work, methods and materials

Where – a description of the location of the work (if applicable)

When – the sequencing of actions with commencement and completion date estimates

All Method Statements (MS) must be in place at least 5 working days prior to the relevant construction activities taking place and must be approved by the ECO prior to being implemented. The following MS must as a minimum be made available to address the following decommissioning related impacts:

Stormwater Management

Fire Risk Management

Waste Management

5.3. Environmental Awareness and Training a) For the construction phase, the ECO should conduct on-going Basic Environmental Awareness Training

sessions with the Contractor, his staff and subcontractors prior to any work taking place. The Contractors are required to provide a facility and interpreter (if required).

b) For day to day operations at the site, it is the responsibility of the Client to ensure that all employees and sub-contractors are fully aware of the operational procedures that must be followed in order to minimise health, safety and environmental risks associated with operations at the facility.

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- 29 - 5.4. Matters Pertaining to Non-Conformance onsite

“Non-conformances” would occur when there are deviations from any of the requirements of this EMP. This may also include non-compliance with the relevant environmental regulations. During the construction phase, the Contractor is responsible for reporting non-conformance with the EMP, to the ECO. The Client and the Contractor, in consultation with the ECO must, thereafter, undertake the following activities:

Investigate and identify the cause of non-conformance;

Implement suitable corrective action (appropriate to the magnitude of the environmental impact), as well as prevent recurrence of the problem, with responsibilities assigned for both.

Non-conformances and corrective action must be recorded in the environmental register, and included in the audit reports compiled by the ECO. The Client may introduce some form of penalty system for contractors onsite if compliance with the EMP proves problematic. During the operational phase, it is the Client’s responsibility to appoint an independent ECO to audit the site once every two years. The audit report must be submitted to the DEA&DP, the DEA, Water Affairs and Rustenburg Local Municipality and must include any incidences of non-conformance and recommendations for any corrective action required. In addition, the Client, their contractors, sub-contractors and employees are legally bound by Section 24(h) National Environmental Management Second Amendment Act, Act No. 107 of 1998, which states that it is “an offence for any person to contravene conditions applicable to any environmental authorization granted for a listed activity. A person convicted of an offence is liable to a fine not exceeding R5 million or to imprisonment for a period not exceeding ten years, or to both such fine and such imprisonment” This Environmental Management Programme, when approved, constitutes a Condition applicable to an Environmental Authorisation (or Waste Licence) and any transgression would thus trigger Section 24(h) of the above-mentioned Act. The exact penalty and fines will be decided on, subsequent to consultation with DEA&DP and the local municipality. All staff working on-site must be made aware of the consequences of non-conformance.

A J SILLITO Pr. Sci. Nat., CEAPSA

I:\jobs\SEC Jobs\0151011\0151011\May 2017 WLA manure\Outputs\EMP\0151011 Trigen Worcester EMP for FBAR Feb 2018.docx

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EMP ANNEXURE A GLOSSARY

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TERMS USED IN THIS EMP The terms used include the following: The term ‘client’ means the owner of the facility to which this EMP applies. The term ‘construction’ means all organised activities concerned with demolition, building, landscaping, maintenance, civil engineering, process engineering, heavy engineering and mining. The term ‘contractor’ means an organisation that contracts with the applicant to carry out the work under a contract, including construction and other services. The term ‘decommission’ means all organised activities concerned with demolition of infrastructure (above and below ground) on site as well as the associated removal of infrastructure on site as well as the rehabilitation and/or site clean up after infrastructure has been removed. The term ‘design’ means the process (and product) of converting a brief into design details ready for documentation, including concept design and design development, and then documentation or detailing of the technical and other requirements for the project in a written form that details the project product sufficiently for it to be constructed or otherwise provided. The term ‘environmental opportunity’ means a potential for beneficial environmental impacts (such as an improvement in air or water quality through environmentally friendly technology alternatives). The term ‘environmental risk’ means a potential for adverse environmental impacts (such as pollution of a water source during decommissioning activities). The term ‘management’ means the planning and interactive controlling of human and material resources to achieve time, cost, quality, performance, functional and scope requirements. It involves the anticipation of changes due to changing circumstances and the making of other changes to minimise adverse effects. The term ‘procurement’ means the collection of activities performed by and for an agency to acquire services and products, including assets, beginning with the identification/detailing of service requirements and concluding with the acceptance (and where applicable, disposal) of the services and products. The term ‘project’ means an undertaking with a defined beginning and objective by which completion is identified. Project delivery may be completed using one contract or a number of contracts. The term ‘service provider’ means a contractor, subcontractor, supplier, consultant (including an agency) and sub-consultant (contracting with a consultant), and their service providers, that contract with a customer to carry out construction, decommissioning, provide other products (including goods) and/or provide services. The term ‘subcontractor’ means an organisation that contracts with a contractor as the customer to carry out construction and related services, and/or provide other products.

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The term ‘supplier’ means an organisation that contracts with a contractor or Principal

Agent to supply a product and/or service.

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EMPR ANNEXURE B POSSIBLE METHOD STATEMENT

TEMPLATE

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METHOD STATEMENT FOR THE:

……………………………………………………. This method statement is to be completed by the Contractor (in consultation with the ECO) at least 5 working days prior to the proposed commencement date of the said work and represents a binding agreement to the Method Statement by all site Contractors and Subcontractors involved in the work for which the Method Statement is submitted. DATE OF SUBMISSION:………………….

CONTRACTOR:…………………….

SUBCONTRACTORS (IF RELEVANT):………………………………………………

A) Describe in detail what work is to be undertaken?

B) Describe in detail where on the site the works are to be undertaken and the extent? Provide sketch plan and grid block reference.

C) When will the works start and what is the anticipated finishing date of these works?

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D) How are the works to be undertaken?

1) Lead supervisor/ foreman name and contact details: 2) Number of personnel:

3) Construction activities:

4) Plant and machinery to be used:

5) Materials to be stored (specify hazardous materials):

6) Other:

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E) What environmental impacts are anticipated and what precautions are proposed to prevent these impacts? (refer to the relevant sections of the EMP for guidance and provide a general camp layout)

Camp site demarcation:

Toilet facilities:

Litter:

Security:

Plant/machinery (operation, servicing, management, storage, refuelling etc.):

Emergencies and fire:

Hazardous materials (handling, management, storage etc.):

Have all personnel involved been through an environmental induction course?

Petrochemical spill remediation and containment measures:

Other:

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DECLARATIONS BY PARTIES 1) CONTRACTOR

I UNDERSTAND THE CONTENTS OF THE METHOD STATEMENT AND THE SCOPE OF THE WORKS

REQUIRED OF ME. I FURTHER UNDERSTAND THAT THE METHOD STATEMENT MAY BE AMENDED

ON APPLICATION TO THE ABOVE SIGNATORIES, AND THAT THE ENVIRONMENTAL CONTROL

OFFICER WILL AUDIT MY COMPLIANCE WITH THE CONTENTS OF THIS METHOD STATEMENT. (PRINT NAME) (SIGNED) DATED:

2) ENVIRONMENTAL CONTROL OFFICER (ECO) THE WORK DESCRIBED IN THIS METHOD STATEMENT, IF CARRIED OUT ACCORDING TO THE

METHODOLOGY DESCRIBED, IS SATISFACTORILY MITIGATED TO PREVENT AVOIDABLE

ENVIRONMENTAL HARM. (PRINT NAME) (SIGNED) DATED: 3) PRINCIPAL AGENT

THE WORK DESCRIBED IN THIS METHOD STATEMENT, IF CARRIED OUT ACCORDING TO THE

METHODOLOGY DESCRIBED, IS SATISFACTORILY MITIGATED TO PREVENT AVOIDABLE

ENVIRONMENTAL HARM. (PRINT NAME) (SIGNED) DATED:

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EMPR ANNEXURE C ROLE OF THE ECO

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DUTIES OF THE ECO 1. Ensuring that the EMP conditions are adhered to at all times and taking action where

the specifications are not being followed.

2. Ensuring that environmental impacts are kept to a minimum.

3. Reviewing and approving method statements in consultation with the Principal Agent.

4. Advising the contractor on environmental issues and assisting in developing

environmentally responsible solutions to problems.

5. Reporting to the applicant on a regular basis and advising of any environmental

impacts.

6. Attending site meetings (when necessary) and giving a report back on the

environmental issues at these meetings and other meetings that may be called

regarding environmental matters.

7. Inspecting and auditing the site and surrounding areas regularly.

8. Establishing and monitoring an on-going environmental awareness program in

conjunction with the contractor.

9. Requesting the removal of person(s) and/or equipment not complying with the

specifications.

10. Keeping both a written and photographic record of progress on site from an

environmental perspective, and an ad hoc record of all incidents or events on site with

environmental ramifications. These records should be dated and accurately

catalogued in the onsite logbook, and separate audit reports.

11. Undertaking continual internal review of the EMP and submitting a report at the end of

the project.

12. The ECO will submit all written instructions and verbal requests to the contractor via

the Municipality project manager.

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EMPR ANNEXURE D

1) SITE LAYOUT PLAN

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EMPR ANNEXURE E

INCIDENT REGISTER & BASIC ACCIDENT REGISTER TEMPLATES

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INCIDENT REGISTER (EXAMPLE)

“Incident” means - an unexpected sudden occurrence, including a major emission, fire or explosion leading to serious danger to the public or potentially

serious pollution of or detriment to the environment, whether immediate or delayed

Date

(yyyy/mm/dd)

Incident

Comments (Include any possible explanations for current

condition and possible responsible parties. Include

photographs, records etc. if available)

Corrective Action Taken (Give details and attach documentation as far

as possible)

Reference no. for

On-Site Logbook (e.g. Rv 6/12 Inc 1)

Signature

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BASIC ACCIDENT REGISTER (EXAMPLE)

Date

(yyyy/mm/dd)

Accident

Names of Persons

Involved

Comments, Including Injuries

Sustained (Include any possible explanations for

current accident. Include photographs,

records etc. if available)

Corrective Action

Taken

(Give details and attach

documentation as far as

possible)

Reference no. for OHS

Documentation and

Attachments (e.g. Rv 6/12 Acc 1)

Signature

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Complaints register (example)

Revision nr 0

Date:

Page: 1 of 1

Root Cause Action requiredDate

implemented

Comms to

ComplainantAddress Detail Location of Complainant

Investigation

TimeName of

ComplainantContact No

COMPLAINTS REGISTER

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EMPR ANNEXURE F

EAP CURRICULUM VITAE’S

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CV: ADRIAN SILLITO

SPECIALISATION : Environmental Management

NATIONALITY : RSA Citizen

PROFESSIONAL QUALIFICATIONS

: MSc Engineering Geology, Natal University 1991 BSc (Hons) Geology, Sheffield University, 1983

DATE OF BIRTH : 24 November 1961 PROFESSIONAL MEMBERSHIP

: Professional Natural Scientist (Pr.Sci.Nat), Certified Environmental Assessment Practitioner of South Africa (CEAPSA), Member of the International Association for Impact Assessment (MIAIA). Fellow of the Geological Society, London (FGS). Member of the SA Institute of Engineering and Environmental Geologists (SAIEG), Member of the Association of Engineering Geologists (MAEG).

PROFESSIONAL EXPERIENCE From 1/11/01 to date Sillito Environmental Consulting (SEC) Subsoil and groundwater contamination investigation, risk

assessment, analysis, reporting and remedial recommendations. Design, implementation and monitoring of remediation systems. Several thousand projects of this nature have been supervised, project managed and reported on. This includes long term site monitoring, data interpretation and reporting

Liaison and reporting to regulatory authorities with regard to contamination issues

Phase 1 & 2 Environmental Due Diligence & Waste Audits for various national and international companies

Production of generic environmental audit protocols

Environmental Impact Assessments for a wide range of proposed activities including residential, commercial, industrial, petrochemical, chemical and telecommunications. This involved the compilation, editing and review of all documents

Site specific environmental management programmes and on-site support/ECO services. Including the review of final documents.

Professional review of reports submitted to the Department of the Environment for the Minister of Environmental Affairs and Development Planning

Green Star SA training, project management and coordination

1996 to 10/2001 K & T Consulting Engineers Contamination Investigation and Risk Assessment

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Contamination investigation, risk assessment and remediation proposals and systems design for a large number of petrochemical facilities countrywide

Geotechnical Investigation Geotechnical investigations for a wide variety of structures, from

pipeline route investigations, large-scale site evaluation for housing, both low and high cost, to individual structures from single houses to multi storey hotels

Slope stability analysis, stabilisation proposals and project management

Quarry site location, materials analysis and reporting

Project Management Project management of the engineering design to closure of

Faure landfill site. Project involved geophysical and geohydrological, hydrological and geotechnical assessment as well as the engineering design for the capping layer

Environmental Impact Assessment Environmental Impact Assessments within the petrochemical,

chemical, mining and quarrying environments, projects completed in all 9 provinces

Development of Environmental Management Plans

Environmental Control Officer experience on various projects

Environmental Management Programme Reporting (Quarry sites)

Review of applications for authorisation (in terms of the Environment Conservation Act) on behalf of the Department of Environment, DEA&DP (Western Cape)

General environmental advice to DEA&DP with regard to the policy development for the Western Cape

Environmental Management Systems ISO 14001 Environmental Management Systems training with

Casella International, UK, 2000 Implementation of ISO 14001 environmental management

systems EARA approved Environmental Auditor course (March 2001)

Phase 1 Environmental Audits (Merger & Acquisition Audits) individually and in conjunction with international environmental companies

1994 – 1996 Africon Geotechnical & Materials Waste disposal site conceptual design (including costing) for

DWAF permit application. Location of suitable liner materials Geotechnical investigation and foundation/support design for a

wide variety of projects from tunnels, township establishment, townhouses, bridges, underpasses, receiver masts, law court complexes, hotels to warehouse developments

Orange-Vaal canal project, route analysis with API (Aerial

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Photograph Interpretation), on-site investigation and construction recommendations. Gariep to Springfontein pipeline investigation

Underground mine backfilling investigation for surface stabilisation of sewage works, analysis and proposal of remedial measures

1992 - 1994 Lesotho Highlands Project Contractors Responsible for all geological and geotechnical input at the Katse

Intake site from slope stability analysis to predicting geological problem areas (stress, lineation intersection, quarry materials quality)

Tunnel support recommendations and classification of ground conditions

Aggregate quarry quality control and mining methodology including environmental controls in terms of waste discharges

1990 - 1991 Natal University, Durban: MSc Engineering Geology One year’s full time lecture course including the soil mechanics

component which was provided by the Civil Engineering Department

Thesis: Analysis of six co-disposal landfill sites in KwaZulu Natal

1988 - 1990 George Orr & Associates Lower Fish River Government water scheme: Site Eng. Geologist.

Dam foundation analysis, grout curtain recommendations, tunnel feasibility investigations (drilling investigations), mapping, quarry monitoring and environmental controls

Ladysmith Flood Attenuation Scheme: Dam site location, investigation and quarry location and evaluation

Henties Bay aquifer recharge project, dam site location and evaluation via satellite imagery and targeted drilling

1984 – 1988 Mining & Exploration Field Exploration Geologist, open cast coal operations

Opencast coal site geologist, quality control on site and at the processing plant, including mine planning

Exploration/Shaft Geologist gold mining environment. Quality control, reserve determination and drilling exploration

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CV: COLLEEN McCREADIE

SPECIALISATION : Environmental Management

NATIONALITY : South African

PROFESSIONAL QUALIFICATIONS : BA Political Studies and Economics, UCT, 1997 BComm (Hons) Economics, UCT, 2000

DATE OF BIRTH : 25 June 1976 PROFESSIONAL MEMBERSHIP : Member of the International Association for Impact Assessment

(IAIA). Member of the National Association for Clean Air (NACA) Associate Member of the Institute for Waste Management of Southern Africa (IWMSA)

COURSES AND SEMINARS ATTENDED

: Sustainable Development and Environmental Analysis and Development Planning Modules towards a BPhil in Sustainable Development Planning and Management, Sustainability Institute, University of Stellenbosch, 2009 Workshop on Basic Assessment, DEA&DP, 2007 Ten Years of EIA in South Africa, DEAT, 2008 Waste Act Roadshow, DEA, 2009 Workshop on the Waste Act, DEA&DP, 2010 Workshop on the 2010 EIA Regulations, DEA&DP, 2010 Workshop on the 2010 EIA Regulations, DEA&DP, 2011 IAIAsa National Conference, 2012 IWMSA Waste Conference, 2014 Workshop on the 2014 EIA Regulations, DEA&DP, 2015 Workshop: In-Stack Emission Monitoring and Reporting in Compliance with Atmospheric Emission Licence Requirements, NACA, 2015 Workshop: Challenges of Dust Deposition Monitoring, NACA, 2015 Presentation by SEC: Maintaining Compliance with AEL Conditions, NACA, 2016 Workshop on 21 (i) & (c) Water Uses presented by the DWS, 2017

PROFESSIONAL EXPERIENCE From 01/03/12 to date SEC Environmental Impact Assessments (project management; report

compilation; compliance monitoring and auditing; public participation management; legislation and regulation review)

EIA’s, Basic Assessments, Rectification Applications, Licence Applications, Permit Applications, Service Provider Registrations in terms of the NEMA, NEM: Waste Act, NEM: Air Quality Act and local by-laws.

From 01/03/11 to 28/02/12 Freelance Environmental Consultant EIA’s and Basic Assessments undertaken in terms of the NEMA

Work undertaken for KHULA Environmental Consultants; SiVEST Environmental Division (Cape Town) and Sillito Environmental

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Consulting (SEC) From 1/07/07 to 28/02/11 SEC Environmental Impact Assessments

On-site Environmental Control Officer (ECO) work

Environmental authority consultation

Input into Environmental Management Plans for construction and operational phase work

From 08/11/06 to 31/05/07 SRK Consulting Junior level: Environmental Impact Assessments within the

residential development and mining sectors, including retrospective authorisation for illegal activities under the NEMA Section 24G legislation

ECO work

Impumelelo Innovations Award Trust: Independent

Researcher An NGO which awards excellence in public-private partnerships

for pro-poor service delivery. Assessing 21 projects submitted to Impumelelo in 2006, to

identify key issues contributing to their success or failure, and analysing the identified issues to recognise trends across the projects, thereby generalising drivers of success or of failure.

01/02/03 – 01/10/06 ERA Steer False Bay Real estate sales associate for the Noordhoek area

Responsibilities included property valuation, property market trend analysis, the marketing of properties including the design and copy for marketing materials and advertisements, negotiation of sales and maintaining client relationships from first contact to after-sales service.

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EMPR ANNEXURE G

1) EMERGENCY RESPONSE PLAN

FOR EFFLUENT BIODIGESTER 2) DRAFT PEST CONTROL PLAN 3) STORMWATER MANAGEMENT

PLAN 4) DAILY EQUIPMENT AND

INFRASTRUCTURE INSPECTION SCHEDULE

5) PLANT PREVENTATIVE MAINTENANCE PLAN

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EMERGENCY EVACUATION PROCEDURE

Rev. Date Prep. Review Approved Description of Revision

00 05/05/2017 J. Campbell D. Gibbison Initial plan

Waterkloof Corner,

Cnr. Crown & Main Streets

Waterkloof, Pretoria

0181

South Africa

PO Box 2814, Brooklyn, 0075

THIS DOCUMENT TEMPLATE IS THE PROPERTY OF C- SAFE SOLUTIONS (PTY) LTD AND CANNOT BE USED, REPRODUCED, TRANSMITTED AND/OR DISCLOSED WITHOUT PRIOR

WRITTEN PERMISSION.

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INDEX

1. Emergency Control

2. Fire Control

3. Evacuation Control

4. First Aid Control

5. Emergency Procedure for injuries on duty during normal working hours

6. Site evacuation procedure / fires

7. Emergency Personnel

8. Emergency contact numbers

9. First Aiders- To be confirmed

10. Emergency Evacuation Drills

Annexure A- Evacuation routes, emergency exits & fire-fighting equipment

Annexure B- Self Assessment on Fire-Extinguisher use

Annexure C- Fire Evacuation Standby Card

Annexure D- Roll Call Register

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1. EMERGENCY CONTROL Emergency planning must be reviewed regularly and updated when necessary, in order to be optimally effective. Emergency leaders must be appointed and their duties delegated in writing. All appointed persons must be adequately trained to perform their duties and that all facets of the Emergency Evacuation Plan are practised regularly. The required equipment must be procured and kept serviceable and secure as per relevant legislation and/or regulations. Emergency facilities (if applicable) must at all times be serviceable and well maintained. Communications must be effective to ensure that instructions can be given to emergency personnel in any part of the Trigen Group (Pty) Ltd office area without delay. The safety of all staff, employees, management and visitors must at all times be planned for. All exits, evacuation routes, fire-fighting equipment and first aid equipment must be prominently displayed and easily accessible. Emergency personnel must at all times be identifiable. Regular drills must be practiced. The secretaries, managers and/or receptionist must be trained to contact the emergency services, when authorised to do so, without delay. Vital movable valuable records and documents are afforded priority ratings for salvage purposes in the event of fire, etc.

2. FIRE CONTROL Fire Team Leaders need to be appointed in writing and all appointed persons must be adequately trained to use fire extinguishers. The safest and most effective fire escapes and evacuation routes must be determined. Fire escapes must be practical and not blocked in such a way to prohibit use. Evacuation routes must be kept clear at all times. Ensure the continuous removal/storage of empty hazardous chemical substances containers so not to be threatened by fire.

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Always ensure that fire-fighting equipment is kept secure, but accessible, is well distributed, well maintained and effective. The training of staff, employees and management in the correct method of reacting in the case of a fire is vital. (As per Evacuation Procedure) Signposting of fire-fighting equipment must be in place at all times.

3. EVACUATION CONTROL The safest possible evacuation route is – as determined and outlined on the Fire plan. - Annexure A Evacuation routes (and alternatives) should be clearly marked on floor plans. Appointment of an Emergency Coordinator for each shift must be in place. A copy of the Trigen Group (Pty) Ltd Evacuation Plan should be forwarded to all personnel, to ensure they are aware of evacuation procedures. Ensure that doors and windows are closed when evacuating the office due to a fire. Ensure that panic is kept to a minimum when evacuating and that order is maintained throughout the Evacuation of the Site. Identification of the emergency assembly area must be prominently displayed and all employees are to be briefed on the location of the assembly area. Multiple assembly areas will be identified, and the wind direction will have a direct impact on the location of the assembly area.

4. FIRST AID CONTROL Management must determine, procure and distribute adequate emergency first aid equipment. The effective distribution of emergency first aid equipment in the TriGen RCL W2V plant office is compulsory. Always ensure that first aid equipment is readily accessible, yet sealed and secure. Always ensure there are sufficient number of first aiders trained and appointed in writing. One appointed first aider is sufficient for the Trigen RCL W2V plant. The First Aider must be identifiable. Storage facilities of first aid equipment should be clearly marked by means of a green cross on a white background and all employees should be briefed on the whereabouts of the first aid equipment.

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5. EMERGENCY PROCEDURE FOR INJURIES ON DUTY DURING NORMAL WORKING

HOURS

Minor Injuries

• Report to site manager immediately

• Report to office first aider

Medical Treatment

• Complete the relevant WCL forms correctly (Can be downloaded from the department of

labour website) WCL 2 forms also available in the Master HSE File.

• Take the injured employee to Worcester Medi Clinic.

• Forward all relevant forms to the site manager/first aider

Major Injuries

• Assess the seriousness of the injury (if unsure; DO NOT MOVE THE VICTIM)

• Contact the Site First Aider, site manager and/or security immediately.

• Contact Emergency Services immediately.

• The First Aider is to render the necessary treatment and remain with the injured employee at

all times, until medical help / paramedics arrive

Phone: 10177 (Ambulance)

021 761 6161 (ER24) or 082 911 (Netcare)

Tell them: Your name

Your location

The type of injury

Brief description of what happened

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6. SITE EVACUATION PROCEDURE

In the event of discovering a fire inform the site manager immediately.

Only try to extinguish a small fire without putting yourself and/or others in more danger.

Fire extinguisher use is displayed as per Annexure B

All employees should be aware of the sound of the fire alarm hooter and location of the emergency exits. Evacuation will take place via the routes as displayed on Fire Plan-Annexure A METHOD: In the event of such an emergency the Site siren will be activated. (Handheld Horn)

The Site manager will be responsible for contacting the Fire Station / Emergency Rescue.

Contact Number for the Worcester Fire Brigade / Rescue: 023 348 9060 / 112-Dialed from any Cell

Phone

WHEN BEING INSTRUCTED:

• Leave the Site by means of the escape routes provided in an orderly manner.

• Escape routes, exits and fire-fighting equipment is displayed as per Annexure A

• Emergency signs will be displayed in the plant areas and on the exit gates.

• PLEASE DO NOT RUN!

• Stay out of the Site.

• Walk to your nearest assembly point – Main Entrance Parking Lot in front of the Site. Gather

at the assembly point sign as displayed.

• Assembly areas are displayed as per relevant signage.

• Trigen appointed personnel will control the evacuation.

• Obey all emergency staff signals and instructions.

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• Once all staff are in the assembly area, roll call will be held to determine if all personnel have

safely evacuated the Site. Personnel not accounted for must be reported at the emergency

services immediately.

• Roll Call register template as per Annexure D

• Do not re-enter the Site at any stage. Only when emergency services have cleared the Site

and declared it safe, the go-ahead will be given to the personnel to re-enter the Site.

7. EMERGENCY PERSONNEL

TRIGEN GROUP (PTY) LTD EMERGENCY COORDINATORS

RENIER LATEGAN

TEL NO- 082 806 7066 TEL NO- TEL NO-

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8. EMERGENCY CONTACT NUMBERS

INSTITUTION NAME ADDRESS CONTACT

NUMBERS

Hospital (Medical

Treatment)

Worcester

Medi-Clinic

67 Fairbairn St,

Worcester, 6849

023 348 1500

Ambulance Services Netcare 911 N/A 082 911

South African Police

Services

Worcester Police

Department

53 Adderley St,

Worcester Central,

Worcester, 6850

023 348 8600

Fire Department Worcester Fire

Department

1 Roux Rd, Bergsig,

Worcester, 6850

10177

/ 023 348 9060

Electrical

Department

Breede Valley

/Worcester area

30 Baring Street

Private Bag X3046

Worcester

Western Cape

6849

023 348 2600

Spill Response Enviroserv 15 Dorbyl Road,

Sacks Circle, Cape

Town, 7530

021 951 8420

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9. FIRST AIDERS

TRIGEN GROUP (PTY) LTD FIRST AIDERS

RENIER LATEGAN NAME

TEL NO- 082 806 7066 TEL NO

10. EMERGENCY EVACUATION DRILLS

Emergency evacuation drills are to be scheduled once per annum and arranged by Trigen Group (Pty) Ltd senior Management

Step 1 Step 4

Vehicles to be stopped via flagmen Once outside, vehicles will be diverted by flagman

to avoid pedestrian motor vehicle accidents

Step 2 Step 5

Employees will make their way out via the main

security entrance

Employees to move to the emergency assembly

area in an orderly manner

Step 3 Step 6

Emergency Coordinators will ensure that all

personnel including visitors and contractors are

diverted out the Site towards the assembly area

Roll call will be undertaken

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Annexure A- Evacuation Routes, Emergency Exits

& Fire-Fighting Equipment

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Annexure B- Self Assessment on Fire Extinguisher Use

P-A-S-S

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Annexure C- Fire Evacuation Standby Card

FIRE AND EVACUATION – STANDBY CARD

IF YOU SEE OR SUSPECT A FIRE REMEMBER R-A-C-E 1. REMOVE anyone in immediate danger. 2. ACTIVATE nearest Fire Alarm or DIAL 102 DIAL 102 and state “FIRE”, giving exact location and type of fire. If using a mobile phone, dial 112. Speak Clearly, Stay Calm 3. CONTAIN fire by closing doors (if it is safe to do so). 4. EXTINGUISH the fire (only if safe to do so, DO NOT put yourself at risk). If the fire is uncontrollable – EVACUATE IMMEDIATELY! On the sounding of the fire alarm: Leave the Site immediately via the nearest escape route. Report to your designated assembly area. Remain at the assembly area until the “ALL CLEAR” is given by either the Fire/Emergency Services or Trigen Group (Pty) Ltd Senior Management.

EMERGENCY PROCEDURES

NB- Standby Card to be printed and issued to all employees!!

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Annexure D- Roll Call Registers

EMPLOYEE NAME CONFIRMED AT

ASSEMBLY AREA-

YES/NO

DATE EMPLOYEE

SIGNATURE


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