ENVIRONMENTAL COMPLIANCE AUDIT REPORT - Scaw

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ENVIRONMENTAL COMPLIANCE AUDIT REPORT PROJECT NAME: Decommissioning of Scaw Metals Dimbaza Foundry PROJECT NO: J2015-08 REPORT NO: 03 DEDEAT REF: EC/11/A/LN1/27 (iv)/13-08 DATE: 16/03/2016

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Indwe Environmental Consulting CC 12 Preston Avenue• Vincent • East London • 5247 www.indwecon.co.za Tel: 043 726 6860 Fax: 086 513 9734 Email: [email protected] Company Registration No.: 2006/074394/23 _____________________________________________________________________

Decommissioning of Scaw Metals Dimbaza Foundry Environmental Inspection Audit Report

Audit Report No: 03

Contents

Chapter Description Page

1 INTRODUCTION - 3 -

1.1 ECO Reporting Requirements - 3 -

2 REPORT NO: 03 - 4 -

2.1 Aspects Inspected - 4 -

2.2 Summary of level of Contractors Compliance to EMPr - 4 -

2.3 Non-Compliance - 4 -

2.4 Partial Compliance - 4 -

2.5 Decommissioning Activities - 4 -

2.6 Positive Aspects - 5 -

2.7 Future Expectations - 5 -

2.8 Conclusion - 5 -

3 AUDIT CHECKLIST - 6 -

3.1 Administration - 6 -

3.2 Site Camp - 7 -

3.3 Work Areas - 9 -

3.4 Close Out - 13 - APPENDIX A Supporting Photographs APPENDIX B Distribution Register

Decommissioning of Scaw Metals Dimbaza Foundry - ECO Audit 03

1 INTRODUCTION

Scaw South Africa (Pty) Ltd appointed Indwe Environmental Consulting as an independent Environmental Control Officer (ECO) to monitor compliance with the Environmental Authorisation and Environmental Management Programme (EMPr) compiled for the Decommissioning of the Dimbaza Foundry located in Dimbaza, King Williamstown, Eastern Cape.

1.1 ECO Reporting Requirements

Section 3.1 of the Environmental Authorisation stipulates that the applicant must appoint an independent Environmental Control Officer to monitor compliance with the conditions of authorisation. Section 4 of the Environmental Authorisation states that the ECO must conduct monitoring sessions to ensure compliance with the conditions of authorisation, as well as the Environmental Management Programme prepared for this project. These monitoring sessions must take place on a quarterly basis and the audit reports must be submitted to the Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) at the end of each quarter.


2 REPORT NO: 03

2.1 Aspects Inspected

The EMPr and Environmental Authorisation contain a host of conditions and specifications. Only those relevant to the current decommissioning activities were audited, the rest were marked as not applicable (Refer to audit checklist below). 2.2 Summary of level of Contractors Compliance to EMPr

Based on observations made during the site visit 100% of the planning phase aspects and 100% of the construction phase aspects audited were compliant. It is evident that Scaw has continued to be vigilant and meticulous to the environmental aspects and compliance of this project.

2.3 Non-Compliance

There were no non-compliance evident or any issues identified during this site inspection.

2.4 Partial Compliance

None

2.5 Decommissioning Activities The decommissioning activities inspected during this audit included: • The safe removal of asbestos sheeting. • The removal of waste contained in the pits. • The cleaning of pits that contained waste. • The decommissioning of steel structures. • The disassembly of electrical transformers.

SITE INSPECTION DETAILS Date: 16/03/2016 Report No: 03 Project: Decommissioning of Scaw

Metals Dimbaza Foundry Client: Scaw Metals

Phase: Decommissioning & Cleaning Present: Indwe ECO (Mr Blake Edwards) Scaw Metals (Mr Jake Venter)


2.6 Positive Aspects

• Scaw have been brilliant with their understanding of the EMPr and its environmental processes. • The site has been kept free of any waste, all solid waste has been either placed in bins or

contained and temporarily stock piled until collection and disposal. • All documentation and records including proof of adequate waste collection and disposal has

been filed and kept in the environmental file in the site office. 2.7 Future Expectations

• Scaw are expected to maintain a 100% level of compliance throughout the decommissioning

phase of the project.

2.8 Conclusion

Scaw have 100 % complied with the EMPr and Environmental Authorisation for this audit and must be commended on their continued compliance level.


3 AUDIT CHECKLIST

3.1 Administration

DECOMMISSIONING PHASE - ADMINISTRATION

1. Environmental File Yes

Part

ial

No

N/A

Observations Corrective Action

• Site Plan Layout. X • The Environmental file has been kept up to date.

• EMPr. X • Permits & Environmental

Authorisation. X

• Method Statements. X • Community Complaints

Register. X

• Emergency Incidents Register

X

• Audit Reports. X • Environmental

Correspondence. X

• Minutes of Meetings. X • Emergency Response Plan

compiled and on site. X

TOTAL: 10 10


2. Environmental Control Officer Ye

s

Part

ial

No

N/A


• Appointment of ECO x

• Written notice to DEDEAT. x TOTAL: 02 2


3. Environmental Induction & Training

Yes

Part

ial

No

N/A


• Contractor EMPr induction. X

• Contractor’s personnel environmental awareness training toolbox talks

X

• Record of environmental training.

X

TOTAL: 03 3


3.2 Site Camp

DECOMMISSIONING PHASE – SITE CAMP

1. Site Camp Establishment

Yes

Part

ial

No

N/A


• Appropriate Site Access. x

• Adequate Signage (i.e. Site entrance, emergency numbers, first aid, fire extinguishers).

x

• Adequate Fencing/ Gates/Security.

x

TOTAL: 03 3


2. Solid Waste Management

Yes

Part

ial

No

N/A


• Litter in site camp. X

• Burning or burying of waste. X • Scavenger proof waste bins. X • Waste collection and

disposal. X

• Documentation for waste collection and disposal.

X

TOTAL: 04 4


3. Hazardous Material & Waste Management

Yes

Part

ial

No

N/A


• Neatness of hazardous material storage area.

X

• Diesel tank adequately bunded.

X

• Sufficient drip trays & use of drip trays.

X

• Sufficient hazardous waste spill kits.

X

• Hazardous waste drums. X • Hazardous material spills &

clean-up. X

• Hazardous waste collection and disposal.

X


X

TOTAL: 08 8


4. Sanitation

Yes

Part

ial

No

N/A


• Sufficient toilets available for both men & woman.

X

• Chemical toilets anchored. X


• Toilets clean and regularly serviced.

X

• Documented proof that the chemical toilets are regularly serviced.

X

TOTAL: 04 4


3.3 Work Areas

DECOMMISSIONING PHASE – WORK AREAS

1. Decommissioning Footprint

Yes

Part

ial

No

N/A


• Site plan demarcating the physical extent of the works.

X

• Adequate demarcation of the work areas.

X

• Decommissioning activities contained within work areas.

X

TOTAL: 03 3


2. Access to Work Areas

Yes

Part

ial

No

N/A


• Adequately demarcated & sufficient signage.

X

• Public protection. X • Access control. X

TOTAL: 03 3


3. Solid Waste Management

Yes

Part

ial

No

N/A


• Litter in work area. X • Burning or burying of

waste X

• Is there a central waste storage area and is it well managed.

X

• Are there sufficient scavenger proof waste bins with lockable lids.

X

• Waste collection and disposal to registered landfill site.

X


X

• Waste separation into different waste categories (i.e. general waste, hazardous waste, inert rubble).

X

• Recycling & Reuse of waste x • Inert Material used for fill. X • Fill adequately compacted. X

TOTAL: 10 9 1


4. Hazardous Waste Management

Yes

Part

ial

No

N/A


• Hazardous waste from x


Area 2 disposed directly as a Type 1 waste to a suitably licensed Class A/H:H Landfill site.

• Hazardous waste from Area 2 treated with lime and disposed of as a Type 4 waste to a suitably licensed Class D or GLB landfill site.

X

• Hazardous waste from within the foundry area appropriately handled and correctly disposed of.

X

• Documented proof of hazardous waste disposal.

X

• Sufficient drip trays & use of drip trays.

X

• Hazardous material spills & clean-up (i.e. pollution of topsoil and watercourses).

X

• Was DEDEAT informed within 24 hours of spill.

X

• Was clean-up conducted within 12 hours of spill.

X

• Servicing of machines and equipment outside of designated area.

X

• Hazardous waste adequately stored at temporary storage area prior to removal and disposal.

X

TOTAL: 10 5 5


5. Sanitation

Yes

Part

ial

No

N/A


• Sufficient toilets within work areas.

X

• Chemical toilets anchored. X • Toilets clean and regularly

serviced. X

• Documented proof that the chemical toilets are regularly serviced.

X

TOTAL: 04 4


6. Noise & Vibration Management

Yes

Part

ial

No

N/A


• Noise levels within reasonable norms.

X

• Surrounding business and residential areas informed of the timeframe for decommissioning.

X

• Community complaints. X • Appropriate work hours. X • Silencers on machinery and

vehicles maintained. X

TOTAL: 05 5



7. Dust Control

Yes

Part

ial

No

N/A


• Adequate dust control measures timeously implemented.

x

TOTAL: 01


8. Culture & Heritage

Yes

Part

ial

No

N/A


• Have archaeological or paleontological items been detected.

x

• Has ECPHRA been informed x TOTAL: 02 2


9. Topsoil Management

Yes

Part

ial

No

N/A


• Topsoil adequately removed from work areas.

X

• Topsoil adequately stockpiled (i.e. does not exceed 2m high, no damming of water, no wind/soil erosion).

X

• Topsoil mixed with subsoil or building rubble.

X

• Topsoil stockpiles dampened during dry conditions.

X

• Driving of vehicles or heavy plant on topsoil stockpiles.

X

TOTAL: 05 5


10. Spoil Stockpiles

Yes

Part

ial

No

N/A


• Spoil material adequately stockpiled (i.e. dedicated area, no damming of water, not mixed with topsoil).

X

• Spoil material removed and appropriately disposed of.

X

• Appropriate areas for spoiling oversized material.

X

TOTAL: 03 3



11. Erosion Management

Yes

Part

ial

No

N/A


• Practical anti-erosion measures timeously implemented and maintained.

X

• Stormwater control measures implemented.

X

TOTAL: 02 2


12. Rehabilitation & Landscaping

Yes

Part

ial

No

N/A


• Shaping and re-vegetation of disturbed surfaces immediately implemented once decommissioning activities are completed.

X

• Rehabilitated areas adequately merge with surrounding environment.

X

TOTAL: 02 2


3.4 Close Out

DECOMMISSIONING PHASE – CLOSE OUT

1. Site Camp

Yes

Part

ial

No

N/A


• All site camp structures removed from site (i.e. containers, fences, building material, spoil material).

X

• Hazardous substance spills cleaned up and appropriately disposed of.

X

• Hardened surfaces ripped, foreign materials removed, topsoil layer replaced and shaped.

X

• Rehabilitated area adequately merges with surrounding environment.

X

TOTAL: 04 4

DECOMMISSIONING PHASE – CLOSE OUT

2. Work Area

Yes

Part

ial

No

N/A


• Decommissioned footprint rehabilitated to appropriate vegetative state.

X

• Area 2 hazardous waste removed and disposed of.

X

• Area 2 rehabilitated. X TOTAL: 03 3


APPENDIX A

SUPPORTING PHOTOS

Figure 1 An area where Asbestos roof sheeting has been removed.

Figure 2 The safe storage area of flamable gas.


Figure 3 Areas where fiberglass sheeting has been removed

Figure 4 Bi-product that has been stockpiled awaiting collection

Figure 5 The dissasembly of an electrical transformer.

Figure 6 The Deisel storage area has been kept clean.


APPENDIX B

DISTRIBUTION REGISTER

FIRST NAME SURNAME ORGANISATION ROLE EMAIL Jake Venter Scaw Metals Site

Manager [email protected]

Briant Noncembu DEAET Regional Manager

[email protected]

ENVIRONMENTAL COMPLIANCE AUDIT REPORT - Scaw

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