This section of the EMPr provides management principles for the decommissioning phase of the project associated with HK3, 4, 5 and associated infrastructure. Environmental actions, procedures and responsibilities as required during the decommissioning phase are specified. Table 1 provides the management measures to be implemented during the decommissioning activities.
Table 1: Impact and Mitigation Measures in Decommissioning and Closure Phase POTENTIAL
ENVIRONMENTAL IMPACT (NATURE OF THE IMPACT)
RECOMMENDED MITIGATION MEASURES
Management and Mitigation Measures Timeframes Responsibilities
General Best-Practice Measures 1. General
Best-Practice
❖ Any temporary storage, lay-down areas or accommodation facilities to be setup in existing built-up areas or disturbed areas where possible.
❖ Ensure small footprint during decommissioning phase.
❖ Regulated area to be strictly controlled in terms of development and movement of people and vehicles in and through it.
❖ All hazardous materials must be stored appropriately to prevent these contaminants from entering the water environment;
❖ All excess materials brought onto site for decommissioning to be removed after decommissioning.
❖ If possible, only existing access roads may be used to and from decommissioning site (study area).
Prior to the
29
❖ Temporary access roads to be rehabilitated after the decommissioning phase.
❖ No pedestrian or vehicular access shall be allowed to such fenced areas.
❖ In places where temporary fencing is required, the Contractor shall erect such fencing when and where required and re-erect and maintain temporary fencing as necessary. Temporary fencing shall remain in position either until it is replaced by permanent fencing or until completion of the works.
3. Ablution Facilities ❖ Provide sufficient ablution facilities (e.g. mobile/portable/VIP toilets) at the decommissioning camp/ decommissioning sites, which conform to all relevant health and safety standards and codes.
❖ Existing ablution facilities will be utilised on site as far as possible.
❖ A sufficient number of toilets shall be provided to accommodate the number of personnel working in any given area.
❖ All staff to use the provided toilets at all times. All temporary/portable/mobile toilets shall be secured to the ground to prevent them from toppling over due to wind or any other cause.
❖ All sanitary fees that may be payable to any local authority shall be paid by the Contractor.
Continuously. ❖ Contractor to
implement
30
❖ Ablutions are to be cleaned/emptied on a regular basis, before they are full and contaminate the environment.
❖ The entrances to the toilets will be adequately screened from public view.
❖ Sanitary hygiene bins will be provided for female staff.
❖ Toilet paper shall be provided.
❖ The Contractor will ensure that no spillage occurs when the toilets are cleaned or emptied and that a licensed service provider removes the
❖ The contractor should make sure that all the decommissioning vehicles and equipment should be well maintained and serviced regularly to reduce level of noise.
❖ Decommissioning working hours and other noise generating activities should be restricted to between 06h00 and 18h00 on Mondays to Fridays, unless otherwise approved by the appropriate competent person in consultation with adjacent landowners/affected persons and ECO. An exception to this will be during the blasting of HK 4 stack which is schedule to occur on Sunday morning to limit traffic disruptions.
❖ All decommissioning vehicles and equipment are to be kept in good repair to reduce operational noise levels.
❖ Where possible, stationary noisy equipment (for example compressors, pumps, pneumatic breakers,) should be encapsulated in acoustic
On-going ❖ Project Manager.
❖ EO/ECO
31 covers, screens or sheds. Proper sound insulation can reduce noise by
up to 20 dB(A).
❖ Noisy decommissioning activities, are to be confined to reasonable hours during the day. No noisy decommissioning activities are to be undertaken at night.
❖ Should PPC receive complaints from adjacent landowners, noise monitoring must be undertaken to ensure that they are within the SANS limits for the site.
❖ Machines in intermittent use should be shut down in the intervening periods between work or throttled down to a minimum.
❖ Vehicles should not be allowed to idle for more than 5-minutes when not in use.
❖ All equipment is to be well maintained and fitted with appropriate noise abatement measures.
❖ The typical rating levels for noise in districts must be adhered to which in this case is: Industrial District with Rating level of 70 dBA day and night.
❖ The residual noise level of any other nearby or affected noise district must not be exceeded by 5dBA or more as per regulation 4(3).
❖ In general, operations should meet the noise standard requirements of the Occupational Health and Safety Act (Act No 85 of 1993).
Decommissioning staff working in areas where the 8-hour ambient noise levels exceed 7 dB(A) should wear ear protection equipment.
32
❖ If noise levels associated with decommissioning material handling activities are deemed as too high, mechanisms to reduce noise levels must be investigated.
❖ A materials handling drop height policy should be maintained onsite. All equipment operators should be trained in the policy such that drop height reduction is implemented to reduce noise generation during decommissioning operations.
❖ Encouraging the receipt of materials during non-peak traffic hours to avoid traffic build-up and associated noise.
❖ Any noise complaints should be directed to site management.
Complaints and any actions arising from a complaint must be recorded in a complaint’s register to be maintained by site management. An investigation should be undertaken to determine the specific activities and/or equipment / machinery which is generating the nuisance noise resulting in the noise complaints.
Blasting Activities associated with HK4 stack
❖ Barricade and erect safety signage around the blasting area associated with the HK4 stack blasting requirements.
❖ Implement a 200m exclusion zone for the required blasting activities.
❖ Notify the surrounding community at least a week before, of the planned date and time of the blasting activities. Blasting activities to be scheduled on a Sunday morning.
33
❖ Vehicles and machinery are to be kept in good working order and meet the manufacturer’s specifications. Should excessive emissions be observed, the contractor is to have the equipment seen to within 24 hours.
❖ Wetting of the area surrounding the blast and within the blast radius should be sprayed beforehand to reduce dust from previous operations from becoming airborne.
❖ If any visible emissions are present, it is recommended that material be wetted by the spraying of water.
When applicable ❖ Contractor
❖ EO/ECO
Road Safety
6. Access and Traffic. ❖ Site access should be controlled and no unauthorized persons should be allowed onto the site.
❖ Any clearing for access or haul roads outside the demarcated works area shall only be undertaken after approval from the Project Manager/Engineer.
❖ The Contractor must comply with all driving, vehicle, licensing and driver ability requirements.
❖ Permission required from the Project Manager for the movement of any vehicles and/or personnel outside of designated working areas for decommissioning purposes.
❖ Contractor to ensure safe access for adjacent landowners on all roads.
❖ The Principal Contractor shall organise the site in such a manner that pedestrians and vehicles can move safely and without risks to health,
Ongoing ❖ Project Applicant –
34 including sufficient and suitable traffic routes and safe walkways with
relevant signage.
❖ Appropriate warning traffic signs, in accordance with the South African Road Traffic Signs Manual, should be erected to protect road users on the approaches to the sharp curves and the access road junction.
Temporary signs should be erected on the approaches to the access road junction warning motorists of heavy vehicle traffic during the decommissioning activities being undertaken.
❖ Any maintenance of the access roads required due to the decommissioning activities, must be collectively implemented by the applicants in agreement with the Local Municipality.
❖ All vehicles and machinery must abide by the relevant speed limits of the roads that they travel on, at all times
Social and labour impact 7. Management of
Labour Force.
❖ Prevent trespassing of decommissioning workers onto private property.
❖ Decommissioning workers must be provided with identity cards and must wear identifiable clothing and remain within the working servitude for the project.
❖ Creating nuisances and disturbances in or near communities shall be prohibited.
❖ Machine/vehicle operators shall receive clear instructions to remain within demarcated access routes and decommissioning areas.
❖ Designated and demarcated smoking areas should be provided, with special bins for discarding of cigarette butts.
On-going ❖ Project Applicant –
35
❖ Training of labour to benefit individuals beyond completion of the project.
Visual 8. Visual Aesthetics. ❖ Maintain a clean and neat site.
❖ Ensure good housekeeping – undertake daily checks of the site with appropriate clean up actions where needed.
On-going ❖ Contractor
❖ EO/ECO.
Waste management 9. Windblown litter -
nuisance conditions.
❖ Store general wastes in a designated area, designed to prevent wind-blown litter
❖ Ensure that all general waste and building rubbles is removed and disposed of at a licensed general waste disposal site
❖ During
❖ All waste produced during the decommissioning should be removed as soon as possible and disposed of at a registered Landfill Site (or an alternative appropriate landfill site).
❖ The waste must be stockpiled in a designated area within the PPC Hercules property and transported to the nearest registered landfill facility on a regular basis. Records of disposal must be kept on file.
❖ All decommissioning materials should be stored in designated areas.
❖ No dumping of decommissioning waste of excess decommissioning materials will be allowed in any areas surrounding the decommissioning site.
36 the surrounding
environment.
❖ Chemical toilets are to be maintained in a clean state and serviced on regular basis. The contractor is to ensure that the surrounding land is not being used as an ablution facility.
❖ Appropriate disposal facilities, such as litter bins, must be provided within the decommissioning camp. All disposal facilities will need to be clearly labeled.
❖ Bins and/or skips must be emptied regularly and waste must be disposed of at a registered landfill site.
11. Dust generation and associated ambient
Kindly refer to Section 6 of the EMPr for the Dust Management Plan to be implemented for the project (to be amended as required). A summary of the required measures for implementation are provided below:
❖ Employees to wear appropriate PPE gear on site and whilst engaged in required site cleaning and decommissioning activities;
❖ The equipment on site to be cleaned (manually) of all excess sand/dust prior to relocation to the new site, where material is planned to be reused;
❖ Avoid washing any sand on site, or allow flow into the connected stormwater channels; and
❖ Light misting or alternative palliative techniques to be utilised during cleaning activities where required.
❖ Daily ❖ Contractor
❖ Checked by
EO/ECO
37 Heritage Resources
12. Destruction of heritage resources identified on site during planned decommissioning activities.
Kiln 3, the Edgar Allen Mill, the Unidan mill and auxiliaries will require a Phase 2 survey and recording and a destruction permit from PHRA-G before demolition can take place.
❖
Pre-decommissioning
❖ Contractor
❖ Project Manager.
❖ EO/ECO
38