5. OPERATIONAL ENVIRONMENTAL MANAGEMENT PLAN
5.2 OPERATIONAL ENVIRONMENTAL MANAGEMENT SPECIFICATIONS:
EMERGENCY PLAN
Management Statement and objective: To prevent incidents, guide the way in which emergencies and/or environmental incidents are handled on site and remediate any damage appropriately.
Impact Management Outcomes: No non-conformances, no injuries and no adverse impacts on the environment as a result of emergency situations and/or environmental incidents.
• An Emergency Plan must be compiled before operations commence on site, and the following must
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be included (Thackwray, 2021):
o The Plan must address the risks of the various scenarios that were discussed in the MHI report;
o The Plan must comply with SANS 1514 Codes; and o The Plan must comply with the MHI Regulations.
• The Emergency Plan must be accepted and signed by Management and the Local Authority.
• Risk reduction programmes should continually be investigated to reduce the impact from accidental fires and explosions on surrounding communities (Thackwray, 2021).
• The following levels of Government need to be notified prior to the installation of the MHI (Thackwray, 2021): Department/ emergency services (Local Authority). Proof of receipt needs to be obtained from the Local Authority;
▪ Copy of the MHI Risk Assessment, along with a cover letter notifying the Provincial Director from the Provincial Department of Labour. A proof of receipt needs to be obtained from the Provincial Department of Labour; and
▪ An advert needs to be placed in a local newspaper informing the public about the MHI. The information that needs to be included in the advert is as follows:
➢ Physical address of the MHI;
➢ Maximum quantity of the substance that resulted in the installation being classified as an MHI;
➢ Contact person where more information can be obtained;
➢ Notify the public that they can comment/ object to the installation with the Department of Labour or the Local Authority;
➢ Expiry date of the 60-day commenting period;
➢ Copy of the MHI, along with a cover letter notifying the Chief Inspector from the National Department of Labour.
➢ Copies of proof of receipts and a copy of the advert must be included
• The MHI Risk Assessment must be reviewed after five years, unless:
o Changes have been made to the plant that can alter the risks on the facility;
o The Emergency Plan was invoked or there was a near miss;
o The changing neighbourhood could result in offsite risks; or
o There is reason to suspect that the current Assessment is no longer valid (Thackwray, 2021).
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WATER USE MANAGEMENT PLAN
Management Statement and objective: To facilitate the efficient use of water resources on the site.
Impact Management Outcomes: No water wastage.
• Collect rainwater off the roofs of the buildings and store the water in rainwater tanks for irrigation purpose (Steytler & Mugabe, 2021).
• Grey water should be recycled.
LEAK DETECTION AND MONITORING OF USTs
Management Statement and objective: To prevent fuel contamination of the environment.
Impact Management Outcomes: No contamination to the environment.
• It is required to undertake integrity testing on Underground Storage Tanks (UST’s) and pipework (or both). Testing shall be carried out prior to burial of the installation;
o When ownership of the UST and associated underground pipework changes;
o When leak detection monitoring methods that may be in place, such as Stock Inventory Reconciliation Analysis, Automatic Tank Gauging (with a reconciliation facility) or interstitial vapour or liquid monitoring of double-walled or jacketed steel tanks, indicate the possibility of a leak. In this instance, an investigation into the possible leak, including integrity testing in the final stages of the investigation, shall be used to track the reasons for a failure to reconcile; and
o Where continuous leak detection monitoring, such as Stock Inventory Reconciliation (SIR), is not carried out at a site. In this instance, UST and associated underground pipe integrity testing should be carried out every 2 years. If USTs and underground pipes do not operate with a continuous leak detection system, but do have cathodic protection installed, then this period may be extended to 10-year intervals.
• USTs are to be fitted with a monitoring tube to allow for the monitoring of leaks through the tank surface (Naicker & Muller, 2021).
• Leak detectors are to be installed to the submersible pumps within UST manholes to ensure that there are no line leaks (Naicker & Muller, 2021).
• A relatively inexpensive soil vapour monitoring installation must be installed which can be monitored on a frequent basis (monthly intervals) using a Photo Ionisation Detector (PID) e.g., Mini RAE 2000 (Naicker & Muller, 2021).
• The installation of Soil Vapour Sampling Points will require the placement of a permeable coarse clean sand layer beneath the storage tanks for a vertical depth of approximately 0.5 m to 1 m in order to locate the vents in the 16 mm diameter monitoring pipe over portion of this depth Naicker & Muller, 2021)..
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• The wash bays must use recycled water (subject to detail design and viability).
• Given the presence of an historical domestic waste body at depth beneath the site, and proximity to a wetland, the abstraction of groundwater at the site for any use is prohibited.
• Repair dripping faucets and any water leaks immediately upon detection.
• Employees must be encouraged to report leaks and be trained on the importance of water efficiency.
• Gardens and landscaped areas should be watered before 10h00 and after 16h00. Watering of gardens and landscaped areas should occur a maximum of four times per week.
• Water restrictions as imposed from time to time by the local authority By-Laws must be adhered to.
• A water awareness programme should, where possible, be implemented within the development (e.g. notifications in rest rooms to use water sparingly).
•
SOLID WASTE MANAGEMENT PLAN
Management Statement and objective: To prevent pollution associated with the generation and temporary storage of general waste, hazardous waste and litter generated by the workforce on site.
Impact Management Outcomes: No non-conformances and no pollution of soil, groundwater and/or stormwater as a result of waste generation and management activities.
• General waste generated during the operational phase will comprise typical domestic waste generated by administrative and housekeeping operations as well as waste associated with convenience stores and take-away food outlets, such as paper, lunch wrappers, packaging material etc. The hazardous waste will comprise of empty oil cans / tins, oily rags, spent fluorescent tubes, etc.
• An integrated waste management system must be implemented, and this must be underpinned by the following waste management hierarchy:
• All general waste material (e.g. non-hazardous waste) should be contained in lined general waste bins.
• Ensure that all litter bins and solid waste storage areas within the depot are weather-proof (i.e., designed to prevent waste from being blown away by wind) (Steytler & Mugabe, 2021).
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SOLID WASTE MANAGEMENT PLAN
• Regularly (at least weekly) inspect the depot site for evidence of wind-blown solid waste and collect any waste encountered and dispose of the waste into the weather-roof bin and/or waste storage area (Steytler & Mugabe, 2021).
• Dedicated recycling bins must be implemented during the operational phase of the depot.
• Any hazardous waste will be stored in separate lined waste bins. The bins would be marked as hazardous and flammable.
• Hazardous waste will be removed by a suitable contractor or transported to an appropriate licensed hazardous landfill/waste facility.
• Note that hazardous waste volumes are not to exceed 20kg per day.
• Any spilling or leakage of product into the soil and/or water courses (e.g., hazardous substances used during the Construction or Operational phase) must be reported to all relevant authorities, including Department of Environmental Affairs and Development Planning: Pollution Management, within 14 days. This requirement is in terms of Section 30 (1OJ of the National Environmental Management Act, No. 107 of 1998 (NEMA) and Section 20 (3) of the National Water Act, No. 36 of 1998 (NWA) that pertains to the control of emergency incidents and should include the reporting, containment and clean-up procedure of such incident and the remediation of the affected area.
All necessary documentation must be completed and submitted within the prescribed timeframes.
Containment, clean-up and remediation must commence immediately.
• Durable building materials to increase the lifespan of the developments must be used.
• Low VOC paints & building materials must be used
PROTECTION OF SOIL, GROUNDWATER & FRESHWATER RESOURCES
Management Statement and objective: To ensure the on-going protection for local soil, groundwater, and freshwater, including stormwater systems.
Impact Management Outcomes: Zero pollution or contamination of the soil, groundwater, and freshwater resources on and off-site.
• A Stormwater Management Plan that is compliant with the CCT Management of Urban Stormwater Impacts Policy (2009) must be implemented (Steytler & Mugabe, 2021).
• Maintenance is considered key to ensure the proposed stormwater drainage system functions correctly. Permeable paving (which is the recommended option) should be maintained as per the manufacturer, which shall include regular sweeping to keep the openings clear. Failure to do so will compromise the detention pond functionality (Saunders et al. 2021).
• To ensure that the storm water drainage and management system performs optimally, it is necessary to perform regular maintenance. The following maintenance schedule should be carried out at least once per year, and at more regular intervals where specified, preferably at the start of the rainy season in May (Saunders et al. 2021):
o Conduit / Road Drainage Network Inspect and clean pipe reaches, catchpits, manholes and headwalls of silt and litter. It is recommended that street sweeping, and litter removal be carried out on a regular basis, during the course of the year to minimise debris entering the underground conduit drainage network.
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PROTECTION OF SOIL, GROUNDWATER & FRESHWATER RESOURCES
o Grassed Channels and Swales Inspect grassed channels and swales once every three months and mow the grass if required. Remove all litter during the monthly inspections.
o Permeable Paving Permeable paving shall be maintained as per the Manufacturer’s guidelines.
o Detention Facilities.
o The following checklist should be used when carrying out inspections:
o Pond Walls o Inlet and Outlet Structures and Headwalls
▪ Free of debris
▪ Undesirable vegetative and/or woody growth
▪ Standing water or wet spots
▪ Sediment and/or trash accumulation o Wet Pond Area
▪ Adequate vegetative cover
▪ Undesirable vegetative and/or woody growth
▪ Sediment and/or trash accumulation o Other
▪ Aesthetics - re-grassing
▪ removal of graffiti / illegal signboards
▪ Condition of maintenance access
▪ Public hazards
▪ Other
• All containment manholes must be regularly inspected as part of the normal management procedures at the service station (Naicker & Muller, 2021).
• Regarding the pipework and USTs, any repair work required is to be conducted according to SABS 1535 (Glass-reinforced polyester-coated steel tanks, including jacketed tanks, for the underground storage of hydrocarbons and oxygenated solvents and intended for burial horizontally) (Naicker &
Muller, 2021).
• No spillage/leakage is allowed to emanate from the culverts and regular maintenance should take place (Naicker & Muller, 2021).
• The containment slab must be graded to drain a catchpit that is connected to discharge to the stormwater system via an oil separator while the surrounding paved surface areas must be graded to ensure rainwater runoff discharges to the stormwater system. No washing in this area is allowed
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PROTECTION OF SOIL, GROUNDWATER & FRESHWATER RESOURCES (Naicker & Muller, 2021).
• A pollution containment chamber is necessary to drain into, i.e., an approved oil/water separator system. Once the wash water has passed through the system, the separated oil must be collected regularly by an approved waste contractor and removed to an approved hazardous waste disposal facility (Naicker & Muller, 2021).
• Spray Booths:
o The spray booth (a closed system) and workshops should be impervious to the ground and fitted with separate appropriately designed drainage.
o Any water emanating from the spray booth and workshops, including cleaning activities should be channelled to where the water is treated before discharged.
o Care should be taken to ensure there are no oil/fuel leaks from buses prior to entry and exit of the spray booth and workshops.
o As far as possible the chemical agents used at the spray booth (including cleaning) should be environmentally friendly and bio-degradable, in efforts to reduce the potential impact should spills occur (Naicker & Muller, 2021).
• Wash Bays:
o As far as possible the cleaning agents used in the washing of the buses should be environmentally friendly and biodegradable (Naicker & Muller, 2021).
• Drip and spill trays should be utilized at the parking areas where buses are parked for periods of time to ensure any oil/other leaks are captured (Naicker & Muller, 2021).
• Any oil/other chemicals emanating from parked buses should be appropriately disposed of with contaminant products from the oil separator/treatment (Naicker & Muller, 2021).
• Washing of the paved bus parking area should be done so in a manner which allows for all liquid to be captured in the stormwater management infrastructure on site that is channelled for treatment and separation (Naicker & Muller, 2021).
• Any surface-water run-off that has been treated can be considered to be discharged into the unpaved areas for recharge, however, the quality of this water must be tested frequently to ensure treatment efficiency and avoid contamination of the aquifer (Naicker & Muller, 2021).
• Observation wells must be installed in the sand fill surrounding the underground storage tanks for regular groundwater monitoring purposes (Naicker & Muller, 2021).
• All containment manholes must be regularly inspected as part of the normal management procedures at the service station (Naicker & Muller, 2021).
• Continuous electronic monitoring (CEM) of product must be carried out. Should discrepancies occur an alarm will be triggered, and site management will review the finding and take appropriate action to rectify the situation as required (Naicker & Muller, 2021).
• Should a leak be found or should the groundwater in the monitoring wells be found to be contaminated with hydrocarbons, a baseline Phase 1 Contamination Assessment should be undertaken, and the site remediated in consultation with a contamination remediation consultant and the Authorities (Naicker & Muller, 2021).
• In terms of Groundwater Monitoring:
o At least four groundwater monitoring boreholes should be installed in order to detect
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PROTECTION OF SOIL, GROUNDWATER & FRESHWATER RESOURCES any potential contamination.
o The monitoring boreholes should be drilled to a depth 15 m. Monitoring boreholes should follow the specifications provided in the construction phase section of this report.
• Pollution of the soil (ground) as a result of any leakage from the fuel storage tanks will cause the area to be considered “as contaminated land”. If any remediation is to take place, note that the contaminated soil will be registered as hazardous waste and must then be treated or disposed of in compliance with the National Environmental Management: Waste Act (Act No.59 of 2008) (NEM:WA), as amended.
• The relevant authorities will need to be notified immediately if such a spill does occur.
• The Groundwater Monitoring Action Plan below must be followed.
Groundwater Monitoring Action Plan (as provided in Naicker & Muller, 2021):
• Boreholes as located and design in terms of Figure 13Figure 14 and Table 6 must be monitored.
• Groundwater levels
Groundwater level measurements are recommended for the monitoring borehole at the study site. A dip meter can be used to measure the water level below the top of the borehole collar/casing height (mbch). The height of the collar/casing height must then also be measured (m). The water level (metres below ground level (mbgl)) can then be calculated by subtracting the collar/casing height from the water level (mbch). The value must be recorded along with the date and time of measurement.
• Sampling process
It is preferable to use a low volume sampling pump in most monitoring boreholes or a bladder pump.
• Sample collection, preservation and submission
Sample bottles must be labelled with the borehole name, site name and date. At the time of sampling field, chemistry parameters must be measured and recorded. These include electrical conductivity (EC), oxidation reduction potential (ORP), pH, temperature and dissolved oxygen (DO). Samples must be taken in their correct sampling container and preserved in the correct manner prior to submission to an accredited laboratory for the analysis parameters. The sample method and preservation must be discussed with the laboratory prior to sampling.
• Sampling frequency and parameter analysis
In order to best understand and monitor the site, it is recommended that quarterly water level measurements be taken (to determine seasonal fluctuation). It is however, considered adequate for boreholes to be sampled bi-annually. Table 7 indicates the potential parameters for ongoing monitoring.
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PROTECTION OF BOTANICAL RESOURCES & LANDSCAPING
Management Statement and objective: To prevent loss of significant botanical resources and to encourage further biodiversity on and around the site.
Impact Management Outcomes: Improvements to biodiversity on and around the site.
• All depot areas must be clearly bordered and fenced in to prevent encroachment into areas not required (Altern, 2021).
• No NEMBA listed invasive alien plants shall be allowed to establish on the site (Altern, 2021). The applicant, and in turn, the operator of the depot, must be responsible for controlling alien invasive plants within the proposed depot in accordance with best practise methods for the identified species (Steytler & Mugabe, 2021).
• No run-off (polluted or not) must be allowed to leave the site into bordering vegetated areas (Altern, 2021).
• Implementation and compliance to the approved Landscape Management Plan for the project.
• The abstraction of groundwater at the site for irrigation use is prohibited.
PROTECTION OF THE WESTERN LEOPARD TOAD
Management Statement and objective: To prevent loss of the Endangered Western Leopard Toad and to encourage movement across site.
Impact Management Outcomes: Zero loss of WLT.
• Employed a suitably trained individual during WLT migrations i.e., before and after breeding (late July-early sept) to check the project area for and move out of harm’s way (Jackson &
Martin, 2021).
• Check for roadkill. Preserve any individuals found and submit with GPS coordinates to SANBI at Kirstenbosch (Jackson & Martin, 2021).
• Record any individuals found as per the ToadNuts requirements and submit findings (Jackson &
Martin, 2021).
• Ensure all vehicles adhere to the relevant noise restrictions (Jackson & Martine, 2021).
• Installation of low UV emitting lights, such as most LEDs (Jackson & Martine, 2021).
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APPENDIX 1
METHOD STATEMENT TEMPLATE
METHOD STATEMENT
CONTRACT: ___________________ DATE: ___________________
PROPOSED ACTIVITY (give title of Method Statement and reference number from the EMPr):
WHAT WORK IS TO BE UNDERTAKEN (give a brief description of the works):
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WHERE ARE THE WORKS TO BE UNDERTAKEN (where possible, provide an annotated plan and a full description of the extent of the works):
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START AND END DATE OF THE WORKS FOR WHICH THE METHOD STATEMENT IS REQUIRED:
HOW ARE THE WORKS TO BE UNDERTAKEN (provide as much detail as possible, including annotated maps and plans where possible):
Start Date: End Date:
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Note: please give too much information rather than too little. Please ensure that issues such as emergency procedures, hydrocarbon management, wastewater management, access, individual responsibilities, materials, plant used, maintenance of plant, protection of natural
Note: please give too much information rather than too little. Please ensure that issues such as emergency procedures, hydrocarbon management, wastewater management, access, individual responsibilities, materials, plant used, maintenance of plant, protection of natural