appendix f public participation information: including a ... · 11th floor, utilitas building, 1...

Appendix F

Public participation information: including a copy

of the register of interested and affected parties, the

comments and responses report, proof of notices,

advertisements and any other public participation

information required in Section C above.

1) Identified interested and Affected Parties and

Organs of State notified of Application

2) Feedback from Organs of State on the Notice

of Intent to Apply (minutes and comments)

Trigen Biodigester Application, Worcester

Initial Notification Table

November 2017

ORGANS OF STATE

Department Means of Notice Date of Communication

DEA&DP Waste Directorate (Competent Authority) Waleed Galvaan 5th Floor, Atterbury House 9 Riebeeck Street Cape Town Tel: 021 483 8788 Fax: 021 483 4425 Email: [email protected]

Email and hand delivery of report

DEA&DP Development Facilitation Unit (on behalf of DEA&DP Development Management – Region 2; DEA&DP Pollution and Chemicals Management; and DEA&DP Air Quality) Adri La Meyer 11th Floor, Utilitas Building, 1 Dorp Street, Cape Town Tel: (021) 483 2887 Fax: (021) 483 4185 E-mail: [email protected]



mailto:[email protected]

Department of Water and Sanitation c/o The Breede Overberg Catchment Management Agency Elkerine Rossouw 51 A Baring Street Worcester 6845 Tel: 023 3468000 / 0716855444 Email: [email protected]

Western Cape Government: Department of Health - Environmental Health Directorate. Mr. Guillaume Olivier Brewelskloof Hospital HRD section Haarlem street Worcester Tel: 0829288467 / 0233428806 Email: [email protected]


Cape Winelands District Municipality Air Quality Officer – Marius Engelbrecht Environmental Health Practitioner – Willie Roux 51 Trappesstraat Worcester Tel: 021 888 5811 / 072 122 5680 / 023 348 2359


Fax: 021 887 9365 Email: [email protected] [email protected]

Breede Valley Local Municipality Pieter Hartzenberg, Chief Town Planner Achmad Kafaar, Air Quality Officer Civic Centre High Street Worcester 6850 Tel: 023 348 2640 / 023 348 2600 (switchboard) Fax: 023 348 2630 Email: [email protected]; [email protected]


Western Cape Department of Agriculture Cor van der Walt (Pr.Sci.Nat) Land Use Management 3rd Floor, Main Building, Elsenburg, Muldersvlei Road Tel: 021 808 5093/9 Email: [email protected]


Department of Energy Lerato April / Lebogang Nkhwashu / Pheladi Masipa Matimba House

Email





Cnr of Paul Kruger & Visagie Streets Pretoria 0002 Tel: 012 4068000 Email: [email protected] [email protected] [email protected]

Heritage Western Cape Waseefa Dhansay Protea Assurance Building Greenmarket Square Cape Town Tel: 021 483 9533 Email: [email protected]

Email

Department of Agriculture Cor van der Walt Tel: 021 808 5099

WARD COUNCILLOR, RATE PAYERS’ ASSOCIATION AND COMMUNITY REP BODIES

Erf & Address Means of Notice Date of Communication

GreenCape Sam Smout Waste Sector Desk Tel: 021 811 0250 [email protected]

Email

Ward 8 Councillor Email





Thandi Williams (Worcester Industrial, Hex Industrial, a section of Roodewal and a section of Zweletemba ) Cell phone: 0784853649 Email Address: [email protected]

Ward 7 and Ward 17 Councillor Cllr Phillip Tyra (Meirings Park, Roux Park, Re-unie Park, Paglande; a section of Zweletemba) Cell phone: 076 887 0365 / 063 541 5135 Email: [email protected]

Email

Ward 16 Councillor Cllr Mangali ( a section of Zweletemba) Cell phone: 0786256918 Email Address: [email protected]

Email

Ward 18 Councillor Cllr Mkhiwane (a section of Zweletemba) Cell phone: 0836906580 Email Address: [email protected]

Email

Resinalo Development Project Email




Contact Person: Victor Rampeng Email:[email protected] Cell No.: 0714981277

Economic Development Contact Person: S. Ngollos Email: [email protected] Cell No.: 0796434938

Email

Thiyhina Services Skills Development Contact Person: Erik Mbuyisile Email: [email protected] Cell No.: 0727919551

Email

Zweletemba Development Forum Contact Person: K Rampeng Email: [email protected] Cell No.: 0624905148

Email

Worcester Business Forum Chariman: Marco Adams [email protected] / [email protected] Communications: Christof Linde [email protected]

Email

ADJACENT LANDOWNERS

Erf & Address Means of Notice Date of Communication








Erf 350 STREEKBESTUURDER 2 LOUIS LANGE STREET WORCESTER 6850

Post

Erf 5928 PENINSULA BEVERAGE PROPERTIES (PTY) LTD 10 MC ALISTER STREET WORCESTER 6850

Post

Erf 16127 ESKOM HOLDINGS LTD TRAUB STREET WORCESTER 6850

Post

Erf 8980 WINELANDS TEXTILES PTY RAYMOND POLLET DRIVE WORCESTER 6850

Post

Erf 13518 BREEDEVALLEI MUNISIPALITEIT c/o BVM Town Planning and Environmental Health departments

Erf 6970 TRANSNET LTD AAN DE DOORNS ROAD WORCESTER

Post

6850

Erf 10387 TRANSNET LTD ABATTOIR STREET WORCESTER 6850

Post

Erf 13936 BLANFORD 006 PTY LTD 33 TRAUB STREET WORCESTER 6850

Post

Erf 16579 A P L CARTONS PTY LTD 19 ABATTOIR STREET WORCESTER 6850

Post

Erf 13531 APL CARTONS (PTY) LTD Address as above

Erf 13530 c/o BVM Town Planning and Environmental Health departments

Professional • Competent • Independent • Efficient

www.environmentalconsultants.co.za

PROPOSED ADAPTATION OF TRIGEN EFFLUENT

BIODIGESTER: RCL FOODS, WORCESTER September 2017

AGENDA

Introduction & purpose of meeting

Project & infrastructure description

Risks / impacts identified

Design and operational phase mitigation proposed

Q&A

2

Environmental solutions for a changing world

Introduction & purpose of meeting

Provide detail on key aspects of development proposal

Provide detail on risks & benefits identified and proposed mitigation measures

Invite queries and feedback

3



Adaptation of effluent Biodigester to include manure as a feedstock.

Drying of the digestate by-product of manure digestion.

Purpose: commercial & environmental sustainability (reduced resource usage; private, cost-

effective power generation; cost effective manure waste management; marketable

fertilizer).

Requires additional infrastructure:

a) Digestion tanks for the anaerobic digestion of the manure to produce biogas.

b) A structure with appropriate pest control for the offloading and storage of the manure for up

to three days.

4



a) An extraction system with chemical scrubber at the exhaust outlet of the manure storage

unit, for the treatment of ammonia-rich exhaust gas prior to release to atmosphere.

b) A closed digestate (waste) storage tank and a closed-system conveyer belt drier for the

drying of the digestate.

c) At least five Combined Heat and Power (CHP) engines.

d) A series of tanks for water recovery – for gravity settling, filtration, RO and flash aeration.

e) Pipelines for the conveyance of manure; treated effluent; hot water; processed water;

biogas and steam.

f) Distribution lines for electricity.

5


Project & infrastructure description: site location

6

Project & infrastructure description: site layout

7

Project & infrastructure description: block PFD

8

Project & infrastructure description: detailed PFD 1

9

Project & infrastructure description: detailed PFD 2

10


11


Construction and decommissioning phases:

Natural stormwater drainage channel contamination from contaminated liquid surface

spillages

Dust

Traffic and access

Fire, health and safety risk

Noise

12



Operational phase impacts:

Groundwater and stormwater system contamination

Fire, health and safety risk

Health and safety risks and impacts on wellbeing from emissions from manure storage and

digestate drying

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

and handling

13



Operational phase benefits:

Reduction in greenhouse gas emissions

Reduction in natural resource usage

Reduction in demand on municipal bulk services infrastructure – water supply and

wastewater treatment

The plant needs to be designed, constructed and operated in such a manner as to avoid or

adequately minimise the risks identified above, and maximize the benefits.

14


Design phase mitigation

proposed

1) Groundwater & stormwater system contamination:

All process tanks and pipework to be designed and constructed according to the relevant

codes of practice, e.g. API STD 620 – recommended rules for design and construction of

low pressure tanks.

Purpose-design of manure storage unit, plus reinforced concrete floors.

Groundwater monitoring programme.

ERP.

15



proposed

1) Fire, health and safety risk

• 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.

• ERP.

• Avoid sources of ignition, e.g. no grinding, cutting and shaping of ferrous metals are allowed

using electrically driven power tools that produces sparks.

16



proposed

1) Health and Safety Risks and Nuisance Odours – Emissions from Manure and from

Digestate Drying

• The ventilation and extraction system for the manure storage unit requires an appropriate

abatement system to ensure that odorous exhaust gases are treated prior to venting to

atmosphere.

• The abatement system is to comprise a chemical scrubber (sulphuric acid), designed by a

registered professional engineer.

• The digestate drier should exhaust to the chemical scrubber at the manure storage unit.

• 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.

17



proposed

1) Health risks due to pests

• The manure storage unit floors will be designed so as to prevent pooling of wash water.

• The storage unit will be cleaned regularly according to a cleaning schedule and work

instruction.

• Fly traps will be installed if necessary.

18


Operational phase mitigation

proposed

1) Fire, Health and Safety Risk

• 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.

• Good housekeeping must be maintained to prevent the accumulation of unnecessary

combustibles.

• Adequate ventilation must be maintained.

• Gas flow to be shut off immediately at source (if safe to do so) during incident.

19


Operational phase mitigation

proposed

1) Groundwater and stormwater system contamination

• Any incident that results in ingress of product into the soil or water courses must be

reported to all relevant authorities, including DEA&DP and 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.

• A spill response kit appropriate to the liquids stored, handled and processed at the site must

be kept at the site at all times.

• In the event of a spill or leak, spill response according to the Emergency Response Plan

must be implemented.

20


Q&A

Contact:

Colleen McCreadie for Sillito Environmental Consulting

Tel: 021 712 5060 Fax: 021 712 5061

Email: [email protected]

21


COMPANY Trigen Group (Pty) Ltd

DATE & TIME 5 September 2017, 11:00

ATTENDEES DEA&DP Waste Directorate: Waleed Galvaan Mpumbu Dimba Dimda DEA&DP Development Management: D’Mitri Matthews DEA&DP Air Quality: Pater Harmse Deon Stoltz Cape Winelands District Municipality: Air Quality: Marius Engelbrecht Cape Winelands District Municipality: Environmental Health: Willie Roux Breede Valley Municipality: Environmental Health: Achmad Kafaar Saskia Langner Breede Gouritz Catchment Management Agency (on behalf of Water Affairs): Elkerine Rossouw RCL Foods (Pty) Ltd (landowner): Martin Pelzer Theunis Botha Vernol De Jager Reynier Oosthuizen Ryno Viljoen Francois Rossouw SEC: Colleen McCreadie

CONCERN / QUERY RESPONSE

Composition and source of manure

Analysis of the manure required. Please refer to the attached analysis of the manure feedstock and of the digestate.

Concern that the feedstock is not appropriate for the Biodigester: quantity and composition.

Only animal manure is proposed as a feedstock and the Biodigester has been purpose-designed with this in mind. Trigen has co-developed the technology with a partner in the United States of America, who


Example discussed of Elgin Biodigester, which has history of failure and which required an amended waste stream in order to operate successfully.

have a number of references worldwide. The Elgin Biodigester example discussed is not a good example of the type of system being proposed by Trigen, who will retain ownership and operation of the system and are well skilled to do so correctly. The newspaper article found on the odours and problems associated with the Elgin Biodigester (see end of document) cite several sources of odour, which the development proposal has addressed: consistent type and supply of feedstock; storage duration; contained storage with emissions abatement; plant managed by competent, trained Trigen staff; etc. etc. Trigen have advised with regards to the Elgin Biodigester that the plant was mismanaged; and that food waste cannot be compared to manure. Trigen have added that they have a detailed understanding of anaerobic technology (as proven with their two existing, successful plants) and are utilising proven technology and waste handling processes to ensure optimisation of the plant. In addition, Trigen’s processes conform with the highest European and American standards employed in densely populated areas. The example of the effective, odour-free operation of the Worcester effluent Biodigester is a case in point of a Trigen project where an odorous feedstock1 is well-managed and fugitive emissions are controlled.

Will the manure be poultry manure only; or animal manure? Animal manure.

1 Effluent composition: 0.25% is comprised of total suspended solids. These solids comprise animal matter, feed (from the intestines and stomach of the processed

chickens), and inorganic matter such as sand


Will the manure be sourced from RCL farms only? No. Whichever farms supply poultry to the RCL plant for processing; as well as other farms in the region, will supply animal manure to the Biodigester plant.

Digestion process

Will pH stabilisation of the solution in the digestion tanks be required? No.

How long does the digestion process take? An approximately 55 day retention time is required by the system.

Grit / blending tank

Will there be fibrous or other material that will need to be separated from the manure prior to digestion? The blending tank is designed for this purpose, but is labelled “grit removal” only: please clarify composition of “grit”?

Yes. In the blending tank, bedding (wood chips) will float and be scraped off the surface and conveyed within a closed system via a screw press for dewatering, to the digestate storage tank. Grit will settle out and will be discharged to a covered skip. Grit is composed mostly of soil.

“Grit” waste separated out in the blending tank - how long will it be stored in the skip? Design of skip? Should be covered for odour control. “Grit” disposed of how?

Grit will be removed from the skip and disposed of to landfill periodically.

Dried digestate / fertilizer storage and loading

Is the fertilizer stored prior to loading or loaded directly to trucks? If stored, what is the container type and loading mechanism from container to trucks?

Digestate will be stored in an enclosed building

If the fertilizer is stored, the container should be covered to prevent rainfall ingress.

See above

If fertilizer is stored, what are the proposed dust control measures for truck loading during windy / dry conditions?

See above

If direct discharge from drier conveyer to trucks, is dust control required and if so, All loading of trucks will take place in enclosed space


what is proposed?

Is the fertilizer storage area linked to the emission scrubber. The storage of the digestate will not be an odour source, but the exhaust gas from drying the digestate will need to be sent to the emissions scrubber

End use of fertilizer

Will the fertilizer need to be registered in terms of the Fertilizers, farm feeds, agricultural remedies and stock remedies Act 36 of 1947?

Section 3 of the Act requires registration of fertilizers. The DoAgriculture will be consulted as to whether this is required for the digestate, since the fertilizer is a product of raw manure digestion and manure is commonly applied to land.

What will be the end use of the fertilizer? Is the fertilizer appropriate for the end use specified?

Currently the manure is applied to land on farms in the area. This is known to be a risky practice in terms of potential for groundwater contamination and possibly also in terms of public health (airborne pathogens) and a source of nuisance odours, dependent on the scale and the intensity of the land application activity. The digestate fertilizer is biologically stable and odour free and so represents an environmentally sustainable alternative to application of raw manure. The digestate is also a superior fertiliser to manure because of the NPK (nitrogen, phosphorous, potassium) balance. The majority of organic material has already been converted to biogas and therefore there is less risk of burning the fields.

Transportation of manure and fertilizer

Proposal states that the fertilizer will be delivered from site by the same trucks that transport manure to the site. Will the interior of the trucks need to be sanitized between delivering the manure and collecting the fertilizer to prevent moisture and odour transfer to the fertilizer? If so, how and where? And means of washwater containment and disposal?

No sanitizing is necessary. Moving floor trucks remove content very efficiently and the moisture content of the digestate will be the same as the manure that is being delivered

Do the exterior of the trucks need to be sanitized regularly to avoid buildup of No truck wash will be provided on site. The logistics companies that


odorous material? If so, how and where? And means of washwater containment and disposal?

currently transport the manure to nearby farms will assist with delivery of manure and collection of digestate. The logistics company will clean their trucks off-site as required , as per their current practice.

Emergency response plan must include response for incident during transportation.

This will be the responsibility of the logistics company, which has emergency procedures in place. It should also be noted that moving floor trucks are completely enclosed

Concern that a side tip truck with tarpaulin cover will not provide a contained enough environment to prevent odours during transportation of raw manure.

Side tip truck

Trigen has indicated that moving floor trucks, which are fully enclosed, will be used instead.

Moving floor truck

What is the current route of manure transportation?

Farms > N1 > R60 > Louis Lange Street > RCL Foods site. Currently the manure is transported from the RCL and other farms along the N1 to other farms – the route remains largely in agricultural


areas when not on the N1. The concern that the raw manure will now be transported through a more built-up area, with potential for sensitive receptors to odour, is noted. Fully enclosed, moving floor trucks, delivering manure to site up to five times per day, is not considered to be a significant source of odour. The application will specify truck type and requirement for regular sanitising by the logistics company.

Concern that currently the manure from the RCL farms are transported by individual loads to other individual farms. There is no concentration of the manure at a central, urbanised point. Such concentration has the potential to increase odours and pests and spread of pathogens.

Digestion of manure and application of the digestate fertilizer is preferable to land application of manure for a host of reasons, including odour control and avoidance of soil and groundwater contamination. The Basic Assessment Report includes detail in this regard. The transportation of the manure will be contained (see above). The offloading and storage of the manure will be contained and controlled. Pest control will be implemented. So whilst it is acknowledged that the land application of manure takes place a greater distance from residential receptors than where the RCL site is situated, overall the practice of digesting the manure is preferable.

Is the activity appropriate for the site?

The site could be too close to residential and commercial receptors to be appropriate for the activity of manure digestion.

The controls (specialised transport, controlled manure handling and storage, etc.) being proposed suggest that there will be no impact on nearby receptors. The outcome of the impact assessment, factoring in the proposed design and operation of the plant, has found the site to be suitable. In terms of land use planning and zoning, it should be noted that the


RCL site is zoned for noxious trade aa a primary land use. Therefore, despite no odours and nuisance being anticipated, in principle the site is appropriate for such a use.

Effluent treatment and effluent discharge

Does RCL’s current effluent discharge permit not need to be amended to factor in the development proposal?

Intro: It needs to be remembered that the effluent Biodigester polishes the RCL plant’s effluent to a much higher quality prior to discharge, than RCL’s original WWTW (removal of about 90% COD’s). RO plant: A portion of the outflow from the effluent Biodigester, 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 will be blended into the effluent stream. 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. Emissions scrubber: The spent scrubber solution, which discharges to the municipal sewerage system, entails a change in the composition of the effluent being discharged. But the volume is only about 1m3/day. Once operational, effluent quality will be sampled. If required, an application will be made to amend the effluent discharge permit.


Water use - General Authorisation

Will the treated water be stored after the RO process and prior to re-use? If so, how and where?

The RO-treated water will be stored in tanks situated at the RO plant, prior to being piped to the RCL plant for re-use.

The re-use of the RO-treated effluent may constitute a Section 21 (g) water use and so may require registration for General Authorisation. Detail on the use of the treated effluent, and where the treated effluent will discharge to after use, is required for the BGCMA to advise further.

The treated water from the RO plant will be utilised in the boilers, cooling towers, to wash crates, etc. These sources discharge to municipal sewer. Trigen have advised that the RO treated water quality will be less than 75mg/L COD

If a GA is required, the EMP should include information that addresses the info required in terms of the 21 (g) GA. BGCMA will then have adequate data upfront to issue the GA, if required.

Emissions

What occupational health limits are being referred to for indoor air quality in the manure storage unit? This area will be operator free unless maintenance is required. Air inside will be ventilated to ensure atmosphere is safe to work in. All air will be channelled to air scrubber for treatment before discharge to atmosphere. All applications are standard processes

The ventilation and extraction system will be designed to ensure adequate indoor air quality. Staff activities in the unit will be minimised. It is expected that only maintenance activities in the storage unit will require staff. Staff will wear PPE. Trigen in conjunction with an accredited occupational hygienist will determine the compounds to be monitored for in terms of the OHS Act (possibly ammonia & hydrogen sulphide); and such monitoring will be undertaken as required by the OHS Act.

A Dust Management Plan for the manure Biodigester plant is required. All potential sources of dust at the plant will be identified and management measures included in the EMP. However, neither the manure nor the digestate present a dust risk due to the controlled nature of transportation, handling and storage. If required, additional dust monitoring points will be identified in conjunction with an emissions testing service provider, for inclusion in RCL’s on-going dust monitoring programme.


An indication must be given that the proposed emissions scrubber is appropriate for all compounds of concern at the manure storage unit and digestate drying unit. Is there certainty that H2S is not a compound of concern?

Yes, H2S is not a compound of concern. Manure: H2S is only released due to anaerobic degradation of sulphates. This will not occur in the 1 to 2 day storage period for the manure. Digestate: Ammonia is highly volatile and will therefore be released in the drying process. H2S is not highly volatile and therefore will be released in insignificant amounts. Also, the high pH of the digestate will discourage the release of H2S.

The project description should include the option to upgrade the H2SO4 emissions scrubber in the event that the scrubber does not prove as efficient at odour reduction as expected. This will prevent the possibility that authorisation for an upgrade would need to be applied for at the time.

Although the emissions scrubber is a proven technology and will be generously sized, the project description will include possible future adaption of the scrubber as required to ensure efficient odour reduction.

Noise

Will the plant entail noisy equipment? The site walk around to the effluent Biodigester plant demonstrated that the noise control measures currently being implemented, and which are proposed for the plant adaptation to accept manure, are adequate.

Bio-security

Spread of pathogens from the manure – how will this be contained and controlled?

The manure delivery trucks will be cleaned as required by the logistics company off-site. All control measures being proposed (contained transport, offloading and storage; and automated feeding within the Biodigester system) are adequate to prevent windborne spread of pathogens.

Major Hazard Installation

Will the plant be an MHI? The RCL plant including effluent Biodigester is an MHI. The MHI will be amended to include the manure Biodigester once the plant has been approved and is in the detailed design phase.


The amended MHI to include the effluent Biodigester (2016) must be submitted to DEA&DP Development Management.

This will be submitted.

Is a fire risk engineer part of the design team? Trigen will consult the local fire department to ensure that the plant complies with requirements.

Traffic impact

Are the trucks travelling to and from the site not a possible source of congestion or impact on traffic safety? Should SANRAL not be consulted with regards to the traffic impact of this proposal?

The manure delivery truck trips that will be made to the RCL site are currently being made from the RCL farms to the farms where the manure is applied to land. The proposal therefore does not represent an overall increase in road traffic., but rather a diverting of these trucks to the Worcester industria area. There is a high degree of confidence that the industrial area and supporting road network is designed to accommodate the heavy vehicle traffic associated with industrial activities. The truck trips associated with the manure Biodigester will be up to 5 truck trips per day. This is considered a negligible number of trips in a developed industrial context; and even in the context of operations at the RCL plant alone, which entail the delivery, slaughter, processing and delivery of some 250 000 – 300 000 birds/day.

Pest management

A basic pest management plan for the Biodigester plant compiled by a suitable provider should be appended to the EMP

Pest Elite currently services the RCL facility. They will be requested to provide a basic pest management plan.

Stormwater management

The stormwater management diagram and the measures relating to stormwater management in the EMP must identify and show nearby stormwater channels; and demonstrate adequate control of surface runoff from the site to cater for flood events.

Noted. Civil engineers will develop a detailed stormwater management plan for the site once the layout has been finalised. Dedicated stormwater infrastructure has already been installed as part of the existing effluent Biodigester plant.

Legislation and odours

Complainants’ rights and Trigen’s responsibilities in terms of odour and odour Noted.


control will be governed by the conditions of the Health Act as well as the Air Quality Act; and the conditions of the Waste Licence.

NEMA Section 30 incidences

The BGCMA must be included in the EMP as the authority to notify on behalf of the DWS in the event of an incident subject to Section 30.

Noted.

NEMAQA Subcategory 8.1 thermal treatment of waste

Subcategory 8.1 applies to the digestate drying activity: “application of heat” is the wording in the activity

Whether the digestate drying triggers the NEMWA definition of “treatment”, or the NEMAQA definition of “thermal treatment”, needs to be investigated further. SEC is consulting with the authorities in this regard In the interim, the Waste Licence application process is proceeding, as SEC has a high degree of confidence that “thermal treatment” is not applicable to a drying operation but rather to high-temperature applications such as incineration, combustion, pyrolysis, etc.

Two separate AEL’s would be in place at the RCL plant – one in RCL’s name for RCL activities (rendering); and one in Trigen’s name for Trigen’s activities (thermal treatment of waste).

Each AEL will need to include the activities of the other licence as emissions sources.

The licensing authority has the discretion to ask for fewer compounds to be sampled for on an annual basis than those listed in the MES. It is likely that for the first year of operation, the full suite of compounds would need to be sampled to demonstrate that the data provided in support of the drying activity not emitting any of the listed compounds, is accurate. Thereafter, the sampling requirements could be reduced. There is no certainty in this regard – at the discretion of the licensing authority. Trigen would need to characterise the emission in support of a reduced sampling regime.

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JV JV JV

0 1 2

09-Jul-17 20-Sep-17 05-Oct-17

ManureManure Manure Manure Manure Manure Manure

Typical

ManureDigestate

2017/08/02 2017/08/17 2017/08/21

07:45 09:00

2017/08/02 2017/09/04 2017/08/28 2016/07/01

AL Abbott AL Abbott AL AbbottNRM

Laboratories

NRM

Laboratories

2017/08/02/

3718

2017/09/04/

4107

2017/08/28/

394872906

Rustenberg

Commissie

Drift (HSE 12

B8)

Contract

Farmers (RRBC

102 HSE 6)

Zuurplaat (HSE

6 B17)Bridgnorth, UK

3

✓ 735 700 508 835 374 400 539 645 508 835 735 700 149 100 28%

✓ 122 400 171 486 155 600 149 829 155 600 171 486 20 451 14%

✓ 62.0% 63.6% 58.4% 61.3% 62.0% 63.6% 2.2% 60.0% 83.3%

✓ 50.8% 53.7% 51.1% 51.9% 51.1% 53.7% 1.3% 29.6%

81.9% 84.4% 87.5% 84.6% 84.4% 87.5% 2.3%

✓ 38 800 39 610 35 880 38 097 38 800 39 610 1 602 4%

✓ 445 719 673 612 673 719 120 20%

✓ 5 900 5 850 5 400 5 717 5 850 5 900 225 4%

✓ 5.91 5.46 5.61 6 6 6 0 3% 9

✓ 14 699 18 000 22 000 18 233 18 000 22 000 2 985 16% 30 000 32 100

✓ 2 400 4 970 3 380 3 583 3 380 4 970 1 059 30% 6 200 3 168

200 23

✓ 481 2 275 2 900 1 885 2 275 2 900 1 025 54% 10 910 71 300

✓ 169 1 850 1 250 1 090 1 250 1 850 696 64%

✓ 5 500 5 200 8 564 6 421 5 500 8 564 1 520 24%

✓ 11 810

✓ 9 750 8 200 16 000 11 317 9 750 16 000 3 372 30% 14 943 45 300

✓ 5 050 5 350 5 680 5 360 5 350 5 680 257 5% 12 400

✓ 1 750 2 040 2 250 2 013 2 040 2 250 205 10% 3 745 18 100

✓ 2 600 2 650 3 250 2 833 2 650 3 250 295 10% 170 685

157

1 212

Copper, Cu

Zinc, Zn

Manure

Std DevMaxPercentile, 50thAverage

Rustenburg

TriGen RCL W2V, Rustenburg Prepared by:

170601C Revision no:

Date:

TriGenAnalytical data

Client:

Location:

Project:

Project no:

Document no:

Units

Date, Sample

Time, Sample

Laboratory

Sample no

Date, Analysis

Sample age

Location

Number of samples

Parameters

COD, Total mg O2/l

Ammonia, NH4 mg N/kg

Total Phosphates, TP mg P/kg

Ortho-Phosphates, PO4 mg P/kg

Total Kjeldahl Nitrogen, TKN mg N/kg

COD, Soluble mg O2/l

Total Solids, TS %

Volatile Solids, VS %

Volatile Fraction %

Calcium, Ca mg/kg

Sulphates, SO4 mg SO4/kg

Total Sulphur, TS mg SO3/kg

Potassium, K mg K/kg

Sodium, Na mg/kg

Total Dissolved Solids, TDS mg/kg

Density kg/m3

Conductivity mS/m

pH pH units

Nitrates, NO3-

mg N/kg

Magnesium, Mg mg/kg

1

Colleen McCreadie

From: Colleen McCreadie

Sent: 26 October 2017 03:03 PM

To: Marius Engelbrecht ([email protected]);

'[email protected]'; 'd'[email protected]';

'[email protected]'; '[email protected]';

[email protected]; Saskia Langner; Elkerine Rossouw ([email protected])

Cc: Guillaume Olivier ([email protected]); Martin Pelzer

([email protected]); 'Theunis Botha'; Adrian Sillito

Subject: Meeting notes with additional information - Trigen Worcester manure Biodigester

Attachments: 0151011 Authority mtg discussion notes 05.09.17.pdf; 170601C - Analytical results

(Manure) - 20171015.pdf

Dear All

Many thanks for your input into this application to date.

We have been in consultation with Trigen since the meeting held with yourselves on 5th

September. Please see

attached notes of the issues, concerns and queries raised by yourselves, and the responses to these based on

information provided by Trigen.

We will incorporate all of the additional information into our Draft Basic Assessment Report and EMP. We will be

circulating these reports for public comment within the next two weeks, and will ensure that all parties have access

to these reports.

Thank you

"Environmental Solutions for a Changing World"

Colleen McCreadie – Environmental Consultant

P: +27 (0) 21 712 5060

F: +27 (0) 21 712 5061

M: +27 (0) 83 695 1664

[email protected]


Suite 105, Block B2, Tokai Village Centre, Vans Road, Tokai, Cape Town, 7966

1

Colleen McCreadie

From: Marius Engelbrecht <[email protected]>

Sent: 10 August 2017 04:22 PM

To: Colleen McCreadie

Cc: Duncan Gibbison ([email protected]); Alister Inglesby ([email protected]);

Martin Pelzer ([email protected]); Hein Boock

Subject: RE: RCL Foods biodigester adaptation - authority site inspection

Ms McCreadie

The Cap[e Winelands District Municipality, Air Quality Management, supports this proposal of site inspection and a

meeting on the proposed RCL Foods bio-digester adaptation.

Currently the Cape Winelands District Municipality are liaising with officials from DEA&DP, Directorate: Air Quality

Management, with regard to this proposal to introduce manure to the bio-digester at RCL Foods. Due to the a

history of odour complaints from this industry with regards to the current animal rendering plant and it’s chicken

farms, this proposal must be assessed as a possible contributor to odour nuisances. The transport of manure from

farms to the bio-digester, the storage of this manure prior to introduction to bio-digester, storage of substrate after

introduction to bio-digester, dry -and pelletizing proses, storage of final product, could all be seen as possible

emission sources of odour. No clear indication was offered on how mentioned processes will be performed to

ensure no releases of offensive odours.

Clarity to if the process of treating manure in a bio-digester and the drying and pelletizing of the substrate, could be

seen as a listed activity in terms of Category, 8, Subcategory 8.1: Thermal Treatment of General and Hazardous

Waste will be clarified prior to this proposed site inspection. Just a reminder that should the manure indeed be

classified as waste, the Minister can become the atmospheric emission licensing authority in terms of Section 36(8)

of NEM:AQA.

It is essential during this initial stages of the proposed RCL Foods bio-digester adaption to ensure involvement of all

governmental interested and affected parties. The officials from the DEA&DP, Directorate: Air Quality Management

and the Air Quality Officer from Breede Valley Municipality should be involved. Could you please extend the invite to

the following officials as well:-

Dr Joy leaner - [email protected]

Peter Harmse - [email protected]

Achmad Kafaar - [email protected]

Kind regards,

Marius Engelbrecht Air Quality Officer Cape Winelands District Municipality

� C/o Langenhoven and Bird Street, Stellenbosch, 7600,

� P.O. Box 100, Stellenbosch, 7599

� 021 888 5811

� 072 122 5680

� 021 887 9365

� [email protected]

� www.capewinelands.gov.za

2

From: Colleen McCreadie [mailto:[email protected]]

Sent: Thursday, August 10, 2017 2:54 PM

To: [email protected]; 'd'[email protected]';

[email protected]; Willie Roux; Marius Engelbrecht; Elkerine Rossouw ([email protected]);

[email protected]; [email protected]; '[email protected]'

Cc: Duncan Gibbison ([email protected]); Alister Inglesby ([email protected]); Martin Pelzer

([email protected])

Subject: RCL Foods biodigester adaptation - authority site inspection

Dear All

Would a site inspection to run through the proposal to adapt the RCL Foods Biodigester, be possible for the week of

14th

August, please? Possibly Friday 18th

?

For those travelling from Cape Town, 11am should be a suitable time? We just need to agree on a date if all are

available, please.

We should have the Draft Basic Assessment Report ready for your review very shortly, with further detail on the

proposal, risks and management. Also, engineers from Trigen will be available to answer technical queries about the

Biodigester process and infrastructure.

We await your response in this regard, thank you.



P: +27 (0) 21 712 5060

F: +27 (0) 21 712 5061

M: +27 (0) 83 695 1664

[email protected]



Marius Engelbrecht Air Quality Officer/Environmental Health Practitioner Cape Winelands District Municipality

� C/o Langenhoven and Bird Street, Stellenbosch, 7600,

� 021 888 5811

� 072 122 5680

� 021 887 9365



1

Colleen McCreadie

From: Willie Roux <[email protected]>

Sent: 07 August 2017 09:07 AM


Cc: Marius Engelbrecht; admin

Subject: FW: Notice of Intent to Apply for a Waste Licence - Trigen Worcester Manure

Biodigester

Attachments: 0151011 Trigen Worcester NoI 05.07.17 final.pdf; 0151011 Trigen EA_06.01.16.pdf

07 August 2017

Sillito Environmental Consulting

For attention: Me Colleen McCreadie

Good day Colleen

Notice of Intent to Apply for a Waste Licence - Trigen Worcester Manure Biodigester

As requested by email on 04 August 2017, find below the requests and comments from this office on the above

mentioned application, send to Mr. Eddie Hanekom from DEA&DP: Waste Management Directorate on 04 August

2017.

Kind regards

Willie Roux

Environmental Health Practitioner

Tell: 023 348 2359


MUNICIPAL HEALTH SERVICES

MUNISIPALE GESONDHEIDSDIENSTE

From: Willie Roux


To: [email protected]

Cc: [email protected]; [email protected]; lance.mcbain-

[email protected]; admin <[email protected]>

Subject: Notice of Intent to Apply for a Waste Licence - Trigen Worcester Manure Biodigester

04 August 2017

Western Cape Government

DEA&DP

Waste Management Directorate

2

For attention: Mr. E. Hanekom

Dear Sir

We refer to the attached “Notice of Intent to apply for a Waste Licence” by Trigen Group for the addition of manure

digestion to the current approved bio-digester at the premises of the RCL Foods situated at 1 McAllister Road,

Worcester.

The storage and processing of manure at this premises concerned is a direct concern to this office due to the risks of

the health and/or wellbeing of occupiers of adjacent premises or nearby communities that could be negatively

affected. It is a well-known fact that the storage and processing of manure could cause offensive odours and fly

problems. Both of these issues are regarded as health nuisances, as defined in the National Health Act, 2003 (Act no

61 of 2003).

This office received numerous complaints over the past years regarding offensive odours emitted by other processes

(By-product plant) on this specific premises as well as from other industries in Worcester, including an industry that

was also producing pellets from chicken manure/compos for agricultural purposes, a similar process that is planned

to be conducted at the premises of RCL Foods at 1 McAllister Road, Worcester. Therefore this office is very

concerned about this planned activities to be conducted in Worcester which involve the handling, storage and

processing of manure.

The Cape Winelands District Municipality has a statutory obligation in terms of the National Health Act, 2003 (Act

No. 61 of 2003) with regards to environmental pollution control to respect, protect, promote and fulfil the rights

towards human health or well-being within the district.

With reference to the attached “Notice of Intent”, this office requests the following:

1. That this office be included in the list of state departments/organs of state to be consulted to

represent the Municipal Health Services directorate of the Cape Winelands District Municipality.

Although Mr. Marius Engelbrecht from this District Municipality is already included on the list, he is

representing this District Municipality in his capacity as Air Quality Officer, responsible for the

implementation of the NEM: Air Quality Act, 2004 (Act No. 39 of 2004).

As it was the case over the past years, it would most properly be this office that will receive

complaints regarding health nuisances from the community that may be caused by this activities.

These complaints will most properly be dealt with in terms of the provisions of the National Health

Act, 2003 (Act No. 61 of 2003). Therefor we see it as crucial for the protection of the wellbeing of

the Worcester community that this office also get the opportunity to give comments, set

conditions and/or objections to this application.

2. In the “Notice of Intent” it is stated by the applicant that an application for rezoning and/or

consent use is not applicable.

This may properly not be the case. In other instances in Worcester where manure was stored

and/or processed on premises, the owners of the involved premises were obliged to apply for

rezoning and/or consent use to enable the applicant to continue with the activity. We advise and

request that this issue be taken up with Mr. Pieter Hartzenberg, Chief Town Planner of Breede

Valley Municipality.

3. In section 3 of the “Notice of Intent”, (Project Description), reference is made to the structure to

be used for the storage of the “incoming” or fresh manure . As the storage of up to 300 tons of

manure may be a big potential source of offensive odour emissions, other health nuisances and

environmental pollution, we would request that more detailed information should be provided

regarding this storage facility, measures to prevent environmental pollutions such as ground and

3

water pollution, as well as detailed measures to be taken to control flies, to prevent fly hatching as

well as the prevention of emission of offensive odours. The vague mentioning of possible measures

to be implemented is not adequate. Information regarding the process of “feeding” the manure

into the bio-digester is also requested.

4. It is also vaguely referred to in section 3 of the “Notice of Intent”, (Project Description), that the

process involve the drying and pelletizing of the approximately 80 tons of digestate per day (waste

product of the bio-digestion process). We assume that this digestate will properly contain mostly

manure. In the past we received numerous complaints regarding offensive odours from a chicken

manure/compos pelletizing industry, also involving drying of the manure/compos. We therefor

requested that detail information must be provided regarding the storage and conveyance method

of the digestate from the bio-digester towards the drying and pelletizing processes, detail

information of the drying and pelletizing processes, as well as details of measures to be

implemented to sufficiently prevent and reduce dust as well as odour emissions from and during

these processes. Also including protective measures applicable to protect the health of workers in

these sections.

5. Regarding section 7 of the “Notice of Intent” ( Public Participation), the following: It seems that the

applicant suggest that public participation will be limited to the owners and/or occupants of

adjacent premises, the municipal ward councillor, various organs of state and a notice in an official

Gazette. Possible odour releases may affect not only the direct adjacent premises owners and

occupants, but may also negatively affect various residential communities, as is currently the

situation with emissions released from other sources situated on this specific involved premises

(the By-product plant). Numerous complaints were received over the years from residential areas

situated further than the adjacent premises regarding offensive odours emitted from this involved

premises, indicating that it is not only the directly adjacent premises that may be negatively

affected by possible emissions of offensive odours. We therefor request that the public

participation process must be expanded to also include a written notice in English and Afrikaans in

a local newspaper and to provide the community the opportunity to also give comments on this

application and/or register objections to it.

Your Departments consideration and addressing of the above mentioned concerns and requests will be

appreciated.

Yours sincerely.

Willie Roux


Tell: 023 348 2359




4

Willie Roux Environmental Health Practitioner Cape Winelands District Municipality

� 51 Trappes Street, Worcester, 6850,

� 023 348 2359

�

� 023 347 3668



1

Colleen McCreadie



To: 'Simon Botha'

Cc: [email protected]


Dear Simon

Thank you for taking the time to discuss the Trigen manure Biodigester project. As requested, we will henceforth not

liaise directly with P&C on this application, but rather anticipate that if the Waste Directorate has any concerns

relating to possible contamination risk, they will request your input.

Thank you



P: +27 (0) 21 712 5060

F: +27 (0) 21 712 5061

M: +27 (0) 83 695 1664

[email protected]



From: Simon Botha [mailto:[email protected]]




Dear Colleen

I am not sure why we have been invited to this meeting.

We deal with NEMA s30 incidents and contaminated land matters in terms of the Waste Act.

We will have to understand why we are being involved before we will be allowed to attend.

Kind regards

Simon Botha

Sub-Directorate: Remediation and Emergency Incident Management

Directorate: Pollution and Chemicals Management

Department Environmental Affairs and Development Planning

5th Floor, Atterbury House

Riebeeck Street, Cape Town

Tel: (+27)21 483 0752

Cell: (+27)60 588 9734

Fax: (+27)21 483 3186

E-mail: [email protected]

Website: www.westerncape.gov.za

2


Sent: 11 August 2017 12:32 PM To: Elkerine Rossouw; Waleed Galvaan; D'mitri C Matthews; Simon Botha; Willie Roux; Marius Engelbrecht

([email protected]); [email protected]; Guillaume Olivier; '[email protected]'; Joy Leaner; [email protected]; Peter Harmse

Cc: Duncan Gibbison ([email protected]); Alister Inglesby ([email protected]); Martin Pelzer

([email protected]) Subject: RE: RCL Foods biodigester adaptation - authority site inspection

Dear all

Could the meeting please be shifted to 22nd

, 23rd

or 24th

August, 11am?



P: +27 (0) 21 712 5060

F: +27 (0) 21 712 5061

M: +27 (0) 83 695 1664

[email protected]



From: Elkerine Rossouw [mailto:[email protected]] Sent: 11 August 2017 12:19 PM

To: Colleen McCreadie; [email protected]; 'd'[email protected]';

[email protected]; Willie Roux; Marius Engelbrecht ([email protected]); [email protected]; [email protected]; '[email protected]'

Cc: Duncan Gibbison ([email protected]); Alister Inglesby ([email protected]); Martin Pelzer ([email protected])


Hi there,

Yes we can meet the 18th

at 11

Kind Regards,

Elkerine Rossouw Water Use Specialist Email: [email protected] Tel: 023 3468000

3



To: [email protected]; 'd'[email protected]'; [email protected]; Willie Roux; Marius Engelbrecht ([email protected]); Elkerine

Rossouw; [email protected]; [email protected]; '[email protected]' Cc: Duncan Gibbison ([email protected]); Alister Inglesby ([email protected]); Martin Pelzer

([email protected])

Subject: RCL Foods biodigester adaptation - authority site inspection

Dear All

Would a site inspection to run through the proposal to adapt the RCL Foods Biodigester, be possible for the week of

14th

August, please? Possibly Friday 18th

?

For those travelling from Cape Town, 11am should be a suitable time? We just need to agree on a date if all are

available, please.

We should have the Draft Basic Assessment Report ready for your review very shortly, with further detail on the

proposal, risks and management. Also, engineers from Trigen will be available to answer technical queries about the

Biodigester process and infrastructure.

We await your response in this regard, thank you.



P: +27 (0) 21 712 5060

F: +27 (0) 21 712 5061

M: +27 (0) 83 695 1664

[email protected]



"All views or opinions expressed in this electronic message and its attachments are the view of the sender and do not necessarily

reflect the views and opinions of the Western Cape Government (the WCG). No employee of the WCG is entitled to conclude a

binding contract on behalf of the WCG unless he/she is an accounting officer of the WCG, or his or her authorised representative. The

information contained in this message and its attachments may be confidential or privileged and is for the use of the named recipient

only, except where the sender specifically states otherwise. If you are not the intended recipient you may not copy or deliver this

message to anyone."

1

Colleen McCreadie

From: Guillaume Olivier <[email protected]>



Cc: Willie Roux

Subject: RE: Manure biodigester, RCL Foods, Worcester

Good afternoon

With regard to your request for comment on the application to adapt an existing bio digester as well as the

construction of a digestate drying plant, the following:

From an environmental health point of view it is vitally important that no health hazard, nuisance or any pollution of

the environment (land, water or air) occurs, neither during the construction phase or during the operational phase

after construction.

This office therefore fully concurs with the comment given by the Municipal Health section of Cape Winelands

District Municipality (Mr Roux) and have nothing further to add to this.

Kind regards

Guillaume Olivier

Environmental Health Co-ordinator: Western Cape Provincial Health department

Tel: 023 3428806

Cell: 082 9288467

Fax: 086 6137156

E-mail: [email protected]


Sent: 10 August 2017 09:19 AM To: Guillaume Olivier

Cc: Willie Roux

Subject: Manure biodigester, RCL Foods, Worcester

Dear Guillome

We obtained your details from Mr Willie Roux at Environmental Health, Cape Winelands District Municipality.

Willie requested that we obtained DoH input on an application that we are submitting on behalf of the Trigen Group

(Pty) Ltd – renewable energy engineers.

The proposal is for the adaptation of an existing effluent-to-biogas Biodigester plant, which is situated at RCL Foods,

McAlister Road, Worcester. The biogas produced is burnt in CHP engines to generate electricity for use by RCL Foods

on site.

The proposal is for the plant to be adapted so that manure can be included as a feedstock. Also, to construct a plant

for drying and pelletizing the digestate by-product of the manure digestion process to produce a marketable and

transportable fertilizer. And also a reverse osmosis water recovery plant to treat the outflows from the current

effluent Biodigester, so that the water can be re-used for suitable applications on non-food production areas of the

site (e.g. crate washing).

Please find attached the Notice of Intent to Apply submitted to the DEA&DP, attached for your reference; as well as

Willie Roux’s feedback on the NoI.

2

We are hoping at this stage to produce a Basic Assessment Report that addresses upfront any concerns that the

authorities may have with the application. Willie’s concerns have been forwarded to Trigen and the project team is

ensuring that they will be addressed in the BAR.

Should the DoH heave any additional concerns or queries that we should address, it would be much appreciated if

you could advise us of same.

We are arranging a site inspection for the various authorities involved in this application, hopefully within the next

few weeks. Would your office wish to attend the meeting to review the existing effluent Biodigester plant and to

discuss any technical aspects with the project engineers?

We await your feedback in this regard, and thank you for your assistance with this application.

Kind regards



P: +27 (0) 21 712 5060

F: +27 (0) 21 712 5061

M: +27 (0) 83 695 1664

[email protected]



"All views or opinions expressed in this electronic message and its attachments are the view of the sender and do not necessarily

reflect the views and opinions of the Western Cape Government (the WCG). No employee of the WCG is entitled to conclude a

binding contract on behalf of the WCG unless he/she is an accounting officer of the WCG, or his or her authorised representative. The

information contained in this message and its attachments may be confidential or privileged and is for the use of the named recipient

only, except where the sender specifically states otherwise. If you are not the intended recipient you may not copy or deliver this

message to anyone."

1

Colleen McCreadie


Sent: 14 July 2017 12:09 PM

To: '[email protected]'; '[email protected]'

Cc: Muneeb Baderoon; [email protected];

[email protected]; Marius Engelbrecht

([email protected]); Alister Inglesby ([email protected]); Duncan

Gibbison ([email protected])

Subject: Notice of Intent to Apply for a Waste Licence - Trigen Worcester Manure

Biodigester

Attachments: 0151011 Trigen Worcester NoI 05.07.17 final.pdf; 0151011 Worcester biodigester

process flow manure.pdf; 0151011 effluent and manure SDP_06.06.17.pdf; 0151011

Trigen EA_06.01.16.pdf; Trigen Worcester WLA Project Schedule Best Case_July

2017.pdf; 0151011 Worcester biodigester PFD risk scenarios.pdf; 0151011 Rainbow

Topo.pdf; 0151011 Rainbow Google Earth.pdf

Dear Eddie and Lance Notice of Intent to Apply for a Waste Licence: Adaption of Waste-to-Value Plant at RCL Foods, Erf 4396, McAlister Street, Worcester – Manure Digestion Our sincere thanks to your office for your prior assistance telephonically and by email with the legislative triggers for the above proposal. The proposal is for the addition of manure digestion at an existing effluent waste-to-value plant at RCL Foods, Worcester. The effluent waste-to-value plant was granted Environmental Authorisation in January 2016 (Ref. No. 16/3/3/1/B2/32/1010/15); and the plant was commissioned in December 2016. At the waste-to-value plant, effluent digesters produce biogas, which is burnt on site in Combined Heat and Power Engines to produce electricity to power the RCL Foods plant. This application is for the installation of additional digesters and associated infrastructure to enable the digestion of manure. It is expected that with the addition of manure as feedstock, the plant can increase electricity output from around 1.5MW to around 6MW. This should be sufficient to supply all of the RCL Foods plant’s electricity needs. A digestate is produced as a by-product (waste) of the manure digestion process. The proposal includes the drying and pelletizing of the digestate prior to its distribution to agricultural users for fertilizer. This proposal also includes the installation of a water recovery plant. The water recovery plant will further polish the treated effluent outflows from the effluent digesters, by means of Reverse Osmosis, so that the highly polished effluent can be used as water supply for certain applications on the site outside of the food processing areas. Application for a Waste Licence will be made: Category A, Activities 3, 5, 6 and 12 will be applied for. In consultation with DEA&DP Development Management, Region 2, it will be determined whether any administrative process is required with regards to the Environmental Authorisation governing the effluent digestion plant. With regards to the Air Quality Act, the RCL Foods facility is a licensed facility for Category 10, animal matter processing not for human consumption (the plant includes a poultry by-products rendering plant, which manufactures meal for animal feed purposes). Preliminary indications are that the thermal drying of the digestate by-product could be included in the Category 10 Atmospheric Emissions Licence for the plant, but this aspect will be clarified with the air quality officer for the Cape Winelands District Municipality. Please find attached electronic copies of the Notice of Intent to Apply for the above proposal, as well as:

� A process flow diagram � An indicative site plan � Site locality maps � The 2016 Environmental Authorization of the effluent digestion plant; and � A project schedule

2

A signed hard copy submission will be made to your office early next week. We would like to kindly request a pre-application site meeting with your office, DEA&DP Development Management; potentially DEA&DP Pollution and Chemicals; and with the CWDM, please. We have also furnished as much detail as possible on the Biodigester plant at this early stage, and we would appreciate any feedback your office may have on the impacts identified for further assessment and management in the Notice of Intent form. Please do not hesitate to contact the undersigned should there be any queries. Kind regards

Colleen McCreadie Sillito Environmental Consulting Copy: Samornay Smidt, DEA&DP Development Management, Region 2: [email protected] Simon Botha, DEA&DP Pollution & Chemicals [email protected] Marius Engelbrecht, Air Quality Officer, Cape Winelands District Municipality [email protected]



P: +27 (0) 21 712 5060

F: +27 (0) 21 712 5061

M: +27 (0) 83 695 1664

[email protected]



1

Colleen McCreadie



To: '[email protected]'

Cc: Marius Engelbrecht ([email protected])

Subject: FW: Manure biodigester, RCL Foods, Worcester

Attachments: 0151011 Trigen Worcester NoI 05.07.17 final.pdf; Rainbow Processing Plant.kmz;

0151011 Trigen EA_06.01.16.pdf; FW: Notice of Intent to Apply for a Waste Licence

- Trigen Worcester Manure Biodigester; RE: RCL Foods biodigester adaptation -

authority site inspection

Dear Achmad

We are submitting an application for a Waste Licence on behalf of the Trigen Group (Pty) Ltd – renewable energy

engineers. In preliminary consultations with the CWDM air quality, Marius Engelbrecht has suggested that we

request input into this application from the BVM’s air quality office.



on site. The existing Biodigester was authorised in January 2016 and commissioned around January 2017: please

refer to the attached Environmental Authorisation.






Please find attached the Notice of Intent to Apply submitted to the DEA&DP, attached for your reference.


authorities may have with the application. In this regard, please refer to the feedback received from CWDM

environmental health and from CWDM air quality in response to the NoI.

Should BVM air quality have any concerns or queries with this manure digestion application, it would be much

appreciated if you could advise us of same.

We are arranging a site inspection for the various authorities involved in this application, hopefully next week.

Possibly Friday 18th? For those travelling from Cape Town, 11am should be a suitable time.

If your office wishes to attend the meeting to review the existing effluent Biodigester plant and to discuss any

technical aspects with the project engineers, please do advise?


Kind regards


P: +27 (0) 21 712 5060

F: +27 (0) 21 712 5061

2


M: +27 (0) 83 695 1664

[email protected]



1

Colleen McCreadie




Cc: Alister Inglesby ([email protected]); Duncan Gibbison ([email protected])

Subject: FW: Notice of Intent to Apply for a Waste Licence - Trigen Worcester Manure

Biodigester


Dear Pieter

Willie Roux at CWDM environmental health has requested that we liaise with you.

RCL Foods poultry processing plant, Erf 4396, McAlister Road, Worcester Industria, refers.

As you will see from the attached documents and from Willie’s email below, Trigen renewable energy engineers are

proposing to adapt the existing effluent digestion plant so that the plant can also digest manure, thereby generating

additional biogas for additional electricity generation purposes.

Willie has raised a concern that this proposed land use (manure storage, digestion, and further digestate processing)

may require some kind to approval or consent use in terms of the zoning scheme. Erf 4396 is currently zoned for

Industrial Zone 2.

Please could your office kindly advise us further in this regard?

Your assistance would be very much appreciated, thank you.



P: +27 (0) 21 712 5060

F: +27 (0) 21 712 5061

M: +27 (0) 83 695 1664

[email protected]



From: Willie Roux [mailto:[email protected]]



Cc: Marius Engelbrecht; admin Subject: FW: Notice of Intent to Apply for a Waste Licence - Trigen Worcester Manure Biodigester

07 August 2017

Sillito Environmental Consulting

For attention: Me Colleen McCreadie

Good day Colleen

2

Notice of Intent to Apply for a Waste Licence - Trigen Worcester Manure Biodigester

As requested by email on 04 August 2017, find below the requests and comments from this office on the above

mentioned application, send to Mr. Eddie Hanekom from DEA&DP: Waste Management Directorate on 04 August

2017.

Kind regards

Willie Roux


Tell: 023 348 2359




From: Willie Roux


To: [email protected]

Cc: [email protected]; [email protected]; lance.mcbain-

[email protected]; admin <[email protected]>

Subject: Notice of Intent to Apply for a Waste Licence - Trigen Worcester Manure Biodigester

04 August 2017

Western Cape Government

DEA&DP

Waste Management Directorate

For attention: Mr. E. Hanekom

Dear Sir

We refer to the attached “Notice of Intent to apply for a Waste Licence” by Trigen Group for the addition of manure

digestion to the current approved bio-digester at the premises of the RCL Foods situated at 1 McAllister Road,

Worcester.

The storage and processing of manure at this premises concerned is a direct concern to this office due to the risks of

the health and/or wellbeing of occupiers of adjacent premises or nearby communities that could be negatively

affected. It is a well-known fact that the storage and processing of manure could cause offensive odours and fly

problems. Both of these issues are regarded as health nuisances, as defined in the National Health Act, 2003 (Act no

61 of 2003).

This office received numerous complaints over the past years regarding offensive odours emitted by other processes

(By-product plant) on this specific premises as well as from other industries in Worcester, including an industry that

was also producing pellets from chicken manure/compos for agricultural purposes, a similar process that is planned

to be conducted at the premises of RCL Foods at 1 McAllister Road, Worcester. Therefore this office is very

3

concerned about this planned activities to be conducted in Worcester which involve the handling, storage and

processing of manure.

The Cape Winelands District Municipality has a statutory obligation in terms of the National Health Act, 2003 (Act

No. 61 of 2003) with regards to environmental pollution control to respect, protect, promote and fulfil the rights

towards human health or well-being within the district.

With reference to the attached “Notice of Intent”, this office requests the following:

1. That this office be included in the list of state departments/organs of state to be consulted to

represent the Municipal Health Services directorate of the Cape Winelands District Municipality.

Although Mr. Marius Engelbrecht from this District Municipality is already included on the list, he is

representing this District Municipality in his capacity as Air Quality Officer, responsible for the

implementation of the NEM: Air Quality Act, 2004 (Act No. 39 of 2004).

As it was the case over the past years, it would most properly be this office that will receive

complaints regarding health nuisances from the community that may be caused by this activities.

These complaints will most properly be dealt with in terms of the provisions of the National Health

Act, 2003 (Act No. 61 of 2003). Therefor we see it as crucial for the protection of the wellbeing of

the Worcester community that this office also get the opportunity to give comments, set

conditions and/or objections to this application.

2. In the “Notice of Intent” it is stated by the applicant that an application for rezoning and/or

consent use is not applicable.

This may properly not be the case. In other instances in Worcester where manure was stored

and/or processed on premises, the owners of the involved premises were obliged to apply for

rezoning and/or consent use to enable the applicant to continue with the activity. We advise and

request that this issue be taken up with Mr. Pieter Hartzenberg, Chief Town Planner of Breede

Valley Municipality.

3. In section 3 of the “Notice of Intent”, (Project Description), reference is made to the structure to

be used for the storage of the “incoming” or fresh manure . As the storage of up to 300 tons of

manure may be a big potential source of offensive odour emissions, other health nuisances and

environmental pollution, we would request that more detailed information should be provided

regarding this storage facility, measures to prevent environmental pollutions such as ground and

water pollution, as well as detailed measures to be taken to control flies, to prevent fly hatching as

well as the prevention of emission of offensive odours. The vague mentioning of possible measures

to be implemented is not adequate. Information regarding the process of “feeding” the manure

into the bio-digester is also requested.

4. It is also vaguely referred to in section 3 of the “Notice of Intent”, (Project Description), that the

process involve the drying and pelletizing of the approximately 80 tons of digestate per day (waste

product of the bio-digestion process). We assume that this digestate will properly contain mostly

manure. In the past we received numerous complaints regarding offensive odours from a chicken

manure/compos pelletizing industry, also involving drying of the manure/compos. We therefor

requested that detail information must be provided regarding the storage and conveyance method

of the digestate from the bio-digester towards the drying and pelletizing processes, detail

information of the drying and pelletizing processes, as well as details of measures to be

implemented to sufficiently prevent and reduce dust as well as odour emissions from and during

these processes. Also including protective measures applicable to protect the health of workers in

these sections.

4

5. Regarding section 7 of the “Notice of Intent” ( Public Participation), the following: It seems that the

applicant suggest that public participation will be limited to the owners and/or occupants of

adjacent premises, the municipal ward councillor, various organs of state and a notice in an official

Gazette. Possible odour releases may affect not only the direct adjacent premises owners and

occupants, but may also negatively affect various residential communities, as is currently the

situation with emissions released from other sources situated on this specific involved premises

(the By-product plant). Numerous complaints were received over the years from residential areas

situated further than the adjacent premises regarding offensive odours emitted from this involved

premises, indicating that it is not only the directly adjacent premises that may be negatively

affected by possible emissions of offensive odours. We therefor request that the public

participation process must be expanded to also include a written notice in English and Afrikaans in

a local newspaper and to provide the community the opportunity to also give comments on this

application and/or register objections to it.

Your Departments consideration and addressing of the above mentioned concerns and requests will be

appreciated.

Yours sincerely.

Willie Roux


Tell: 023 348 2359




Willie Roux Environmental Health Practitioner Cape Winelands District Municipality

� 51 Trappes Street, Worcester, 6850,

� 023 348 2359

�

� 023 347 3668



1

Colleen McCreadie



To: '[email protected]'; Peter Harmse

Cc: Marius Engelbrecht ([email protected]); 'Waleed Galvaan';

'd'[email protected]'



0151011 Trigen EA_06.01.16.pdf; FW: Notice of Intent to Apply for a Waste Licence

- Trigen Worcester Manure Biodigester; RE: RCL Foods biodigester adaptation -

authority site inspection

Dear Joy and Peter

We hope this emails finds you well?


engineers. In preliminary consultations with the CWDM air quality, Marius Engelbrecht has suggested that we

request input into this application from the DEA&DP’s air quality directorate.












authorities may have with the application. In this regard, please refer to the feedback received from CWDM

environmental health and from CWDM air quality in response to the NoI.

Should DEA&DP air quality have any concerns or queries with this manure digestion application, it would be much

appreciated if you could advise us of same.

We are arranging a site inspection for the various authorities involved in this application, hopefully next week.

Possibly Friday 18th? For those travelling from Cape Town, 11am should be a suitable time.

If your office wishes to attend the meeting to review the existing effluent Biodigester plant and to discuss any

technical aspects with the project engineers, please do advise?


Kind regards

2



P: +27 (0) 21 712 5060

F: +27 (0) 21 712 5061

M: +27 (0) 83 695 1664

[email protected]



1

Colleen McCreadie






0151011 Trigen EA_06.01.16.pdf

Dear Lerato

We hope this emails finds you well?


engineers.












authorities may have with the application. Should the DoE heave any concerns or queries with this small-scale,

private use energy application, it would be much appreciated if you could advise us of same.





Kind regards



P: +27 (0) 21 712 5060

F: +27 (0) 21 712 5061

M: +27 (0) 83 695 1664

[email protected]



1

Colleen McCreadie




Cc: 'Willie Roux'

Subject: Manure biodigester, RCL Foods, Worcester

Attachments: FW: Notice of Intent to Apply for a Waste Licence - Trigen Worcester Manure

Biodigester; 0151011 Trigen Worcester NoI 05.07.17 final.pdf; Rainbow Processing

Plant.kmz

Dear Guillome

We obtained your details from Mr Willie Roux at Environmental Health, Cape Winelands District Municipality.

Willie requested that we obtained DoH input on an application that we are submitting on behalf of the Trigen Group

(Pty) Ltd – renewable energy engineers.



on site.






Please find attached the Notice of Intent to Apply submitted to the DEA&DP, attached for your reference; as well as

Willie Roux’s feedback on the NoI.


authorities may have with the application. Willie’s concerns have been forwarded to Trigen and the project team is

ensuring that they will be addressed in the BAR.

Should the DoH heave any additional concerns or queries that we should address, it would be much appreciated if

you could advise us of same.





Kind regards

"Environmental Solutions for a


P: +27 (0) 21 712 5060

F: +27 (0) 21 712 5061

M: +27 (0) 83 695 1664

[email protected]

2

Changing World" www.environmentalconsultants.co.za


1

Colleen McCreadie



To: Elkerine Rossouw ([email protected]); '[email protected]'

Subject: RCL Foods McAlister Road, Worcester - proposed manure digestion


Dear Elkerine

We hope this email finds you well?

The RCL Foods poultry processing plant, Erf 4396, McAlister Road, Worcester Industria, refers.

As you will see from the attached documents, Trigen renewable energy engineers are proposing to adapt the

existing effluent digestion plant so that the plant can also digest manure, thereby generating additional biogas for

additional electricity generation purposes.

The plant has an associated risk of groundwater or surface water contamination – if on a large scale and long-term

basis, the manure is stored in an uncontrolled manner. This is unlikely to occur, since manure offloading and storage

will take place in a purpose-designed unit. And from the unit onwards in the process, the biodigestion process is a

closed system.

We are proposing a groundwater monitoring programme on the precautionary principle: Groundwater monitoring

wells should be established up- and down-hydraulic gradient of the plant; and sampling for XXX should be

undertaken during the rainy and the dry season.

Could your office please advise what parameters you would wish to be sampled for given the contaminant potential

of manure? Also, of effluent from the existing plant? From our Draft BAR for a new effluent and manure Biodigester

plant up in Rustenburg:

Contamination of groundwater and the stormwater system[1]: There is a risk of contamination of groundwater (exposed soil surfaces) and surface water runoff across hardened site surfaces during the construction, operational and decommissioning phase. During the construction and decommissioning phases, industry standard management measures should adequately minimise this risk (e.g. cement mixing in containers; a dedicated, secure and bunded chemical store, etc.). However, during the operational phase, such contamination could occur due to a spillage of effluent, or of acids used intermittently as an input into the effluent biodigestion tanks to balance pH. Contamination could also occur from leaching of liquids from the manure feedstock with a high contaminant load. Ingress to soil could occur if the manure were stored in an uncontrolled manner, on a large scale and on a long-term basis. Ingress to the stormwater system could occur if the manure storage area (large scale, long term) were open to rainfall and surface water flows to stormwater became contaminated. The table below illustrates the potential pollutant linkages associated with the proposed Biodigester development in terms of the source, pathway and receptor:

Source Pathway Receptor

Leaking tanks/pipework Uncontrolled manure storage – large scale, long term

Surface runoff Stormwater system feeding into wetlands/natural drainage channels

Leaking tanks / pipework Uncontrolled manure storage – large scale, long term

Exposed ground Groundwater and groundwater users

Effluent: Contamination of the stormwater system (potentially including wetlands and natural drainage channels) and groundwater would entail increased chemical oxygen demand from effluent ingress, thereby altering biological activity in the receiving freshwater systems.

2

Acid: Acid ingress into natural freshwater systems could lower the pH of these systems. This could cause, for example, invasion of non-desirable species of plankton; and disappearance of fish populations. Manure: Compounds of concern which occur in manure include nitrate-nitrogen (NO3-N), phosphorus (P), ammonia (NH3), organic matter and bacteria. Examples of impacts on groundwater and freshwater systems from some of these compounds is as follows:

� Phosphorus impacts freshwater systems though increased nutrification, leading to excessive algae growth. With the die-off and decomposition of algae, dissolved oxygen in the freshwater system is reduced, which can lead to suffocation of fish and other aquatic life. Accelerated nutrification can then also accelerate eutrophication of water bodies – the process whereby the water body “evolves into a bog or marsh and eventually disappears”.

� Organic matter present in manure runoff can greatly increase biological oxygen demand in freshwater systems, with the potential for

suffocation of fish and other aquatic life.

� Elevated levels of nitrate-nitrogen (NO3-N) in drinking water (boreholes; users of river water) can pose health problems, especially for young infants (where bacteria in the stomach convert the nitrate to nitrite (NO2). NO2 impacts the ability of the bloodstream to effectively take up oxygen). Similarly, young livestock are susceptible to health problems from high NO3-N containing drinking water.

� Faecal bacteria-contamination can also impact groundwater and surface water users – infectious diseases such as dysentery, typhoid

and hepatitis can be spread. It is therefore essential to prevent contact of the identified compounds of concern with groundwater (through exposed surfaces) and surface water (across hardened surfaces into the stormwater system). The likelihood of contamination occurring due to spills or leaks of effluent, acid or from overexposure of manure to the soil or rainfall, is considered to be low associated with the waste-to-value plant. The aboveground tanks and pipework will be designed and constructed according to industry best-practice; hardened surfaces and bunded areas will be in place as required; and a rapid spill / emergency detection and response is anticipated in accordance with an appropriate Emergency Response Plan.

Suitable mitigation and management measures for minimising contamination risk include:

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

− API STD 620 – recommended rules for design and construction of low pressure tanks

− AWWA D103 – design, construction, inspection and testing of factory coated steel bolted tanks

− AWWA D100 - design, manufacture and procurement of welded carbon steel tanks

− BS2594 - specification for carbon steel welded horizontal cylindrical storage tanks

− BS2654 - manufacture of vertical steel welded storage tanks with butt welded shells

− SANS 1476 - fabricated flanged steel pipework, pipe and fittings

− SANS310 - storage tank facilities for hazardous chemicals)

− BS 8007 - design of concrete structures for retaining aqueous liquids

− SANS 10100 - the structural use of concrete

− SANS 10162 - the structural use of steel

− SANS 10108 - the classification of hazardous locations and the selection of equipment for use in such locations

− SANS 62305 – protection against lightning

� 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. Please refer to the example of a suitable storage unit attached in Appendix D.

� A groundwater monitoring programme should be established at the waste-to-value plant. Groundwater Monitoring wells should be established up- and down-hydraulic gradient of the plant; and sampling for XXX should be undertaken during the rainy and the Dry season.

Your assistance with this matter would be much appreciated.

Kind regards


P: +27 (0) 21 712 5060

3


F: +27 (0) 21 712 5061

M: +27 (0) 83 695 1664

[email protected]



[1]

http://www.lenntech.com/aquatic/acids-alkalis.htm The Centre for Soil and Water Conservation, University of Guelph. Impacts of Livestock Manure on Water Quality in Ontario: An

Appraisal of Current Knowledge.

University of Missouri. Assessing the Risk of Groundwater Contamination from Animal Manure Management Facilities, October

1995 ( http://extension.missouri.edu/p/WQ657)

Minnesota Pollution Control Agency. Nutrients: Phosphorus, Nitrogen - Sources, Impact on Water Quality - A General Overview.,

May 2008 (https://www.pca.state.mn.us/sites/default/files/wq-iw3-22.pdf)

appendix f public participation information: including a ... · 11th floor, utilitas building, 1...

Documents