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ENVIRONMENTAL COMPLIANCE AUDIT REPORT PROJECT NAME: Decommissioning of Scaw Metals Dimbaza Foundry
PROJECT NO: J2015‐08
REPORT NO: 01
DEDEAT REF: EC/11/A/LN1/27 (iv)/13‐08
DATE: 23/09/2015
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Indwe Environmental Consulting CC 12 Preston Avenue• Vincent • East London • 5247 www.indwecon.co.za Tel: 043 726 6860 Fax: 086 513 9734 Email: [email protected] Company Registration No.: 2006/074394/23
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Decommissioning of Scaw Metals Dimbaza Foundry Environmental Inspection Audit Report
Audit Report No: 01
Contents
Chapter Description Page
1 INTRODUCTION ‐ 3 ‐
1.1 ECO Reporting Requirements ‐ 3 ‐
2 REPORTNO: 01 ‐ 4 ‐
2.1 Aspects Inspected ‐ 4 ‐
2.2 Summary of level of Contractors Compliance to EMPr ‐ 4 ‐
2.3 Non‐Compliance ‐ 4 ‐
2.4 Partial Compliance ‐ 4 ‐
2.5 Decommissioning Activities ‐ 4 ‐
2.6 Positive Aspects ‐ 5 ‐
2.7 Future Expectations ‐ 5 ‐
2.8 Conclusion ‐ 5 ‐
3 AUDIT CHECKLIST ‐ 6 ‐
3.1 Administration ‐ 6 ‐
3.2 Site Camp ‐ 7 ‐
3.3 Work Areas ‐ 9 ‐
3.4 Close Out ‐ 13 ‐ APPENDIX A Supporting Photographs APPENDIX B Distribution Register
Decommissioning of Scaw Metals Dimbaza Foundry - ECO Audit 01 - 23/09/2015
1 INTRODUCTION
Scaw South Africa (Pty) Ltd appointed Indwe Environmental Consulting as an independent Environmental Control Officer (ECO) to monitor compliance with the Environmental Authorisation and Environmental Management Programme (EMPr) compiled for the Decommissioning of the Dimbaza Foundry located in Dimbaza, King Williamstown, Eastern Cape.
1.1 ECO Reporting Requirements
Section 3.1 of the Environmental Authorisation stipulates that the applicant must appoint an independent Environmental Control Officer to monitor compliance with the conditions of authorisation. Section 4 of the Environmental Authorisation states that the ECO must conduct monitoring sessions to ensure compliance with the conditions of authorisation, as well as the Environmental Management Programme prepared for this project. These monitoring sessions must take place on a quarterly basis and the audit reports must be submitted to the Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) at the end of each quarter.
Decommissioning of Scaw Metals Dimbaza Foundry - ECO Audit 01 - 23/09/2015
2 REPORT NO: 01
2.1 Aspects Inspected
The EMPr and Environmental Authorisation contains a host of conditions and specifications. Only those relevant to the current decommissioning activities were audited, the rest were marked as not applicable (Refer to audit checklist below). 2.2 Summary of level of Contractors Compliance to EMPr
Based on observations made during the site visit 100% of the planning phase aspects and 100% of the construction phase aspects audited were compliant. It is evident that Scaw has been vigilant and played detailed attention to the environmental aspects and compliance of this project.
2.3 Non‐Compliance
There were no non‐compliance issues identified during this site inspection.
2.4 Partial Compliance
There were no partial‐compliance issues identified during this site inspection.
2.5 Decommissioning Activities
The decommissioning activities inspected during this audit included:
The dismantling and plasma cutting of the existing steel structures around the site.
The safe removal and temporary storage of asbestos sheeting.
The clean up and disposal of mineral waste.
The removal of waste contained in the pits.
SITE INSPECTION DETAILS
Date: 23/09/2015 Report No: 01
Project: Decommissioning of Scaw Metals Dimbaza Foundry
Client: Scaw Metals
Phase:
Present:
Indwe ECO (Mr Blake Edwards)
Scaw Metals (Mr Jake Venter)
Decommissioning of Scaw Metals Dimbaza Foundry - ECO Audit 01 - 23/09/2015
2.6 Positive Aspects
All aspects of the EMPr and Environmental Authorisation have been complied with.
Scaw have maintained brilliant housekeeping on site.
The site has been kept free of and all solid waste has been either placed in bins or contained and temporarily stock piled until collection and disposal.
All documentation including proof of adequate waste disposal has been filled and kept in the site office.
2.7 Future Expectations
Scaw are expected to maintain a great level of compliance throughout the decommissioning
phase of the project.
2.8 Conclusion
Scaw have 100 % complied with the EMPr and Environmental Authorisation for this audit and must be commended on their compliance, although there has only been a small amount decommissioned to date.
Decommissioning of Scaw Metals Dimbaza Foundry - ECO Audit 01 - 23/09/2015
3 AUDIT CHECKLIST
3.1 Administration
DECOMMISSIONING PHASE ‐ ADMINISTRATION
1. Environmental File Yes
Partial
No
N/A
Observations Corrective Action
Site Plan Layout. X The Environmental file has been kept up to date. EMPr. X
Permits & Environmental Authorisation.
X
Method Statements. X
Community Complaints Register.
X
Emergency Incidents Register
X
Audit Reports. X
Environmental Correspondence.
X
Minutes of Meetings. X
Emergency Response Plan compiled and on site.
X
TOTAL: 10 10
DECOMMISSIONING PHASE ‐ ADMINISTRATION
2. Environmental Control Officer Y
es
Partial
No
N/A
Observations Corrective Action
Appointment of ECO x
Written notice to DEDEAT. x
TOTAL: 02 2
DECOMMISSIONING PHASE ‐ ADMINISTRATION
3. Environmental Induction & Training
Yes
Partial
No
N/A
Observations Corrective Action
Contractor EMPr induction. X
Contractor’s personnel environmental awareness training toolbox talks
X
Record of environmental training.
X
TOTAL: 03 3
Decommissioning of Scaw Metals Dimbaza Foundry - ECO Audit 01 - 23/09/2015
3.2 Site Camp
DECOMMISSIONING PHASE – SITE CAMP
1. Site Camp Establishment
Yes
Partial
No
N/A
Observations Corrective Action
Appropriate Site Access. X
Adequate Signage (i.e. Site entrance, emergency numbers, first aid, fire extinguishers).
X
Adequate Fencing/ Gates/Security.
X
TOTAL: 03 3
DECOMMISSIONING PHASE – SITE CAMP
2. Solid Waste Management
Yes
Partial
No
N/A
Observations Corrective Action
Litter in site camp. X
Burning or burying of waste. X
Scavenger proof waste bins. X
Waste collection and disposal.
X
Documentation for waste collection and disposal.
X
TOTAL: 04 4
DECOMMISSIONING PHASE – SITE CAMP
3. Hazardous Material & Waste Management
Yes
Partial
No
N/A
Observations Corrective Action
Neatness of hazardous material storage area.
X
Diesel tank adequately bunded.
X
Sufficient drip trays & use of drip trays.
X
Sufficient hazardous waste spill kits.
X
Hazardous waste drums. X
Hazardous material spills & clean‐up.
X
Hazardous waste collection and disposal.
X
Documentation for waste collection and disposal.
X
TOTAL: 08 8
DECOMMISSIONING PHASE – SITE CAMP
4. Sanitation
Yes
Partial
No
N/A
Observations Corrective Action
Sufficient toilets available for both men & woman.
X
Chemical toilets anchored. X
Decommissioning of Scaw Metals Dimbaza Foundry - ECO Audit 01 - 23/09/2015
Toilets clean and regularly serviced.
X
Documented proof that the chemical toilets are regularly serviced.
X
TOTAL: 04 4
Decommissioning of Scaw Metals Dimbaza Foundry - ECO Audit 01 - 23/09/2015
3.3 Work Areas
DECOMMISSIONING PHASE – WORK AREAS
1. Decommissioning Footprint
Yes
Partial
No
N/A
Observations Corrective Action
Site plan demarcating the physical extent of the works.
X
Adequate demarcation of the work areas.
X
Decommissioning activities contained within work areas.
X
TOTAL: 03 3
DECOMMISSIONING PHASE – WORK AREAS
2. Access to Work Areas
Yes
Partial
No
N/A
Observations Corrective Action
Adequately demarcated & sufficient signage.
X
Public protection. X
Access control. X
TOTAL: 03 3
DECOMMISSIONING PHASE – WORK AREAS
3. Solid Waste Management
Yes
Partial
No
N/A
Observations Corrective Action
Litter in work area. X
Burning or burying of waste
X
Is there a central waste storage area and is it well managed.
X
Are there sufficient scavenger proof waste bins with lockable lids.
X
Waste collection and disposal to registered landfill site.
X
Documentation for waste collection and disposal.
X
Waste separation into different waste categories (i.e. general waste, hazardous waste, inert rubble).
X
Recycling & Reuse of waste X
Inert Material used for fill. X
Fill adequately compacted. X
TOTAL: 10
DECOMMISSIONING PHASE – WORK AREAS
4. Hazardous Waste Management
Yes
Partial
No
N/A
Observations Corrective Action
Hazardous waste from x
Decommissioning of Scaw Metals Dimbaza Foundry - ECO Audit 01 - 23/09/2015
Area 2 disposed directly as a Type 1 waste to a suitably licensed Class A/H:H Landfill site.
Hazardous waste from Area 2 treated with lime and disposed of as a Type 4 waste to a suitably licensed Class D or GLB landfill site.
X
Hazardous waste from within the foundry area appropriately handled and correctly disposed of.
X
Documented proof of hazardous waste disposal.
X
Sufficient drip trays & use of drip trays.
X
Hazardous material spills & clean‐up (i.e. pollution of topsoil and watercourses).
X
Was DEDEAT informed within 24 hours of spill.
X
Was clean‐up conducted within 12 hours of spill.
X
Servicing of machines and equipment outside of designated area.
X
Hazardous waste adequately stored at temporary storage area prior to removal and disposal.
X
TOTAL: 10 5 5
DECOMMISSIONING PHASE – WORK AREAS
5. Sanitation
Yes
Partial
No
N/A
Observations Corrective Action
Sufficient toilets within work areas.
X
Chemical toilets anchored. X
Toilets clean and regularly serviced.
X
Documented proof that the chemical toilets are regularly serviced.
X
TOTAL: 04 4
DECOMMISSIONING PHASE – WORK AREAS
6. Noise & Vibration Management
Yes
Partial
No
N/A
Observations Corrective Action
Noise levels within reasonable norms.
X
Surrounding business and residential areas informed of the timeframe for decommissioning.
X
Community complaints. X
Appropriate work hours. X
Silencers on machinery and vehicles maintained.
X
TOTAL: 05 5
Decommissioning of Scaw Metals Dimbaza Foundry - ECO Audit 01 - 23/09/2015
DECOMMISSIONING PHASE – WORK AREAS
7. Dust Control
Yes
Partial
No
N/A
Observations Corrective Action
Adequate dust control measures timeously implemented.
x
TOTAL: 01
DECOMMISSIONING PHASE – WORK AREAS
8. Culture & Heritage
Yes
Partial
No
N/A
Observations Corrective Action
Have archaeological or paleontological items been detected.
x
Has ECPHRA been informed x
TOTAL: 02 2
DECOMMISSIONING PHASE – WORK AREAS
9. Topsoil Management
Yes
Partial
No
N/A
Observations Corrective Action
Topsoil adequately removed from work areas.
X
Topsoil adequately stockpiled (i.e. does not exceed 2m high, no damming of water, no wind/soil erosion).
X
Topsoil mixed with subsoil or building rubble.
X
Topsoil stockpiles dampened during dry conditions.
X
Driving of vehicles or heavy plant on topsoil stockpiles.
X
TOTAL: 05 5
DECOMMISSIONING PHASE – WORK AREAS
10. Spoil Stockpiles
Yes
Partial
No
N/A
Observations Corrective Action
Spoil material adequately stockpiled (i.e. dedicated area, no damming of water, not mixed with topsoil).
X
Spoil material removed and appropriately disposed of.
X
Appropriate areas for spoiling oversized material.
X
TOTAL: 03 3
DECOMMISSIONING PHASE – WORK AREAS
Decommissioning of Scaw Metals Dimbaza Foundry - ECO Audit 01 - 23/09/2015
11. Erosion Management
Yes
Partial
No
N/A
Observations Corrective Action
Practical anti‐erosion measures timeously implemented and maintained.
X
Stormwater control measures implemented.
X
TOTAL: 02 2
DECOMMISSIONING PHASE – WORK AREAS
12. Rehabilitation & Landscaping
Yes
Partial
No
N/A
Observations Corrective Action
Shaping and re‐vegetation of disturbed surfaces immediately implemented once decommissioning activities are completed.
X
Rehabilitated areas adequately merge with surrounding environment.
X
TOTAL: 02 2
Decommissioning of Scaw Metals Dimbaza Foundry - ECO Audit 01 - 23/09/2015
3.4 Close Out
DECOMMISSIONING PHASE – CLOSE OUT
1. Site Camp
Yes
Partial
No
N/A
Observations Corrective Action
All site camp structures removed from site (i.e. containers, fences, building material, spoil material).
X
Hazardous substance spills cleaned up and appropriately disposed of.
X
Hardened surfaces ripped, foreign materials removed, topsoil layer replaced and shaped.
X
Rehabilitated area adequately merges with surrounding environment.
X
TOTAL: 04 4
DECOMMISSIONING PHASE – CLOSE OUT
2. Work Area
Yes
Partial
No
N/A
Observations Corrective Action
Decommissioned footprint rehabilitated to appropriate vegetative state.
X
Area 2 hazardous waste removed and disposed of.
X
Area 2 rehabilitated. X
TOTAL: 03 3
Decommissioning of Scaw Metals Dimbaza Foundry - ECO Audit 01 - 23/09/2015
APPENDIX A
SUPPORTING PHOTOS
Figure 1 An example of bins provided on site for solid waste.
Figure 2 Evidence that the deisel tank is not leaking and the bunded area is in
good condition.
Decommissioning of Scaw Metals Dimbaza Foundry - ECO Audit 01 - 23/09/2015
Figure 3 Hazardous waste storage area.
Figure 4 Mineral waste stored in bags.
Figure 5 Asbestos that has been stored and covered in black plastic sheeting.
Figure 6 One of the pits that have recently been emptied.
Decommissioning of Scaw Metals Dimbaza Foundry - ECO Audit 01 - 23/09/2015
APPENDIX B
DISTRIBUTION REGISTER
FIRST NAME SURNAME ORGANISATION ROLE EMAILJake Venter Scaw Metals Site
Manager [email protected]
Briant Noncembu DEAET Regional Director