MANUFACTURING OF PORCELAIN TILES - jaws.co.za Farms IWULA/F… · RAYAL INDUSTRIAL (PTY) LTD ....

RAYAL INDUSTRIAL (PT Y) LTD

S o u t h A f r i c a n p o r c e l a i n R o o f & F l o o r T i l e s P r o d u c e

MANUFACTURING OF PORCELAIN TILES ERVEN 171-176 GALENA STREET, EKANDUSTRIA,

CITY OF TSHWANE, GAUTENG

DRAFT ENVIRONMENTAL MANAGEMENT PROGRAMME REPORT

GDARD Reference Number: S24G/03/14-15/0327

APRIL 2016

Report prepared by:

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PURPOSE OF THIS DOCUMENT

Rayal Industrial (Pty) Ltd operates a porcelain tile manufacturing facility, at Erven 171-176 Galena Street, Ekandustria, in the City of Tshwane Metropolitan Municipality, Gauteng. The facility produces roof tiles and floor tiles, which are sold in bulk to commercial clients such as CTM, Builders Warehouse, and others.

Porcelain tile production is a listed activity in terms of the National Environmental Management: Air Quality Act (NEM:AQA) (Act No. 39 of 2004). As a result the facility must have an atmospheric emission license (AEL) in terms of this Act. In addition, prior to commencing with a listed activity, the company was supposed to obtain an environmental authorisation (EA) in terms of the National Environmental Management Act (NEMA) (Act 107 of 1998). Since the company has commenced with operations without the necessary EA and AEL, it needs to apply for a Section 24G rectification in terms of NEMA from the Gauteng Department of Agriculture and Rural Development (GDARD) and an AEL from the local municipality.

The GDARD issued a Directive to Rayal Industrial on 20 August 2016, instructing the company to apply for the NEMA Section 24G rectification. One of the conditions of the Directive, was the compilation of an Environmental Management Programme Report (EMPr) for the facility. This report provides an initial EMPr for GDARD to cover the key risks and potential impacts identified for the site. It includes commitments for further investigations to address risks and potential impacts that could not be quantified during the Section 24G application. The report is a living document that should be reviewed and updated regularly to include any further investigations and any changes to the facility as it continues operations.

This report was prepared by:

Environmental Assessment Practitioner:

Praveshni Sewmohan PO Box 665, Lonehill 2062 Email: [email protected] Fax: 086 503 9471 Cel: 083 629 8825

Proponent:

Assistant General Manager: Mr Haroon Khan Rayal Industrial (Pty) Ltd PO Box 71192 Die Wilgers 0041 Email: [email protected] Tel: 013 933 3846 Fax: 013 933 4005

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TABLE OF CONTENTS

1 INTRODUCTION ............................................................................................................. 1 1.1 Purpose of this report .................................................................................... 1 1.2 Content of this report .................................................................................... 1 1.3 Environmental Assessment Practitioner ....................................................... 1 1.4 Applicable Environmental Legislation ........................................................... 2

2 BACKGROUND TO THE PROJECT ............................................................................... 5 2.1 Property and location .................................................................................... 5 2.2 Background to Rayal Industrial ..................................................................... 5 2.3 Capacity of the facility ................................................................................... 5 2.4 Existing operations at the site ....................................................................... 5 2.5 Water supply ................................................................................................. 9 2.6 Waste management ...................................................................................... 9

3 PUBLIC PARTICIPATION ............................................................................................. 10 3.1 Identification of stakeholders and an I&AP register .................................... 10 3.2 Site Notice ................................................................................................... 10 3.3 Written notice and involving disadvantaged stakeholders .......................... 10 3.4 Advertisement ............................................................................................. 10 3.5 Availability of the Section 24G and AEL Report for public review ............... 10 3.6 Notification of GDARD Decision ................................................................. 10 3.7 Issues and comments of concern ............................................................... 10

4 RECEIVING ENVIRONMENT ....................................................................................... 11 4.1 Topography ................................................................................................. 11 4.2 Climate ........................................................................................................ 11 4.3 Surface water .............................................................................................. 11 4.4 Ground water .............................................................................................. 11 4.5 Soils and geology ........................................................................................ 11 4.6 Air quality .................................................................................................... 11 4.7 Social .......................................................................................................... 12 4.8 Sense of place ............................................................................................ 13 4.9 Cultural and heritage ................................................................................... 13

5 IMPACT ASSESSMENT ................................................................................................ 14 5.1 Methodology for Impact Assessment .......................................................... 14 5.2 Assessment of potential impacts ................................................................ 15 5.3 Recommendations to address identified impacts........................................ 16

6 ROLES AND RESPONSIBILITIES ................................................................................ 18 7 ENVIRONMENTAL MITIGATION AND MANAGEMENT ............................................... 19

7.1 Closure and post-closure plan .................................................................... 23 8 ENVIRONMENTAL MONITORING PLAN ..................................................................... 24

8.1 Objectives ................................................................................................... 24 8.2 Sampling and methodology ........................................................................ 24 8.3 Air quality .................................................................................................... 24 8.4 Water quality and quantity .......................................................................... 25 8.5 Health and safety ........................................................................................ 26 8.6 Infrastructure integrity ................................................................................. 26

9 ENVIRONMENTAL AWARENESS PLAN ..................................................................... 27 9.1 Legal Requirements .................................................................................... 27 9.2 Objectives of the Environmental Awareness Plan ...................................... 27 9.3 Implementation of the Environmental Awareness Plan and other Training Programmes 27

10 REPORTING ................................................................................................................. 30 10.1 Reporting to Authorities .............................................................................. 30 10.2 Internal Reporting ....................................................................................... 30

11 CONCLUSION ............................................................................................................... 31

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12 REFERENCES .............................................................................................................. 32 FIGURES Figure 1: Site location of the Rayal Industrial facility within Ekandustria, showing surrounding areas 6 Figure 2: Facility Organogram 18 Figure 3: Ambient air quality monitoring point for the site 25 TABLES Table 1: Summary of Activities Requiring Authorisation under R543, 544 and 545 of 2010 3 Table 2: Summary of Activities Requiring an Atmospheric Emission License in terms of GN 893 4 Table 3: Waste streams generated at Rayal Industrial 9 Table 4: Scoring of impacts 14 Table 5: Impact Assessment Summary 15 Table 6: Point source emission monitoring for the site 24 Table 7: Ambient air quality monitoring for the site 25 APPENDICES Appendix 1: Emergency Response Plan

EMPr: MANUFACTURING OF TILES IN EKANDUSTRIA Rayal Industrial GDARD Reference Number: S24G/03/14-15/0327

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1 INTRODUCTION Rayal Industrial (Pty) Ltd operates a porcelain tile manufacturing facility, at 14 Galena Street, Ekandustria, in the City of Tshwane Metropolitan Municipality, Gauteng from September 2013. The facility produces roof tiles and floor tiles, which are sold in bulk to commercial clients.

Tile production is a listed activity in terms of the National Environmental Management: Air Quality Act (NEM:AQA) (Act No. 39 of 2004). As a result the facility must have an atmospheric emission license (AEL) in terms of this Act. In addition, prior to commencing with a listed activity, the company was supposed to obtain an environmental authorisation (EA) in terms of the National Environmental Management Act (NEMA) (Act 107 of 1998). Since the company has commenced with operations without the necessary EA and AEL, it needs to apply for a Section 24G rectification in terms of NEMA from the Gauteng Department of Agriculture and Rural Development (GDARD) and an AEL from the local municipality.

1.1 Purpose of this report The GDARD issued a Notice of Intention to Issue a Compliance Notice on 27 November 2014 and a Directive on 20 August 2016, instructing Rayal Industrial (Pty) Ltd to apply for the NEMA Section 24G rectification. One of the conditions of the Directive, is the compilation of an Environmental Management Programme report (EMPr) for the facility.

This EMPr provides mitigation and management measures to address the key risks and impacts identified for the site during the Section 24G application process. It includes commitments for further investigations to address risks and potential impacts that could not be quantified during the Section 24G application. The report is a living document that should be reviewed and updated regularly to include any further investigations and any changes to the facility as it continues operations.

1.2 Content of this report This report provides the following information:

• Background information to the project (Section 2). • Public comment and concerns raised about the facility during the Section 24G process

(Section 3). • Receiving environment (Section 4). • Impact Assessment (Section 5). • Roles and Responsibilities (Section 6). • Environmental Management Measures (Section 6). • Environmental Monitoring Plan (Section 8). • Environmental Awareness Plan (Section 9). • Emergency Response Plan (Appendix 1).

1.3 Environmental Assessment Practitioner Rayal Industrial appointed Praveshni Sewmohan, an environmental assessment practitioner (EAP) to conduct this Section 24G application and prepare this EMPr.

1.3.1 Air quality specialist An air impact assessment was conducted by Airshed Planning Professionals, a specialist consulting company undertaking air impact assessments for over 20 years, and their report is part of the Section 24G Application Report.


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1.4 Applicable Environmental Legislation The following environmental legislation is applicable to the project.

1.4.1 The Constitution of the Republic of South Africa (Act 108 of 1996) Section 24 of the Constitution states that: Everyone has the right:

a) to an environment that is not harmful to their health or well-being; and

b) to have the environment protected, for the benefit of present and future generations, through reasonable legislative and other measures that-

i. prevent pollution and ecological degradation;

ii. promote conservation; and

iii. secure ecologically sustainable development and use of natural resources, while promoting justifiable economic and social development

The current environmental laws in South Africa concentrate on protecting, promoting, and fulfilling the Nation’s social, economic and environmental rights; while encouraging public participation, implementing cultural and traditional knowledge and benefiting previously disadvantaged communities.

1.4.2 National Environmental Management Act (Act 107 of 1998), as amended (NEMA)

The National Environmental Management Act, 107 of 1998, as amended, (NEMA), specifies that it is necessary for an applicant to undertake an EIA, which meets the minimum requirements of section 24(7) of NEMA, where an activity requires permission by law. The minimum requirements of section 24(7) of NEMA are regulated by the EIA Regulations, of which the latest Regulations were promulgated in December 2014 (Government Notices R983 and R984). Since this facility commenced in September 2013, the previous EIA Regulations, viz. Government Notices R543, R544 and R545 of June 2010, as amended, is also applicable. The identified listed activities applicable to the facility are listed in Table 1 below.

1.4.3 National Environmental Management: Air Quality Act (Act 39 of 2004) (NEM:AQA)

Government Notice GN893 of 22 November 2013 identifies activities which have emissions that have or may have significant detrimental effects. An atmospheric emissions license (AEL) is required for the undertaking of such activities. Table 2 lists the activities that apply to the facility in terms of GN893.


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Table 1: Summary of Activities Requiring Authorisation under R543, 544 and 545 of 20101

2010 EIA Regulations 2014 EIA Regulations Explanation of Applicability R544, 18 June 2010: Listing Notice 1 R983, 4 December 2014: Listing Notice 1 Activity 23: The transformation of undeveloped, vacant or derelict land to –

(i) residential, retail, commercial, recreational, industrial or institutional use, inside an urban area, and where the total area to be transformed is 5 hectares or more, but less than 20 hectares, or (ii) residential, retail, commercial, recreational, industrial or institutional use, outside an urban area and where the total area to be transformed is bigger than 1 hectare but less than 20 hectares;

except where such transformation takes place – (i) for linear activities; or (ii) for purposes of agriculture or afforestation, in which case Activity 16 of Notice No.R. 545 applies.

Activity 28: Residential, mixed, retail, commercial, industrial or institutional developments where such land was used for agriculture or afforestation on or after 01 April 1998 and where such development:

(i) will occur inside an urban area, where the total land to be developed is bigger than 5 hectares; or (ii) will occur outside an urban area, where the total land to be developed is bigger than 1 hectare;

excluding where such land has already been developed for residential, mixed, retail, commercial, industrial or institutional purposes

The property is already zoned for Industrial 1 and therefore is considered to be inside an urban area. The property is 21.767 hectares in extent. However, the facility covers 4.81 hectares only (48 062 m2), i.e., the facility covers less than 5 hectares. This activity was identified in the Section 24G application, and was identified in the GDARD Directive. However, due to the limited extent of the development, this listed activity does not apply to this facility.

R545, 18 June 2010: Listing Notice 2 R984, 4 December 2014, Listing Notice 2 Activity 5: The construction of facilities or infrastructure for any process or activity which requires a permit or license in terms of national or provincial legislation governing the generation or release of emissions, pollution or effluent and which is not identified in Notice No. 544 of 2010 or included in the list of waste management activities published in terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in which case that Act will apply.

The development of facilities or infrastructure for any process or activity which requires a permit or licence in terms of national or provincial legislation governing the generation or release of emissions, pollution or effluent, excluding (i) activities which are identified and included in Listing Notice 1 of 2014; (ii) activities which are included in the list of waste management activities published in terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in which case the National Environmental Management: Waste Act, 2008 applies; or (iii) the development of facilities or infrastructure for the treatment of effluent, wastewater or sewage where such facilities have a daily throughput capacity of 2000 cubic

The facility requires an AEL in terms of the NEM:AQA and therefore this Activity applies.

1 As corrected by “Correction Notice 1” of 30 July 2010, GN No. R. 660 and “Correction Notice 2” (GN No. R. 1159 of 10 December 2010)


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2010 EIA Regulations 2014 EIA Regulations Explanation of Applicability metres or less.

Activity 26: Commencing of an activity, which requires an atmospheric emission license in terms of section 21 of the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004), except where such commencement requires basic assessment in terms of Notice of No. R544 of 2010.

Activity 28: Commencing of an activity, which requires an atmospheric emission license in terms of section 21 of the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004), excluding - (i) activities which are identified and included in Listing Notice 1 of 2014; (ii) activities which are included in the list of waste management activities published in terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in which case the National Environmental Management: Waste Act, 2008 applies; or (iii) the development of facilities or infrastructure for the treatment of effluent, wastewater or sewage where such facilities have a daily throughput capacity of 2000 cubic metres or less.

The facility requires an AEL in terms of the NEM:AQA and therefore this Activity applies.

Table 2: Summary of Activities Requiring an Atmospheric Emission License in terms of GN 893

Process Number: Listed Process Description: Explanation of Applicability

3.6

Synthetic gas production and clean-up: The production and clean-up of a gaseous stream derived from coal gasification and includes gasification, separation and clean up of a raw gas stream through a process that involves sulphur removal and Rectisol as well as the stripping of a liquid tar stream derived from the gasification process. Application: All facilities.

The synthetic gas plant includes clean-up of tar and therefore this activity applies.

5.2

Drying: The drying of mineral solids including ore, using dedicated combustion installations. Application: Facilities with a capacity of more than 100 tons/month product.

The raw materials spray tower dryer utilises a dedicated coal water slurry furnace, which is a combustion installation. The spray tower produces a maximum of 9 000 tons/ month and therefore this activity applies.

5.9 Ceramic production: The production of tiles, bricks, refractory bricks, stoneware or porcelain ware by firing, excluding clamp kilns. Application: All installations producing 100 ton per annum or more.

The facility produces porcelain tiles which are fired in an open kiln. The facility produces 104 million tons per annum and therefore this activity applies.

S24G Report: MANUFACTURING OF TILES IN EKANDUSTRIA Rayal Industrial GDARD Reference Number: S24G/03/14-15/0327

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2 BACKGROUND TO THE PROJECT

2.1 Property and location The Rayal Industrial facility is situated at Erven 171-176, Galena Street, in Ekandustria, within the City of Tshwane Metropolitan Municipality as shown in Figure 1. This part of Ekandustria is zoned for industrial use and comprises a number of industrial stands. The site is surrounded by other industries and undeveloped industrial stands.

2.2 Background to Rayal Industrial Rayal Industrial is the first porcelain roof and floor tile manufacturer in South Africa and the whole of Africa. Brought to South Africa at the invitation of the Department of Trade & Industry, Rayal has made inroads into the local market and has created permanent jobs in its niche market. The technology and some of the equipment is brought from China.

2.3 Capacity of the facility The existing facility has one production line. The design capacity of the current production line is 15 000 m2 of tiles per day, whilst current production is around 11 000 m2 per day. This translates to 104 million tons of tiles per annum.

2.4 Existing operations at the site The Rayal Industrial facility consists of raw material storage, access roads, synthetic gas plant, ball mills for crushing of raw materials, dryer for crushed material, crushed material (powder) storage, tile press, tile dryer, tile glazing and printing, tile kiln, automated packaging.

2.4.1 Raw material storage Raw material is stored in walled, covered concrete bunkers at the northern end of the site. Trucks are allowed access at the northern end via a secure access gate and material is weighed on a weigh bridge. From the bunkers, material is taken to the ball mill using trucks and bulldozers, as required.

S24G Report: MANUFACTURING OF TILES IN EKANDUSTRIA Rayal Industrial GDARD Reference Number: S24G/03/14-15/0327

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Figure 1: Site location of the Rayal Industrial facility within Ekandustria, showing surrounding areas


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2.4.2 Synthetic gas plant Coal is used to produce synthetic gas, which is then used as the fuel for the tile dryer and kiln. Large nut coal burns in the gasifier, where the right amount of air and water vapour is sent through the induced draft fan (combustion fan) into the gas furnace.

The raw synthetic gas is sent through a dust-extraction unit, electrostatic tar catcher, and electrostatic light oil catcher to produce a clean synthetic gas, which is used in the kiln and tile dryer. In order to prevent waste, tar and light oil from the gas cleaning system is used in the coal water slurry furnace, which provides heat to the dryer for crushed materials. The coal dust is sent to the coal water ball mill, from where it is used in the coal water slurry furnace.

2.4.3 Ball mills for crushing of raw materials The facility has a Coal Water Ball Mill and a Raw Material Ball Mill that are operated on a batch basis.

Coal Water Ball Mill Coal duff and coal dust are milled in this ball mill for a certain period of time to create a liquid that will be sprayed into the Coal Water Slurry Furnace.

The ball mill is operated for 8 hours of the day and produces 10 tons of slurry per day. The slurry is stored in a concrete reservoir from where it is pumped to the coal water slurry furnace.

Raw Material Ball Mill Raw materials from the storage areas are moved by truck and bulldozer to this ball mill. Different raw materials are mixed in the correct proportions required for the specific tile to be manufactured. The materials are crushed in the ball mills into a liquid slurry, where the particles are reduced to a fine powder consistency. The slurry is stored in an underground concrete storage bunker. When required, the slurry is pumped from the storage bunker to the dryer for crushed materials.

The ball mill is operated for 13 to 15 hours per day, and produces up to 100 tons of slurry per day, depending on the production rate of the rest of the facility.

2.4.4 Coal water slurry furnace There are two sources of fuel to this furnace: coal water slurry from the coal water ball mill and oil and tar from the gas cleaning plant. These two streams are mixed together in a given ratio and the mixture is jet sprayed into the furnace and ignited. The fuel burns at temperatures of approximately 1200 degrees. The hot gas stream in the furnace is sent to the spray tower dryer.

2.4.5 Dryer for crushed material The raw material slurry from the underground bunker is pumped to a spray tower dryer and is forced through high pressure jets. The hot gas stream generated in the Coal Water Slurry Furnace is pushed into the spray tower and causes the raw material slurry to dry out, becoming a powder as the moisture is extracted from it. The powder drops to the bottom of the spray tower. The moisture laden air from the spray tower passes through a cooling system to re-capture the water. The re-captured water is sent to the recycling pond on site. The dried powder (10% moisture content) is stored in metal silo-type storage bins and is used as required for manufacturing the tiles. Some moisture is lost through the spray tower vent in the form of steam.


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2.4.6 Tile press Powder from the storage bins drops into a press machine. The press uses different moulds for the specific tile that needs to be made. The powder is pressed by the mould to create the flat floor tile or wavy roof tile shape, and is released on a solid base, on a conveyor track. The conveyor moves the pressed powder to the dryer. In this form, the powder has not become bound and crumbles easily if touched. Therefore, the conveyor system moves each tile along from this point forward until the tile has been baked and can be packaged.

2.4.7 Tile dryer The pressed tiles move through the tile dryer on the conveyor track. Waste hot air from the kiln is passed through the dryer to remove the remaining moisture and bind the powder. Additional heat can be added by burning synthetic gas in the dryer if required. The dryer allows the powder to become completely dry, ensuring no weak spots in the tile, and to allow the powder to bind to a limited extent, so that the tile does not crumble if touched. The dryer is essentially a long drum through which the conveyor track enters one side and exits the other side, moving the tiles along from one end to the other.

2.4.8 Tile glazing and printing Once the drying process is complete, the roof tiles are colour glazed and the floor tiles are first glazed and then screen-printed or digitally printed to give the tiles the desired colour and pattern. The tiles move along the conveyor and the glazing and printing is automated to minimise touching and handling of the tiles. Staff observe the entire process to ensure quality control. The tiles are now ready for the kiln where they can be baked to form a tough but beautiful porcelain tile.

2.4.9 Kiln Tiles move through the kiln, where they are fired at temperatures of up to 1200 °C and thereafter gradually cooled as it exits the kiln. Like the dryer, the kiln is a much longer drum and the tiles stay on the conveyor as they enter the kiln on one end and exit the other end. The kiln utilises the synthetic gas, which is burned through a series of gas burners inside the kiln to heat up the tiles. Towards the exit, the tiles are air cooled.

2.4.10 Packaging The roof tiles are immediately packed after the kiln whereas the floor tiles are edged around the 4 sides (bevelled) before being automatically boxed, packed and palletised. Packaging depends on the type of tile produced and on the branding requirements for that batch of tiles. Packaged tiles are stored within the main building, and are removed from the facility by truck directly to customers.

2.4.11 Water management There are two water management systems on site, as described below.

Storm water management All storm water is diverted from storage areas and the roofs of buildings via drains and channels to the municipal storm water drain that runs along the property boundary. This water is considered clean and uncontaminated and is allowed to leave the site.

Process water management All recovered water within the process is sent to the recycle pond. At the recycle pond, calcium carbonate is added to the water to remove any sulphates in the water. The resulting calcium sulphate sludge drops to the bottom of the recycle pond. The pond is dredged regularly to remove the sludge. The sludge is temporarily stored on site to dry it out, and then included in the raw material sent to the raw material ball mill (i.e., it is incorporated into the tile making process). The ball mills use up all the water sent to the recycle pond. The


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recycle pond has a capacity of 2 280m3 The site has a borehole to supplement its process water stream. The borehole has a yield of 19.7 m3/hour. Water from the borehole is pumped directly into the recycle pond

2.5 Water supply The site obtains municipal water for drinking purposes and for ablutions. The site uses borehole water as make-up water for its tile making processes. The quantities of water used on site needs to be verified.

2.6 Waste management The following Table provides a description of the waste streams generated on the site. A waste management plan needs to be developed for the site and is included as a management measure in the EMPr since quantities and classification of waste streams were not known at the time this report was compiled.

Table 3: Waste streams generated at Rayal Industrial

Source of Waste Waste stream description How this stream is managed

Synthetic gas plant

Ash Temporarily stored on site. Facility plans to give this to brick makers.

Tar and oil Used as a fuel in the coal water slurry furnace

Coal dust Used as a fuel in the coal water slurry furnace

Coal water ball mill No waste

Coal water slurry furnace Ash Temporarily stored on site.

Facility plans to give this to brick makers.

Raw material storage and handling

Spills of material Material is picked up and returned to storage for use

Raw material ball mill and spray tower dryer

No waste

Tile press, tile dryer, tile glazing and printing

Damaged or broken tiles Sent to the raw material ball and re-used

Kiln

Substandard tiles Sold to the public/small retailers Broken/unusable tiles Temporarily stored on site, taken

by builders as an inert fill for excavations

Powder from edgings of floor tiles

Collected and sent to the raw material ball mill for re-use

Packaging Waste packaging Taken by plastic and paper recyclers

Entire facility

Storm-water Considered clean and released to the municipal storm water drain

Process water Treated and re-used via the recycle pond

Office and general waste Taken to the municipal landfill


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3 PUBLIC PARTICIPATION

3.1 Identification of stakeholders and an I&AP register Stakeholders, representing the following sectors were identified and served as the initial I&AP database:

• The owner and occupiers of the Rayal Industrial premises in Ekandustria • Landowners and occupiers adjacent to the Rayal Industrial premises • Relevant organs of state including national, provincial and local government (including

the municipal councillor) • Organised groups such as the rate payers’ association, water and environmental forums • Media

The initial I&AP database and all I&APs responding to the announcement of the application process will be included in the I&AP register and will be informed of progress and the opportunity to comment on the assessment.

3.2 Site Notice A number of copies of the site notice were placed on Wednesday, 13 April 2016 at and around the Rayal Industrial premises in Ekandustria.

3.3 Written notice and involving disadvantaged stakeholders Written notice of the application was provided to the initial I&APs database. A Background Information Document (BID) and a comment sheet was emailed to those listed and copies of the BID were hand delivered to I&APs adjacent to the facility on 13 April 2016.

3.4 Advertisement An advertisement was published in the Streeknuus newspaper on Friday, 15 April 2016.

3.5 Availability of the Section 24G and AEL Report for public review The Draft Section 24G and AEL Report was made available for public review from 15 April to 20 May 2016.

I&APs will be notified of the availability of the Final Section 24G and AEL Report via an email/fax/letter notification. I&APs will be requested to send their final comments to the GDARD and the City of Tshwane and to copy the public participation practitioner.

3.5.1 Comments and Responses Register The comments received from I&APs will be recorded and documented in a Comments and Responses Register (CRR) and appended to the Section 24G Report.

3.6 Notification of GDARD Decision The GDARD decision regarding the application and the opportunity to appeal the decision will be announced to the I&AP register when the decision is issued by the GDARD.

3.7 Issues and comments of concern To be completed after public review of the S24G report


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4 RECEIVING ENVIRONMENT This section briefly outlines the receiving environment within which the site exists.

4.1 Topography The topography around the Ekandustria site is generally flat with an average slope of 8.1%. The site has an elevation of between 1505 m and 1510 m, draining towards the north-west.

4.2 Climate Mean daily temperatures in the area arrange between 17°C and 34°C in January to between 2°C and 20°C in July. Rainfall occurs in the summer months, with dry winter months. The average precipitation for the area is in the region of 600mm to 700mm per annum, with most of the rain occurring in the months of January and December. Almost no rain is experienced in July.

The predominant wind direction at Ekandustria for the period 2010-2013 is from the northeast. Day-time winds are usually from the northern sector (north-west and north-east); however, and night-time wind fields show a stronger predominance from the easterly sector (north-easterly and south-easterly). It should be noted that relatively low wind speeds and very little wind from the south western sector occurs.

4.3 Surface water The site drains to the north-west towards an unnamed tributary of the Masokolo River, which drains further north-west into the Elands River, which is part of the B31A quaternary catchment.

4.4 Ground water The site has a borehole for supply of water. Borehole samples were taken in January 2016 and analysed at Regen Waters, an independent SANAS accredited laboratory. The results indicate that the water quality complies with the SANS Standards -241-2:2015 Ed 2 Domestic Water (drinking water standard), but that the water contains bacteria of non-pathogenic nature.

Borehole yield testing was undertaken by Waterman, and indicated that the borehole can yield 19 755 ℓ per hour over a 6-hour pump test. The static water level is 10m deep and the dynamic water level went to 1m deep. The borehole is 80m deep.

4.5 Soils and geology A geotechnical investigation was undertaken for the site in July 2011 by Lamola & Raphekwane Engineers & Project Managers, prior to establishment. The report indicates that the site is underlain by igneous rock of the Rooiberg and Pretoria Group, Bushveld complex of the Lebowa granite suite, which comprises the locally weathered clay material.

The site’s typical soil profile consists of a variable but thick layer of topsoil and hillwash, with underlain clay. The soil profile consists of a topsoil horizon of typically 300mm covering the reddish brown, silty clay hillwash layer up to 1.2m deep and a firm reddish brown silty clay layer with ferrigunisation and concretion of 20mm, with depth varying up to 3m. Ground water was not encountered during the investigation.

4.6 Air quality The City of Tshwane Metropolitan Municipality conducts ambient air quality monitoring as part of the Tshwane Air Quality Network. Data obtained at the Ekandustria monitoring station which is the closest to the site are summarised below. Carbon monoxide (CO), nitrous oxide


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(NO2), sulphur dioxide (SO2) and particulates derived from observations at this station were obtained from DEA’s SAAQIS webpage (http://www.saaqis.org.za/).

CO The hourly average and diurnal CO concentrations observed at the Ekandustria station are well below the DEA NAAQS limit (30 000 µg/m³ / 26 ppm). The expected CO hourly average concentration at the proposed development is expected to be within the same range as that of the Ekandustria station, with a maximum of about 3 490 µg/m³ (3 ppm).

NO2 The hourly NAAQS of 200 µg/m³ (106 ppb) was exceeded on numerous occasions during the period July 2012 to December 2012, but not thereafter in 2013 or 2014. It is therefore anticipated that the highest hourly average NO2 concentration at the proposed development would be similar at the levels measured for 2013/2014, i.e. between 57 µg/m³ and 115 µg/m³ (30 ppb and 60 ppb). The data also shows an increase in NO2 concentrations between 4am and 8am in the morning, and between 4pm and 8pm in the evening.

SO2 The highest hourly concentrations were observed to be below the NAAQS limit value of 350 µg/m³ (134 ppb) throughout the monitoring period. It is therefore probable that the levels at the study site does not exceed the air quality standard for SO2.

Particulate Air Concentrations The daily average NAAQS limit value for PM10 (75 µg/m³) were shown to be exceeded 4 days in 2013 and about 20 days between March and August in 2014. The particulate air concentrations were higher during the night. Two very distinct peaks are also observed at about 6h00 and 18h00, which coincides with increased household fires and the development of a night-time stable layer. An annual average concentration was determined as 46.7 µg/m³ (from measured monthly average concentrations), which exceeds the annual average NAAQS limit value for PM10 (40 µg/m³).

The particulate air concentrations at the study site (background) are expected to be high and could also exceed the NAAQS limit value.

4.6.1 Ecology The site sits close to the watershed, but falls entirely on the western side that drains to a tributary of the Masokolo River. According to the Metsweding District Municipality Environmental Management Framework (2011) “biodiversity within the Metsweding area has been highly affected by land transformation activities, notably urban expansion, mining and agriculture. The most sensitive and valuable features within the area include the ridges (notably the Bronberg area), remaining areas of intact natural vegetation, wetlands and river and riperian areas”. The site lies within the Rand Highveld grassland, however, previous Google Earth images indicate that site was fenced off for development as early as 2004 and that on site, no significant wetlands, pans or sensitive features existed at that time or subsequently.

4.7 Social According to the 2011 Census, Ekangala (which includes Ekandustria) has a population of 48 493 people, consisting of 13 618 households. Females make up 51.5% of the population, whilst males make up 48.5%. Black Africans consist of 99% of the population, with 0.3% Indian/Asian, 0.3% Coloured and 0.4% classified as Other. Only 0.04% of the population are classified as White. isZulu is the first language of 33.4% of the population, and isiNdebele is the first language of 28.6% of the population. Other first languages include Sepedi (15%), Sesotho (6%), Xitsonga (4%), SiSwati (3%), Setswana (3%), isiXhosa (2%). English, Tshivenda, Afrikaans and other languages are also spoken by a few of the population.


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Although Ekandustria covers 23% of the total area of Ekangala, it holds only 0.2% of the population due to this area being an Industrial area.

4.8 Sense of place Ekandustria is a zoned industrial node, characterised by light to medium industrial developments to the south, east and north east of the site. The closest residential areas are some 2 km to 5 km away from the site, consisting of Rethabiseng in the south east and various parts of Ekangala to the north east. The area immediately to the south-west, west and north-west of the site is currently undeveloped. Thus, the overall sense of place for the site is industrial, surrounded by townships and rural areas.

4.9 Cultural and heritage There are no known cultural or heritage resources on the site or in the surrounding areas.

The Jabulani Junior Primary Private School is situated some 2 km away in Rethabiseng. A number of primary and high schools are situated in the Ekangala area, between 4 and 5 km east-north-east of the site. A police station and a post-office is present in Ekangala. Health clinics are found 4 to 5 km to the north-north-west of the site. The closest formal towns are Bronkhorstspruit about 11 km south-south-east of the site and Cullinan about 17 km to the west-north-west of the site. The edge of the greater Pretoria area lies 25 km to the west of the site.


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5 IMPACT ASSESSMENT

5.1 Methodology for Impact Assessment Potential impacts are scored according to Table 4.

Table 4: Scoring of impacts

SEVERITY OCCURRENCE

Magnitude (severity) of impact

Duration of impact Extent of impact Probability of occurrence

Magnitude Duration Scale Probability 10 Very high/ don’t know

5 Permanent 5 International 5 Definite/don’t know

8 High 4 Long-term (impact ceases after closure of activity)

4 National 4 Highly probable

6 Moderate 3 Medium-term (5 to 15 years)

3 Regional 3 Medium probability

4 Low 2 Short-term (0 to 5 years)

2 Local 2 Low probability

2 Minor 1 Transient 1 Site only 1 Improbable 1 None/insignificant

After ranking these factors for each impact, the significance of the aspects, occurrence and severity, was assessed using the following formula:

SP (significance points) = (magnitude + duration + scale) x probability

The maximum value is 100 significance points (SP). The environmental effects were then rated on the following basis:

SP >70 Indicates high environmental significance

Where it would influence the decision regardless of any possible mitigation. An impact that could influence the decision about whether or not to proceed with the project.

SP 40 - 70 Indicates moderate environmental significance

Where it could have an influence on the decision unless it is mitigated. An impact or benefit which is sufficiently important to require management. Of moderate significance - could influence the decisions about the project if left unmanaged

SP <40 Indicates low environmental significance

Where it will not have an influence on the decision. Impacts with little real effect and which should not have an influence on or require modification of the project design or alternative mitigation

+ Positive impact An impact that is likely to result in positive consequences / effects.


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5.2 Assessment of potential impacts Table 6 provides a summary of the potential impacts, of which the significant impacts are discussed below.

Table 5: Impact Assessment Summary

Environmental Impact

ENVIRONMENTAL SIGNIFICANCE

Before mitigation After mitigation

M D S P Total SP M D S P Total SP

1. Geology Not applicable-the proposed project has not resulted in any changes to the geology.

- - - - - - - - - - - -

2. Topography Not applicable-the proposed project will not resulted in significant changes to topography.

- - - - - - - - - - - -

3. Soils Topsoils would have been lost during excavations. This impact has already occurred and cannot be mitigated.

2 5 1 5 40 M This impact has already occurred and cannot be mitigated.

4. Land capability and use The area is zoned for industrial development therefore no impact. - - - - - - - - - - - -

5. Ecology The facility was developed on a stand zoned for industrial. Historic photo’s do not indicate the presence of sensitive features.

- - - - - - - - - - - -

6. Surface water Spillages or leaks from piping and storage vessels could impact on storm water. None of the solid materials stored on site are noxious or toxic.

4 1 1 4 24 L 4 1 1 2 12 L

7. Groundwater The project has not resulted in changes to ground water. However, underground slurry storage and other water holding structures could contaminate ground water if these leak.

4 3 1 4 32 L 2 2 1 3 15 L

8. Air quality The air impact assessment indicates significant hydrogen fluoride emissions. All other emissions are within emission compliance limits.

6 4 2 5 60 M 2 4 1 5 35 L

9. Noise Noise measures have been implemented on site. Noise levels were observed to be low on site.

6 2 1 4 36 L 2 1 1 4 16 L

10. Visual aspects Steam emitting from the spray tower dryer has a visual impact on the local area. 4 4 2 5 50 M 4 4 2 5 50 M

11. Cultural heritage


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Environmental Impact

ENVIRONMENTAL SIGNIFICANCE

Before mitigation After mitigation

M D S P Total SP M D S P Total SP

The project has not result in any changes to heritage resources. - - - - - - - - - - - -

12. Socio-economic aspects

Investment of R250 million 6 2 3 5 55 M+ 8 3 3 5 70 H+

270 local permanent jobs created 4 4 2 5 50 M+ 6 4 2 5 60 M+

13. Traffic and transport aspects Trucks access the site for raw material deliveries and for transportation of product. R513 is a dual lane road, easily accommodating heavy traffic for this area.

2 2 2 5 30 L 2 2 2 5 30 L

14. Waste management The site will develop a waste management plan to address temporary storage on site. 4 3 1 5 40 M 2 2 1 5 25 L

15. Health and safety Staff health and safety: investigation of dust levels 6 3 1 5 50 M 2 3 1 5 30 L

5.3 Recommendations to address identified impacts

5.3.1 Surface water It is recommended that pipes, pumps and vessels are regularly inspected and maintained to minimise the likelihood of spills and leaks due to major failure.

5.3.2 Ground water It is recommended that annual monitoring of the on-site borehole is carried out and must include an organics analysis. It is further recommended that a civil/structural engineer inspect the water-holding structures and verify their integrity.

5.3.3 Air quality The facility complies with the minimum emission standards for the dryer and spray tower, and the emissions are well below the standard. The kiln emissions also comply with the minimum emission standards for SO2 and particulate matter. However, it is significantly out of compliance in terms of its HF emissions.

Dust was assessed in terms of total suspended particles (TSP), respirable particles smaller than 10µm (PM10) and respirable particles smaller than 2.5µm (PM2.5). There are no emission standards for dust from area sources. However, dust estimated to be generated on site was included in the dispersion model for the project in order to assess the impact on the local surrounding area.

Predicted ground level concentrations for PM10, PM2.5 and TSP are all within compliance of the NAAQS. However, in light of elevated particulate air concentrations measured at the nearby Ekandustria ambient monitoring station cumulative PM10. PM2.5 and TSP ground level impacts may result in exceedances of the respective daily average and annual NAAQS.


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The stack emissions are well within the emission standard, therefore dust management measures are proposed to address area source emissions.

The HF emissions from the site significantly exceed the minimum emission standard. Predicted ground level concentrations for HF do not comply with international ambient air standards.. It is noted that the extent of the non-compliance is outside the site boundary but does not impact on any of the identified receptors in close proximity to the site. Measures to reduce HF emissions are proposed.

5.3.4 Noise An occupational noise survey was carried out by Mr E Steenkamp in 2014. His findings were that employees working at the synthetic gas plant during the loading of coal and sludge removing actions, all milling operations, tile press area, tile packing, cooling fans, edging operations and palletising operations at the end of the line are exposed to noise exceeding the statutory limit of 85 dB (A), and recommended measures that were observed to be implemented on site, however, follow-up noise monitoring and medical surveillance has not been confirmed.

It is recommended that annual monitoring of noise at the noise zones and at the fence boundary is carried out. It is also recommended that the medical surveillance is implemented to protect the company and its staff.

5.3.5 Social There are two aspects to the social benefits of this project.

Investment and local development The site required an investment of R250 million which benefited the local, regional and national community. In addition, the company provides staff training and has initiated training for local suppliers and contractors with regards to raw materials and product. The site is also the first porcelain roof and tile manufacturer in South Africa, and these products were previously imported to South Africa.

It is recommended that the company structure its training and development initiatives to maximise the benefit to the local and regional communities and businesses.

Local job creation The facility has provided 270 permanent jobs to local people.

It is recommended that the company continue to train and develop staff in order to increase the amount of local labour it uses on site.

5.3.6 Traffic It is recommended that incoming and outbound loads are well managed and scheduled to minimise potential disruptions on the R513 or at the site access.

5.3.7 Waste It is recommended that a site waste management plan is developed.

5.3.8 Health and safety It is recommended that an occupational health and safety review is carried out by the site.


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6 ROLES AND RESPONSIBILITIES The organogram for Rayal Industrial (Pty) Ltd is provided in the Figure below.

Figure 2: Facility Organogram


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7 ENVIRONMENTAL MITIGATION AND MANAGEMENT

Aspect Impact Management/Mitigation Responsible Person Reporting, control and budgeting

General Non-compliance with license and authorisation

1. The environment monitoring plan shall be implemented, adjusted and maintained over the life of the facility.

2. Interpretation of environmental data shall be carried out in line with licence and authorisation requirements in order to identify any impacts, deteriorating trends, etc. Corrective measures must be identified and implemented where negative environmental impacts are occurring.

3. Regular environmental management audits shall be conducted as per the requirements of licences and authorisations. Environmental audit reports must be made available to the authorities.

4. It is recommended that Rayal Industrial joins an environmental management and labour forum, if this exists locally, with adjacent land owners, communities, authorities, etc., At forum meetings the following aspects should be discussed: • Environmental monitoring information and interpretations; • Audit findings and recommendations • Labour issues and concerns; • Vandalism, theft and public safety; etc.

5. Rayal Industrial will investigate the development and implementation of ISO 9 000 (quality) and 14 000 (environmental management) systems in order to obtain accreditation thereof.

General Manager Factory Manager

To be included in plant operating and maintenance costs. Factory Manager to report monthly incidents to General Manager.

Materials handling and road transportation of materials.

Dust emissions 1. Regular maintenance of infrastructure. 2. Road transport of material to be scheduled in order to avoid

traffic back-ups at the access to the site. 3. Any haulage by truck must include covers on the trucks to

minimise dust and spillage. 4. Daily inspection of roads and materials storage areas to identify

spills. 5. Spills to be cleaned up within 12 hours and returned to materials

stockpile.

General Manager Factory Manager to follow up on inspections.

To be included in plant operating and maintenance costs. Factory Manager to report incidents monthly to General Manager.


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6. Spills to be followed up with inspection to ensure clean-up is sufficiently thorough. Road and materials handling improvements may be required to prevent recurring spills.

7. Ensure workshops carry stock of high frequency spares and long lead items for materials handling infrastructure.

8. Ensure bunded areas and silt traps are serviced regularly. 9. .Conduct the required inspections and audits as per the

requirements of the site licenses.

Combustion of coal Particulate, NOx and SO2 emissions.

Maintain synthetic gas plant and coal furnace and associated stacks to meet emission standards. Monitor emissions levels as per the requirements of the AEL.



Kiln Unacceptably high emission of HF

The facility will investigate and implement the following primary measures in order to reduce HF emissions: • The use of low fluorine raw materials and additives • In the case of fluorine rich materials, the addition of low fluoride

body additives (e.g. sand) or low fluoride clay to reduce fluoride emissions by a dilution effect.

The facility will investigate and implement the following primary measures in order to reduce HF formation: • Reduce the rate of heating in the lowest temperature range (up

to 400 CaF2, resulting in a decrease of HF emissions.

• Faster firing cycles generally result in reduced fluoride emissions. The characteristics of the raw material influence a fluorine release, but for any given ceramic product the firing time above the temperature of 800 °C is crucial.

• Control of oxygen levels in firing processes maximises combustion efficiency.

Should HF emissions remain out of compliance with the emission standard after implementation of the above primary measures, the following secondary measures should be investigated and implemented:

General Manager Factory Manager

Investigations to be budgeted for and executed during 2017. Implementation of primary measures to be budgeted for and executed by 2019. If required, further investigations to be budgeted for and executed during 2020. Implementation of secondary measures to be budgeted for and executed by 2022. Factory Manager to report quarterly on monitoring information to General Manager. Factory Manager to report to General Manager on the outcome of investigations undertaken for primary and secondary measures. Factory Manager to report annually to General Manager on latest HF


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• Cascade-type packed bed adsorbers (provide simultaneous removal of HF, SOx and HCl in kiln emissions);

• Honeycomb module adsorbers (mainly used for HF removal); • Dry flue gas cleaning with a filter (fabric filter baghouses). Stay in touch with technological developments for the control, reduction and prevention of HF emissions. Quarterly monitoring of HF emissions until compliance with the emission limit for HF is met. Thereafter, monitoring as per the AEL requirements.

emission technologies.

Storm water and process water management

Spillages of polluted water to the local environment.

Regular maintenance of storm water, dirty water and process water infrastructure, including canals, pipes, sumps and dams. Daily inspection of oil and silt trap at the workshop, and servicing when required. Silt removed from any oil and silt traps to be classified and disposed of at an appropriately licensed waste disposal facility. Recovered oils to be recycled where possible. Report contaminated spills to the Department of Water & Sanitation within 24 hours. Clean up spills within 24 hours. Assess reasons for spills and put corrective action plans in place. Inspect and repair any erosion due to damage to water management infrastructure. Remediate any contaminated soils or remove for proper disposal.

General Manager Factory Manager to follow up on maintenance, spills and inspections.


Use of borehole water Compliance with National Water Act (NWA).

Consult regional DWS office to determine if borehole needs to be registered and/or licensed.

Factory Manager Costs to be included in next annual budget. Factory Manager to report to General Manager on compliance with NWA.

Recycle pond, storage of ball mill slurry, coal furnace water and all underground piping and infrastructure

Contamination of ground water due to leaking infrastructure

Implement annual inspection of underground structures during plant shut-downs. Obtain engineer’s report on integrity of underground infrastructure. Monitor onsite borehole.

Factory Manager General Manager

Include in shut-down costs. General Manager to present inspection report to Board Include budget for implementation of engineer’s recommendation in next financial year unless urgent work is


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required, in which case, re-allocate current annual budget to implement recommendations. Factory Manager to include borehole monitoring in annual report to General Manager.

Waste management Inadequate waste management leading to pollution

Develop a waste management plan for the site to address temporary storage of waste streams. Implement appropriate measures based on the waste management plan

General Manager Development of the waste management plant to be included in next financial year budget. Any measures to be included in next two financial years.

Health and safety of personnel

Health and safety of personnel Undertake annual occupational health and safety inspection of the site, to ensure noise, dust and other hazards are addressed through appropriate measures on site and the use of personal protective equipment. Undertake 5-yearly independent review of facility

General Manager Annual report on occupational health and safety to be presented to the Board.

Services Supply chain opportunities Engage with local businesses to assist with meeting requirements for tender processes and documentation. Communicate supply chain opportunities through a company/project’s website and communication materials. Communicate supply chain opportunities through local business networks. Engage with local stakeholders to establish a local business forum to increase access to opportunities.

Factory Manager. To be included in plant operating and maintenance costs. Factory Manager to report monthly to General Manager.

Community Engagement

Complaints from community Implement complaints register Erect signage indicating where complaints may be lodged. Follow up on complaints and develop action plan where required to address valid complaints.

General Manager Factory Manager to follow up on complaints.

To be included in plant operating and maintenance costs. Factory Manager to report monthly to General Manager on complaints, follow up on complaints and action plans.


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7.1 Closure and post-closure plan


All infrastructure Inadequate removal of infrastructure and residual materials that could enter the environment.

Develop a detailed closure plan for the site approximately 3 years prior to closure. Closure plan to include:

• Detailed demolition and infrastructure removal plan. • Clean-up of contaminated areas. • Rehabilitation of cleared site area with natural vegetation. • Ensure site is shaped to be free draining. • Disposal of contaminated materials, building rubble and wastes from the site at a

licenced waste disposal facility. • Post-closure monitoring plan of ground and surface water, as well as dust

monitoring. • Environmental awareness training of remaining staff. • Recruitment of local companies and labour for closure activities and closure

monitoring.


To be included in closure costs.

Retrenchment of staff Loss of income for staff Retraining of staff so that they can seek other opportunities. Adequate retrenchment packages to allow staff to seek other opportunities. Engage with local labour organisations to identify job opportunities for employees.

General Manager

To be included in closure costs.


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8 ENVIRONMENTAL MONITORING PLAN This monitoring plan allows for monitoring during operations. Minimum monitoring requirements are outlined for closure, which must be expanded on when a detailed closure plan is developed.

8.1 Objectives The objectives of the monitoring plan are to:

• Ensure all infrastructure associated with the site allow compliance with regards to water and waste management conditions in the license and authorisation.

• Provide early warning system of potentially significant changes in the local environmental media, which will allow for action plans to be developed where required.

• Monitor compliance with license conditions.

• Provide data required for reporting to licensing departments.

• Track environmental performance and compliance of the site.

8.2 Sampling and methodology The required sampling equipment and sampling procedure is not outlined in this document since it is assumed that suitably qualified scientists contracted by the site will undertake the sampling. It is also assumed that all analyses will be undertaken in accredited laboratories.

The data system for storage and management of analytic data arising from the monitoring plan is not outlined in this report since these systems need to be developed by Rayal Industrial operational staff. However, reporting requirements are outlined in Section 10 of this report.

8.3 Air quality

8.3.1 Listed activities: emissions Emissions from the following point sources must be monitored as per the requirements of GN 893 of 2004, Annexure A: Methods for Sampling and Analysis.

Table 6: Point source emission monitoring for the site

Point source code

Source name

Latitude (decimal degrees)

Longitude (decimal degrees)

Parameters Frequency

ST1 Dryer stack -25.70485 28.69794 SO2, NOx, TSP, PM10, PM2.5

Annual

ST2 Ceramic stack -25.70486 28.69802 TSP, PM10,

PM2.5, HF Annual

ST3 Spray tower -25.70373 28.69824 SO2, NOx, TSP, PM10, PM2.5

Annual

8.3.2 Ambient sampling Ambient conditions must must be monitored annually at the fence-line. The monitoring point is as shown in the Figure below and the required monitoring is shown in the Table below.


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Figure 3: Ambient air quality monitoring point for the site

Table 7: Ambient air quality monitoring for the site

Point source code

Source name

Latitude (decimal degrees)

Longitude (decimal degrees)

Parameters Frequency

ST4 Fence-line -25.703563 28.696880 SO2; NOx, TSP, PM10, PM2.5, HF

Annual

8.4 Water quality and quantity

8.4.1 Borehole usage Daily volumes pumped from the borehole will be recorded.


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8.4.2 Borehole water quality Annual analysis of the borehole water for drinking water parameters as well as total organics.

8.4.3 Spills and leaks Any spills and leaks from pipes, pumps, recycle pond, ball mill slurry storage, coal furnace water storage and storm water canals that exits the site must be sampled and analysed for total organics. pH, conductivity, total dissolved solids, total alkalinity, sulphate, chloride, sodium, calcium, magnesium, potassium, total ammonia and ammonium, nitrate, manganese total and dissolved, cadmium – dissolved, antimony – dissolved, fluoride, iron total and dissolved, boron – dissolved, barium – dissolved, total phosphorus.

8.5 Health and safety Annual health and safety review of site by managers and 5-yearly review by an independent occupational health and safety consultant.will be carried out

8.6 Infrastructure integrity Annual inspection by maintenance team and 5-yearly inspection by an independent structural engineer regarding recycle pond, coal furnace water storage, ball mill slurry storage, and storm water infrastructure.


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9 ENVIRONMENTAL AWARENESS PLAN This awareness plan meets the following requirements:

• Outline the manner in which the facility intends to educate and inform one’s employees of any potential harm that can be done on the environment or environmental risk by the workings at the proposed operation; and

• Include the way in which pollution and degradation is to be avoided or indicate how the risk must be dealt with in order to avoid the pollution or degradation.

9.1 Legal Requirements The following legislation forms the basis for an Environmental Awareness Plan:

• The Constitution of the Republic of South Africa (Act 108 of 1996);

• National Environmental Management Act (Act 107 of 1998);

• National Water Act (Act 36 of 1998);

• National Environmental Management: Air Quality Act (Act 39 of 2004); and

• National Environmental Management Waste Act (Act 59 of 2008).

• National Environmental Management: Biodiversity Act, 2004 (Act 10 of 2004);

9.2 Objectives of the Environmental Awareness Plan The objectives of this Environmental Awareness Plan are to inform employees and contractors of any environmental risks that may result from their work and indicate how they should deal with such risks should they materialise.

The overall purpose of implementing an Environmental Awareness Plan is to optimise the awareness of those partaking in the activities which have the potential to negatively impact on the environment and in doing so, promote the global goal of sustainable development.

9.3 Implementation of the Environmental Awareness Plan and other Training Programmes

In-house training takes place regularly with all new employees receiving on the job training as well as basic safety training before assuming duty. Safety officers at the facility have been drawn from the pool of employees and sent to NOSA for training. Safety Reps nominated by the employees have also received basic training at NOSA. All first aiders selected on the various shifts have been trained by NOSA.

Rayal Industrial will ensure a basic induction process is followed by all employees working on site, including visitors. This induction process should include a brief statement on “Environmental and Community awareness at the Rayal Industrial Facility”. The statement must be made available on entry to the facility, upon request and will form the awareness part of the induction procedure for all staff and guests to the facility. The subject of Environmental awareness is also to be addressed at staff sessions held on site.

Environmental principles must be communicated effectively to newly appointed employees, as well as to contractors and visitors upon entering the facility. This must be done in conjunction with any other induction or safety awareness education.

The Environmental Awareness Plan/induction process/statement presented will include the following concepts:


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• Why the environment needs protecting?

• How do we protect and manage our environment?

• Working area management;

• Water management;

• Floral and faunal management;

• Fire management;

• Air quality management;

• Waste systems; and

• Incident reporting.

An EMPr and AEL contain various measures to protect the environment. Legally, Rayal Industrial must make employees and contractors aware of the commitments made in the EMPr in order for all parties to work towards fulfilling these obligations and thus protecting the environment.

9.3.1 What is the environment? The environment can be separated into the natural and built environment. The natural environment includes the air, water, soil, plants, animals and people. The built environment in this instance includes materials storage, synthetic gas plant, coal gas furnace, dryer, tile manufacture, roads and machinery. Controlling the environment we are in and in which we interact, forms the basis of environmental management.

9.3.2 Why does the environment need protecting? We need to be mindful of, and protect the environment for four reasons:

• It provides us with food, water and air to breathe;

• It is our right to a healthy environment;

• The next generation has a right a healthy environment; and

• The law demands that we protect the environment.

If we fail to protect the environment,

• Rayal Industrial may be subject to a fine or prosecution; and/or

• Individuals may be removed from site; and/or

• Operations may be stopped.

9.3.3 How can we protect and manage our environment? To protect our environment; we must:

• Report all incidents to a superior,

• Work together; and

• Follow rules and management measures discussed below.

9.3.4 Working area management All personnel must stay within demarcated working areas on site. Areas marked as ‘no go’ must be obeyed. The reason for this is that the sites may be chosen based on having the smallest impact or based on not destroying sensitive landscapes. If these rules are not


29

obeyed, unnecessary damage may be done to the environment and disciplinary action may be taken.

9.3.5 Water management Water must be saved on site by ensuring taps are closed, ensuring pipes are checked for leaks. Prevention of water pollution needs to be undertaken by preventing spillage of solvents, oils and diesel. This is crucial as water is a scarce resource and a non-renewable resource.

9.3.6 Floral and faunal management Any animals on or near the site must not be harmed or killed but rather should be removed safely when found. Similarly no trees, shrubs or grasses may be removed or killed without permission from the General Manager. Animals and plants play a role in the environment even if they are deemed as pests to humans.

9.3.7 Fire management Matches and cigarette butts must be disposed of in demarcated areas and bins provided. No fire, including matches, are allowed near solvents, oils and fuels such as diesel. Rubbish must not be burned and personnel must be aware of the location of the nearest fire safety equipment. Fires can be difficult to control and may cause explosions that can burn people, damage equipment and reduce the safety of the surrounding areas.

9.3.8 Air quality management Dust creation should be prevented or minimised as far as possible. Dust can be suppressed by sweeping of roads and materials handling areas and watering of gravel roads. Dust causes irritation to lungs and eyes. It also reduces visibility on site which can be dangerous to drivers and personnel.

9.3.9 Waste systems Any wastes generated must be stored properly and disposed of in the correct manner. This includes hazardous wastes such as waste or residual solvents, oils and fuels or non-hazardous wastes such as food, litter, office waste, packaging, etc. Waste that is not disposed of correctly can cause pollution or harm to people and the natural environment.

9.3.10 All incidents must be reported Any problems such as water leaks, oil spills, material spillages, litter, etc. must be reported to the General Manager or the responsible supervisor. Always report incidents with date, time, location and brief descriptions.

The awareness training of employees, contractors and visitors will help to ensure that co-operation in terms of environmental management will occur. In addition, it will ensure the success of the facility regarding compliance with legislation, and avoid possible future disciplinary and legal action from a lack of awareness on the site.


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10 REPORTING The following reporting requirements will be updated to reflect authorisation and license conditions if issued.

10.1 Reporting to Authorities Reporting to licensing departments will meet the requirements of the various licenses for the project, if these are approved and issued.

Spills and leaks that exit the site (surface and ground water) must be reported to the Regional Director: Gauteng of the Department of Water & Sanitation.

10.2 Internal Reporting Internal reporting will be undertaken in line with company policy, protocol and procedures. These have not yet developed, pending the outcome of the various license applications. The following minimum reporting must take place:

10.2.1 Factory Manager to General Manager

Monthly Water usage, environmental incidents, health and safety incidents, complaints.

Quarterly Monitoring information, complaints follow-ups and action plans, status of local business initiatives.

10.2.2 General Manager to Board

Annually Water usage by site, borehole water quality, integrity of infrastructure, health and safety review, monitoring information, complaints and status of action plans, status of local business initiatives.


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11 CONCLUSION This report has provided a description of the activities undertaken at the facility, the applicable legislation and the impacts associated with the facility. Mitigation and management measures are included in the EMPr.

There are no immediate risks to the public due to the activities at the site. It is recommended that this report is updated if the site is issued with a Section 24G rectification authorisation and an AEL to include their conditions and requirements. Thereafter, this EMPr should be reviewed annually to determine if it needs updating.


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12 REFERENCES

1. Airshed Planning Professionals, April 2016 “Atmospheric Impact Report: Rayal Industrial (Pty) Ltd, Ekandustria, Gauteng”.

2. Lamola & Raphekwane Engineers and Project Managers, July 2011 “Geotechnical Investigation for the proposed new tile factory in Ekandustria”.

3. Metsweding District Municipality (2011). “Metsweding District Environmental Management Framework and Strategic Environmental Management Plan. Final Report of the Metsweding Environmental Management Framework and Environmental Management Plan”.

4. Steenkamp E, October 2014 “Occupational Hygiene Survey, Rayal Trading, 14 Galena Street, Ekandustria, Bronkhorstspruit”.

4. Census information: http://census2011.adrianfrith.com/place/799 http://census2011.adrianfrith.com/place/799054

5. Climate information: https://www.meteoblue.com/en/weather/forecast/modelclimate/wonderboom-airport_south-africa_938159

6. DWS water quality data: https://www.dwaf.gov.za/iwqs/wms/data/b31/b31_189529.pdf

http://census2011.adrianfrith.com/place/799

http://census2011.adrianfrith.com/place/799054

https://www.meteoblue.com/en/weather/forecast/modelclimate/wonderboom-airport_south-africa_938159

https://www.meteoblue.com/en/weather/forecast/modelclimate/wonderboom-airport_south-africa_938159

https://www.dwaf.gov.za/iwqs/wms/data/b31/b31_189529.pdf

Appendix 1: Emergency Response Plan

RAYAL INDUSTRIAL (PT Y) LTD S o u t h A f r i c a n p o r c e l a i n R o o f & F l o o r T i l e s P r o d u c e r

HEALTH AND SAFETY OCCUPATIONAL HEALTH AND SAFETY MONOTORING INFORMATION, PROROCOLS AND PROCEDURE. Hazard Identification and Risk Analysis

The factory is made up of departments where workers perform different types of duties and also these departments are made up of different working environments.

Hazard Identification and Risk Analysis aims at ensuring a safe working environment for employees, visitors, contractors etc.

Health and Safety Officers go through the factory and Hazard Identification is done in a number of ways including.

Visual Inspection Which is done by walking around the factory through different departments, picking up issues arising from duties being performed by workers, equipment being used to perform the duties and the conditions in the working environment. Inspection is also done around the floor and the factory yard, the factory yard we look for issues that affect the environment and things that could or are causing pollution to the environment and we then make recommendations after the analysis of what we saw. Interviewing workers We interview workers to hear their views on Health and Safety issues, and they report unfavorable working conditions and faulty equipment, and the Health and Safety Department put together a report detailing the reports coming from workers, and give solutions.


Toolbox Talks Workers and the Health and Safety Department discuss Health and Safety issues and discuss possible solutions as well. Incident Investigation When and incident occurs the Health and Safety Department has to find out what caused the incident and the result of that investigation determine the issues present in that particular Department. IOD’S Injuries On Duty are investigated recorded, and reported IOD forms filled then injured worker goes to IOD doctor and brings back a medical report. Occupational diseases Workers have to bring a full medical report from doctor to confirm the condition; we investigate and confirm the cause. Medical Assessments All employees go through medical assessments, different departments present different working environments therefore some need medical assessments more frequently than others Risk Analysis Once Hazard has been identified the next step is to determine what kind of a risk it poses and the severity thereof, the steps that need to be taken to eliminate the risk if it cannot be eliminated then we determine how to mitigate the risk. Recording and Reporting Health and Safety Department reports to HR.


Compliance

All employees are expected to comply with all Health and Safety regulations.

Workers are expected to report fit for work to avoid IOD’s, we administer Breathalyzer tests on suspected workers to ensure compliance.

Workers must wear required PPE’s, if they are worn out the must return worn out one’s for replacements, the Health and Safety Department is responsible for checking if there is enough PPE’s and report it to relevant department with an order.

In the case when a new type of PPE is needed the Health and Safety Department has to make recommendations for the PPE to be ordered.

Training needs

The Health and Safety Department does the safety induction training of new employees, contractors, visitors etc.

Safety induction training is also done in case a new machine is introduced; a new law requires that we train workers or all affected by the change, there is a change in the working environment etc.

SWP Safety Work Procedures are remedy solution that guide the workers to work safely, should issues arise concerning machinery, working conditions a SWP document will be drafted and workers will be trained. Emergency Monitoring Plan Evacuations


In case of a fire horns are used to make fire alerting sounds, workers are expected to immediately leave the work area going outside

There are three assembly points outside the factory where workers assemble awaiting a head count to determine that all workers are present and safe

Workers aren’t allowed to run around the factory during times of emergency like fire they are supposed to leave immediately

Assembly points are for specific departments to make the whole process easier

Demarcation/signage

Specific areas are allocated for specific activities There a special designated areas/enclosures within the factory for

smoking, smoking anywhere else is not allowed There are areas within the factory that are dangerous and there

are signage’s prohibiting entry. Fire Equipment

Health and Safety department ensure that fire equipment are in good condition report if they need servicing.

Implementation of ISO 9001 Standard

Health and Safety department does the checklists necessary particularly those that are related to safety.

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