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2.SCOPE OF AUDIT 2
3.AUDIT PROCESS 3
3.1Plant Walkthrough 3
3.1.1SPL STORAGE AREA 3
3.1.2TRANSPORT SYSTEM 3
3.2LEGAL complaince REVIEW 3
3.3GENERAL HSE ISSUES 4
6.DEFINITIONS AND ABBREVIATIONS 4
7.DOCUMENTATION VIEWED 5
BHP Billiton Aluminium generates SPL Carbon waste materials after delining of the electrolytic cells used for aluminium production. These wastes are classified as highly hazardous (H:H), due mainly to the presence of leachable cyanides.
Cape Gate is able to process the SPL Carbon portion as partial raw material replacement.
The National Environmental Management Act details the requirement for adherence to the Cradle-to-Grave principle [Section 2(4)(e)]. In effect, a person or organisation is required to take responsibility for the environmental, health and safety consequences of a policy, program, project, product, process, service or activity throughout its life cycle.
As a generator of waste products, BHP Billiton Aluminium carries full responsibility in ensuring that its waste products are managed, transported and disposed / recycled according to applicable legislation and in an environmentally sound and responsible manner.
Due to Cape Gate’s operations carrying certification in ISO 9001 and 14001 management systems, the audit scope was limited to plant issues relating specifically to SPL.
BHP Billiton Aluminium environmental liability arising from the processing of Silicone Carbide SPL at the Columbus Stainless facility can be considered to be limited due to Columbus’s legal compliance to environmental legislation and the HSE controls implemented by the operations staff as well as the small tonnage’s being sent to them.
Due to Cape Gate’s operations carrying certification in ISO 9001 and ISO 14001, the audit scope was limited to plant issues relating specifically to SPL.
An environmental audit of Cape Gate was conducted on the 4th October 2011. The criteria for conducting the audit included the following:
The SPL material that was sent to Cape Gate has all been used up and the company is currently not taking anymore material.
The material that was sent to Cape Gate was stored inside a silo
The SPL, once it has passed through the radiation detector system, is offloaded onto a grid which has three vibro’s underneath it. This material is then sent from conveyor one to conveyor two (pocket conveyor) and finally onto conveyor three which sends the material into the SPL Silo.
If the Vibro’s is busy with another vehicle then the vehicle, to avoid vehicle delays on site, dumps the material on the ground behind the vibro’s building and a Front End Loader later picks up the material once the Vibro’s are available again
However if it is raining then SPL was not dumped on the ground. The vehicles remained on site with the vehicles covered to avoid the SPL getting wet until such time that the Vibro’s was available again to offload the material.
BHP Billiton Aluminium used to send SPL Carbon to Cape Gate as a raw material
Cape Gate is in possession of valid APPA certificates for the steel making process. The certificate has expired, but the company did receive an extension letter from the Acting Chief Director: Air Quality management; Mr. M.M. Lushaba dated 12/08/2011.
This extension is valid for three years dated from Date of Issue/01 April 2010 to apply for the conversion of a registration certificate to an Atmospheric Emissions License (AEL)
The company also has a valid Waste License for its operations
The SPL offloading area was very controlled and no human/machine interaction was occurring. All personnel were inside a closed off area while material was being offloaded. The area used was very clean and with its transport system the possibility of spillages, cross contamination was minimal.
The area where material would be dumped if the vibro’s was being used was not on a concreted area, but on inspection no storm water drains were seen nearby. This material would also only be left on the ground for a few hours.
The Safe Disposal Certificates (SDC) for material sent to Cape Gate in the beginning of the year was received by the Waste coordinator for BHP Billiton Aluminium South Africa, however we have not yet received January and February 2011 SDC’s. We were informed that they will look into the query
BHP Billiton Aluminium environmental liability arising from the processing of SPL at the Cape Gate facility can be considered to be limited due to Cape Gates legal compliance to environmental legislation and the HSE controls implemented by the operations staff as well as the fact that no more SPL is currently being sent to them
BHP Billiton would like to extend a word of thanks to the staff at Cape Gate for the hospitality and the open manner in which the audit was conducted.