10 May 2022 Frequently Asked Questions: Rooikat Recycling Project, Great Brak River

Frequently Asked Questions and Answers: Rooikat Recycling Project, Great Brak River

Click on the questions below to view the answers to frequently asked questions.

1. What is the Rooikat recycling project in Great Brak River?

Rooikat Recycling is developing robust, fit for purpose, thermal depolymerisation technology.  This technology will allow the treatment of waste plastic and tyres to produce a basket of fuels that can be placed in the existing market.

All waste will be delivered to the site directly from designated sources for processing. Waste will be sourced from private companies wishing to reduce their solid waste footprint and reputable waste management entities e.g., recycling companies.  Waste from the public will not be accepted.

2. What is the Garden Route District Municipality’s involvement in the project?

In terms of Section 36(1) of the National Environmental Management: Air Quality Act, Act 39 of 2004 (the Act), metropolitan and district municipalities are responsible for implementing the atmospheric emission licensing system referred to in Section 22 of the Act.

The Garden Route District Municipality is the Air Quality licencing authority for the Rooikat Recycling Project.

The Provincial Department of Environmental Affairs and Developmental Planning is the competent authority for the Waste Management Licence and the subsequent Environmental Authorisation.

3. Why was an air emissions license issued?

The proposed activity triggers two Section 21 listed activities, Categories 8.1 and 3.4 and subsequently, Rooikat Recycling applied for an Atmospheric Emission License (AEL) on the South African Atmospheric Emission Licencing and Emissions Inventory Portal (SAAELIP).

The application also triggered activity 6 of the NEMA Listing Notice 2 and required Environmental Authorisation and a Waste Management Licence.

A specialist Air Quality Impact Assessment was required in terms of section 38(1)(a) and also a public participation process as per section 38(3) of the Act.

The issuing of the AEL was subjected to Environmental Authorisation as it takes precedence and must inform the AEL decision.

All Section 39 factors (impact factors) were considered in reaching the decision to issue the granting letter (minimum emission standards, ambient standards, pollution caused by the activity and effect on health, environment, best available technology, etc.)

4. What is depolymerisation?

Depolymerisation is a mild form of pyrolysis. Pyrolysis is an established chemical process that breaks down large molecules (plastic and tyres) into smaller molecules (fuel oil) by the application of heat.  Heat is supplied by burning petroleum gas (LPG) and fuel oil in a furnace.  The process uses a closed-loop system to produce oil (fuel oil).  Carbon black and petroleum gas are produced as by-products.  Petroleum gas is used internally as a fuel.  Both fuel oil and carbon black are sold as fuels or chemical feedstock.  The significant emission from the process is the combustion gas produced in the furnace.   All water produced in the process is recycled as cooling water.  Rainwater is contained on the plant and recycled.

5. What are the emissions associated with this process?

The furnace is the main emission source.  Petroleum gas and fuel oil are combusted in a purpose-designed burner in the furnace to provide heat.  The burner is designed to completely combust the petroleum gas and fuel oil to produce carbon dioxide and water, similar to a vehicle’s exhaust gas.  All combustion processes may produce by-products including particulates (black smoke) which are pollutants. To remove pollutants the combustion gas from the furnace is cleaned, by scrubbing with water, before it is released to the atmosphere.  The cleaned combustion gas is the main air emission from the process.  This is in great contrast to the common idea of tyre, plastic or waste burning or incineration.

6. Will tyres and plastic be burned in the process?

No, Garden Route District Municipality will never allow the uncontrolled burning of tyres and waste.  This is illegal.  Burning of plastic or tyres is not permitted as toxic by-products are produced and released into the atmosphere.  The proposed process does not burn tyres or plastic. The process heats tyres or plastic, to elevated temperatures, in an oxygen-free environment.

7. In the Final Bar it is mentioned that further distillation of diesel oil will take place. This changes the plant from a pilot plant to a processing production plant. Was this considered?

Yes, it was considered.  A suggestion from the public participation process was to explicitly include the distillation of oil to produce diesel, as part of the process description for transparency.  Diesel is a product of the distillation process.  The distillation step is not a new process, but a modification to improve an existing process.  There is no change in environmental impact or emission.  The classification of the plant or process is not changed.

Category 2 of the section 21 activities covers the Petroleum Industry, the production of gaseous and liquid fuels as well as petrochemicals from crude oil, coal, gas or biomass.

  • Subcategory 2.1 Combustion Installations
  • Subcategory 2.2: Catalytic Cracking Units
  • Subcategory 2.3: Sulphur Recovery Units
  • Subcategory 2.4: Storage and Handling of Petroleum Products
  • Subcategory 2.5: Industrial Fuel Oil Recyclers

The distillation of diesel is not a listed activity in terms category 2. The proposed activity triggers only 8.1 and 3.4.

The Act in terms of category 8.1 and 3.4 does not make provision for ‚Äúpilot plants‚ÄĚ. The emission limits and special arrangements for the proposed facility fully applies. For example, the installation of a CEMS unit remains a requirement although the application referrers to the proposed facility as a pilot plant.

8. The area is surrounded by many dairy farms, old age homes and tourism venues. Surely the emission of noxious gasses will have a detrimental effect on this pristine area?

The operation of the facility is highly regulated.  The facility must be operated to comply with both the Waste Management and Atmospheric Emission Licences to ensure the operation is not detrimental to the environment.

An atmospheric emission licence must be seen as a regulatory tool which is implemented to ensure compliance and protect the ambient air quality of a specific air space.   The applicant will only be issued with a Provisional AEL. Only if the applicant can prove compliance with the conditions of the Provisional for period of at least 6 months, will a full AEL be considered.  The facility cannot operate without an AEL.

Based on the outcome of the specialist study the activity will not have a significant detrimental effect on the environment, including health, social conditions, economic conditions, ecological conditions or cultural heritage. The assessment made was based on the minimum emission limits as per the categories and the results demonstrated that the emissions will not exceed the limits as per the National Ambient Air Quality Standards (GN1210 of December 2009). International ambient air quality standards were used to compare the results where ambient air quality standards for specific pollutants are not included in GN1210 of December 2009. The study also included the cumulative impact of the surrounding industries (brick factory and pole yard) on ambient air quality.

9. Why is the plant located in Great Brak River and not in another industrial location such as Mossdustria?

This site was chosen based on its zoning and is an existing industrial zone.  This site is zoned Industrial Zone 3.  The other industrial site investigated, including Mossdustria, is zoned Industrial Zone 2.  This site is part of an existing serviced development and is in a disturbed state.   The site is on the existing Mobicast facility, bordered to the north by a sawmill/pole yard and to the south by the Rheebokstene brick factory. The landfill site is also north of the pole yard.

The entire facility, including storage, office, plant and roads has a footprint of approximately 2 100m².  This is relatively small compared to the sizes of the surrounding industries; Mobicast (43 000m²), Rheebokstene (195 000m²), Woodline Timber Industries (163 000m²) and the Landfill site (74 000m²).

As the proposed site is within the existing Mobicast site on a previously disturbed area and will be fully walled/fenced, its impact on the sense of place of the area would be low. The impact on tourism in the area is negligible due to the presence of existing industry surrounding the chosen site.

10. What process was followed to offer the public an opportunity to lodge their concerns aboutthe proposed project?

Public participation is understood to be a series of inclusive and culturally appropriate interactions aimed at providing stakeholders with opportunities to express their views, so that these can be considered and incorporated into the decision-making process. Effective public participation requires the disclosure of relevant and adequate project information to enable stakeholders to understand the risks, impacts, and opportunities of the Proposed Project.

The processes regulating the application for and granting of both Waste Management and Atmospheric Emission Licenses require public participation at various stages and in different forms.  The timing and nature of the public participation is prescribed by the licensing authority and subsequent legislation.

The following public participation processes were performed as part of the application for a Waste Management Licence:

  1. Pre-application Public Participation
  2. Application Public Participation including clarification meetings
  3. Appeal to granting of Waste Management License

The following public participation processes were performed as part of the application for an Atmospheric Emission Licence:

  1. Application Public Participation
  2. Appeal to granting of Atmospheric Emission License

The following was done in terms of the Waste Management License application:

Pre-application: Due to the nature of the project, a pre-application public participation process was undertaken to obtain comments on the proposed project prior to submission of the Draft BAR application.

Application: More than 150 individuals, organisations and authorities registered as interested and Affected Parties. Methods used to inform the public were inter alia: direct notification, advertisements, site notices, availability of draft basic assessment reports and final draft basic assessment reports.  This was also supplemented with:

Clarification Meeting with Representatives of the Resident’s Associations

  • The Rooikat project team was invited to attend a virtual meeting on 23 November 2020 to provide clarity on the proposed project. This meeting was hosted by representatives from the Resident Associations in the area.

Public Participation Feedback Meeting with Interested & Affected Parties

  • The Rooikat project team hosted a virtual meeting on 10 December 2020 to provide feedback on the main comments and concerns raised during the public participation.

Appeal:  The public participation process also allows the public to appeal the Waste Management License and Air Emissions License after the licenses are granted. Appeals were lodged by the public for both licenses post granting. The appeals were reviewed by the respective licensing authorities and the final licenses were granted.

Other public participation processes followed:

  • There was a parallel Public Participation process in terms of the Air Quality Act which was done according to the requirements of the Air Quality act.
  • Furthermore, a presentation was done to the Mayor of Mossel Bay and was open to the public with a special link. Question and answer sessions were allowed.
  • Media 24 also approached Mossel Bay and Garden Route District Municipalities to produce a video. They interviewed and published a video on their network after interviewing some of the relevant role-players of the project. ¬†Not all role-players chose to be interviewed.
  • The project was presented to the Garden Route Council and a resolution was approved to communicate the project further by means of this question and answers press release to inform the community accordingly.

11. What assurance does the public have if the projects do not live up to the expectations of not affecting the receptor environment?

The facility must be operated to comply with both the Waste Management and Atmospheric Emission Licences to ensure the operation is not detrimental to the environment.  The facility cannot operate without these licenses.

The facility is required to measure and report on its operation to the Licensing Authorities.  The Licensing Authorities also conduct inspections.  The Garden Route Municipality will ensure that the applicant operates within the regulations of the Atmospheric Emission License.  Should the facility not operate within the license conditions, the license may be withdrawn and the facility shutdown.  This has happened to another operating entity in the Garden Route District Municipality in the recent past.

For Air Quality-related queries and assistance, contact Dr Johann Schoeman (Manager: District Air Quality) via e-mail: jschoeman@gardenroute.gov.za 
Learn more about Air Quality here: Air Quality

All media-related queries can be directed to Herman Pieters (Chief Communications Officer), e-mail: communications@gardenroute.gov.za

Photo credit: Istock.