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Full Disclosure 2016

Paper & Pulp

Licences and authorisations required for operation

Licence Activity Applicable Legislation
Atmospheric Emission Licence Pulp and paper manufacturing activities include:
  1. the recovery of lime from the caustisizing process;
  2. the recovery of chemicals from the thermal treatment of spent liquor using furnaces;
  3. the recovery of chemicals from the thermal treatment of spent liquor using Copeland reactors;
  4. production and use of chlorine dioxide for paper production; and/or
  5. the burning or drying of wood by an external source of heat; and the manufacture of laminated and compressed wood products.
 List of activities which result in atmospheric emissions which have or may have a significant detrimental effect on the environment1 and accordingly require an Atmospheric Emission Licence before commencement (GN 893): Category 9, Sub-categories 9.1 – 9.5.
Atmospheric Emission Licence Solid biomass fuel2 combustion installations used primarily for steam raising or electricity generation (or combustion installations co-feeding waste3 with conventional fuels in processes used primarily for steam raising or electricity generation) GN 893: Category 1, Sub-category 1.3 (or Sub-category 1.6).
Water Use Licence Taking of water from a water resource.4 National Water Act: Section 21(a).
Water Use Licence Storing water.5 National Water Act: Section 21(b).
Water Use Licence Impeding or diverting the flow of water in a watercourse.6 National Water Act: Section 21(c).
Water Use Licence Engaging in a stream flow reduction activity contemplated in section 36 of the National Water Act.7 National Water Act: Section 21(d).
Water Use Licence Engaging in a controlled activity defined as such in section 37(1) or declared under section 38(1) of the National Water Act.8 National Water Act: Section 21(e).
Water Use Licence Discharging waste or water containing waste into a water resource through a pipe, canal, sewer, sea outfall or other conduit.9 National Water Act: Section 21(f).
Water Use Licence Disposing waste in a manner which may detrimentally impact on a water resource.10 National Water Act: Section 21(g).
Water Use Licence Disposing in any manner of water which contains waste from, or which has been heated in, any industrial or power generation process.11 National Water Act: Section 21(h).
Water Use Licence Altering the bed, banks, course or characteristics of a watercourse.12 National Water Act: Section 21(i).
Registration as dam with a safety risk The owner of a dam with a safety risk13 must register that dam within 120 days. National Water Act: Section 120 (read with Regulations regarding the Safety of Dams in terms of section 123(1) of the National Water Act14 (the Dam Regulations)).
Waste Management Licence The sorting, shredding, grinding, crushing, screening or bailing of general waste at a facility that has an operational area in excess of 1 000 square metres.15 List of waste management activities that have, or are likely to have, a detrimental effect on the environment16 and accordingly require a waste management licence (GN 921): Category A 3(2).
Waste Management Licence The recycling17 of general waste at a facility that has an operational area in excess of 500 square metres, excluding recycling that takes place as an integral part of an internal manufacturing process within the same premises. GN 921: Category A 3(3).
Waste Management Licence The recovery18 of waste including the refining, utilisation, or co-processing of waste in excess of 10 tons but less than 100 tons of general waste per day or in excess of 500 kilogram but less than 1 ton of hazardous waste per day, excluding recovery that takes place as an integral manufacturing process within the same premises. GN 921: Category A 3(5) (or Category B 4(3), where the recovery of waste is in excess of 100 tons of general waste or in excess of 1 ton of hazardous waste per day).
Waste Management Licence The treatment19 of general waste using any form of treatment at a facility that has the capacity to process in excess of 10 tons but less than 100 tons. GN 921: Category A 3(6) (or Category B 4(6) where the capacity to process is in excess of 100 tons per day calculated as a monthly average, using any form of treatment).
Waste Management Licence The construction of a facility for a waste management activity listed in Category A (not in isolation to associated waste management activity). GN 921: Category A 3(12) (or Category B 4(10) where the waste management activity is listed in Category B).
No licence, only compliance with Norms and Standards for Storage of Waste, 2013 The storage of general waste at a facility that has the capacity to store in excess of 100 cubic metres of general waste at any one time, excluding the storage of waste in lagoons or temporary20 storage of such waste. GN 921: Category C 5(1) (or Category C 5(2) where the capacity to store is in excess of 80 cubic meters of hazardous waste).
Environmental Authorisation The development of facilities or infrastructure for the generation of electricity from a renewable resource21 where the electricity output is more than 10 megawatts but less than 20 megawatts or the output is 10 megawatts or less but the total extent of the facility covers an area in excess of 1 hectares. Environmental Impact Assessment Regulations, Listing Notice 122 (Listing Notice 1): Activity 1 (or Listing Notice 2: Activity 1 where the electricity output is 20 megawatts or more).
Environmental Authorisation Development and related operation of facilities or infrastructure for the generation of electricity from non-renewable resources23 where the electricity output is more than 10 megawatts but less than 20 megawatts or the output is 10 megawatts or less but the total extent of the facility covers an area in excess of 1 hectares. Listing Notice 1: Activity 2 (or Listing Notice 2: Activity 2 where the electricity output is 20 megawatts or more).
Environmental Authorisation The development of infrastructure exceeding 1000 metres in length for the bulk transportation of water24 or storm water with an internal diameter of 0.36 metres or more, or with a peak throughput of 120 litres per second or more, excluding where such infrastructure is for bulk transportation of water or storm water or storm water drainage inside a road reserve, or where such development will occur within an urban area. Listing Notice 1: Activity 9.
Environmental Authorisation The development and related operation of infrastructure exceeding 1000 metres in length for the bulk transportation of sewage, effluent, process water, waste water,25 return water, industrial discharge or slimes – (i) with an internal diameter of 0,36 metres or more; or with a peak throughput of 120 litres per second or more. Listing Notice 1: Activity 10.
Environmental Authorisation The development of facilities or infrastructure for the off-stream storage26 of water, including dams and reservoirs, with a combined capacity of 50 000 cubic metres or more, unless such storage falls within the ambit of activity 16 in Listing Notice 2. Listing Notice 1: Activity 13.
Environmental Authorisation The development of facilities or infrastructure for the storage, or storage and handling, of a dangerous good,27 where such storage occurs in containers with a combined capacity of 80 but not exceeding 500 cubic metres. Listing Notice 1: Activity 14 (or Listing Notice 2: Activity 4, where the capacity exceeds 500 cubic metres).
Environmental Authorisation The development and related operation of facilities for the treatment of effluent, wastewater or sewage with a daily throughput capacity of more than 2 000 cubic metres but less than 15 000 cubic metres. Listing Notice 1: Activity 25 (or Listing Notice 2: Activity 25, where the capacity exceeds 15 000 cubic meters).
Environmental Authorisation 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 activities which are identified in Listing Notice 1, activities which are included in the list of waste management activities published in terms of section 19 of the National Environmental Management: Waste Act (in which case that Act will apply), or facilities with a daily throughput capacity of less than 2000 cubic metres. Environmental Impact Assessment Regulations, Listing Notice 228(Listing Notice 2): Activity 6.
Environmental Authorisation The development of facilities or infrastructure for the transfer of 50 000 cubic metres or more of water per day, from and to or between water catchments, water treatment works29 or impoundments, excluding treatment works where water is treated for drinking purposes. Listing Notice 2: Activity 11.
Environmental Authorisation The physical alteration of virgin soil to agriculture, or afforestation for the purposes of commercial tree, timber or wood production of 100 hectares or more. Listing Notice 2: Activity 13.
Environmental Authorisation The clearance of an area of 300 square metres or more of indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan.30 Environmental Impact Assessment Regulations Listing Notice 331 (Listing Notice 3): Activity 12.
Heritage Approval For large-scale developments of the following categories, the heritage resources authority in the applicable area must be notified (and having been notified will assess whether heritage approval is required):32
  1. the construction of a road, wall, powerline, pipeline, canal or other similar form of linear development or barrier exceeding 300 metres in length;
  2. the construction of a bridge or similar structure exceeding 50 metres in length;
  3. any development or other activity which will change the character of a site –
    1. exceeding 5 000 square metres in extent; or
    2. involving three or more existing erven or subdivisions thereof; or
    3. involving three or more erven or divisions thereof which have been consolidated within the past five years; or
    4. the costs of which will exceed a sum set in terms of regulations by SAHRA or a provincial heritage resources authority;
  4. the re-zoning of a site exceeding 10 000 square metres in extent; or
  5. any other category of development provided for in regulations by South African Heritage Resources Authority or a provincial heritage resources authority.
 National Heritage Resources Act: Section 38.
National Forests Act licence A licence is required for any of these activities in a State forest:33
  1. the establishment and management of a plantation;34
  2. the felling of trees and removal of timber;
  3. the cutting, disturbance, damage or destruction of any other forest produce; or
  4. the removal or receipt of any other forest produce.
 National Forests Act: Section 23.
Approval in terms of the Conservation of Agricultural Resources Act Prior to the cultivation or mechanical disturbance of any virgin soil, approval must be obtained from the relevant authority. Conservation of Agricultural Resources Act – Regulations:35 Regulation 2.

 

  1. Published under Government Notice 893 in Government Gazette 37054 of 22 November 2013.
  2. Sometimes, black liquor is concentrated in an evaporator and burnt in a recovery boiler to generate the electricity required to run the paper mill.
  3. This is applicable if conventional fuel is co-fed with waste to generate electricity.
  4. This is applicable if water is not supplied by the municipality and is not authorised in terms of a general authorisation.
  5. Water Use Licence may be required unless water storage is authorised in terms of a general authorisation.
  6. If any of its activities impede or divert the flow of water in a watercourse, a Water Use Licence may be required.
  7. The use of land for afforestation which has been or is being established for commercial purposes, is considered a stream flow reduction activity (section 36(1)(a), National Water Act).
  8. The irrigation of any land with waste or water containing waste generated through any industrial activity or by a waterwork, is considered a controlled activity (section 37(1), National Water Act). If the company irrigates land with waste water generated from its paper and pulp production process, a Water Use Licence may be required.
  9. If the company discharges waste water into a water resource, such as a river, a Water Use Licence may be required.
  10. If waste disposed is disposed of on land and may impact the quality of underground water, a Water Use Licence may be required.
  11. When pulp is washed, chemicals are added and the water is heated. A Water Use Licence may be required to regulate the disposal of such heated water.
  12. If any structures are constructed near or within watercourses, which result in the altering of its characteristic, a Water Use Licence may be required.
  13. A “dam with a safety risk” is defined in the National Water Act as “a dam which can contain, store or dam more than 50 000 cubic metres of water, whether that water contains any substance or not, and which has a wall of a vertical height of more than 5 metres, measured as the vertical difference between the lowest downstream ground elevation on the outside of the dam wall and the non-overspill crest level or the general top level of the dam wall”, or is declared a dam with a safety risk under the National Water Act.
  14. Published under Government Notice R139 in Government Gazette 35062 of 24 February 2012.
  15. This would be applicable if the company collects waste paper for recycling, and such waste materials are sorted on site.
  16. Published under Government Notice 921 in Government Gazette 37083 of 29 November 2013.
  17. “Recycle” is defined in the National Environmental Management: Waste Act as “a process where waste is reclaimed for further use, which process involves the separation of waste from a waste stream for further use and the processing of that separated material as a product or raw material”. Some companies use alternative raw materials for the production of paper, for example, Sappi uses bagasse (sugar cane waste) to produce coated fine paper at its Stanger Mill and its Cape Kraft Mill runs on 100% post-consumer waste.
  18. “Recovery” is defined in the National Environmental Management: Waste Act as the “controlled extraction or retrieval of any substance, material or object from waste”. “Black liquor” is a by-product of the pulp production process and is a black residue that remains after wood is pulped. Some companies use (like Sappi) use this as an alternative fuel and in its recovery boiler. If it takes place as an integral part of the company’s paper manufacturing process within the same premises, a Waste Management Licence is not required.
  19. “Treatment” is defined in the National Environmental Management: Waste Act as “any method, technique or process that is designed to-
    • change the physical, biological or chemical character or composition of a waste; or
    • remove, separate, concentrate or recover a hazardous or toxic component of a waste; or
    • destroy or reduce the toxicity of a waste.
    in order to minimise the impact of the waste on the environment prior to further use or disposal.” The treatment of black liquor, recycled fibre and other waste during the pulp and paper production process may require a Waste Management Licence.
  20. “Temporary storage” is defined in GN921 as “once off storage that does not exceed 90 days”.
  21. If the company generates its own electricity from renewable resources (for example, by using black liquor as fuel to generate electricity), it may need to obtain Environmental Authorisation.
  22. GN 983, published in Government Gazette 38282 of 4 December 2014.
  23. If the company generates its own electricity from non-renewable resources it may need to obtain Environmental Authorisation.
  24. The pulp and paper process requires large quantities of water for bleaching, washing, pulping, etc. If facilities are constructed to transport water to site and they meet the thresholds prescribed, then Environmental Authorisation is required.
  25. If wastewater is generated by the company and they construct facilities to transport such wastewater, this activity may be triggered.
  26. If water is drawn from water resources and stored on site, then Environmental Authorisation is required for the construction of such a water storage facility or infrastructure if the prescribed thresholds are met.
  27. Chemicals are used during the bleaching process and chemical pulping process. Some of these chemicals are regarded as harmful / dangerous substances. If facilities are constructed for the storage of such substances (and the storage capacity exceeds the prescribed threshold), then Environmental Authorisation is required.
  28. Government Notice R 984 published in Government Gazette 38282 of 4 December 2014.
  29. Companies need to treat waste water used in the paper and pulp production process. If facilities are constructed to transfer certain quantities of water between the treatment works, then Environmental Authorisation is required.
  30. Applicable if indigenous vegetation is removed for the construction of a paper and pulp factory.
  31. Published under Government Notice R 985 in Government Gazette 38282 of 4 December 2014.
  32. Heritage approval is not required if heritage impacts are assessed as part of an environmental impact assessment process for Environmental Authorisation, provided that comments received from the heritage authority are incorporated into the final report (as per section 38(10) of the National Heritage Resources Act).
  33. Only required if plantation is established within a State forest.
  34. “Plantation” is defined in the National Forests Act as “a group of trees cultivated for exploitation of the wood, bark, leaves or essential oils in the trees”.
  35. Published under Government Notice R1048 in Government Gazette 10029 of 25 May 1984.