Basic Assessment for the Prima Industrial Holdings ... · Reg. No. 2000/000392/07 PO Box 6002 Halfway House 1685, South Africa Building 1, Maxwell Office Park, Magwa Crescent West

Zitholele Consulting Reg. No. 2000/000392/07

PO Box 6002 Halfway House 1685, South Africa Building 1, Maxwell Office Park, Magwa Crescent West c/o Allandale Road & Maxwell Drive, Waterfall City, Midrand T : 011 207 2060 F : 086 674 6121 E : [email protected]

Directors : Dr. R.G.M. Heath, S. Pillay, N. Rajasakran

REPORT ON

Basic Assessment for the Prima Industrial Holdings: Environmental

Authorisation and Atmospheric Emission Licence Applications in

Ekurhuleni, Benoni South, Gauteng Province

GDARD Reference No.: to be obtained

Report No: 16111-46-Rep-001-Prima DBAR-Rev0

Submitted to:

Gauteng Department of Agriculture and Rural Development

P.O. Box 8769 Johannesburg

2000

17 March 2017 16111

17 March 2017 i 16111

ZITHOLELE CONSULTING

DOCUMENT CONTROL SHEET

Project Title: Basic Assessment for the Prima Industrial Holdings: Environmental Authorisation and Atmospheric Emission Licence Applications in Ekurhuleni, Benoni South, Gauteng Province Project No: 16111 Document Ref. No: 16111-46-Rep-001-Prima DBAR-Rev0

DOCUMENT APPROVAL

ACTION DESIGNATION NAME DATE SIGNATURE

Prepared Project Manager Virginia

Ramakuwela 24 February

2017

Reviewed & Approved

Project Associate Sharon Meyer-

Douglas 15 March

2017

17 March 2017 ii 16111

TABLE OF CONTENTS

SECTION PAGE

SECTION A: ACTIVITY INFORMATION .................................................................... 3 1. PROPOSAL OR DEVELOPMENT DESCRIPTION ........................................... 3 2. APPLICABLE LEGISLATION, POLICIES AND/OR GUIDELINES ................... 7 3. ALTERNATIVES ................................................................................................ 9 4. PHYSICAL SIZE OF THE ACTIVITY ............................................................... 10

5. SITE ACCESS .................................................................................................. 11 6. LAYOUT OR ROUTE PLAN ............................................................................ 11 7. SITE PHOTOGRAPHS .................................................................................... 12 8. FACILITY ILLUSTRATION ............................................................................... 12 SECTION B: DESCRIPTION OF RECEIVING ENVIRONMENT ............................. 13

1. PROPERTY DESCRIPTION ............................................................................ 13 2. ACTIVITY POSITION ....................................................................................... 13

3. GRADIENT OF THE SITE................................................................................ 14 4. LOCATION IN LANDSCAPE ........................................................................... 14 5. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE ...... 14 6. AGRICULTURE ................................................................................................ 15

7. GROUNDCOVER ............................................................................................. 15 8. LAND USE CHARACTER OF SURROUNDING AREA .................................. 16 9. SOCIO-ECONOMIC CONTEXT ...................................................................... 17

10. CULTURAL/HISTORICAL FEATURES ........................................................... 18 SECTION C: PUBLIC PARTICIPATION (SECTION 41) .......................................... 19

1. LOCAL AUTHORITY PARTICIPATION ........................................................... 19

2. CONSULTATION WITH OTHER STAKEHOLDERS ...................................... 19

3. GENERAL PUBLIC PARTICIPATION REQUIREMENTS ............................... 19 4. APPENDICES FOR PUBLIC PARTICIPATION .............................................. 19

1. WASTE, EFFLUENT, AND EMISSION MANAGEMENT ................................ 20 2. WATER USE .................................................................................................... 21 3. POWER SUPPLY ............................................................................................. 22

4. ENERGY EFFICIENCY .................................................................................... 22 SECTION E: IMPACT ASSESSMENT ..................................................................... 23

1. ISSUES RAISED BY INTERESTED AND AFFECTED PARTIES .................. 23 2. IMPACTS THAT MAY RESULT FROM THE CONSTRUCTION AND

OPERATIONAL PHASE .................................................................................. 23 3. IMPACTS THAT MAY RESULT FROM THE DECOMISSIONING AND

CLOSURE PHASE ........................................................................................... 29 4. CUMULATIVE IMPACTS ................................................................................. 30 5. ENVIRONMENTAL IMPACT STATEMENT .................................................... 30

6. IMPACT SUMMARY OF THE PROPOSAL OR PREFERRED ALTERNATIVE .......................................................................................................................... 31

7. SPATIAL DEVELOPMENT TOOLS ................................................................. 32 8. RECOMMENDATION OF THE PRACTITIONER ............................................ 32 9. THE NEEDS AND DESIRABILITY OF THE PROPOSED DEVELOPMENT .. 32

10. THE PERIOD FOR WHICH THE ENVIRONMENTAL AUTHORISATION IS REQUIRED ....................................................................................................... 32

11. ENVIRONMENTAL MANAGEMENT PROGRAMME (EMPR) ........................ 33

SECTION F: APPENDIXES ...................................................................................... 34

17 March 2017 iii 16111

LIST OF FIGURES Figure 1: Process flow for the proposed New Silica Sand Plant. ................................ 4

Figure 2: Process flow for the proposed New Silica Shot Blast Unit. .......................... 5

Figure 3: Location of the study area in relation to the surrounding land uses. .......... 6

LIST OF TABLES Table 1: Detailed description of the listed activity associated with the project .......... 6

Table 2: Criteria for the assessment of the extent of the impact. .............................. 23

Table 3: Criteria for the rating of the duration of an impact. ....................................... 23

Table 4: Criteria for impact rating of potential intensity of a negative impact. ......... 24

Table 5: Criteria for the impact rating of potential intensity of a positive impact. .... 24

Table 6: Criteria for the rating of the likelihood of the impact occurring ................... 24

Table 7: Significance rating formulas. ............................................................................ 25

Table 8: Example of Rating Scale ................................................................................. 25

LIST OF APPENDICES APPENDIX A: SITE PLAN (S)

APPENDIX B: PHOTOGRAPHS

APPENDIX C: FACILITY ILLUSTRATION(S)

APPENDIX D: ROUTE POSITION INFORMATION

APPENDIX E: PUBLIC PARTICIPATION INFORMATION

APPENDIX F: WATER USE LICENSE(S) AUTHORISATION, SAHRA INFORMATION, SERVICE LETTERS FROM MUNICIPALITIES, WATER SUPPLY INFORMATION

APPENDIX G: SPECIALIST REPORTS

APPENDIX H: EMPr

APPENDIX I: OTHER INFORMATION

17 March 2017 iv 16111

LIST OF ACROYNYMS

Acronym Description

BA Basic Assessment

BAR Basic Assessment Report

EAP Environmental Assessment Practitioner

EIA Environmental Impact Assessment

EMM Ekurhuleni Metropolitan Municipality

EMPr Environmental Management Programme

GDARD Gauteng Department of Agriculture and Rural Development

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

NEMWA National Environmental Management Waste Management Act 59 of 2008

NWA National Water Act 36 of 1998

OHS Occupational Health and Safety Act 85 of 1993

PAIA Promotion of Access to Information Act 2 of 2000

PPP Public Participation Process

WUL Water Use Licence

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Basic Assessment Report in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998), as amended, and the Environmental Impact Assessment Regulations, 2014 (Version 1) Kindly note that: 1. This Basic Assessment Report is the standard report required by GDARD in terms of the EIA Regulations, 2014.

2. This application form is current as of 8 December 2014. It is the responsibility of the EAP to ascertain whether subsequent

versions of the form have been published or produced by the competent authority.

3. A draft Basic Assessment Report must be submitted, for purposes of comments within a period of thirty (30) days, to all State Departments administering a law relating to a matter likely to be affected by the activity to be undertaken.

4. A draft Basic Assessment Report (1 hard copy and two CD’s) must be submitted, for purposes of comments within a period of thirty (30) days, to a Competent Authority empowered in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998), as amended to consider and decide on the application.

5. Five (5) copies (3 hard copies and 2 CDs-PDF) of the final report and attachments must be handed in at offices of the relevant competent authority, as detailed below.

6. The report must be typed within the spaces provided in the form. The size of the spaces provided is not necessarily indicative of the amount of information to be provided. The report is in the form of a table that can extend itself as each space is filled with typing.

7. Selected boxes must be indicated by a cross and, when the form is completed electronically, must also be highlighted.

8. An incomplete report may lead to an application for environmental authorisation being refused.

9. Any report that does not contain a titled and dated full colour large scale layout plan of the proposed activities including a coherent legend, overlain with the sensitivities found on site may lead to an application for environmental authorisation being refused.

10. The use of “not applicable” in the report must be done with circumspection because if it is used in respect of material information that is required by the competent authority for assessing the application, it may result in the application for environmental authorisation being refused.

11. No faxed or e-mailed reports will be accepted. Only hand delivered or posted applications will be accepted.

12. Unless protected by law, and clearly indicated as such, all information filled in on this application will become public information on receipt by the competent authority. The applicant/EAP must provide any interested and affected party with the information contained in this application on request, during any stage of the application process.

13. Although pre-application meeting with the Competent Authority is optional, applicants are advised to have these meetings prior

to submission of application to seek guidance from the Competent Authority.

DEPARTMENTAL DETAILS Gauteng Department of Agriculture and Rural Development Attention: Administrative Unit of the of the Environmental Affairs Branch P.O. Box 8769 Johannesburg 2000 Administrative Unit of the of the Environmental Affairs Branch Ground floor Diamond Building 11 Diagonal Street, Johannesburg Administrative Unit telephone number: (011) 240 3377 Department central telephone number: (011) 240 2500

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If this BAR has not been submitted within 90 days of receipt of the application by the competent authority and permission was not requested to submit within 140 days, please indicate the reasons for not submitting within time frame.

Not applicable

Is a closure plan applicable for this application and has it been included in this report?

if not, state reasons for not including the closure plan.

The proposed project will be operational until the unforeseeable future. A separate process will be undertaken nearing the closure time, which will include the closure plan.

Has a draft report for this application been submitted to a competent authority and all State Departments administering a law relating to a matter likely to be affected as a result of this activity? Is a list of the State Departments referred to above attached to this report including their full contact details and contact person?

Yes

If no, state reasons for not attaching the list.

Not Applicable

Have State Departments including the competent authority commented?

If no, why? An opportunity for all State Departments to comment will be during the 30 day public review period of this Basic Assessment Report (BAR).

(For official use only) NEAS Reference Number:

File Reference Number: Application Number:

Date Received:

No

Yes

No

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SECTION A: ACTIVITY INFORMATION 1. PROPOSAL OR DEVELOPMENT DESCRIPTION

Project title (must be the same name as per application form):

Basic Assessment for the Prima Industrial Holdings: Environmental Authorisation and Atmospheric Emission Licence Applications in Ekurhuleni, Benoni South, Gauteng Province

Select the appropriate box

The application is for an upgrade of an existing development

The application is for a new development

Other,

specify

Does the activity also require any authorisation other than NEMA EIA authorisation?

YES NO

If yes, describe the legislation and the Competent Authority administering such legislation

National Environmental Management: Air Quality Act (Act 39 of 2004). The competent authority for the proposed application will be Ekurhuleni Metropolitan Municipality.

If yes, have you applied for the authorisation(s)? YES NO

If yes, have you received approval(s)? (attach in appropriate appendix) YES NO

Project Description

Background

Prima Industrial Holdings (Pty) Ltd, hereinafter known as Prima, is a foundry which has offered more than 60 years of service to the local and international mining, crushing, and extraction industries. They specialize in designing and manufacturing of manganese steel castings for a range of industries.

Existing Activities

Prima produces ferrous castings by pouring molten metal into moulds, with cores to create hollow internal sections. After the metal has cooled, the casting is separated from the mould and undergoes cleaning and finishing.

Scrap steel along with ferro-alloys (FeMn, FeCr, FeSi) are loaded into electric arc furnaces and smelted. The molten metal is then tapped into a ladle which is used to pour into chrome sand moulds. The moulds are made up of chrome sand mixed with either Phenolic Resin or bentonite. Once the molten metal has set, the casting is removed from the moulds at the shakeout station. Following shakeout, the castings are sent for heat treatment and finishing. Waste generated from the process include broken and/or damaged mounds and cores, spent foundry sand, slag from the melting process, used electrodes, waste quenching water and scale. Air emissions from the process include fumes from the smelting and pouring processes, fugitive dust emissions from the metals storage scrapyard, unpaved roads in the plant, sand reclamation yard and materials handling activities on site.

The foundry operation consists of these six (6) principle steps

Obtaining the casting geometry - The casting geometry is obtained by sending blueprint drawings to the foundry, or computer aided designs are utilized.

Pattern making - The pattern is a physical model of the casting that will be used to make the mold. The mold is made by packing sand material around the pattern. When the pattern is withdrawn, the imprint provides the mold cavity, which is filled with metal to become the casting. If the casting needs to be hollow, then cores are patterned and used to form these hollow cavities.

Core-making - Cores are forms, usually made of sand, which are placed into a mold cavity to form the interior surfaces of castings. The void space between the core and mold-cavity surface is what eventually becomes the casting.

Molding - The molding consists of all the operations necessary to prepare a mold for receiving the molten metal. Molding involved placing a molding aggregate (compacted sand) around a pattern held with a support frame. The pattern is then removed to leave the mold cavity, setting the cores in the mold cavity and finishing and closing the mold.

Melting and Pouring - The preparation of molten metal for casting is referred to as melting. Melting is done in several specifically designated areas of the foundry, where the furnaces are located. Prima foundry melts scrap metal and ferrous alloys. The molten metal is transferred to the pouring area where the molds are filled.

Shake-out / Cleaning - Cleaning refer to all activities that remove the sand, scale and excess metal from a casting. The casting is separated from the mold and transported to the cleaning department. Burned-on sand and scale are removed to improve the surface appearance of the casting. Excess metal is also removed by blasting or grinding.

Existing Environmental Authorisations

Prima is currently authorised in the form of a Waste Management Licence (WML) for the above-mentioned activities (reuse, recycling and recovery of scrap metal and spent foundry sand (Licence number: 12/9/11/L1308/3, dated 11 December 2014). Refer to Appendix I1.

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Description of Proposed Project Activities

Prima intends to refurbish an old sand reclaiming plant for the installation and operation of the new Silica Sand Plant and new Silica Shot Blast Unit, including new stacks within Prima property. The Basic Assessment (BA) process is being undertaken for only the proposed upgrade, i.e. installation and operation of a new Silica Sand Plant and new Silica Shot Blast Unit. Two (2) additional stacks will be installed within the boundary of the existing operational area. Replacing the existing sand reclaiming plant with the installation and operation of the new Silica Sand Plant as well as installation and operation of a new Silica Shot Blast Unit within Prima property will comprise of the following:

Replacements of an existing Green Sand reclaim Plant;

Installation of a new Silica Sand Plant ~ 1 850 m² footprint;

Installation of a new Silica Shot Blast Unit within 1- 2 years ~ 69.3 m² footprint;

Installation of two dust extraction units (for existing Shakeout Station and Sand Reclamation plant) comprising of an additional emission stack, and refurbishment and relocation of an existing emission stack;

Installation of a new filter cartridges on the Shakeout station for the proposed Silica Sand Plant;

Mixing of sand (comprising of reclaimed silica sand, phenolic resin and acid catalyst); and

Operations of the new Silica Sand Plant and Silica Shot Blast Unit.

The existing infrastructure and/or processes on site have been in place since 1937, prior to the promulgation of the South African environmental legislation. Therefore, these activities predate the requirement for authorisation and are not covered in this BA process.

Refer to Figure 1 and Figure 2 for process flow diagram for the operation of new silica sand and new silica shot blast unit process flow diagrams respectively.

Figure 1: Process flow for the proposed New Silica Sand Plant.

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Figure 2: Process flow for the proposed New Silica Shot Blast Unit.

Detailed Project Description

Pre-Construction and Construction process for the proposed development

A description of the activities which forms part of replacing an old sand reclaiming plant with the installation and operation of the new

Silica Sand Plant and new silica shot blast unit is provided below:

Pit for sand processing and pumping: This pit shall be excavated (~219m³) by manual and mechanical means where possible. During this process, any ground water shall be pumped into the municipal sewer unless it can be used as part of our production process i.e. water quenching of our castings.

Sand removed from the pit shall be used as filling material in other parts of the premises or properly disposed of if there is no use for it. A waterproof plastic membrane shall be installed by Gundle Plastics followed by reinforced steel as per the design of the structural engineer. The concrete floor- and side wall shall then be cast where after the surrounding concrete floor shall be cast.

Concrete support plinths: The excavation for these plinths shall be by manual means and the same procedure as in “1” shall apply. There would however not be any membrane installed.

Holding silo’s and related steelwork: All these would be fabricated off-site at the premises of the various contractors and thereafter be transported to our site where after it would be assembled and erected by sub-contractors by means of a mobile crane.

An existing storage silo shall be modified for use in the new process. This silo shall not be moved in any way as it is one that was in use for our previous reclaim plant. The modification is limited to installation of separation plates on the inside of the silo as well as the modifications to the sand in- and outlets. Further modifications will be a new coat of paint.

Dust extraction units: Existing unit destined for the shake-out station shall be dismantled, serviced and re-erected by our own personnel with the help of a mobile crane. Once erected, this unit shall be inspected for compliance by Freudenberg, the original manufacturer and commissioned and performance tested once we have received permission from the authorities to start the plant. The new unit for the reclaim part of the plant shall be erected by our own personnel under supervision from Freudenberg. Thereafter the same will apply as in the case of the shake-out dust extractor

Other equipment: All other equipment will be installed and assembled by sub-contractors or by our own personnel where possible. Where necessary, either a mobile crane or one of our existing overhead cranes shall be used for installation and

6

assembly.

Electrical equipment: Electrical control gear and power- and control cables shall be installed by our own personnel where after the system will be calibrated, tested and commissioned by the engineers of the equipment supplier.

The construction of the proposed construction will take approximately four (4) months. However, the silica shot blast will only be installed within 1 – 2 years.

Operational activities

During the operational and maintenance phase of the project, the applicant will ensure that operation and maintenance activities are carried out by suitable qualified individual as the activities are specialised.

Decommissioning activities

Prima will remain operational for the unforeseeable future. However, decommissioning of the proposed activities will include reversal of the construction activities. Necessary authorisations for the decommissioning phase will be acquired nearing the time and prior to commencement with decommissioning activities.

Study Area / Site Description

The proposed project is located on Stands 9/2777, 11/2777, 3929 and 8403 of the Nestadt Industrial Sites in Benoni South, Gauteng Province (refer to Figure 3 and Appendix A2 for the Locality map). The properties are located along the Lincoln Road to the east of Atlas and Van Dyk Road(s) in Benoni (Physical address of the plant: 28 Lincoln Rd, Benoni, 1501) within the Ekurhuleni Metropolitan Municipality (EMM). The properties fall within an urban area and are approximately 45 ha in extent. The current land use zoning is industrial. The project site is an existing “brownfields site”.

Surrounding land uses include related commercial / industrial undertakings (e.g. factories producing industrial products). The project site is accessible from the east via an entrance on Lincoln Road. Foundry operations have been taking place on the property since 1937 and the biophysical environment has been significantly impacted on by historic and current anthropogenic impacts (industrial establishments, residential establishments, etc.).

Figure 3: Location of the study area in relation to the surrounding land uses.

Listed Activities triggered by the development

The activities that are associated with the proposed project trigger activities listed in Government Notice No. R.983 (2014), refer to Table 1. As set out in Regulations 19 of the National Environmental Management Act (Act 107 of 1998) as amended (NEMA) Environmental Impact Assessment (EIA) Regulations, 2014, the proposed project is subjected to a Basic Assessment (BA) Process (Government Notice No. R.982). Prima has therefore appointed Zitholele Consulting (Pty) Ltd (Zitholele) as the independent Environmental Impact Assessment Practitioner (EAP) to undertake the BA Process for the proposed project.

Table 1: Detailed description of the listed activity associated with the project

Indicate the number of the relevant Government Notice:

Activity No (s) (relevant notice): e.g. Listing notices 1, 2 or 3

Describe each listed activity as per the wording in the listing notices:

7

GN 983,

08 Dec 2014

Activity 34

(Listing Notice 1)

The expansion or changes to existing facilities for any process or activity where such expansion or changes will result in the need for a permit or licence or an amended permit or licence in terms of national or provincial legislation governing the release of emissions or pollution.

Further, the proposed activity triggers activity listed in Section 21 of the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) (NEM:AQA). Accordingly, Atmospheric Emissions Licence (AEL) Application Process must be conducted. The AEL application will be submitted to the EMM (competent/licensing authority) subsequent to the finalisation of the current BA process. The required AEL application will be an amendment to an AEL application submitted for the existing operational activities (Prima’s activities since 1937) in March 2014. Therefore, the AEL application will now include the existing operational activities as well as the proposed upgrade at Prima.

2. APPLICABLE LEGISLATION, POLICIES AND/OR GUIDELINES List all legislation, policies and/or guidelines of any sphere of government that are applicable to the application as contemplated in the EIA regulations:

Title of legislation, policy or guideline: Administering authority: Promulgation Date:

The Constitution of the Republic of South Africa (Act 106 of 1998) The Judiciary 18 December 1996

National Environmental Management Act, 1998 (Act No. 107 of 1998 as amended) (NEMA).

National & Provincial 27 November 1998

NEMA Environmental Impact Assessment (EIA) Regulations 2014 (published in Government Notice No. R.982)

Gauteng Department of Agriculture and Rural Development (GDARD)

4 December 2014

NEMA Listing Notice 1: List of activities and Competent Authorities identified in terms of Sections 24(2) and 24D (published in Government Notice No. R.983)

GDARD 4 December 2014

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

National and Provincial Department of Environmental Affairs or District or Metropolitan Municipality.

24 February 2005

National Water Act 36 of 1998 (NWA) Department of Water and Sanitation (DWS)

20 August 1998

National Environmental Management Waste Act 59 of 2008 (as amended) (NEMWA), National Norms and standards for the Storage of Waste (GNR.926 of 29 November 2013)

GDARD 10 March 2009 29 November 2013

Promotion of Access to Information Act 2 of 2000 (PAIA) GDARD 9 March 2001

Occupational Health and Safety Act 85 of 1993 Provincial Department of Labour.

23 June 1993

Integrated Environmental Management Guideline Series (Guideline 5) Companion to the EIA Regulations 2010 published in Government Notice 805

National and Provincial 10 October 2012

Integrated Environmental Management Guideline Series (Guideline 7) Public Participation in the EIA Process published in Government Notice 805

National and Provincial 10 October 2012

Environmental Management Plans, Integrated Environmental Management, Information Series 12, Department of Environmental Affairs and Tourism

National and Provincial 2004

Gauteng Provincial Environmental Management Framework GDARD 2014

Applicable by-laws of the Ekurhuleni Metropolitan Municipality. Ekurhuleni Metropolitan Municipality

-

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Description of compliance with the relevant legislation, policy or guideline:

Legislation, policy of guideline Description of compliance

The Constitution of the Republic of South Africa (Act 106 of 1998)

Section 24 of the Constitution of the Republic of South Africa provides for a comprehensive environmental right. Therefore, stakeholders and Interested and Affected Parties may exercise their right through providing comment during the PP process and raising issues of concern that are likely to infringe upon their environmental right. The Basic Assessment process recognises this right and the EAP has recorded, considered and responded to any and all issues of concern raised by the I&APs.

National Environmental Management Act 107 of 1998 (NEMA) and subsequent amendments to the Act.

The NEMA (as amended) is regarded as South Africa’s environmental framework legislation which provides for environmental management and gives effect to section 24 of the Constitution. The Basic Assessment and Public Participation processes were undertaken in strict compliance with the NEMA, as amended.

NEMA Environmental Impact Assessment (EIA) Regulations 2014 (published in Government Notice No. R.982)

The Basic Assessment Process for the proposed project is being carried out in accordance with the Regulations 19 and 20 of the NEMA EIA Regulations, 2014.

NEMA Listing Notice 1: List of activities and Competent Authorities identified in terms of Sections 24(2) and 24D (published in Government Notice No. R.983)

The proposed project activities trigger activities which are listed in Listing Notice 1. EA is therefore required before these activities may be implemented.

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

The air quality act provides for the protection of the environment by providing reasonable measures for the prevention of pollution and ecological degradation and for securing ecologically sustainable development while promoting justifiable economic and social development; to provide for national norms and standards regulating air quality monitoring, management and control by all spheres of government; for the specific air quality measures; and for the matters incidental thereto.

National Water Act 36 of 1998 (NWA)

The proposed project has considered the following: Section 19: prevention and remedying the effects of pollution; Section 20: control of emergency incidence; and Chapter 4: use of water and licensing. This Basic Assessment Process has considered such potential impacts and/or incidences.

National Environmental Management Waste Act 59 of 2008 (as amended) (NEMWA), National Norms and standards for the Storage of Waste (GNR.926 of 29 November 2013)

All requirements / provision concerning waste producing activities and the handling of waste, as provided in the NEMWA and the regulations thereunder must be conformed to. The quantity of general waste that will be temporarily be stored at the construction site is anticipated to be less than 100 m

3. In the event that more than 100 m

3 of waste is stored

at any one time, the developer must comply with the National Norms and standards for the Storage of Waste.

Promotion of Access to Information Act 2 of 2000 (PAIA)

Any information that is required for the completion of this basic assessment, and is not available in the public domain can be requested through this act. As per the NEMA EIA Regulations, 2014, as well as the principles/objectives of the PAIA, the Basic Assessment Report as well as all supporting documentation (e.g. specialist studies) will be made available to the public.

Occupational Health and Safety Act 85 of 1993

This is primarily intended to provide for the health and safety of persons at work and for the health and safety of persons in connection with the activities of persons at work. All work that is carried out for the implementation of the project activities as well as during each phase of the project lifecycle should be carried out in accordance with the provisions of the OHS Act.

Integrated Environmental Management Guideline Series (Guideline 5) Companion to the EIA Regulations 2010 published in Government Notice 805 (10 October 2012)

The aim of the guideline is to provide a detailed consideration of the practical implementation of the NEMA EIA Regulations. The guideline also provides guidance and clarity on the EA Process to be followed and interpretation of the listed activities. The guideline was used as a reference document to the applicability of the NEMA EIA Regulations, 2014 on the proposed project.

Integrated Environmental Management Guideline Series (Guideline 7) Public Participation in the EIA Process published in Government Notice 805 (10 October 2012)

The guideline is intended to provide information on the benefits of public participation, the minimum legal requirements for the Public Participation Process (PPP), the steps of the PPP, guidelines for planning a PPP and a description of the roles and responsibilities of the various role-players. The guideline was referred to, to facilitate an adequate understanding of the execution of the PPP.

Environmental Management Plans, Integrated Environmental Management, Information Series 12, Department of Environmental Affairs and Tourism

The guideline aims to provide a generic introductory information source on the purpose, objectives and content of Environmental Management Plans.

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Gauteng Provincial Environmental Management Framework (GPEMP)

The objective of the GPEMF is to guide sustainable land use management within the Gauteng Province.

Applicable by-laws of the Ekurhuleni Metropolitan Municipality.

A by-law is considered as piece of legislation that is specific to the municipal area of jurisdiction. By-laws are intended to regulate the affairs and the services it provides within the municipal boundaries. A by-law is passed by the Council of a municipality.

3. ALTERNATIVES Describe the proposal and alternatives that are considered in this application. Alternatives should include a consideration of all possible means by which the purpose and need of the proposed activity could be accomplished. The determination of whether the site or activity (including different processes etc.) or both is appropriate needs to be informed by the specific circumstances of the activity and its environment. The no-go option must in all cases be included in the assessment phase as the baseline against which the impacts of the other alternatives are assessed. Do not include the no go option into the alternative table below. Note: After receipt of this report the competent authority may also request the applicant to assess additional alternatives that could possibly accomplish the purpose and need of the proposed activity if it is clear that realistic alternatives have not been considered to a reasonable extent. Please describe the process followed to reach (decide on) the list of alternatives below

Only the proposed and a no-go alternative were considered for the proposed project. The decision on the proposed site is mainly due to applicant’s ownership and operation that has been in effect for more than 60 years on the specified property.

Provide a description of the alternatives considered

No. Alternative type, either alternative: site on property, properties, activity, design, technology, energy, operational or other(provide details of “other”)

Description

1 Proposal Replacing the existing sand reclaiming plant with the installation and operation of the new Silica Sand Reclaim Plant will comprise of the following:

Replacements of an existing Green Sand reclaim Plant;

Installation of a new Silica Sand Plant ~ 1 850 m² footprint;

Installation of a new Silica Shot Blast Unit within 1- 2 years;

Installation of two dust extraction units (for existing Shakeout Station and Sand Reclamation plant) comprising of an additional emission stack, and refurbishment and relocation of an existing emission stack;

Installation of a new filter cartridges on the Shakeout station for the proposed Silica Sand Plant;

Mixing of sand (comprising of reclaimed silica sand, phenolic resin and acid catalyst); and

Operations of the new Silica Sand Plant and Silica Shot Blast Unit.

2 Alternative 1

3 Alternative 2

Etc.

In the event that no alternative(s) has/have been provided, a motivation must be included in the table below.

The “alternatives”, in relation to a proposed activity, means different means of meeting the general purpose and requirements of the activity, which may include alternatives to the— (a) property on which or location where it is proposed to undertake the activity; (b) type of activity to be undertaken; (c) design or layout of the activity; (d) operational aspects of the activity; and (f) option of not implementing the activity.

Motivation for not considering site alternatives

Due to the nature of the project, i.e. refurbishment of an old sand reclaiming plant for the installation and operation of the new Silica Sand Plant including a stack, installation and operation of a new silica shot blast unit, including a new stack, refurbishment of installation of an existing stack on the shake-out within Prima property, no site alternatives were considered. Prima is existing and currently operational. Therefore, the proposed work is for expanding the existing operations. The proposed upgrade will occur where the old sand reclaiming plant requiring replacements as well as existing shake-out unit are located.

An Environmental Assessment Practitioner (EAP) considered the exclusion of site alternatives for the following reasons:

The proposed project will take place within Prima properties and existing operations;

The proposed project will occur within an industrial area and on an already impacted area instead of impacting a completely new footprint;

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Prima’s current operation has for over many years fixed the location for their operations including the sand reclaiming plant and shake-out unit. Consequently, the problem is area specific and therefore, there cannot be an alternative site; and

In addition, no environmental sensitivities and/or fatal flaws were identified on site that would prevent the use of the existing operational site for the proposed upgrade activities.

The objective of this BA process is therefore, to mitigate and manage the possible impacts of the proposed upgrade on the receiving environment. No other location alternatives have been investigated as relocating Prima to another location will not be financially feasible and would rather result in more environmental impacts as a new site would have to be established.

Motivation for not considering type of activity alternatives

The proposed upgrade is located within the existing Prima operations which have been for over many years fixed within an area currently zoned as Industrial. Prima’s products are in high demand and are supplied to both local and international consumers. As a result, Prima is a great contributor to the local economy and consequently to the South African economy. The proposed activity (upgrade) is sought to address the high demands (in the forms of quotations made to Prima recently) from both local and international consumers. Therefore, considering an alternative activity has not been considered a viable alternative. The proposed project is an upgrade or expansion of the existing operation.

Motivation for not considering design or layout alternatives

The proposed layout is considered to be the most feasible layout and design as it aligns with the existing Prima’s infrastructures. By utilising the existing Prima Foundry footprint, no Greenfields sites will be impacted. This necessitates designing the expansion to fit into available area within the currently impacted Prima property.

Motivation for not considering technology alternatives

The proposed refurbishment of an old sand reclaiming plant with a new Silica Sand Plant and new shot blast unit is sought to improve the current technology employed by Prima. Primarily, the new Silica Sand Plant will promote re-using of sand, using of finer sands, better surface finish, exceptional shakeout characteristics and eliminate generation of fumes during pouring operations. Installation and operation of new Silica Sand Plant will enable Prima to operate economically at the production rates expected (4-6 moulds per hour). The replacement of the existing system with this new system (new Silica Sand Plant and Silica Shot Blast Unit) will result in far lower dust emissions due to technology advancements. Based on the above-mentioned reason, no further technology alternatives regarding the proposed upgrade have been considered.

Consideration of No-Go Alternative

The ‘No-Go’ alternative refers to not implementing any of the proposed project activities described in this report. The option of not proceeding with the proposed upgrade will result in:

The continuation of the status quo and denied opportunity to contribute to the local economic development;

No opportunity for Prima to expand and inability for Prima to meet the high demand for their products;

Loss of employment through retrenchments; and

Loss of job opportunities that could become available because of the proposed expansion.

However, all impacts, although minimal, on the receiving environment that are likely to result during the Construction and Operational Phases of the proposed project will not transpire.

4. PHYSICAL SIZE OF THE ACTIVITY Indicate the total physical size (footprint) of the proposal as well as alternatives. Footprints are to include all new infrastructure (roads, services etc), impermeable surfaces and landscaped areas: Size of the activity:

Proposed activity (Total Footprint (Silica sand plant - 1 850 m² and silica shot blast unit - 69.3 m²))

1 919.3 m²

Alternatives: Alternative 1 (if any)

Alternative 2 (if any)

Ha/ m2

or, for linear activities: Length of the activity:

Proposed activity



m/km Indicate the size of the site(s) or servitudes (within which the above footprints will occur): Size of the site/servitude:

Proposed activity 1 919.3 m²

11



Ha/m2

5. SITE ACCESS Proposal

Does ready access to the site exist, or is access directly from an existing road? YES NO

If NO, what is the distance over which a new access road will be built m

Describe the type of access road planned:

The site earmarked for the proposed upgrade is within Prima property (existing operations’ site) and is accessible from the east via an entrance on Lincoln Road (to the east of Atlas and Van Dyk Road(s)), as illustrated on the Site Layout Plan (Appendix A-1)

Include the position of the access road on the site plan (if the access road is to traverse a sensitive feature the impact thereof must be included in the assessment). Alternative 1




Include the position of the access road on the site plan. (if the access road is to traverse a sensitive feature the impact thereof must be included in the assessment). Alternative 2




Include the position of the access road on the site plan. (if the access road is to traverse a sensitive feature the impact thereof must be included in the assessment).

PLEASE NOTE: Points 6 to 8 of Section A must be duplicated where relevant for alternatives

(only complete when applicable)

6. LAYOUT OR ROUTE PLAN A detailed site or route (for linear activities) plan(s) must be prepared for each alternative site or alternative activity. It must be attached to this document. The site or route plans must indicate the following: the layout plan is printed in colour and is overlaid with a sensitivity map (if applicable); layout plan is of acceptable paper size and scale, e.g.

o A4 size for activities with development footprint of 10sqm to 5 hectares; o A3 size for activities with development footprint of ˃ 5 hectares to 20 hectares; o A2 size for activities with development footprint of ˃20 hectares to 50 hectares); o A1 size for activities with development footprint of ˃50 hectares);

The following should serve as a guide for scale issues on the layout plan:

o A0 = 1: 500 o A1 = 1: 1000 o A2 = 1: 2000 o A3 = 1: 4000 o A4 = 1: 8000 (±10 000)

shapefiles of the activity must be included in the electronic submission on the CD’s; the property boundaries and Surveyor General numbers of all the properties within 50m of the site; the exact position of each element of the activity as well as any other structures on the site; the position of services, including electricity supply cables (indicate above or underground), water supply pipelines, boreholes,

sewage pipelines, septic tanks, storm water infrastructure; servitudes indicating the purpose of the servitude; sensitive environmental elements on and within 100m of the site or sites (including the relevant buffers as prescribed by the

competent authority) including (but not limited thereto): o Rivers and wetlands; o the 1:100 and 1:50 year flood line; o ridges; o cultural and historical features; o areas with indigenous vegetation (even if it is degraded or infested with alien species);

Section A 6-8 has been duplicated No Number of times

12

Where a watercourse is located on the site at least one cross section of the water course must be included (to allow the position of the relevant buffer from the bank to be clearly indicated)

FOR LOCALITY MAP (NOTE THIS IS ALSO INCLUDED IN THE APPLICATION FORM REQUIREMENTS)

the scale of locality map must be at least 1:50 000. For linear activities of more than 25 kilometres, a smaller scale e.g. 1:250

000 can be used. The scale must be indicated on the map; the locality map and all other maps must be in colour; locality map must show property boundaries and numbers within 100m of the site, and for poultry and/or piggery, locality map

must show properties within 500m and prevailing or predominant wind direction; for gentle slopes the 1m contour intervals must be indicated on the map and whenever the slope of the site exceeds 1:10, the

500mm contours must be indicated on the map; areas with indigenous vegetation (even if it is degraded or infested with alien species); locality map must show exact position of development site or sites; locality map showing and identifying (if possible) public and access roads; and the current land use as well as the land use zoning of each of the properties adjoining the site or sites.

7. SITE PHOTOGRAPHS Colour photographs from the center of the site must be taken in at least the eight major compass directions with a description of each photograph. Photographs must be attached under the appropriate Appendix. It should be supplemented with additional photographs of relevant features on the site, where applicable.

8. FACILITY ILLUSTRATION A detailed illustration of the activity must be provided at a scale of 1:200 for activities that include structures. The illustrations must be to scale and must represent a realistic image of the planned activity. The illustration must give a representative view of the activity to be attached in the appropriate Appendix.

Refer to Appendix A-1: Layout Map and Appendix A-3: Sensitivity Map

Refer to Appendix A-2: Locality Map

Refer to Appendix B: Site Photographs

Refer to Appendix C: Facility Illustration

13

SECTION B: DESCRIPTION OF RECEIVING ENVIRONMENT

Note: Complete Section B for the proposal and alternative(s) (if necessary) Instructions for completion of Section B for linear activities

1) For linear activities (pipelines etc) it may be necessary to complete Section B for each section of the site that has a significantly different environment.

2) Indicate on a plan(s) the different environments identified 3) Complete Section B for each of the above areas identified 4) Attach to this form in a chronological order 5) Each copy of Section B must clearly indicate the corresponding sections of the route at the top of the next page.

Instructions for completion of Section B for location/route alternatives 1) For each location/route alternative identified the entire Section B needs to be completed 2) Each alterative location/route needs to be clearly indicated at the top of the next page 3) Attach the above documents in a chronological order

(complete only when appropriate)

Instructions for completion of Section B when both location/route alternatives and linear activities are applicable for the application Section B is to be completed and attachments order in the following way

All significantly different environments identified for Alternative 1 is to be completed and attached in a chronological order; then

All significantly different environments identified for Alternative 2 is to be completed and attached chronological order, etc.

Section B - Section of Route (complete only when appropriate for above)

Section B – Location/route Alternative No. (complete only when appropriate for above)

1. PROPERTY DESCRIPTION

Property description: (Including Physical Address and Farm name, portion etc.)

The proposed project is located on Stands 9/2777, 11/2777, 3929 and 8403 of the Nestadt Industrial Sites in Benoni South, Gauteng Province. The properties are located along the Lincoln Road to the east of Atlas and Van Dyk Road(s) in Benoni (Physical address of the plant: 28 Lincoln Rd, Benoni, 1501) within the EMM.

2. ACTIVITY POSITION Indicate the position of the activity using the latitude and longitude of the centre point of the site for each alternative site. The co-ordinates should be in decimal degrees. The degrees should have at least six decimals to ensure adequate accuracy. The projection that must be used in all cases is the WGS84 spheroid in a national or local projection.

Alternative: Latitude (S): Longitude (E):

Proposed site -26.207723° 28.293378°

In the case of linear activities: Alternative: Latitude (S): Longitude (E):

Starting point of the activity o

o

Middle point of the activity o

o

End point of the activity o o

For route alternatives that are longer than 500m, please provide co-ordinates taken every 250 meters along the route and attached in the appropriate Appendix

Addendum of route alternatives attached N/A

Section B has been duplicated for sections of the route "insert No. of duplicates" times

Section B has been duplicated for location/route alternatives "insert No. of duplicates" times

14

The 21 digit Surveyor General code of each cadastral land parcel

PROPOSAL T 0 I R 0 0 5 4 0 0 0 0 2 7 7 7 0 0 0 1 1 T 0 I R 0 0 5 4 0 0 0 0 2 7 7 7 0 0 0 0 9 T 0 I R 0 0 4 8 0 0 0 0 3 6 2 9 0 0 0 0 0 T 0 I R 0 0 4 8 0 0 0 0 8 4 0 3 0 0 0 0 0 ALT. 1 ALT. 2 etc.

3. GRADIENT OF THE SITE Indicate the general gradient of the site.

Flat 1:50 – 1:20 1:20 – 1:15 1:15 – 1:10 1:10 – 1:7,5 1:7,5 – 1:5 Steeper than 1:5

4. LOCATION IN LANDSCAPE Indicate the landform(s) that best describes the site.

Ridgeline Plateau Side slope of

hill/ridge Valley Plain

Undulating plain/low

hills

River front

5. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE

a) Is the site located on any of the following?

Shallow water table (less than 1.5m deep) YES NO

Dolomite, sinkhole or doline areas YES NO

Seasonally wet soils (often close to water bodies) YES NO Unstable rocky slopes or steep slopes with loose soil YES NO Dispersive soils (soils that dissolve in water) YES NO Soils with high clay content (clay fraction more than 40%) YES NO Any other unstable soil or geological feature YES NO An area sensitive to erosion YES NO

(Information in respect of the above will often be available at the planning sections of local authorities. Where it exists, the 1:50 000 scale Regional Geotechnical Maps prepared by Geological Survey may also be used).

b) are any caves located on the site(s) YES NO

If yes to above provide location details in terms of latitude and longitude and indicate location on site or route map(s) Latitude (S): Longitude (E):

o o

c) are any caves located within a 300m radius of the site(s) YES NO


o o

d) are any sinkholes located within a 300m radius of the site(s) YES NO


o o

If any of the answers to the above are “YES” or “unsure”, specialist input may be requested by the Department

Refer to Appendix A-4: Topography Map

Refer to Appendix A-4: Topography Map

Refer to Appendix A-5 and Appendix A-6 for the Soil and Geological Map respectively

15

6. AGRICULTURE Does the site have high potential agriculture as contemplated in the Gauteng Agricultural Potential Atlas (GAPA 4)?

YES NO

Please note: The Department may request specialist input/studies in respect of the above.

7. GROUNDCOVER To be noted that the location of all identified rare or endangered species or other elements should be accurately indicated on the site plan(s). Indicate the types of groundcover present on the site and include the estimated percentage found on site

Natural veld - good condition

% =

Natural veld with scattered aliens

% =

Natural veld with heavy alien infestation

% =

Veld dominated by alien species

%

Landscaped (vegetation)

% =

Sport field % =

Cultivated land %

Paved surface (hard landscaping)

% = 3

Building or other structure % = 90

Bare soil % = 7

Please note: The Department may request specialist input/studies depending on the nature of the groundcover and potential impact(s) of the proposed activity/ies.

Are there any rare or endangered flora or fauna species (including red list species) present on the site

YES NO

If YES, specify and explain:

Are there any rare or endangered flora or fauna species (including red list species) present within a 200m (if within urban area as defined in the Regulations) or within 600m (if outside the urban area as defined in the Regulations) radius of the site.

YES NO


Are there any special or sensitive habitats or other natural features present on the site? YES NO


Was a specialist consulted to assist with completing this section YES NO

If yes complete specialist details

Name of the specialist:

Qualification(s) of the specialist:

Postal address:

Postal code:

Telephone: Cell:

E-mail: Fax:

Are any further specialist studies recommended by the specialist? YES NO

If YES, specify:

If YES, is such a report(s) attached? YES NO

Southern border of the proposed upgrade site has been categorised according to the surface-area classes as ‘class 1’ of the High Potential Agricultural Land (HPAL). As described in GAPA 4, class 1 refers to areas covering the surface-area ranging from 0 – 24.99 ha. However, Prima is not located within an area earmarked as HPAL according to GAPA 4. In addition, the cultivation status as contemplated by GAPA 4 indicated that there are no agricultural activities taking place within the proposed upgrade site as per 2009 and 2012 data (GAPA 4). Only pieces of land to the south-west and north-west of the proposed upgrade site has been identified to have medium cultivation activities taking place as per information updated in 2012 (GAPA 4). According to the Agro-Ecological Zones (AEZ) as contemplated in GAPA 4, the proposed site has been zoned as 101. Refer to Error! Reference source not found. below for the Land Capability, Land cover, Land use and Biodiversity status.

Refer to Appendix A-7 for Agricultural Map

Refer to Appendix A-8 for Land Cover Map.

16

If YES list the specialist reports attached below

Signature of specialist: Date:

Please note; If more than one specialist was consulted to assist with the filling in of this section then this table must be appropriately duplicated

8. LAND USE CHARACTER OF SURROUNDING AREA Using the associated number of the relevant current land use or prominent feature from the table below, fill in the position of these land-uses in the vacant blocks below which represent a 500m radius around the site

1. Vacant land 2. River, stream,

wetland 3. Nature conservation

area 4. Public open space 5. Koppie or ridge

6. Dam or reservoir 7. Agriculture 8. Low density

residential 9. Medium to high

density residential 10. Informal residential

11. Old age home 12. Retail 13. Offices 14. Commercial &

warehousing 15. Light

industrial

16. Heavy industrialAN

17. Hospitality

facility 18. Church

19. Education facilities

20. Sport facilities

21. Golf course/polo fields

22. AirportN

23. Train station or shunting yard

N

24. Railway lineN

25. Major road (4 lanes or more)

N

26. Sewage treatment plant

A

27. Landfill or waste treatment

siteA

28. Historical building 29. Graveyard 30. Archeological

site

31. Open cast mine 32. Underground

mine 33.Spoil heap or

slimes damA

34. Small Holdings

Other land uses (describe):

Refer to Appendix A-1 and Appendix A-8 for layout and Land Cover

Maps respectively.

17

Note: More than one (1) Land-use may be indicated in a block Please note: The Department may request specialist input/studies depending on the nature of the land use character of the area and potential impact(s) of the proposed activity/ies. Specialist reports that look at health & air quality and noise impacts may be required for any feature above and in particular those features marked with an “

A“ and with an “

N” respectively.

Have specialist reports been attached YES NO

If yes indicate the type of reports below

Appendix G-1: Air Quality Impact Assessment Report

Refer to Appendix I-1 for the previously conducted specialist reports.

9. SOCIO-ECONOMIC CONTEXT Describe the existing social and economic characteristics of the area and the community condition as baseline information to assess the potential social, economic and community impacts.

Ekurhuleni Metropolitan Municipality

Level of unemployment:

In terms of employment, Ekurhuleni Metropolitan has a total of about 1,6 million economically active individuals (i.e. those who are employed or unemployed but looking for work) (Statistics South Africa Census, 2011). Out of these individuals, 28,8% are unemployed. There are about 840 000 economically active youth (15–34 years), 36,9% of whom are unemployed (Census, 2011).

Economic profile of local municipality:

Ekurhuleni Metropolitan has a large and diverse economy within the South African context. It contributes about a quarter of the Gauteng Province economy, which in turn contributes to over a third of the National Gross Domestic Product (Ekurhuleni IDP, 2013/2013). This is due to the reason that many of the factories for production of goods and commodities are located in Ekurhuleni, which is often referred to as "Africa's Workshop" (IDP, 2013/2014).

Moreover, Ekurhuleni Metropolitan has a network of roads, airports, rail lines, telephones, electricity grids and telecommunications that challenges those of Europe and America. It can be regarded as the transportation hub of the country. OR Tambo International Airport which is the South Africa's largest railway hub; a number of South Africa's modern freeways and expressways; the Maputo corridor development; direct rail, road and air links connecting Ekurhuleni to Durban; the Blue IQ projects, the Gautrain rapid rail link to Johannesburg and Tshwane; and the OR Tambo International Airport Industrial Development Zone (IDZ) are found within this municipality (IDP, 2013/2014). As a result of OR Tambo International airport being located in this municipality, a number of airline company headquarters are located within the municipality, such as South African Airways, Comair, Kulula.com, and 1Time, to name the few (IDP, 2013/2014).

Main Economic Sectors include: Manufacturing, mining, industrial and business sectors.

NORTH

WEST

1, 16 1, 15, 16, 24

1, 9, 15, 25

9, 15, 16

9, 15, 16

EAST

15, 16, 24, 25

16, 24 15, 16, 24

15, 16 9, 15, 16

1, 15, 16, 23,

24

15, 16 15, 16 15, 16

1, 15, 16

15, 16 1, 15, 16

15, 16 15, 16

1, 15, 16

15, 16, 20

1, 9, 15, 16,

9, 15, 16

15, 16

SOUTH

NOTE: Each block represents an area of 250m X 250m, if your proposed development is larger than this please use the

appropriate number and orientation of hashed blocks

= Site

18

Level of education:

According to the Statistics South Africa (Census, 2011), the level of education in Ekurhuleni Metropolitan Municipality was as follows: Higher education aged 20+ : 14.6 % Matric aged 20+ : 35.4 % No schooling : 3.6%

10. CULTURAL/HISTORICAL FEATURES Please be advised that if section 38 of the National Heritage Resources Act 25 of 1999 is applicable to your proposal or alternatives, then you are requested to furnish this Department with written comment from the South African Heritage Resource Agency (SAHRA) – Attach comment in appropriate annexure 38. (1) Subject to the provisions of subsections (7), (8) and (9), any person who intends to undertake a development categorised as- (a) the construction of a road, wall, powerline, pipeline, canal or other similar form of linear development or barrier exceeding 300m

in length; (b) the construction of a bridge or similar structure exceeding 50m in length; (c) any development or other activity which will change the character of a site- (i) exceeding 5 000 m2 in extent; or (ii) involving three or more existing erven or subdivisions thereof; or (iii) involving three or more erven or divisions thereof which have been consolidated within the past five years; or (iv) the costs of which will exceed a sum set in terms of regulations by SAHRA or a provincial heritage resources

authority; (d) the re-zoning of a site exceeding 10 000 m2 in extent; or (e) any other category of development provided for in regulations by SAHRA or a provincial heritage resources authority, must at the

very earliest stages of initiating such a development, notify the responsible heritage resources authority and furnish it with details regarding the location, nature and extent of the proposed development.

Are there any signs of culturally (aesthetic, social, spiritual, environmental) or historically significant elements, as defined in section 2 of the National Heritage Resources Act, 1999, (Act No. 25 of 1999), including archaeological or palaeontological sites, on or close (within 20m) to the site?

YES NO

If YES, explain:

If uncertain, the Department may request that specialist input be provided to establish whether there is such a feature(s) present on or close to the site.

Briefly explain the findings of the specialist if one was already appointed:

Will any building or structure older than 60 years be affected in any way? YES NO

Is it necessary to apply for a permit in terms of the National Heritage Resources Act, 1999 (Act 25 of 1999)?

YES NO

If yes, please attached the comments from SAHRA in the appropriate Appendix

19

SECTION C: PUBLIC PARTICIPATION (SECTION 41) The Environmental Assessment Practitioner must conduct public participation process in accordance with the requirement of the EIA Regulations, 2014. 1. LOCAL AUTHORITY PARTICIPATION Local authorities are key interested and affected parties in each application and no decision on any application will be made before the relevant local authority is provided with the opportunity to give input. The planning and the environmental sections of the local authority must be informed of the application at least thirty (30) calendar days before the submission of the application to the competent authority.

Was the draft report submitted to the local authority for comment? YES NO

If yes, has any comments been received from the local authority? YES NO

If “YES”, briefly describe the comment below (also attach any correspondence to and from the local authority to this application):

Process currently in 30 day BAR public review period. Awaiting comments from Interested and Affected Parties (I&APs).

If “NO” briefly explain why no comments have been received or why the report was not submitted if that is the case.

This is the draft report that is yet to be reviewed for a period of 30 days from the date it is available for review, i.e. in March 2017. Details on this section will be completed fully subsequent to the review period as stated above.

2. CONSULTATION WITH OTHER STAKEHOLDERS Any stakeholder that has a direct interest in the activity, site or property, such as servitude holders and service providers, should be informed of the application at least thirty (30) calendar days before the submission of the application and be provided with the opportunity to comment.

Has any comment been received from stakeholders? YES NO

If “YES”, briefly describe the feedback below (also attach copies of any correspondence to and from the stakeholders to this application):

If “NO” briefly explain why no comments have been received

Same as above.

3. GENERAL PUBLIC PARTICIPATION REQUIREMENTS The Environmental Assessment Practitioner must ensure that the public participation process is adequate and must determine whether a public meeting or any other additional measure is appropriate or not based on the particular nature of each case. Special attention should be given to the involvement of local community structures such as Ward Committees and ratepayers associations. Please note that public concerns that emerge at a later stage that should have been addressed may cause the competent authority to withdraw any authorisation it may have issued if it becomes apparent that the public participation process was flawed. The EAP must record all comments and respond to each comment of the public / interested and affected party before the application report is submitted. The comments and responses must be captured in a Comments and Responses Report as prescribed in the regulations and be attached to this application. 4. APPENDICES FOR PUBLIC PARTICIPATION All public participation information is to be attached in the appropriate Appendix. The information in this Appendix is to be ordered as

detailed below:

Appendix 1 – Proof of site notice

Appendix 2 – Written notices issued as required in terms of the regulations

Appendix 3 – Proof of newspaper advertisements

Appendix 4 –Communications to and from interested and affected parties

Appendix 5 – Minutes of any public and/or stakeholder meetings

Appendix 6 - Comments and Responses Report

Appendix 7 –Comments from I&APs on Basic Assessment (BA) Report

Appendix 8 –Comments from I&APs on amendments to the BA Report - Not Applicable.

Appendix 9 – Copy of the register of I&APs

20

Section D: resource use and process details

Note: Section D is to be completed for the proposal and alternative(s) (if necessary)

Instructions for completion of Section D for alternatives 1) For each alternative under investigation, where such alternatives will have different resource and process details (e.g.

technology alternative), the entire Section D needs to be completed 4) Each alterative needs to be clearly indicated in the box below 5) Attach the above documents in a chronological order

(complete only when appropriate)

Section D Alternative No. "insert alternative number" (complete only when appropriate for above)

1. WASTE, EFFLUENT, AND EMISSION MANAGEMENT Solid waste management

Will the activity produce solid construction waste during the construction/initiation phase? YES NO

If yes, what estimated quantity will be produced per month? ~15m3

How will the construction solid waste be disposed of (describe)?

Construction waste generated from the proposed activities will include some spoils such as earth rock, cement and steel materials. Any construction material to be disposed of needs to be at a recognised and licensed disposal site. The applicant will conform to the National Waste Management Strategy and the principles of the Waste Management Hierarchy. The waste will either be re-used or recycled where possible. Any loose rock generated by the proposed project would be used in the construction of the project (as backfill, etc.) whilst spent sand and slag is supplied to other users (such as RFR factory). Where waste cannot be re-used or recycled it shall be transported to the nearest licensed waste disposal facility, either by the EnviroServe service provider or through the official integrated waste management service provider to the EMM. Certificates of disposal indicating type and volume/mass of waste will be retained for verification and compliance purposes. Littering on site will not be permitted. No waste will be buried or dumped on site and no unauthorised burning of any waste materials, litter or refuse will be allowed. Waste management at Prima is managed as per their existing WML (Licence number: 12/9/11/L1308/3) for the reuse, recycling and recovery of scrap metal and spent foundry sand was issued to Prima on 11 December 2014, refer to Appendix I-1).

Where will the construction solid waste be disposed of (describe)?

Same as above.

Will the activity produce solid waste during its operational phase? YES NO

If yes, what estimated quantity will be produced per month? `±15 m3

How will the solid waste be disposed of (describe)?

Waste will be separated into the different waste types and placed in appropriately marked waste containers. The waste containers will be transported to the nearest licensed waste disposal facility (Waste Landfill Site) either by an accredited service provider or Ekurhuleni’s official integrated waste management service provider. Certificate of disposal indicating type and volume/mass of waste will be retained. The applicant will conform to their existing WML at all times.

Has the municipality or relevant service provider confirmed that sufficient air space exists for treating/disposing of the solid waste to be generated by this activity?

YES NO

Where will the solid waste be disposed if it does not feed into a municipal waste stream (describe)?

The waste will either be re-used or recycled where possible. Where waste cannot be re-used or recycled, it shall be separated into the different waste types and placed in appropriately marked waste containers. The waste containers will be transported to the nearest licensed waste disposal facility. Certificate of disposal indicating type and volume/mass of waste will be retained. The applicant will conform to their existing WML at all times.

Note: If the solid waste (construction or operational phases) will not be disposed of in a registered landfill site or be taken up in a municipal waste stream, the applicant should consult with the competent authority to determine whether it is necessary to change to an application for scoping and EIA.

Can any part of the solid waste be classified as hazardous in terms of the relevant legislation? YES NO

If yes, inform the competent authority and request a change to an application for scoping and EIA.

Is the activity that is being applied for a solid waste handling or treatment facility? YES NO

Section D has been duplicated for alternatives "insert No. of duplicates" times

21

If yes, the applicant should consult with the competent authority to determine whether it is necessary to change to an application for scoping and EIA.

Describe the measures, if any, that will be taken to ensure the optimal reuse or recycling of materials:

The waste materials generated during the operational phase of the proposed development will be managed as per their existing WML (Licence number: 12/9/11/L1308/3) for the reuse, recycling and recovery of scrap metal and spent foundry sand was issued to Prima on 11 December 2014, refer to Appendix I1).

Liquid effluent (other than domestic sewage)

Will the activity produce effluent, other than normal sewage, that will be disposed of in a municipal sewage system?

YES NO

If yes, what estimated quantity will be produced per month? N/A m3

If yes, has the municipality confirmed that sufficient capacity exist for treating / disposing of the liquid effluent to be generated by this activity(ies)?

YES NO

Will the activity produce any effluent that will be treated and/or disposed of on site? Yes NO

If yes, what estimated quantity will be produced per month? N/A m3

If yes describe the nature of the effluent and how it will be disposed.

Not applicable.

Note that if effluent is to be treated or disposed on site the applicant should consult with the competent authority to determine whether it is necessary to change to an application for scoping and EIA

Will the activity produce effluent that will be treated and/or disposed of at another facility? YES NO

If yes, provide the particulars of the facility:

Facility name:

Contact person:

Postal address:

Postal code:

Telephone: Cell:

E-mail: Fax:

Describe the measures that will be taken to ensure the optimal reuse or recycling of waste water, if any:

Not applicable.

Liquid effluent (domestic sewage)

Will the activity produce domestic effluent that will be disposed of in a municipal sewage system? YES NO

If yes, what estimated quantity will be produced per month?

If yes, has the municipality confirmed that sufficient capacity exist for treating / disposing of the domestic effluent to be generated by this activity(ies)? Refer to Appendix F2.

YES NO

Will the activity produce any effluent that will be treated and/or disposed of on site? YES NO

If yes describe how it will be treated and disposed off.

Not applicable.

Emissions into the atmosphere

Will the activity release emissions into the atmosphere? YES NO

If yes, is it controlled by any legislation of any sphere of government? YES NO

If yes, the applicant should consult with the competent authority to determine whether it is necessary to change to an application for scoping and EIA.

If no, describe the emissions in terms of type and concentration:

This BA is being undertaken for the proposed upgrade at Prima and the AEL application for the operational activities that affect emissions generated Construction Phase: Dust and exhaust emissions from construction vehicles will be generated. However, watering will be used to suppress dust on site. Operational Phase: Prima releases the following pollutants during the operational activities: Dust, PM, NOx and SO2. Decommissioning Phase: fugitive dust is anticipated during this phase. However, impact assessment for this phase will be focused at separately nearing the time.

2. WATER USE Indicate the source(s) of water that will be used for the activity

municipal Directly from water board

groundwater river, stream, dam or lake

other the activity will not use water

If water is to be extracted from groundwater, river, stream, dam, lake or any other natural feature, please indicate

22

the volume that will be extracted per month: 0 liters

If Yes, please attach proof of assurance of water supply, e.g. yield of borehole, in the appropriate Appendix. N/A

Does the activity require a water use permit from the Department of Water and Sanitation? YES NO

If yes, list the permits required

The proposed development and associated infrastructures do not trigger Section 21 of NWA. Therefore, a Water Use Licence (WUL) will not be required for such activities/water uses.

If yes, have you applied for the water use permit(s)? YES NO

If yes, have you received approval(s)? (attached in appropriate appendix) YES NO

3. POWER SUPPLY Please indicate the source of power supply eg. Municipality / Eskom / Renewable energy source

Electricity to the site and for the operations is provided by the EMM. Current electricity supply is sufficient and it is not expected that additional capacity will be required in the future as the activities will remain the same.

If power supply is not available, where will power be sourced from?

Refer to above.

4. ENERGY EFFICIENCY Describe the design measures, if any, that have been taken to ensure that the activity is energy efficient:

Where possible, energy will be saved /conserved through the following measures:

Installation and improvement of power factor correction. Power factor correction reduce line currents supplied to low power factor loads.

Describe how alternative energy sources have been taken into account or been built into the design of the activity, if any:

None has been considered.

23

SECTION E: IMPACT ASSESSMENT The assessment of impacts must adhere to the minimum requirements in the EIA Regulations, 2014, and should take applicable official guidelines into account. The issues raised by interested and affected parties should also be addressed in the assessment of impacts as well as the impacts of not implementing the activity (Section 24(4)(b)(i).

1. ISSUES RAISED BY INTERESTED AND AFFECTED PARTIES Summarise the issues raised by interested and affected parties.

No issues have been raised yet regarding this proposed development. This report is a draft and subjected to public review from mid-March to Mid-April 2017. Comments and /or issues are anticipated only after such public review has taken place.

Summary of response from the practitioner to the issues raised by the interested and affected parties (including the manner in which the public comments are incorporated or why they were not included) (A full response must be provided in the Comments and Response Report that must be attached to this report):

To be completed after review of this draft report.

2. IMPACTS THAT MAY RESULT FROM THE CONSTRUCTION AND OPERATIONAL PHASE Briefly describe the methodology utilised in the rating of significance of impacts

IMPACT ASSESSMENT METHODOLOGY

The impacts will be ranked according to the methodology described below. Where possible, mitigation measures will be provided to manage impacts. In order to ensure uniformity, a standard impact assessment methodology will be utilised so that a wide range of impacts can be compared with each other. The impact assessment methodology makes provision for the assessment of impacts against the following criteria, as discussed below. Nature of the impact

Each impact should be described in terms of the features and qualities of the impact. A detailed description of the impact will allow for contextualisation of the assessment. Extent of the impact

Extent intends to assess the footprint of the impact. The larger the footprint, the higher the impact rating will be. The table below provides the descriptors and criteria for assessment. Table 2: Criteria for the assessment of the extent of the impact.

Extent Descriptor Definition Rating

Site Impact footprint remains within the boundary of the site. 1

Local Impact footprint extends beyond the boundary of the site to the adjacent surrounding areas.

2

Regional Impact footprint includes the greater surrounds and may include an entire municipal or provincial jurisdiction.

3

National The scale of the impact is applicable to the Republic of South Africa.

4

Global The impact has global implications 5

Duration of the impact

The duration of the impact is the period of time that the impact will manifest on the receiving environment. Importantly, the concept of reversibility is reflected in the duration rating. The longer the impact endures, the less likely it is to be reversible. See Table 3 for the criteria for rating duration of impacts. Table 3: Criteria for the rating of the duration of an impact.

Duration Descriptor

Definition Rating

Construction / Decommissioning phase only

The impact endures for only as long as the construction or the decommissioning period of the project activity. This implies that the impact is fully reversible.

1

Short term The impact continues to manifest for a period of between 3 and 5 years beyond construction or decommissioning. The impact is still reversible.

2

Medium term The impact continues between 6 and 15 years beyond the construction or decommissioning phase. The impact is still reversible with relevant and applicable mitigation and management actions.

3

Long term The impact continues for a period in excess of 15 years beyond construction or decommissioning. The impact is only reversible with considerable effort in implementation of rigorous mitigation actions.

4

Permanent The impact will continue indefinitely and is not reversible. 5

24

Potential intensity of the impact

The concept of the potential intensity of an impact is the acknowledgement at the outset of the project of the potential significance of the impact on the receiving environment. For example, SO2 emissions have the potential to result in significant adverse human health effects, and this potential intensity must be accommodated within the significance rating. The importance of the potential intensity must be emphasised within the rating methodology to indicate that, for an adverse impact to human health, even a limited extent and duration will still yield a significant impact. Within potential intensity, the concept of irreplaceable loss is taken into account. Irreplaceable loss may relate to losses of entire faunal or floral species at an extent greater than regional, or the permanent loss of significant environmental resources. Potential intensity provides a measure for comparing significance across different specialist assessments. This is possible by aligning specialist ratings with the potential intensity rating provided here. This allows for better integration of specialist studies into the environmental impact assessment. See Table 4 and Table 5 below. Table 4: Criteria for impact rating of potential intensity of a negative impact.

Potential Intensity Descriptor

Definition of negative impact Rating

High Significant impact to human health linked to mortality/loss of a species/endemic habitat.

16

Moderate-High Significant impact to faunal or floral populations/loss of livelihoods/individual economic loss.

8

Moderate Reduction in environmental quality/loss of habitat/loss of heritage/loss of welfare amenity

4

Moderate-Low Nuisance impact 2

Low Negative change with no associated consequences. 1

Table 5: Criteria for the impact rating of potential intensity of a positive impact.

Potential Intensity Descriptor

Definition of positive impact Rating

Moderate-High Net improvement in human welfare 8

Moderate Improved environmental quality/improved individual livelihoods. 4

Moderate-Low Economic development 2

Low Positive change with no other consequences. 1

It must be noted that there is no HIGH rating for positive impacts under potential intensity, as it must be understood that no positive spinoff of an activity can possibly raise a similar significance rating to a negative impact that affects human health or causes the irreplaceable loss of a species. Likelihood of the impact

This is the likelihood of the impact potential intensity manifesting. This is not the likelihood of the activity occurring. If an impact is unlikely to manifest then the likelihood rating will reduce the overall significance. Table 6 provides the rating methodology for likelihood. The rating for likelihood is provided in fractions in order to provide an indication of percentage probability, although it is noted that mathematical connotation cannot be implied to numbers utilised for ratings. Table 6: Criteria for the rating of the likelihood of the impact occurring

Likelihood Descriptor

Definition Rating

Improbable The possibility of the impact occurring is negligible and only under exceptional circumstances.

0.1

Unlikely The possibility of the impact occurring is low with a less than 10% chance of occurring. The impact has not occurred before.

0.2

Probable The impact has a 10% to 40% chance of occurring. Only likely to happen once in every 3 years or more.

0.5

Highly Probable It is most likely that the impact will occur and there is a 41% to 75% chance of occurrence.

0.75

Definite More than a 75% chance of occurrence. The impact will occur regularly.

1

Cumulative Impacts

Cumulative impact is reflected in the in the potential intensity of the rating system. In order to assess any impact on the environment, cumulative impacts must be considered in order to determine an accurate significance. Impacts cannot be assessed in isolation. An integrated approach requires that cumulative impacts be included in the assessment of individual impacts. The nature of the impact should be described in such a way as to detail the potential cumulative impact of the activity.

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Significance Assessment

The significance assessment assigns numbers to rate impacts in order to provide a more quantitative description of impacts for purposes of decision making. Significance is an expression of the risk of damage to the environment, should the proposed activity be authorised. To allow for impacts to be described in a quantitative manner in addition to the qualitative description given above, a rating scale of between 1 and 5 was used for each of the assessment criteria. Thus, the total value of the impact is described as the function of significance, which takes cognisance of extent, duration, potential intensity and likelihood. Impact Significance = (extent + duration + potential intensity) x likelihood Table 7 provides the resulting significance rating of the impact as defined by the equation as above. Table 7: Significance rating formulas.

Score Rating Implications for Decision-making

< 3 Low Project can be authorised with low risk of environmental degradation

3 - 9 Moderate Project can be authorised but with conditions and routine inspections. Mitigation measures must be implemented.

10 - 20 High Project can be authorised but with strict conditions and high levels of compliance and enforcement. Monitoring and mitigation are essential.

21 - 26 Fatally Flawed Project cannot be authorised

An example of how this rating scale is applied is shown below in Table 8. Table 8: Example of Rating Scale

Acti

vit

y

Natu

re o

f

Imp

act

Imp

act

typ

e

Exte

nt

Du

rati

on

Po

ten

tial

Inte

ns

ity

Lik

elih

oo

d

Rati

ng

Mit

iga

tio

n

Inte

rpre

tat

ion

SO2 emissions

Direct Impact:

Existing 3 4 16 1 23 - FLAW

With mitigation (FGD) the residual

air quality impact will

be reduced due to a

lower probability

of SO2 emission from the Power

Station.

Ambient air quality is high impact for the

area.

SO2 emissions on air quality within an area of high priority air pollution.

Cumulative 2 4 16 0,2 4 - MOD

Air quality will remain high impact with the power

station coming on-line

Residual 5 4 16 0,5 13 - HIGH

With mitigation (FGD) the residual air

quality impact will be

reduced due to a lower

probability of SO2 emission

from the Power

Station.

Notation of Impacts

In order to make the report easier to read the following notation format is used to highlight the various components of the assessment:

Extent- in italics

Duration – in underline

Potential intensity – IN CAPITALS

Likelihood - in bold

Please note that the impact rating system may change slightly to accommodate ease of use. However, the basic principle of the rating system will remain the same.

26

Briefly describe and compare the potential impacts (as appropriate), significance rating of impacts, proposed mitigation and significance rating of impacts after mitigation that are likely to occur as a result of the construction phase for the various alternatives of the proposed development. This must include an assessment of the significance of all impacts. Refer to Appendix I2 for Impact Assessment Tables. Proposal

Activity Potential impacts:

Significance rating of impacts (positive or negative):

Proposed mitigation:

Significance rating of impacts after mitigation:

Risk of the impact and mitigation not being implemented

Pre-Construction Phase

Appointment of construction contractor

Appointment of construction contractor

4 - MOD Positive

Ensure that the construction contractor utilised for the installation of equipment are predominately South Africans.

5 - MOD

There will be no improvement on the unemployment conditions in the area and livelihood of the surrounding communities.

Construction

Transportation, handling, and storage of construction materials

Additional vehicle

traffic

1 - LOW Negative

Ensure that proper road signage is used. Limit access to the construction site to construction vehicles only.

1 - LOW

Risk to the surrounding community.


Pollution from chemical

/ hydrocarbon spills

1- LOW Negative

Establish a chemical storage area that is suitably designed to contain all spills. Ensure that hydrocarbons are stored in a bunded area with a capacity of 110% of storage volume. Ensure that the bunded area is suitably designed to allow for cleaning and prevent spillage to the environment. Ensure that all vehicles, storage, and usage areas have suitable spill kits. Develop a chemical and hydrocarbon spill procedure. Ensure that chemical and hydrocarbon usage is controlled.

1 - LOW

Pollution of the water resources.


Pollution may enter

ground / surface water

1 - LOW Negative

Establish a chemical storage area that is suitably designed to contain all spills. Ensure that hydrocarbons are stored in a bunded area with a capacity of 110% of storage volume. Ensure that the bunded area is suitably designed to allow for cleaning and prevent spillage to the environment. Ensure that all vehicles, storage, and usage areas have suitable spill kits. Develop a chemical and hydrocarbon spill procedure. Ensure that chemical and hydrocarbon usage is controlled.

1 - LOW


Excavation for replacement equipment and/or footings as well as installation activities

Erosion and loss of soil resources

0 - LOW Negative

Soil stock piling to be done at the designated area.

1 - LOW

Soil erosion and pollution of water resources.

27

Proposal


Increased noise

0 - LOW Negative

Limit construction activities to daylight working hours.

1 - LOW

Exceedance of the maximum allowable noise as per the Municipal noise control bylaws.


Sedimentation, siltation, and increased turbidity in surface water in surface water

1 - LOW Negative

Soil stock piling to be done at the designated area.

1 - LOW



Pollution of soils by cement spills, litter, waste metals, hydrocarbons and chemicals

1 - LOW Negative

No servicing of vehicles onsite. Regular inspection and servicing of vehicles. Develop a spill management procedure for vehicles that may leak accidently. Have a waste management plan. Ensure that concrete spills are cleaned up. Ensure litter is cleared regularly to designated waste areas.

1 - LOW

Pollution of soil and consequently water resources.

Installation of the proposed equipment

Uncontrolled activities may lead to fires

1 - LOW Negative

Undertake monitoring to determine if fires have any impact on the surrounding environment, suitable rehabilitation is to be undertaken where necessary. .A fire management plan to be established prior to construction commencing. Any materials that are likely to catch fire must be removed in areas where welding is undertaken to prevent fires from occurring. Fire breaks along the servitude are to be established. Suitable firefighting equipment and training is to be provided.

0 - LOW

Health and safety risks to the surrounding areas.

Fugitive dust emissions

Fugitive dust concentrations resulting in the degradation of the ambient air quality and creating a nuisance.

3 - MOD Negative

Minimising dust emissions with the use of water sprays or a dust binder (when necessary). Avoid the use of unpaved roads where possible.

0 - LOW Health risk.

Operational

Particulate matter emissions

Particulate matter emissions concentrations resulting in the degradation of the ambient air quality.

7 - MOD Negative

Ensuring all equipment is well maintained and in good working order; ensuring equipment and vehicles are switched off when not in use; and avoiding the use of unpaved roads (where possible).

0 - LOW

Health risks.

Particulate matter emissions

Ambient PM concentrations resulting from Prima's emissions with the potential to affect human health at an identified receptor location.

4 - MOD Negative

Ensuring all equipment is well maintained and in good working order; ensuring equipment and vehicles are switched off when not in use; and avoiding the use of unpaved roads (where possible).

0 - LOW

Health risks.

Sulphur dioxide emissions

SO2 emissions concentrations resulting in the degradation of the ambient air quality.

1- LOW Negative

Ensuring all equipment is well maintained and in good working order and ensuring equipment and vehicles are switched off when not in use.

0- LOW

Health risks.

28

Proposal

Sulphur dioxide emissions

Ambient SO2 concentrations resulting from Prima's emissions with the potential to affect human health at an identified receptor location.

1- LOW Negative


0- LOW

Health risks

Oxides of nitrogen emissions

NO2 emissions concentrations resulting in the degradation of the ambient air quality.

1- LOW Negative


0- LOW

Health risks.

Oxides of nitrogen emissions

Ambient NO2 concentrations resulting from Prima's emissions with the potential to affect human health at an identified receptor location.

1- LOW Negative


0- LOW

Health risks.

Inspection and maintenance of the proposed upgrade equipment.

Pollution from litter, waste metals, vehicle spills / hydrocarbon spills during maintenance activities.

1- LOW Negative

Ensure that a site clean-up is undertaken at the end of every maintenance cycle to ensure that no pollution has occurred. Where this has happened, appropriate remedial action is to be taken.

1- LOW

Pollution and mismanagement of soil, waste and water resources.

Alternative 1 (Not applicable)






No Go






Activities for the current operations to remain the same.

Negative Environmental impacts will remain the same as for the current operations.

6 - MOD Negative

Authorise and implement the proposed upgrade activities.

6 - MOD

No opportunity for contributing to the local economic development, improvement on livelihood of the local communities and improvement on the environmental quality of the area.

Project does not proceed.

No opportunity for contributing to the local economic development, for Prima to meet their consumer's demand and improvement on livelihood of the local communities.

9 - MOD Negative

6 - MOD No opportunity for contributing to the local economic development. Prima will have to cancel significant number of orders (~75%) and

29

Proposal

consequently retrench up to 65 employs instead of creating about 20 new jobs over the next two (2) years.

List any specialist reports that were used to fill in the above tables. Such reports are to be attached in the appropriate Appendix.

Air Quality Impact Assessment (AQIA) Specialist Report attached as Appendix G has been considered for the proposed project.

Describe any gaps in knowledge or assumptions made in the assessment of the environment and the impacts associated with the proposed development.

No gaps have been identified during the assessment of this proposed upgrade.

3. IMPACTS THAT MAY RESULT FROM THE DECOMISSIONING AND CLOSURE PHASE Briefly describe and compare the potential impacts (as appropriate), significance rating of impacts, proposed mitigation and significance rating of impacts after mitigation that are likely to occur as a result of the decommissioning and closure phase for the various alternatives of the proposed development. This must include an assessment of the significance of all impacts. Proposal


6 Proposed mitigation:



Fugitive dust emissions

Fugitive dust concentrations resulting in the degradation of the ambient air quality and creating a nuisance.

6- MOD Negative

Dust suppression should be done where possible. Avoid the use of unpaved roads where possible.

0- LOW

Health risks.

Further impacts associated with the decommissioning phase will be identified and assessed nearing the closure of Prima operations.













List any specialist reports that were used to fill in the above tables. Such reports are to be attached in the appropriate Appendix.

The decommissioning phase is not envisioned in the near future. As a result, impact assessments for the decommissioning activities are not considered in this assessment.

Where applicable indicate the detailed financial provisions for rehabilitation, closure and ongoing post decommissioning management for the negative environmental impacts.

N/A

30

4. CUMULATIVE IMPACTS Describe potential impacts that, on their own may not be significant, but is significant when added to the impact of other activities or existing impacts in the environment. Substantiate response:

Cumulative impacts are envisaged on the environment. The impact of the emissions on ambient air quality may be significant although localised. Prima’s emissions will have a cumulative impact on the already degraded airshed. Prima is located within the Highveld Priority Area, synonymous with poor air quality as a result of the high concentration of industry, mining, power generation and other non-industrial sources (Held et. al. 1996 and DEAT, 2006). It is expected that air quality will be poorer during the winter months as a result of temperature inversions common over the region and the cumulative effects of pollution caused by the burning of coal and wood in households, and from veld fires common in winter. However, with the proper implementation of the mitigation measures, cumulative air quality impacts to the environment will be reduced.

5. ENVIRONMENTAL IMPACT STATEMENT Taking the assessment of potential impacts into account, please provide an environmental impact statement that sums up the impact that the proposal and its alternatives may have on the environment after the management and mitigation of impacts have been taken into account with specific reference to types of impact, duration of impacts, likelihood of potential impacts actually occurring and the significance of impacts. Proposal

No Site Alternatives were identified as the proposed development has been identified as a project specific. The site is already degraded due to current land use in the area, i.e. industrial activities. In addition, the proposed development is located within the current Prima’s operational site. There are NO watercourses and wetlands located within 500m of the proposed activity location. Furthermore, NO culturally significance elements have been observed within the close proximity of the proposed activity location. The proposed upgrade is located in a highly degraded and fragmented industrial area, with no ecological integrity and functioning, and being situated in an industrial area, it is anticipated that degradation of the site will continue over time. The site does not comprise of any flora and fauna habitat due to existing operations on site. Moreover, considering the disturbed nature of the site, it is highly unlikely that any species of conservation concern (i.e. Red List/protected species) will exist on site. Construction Phase: The construction activities will predominantly have a LOW negative impact on the receiving environment prior to the implementation of mitigation measures. The main reason for rating construction activities with MODERATE to LOW is that the project area has been severely degraded due to current industrial activities in the area. The elements of the environment most affected will be the on-site soils, the social environment (traffic and particulate emissions) and potentially surface groundwater. However, majority of the above-mentioned impacts already exist on site as a result of existing Prima activities. The impacts will be predominantly limited to the site and study area. The impacts will also act for the time of construction phase, which is approximately four (4) months. All of the impacts identified during the construction phase can be mitigated to acceptable limits and the majority of the impacts showed a LOW significance before and after mitigation measures are implemented. Construction for the proposed upgrade is therefore not likely to significantly impact on the already degraded land. Operational Phase: Impacts identified for the operational phase of the proposed upgrade are largely rated as MODERATE to LOW negative impact on the receiving environment. The elements of the environment most affected will be the soils particularly during maintenance of the proposed upgrade, the social and receiving environment (health risk due to air emissions from Prima’s activities or change in air quality) and potentially surface and groundwater (spillage during equipment maintenance). Emission to the atmosphere is not anticipated to make a vast difference to the current emissions as a result of the current operations on site. Noise impacts will be predominantly limited to the site. Air emissions and dust will be felt as wide as the local area. The impacts associated with the operation of the Prima will occur for as long as the infrastructure is operational and is thus deemed to be in the Long term. All impacts incurred can be reversed with time during the decommissioning phase, and none of the operation phase impacts are permanent. As part of the mitigation measures, monitoring and all measures recommended in the in the EMPr attached hereto as Appendix H should be adhered to. Decommissioning Phase: It is not envisaged that the proposed upgrade and activities will be decommissioned as it provides economic opportunities to the surrounding communities. Decommissioning phase activities associated with the decommissioning of the Prima will involve the reversal of the construction phase plant and structures. The end result of the decommissioning phase will be a positive impact on the environment. However, during the decommissioning phase similar nuisance impacts such as noise, traffic, particulate emissions will be experienced. These too can be mitigated. Overall, the impact of the proposed activity is expected to be LOW as the study site is already heavily impacted by the surrounding activities and land use. The activities will further be mitigated to acceptable levels.

Alternative 1

Not applicable.

31

Alternative 2

Not applicable.

No-go (compulsory)

The ‘No-Go’ alternative refers to not implementing any of the proposed project activities described in this report. The option of not proceeding with the proposed project will result in the continuation of the status quo and denied opportunity for Prima to contribute to the local economic development as well as changes to the local communities in terms of employment (both temporary and permanent). All impacts on the receiving environment that is likely to occur as a result of the proposed upgrade at Prima will not transpire. In terms of the environmental impacts, the current environmental status quo will remain the same. Impacts associated with the No-Go alternative are thus rated as HIGH.

6. IMPACT SUMMARY OF THE PROPOSAL OR PREFERRED ALTERNATIVE For proposal:

The impacts have been identified and assessed during the BA process. Based on the impact assessment, impacts will be predominantly limited to the site and study area. The impacts which will act for the time of construction phase, which will be approximately four (4). Impact to act for the time of operational phase will be for an unforeseeable future All of the impacts identified during the construction and operational phase can be mitigated to acceptable limits and the majority of the impacts showed a LOW significance before and after mitigation measures are implemented. The proposed upgrade at Prima is therefore not likely to significantly impact on the already degraded land. For alternative:

Not applicable. Having assessed the significance of impacts of the proposal and alternative(s), please provide an overall summary and reasons for selecting the proposal or preferred alternative.

The development contributes to addressing the current needs of Prima’s products consumers

The proposed upgrade is located within the existing Prima operations, which have been for over many years fixed within an area currently zoned as Industrial. Prima’s products are in high demand and are supplied to both local and international consumers. As a result, Prima is a great contributor to the local economy and consequently to the South African economy. The proposed activity (upgrade) is sought to address the high demands (in the forms of quotations made to Prima recently) from both local and international consumers. Therefore, considering an alternative activity has not been considered a viable alternative.

Due to the nature of the project, i.e. refurbishment of an old sand reclaiming plant for the installation and operation of the new Silica Sand Plant including a stack, installation and operation of a new silica shot blast unit, including a new stack, refurbishment of installation of an existing stack on the shake-out within Prima property, no site alternatives were considered. Prima is existing and currently operational. Therefore, the proposed work is for expanding the existing operations. The proposed upgrade will occur where the old sand reclaiming plant requiring replacements as well as existing shake-out unit are located.

An Environmental Assessment Practitioner (EAP) considered the exclusion of site alternatives for the following reasons:

The proposed project will take place within Prima properties and existing operations;

The proposed project will occur within an industrial area and on an already impacted area instead of impacting a completely new footprint;

Prima’s current operation has for over many years fixed the location for their operations including the sand reclaiming plant and shake-out unit. Consequently, the problem is area specific and therefore, there cannot be an alternative site; and

In addition, no environmental sensitivities and/or fatal flaws were identified on site that would prevent the use of the existing operational site for the proposed upgrade activities.

The site is currently heavily impacted and transformed

The proposed upgrade will occur at an existing Prima facility within existing old building structures located at Nestadt Industrial Sites in Benoni South. The area is heavily impacted and transformed due to industrial activities on site and the surrounding. No environmental sensitivities exist on the proposed site

There are NO watercourses and wetlands located within 500m of the proposed activity location. Furthermore, NO culturally significance elements have been observed within the close proximity of the proposed activity location.

The proposed upgrade is located in a highly degraded and fragmented industrial area, with no ecological integrity and functioning, and being situated in an industrial area, it is anticipated that degradation of the site will continue over time. The site does not comprise of any flora and fauna habitat due to existing operations on site. Moreover, considering the disturbed nature of the site, it is highly unlikely that any species of conservation concern (i.e. Red List/protected species) will exist on site.

32

7. SPATIAL DEVELOPMENT TOOLS Indicate the application of any spatial development tool protocols on the proposed development and the outcome thereof.

Use of GIS tool for mapping (using data from GDARD such as EMF, GAPA and GIDSv10, and other data), refer to attached maps in Appendix A.

8. RECOMMENDATION OF THE PRACTITIONER

Is the information contained in this report and the documentation attached hereto sufficient to make a decision in respect of the activity applied for (in the view of the Environmental Assessment Practitioner as bound by professional ethical standards and the code of conduct of EAPASA).

YES NO

If “NO”, indicate the aspects that require further assessment before a decision can be made (list the aspects that require further assessment):

Not applicable.

If “YES”, please list any recommended conditions, including mitigation measures that should be considered for inclusion in any authorisation that may be granted by the competent authority in respect of the application:

The EAP recommends that the proposed upgrade at Prima be authorised at the proposed location. All mitigation measures listed by the Air Quality specialist in their specialist report, and proposed in the Environmental Management Programme (EMPr) must be implemented.

9. THE NEEDS AND DESIRABILITY OF THE PROPOSED DEVELOPMENT

(AS PER NOTICE 792 OF 2012, OR THE UPDATED VERSION OF THIS GUIDELINE) The existing facility operates as a foundry, melting scrap metal and ferro-alloys for its products which are then sold. Prima plays an important role in the recycling of materials. The recycling of scrap materials is very important, since the residues of this material can be reused without any loss of quality. However, there are environmental concerns associated to the process regarding greenhouse gases and spent foundry sand with heavy trace metals. In addition to this, foundry processes are energy-intensive. In comparison to primary aluminum production, the secondary process (the recovery of aluminum from scrap to produce secondary aluminum ingot) consumes significantly less energy (about 5-10% of the energy required to produce primary aluminum), reducing environmental damage from electricity production as well as from raw materials extraction and processing. This significant energy difference is particularly important in the current South African context and forms part of the emphasis on the importance of recycling in today’s society and in the foundry industry. Furthermore, fluorocarbon gases are not produced with secondary smelting. The principal greenhouse gas is carbon and because of the lower energy consumption, very much less pollution is emitted to the atmosphere than that produced in primary smelting. Moreover, the secondary process generates between five to nine times less solid wastes and consumes much less water (OECD, 2010). The overarching environmental benefit is that Prima diverts a potentially large waste stream (scrap metals) from already capacity-constrained landfills. Recycling the scrap materials also aids in a large reduction of the energy requirements as compared to primary steel and/or metal producers and there are significantly fewer emissions into the atmosphere as opposed to primary producers. Scrap and ferro-alloys is recycled to produce various products that can then be considered as commodities. The recycling of scrap metals makes sense from both an economic and environmental perspective. Prima provides employment for approximately 300 staff on site. The operation also attracts financial investment into the local municipality. Spin-off industries from the operation also contribute to positive socio-economic growth. Prima employs and provides long-term job security for about 300 staff members. On-site training and skills development takes place. The proposed upgrade will enable Prima to meet their supply target. It this proposed upgrade is not implemented, Prima will not meet their supply targets resulting from numerous requests to supply both local and international and will therefore have to cancel the orders. Cancellation of orders will be felt both nationally and locally as Prima is one of the great contributors to the local and national economy. In return, jobs will be lost for up to 45 employees as Prima will then have to retrench people. Prima’s products are in high demand and are supplied to both local and international consumers. Thus, Prima is a great contributor to the local economy and consequently to the South African economy. The proposed activity (upgrade) is sought to address the high demands (in the forms of quotations made to Prima recently) from both local and international consumers. Therefore, the proposed development will see an increase in the economic activities of the area as well as improve employment opportunities that will accrue largely to previously disadvantaged people.

10. THE PERIOD FOR WHICH THE ENVIRONMENTAL AUTHORISATION IS REQUIRED

(CONSIDER WHEN THE ACITIVTY IS EXPECTED TO BE CONCLUDED)

The environmental authorisation is required for the duration of both the construction and operation of Prima. Prima will continue to be operational for an unforeseeable future and therefore, the definite period for Prima’s operation is not known at this stage.

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11. ENVIRONMENTAL MANAGEMENT PROGRAMME (EMPR) (MUST INCLUDE POST CONSTRUCTION MONITORING REQUIREMENTS AND WHEN THESE WILL BE CONCLUDED.) If the EAP answers “Yes” to Point 7 above then an EMP is to be attached to this report as an Appendix

EMPr attached YES

Refer to Appendix H for the EMPr.

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SECTION F: APPENDIXES The following appendixes must be attached as appropriate (this list is inclusive, but not exhaustive): It is required that if more than one item is enclosed that a table of contents is included in the appendix

Appendix A: Site plan(s) – (must include a scaled layout plan of the proposed activities overlain on the site sensitivities indicating areas to be avoided including buffers)

Appendix A1 – Layout Map Appendix A2 – Locality Map Appendix A3 – Sensitivity Map Appendix A4 – Topography Map Appendix A5 – Geology Map Appendix A6 – Soil Map Appendix A7 – Agriculture Map Appendix A8 – Land cover Map Appendix A9 – Vegetation Types Map Appendix A10 – Vegetation Conservation Status Map

Appendix B: Photographs Appendix C: Facility illustration(s) Appendix D: Route position information

NOT APPLICABLE.

Appendix E: Public participation information

To be compiled after a 30-day review period.

Appendix F: Water use license(s) authorisation, SAHRA information, service letters from municipalities,

water supply information

NOT APPLICABLE.

Appendix G: Specialist reports

Appendix G – Air Quality Impact Assessment Specialist

Appendix H: EMPr Appendix I: Other information

Appendix I1 – Existing Waste Management Licence Appendix I2 – Impact Assessment Tables

CHECKLIST To ensure that all information that the Department needs to be able to process this application, please check that:

X Where requested, supporting documentation has been attached;

X All relevant sections of the form have been completed.

17 March 2017 35 16111

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ZITHOLELE CONSULTING (PTY) LTD Virginia Ramakuwela Sharon Meyer Project Manager Project Associate Z:\PROJECTS\16111- PRIMA BA & AEL\4 REPORTS\46 ENVIRONMENTAL\001 DBAR\16111-46-REP-001-PRIMA DBAR-REV0.DOC

Documents

Basic Assessment for the Prima Industrial Holdings ... · Reg. No. 2000/000392/07 PO Box 6002 Halfway House 1685, South Africa Building 1, Maxwell Office Park, Magwa Crescent West