Environmental Impact Assessment

Integrated Environmental Authorisation (Environmental Impact Assessment, Water Use License and Waste Management License Applications) for the Proposed 60 Year Ash Disposal Facility and associated infrastructure at Kusile Power Station (DEA Ref No 12/12/20/2412 (NEAS Reference: DEA/EIA/0000514/2011)

Comments and Responses Report Version 4

The Comments and Responses Report (CRR) captures the comments and issues raised by stakeholders during the Announcement, Scoping and Impact Assessment Phase of the Environmental Impact Assessment (EIA) and Water Use License Application processes for the proposed Continuation of Ash Disposal at Kendal Power Station, Mpumalanga Province.

This CRR is a record of all the comments and issues raised by Stakeholders ranging across all sectors of society during the abovementioned public participation process of the EIA. A full record of issues raised is included in Appendices F2 of the FEIR.

For easy reference, comments / issues received have been categorised according to environmental impacts and according to the Stakeholders’ surnames to assist Stakeholders in their verification process that their comment(s) / concern(s) / issues(s) have been properly addressed. Comments and Responses Report (Version 4) i 12712

ACRONYMS:

NEMA National Environmental Management Act SAHRA South African Heritage Resources agency

ABBREVIATIONS:

ADF Ash Disposal Facility CRR: Comments and Responses Report

DEIR Draft Environmental Impact Assessment Report DSR Draft Scoping Report

DWS Department of Water & Sanitation EIA Environmental Impact Assessment

EMPr Environmental Management Programme FGM Focus Group Meeting

HIA Heritage Impact Assessment PPP Public Participation Practitioner

MHI Major Hazard Installation MTPA Mpumalanga Tourism & Parks Agency

NHRA National Heritage Resources Act PS Power Station

TPSA TOPIGS SA (Pty) Ltd ZC Zitholele Consulting

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TABLE OF CONTENTS

1 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT: COMMENTS RECEIVED DURING THE REVIEW PERIOD (TUESDAY 29 JULY TO MONDAY 08 SEPTEMBER 2014) ...... 1

1.1 Authorities Comments...... 1

1.1.1 Water (wetland/ground water & surface water) Related Comments ...... 1 1.1.2 Ash By-products Comments ...... 4 1.1.3 Kusile Power Station’s existing Ash Disposal Facility Comments ...... 4 1.1.4 EIA Process Related Comments ...... 5 1.1.5 Site A Related Comments ...... 5 1.1.6 Biodiversity Related Comments ...... 6 1.1.7 Visual Related Comments ...... 6 1.1.8 Heritage Related Comments ...... 6 1.1.9 Social and Socio-economic Related Comments ...... 6 1.1.10 Monitoring / EMPr Related Comments ...... 6 1.1.11 Communication Related Comments ...... 7 1.2 Stakeholders’ Comments ...... 7

1.2.1 Water (wetland/ground water & surface water) Related Comments ...... 7 1.2.2 Air Quality Related Comments ...... 9 1.2.3 Ash Disposal Facility (Proposed) Related Comments ...... 11 1.2.4 Conveyor Belt Infrastructure (Proposed) Related Comment ...... 12 1.2.5 Tourism Related Comment ...... 12

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1.2.6 Site Alternatives Related Comments ...... 14 1.2.7 Social and Socio-Economic Related Comments ...... 15 1.2.8 Kusile Power Station Related Comments ...... 16 1.2.9 Communication Related Comments ...... 16 1.2.10 General Comments ...... 18

2 IMPACT PHASE PROCESS COMMENTS ...... 21

2.1 EIA Process Related Comments ...... 21

2.2 Site Alternatives Related Comments ...... 26

2.3 Social and Socio-economic Related Comments...... 35

2.4 Water Related Comments ...... 39

2.5 Agricultural Related Comments ...... 57

2.6 Cumulative Impacts Related Comments ...... 57

2.7 Specialist Studies Comments ...... 60

2.8 Mining Right Related Comment ...... 61

2.9 GIS / Maps Related Comments / Requests ...... 62

2.10 Kusile Power Station Related Comments...... 62

2.11 Communication / Consultation Comments ...... 65

2.12 General Comments ...... 69

3 SCOPING PHASE PROCESS COMMENTS ...... 87

3.1 Draft and Final Scoping Report Comments ...... 87

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3.1.1 Site Alternatives Comments ...... 91 3.1.2 Technical Comments ...... 96 3.1.3 Water Comments ...... 103 3.1.4 Pollution (Dust, Fly ash, Air) Comments ...... 113 3.1.5 Noise Comments ...... 129 3.1.6 Agriculture Comments ...... 129 3.1.7 Compensation Comments ...... 140 3.1.8 Social Comments ...... 140 3.1.9 Communication Comments ...... 144 3.1.10 General Comments ...... 146

4 EIA FOR KUSILE POWER STATION AND TEN YEAR ASH DISPOSAL FACILITY COMMENTS ...... 146

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1 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT: COMMENTS RECEIVED DURING THE REVIEW PERIOD (TUESDAY 29 JULY TO MONDAY 08 SEPTEMBER 2014)

NO. COMMENTS, QUESTIONS AND ISSUES COMMENTATOR(S) SOURCE(S) RESPONSE(S)

1.1 Authorities Comments

1.1.1 Water (wetland/ground water & surface water) Related Comments

1 Large A1 descriptive Master Layout Plan to scale be submitted HLONGWANE, DG Letter: 21 October A large A1 descriptive Master Layout Plan will of all infrastructure, watercourses, diversions, circulation, DWS 2014 be developed and submitted with the watercourse crossing. Integrated Water Use Licence Application (IWULA) to the department for consideration. Mathys Vosloo, EAP 2 Detail Rehabilitation Plan to be drawn up and submitted that will A detailed rehabilitation plan will be developed inter alia include all wetlands and rivers impacted upon up to the and submitted with the IWULA to the confluence with the Wilge River. Degraded river and wetland department for consideration. sections must be rehabilitated up to the confluence. Mathys Vosloo, EAP 3 Plant Species Plans must be drawn up by a landscape architect, Plant Species Plans will be drawn up by the river ecologist, botanist, wetland specialist or combination of relevant specialist for the Holfonteinspruit and them for the Holfoteinspruit River and Klipfonteinspruit Rive and Klipfonteinspruit and will be submitted to the associated wetlands up to the confluence of the Wilge River.r department for consideration. Mathys Vosloo, EAP 4 Water lost to these rivers and wetlands because of the ash A detailed surface water – groundwater dump and New Largo cone of depression impacts must be interaction study will be undertaken during the modelled and Recharge Plans and Programmes be submitted to IWULA, which will shed light in the potential the Provincial Head for approval. Water lost to the system must losses to the surface water and groundwater be sourced elsewhere and discharge again to maintain the systems. Detailed recharge plans will also be ecological class of rivers and wetlands. Details to be provided. developed to ensure rivers and wetlands Water of an acceptable aquatic quality must be discharged. maintain their ecological class. Designs of discharge points to be detailed as bio retention Mathys Vosloo, EAP wetland ponds. Dirty water from the filter drains below the ash dump must be treated to an acceptable quality before discharge. Water from the drains must be measured. 5 Clean water drains and diversions to be constructed as natural Designs for clean water drains and diversion as possible to resemble natural streams. canals will be provided with the IWULA to the department. Mathys Vosloo, EAP

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6 Ash facility leachate protection system must be detailed and Concept designs for the leachate detection submitted. Leak detection system to be implemented and system are included with the Environmental submitted for approval. Impact Assessment (EIA) for the 60 year ash disposal facility (ADF). Detailed designs for the leachate detection and protection system will be provided to the department with the WULA. Mathys Vosloo, EAP 7 Lining must be detailed and submitted for approval to Civil and The lining system detail was presented to Designs of DWS component. Kelvin Legge from the DWS and was approved in principle. Detailed designs for the lining system will be included in the IWULA to the department for approval. Mathys Vosloo, EAP 8 Water losses from subsurface flows must be modelled. Water losses from the subsurface flows will be modelled in detail during the IWULA. Mathys Vosloo, EAP 9 Ecological management class of rivers and wetlands must stay Management measures to mitigate impacts on the same before and after. water courses outside the footprint of the proposed ADF on Site A have been proposed in the EIA for the 60 year ADF. Detailed rehabilitation and monitoring plans will be included in the IWULA for downstream water courses and wetlands identified in the wetland offset plan. Mathys Vosloo, EAP 10 Dust and noise must be controlled sufficiently. Mitigation measures to control dust and noise have been included in the Final Environmental Impact Report (FEIR) and Environmental Management Programme (EMPr), and shall be strictly monitored for compliance throughout the life of the power station. Mathys Vosloo, EAP 11 Diversions must be made as natural as possible via the use of Diversions will be designed to mimic the shaping to 1:3 or flatter, use of rock, rock mattresses, topsoil natural setting of a water course as far and vegetation. possible. Designs for the diversions will be included in the IWULA. Mathys Vosloo, EAP 12 Rehabilitation of side slopes of ash facility must be concurrent Concurrent rehabilitation of the ADF as the with development of facility and not steeper than 1:3. Slide disposal facility develops has been adopted in slopes must be protected against erosion, topsoil and be the development philosophy for the ash

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revegetated. disposal facility, and has been detailed as such in the FEIR. Mathys Vosloo, EAP 13 Topsoil must be stored correctly. Management measures for topsoil are discussed in the EMPr that will accompany the FEIR to the department for consideration. Mathys Vosloo, EAP 14 Rehabilitation team and equipment must be detailed. The rehabilitation team and equipment to be used will be stipulated in the IWULA to be submitted to the department. Mathys Vosloo, EAP 15 Surrounding seeds must be harvested as part of rehabilitation. The IWULA will stipulate the harvesting of seeds in the detailed rehabilitation plan. Mathys Vosloo, EAP 16 Water quality and Bio-monitoring must be ongoing. Plan and Commencement or continuation of the water program to be detailed. quality and bio-monitoring at the proposed ADF site and Kusile at large has been recommended in the FEIR and EMPr. Mathys Vosloo, EAP 17 Storm water management plan to be detailed. A detailed storm water management plan will be developed and included in the IWULA to be submitted to the department for consideration. Mathys Vosloo, EAP 18 Water sources and water balance to be detailed. A detailed Water and Salt Balance, and Integrated Waste And Water Management Plan (IWWMP) will be developed during the IWULA for consideration by the department. Mathys Vosloo, EAP 19 Waste and sewer management plan to be detailed and A detailed IWWMP will be developed during submitted. the IWULA for consideration by the department. Mathys Vosloo, EAP 20 Site A option is recommended for further optimisation. Zitholele Consulting acknowledges the department’s conclusion that Site A is recommended for further optimisation. Mathys Vosloo, EAP 21 Has the IWULA been authorised yet? NGCEBETSHA, KSW: 20 August The process is lagging behind but that Anele 2014 extensive consultation has taken place with the Ngankala District Department of Water and Sanitation (DWS) Municipality during the scoping phase of the EIA process.

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Towards this consultation process, a workshop was held earlier this year with both the Department of Environmental Affairs (DEA) and the DWS. Mathys Vosloo, EAP 22 It was mentioned that it seems that Site A is full of wetlands. The Klipfontein Spruit and Holfontein Spruit are present on Site A which meets and end up in the Wilge River, and that is the only disadvantage about Site A (from a wetland perspective). Mathys Vosloo, EAP 23 Will there be any offsets done? Discussions are being held with the DWS regarding offsets. In the EIR, some principles to be observed in development of the offsets strategy are provided. Mathys Vosloo, EAP 24 Who will be taking the samples on site since there is an issue Various consulting firms monitor the with leakages as per some comments from the public? groundwater, surface water, wetlands and air quality. Tobile Bokwe, Eskom

1.1.2 Ash By-products Comments 1 What is the difference between ash and gypsum? NGCEBETSHA, KWS: 20 August Ash is a combination of different elements and Anele, Nkangala 2014 gypsum is the by-product that will be produced District Municipality from the Flue Gas Desulphurisation process to be used as air quality abatement technology at Kusile coal fired power station. Mathys Vosloo, EAP

1.1.3 Kusile Power Station’s existing Ash Disposal Facility Comments 1 Is the 10 year (10y) ash disposal facility (ADF) currently being NGCEBETSHA, KWS: 20 August The process is lagging behind but that used? Anele, Nkangala 2014 extensive consultation has taken place with District Municipality the Department of Water and Sanitation (DWS) during the scoping phase of the EIA process. A workshop was held earlier this year with both the Department of Environmental Affairs (DEA) and the DWS. Mathys Vosloo, EAP

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1.1.4 EIA Process Related Comments 2 Has the case officer been on the site visit? NGCEBETSHA, KWS: 20 August The case officer, Masina Litsuane (DEA), did Anele, Nkangala 2014 undertake a site visit. District Municipality Mathys Vosloo, EAP 3 Everything always looks good on paper, the Report has been Eskom will have to comply with the conditions done and the recommendations are made but what measures set out in the EA. If not, non-compliance by are in place to ensure that Eskom complies with the conditions Eskom can be reported to the DEA and should stipulated in the EA and licenses? the investigation prove that Eskom has not complied to the conditions, Eskom can receive a heavy fine. Mathys Vosloo, EAP

There is a clause in the license to say that if the license holder doesn’t comply to any of the conditions, the non-compliance must be reported to the DEA within 24 hours. There will also be an Environmental Control Officer (ECO) on site to monitor activities and make sure that license conditions are adhered to. The only assurance that the public has that Eskom is compliant is to request Reports that are compiled by Eskom on their various monitoring activities. The Reports are drafted either monthly or quarterly, as required by the EA. Tobile Bokwe, Eskom

1.1.5 Site A Related Comments 1 Are there any activities happening on site A such as farming and NGCEBETSHA, KWS: 20 August There is agricultural activity currently taking will the ADF impact on the crop productivity when the ADF is Anele, Nkangala 2014 place on site A and that there are some operational? District Municipality portions of the land that will be lost to the ashing activity. It was mentioned that the property within which site A is located is entirely owned by Eskom. Site A has more wetlands than the other sites. Mathys Vosloo, EAP

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1.1.6 Biodiversity Related Comments 1 Do you have a relocation plan for biodiversity? NGCEBETSHA, KSW: 20 August That it is not done yet. It will be included in the Anele, Nkangala 2014 EA conditions as a post-authorisation District Municipality condition. Mathys Vosloo, EAP 2 Do some of the species need a permit and has this been taken This will be done post-authorisation where that into consideration. required. Mathys Vosloo, EAP

1.1.7 Visual Related Comments 1 Will landscaping / screening be done in such a manner that the NGCEBETSHA, KSW: 20 August The design will be done to minimise visual facility does not stand out? Anele, Nkangala 2014 impact i.e. shaping the ADF that it blends in as District Municipality naturally as possible into the surrounding landscape. Mathys Vosloo, EAP

1.1.8 Heritage Related Comments 1 How long does SAHRA (South African Heritage Resource NGCEBETSHA, KSW: 20 August The exact timeframes are not known but the Agent) take to issue a permit to relocate any graves that may Anele, Nkangala 2014 required process as set out by SAHRA was need to be relocated? District Municipality followed. Mathys Vosloo, EAP

1.1.9 Social and Socio-economic Related Comments 1 Will there be any relocation of people from Site A? NGCEBETSHA, KSW: 20 August There are no occupants that required Anele, Nkangala 2014 relocation as the farm is rented from Eskom. District Municipality Mathys Vosloo, EAP

1.1.10 Monitoring / EMPr Related Comments 1 How do you make sure that all the recommendations are NGCEBETSHA, KWS: 20 August This will be the responsibility of the appointed adhered to during construction? Anele, Nkangala 2014 independent ECO. District Municipality Mathys Vosloo, EAP 2 As a suggestion there should be a quarterly environmental forum Currently Kusile Power Station has an EMC where the public can get feedback on activities during (Environmental Management Committee) construction and operations of ADF. She enquired as to what forum which compromises of general public, happens with complaints received and whether these complaints landowners and stakeholders that are around are just put in the report as a suggestion? the Power Station. During these meetings complaints are captured and given to the correct people / department to address the

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issues. Tobile Bokwe, Eskom

1.1.11 Communication Related Comments

1 Please note that my office do not comment on Draft EIA/BA MOOLMAN, Ms E-mail: 15 August Acknowledges DWS’s information provided. Reports. It is the DWS Regional Office who comments on the Wilna 2014 Zitholele Consulting can confirm that the DEIR Report. My office are just doing RoD’s in terms of the Waste Act Resource Protection has been delivered, for written comments, to and just on request from DEA or the Provincial Departments. and Waste Source Mr Dumisane: DWS Mpumalanga Regional Co-ordination Office, Bronkhorstspruit. Refer to Appendix F2. DWS Nicolene Venter, PPP 2 As per the Report it is noted that SANBI is being consulted. NGCEBETSHA, KWS: 20 August Eskom, together with DWS, approached Anele, Nkangala 2014 SANBI to assist with the framework for the District Municipality offset plan. This consultation will be on going throughout the WULA process. Mathys Vosloo, EAP

1.2 Stakeholders’ Comments

1.2.1 Water (wetland/ground water & surface water) Related Comments

1 What is going to happen to the surrounding wetlands? CHERRY, Andre, DEIR Focus Group The ash disposal facility (ADF) is designed in Landowner Meeting, 20 August such a way that any run-off water will be 2014 channelled to holding dams from where it will be released back into the surrounding wetland systems. Mathys Vosloo, EAP

Post-meeting noteNote: As part of the mitigation and rehabilitation strategy for the Kusile ADF, surrounding wetlands will be rehabilitated and monitored for signs of impact, while a comprehensive offset strategy will be put in place to offset the loss of wetlands within the ADF footprint. Mathys Vosloo, EAP 2 Why should Eskom take the risk to build the ash disposal facility MAKHUBELO, PM: 20 August The system that will be built is known as a as it will contaminate the water at some point? Nomcebo, 2014 closed system, which means zero impact Mpumalanga Youth outside the footprint of the ash facility. From Against Climate a technical point of view all coal fired Change (MYACC) power stations generate ash and the ash

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needs to be deposited somewhere. If there is no ash disposal facility then the power station will need to shut down. Leon Stapelberg, Kusile Power Station 3 Is concerned about the water that will be used and asked NGWENYA, Lydia, PM: 20 August Water will not be used from the Wilge River for whether the Wilge River will be able to supply the quantity of Guqa Community 2014 the proposed project. Water will be obtained water required as there is already a shortage of water in Phola. Environmental from the water pipeline from Kendal Power Service Station that is currently supplying Kusile Power Station with water. Mathys Vosloo, EAP

Mr Leon Stapelberg added to Dr Vosloo’s response that water will be supplied to Kusile Power Station from Kendal Power Station, and this water pipeline forms part of the Vaal Scheme. The water supply to Phola is not being supplied from this water pipeline, but from eMalahleni Local Municipality and Phola would therefore not be impacted by the proposed project regarding water supply. Leon Stapelberg, Kusile Power Station 4 Does Eskom recycle the water for the community? The engineers designed the facility in such a way that the dirty water is caught in the ash/waste water return dam, which is then recycled to be used for the dust suppression. Mathys Vosloo, EAP 5 Concern regarding the possible negative impact this will have on In terms of the air quality assessment done the community especially those that use land close to Kusile and the mitigation measures as proposed in Power Station for growing crop as dust will settle on the crops the EMPr will be sufficient to address the that will be harvested by the farmers. How will this impact be negative impact. mitigated? Mathys Vosloo, EAP 6 In the Water Act it stated that developments should stay clear of No matter which site is selected, wetlands will wetlands, with a 100m radius. In the presentation it is shown that be affected. this Act is not complied with and instead a wetland will be Leon Stapelberg, Kusile Power Station destroyed. How do we preserve the ecosystem if we destroy the wetlands? The decision regarding the wetlands was not taken lightly. The wetland impact was discussed at length with the Department of Water and Sanitation (DWS) and the South African National Biodiversity Institute (SANBI).

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Mathys Vosloo, EAP 7 The farmers also rely on borehole water. How will leachate and Eskom is already engaged in monitoring their runoffs into the boreholes be monitored? groundwater sources via various boreholes, and that there is a consultation process with farmers and community members that raise concerns regarding the quality of the water at their boreholes. On the Site A no negative effluence were identified in the boreholes. Leon Stapelberg, Kusile Power Station

Post meeting note: The project has applied for the Waste Management Licence and a Water Use Licence, both of these licences, if acquired, will have conditions for water monitoring. Mathys Vosloo, EAP

1.2.2 Air Quality Related Comments

1 Except the ash site for Kusile, Kendal is very close to Kusile MNGUNI, Thomas, PM: 20 August The cumulative impacts are addressed in the Power Station and taking that into consideration, what Greater Middelburg 2014 Report but on impact basis and not specifically cumulative impacts are there from all of these sites? Residents in detail on cumulative impacts. Association Mathys Vosloo, EAP

Mrs Nicolene Venter reported that she will forward the page number from the report to where it talks about cumulative impacts. Nicolene Venter, PPP

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Post-meeting note: Page 18, Paragraph 3.2.2: Impact Assessment Methodology. Under each Specialist Summary in the DEIR the specialists included cumulative impacts, which contribute to the specialist findings and recommendations. These recommendations were incorporated into the DEIR as presented by the specialists. Mathys Vosloo, EAP 2 Are the team not under estimating the impact of fly ash in the MNGUNI, Thomas, PM: 20 August The concern will be forwarded to the air quality province by saying that the risk is very minimal? If one combine Greater Middelburg 2014 specialist for review. all the toxins in the ash, one cannot be too cautious with Residents Mathys Vosloo, EAP mitigations. Association A pre-cautionary approach has been taken with regards to complex impacts such as ash fallout on a provincial basis. The assessment of air quality impacts were done on the information at hand at the time of compiling the EIR. However, once the power station produces ash it will be analysed and classified in terms of the relevant waste regulations. At this point mitigation measures can be intensified to further minimise the impact of ash on the surrounding environment and the EMPr updated. It must still be noted that if the mitigation measures recommended by the specialist is implemented successfully the impact of windblown ash can be minimised to the ash disposal facility footprint. Mathys Vosloo, EAP 3 There are many dangerous toxins in the ash e.g. lead, mercury, SHILUBONE, PM: 20 August Exposure to toxin in the ash can happen in two aluminium etc. How sure are Zitholele that this will not affect the Khensani, Middelburg 2014 ways: community as this can cause cancer, kidney problems etc? The Environmental Justice 1. Through run off containing ash; or reason for the question was that there was an incident at Network (MEJN) 2. windblown ash. Hendrina Power Station where two kids were ill as a result of the The engineers are confident that the design of toxins caused by the ash. the ADF will prevent or minimise such incidents and the team is also confident that the mitigations recommended in the EMPr will address these situations.

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In terms of the windblown ash, the air quality specialist is confident with the mitigations that they have recommended such as dust suppression and rehabilitation of the ADF. If these mitigation measures are done correctly, it will limit the windblown dust to the footprint of the site. It is very unlikely that the community members will be affected if the mitigation measures are put into place and adhered to. Mathys Vosloo, EAP

Mr Leon Stapelberg (Eskom Holdings) further commented that he is unaware of any employees of Eskom working at power stations including Kusile Power Station, being diagnosed with any of the disease mentioned by Ms Shilubone. Leon Stapelberg, Kusile Power Station 4 Will the ash have significant impact on air quality? SMITH, Gert, Agri PM: 20 August The Air Quality Specialist did identify that there Mpumalanga 2014 will be an impact on air quality but it will not be significant, after successful mitigation, and the impact will be below the standards and limits as set out in the National Environment Management: Air Quality Act. Mathys Vosloo, EAP

1.2.3 Ash Disposal Facility (Proposed) Related Comments

1 How much top soil goes on top of the ash? CHERRY, Andre, DEIR Focus Group 300 mm goes on top. Landowner Meeting, 20 August Charl Cilliers, Design Engineer 2014 2 Is Eskom going to do to rehabilitate the other land where the CHERRY, Andre, DEIR Focus Group It is not entirely clear what “other land” the emergency ashing will be done? Landowner Meeting, 20 August stakeholder is talking about. However Eskom 2014 will have to remedy any area, whether within the Eskom owned property or outside the Eskom owned property that has become contaminated with ash. Eskom will have to abide by the “duty of care” and “polluter pays” principles. Mathys Vosloo, EAP 3 Why are the minimum standards used for the liner design? CHERRY, Andre, DEIR Focus Group The standard that is used is the National

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Landowner Meeting, 20 August Environmental Management: Waste Act’s 2014 Waste Classification and Management Regulations (R634), National Norms and standards for assessment of waste for landfill disposal (R635), and National norms and standards for disposal of waste to landfill (R636). These regulations do not represent minimum standards but are prescribed by the Department of Environmental Affairs as the maximum interventions to be implemented to prevent pollution of land and water resources. Mathys Vosloo, EAP

1.2.4 Conveyor Belt Infrastructure (Proposed) Related Comment

1 Commented that no dust suppression should be allowed as the CHERRY, Andre, DEIR Focus Group The design can be re looked at again, if ash should be kept wet when it is travelling on the conveyor belt. Landowner Meeting, 20 August required. If it cannot be watered down then the conveyor belt should be an 2014 Charl Cilliers, Design Engineer enclosed system. The ash is treated with water when it leaves the station via the conveyor belt to the ADF. This is required to ensure that large volumes of ash do not become airborne during windy days. Dust suppression on the ADF itself is also of critical importance as the surface of the compacted ash, before soil covering is applied, will dry out causing the ash to be carried by the wind and surface runoff.

1.2.5 Tourism Related Comment

1 They have attended all the meetings and their business VAN VUUREN, PM: 20 August Comments are captured in the comments and focusses on tourist from overseas. It is a concern that the Tersia, Landowner 2014 response report. There were responses Zitholele, in their presentation indicated that the study area is not provided to the comments that were raised. a tourism destination and therefore a tourism study was not Nicolene Venter, PPP required nor noted as such in the report. It is therefore believed that their concerns / comments submitted via e-mail were not The comments will be forwarded to the social taken into consideration. specialist team for further investigation or response. Mathys Vosloo, EAP

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In terms of the residential and accommodation aspect of the property, the proposed ash disposal facility will not be visible from either the farmstead (located in a depression in the landscape) or from the two chalets (located deep in the river valley) in the early lifespan of the ADF. However, during the site investigation it became evident that the ADF would become visible from the farmstead during the later years of the ADF’s life. With reference to the activities (hiking, mountain biking, 4x4-ing and hunting), the proposed ash disposal facility will be partially to fully visible when travelling in an eastern and south- eastern direction along routes on the main koppie / mountain. These views would also, to some extent, include the Kusile Power Station currently being constructed. Upon leaving the adventure facility, the proposed ash disposal facility would be partially visible in conjunction with full-on views of the Kusile Power Station.

The rating of the impact from this sensitive visual receptor will be included in the addendum to the Visual Impact Report Mitha Cilliers, Visual specialist

Although there are tourism activities in the area, it is not the main economic activity, and therefore a specific tourism impact assessment was not required. This does not mean that the stakeholder’s comments were not considered. The Kusile Power Station has been constructed already, and cannot operate without an ash disposal facility. The site selection aimed to choose the site with the least impacts in close proximity to the power station in order to minimise impacts. The operation of the power station will result in an increase in the demand for overnight facilities

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which may be beneficial to tourism operators. Mrs. Van Vuuren operates a very specific tourism facility, namely adventure tourism, and caters for a specific market. At the time of the assessment it was found that the proposed development will not be visible from their property. Ilse Aucamp, Social specialist

1.2.6 Site Alternatives Related Comments

1 Commented that it will be ideal to use Site C so that the ash can CHERRY, Andre, DEIR Focus Group Site C has its own constraints associated with blow onto Eskom property and not onto the famers land. Landowner Meeting, 20 August the site. Most significant constraints include 2014 the fact that wetlands on site C has already been set aside for wetland offset plan for an authorised Kusile project, and that people have been relocated previously from another area to site C, and as recommended by the social specialist should not be relocated again. 2 Mr Andre Cherry commented that he totally objects to Site A, CHERRY, Andre, DEIR Focus Group Ms Nicolene Venter acknowledged the especially when the wind blows then it will be blown in the Landowner Meeting, 20 August comment regarding the objection raised. direction of the landowners’ properties. 2014 Nicolene Venter, PPP

Post-meeting note: The air quality specialist identified potential impacts such as windblown ash and modelled the potential movement of the ash with and without mitigation in place. Conclusions from the exercise were that with mitigation successfully implemented it can be said with confidence that dust and ash can be limited to the ADF footprint. Furthermore, dust fallout monitoring will have to be done on neighbouring properties to measure effectiveness of the mitigation measures. Mathys Vosloo, EAP 3 Site C is the better site for the ADF. JANSEN VAN DEIR Focus Group All the issues and recommendation will be RENSBURG, Hans, Meeting, 20 August captured and submitted for decision making to Landowner 2014 the Department of Environmental Affairs (DEA). Should the landowners not be happy or in agreement with the DEA’s decision, then

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they will have an opportunity to appeal the decision that has been taken. Tobile Bokwe, Eskom

Post-meeting note: The statement that Site C is the better site for the ADF is considered unqualified as no explanation or reasons were given why it is considered the better site from the commenter. In terms of the EIA conclusions drawn a process was followed where environmental, socio-economic, and technical aspects were considered which led the project team to the conclusion that site C was not a preferred site for placement of the ADF. Mathys Vosloo, EAP

1.2.7 Social and Socio-Economic Related Comments

1 Mr Thomas Mnguni requested that a clearer breakdown be done MNGUNI, Thomas, PM: 20 August If a principle contractor is appointed on site from the social specialist, as this project is not about only Greater Middelburg 2014 they have to appoint local labour from the creating jobs but also about people losing their livelihood in the Residents community. This is a complex issue and there area. Association will always be people who are not happy. Leon Stapelberg, Kusile Power Station

It is not clear what Mr. Mnguni means with a clearer breakdown. The SIA did consider impacts on livelihoods and made recommendations in this regard. The client needs to implement the recommendations as the project proceeds. Ilse Aucamp, Social specialist 2 Ms Khensani Shilubone also commented that it is not only the SHILUBONE, PM: 20 August Nicolene Venter acknowledged the comment. power station that hires labour from outside the community but Khensani, Middelburg 2014 Nicolene Venter, PPP the mines do the same thing. Environmental Justice Network (MEJN) 3 Have all the properties of the alternative sites been purchased? SMITH, Gert PM: 20 August No new property is required as Site A is Agri Mpumalanga 2014 already owned by Eskom. Mathys Vosloo, EAP

Post Meeting Note:

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At the EIA phase the alternative sites are only considered with consultation with land owners. Only after an environmental authorisation has been granted will negotiation with land owners and purchase agreements be finalised for the authorised alternative site. In the case of the Kusile 60-year ash dump recommended site, the property on which the recommended preferred site is located is already owned by Eskom. Mathys Vosloo, EAP

1.2.8 Kusile Power Station Related Comments

1 What is the projected tonnage of ash that will be disposed of CHERRY, Andre, DEIR Focus Group Comments were noted by the EAP daily at Kusile Power Station? Landowner Meeting, 20 August Mathys Vosloo, EAP 2014 Post meeting note: The tonnage per day being generated by all six units of the Kusile Power Station, when operational, is expected to be in the order of 19440 tonnes per day. Mathys Vosloo, EAP 2 If Site A is chosen then the system used for disposing the ash CHERRY, Andre, DEIR Focus Group There is always a possibility that the best should be of very high standard to ensure that when one system Landowner Meeting, 20 August designed system can fail. is down then another system must kick in, and a third system 2014 Leon Stapelberg, Kusile Power Station should the other two fail. Post-meeting note: The system used for controlling ash on the ash disposal facility is a dust suppression sprinkler system. This will be a new system, and in the event that the system fails the power station will employ water trucks and water bowsers to control dust on the site. Rehabilitation of the exposed ash will also be rehabilitated as soon as the area is stabilised to minimise windblown ash and dust fallout. Mathys Vosloo, EAP

1.2.9 Communication Related Comments

1 Only the landowners on the site alternatives were consulted and CHERRY, Andre, DEIR Focus Group There is forum called the Environmental

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not the neighbours, even during the site selection process. Not Landowner Meeting, 20 August Management Committee (EMC) where issues Eskom or the engineers consulted the neighbouring landowners. 2014 can be tabled, discussed and be addressed. The only people who visited their properties where the specialist Tobile Bokwe, Eskom during their specialist studies 2 The venue for the meeting is not accessible for community MNGUNI, Thomas, PM: 20 August There were challenges between the project members to attend the public meeting and there was no Greater Middelburg 2014 team and the communities, and due to transport made available to the community Residents unforeseen circumstances, the public meeting Association had to be moved to this location (El Toro). Aware of the project deadlines but the only way to access the Nicolene Venter, PPP reports is at the library and this is a problem because there is not enough time to read the report; Post meeting note: One of the reasons that the meeting venue Did not understand the technical jargon that was used in the was moved was due to the fact that Eskom presentations. It would have been nice to make the and the labour force was in wage negotiations presentations simpler; and with a risk of strikes deemed looming. Due to the identified potential risk it was identified that There should be another meeting for the community members having the meeting at the Phola Community that have not attended the meeting today. Hall could flare up tensions between Eskom and the work force. It was therefore decided, for safety of residents and the project team, to move the venue to the closest neutral venue, which was El Toro.

Ms Venter acknowledged the constraint to access the Report and, with the approval of the project team, provided a hard copy of the Report (including the Appendices) to Mr Mnguni and his organisation. It was requested that the Report be circulated to their members and it was agreed that a collective written comment on the DEIR will be submitted to Zitholele within the presented time frame.

Ms Nicolene Venter, on behalf of Zitholele Consulting, acknowledged the comment and will take the matter forward for future projects.

The response for a meeting in Phola was acknowledged and will be presented to the team for consideration.

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Mathys Vosloo, EAP 3 Have all the landowners been informed about this project? SMITH, Gert, Agri PM: 20 August Landowners within the study area were Mpumalanga 2014 identified and informed throughout the EIA process. Organisations such as AgriSA and TLU SA were also informed with the understanding that they will filter the information through to their members. Nicolene Venter, PPP

1.2.10 General Comments

1 Why is there ash shown on the conveyor belt cover [shown in CHERRY, Andre, DEIR Focus Group The picture on the slide was to show how the DEIR presentation]? Should it not be wet? Landowner Meeting, 20 August site will be rehabilitated. The picture that was 2014 used in the presentation was from Matimba Power Station just to illustrate the conveyor belt system. Charl Cilliers, Design Engineer

Post meeting note: There will always be some degree of dust fallout directly associated with the conveyor system. The ash is conditioned to be damp when transported along the conveyor to minimise dust fallout around the conveyor. Mathys Vosloo, EAP 2 If Kusile is managed like Kendal Power Station then there will be Mr Leon Stapelberg commented that he could disastrous consequences. Currently the infrastructure at Kendal not respond regarding Kendal Power Station’s Power Station is not managed properly and foresees this as infrastructure. One can only put so many happening at Kusile Power Station. checks and balances in place, and there is no perfect system and it can fail at any time. The attendees were also informed that cognisance need to be taken that living in this area, with all the developments taking place, the environment will change in the near future. Leon Stapelberg, Kusile Power Station

Post meeting note: Challenges with the management of the Kendal Power Station infrastructure must be dealt with and rectified by Eskom. However, when dealing with the expected and potential

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impacts associated with the Kusile Power Station infrastructure, mitigation measures that will prove successful is identified and must be implemented to ensure the impacts are avoided, or minimised. It remains Eskom’s responsibility to ensure that in the event of failure an emergency response back-up system is in place to continue to mitigate the impact. It further remains the Interested and Affected Parties’ responsibility to raise such events or impacts with the Eskom Environmental Management Committee or the competent authority in order to address these impacts in terms of the authorisation granted. Mathys Vosloo, EAP 3 The decision has already been taken, this is just a process. JANSEN VAN DEIR Focus Group The team does not take a decision as to RENSBURG, Hans, Meeting, 20 August whether the project is approved or not. The Landowner 2014 only recommendation that the team makes is to ensure that the facility is placed in an area where it will have the least environmental impact (biophysical as well as social). Comments received from landowners, I&APs and stakeholders are also taken into consideration, but the final decision is taken by the DEA. Nicolene Venter, PPP

The license holder (e.g. Eskom) is compelled to comply with the conditions set out in the Environmental Authorisation. If the stakeholders or landowners believes that the licence holder is not complying with the conditions, then the matter can be escalated to the DEA for non- compliance. The DEA will set out the various avenues to report non compliances to an Environmental Authorisation granted. Tobile Bokwe, Eskom

Post meeting note:

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A process was followed during the EIA where potential developable areas were identified within 15 radius of the Kusile Power Station. Next feasible sites were identified, which was further investigated by a host of specialist to identify environmental, socio-economic and technical constraints and sensitivities. Based on the recommendations of these studies a preferred site was identified, which has now been recommended for consideration by the competent authority. The project team has therefore made a recommendation to the competent authority, which must however make the final decision regarding the merits of the alternative sites considered and the preferred site recommended. Mathys Vosloo, EAP 4 It was asked whether consultation was done with DEA and NGWENYA, Lydia, PM: 20 August All Government Officials, including the DEA, Government officials, and if so, why are they not present at the Guqa Community 2014 that are registered on the project database meeting as members of the public cannot get hold of them. Environmental received the DEIR notification and Public Service Meeting invitation. Attendance of a public meeting is not compulsory, but a choice. Nicolene Venter, PPP 5 The Medical Research Council has done a study on the impacts MNGUNI, Thomas, PM: 20 August Ms Nicolene Venter acknowledged the of lead on crops, and what they have found is that around the Greater Middelburg 2014 comment and replied that the team will search Middleburg and Witbank areas there are heavy lead deposits on Residents for such a report on the Medical Research the crops. Association Council’s website. Should such a report not be found, then Mr Mnguni will be requested to send a copy of the Report to Zitholele Consulting. Nicolene Venter, PPP 6 How does Eskom carry the burden if something negative Eskom adheres to strict safety rules to happens? eliminate any possible negative impacts / incidents. Should these occur, Eskom responds responsibly and effectively with respect to incidents. Leon Stapelberg, Kusile Power Station 7 Are you aware that one of the largest open cast mines will be in SMITH, Gert, Agri PM: 20 August The project is aware of the newly proposed the area? Mpumalanga 2014 open cast mine.

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2 IMPACT PHASE PROCESS COMMENTS

NO. COMMENTS, QUESTIONS AND ISSUES COMMENTATOR(S) SOURCE(S) RESPONSE(S)

2.1 EIA Process Related Comments 1 Given that the specialist reports note that the catchment is MEYER, Dr James Letter: 08 Environmental Authorisation Processes already heavily impacted upon, it is argued that with the total TOPIGS SA (Pty) Ltd September 2014 carried out for various projects are not cumulative impacts from all the related activities should be conducted concurrently. addressed and assessed collectively, including: All efforts have been made to consider the  Proposed Continuous Ash Disposal Facility at Kendal cumulative impacts of surrounding land uses Power Station (DEIR:DEA Ref Number: 14/12/16/3/3/3/63 and other known and planned developments. NEAS Reference Number: DEA/EIA/0001508/2012); and The EAP as well as the specialists who carried  AAIC New Largo Colliery EA granted: Application out the various studies for the proposed project Number:17/2/3N-41 NEAS Reference Number: have conducted similar studies or have to MPP/EIA/0000181/2011. some extent been involved with the following projects:  Proposed Kendal Power Station Continuous ADF Project ((DEA Reference: 14/12/16/3/3/3/63, NEAS Reference: DEA/EIA/0001508/2012);  Proposed 30 Year ADF for KPS Project (NEAS Reference: DEA/EIA/0001624/ 2013, DEA Reference: 14/12/16/3/3/3/68); and  Anglo American Inyosi Coal the New Largo Colliery (MDEDET Reference: 17/2/3N-41, DMR Reference: 30/5/1/2/2/511MR F/2011/04/14/002 and DWA Reference: 16/2/7/B200/C528. Consideration of Cumulative and Existing Impacts Taking the aforementioned into account, the bearing of the impacts associated with the projects listed above were considered when determining the baseline environmental

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description as well as the anticipated direct, indirect and cumulative impacts for the proposed project. Cumulative impacts were especially considered during the air quality and water related specialist studies, which are summarised in the FEIR with full specialist studies available in Appendix F of the FEIR. Mathys Vosloo, EAP 2 TPSA wishes it noted that the approach to submit separate MEYER, Dr James Letter: 08 Environmental Authorisation Processes requests for authorisation for related activities underestimates TOPIGS SA (Pty) Ltd September 2014 carried for various projects are not the cumulative impact on the TPSA environment and prevents conducted concurrently. the competent authorities from making an appropriately informed All efforts have been made to consider the decision, and may also result in the conditions stipulated in cumulative impacts of surrounding land uses licences and authorisations granted being insufficient with which and other known and planned developments. to ensure the protection of the environment, animal health and The EAP as well as the specialists who carried public health. As noted in the KPS EMC documentation out the various studies for the proposed project submitted to the relevant authorities, the KPS states that have conducted similar studies or have to upstream activities contribute to the environmental and water some extent been involved with the following resource pollution observed in the monthly monitoring reports. projects: The preferred Site A for the ADF is also impacted by the Anglo  Proposed Kendal Power Station American Inyosi Coal New Largo Colliery. This thus relates to Continuous ADF Project ((DEA numerous activities including: Reference: 14/12/16/3/3/3/63, NEAS  The Kusile Power Station Phola Overland Coal Conveyor, Reference: DEA/EIA/0001508/2012); B&E International Mining Kusile Aggregate Mine, Anglo  Proposed 30 Year ADF for KPS Project American Inyosi Coal: New Largo Colliery (AAIC NLC) and (NEAS Reference: the Kendal Power Station Continuous Ash Disposal and DEA/EIA/0001624/2013 DEA Reference: New ADF; and additional coal mines in the area. 14/12/16/3/3/3/68); and  Anglo American Inyosi Coal the New Largo Colliery (MDEDET Reference: 17/2/3N-41, DMR Reference: 30/5/1/2/2/511MR F/2011/04/14/002 and DWA Reference: 16/2/7/B200/C528. Consideration of Cumulative and Existing Impacts Taking the aforementioned into account, the bearing of the impacts associated with the projects listed above were considered when determining the baseline environmental description as well as the anticipated direct, indirect and cumulative impacts for the

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proposed project. Cumulative impacts were especially considered during the air quality and water related specialist studies, which are summarised in the FEIR with full specialist studies available in Appendix F of the FEIR. Also with the proposed site A being located close to the Kusile Power Station, New Largo Colliery and other industrial activities within the same catchment, comprehensive management of the impacts associated with the site and beyond will have to be considered by the proponent. Mathys Vosloo, EAP 3 As has been noted in previous documentation submitted MEYER, Dr James Letter: 08 Environmental Authorisation Processes regarding the KPS/Eskom related activities, the specialists and TOPIGS SA (Pty) Ltd September 2014 carried for various projects are not EAP used are presumably well acquainted with the extent of conducted concurrently. impact to the aquatic ecosystem by involvement in the Kusile All efforts have been made to consider the Power Station, Kendal Ash Dumps, Phola-Kusile Overland cumulative impacts of surrounding land uses Conveyor and other projects, such as the Turbidity Guidelines and other known and planned developments. for the Wilge River. As such, specific reference to these Existing impacts and impacts associated with significant associated impacts and activities is generally lacking. the New Largo Colliery, especially with regards It is argued that the assessments should not be in isolation of to water related specialist studies have been one another but take cognizance of the total impact. assessed by specialists and incorporated in their reports. For some studies cumulative impacts associated with other developments in the area, e.g. the New Largo Colliery, was more prominent such as for the potential impacts on groundwater, surface water and wetlands. The New Largo development will most likely cause a cone of depression relating to dewatering of their operations, ultimately causing reversal of the groundwater flow at site A towards the New Largo Colliery. Water quality and erosion impacts already occurring in the area as a result of pig farming, chicken farming, existing agricultural practices, construction of the Kusile Power Station and mining activities does have a cumulative impact when impacts associated with the ADF is considered. Eskom has committed through

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the implementation and compliance of the EMPr to implement extensive and encompassing management measures to reduce this cumulative impact within their zone of influence. Engagement of the other stakeholders in the catchment will also need to be undertaken to ensure all stakeholder exercise duty of care for impacts associated with their activities in the catchment.

Consideration of Cumulative and Existing Impacts Taking the aforementioned into account, the bearing of the impacts associated with the projects listed above were considered when determining the baseline environmental description as well as the anticipated direct, indirect and cumulative impacts for the proposed Kusile Power Station 60 year Ash Disposal Facility Project and Kendal Power Station Continuous ADF Project. The EIA Process for the proposed KPS Continuous ADF Project and that of the proposed 30 Year ADF for KPS Project constitute two separate processes. The EIA Phase for the proposed Kendal Power Station Continuous ADF Project has been completed, while the Kendal 30 year ADF project is in the EIR phase of the EIA. The EIA Phase for the Kusile Power Station 60 year ADF Project is still in progress.

The following extract which provides summary of the approach that was taken for assessing the anticipated surface water impacts, illustrates that the existing impacts were taken into account (refer to Part 6.1.7 and Part 7.3 of the Surface Water Study included as Appendix F11 of the Final EIR) :

Part 6.1.7: Cumulative Impacts

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It is a requirement that the impact assessments take cognisance of cumulative impacts. In fulfilment of this requirement the impact assessment will take cognisance of any existing impact sustained by the operations, any mitigation measures already in place, any additional impact to environment through continued and proposed future activities, and the residual impact after mitigation measures. It is important to note that cumulative impacts at the national or provincial level will not be considered in this assessment, as the total quantification of external companies on resources is not possible at the project level due to the lack of information and research documenting the effects of existing activities. Such cumulative impacts that may occur across industry boundaries can also only be effectively addressed at Provincial and National Government levels”.

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practices are not implemented. The Wilge River, a tributary of the Olifants River, flows northwards until it is joined by its main tributary, the Bronkhorstspruit River. The river then flows in a north-easterly direction until it joins the Olifants River upstream of the Loskop Dam. Given the fact that the Olifants River feeds into several water supply storage facilities utilised by local settlements, the impact of deteriorating water quality, which makes the water less fit for use, has significant environmental as well as social and economic implications. Due to the fact that several upstream impacts are already occurring when considering significance rating for cumulative impacts for each of the proposed sites, the impact class will not change considerably compared to those shown in Table 16. However, should mitigation be put in place then the local cumulative impacts would reduce the significance rating for the local area but may not have much of a positive impact on the broader catchment. This would need to be assessed considering all other users in the catchment.” Mathys Vosloo, EAP

2.2 Site Alternatives Related Comments 1 Telephone enquiry as to which site has been identified as the BRIEL, Rudie Fax on 21 October Graag bevestig ek ons telefoniese gesprek van EIA preferred Site. Commercial 2013. vanmiddag waarin jy versoek het of ‘n besluit Manager: Eagles rakende die gekose terrein vir die 60 Jaar Pride Hatchery Asprojek vir Kusile Kragstasie al geneem is. Telephone: 26 February 2014 Soos genoem, blyk dit op hierdie stadium of terrein A die mees geskikste terrein is, maar Summary of telephone conversation confirmed as correct. E-mail: 27 February die bevestiging rondom my antwoord sal dalk 2014 eers deur die loop van die week bevestig kan word. Ek sluit Mathys Vosloo, projekbestuurder vir die OIE by hierdie kommunikasie in.

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Ek bevestig ook dat jy genoem het dat jy dringend moet weet wat die besluit rondom die terrein is aangesien uitbreidings aan die infrastruktuur van Eagles Pride gedoen moet doen en aangesien julle eiendom aangrensend tot terrein B is, sal die vestiging van ‘n asfasiliteit Eagles Pride se besigheid nadelig beindvloed.

Bevestig asseblief of bogenoemde opsimming van ons gesprek korrek is. Indien nie, is jy meer as welkom om korreksies aan te bring.

Translation:

I would like to confirm our telephonic conversation of this afternoon in which you asked whether a decision has been taken regarding the preferred site for the 60 year Ash Project for Kusile Powerstation.

As mentioned, it appears at this stage that site A would be the most appropriate site, but my answer would possibly only be confirmed during the course of the week. I include Mathys Vosloo, project manager for the EIA, in this communique.

I also confirm that you mentioned that you have to know urgently what the decision is regarding the site, since extensions to the infrastructure of Eagles Pride must be done and since your property is adjacent to site B, the establishment of an ash facility would have a negative effect on the business of Eagles Pride.

Please confirm the correctness of the summary above of our conversation. You are more than welcome to make any corrections if

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it is not accurate. Nicolene Venter, PPP (e-mail: 26 February 2014) 2 Daar is 4 gebiede op die kortlys en ons wag vir MOLL, Andreas E-mail: 12 February Soos belowe, hiermee terugvoer na die Omgewingssake. Landowner: Farm 2013 spesialiste werkswinkel wat ons verlede week Kan ek ‘n kopie kry van die verslag soos gestuur na Jakhalsfonteint E-mail: 11 February gehou het. Dié werkswinkel was toe nie om die Omgewingssake? (Bio-Select) 2013 voorgestelde alternatiewe te bespreek nie Gedeelte 10 is geregistreer in die naam van Bio-Select CC en maar om aan die spesialiste addisionele ek is die enigste lid van Bio-Select CC. inligting te gee wat hulle in aanmerking moet Hanna van Aswegen van Kortfontein (nie Jakhalsfontein 21) is neem met hulle detail studies en die die skoolhoof by Balmoral Laerskool. Ek het nie die nommer nie evalueringsmetode. maar jy kan die skoolnommer maklik vind. Het jy ‘n tekening/kaart oor waar gedeelte 21 gelee is? Dan kan Die werkswinkel waar die alternatiewe ek help. bespreek sal word vind huidiglik teen einde Maart plaas – sou die datum verander, sal ek Translation: jou weer laat weet. Dit is die verwagting dat die Konsep Omgewingsimpakverslag kort daarna There are four areas on the shortlist and we are waiting for aan die publiek, en julle as grondeienaars, Environmental Affairs. beskikbaar gestel sal word vir insae en Can I obtain a copy of the report that was sent to Environmental kommentaar. Affairs? Portion 10 is registered in the name of Bio-Select CC and I am Ek sal weer met jou in verbinding tree sodra the only member of Bio-Select CC. die verslag reg is vir verspreiding. Hanna van Aswegen from Kortfontein (not Jakhalsfontein 21) is the school principal at Balmoral Primary School. I do not have a Translation: number, but you could get hold of the school’s number easily. Do you have a sketch/map on where Portion 21 is located? As promised, herewith feedback after the Then I can assist. specialist workshop we held last week. This workshop was not to discuss the proposed alternatives, but rather to provide additional information to the specialists for them to take into account with their detailed studies and the assessment method.

The workshop where the alternatives will be discussed will currently take place at the end of March – should the date change, I will inform you. It is expected that the Draft Environmental Impact Report will be made available to the public and to you as

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landowners shortly thereafter for overview and comments.

I will contact you again as soon as the report is ready for distribution. Nicolene Venter, PPP (e-mail 06 March 2013) Jy is korrek, daar is 4 areas (A (hier is ook area G1 en G2), B, C, F – ek stuur vir jou die Locality Map per LARGEFILESASAP (of een van die programme) – hy is sowat 12MB groot.

Die verslag is ook op Zitholele se webwerf (http://www.zitholele.co.za/kusile-ash) beskikbaar of as jy verkies kan ons vir jou ‘n CD/DVD stuur met die verslag op – dit is ook heelwat MBs groot. Laat my asseblief weet wat jy verkies. Voorsien my asb ook van jou posbus en fisiese adres vir aflewering sou jy ‘n CD/DVD verlang.

Translation:

You are correct, there are four areas (A (there is also area G1 and G2), B, C, F – I am sending you the Locality Map per LARGEFILESASAP (of one of the programs) – it is about 12 MB in size.

The report is also available on Zitholele’s website (http://www.zitholele.co.za/kusile-ash) or if you prefer, we can send you a CD/DVD with the report – it is also several MBs in size. Please let me know which you prefer. Also, please furnish me with your postal box and physical address for delivery, should you require a CD/DVD. Nicolene Venter, PPP (e-mail 12 February 2013)

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Post-meeting note: CD was posted on 13 February 2013 3 Stuur gerus aan, ek wil graag weet wat die stand van sake is. Ek Soos belowe, find asseblief aangeheg die is maar bekommerd. publieke dokumente rakende die voorgestelde breiding van aswegdoenfasiliteite by die Translation: Kusile-kragstasie uitwat tot dusver versprei is: • Bekendstellings Fase: Please send it; I would like to know what the situation is. I am  Inligtingsbrief quite concerned.  Studie-area kaart  Lys van plase/eiendomme wat moontlik deur die projek geraak mag word  Bewys van advertensies geplaas (ek was selektief en heg net Beeld en Streeknuus aan. Die advertensie was ook in die volgende koerante geadverteen . _Corridor Gazette . _Die Springs Advertiser . _Echo . _Ekasi News . _Mpumalanga News . _Ridge Times . _The Herald . _Witbank Nuus • Bestekopname Fase  Konsepverslag . Aankondiging dat die Konsep Omgewingsimpakverslag beskikbaar is vir kommentaar . Brief of belangegroepe te herinner aan die publieke vergadering  Finaleverslag . _Aankondiging dat die Finale Konsep Omgewingsimpakverslag aan die Departement . Omgewingsake ingedien is vir besluitneming Sal jy asseblief bevestig dat die plaas

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Jakhalsfontein 528, Ged 10) in jou naam geregistreer is. En, het jy dalk die kontakinligting (selfoon- nommer en e-pos adres) van jou bure of Jakhalsfontein 528, Ged 21, Hanna van Aswegen? Ons het net ‘n landlyn nommer (013) 680 1081 en kom nie deur na die nommer nie. Ons sal jou op hoogte hou en uitnooi na die volgende reeks vergaderings wat beplan word. Op hierdie stadium, moet asseblief nie huiwer om ons te kontak indien jy enige additionele inligting verlang nie.

Translation: As promised, please find attached the public documents regarding the proposed expansion of the ash disposal facility at the Kusile Powerstation that have been distributed thus far: • Introduction Phase:  Information letter  Map of Study Area  List of farms/properties that could possibly be affected by the project  Proof of advertisements that were placed (I was selective and only attached those from Beeld and Streeknuus). The advertisement was also placed in the following newspapers: . Corridor Gazette . The Springs Advertiser . Echo . Ekasi News . Mpumalanga News . Ridge Times . The Herald . Witbank Nuus

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• Scoping Phase  Draft report . Announcement that the Draft Environmental Impact Report is ready for comments . Letter to remind interest groups about the public meeting  Final Report . Announcement that the Final Draft Environmental Impact Report was submitted to the Department of Environmental Affairs for decision-making Would you kindly confirm that the farm Jakhalsfontein 528 (Portion 10) is registered in your name? And do you possibly have the contact details (cellular number and e-mail address) of your neighbours of Jakhalsfontein 528, Portion 21, Hanna van Aswegen? We only have a landline number (013) 680 1081 and nobody answers at that number. We will keep you informed and invite you to the next series of meetings that is planned. At this stage, please do not hesitate to contact us should you require any additional information. Nicolene Venter, PPP (e-mail 02 December 2013) 4 Concerned about alternative C. MOTAUNG, Lindiwe EIA Newsletter With reference to your EIA Newsletter Snr Environmental Comment Form Comment Sheet received (refer to attached Advisor PDF), you included a comment in the Farm Eskom Holdings SOC name and portion number if you are a Limited potentially affected landowner or own property adjacent to the proposed sites informing us that you are concerned regarding alternative C.

Zitholele is in the process of finalising the Comments and Responses Report for inclusion into the Draft Environmental Impact

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Assessment Report and we would appreciate it if you can please be so kind as to elaborate what your concern regarding Site C is. Currently we cannot respond to your concern.

It will be appreciated if your written concern can be received before the end of business day on Monday 21 July 2014. Nicolene Venter, PPP (e-mail: 20 July 2014)

Post-meeting note:

No further comments were received from Ms Motaung following the request for clarification of her concerns. 5 We act on behalf of Before Sunset Properties 36 (Pty) Ltd & SWEKE, Desmond E-mail: 06 January Acknowledge receipt of e-mail dated Nooitgedacht Farm who is the owner of substantial portions of Settlement Planning 2014 06 January 2013. Confirmation provided that land in the subject area, including the Remaining Extent of Services the following stakeholder is registered on the Portion 9 (A Portion of Portion 1) of the Farm Nooitgedacht 525 project database as a landowner of the Farm Registration Division JR Gauteng Nooitgedacht: David Singer Landowner I presume, based on us having received the correspondence Before Sunset Properties 36 (Pty) Ltd & from you, that we are registered as an “Interested and Affected Nooitgedacht Farm (contact details provided Party” in the Environmental Authorisation Process. If not, it is as per Maximizer). important that we be included as such. With regard to the It will be appreciated if the above-mentioned proposed alternatives for the extension of the Ash Disposal information can be confirmed as correct. Facility, “option B” is close to our property and could potentially It was noticed that Setplan, acting on behalf of have negative impacts from an air quality, water quality and Before Sunset Properties 36 (Pty) Ltd & visual perspective. “Option C” being visible from the N4 highway Nooitgedacht Farm, is not registered on the could possibly negatively affect the value of property in the wider project database and confirmation is provided area. The best options from our point of view, appears to be that you, as representative from Setplan, have options A, G or F. now been registered on the project database. Confirmation received that the landowner information as per Zitholele also confirms that Setplan will receive database is correct. all future correspondence relating to this proposed project. Nicolene Venter, PPP (e-mail: 08 January 2014)

Assessment of the site alternatives is not only based on air quality, water quality and visual aspects. A number of specialist studies were

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undertaken to assess the suitability of the alternative sites. We can confirm at this point that the cumulative impacts suggest that Site A would be the best site with least environmental, technical, and socio-economic impacts for an Ash Disposal Facility. Mathys Vosloo, EAP 6 Verneem namens Mnr van Rensburg of daar al uitsluitsel oor die SMIT, Sonja E-mailed: 20 June Met verwysing na die telefoniese gesprek van terreinalternatiewe vir die asgat is. On behalf of HvR 2014 25 Junie 2014 rakende die OIE status van die Boerdery Kusile Aswegdoeningsfasiliteit en Translation: Afvalbestuur-lisensie projek word dit bevestig dat die impakfase reeds begin het waartydens Asking on behalf of Mr Van Rensburg whether there has been die onderskeie alternatiewe terreine in detail finalisation regarding the site alternatives for the ash hole. ondersoek word om die mees geskikste terrein (omgewing sowel as tegnies) te identifiseer.

Grondeienaar sal op hoogte gehou word van enige verwikkelinge in die verband.

Translation:

With reference to the telephone conversation of 25 Junie 2014 regarding the EIA status of the Kusile Ash Disposal Facility and Waste Management Licence project, it is confirmed that the impact phase has already started during which the various alternative sites will be investigated in detail to identify the most appropriate site (environmental and technical).

Landowners will be informed of any developments in this regard. Nicolene Venter, PPP (e-mail: 26 June 2014)

A number of specialist studies were undertaken to assess the suitability of the alternative sites. It is confirmed at this point that the cumulative impacts suggest that Site A would be the best site with least environmental, technical, and socio-economic

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impacts for an Ash Disposal Facility. Mathys Vosloo, EAP

2.3 Social and Socio-economic Related Comments 1 Ek word geraak op gedeelte 10, Jakhalsfontein, wat ‘n “possible MOLL, Andreas EIA Newsletter In the event that Site B is identified as the most affected property” is. Op hierdie eiendom is 70% van my Landowner: Farm Comment Form: 13 suitable scenario, negotiation with Eskom organiese bessies en die pakhuis. My woonhuis en die ander Jakhalsfonteint December 2013 regarding land purchases must be undertaken. 30% organises Bessies is op Gedeelte 1, Jakhalsfontein, wat (Bio-Select) This negotiation process is however not part of aangresend is aan Gedeelte 10. the EIA process but will be part of negotiation Indien ek geraak word deur die ashoop word beide bedeeltes process that will start during the EIA process, geraak en word beide gekoop! however will only be concluded after environmental authorisation has been granted. Translation: Mathys Vosloo, EAP

I am affected at Portion 10, Jakhalsfontein, which is a “possible affected property”. 70% of my organic berries as well as the warehouse is on this property. My residence and the other 30% organic berries are on Portion 1, Jakhalsfontein, which is adjacent to Portion 10. If I am affected by the ash heap, both these portions are affected and both are being purchased! 2 Our main farming operation is with pigs. L van Dalen Boerdery is VAN DALEN, Leanert Letter: 07 January As per acknowledgement dated 07 January a permanent employer of LHW van Dalen and a number of Landowner: Farm 2014 2014 of Leo’s Engineering’s Comment Sheet employees, which will be unemployed should the farm be sold. Witklip and letter received as a response to our EIA Newsletter distributed in December 2013, Zitholele can now inform you that the EIA team is closer to making a decision regarding the preferred site for the ADF. Once finalisation has been received, we will communicate this information to stakeholders such as yourself. A formal response to your letter will be attended to shortly. Please do not hesitate to contact me should you have any further queries or need clarification regarding the EIA Process Nicolene Venter, PPP (e-mail: 07 January 2014) A number of specialist studies were undertaken to assess the suitability of the alternative sites. Zitholele can confirm at this

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point that the cumulative impacts suggest that Site A would be the best site with least environmental, technical, and socio-economic impacts for an Ash Disposal Facility. Mathys Vosloo, EAP 3 L van Dalen Boerdery is currently in an upgrading and In the event that Site B is authorised by the expanding process for the cages, etc. DEA, an appeal process will follow during which further submission can be made to the minister. However, Zitholele can confirm at this point that the cumulative impacts suggest that Site A would be the best site with least environmental, technical, and socio-economic impacts for an Ash Disposal Facility. The EAP will thus recommend Site A as the preferred site alternative. Mathys Vosloo, EAP 4 Loss of income will be for three (3) years due to the fact that In the event that Site B is authorised by the pigs must be sold and new cages built once a new farm is DEA, an appeal process will follow during selected for breeding purposes and income will be needed which further submission can be made to the primarily to do so. minister. However, Zitholele can confirm at this point that the cumulative impacts suggest that Site A would be the best site with least environmental, technical, and socio-economic impacts for an Ash Disposal Facility. The EAP will thus recommend Site A as the preferred site alternative.33 Mathys Vosloo, EAP 5 With reference to the telephonic conversation with Patiswa DU PLESSIS, Louise Fax: 21 October Zitholele Consulting will be releasing the Draft Mnqokoyi on the 17th October 2013 the following Lawyers for Human 2013 Environmental Impact Assessment Report Refer to points 3.1 to 3.4 below Rights: Land and (DEIR) on Friday 25 July 2014 for public Housing Unit review and comments.

To ensure that we address all issues raised during the public participation process, we would like to confirm a meeting date during the DEIR review period which is from Tuesday 29 July 2014 until Monday 08 September 2014. The reason for this request is that I am not

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sure whether your Firm responded to my e- mail dated 04 November 2013 (see below), but I recall not receiving a confirmation date. If you did respond, would you please be so kind as to forward the e-mail to me again so that it can be included in our correspondence Appendix to the DEIR.

We also kindly request a copy of the correspondence dated 3 October 2013.

I can also confirm that through the detailed environmental assessment undertaken, Site A has been identified as the preferred site (property owned by Eskom) and Site F, one of the site alternatives proposed during the scoping phase and which was located on the Farms Bossemanskraal 538 (Ptns 5, 7, 8, 9, 10 & 12), Witpoort 563 (Ptns 1, 4, 8, 13 & 16) and Dwaalfontein 565 (Ptns 1 & 2) was discarded.

As per the correspondence received from Lawyers for Human Rights, Land and Housing Unit, acting on behalf of the Maphosa Family, the Maphosa Family has a land claim on the Farm Bossemanskraal 538JR.

For easy reference, please find attached a PDF document which includes your Firms correspondence and our e-mail communications. Nicolene Venter, PPP (e-mail: 20 July 2014) As per our e-mail correspondences below, we 6 Take note that we have previously sent through correspondence would like to confirm that the purpose of the to you on the 3rd of October 2013, but as of yet have not meeting with HR, Lawyers for Human Rights, received any response. Land and Housing Unit, is to discuss the EIA 7 As per the telephone conversation, Zitholele Consulting process to date and present the 5 sites (6 indicated that they shall revert back to us with regards to our disposal scenarios) currently under meeting request and the contents of our previous environmental investigation after which a most

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correspondence on Monday 14 October 2013. suitable site will be recommended for decision- 8 We propose that we meet and discuss the planned land use of making to the Department of Environmental the farm. Affairs. Should HR need to discuss 9 We are still awaiting your response to our proposal; kindly revert compensation matters, Zitholele Consulting will back to us on a proposed date or dates when you will be unfortunately not be able to answer those available to meet with us. questions and it is believed that it is too early in the process for these type of discussions.

Currently, with the environmental information available, we can inform you that the indication is that Site F, on the farm Bossemanskraal 538 JR will likely not be a recommended site.

As previously requested, please confirm whether the Bossemanskraal 538 JR, as a whole, is part of the Claim in Restitution. If not, please provide us with a list of the portion numbers that forms part of the Land Claim.

We would like to propose a date and time for the week of 11 November 2013 and it will be appreciated if you can indicate whether the meeting can be held at your offices in Pretoria. Nicolene Venter, PPP (e-mail: 04 November 2014)

Post-meeting note: Dates for possible meetings with the Lawyers for Human Rights: Land and Housing Unit were requested, however further responses from the I&AP was not received. No subsequent correspondence has been received. Nicolene Venter, PPP 10 We represent the Maphosa – family who has a land claim on the Fax: 09 July 2013 With reference to your letter dated 21 October farm Bossemanskraal 538JR, some of the family members still 2013 in which Lawyers for Human Rights occupy the farm as labour tenants. requested a meeting with the project team for 11 Our clients also have a pending application in the Land Claims the proposed abovementioned project, Court. Zitholele Consulting request that you please 12 Our clients brought it to our attention that a decision was made provide us with three proposed meeting dates

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by the commission that the farm is not restorable because of (and times) within the next three weeks, and I Eskom’s planned activities. Our clients were never given an will co-ordinate dates with Eskom project team opportunity to address the commission. members and that of the EIA team. 13 We propose that we meet and discuss the planned land use of the farm in order for us to advise our clients. Also, please indicate where would be a 14 Kindly advise us when you will be available for such a meeting. convenient place to hold this meeting: • your offices; • Eskom Megawatt Park, Sunninghill; or • Zitholele’s offices in Midrand.

I will forward you in a separate e-mail a map indicating the sites under environmental assessment and the farm Bossemanskraal (Maphosa Family). Would you please be so kind as to provide us with the portion number. Nicolene Venter, PPP (e-mail: 25 October 2014)

2.4 Water Related Comments 1 TPSA refers to previous comments and documentation MEYER, Dr James Letter: 08 Various Environmental Authorisation submitted to Eskom/Kusile Power Station (KPS), Zitholele TOPIGS SA (Pty) Ltd September 2014 Processes have been carried out for numerous Consulting, and Competent Authorities, regarding the current aspects / elements of the Kusile Power construction activities and proposed operational activities at the Station. The Environmental Authorisation KPS in which concerns regarding significant and unacceptable Process (S&EIR Process) that has been monitoring and baseline description gaps for air and water carried out for the project at hand (i.e. quality monitoring and assessments were described. proposed project) however relates specifically to the construction of the Kusile Power Station It is clear from this report that multiple adverse impacts are 60 year ADF project. expected, both during construction, operation and rehabilitation phases. Furthermore, many of these impacts are difficult to The baseline environmental description predict and the various ratings awarded may be not only provided in Part 7 of the final EIR provides an

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challenged in view of the failure to adequately described the overview of the current environmental current baseline conditions and predicted pollutants, but also conditions. With no other baseline information due to the failure to assess the cumulative impacts referred to in available at the time, the project team could section 3 above. only rely on the data available to assess the impacts of the development. The baseline environmental description provided, also serves as a point of reference for determining the environmental consequences of the proposed 60 year ADF and associated project activities. Although the cumulative impact of the proposed project have been taken into consideration, the EAP cannot provide comment on the adequacy of the monitoring and baseline description gaps for air and water quality monitoring and assessments provided in previous EIRs and for which Environmental Authorisation have been granted. For this purpose the Eskom EMC was established where these issues must be highlighted and addressed.

Eskom must furthermore ensure compliance with the conditions of the environmental authorisations that has been issued for previous Kusile projects. Non-compliance with these conditions must be reported to the authorising authority with mediation. Mathys Vosloo, EAP

The following limitations have been inserted into the aquatic specialist report. Limitations and assumptions: It should be noted that no detailed plans were available for this site, nor for the conveyor crossings. As such impacts were generically assessed. Many of the impacts were difficult to quantify with a high degree of accuracy. This may have been due to:  a lack of factual certainty (e.g. the probability of a spill cannot be predicted

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and the magnitude of a spill can range from minor to catastrophic),  the difficulty of predicting the effectiveness with which mitigation measures are implemented, and  the limited scope of the baseline survey. (A comprehensive description of baseline conditions would require several years of study with extensive field surveys and analyses.) Norma Sharratt, Aquatic specialist 2 It is of great concern to TPSA that despite clear recognition of The Eskom EMC was established where the failure to adhere to the licence and RoD conditions, KPS issues regarding non-compliance must be continues to impact the environment without implementing the highlighted and addressed. Eskom must recommended measures. The Contamination Study was furthermore ensure compliance with the completed in the 3rd Quarter of 2013, yet at the June 2014 KPS conditions of the environmental authorisations EMC it was acknowledge that the recommendations have not that has been issued for previous Kusile been implemented due to “budgetary constraints in Eskom”. projects. Non-compliance with these conditions must be reported to the authorising authority with mediation. Mathys Vosloo, EAP 3 Section 14.4.1.9: Monitoring refers: The biomonitoring referred to (Section 14.4.3) 4.1.4.1 This section fails to specify the constituents of concern refers to the monitoring of aquatic ecosystems linked to the ADF and should prescribed the correct inorganic only. The monitoring required for surface water ICP-MS methodology as developed for the Water Research quality is covered in a separate surface water Commission EDC Programme which has been communicated to assessment report. To clarify this distinction, the KPS EMC on several occasions and conducted by the the following has been added: surface and groundwater specialists during 2012 – 2013 (mid- December). 4.1.4.2 Failure to adequately monitor the source, Biomonitoring should include: pathway and receptors relevant for the relevant potential Water quality (including major anions and hazardous constituents prevents the ability to sufficiently protect cations, pH, ICP scans for metals, TSS, the environment, animal and public health receptors. turbidity). These limited water quality analyses merely serve to inform the interpretation of biological data and do not constitute a detailed water quality monitoring programme. For the latter, please refer to the surface water specialist report.  Toxicity testing downstream of pollution control dams  Habitat Integrity

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 SASS5 and fish  Wetland Rehabilitation and/or erosion (e.g. of the Klipfonteinspruit)

Sampling sites should include sites, KS2, KS3, W3, W4, W5, W6, B1, B2, B3, B4, B Pan, with additional sites where relevant.

It is recommended that water quality monitoring (as part of the biomonitoring programme) be conducted every four months, with pH, Electrical conductivity, suspended solids and turbidity monitored weekly during the construction phase (or as recommended in the surface water assessment report). Norma Sharratt, Aquatic specialist 4 TPSA wishes it noted that the current direct impacts on the The specialist wetland assessment details the wetland systems and related catchments, contravene several present ecological status (PES) of all the schedules to Acts and stated objectives of the Government wetlands within and immediately adjacent to Departments and Provinces involved, and concern thus exists the various alternatives investigated. The PES that further impacts will add to this already unacceptable loss assessments (Section 6.4 of the wetland and burden. report) include consideration of current impacts and compare the current condition of the wetlands to the natural/pristine state of the wetland. The majority of wetlands in the area were rated as being moderately modified (PES category C) and largely modified (PES category D), indicating that many of the wetlands have already been considerably impacted and degraded by current land uses and activities, which include mining and energy related activities, as well as agriculture. Dieter Kassier, Wetland specialist 5 As noted in the background above, TPSA requires that the This matter, while applicable to Kusile power activities being undertaken, and related activities, do not impact station, is not relevant to the Kusile 60 year adversely on their operations, specifically in terms of air quality, ash project. It is thus recommended that TPSA water quality and quantity, and biosecurity. The proposed makes their submission to the Kusile EMC. monitoring programmes for the continuous ash disposal facility Tobile Bokwe, Eskom (in conjunction with the new 30 year facility) at Kendal Power Station are an example of the Eskom approach follows that does The EMPr and monitoring programmes

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not propose sufficiently protective monitoring programmes – proposed for the Kusile ADF must be seen as whilst it is recognized that this will be formulated in the EMPr, a living document, therefore it must be updated such proposals can only be adequate if the initial EIA monitoring as additional or more detailed information details the required constituents, as noted above. The same becomes available, and as findings and approach appears to have been followed for the KPS ADF. outcomes of monitoring programmes becomes available. Impacts for contaminants off-site must also be monitored at the downstream bound of the Kusile ADF site before it leaves the site, and within neighbouring properties as may be the case with air and noise pollution, and visual impacts. Monitoring recommendations for other Kusile construction activities must be addressed at the Eskom EMC. Monitoring requirements that was recommended by the groundwater and surface water specialist are presented below. Mathys Vosloo, EAP

Monitoring provisions included in the Groundwater Study Groundwater monitoring network should be installed before the commencement of any construction activities on site. Effective groundwater monitoring systems on a mine or ash disposal facility consist of the following components:  Surface water/groundwater quality monitoring system.  Flow/water level monitoring system.  Data and information management system.

When designing the monitoring system the following issues must also be taken into consideration:  Potential or actual water use;  Aquifer or catchment vulnerability;  Toxicity of chemicals;  Potential for seepage or releases; and  Quantities and frequency of release to the

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environment (point and non-point); and  Management measures in place to minimize risk.

Monitoring provisions included in the Surface Water Study In all cases an adequate surface water monitoring programme that would include biomonitoring must be put in place and implemented in such a way that as soon as pollution incidents occur or negative environmental trends are noticed rehabilitation will kick in. 6 As a downstream receptor, TPSA receives impacts from both Noted and considered during the EIA. the following related activities: Kusile Power Station, B&E Mathys Vosloo, EAP International Mining, Anglo American Inyosi Coal: New Largo Colliery and the Kendal Power Station. While this EIA considers cumulative impacts of all the projects, TPSA is encouraged to submit their issues with the projects and their engagement processes. The Kusile issues can be addressed through the EMC. Tobile Bokwe, Eskom 7 TPSA is located downstream of the KPS and NLC operations Noted and considered during the EIA. The and receives the Klipfonteinspruit on its south eastern boundary location of TPSA downstream of Kusile Power (25°54’50.14”S 28°52’51.91” entry point of the Klipfonteinspruit Station has been confirmed. onto TPSA property). Mathys Vosloo, EAP 8 In addition to the impacts described in the KPS EMC Monthly Noted and considered during the EIA. Surface and Groundwater Monitoring Reports by mining Mathys Vosloo, EAP activities noted in the upstream sections of the Klipfonteinspruit, the loss of wetland areas due to direct and indirect impacts are of serious concern to TPSA. 9 It has been noted in several documents pertaining to the New Although the projects are all related to Kusile Largo Colliery, Kusile Power Station, Kendal Power Station and power station, impacts and non-compliance related activities on Eskom Property, that the area is already issues related to the current Kusile Power heavily impacted upon by the coal mining and related activities Station construction site should be discussed to the power stations, and that it cannot receive any further and addressed at the Eskom EMC set up for pollutant load or afford to suffer the loss of any wetland areas. the Kusile Power Station development, and is currently active..

Impacts associated with the development of

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the ash disposal facility at site A must be managed to prevent or minimise pollutants offsite through implementation and compliance monitoring to the EMPr. Wetland areas downstream of site A and the Klipfonteinspruit and Holfonteinspruit will be rehabilitated to ensure the wetland system is improved and managed effectively. Dirty water from the ADF will be isolated and recycled thus preventing the release of contaminants into the environment. Clean water runoff from the catchment will be channelled in an artificial canal that features a reconstructed wetland system. Clean water will be monitored before release into the natural environment and will be released at pre-development flow rates, thus to prevent erosion and water quality deterioration. Eskom is also currently putting measures in place to deal with sedimentation and turbidity issues emanating from the construction site. Mathys Vosloo, EAP

Part 6.1.7: Cumulative Impacts It is a requirement that the impact assessments take cognisance of cumulative impacts. In fulfilment of this requirement the impact assessment will take cognisance of any existing impact sustained by the operations, any mitigation measures already in place, any additional impact to environment through continued and proposed future activities, and

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the residual impact after mitigation measures. It is important to note that cumulative impacts at the national or provincial level will not be considered in this assessment, as the total quantification of external companies on resources is not possible at the project level due to the lack of information and research documenting the effects of existing activities. Such cumulative impacts that may occur across industry boundaries can also only be effectively addressed at Provincial and National Government levels”.

Part 7.3: Cumulative Impacts “The cumulative impact assessment considers the project within the context of other similar land uses, in the local study area and greater regional context. Historical agricultural and mining practices over the past few decades have had detrimental effects on the surface water environment in the area. This is mainly attributed to fertilizer application, erosion, siltation and point-source discharges by wastewater treatment works (WWTWs) into the surrounding watercourses upstream of the Kusile Power Station site. The presence of several industrial and mining activities within one catchment may have severe effects on the surface water environment. The receiving water resource within the area is the Wilge River, which will soon experience significant water quality concerns if best management practices are not implemented. The Wilge River, a tributary of the Olifants River, flows northwards until it is joined by its main tributary, the Bronkhorstspruit River. The river then flows in a north-easterly direction until it joins the Olifants River upstream of the Loskop Dam. Given the fact that the Olifants River feeds into several water supply storage

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facilities utilised by local settlements, the impact of deteriorating water quality, which makes the water less fit for use, has significant environmental as well as social and economic implications. Due to the fact that several upstream impacts are already occurring when considering significance rating for cumulative impacts for each of the proposed sites, the impact class will not change considerably compared to those shown in Table 16. However, should mitigation be put in place then the local cumulative impacts would reduce the significance rating for the local area but may not have much of a positive impact on the broader catchment.” Mathys Vosloo, EAP

The loss of wetland habitat is indeed a concern. The wetland report details the likely direct impact on wetlands of the various alternatives considered, as well as the indirect impact to adjacent wetland areas. Given the size of the ash disposal facility required (approximately 1000 ha), it is considered highly unlikely that a site of this size could be identified on the Mpumalanga Highveld where no impact to wetlands will occur, let alone within close proximity to Kusile Power Station. It is recommended that the unavoidable loss of wetland habitat be offset through a wetland offset strategy guided by the best-practice guideline recently developed by SANBI and the DWA (Macfarlane et al., 2014), and that at least a substantial portion of the offset is located within the same affected sub- catchments as the wetland loss. Specifically the management and maintenance of the Klipfonteinspruit wetland downstream of the Kusile ADF and Kusile Power Station should form a focus of such an offset strategy.

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Dieter Kassier, Wetland specialist 10 The Aquatics Report (Appendix F2) refers: MEYER, Dr James Letter: 08 The EAP fails to see how the statement quoted Some of the comments presented are unsubstantiated and TOPIGS SA (Pty) Ltd September 2014 from the Aquatic Report “significantly contradict those made by specialists reporting to the KPS EMC. contradicts” findings of studies presented in An example of this is found in Section 14.1: Status Quo, where it the EMC. Section 14.1 of the Aquatic report is observed that: “The main current impacts to surface water are refers to land use associated with the site B related to agriculture. The Ash Disposal Facility footprint covers alternative footprint as investigated by the an area that is commercially cultivated and irrigated. specialists. Site characteristics are indeed that Construction activities related to the Kusile Power Station, as surface water impacts on or close to the site is well as mining-related water quality impacts were evident within dominated by agricultural activities, as site B is the Klipfonteinspruit”. almost exclusively under commercial cultivation and grazing by livestock. This significantly contradicts the specialist reports on the aquatic Furthermore it is not disputed in the least that ecosystem, monthly surface and groundwater monitoring impacts from the Kusile Power Station reports, and Turbidity Management Strategy presented by the construction site impacts on the surrounding KPS, in which the impacts of the KPS Construction activities and water courses as has been found by other mining and related activities are acknowledged – refer the monitoring reports and other studies. following that demonstrated the continued impact of KPS on the Mathys Vosloo, EAP surrounding water resources:  KPS EMC Reports  Section 1.5.1.7 above Section 14.a refers specifically to Site  Kusile Power Station Turbidity Management Strategy – Alternative B. As such the footprint of the ash Prime Africa: dated: 05.02.2014 disposal facility covers mainly cultivated land. Recent KPS Notification of Events (22 July 2014 and 12 August The conveyor to Alternative B will cross the 2014). Klipfonteinspruit and the Wilge River which are currently impacted by the KPS and mining. Section 14.1 has been amended (see below) to clarify this. This section refers only to Alternative B and excludes Alternative A.

Our understanding is that the KPS biomonitoring reports did not include the area covered by Alternative B, nor all the watercourses draining Alternative B, but were focused mainly on the KPS tributaries and Wilge River.

14.1 STATUS QUO: Alternative B The area that has been identified as a potential location for the Alternative B ash dam, covers

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an area that is currently under commercial cultivation and irrigation. As such, the current impacts to water resources within the area identified for Alternative B are agriculture (abstraction, fertilisers, farm dams, etc.). The area is situated at the top of two catchments and includes at least one spring and a number of drainage lines that drain into the Bronkhorstspruit and Wilge River. The conveyor to site Alternative B, however, will cross the Klipfonteinspruit and Wilge River. The water quality and habitat integrity of the Klipfonteinspruit and Wilge River are currently impacted by the Kusile Power Station, various mining activities and road crossings, together with some minor agricultural impacts (e.g. farm dams). Norma Sharratt, Aquatic specialist 11 Section 6.11 of the DEIR refers. In the functional assessment it MEYER, Dr James Letter: 08 The literature and guidelines that were referred is noteworthy that no reference to the Mpumalanga Biodiversity TOPIGS SA (Pty) Ltd September 2014 to by the Wetland Specialist’, are provided in Conservation Plan Handbook (Ferrar & Lotter, 2007) can be Part 11 of the Wetland Delineation and found. It is submitted that this is a fundamental requirement in Assessment Study. The Mpumalanga order for the competent authority to consider the application Biodiversity Conservation Plan Map (Ferrar & appropriately and must be stipulated for the studies that follow. Lotter, 2006) is included in the list of references provided in Part 11 of the Wetland Delineation and Assessment Study (refer to Appendix F15 of the final EIR). Therefore even though the wetland specialist report did not specifically reference the conservation plan in the text, it was considered by the specialist as this forms one of the key bioregional plans that manages biodiversity in Mpumalanga. Mathys Vosloo, EAP

The functional assessment undertaken as part of the specialist wetland report (WCS, 2014, Report Reference 913/2012) was based on the WET-EcoServices methodology (Kotze et al., 2009). However, the specialist wetland report has been updated to include reference to the

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Mpumalanga Biodiversity Conservation Plan Handbook (Ferrar & Lotter, 2007) and the more recently compiled Mpumalanga Biodiversity Sector Plan, for which no handbook as yet been published. Please refer to Section 4.5 of the specialist wetland report. Dieter Kassier, Wetland specialist 12 Valley bottom and seepage wetlands occur in the area and the MEYER, Dr James Letter: 08 Refer to Section 4.3 and Section 6.1 for the Status of these River Ecosystems are Critically Endangered and TOPIGS SA (Pty) Ltd September 2014 different type of wetlands identified in the area Endangered with the sub-catchment health or integrity and the current conservation status of the significantly modified and falling within a sub-catchment required wetland types and wetland vegetation groups. for meeting aquatic biodiversity targets and noted as having Floodplain, valley bottom and depression (pan) areas of highly significant and important and necessary areas in wetlands falling within the Mesic Highveld the biodiversity assessment categories. Grassland Group 4 wetland ecosystem type are all classified as Critically Endangered and seeps as Endangered (National Biodiversity Assessment 2011: Freshwater Component (Nel et al., 2011b). Dieter Kassier, Wetland specialist 13 The Wetland Offset Mitigation Strategy should be made MEYER, Dr James Letter: 08 A draft wetland offset framework was available to TPSA immediately and a clear contractually binding TOPIGS SA (Pty) Ltd September 2014 presented in the DEIR. This process of commitment made in this regard in which the proposed National developing a comprehensive wetland offset Wetland Offset Guidelines are effected, including, but not limited plan, with consultation from the Department of to, issues such as Stakeholder Participation, Securing of Land, Water Affairs (now Department of Water and and the Assessment of Financial Implications. Sanitation) and SANBI, will be undertaken in the Water Use Licence Application phase, which is only kicking off at this stage of the EIA process. The wetland offset plan has therefore not yet been drafted, however consultation with key stakeholder will be undertaken during the WULA where the wetland offset plan will be made available for comment by key stakeholders. Mathys Vosloo, EAP 14 TPSA notes that the primary justification of the proposed 60 year MEYER, Dr James Letter: 08 A draft wetland offset framework was ADF for the KPS makes note of a “Wetland Offset strategy” and TOPIGS SA (Pty) Ltd September 2014 presented in the DEIR. This process of that this is also noted in the AAIC NLC EIA and EMPr developing a comprehensive wetland offset undertakings, yet TPSA notes that: plan, with consultation from the Department of  No corresponding appropriate stakeholder participation Water Affairs (now Department of Water and has occurred. Sanitation) and SANBI, will be undertaken in

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 Only references to a “Draft Wetland Offset Mitigation the Water Use Licence Application phase, Strategy” are made, with the actual document not which is only kicking off at this stage of the EIA available. process. The wetland offset plan has therefore  No specialist was present at the FGM or PPM in which the not yet been drafted; however consultation detail of this strategy could be provided. with key stakeholder will be undertaken during the WULA where the wetland offset plan will TPSA wishes thus to note that it requests that the be made available for comment by key comprehensive documentation be provided and the required stakeholders. stakeholder participation be conducted, as would be reasonably Mathys Vosloo, EAP expected and prescribed by the relevant SANBI / DWS National Wetland Offset Guidelines, before the DEIR can be considered The I&AP’s attention is drawn to the fact that sufficiently complete to submit to the authorities for the Wetland Delineation and Impact Study was consideration. intended to identify wetlands within the study area and to determine and evaluate anticipated wetland impacts. The implementation of wetland offsets and rehabilitation of offsite wetlands is proposed in the Wetland Delineation. The recommendations provided by the Wetland Specialist relating to wetland offsets should serve as point of departure for the implementation of such a strategy and will form the basis for the development of a comprehensive wetland offset strategy for Kusile Power Station in the WULA phase.

The following extract relating to the implementation of wetland offset is provided in Part 9.3.1 of the Wetland Delineation and Impact Study: “The following extract taken from Part Undertake a wetland offset study to investigate the possibility of mitigating the loss of wetland habitat on Site A through the rehabilitation and protection of wetlands elsewhere:

 Such an offset should ideally be located within the same catchment;  A potential target wetland for rehabilitation is the Klipfonteinspruit system downstream

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of the proposed ash disposal facility site. This system already receives most of the storm water discharges from Kusile Power Station and will require management interventions as it is already on a negative trajectory of change;  That wetland offsets and rehabilitation of offsite wetlands be investigated to compensate for the loss of wetland habitat within the Site A footprint. In this regard the development and implementation of a management plan for the Klipfonteinspruit could be considered, while it is known that wetlands within Site C have already been identified as potential rehabilitation targets”. 15 The proposed National Wetland Offset Guidelines refer: MEYER, Dr James Letter: 08 A draft wetland offset framework was  No detail with regard to the Stakeholder Participation TOPIGS SA (Pty) Ltd September 2014 presented in the DEIR. This process of Process can be found in the DEIR or related developing a comprehensive wetland offset documentation that accord with these guidelines; plan, with consultation from the Department of  No detailed report (even in Draft form) has been presented Water Affairs (now Department of Water and to the I&APs with which to justify the proposed activity; and Sanitation) and SANBI, will be undertaken in Clear identified acceptable offsets have not been communicated the Water Use Licence Application phase, to TPSA. which is only kicking off at this stage of the EIA process. The wetland offset plan has therefore not yet been drafted, however consultation with key stakeholder will be undertaken during the WULA where the wetland offset plan will be made available for comment by key stakeholders. Mathys Vosloo, EAP

The draft wetland offset strategy was not compiled by WCS, but rather by Prime Africa Consultants. Please refer all questions regarding the wetland offset strategy directly to Prime Africa. However, a number of comments regarding the need for a wetland offset strategy are made in the specialist wetland assessment report (WCS, 2014, Report

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Reference 913/2012). To highlight some of the most important recommendations made in this regard, some of these are repeated here:

 Wetland offsets and rehabilitation of offsite wetlands should be investigated to compensate for the loss of wetland habitat within the Kusile ADF footprint. In this regard the development and implementation of a management plan for the Klipfonteinspruit could be considered.  Any offset project should be undertaken according to the offset guidelines which are currently being updated by SANBI.  Wetland offsets should ideally be located within the same catchment.  A potential target wetland for rehabilitation is the Klipfonteinspruit system downstream of the proposed ash dam site. This system already receives most of the stormwater discharges from Kusile Power Station and will require management interventions as it is already on a negative trajectory of change.  Include Red Data species and suitable habitat in offset considerations.  Any offset project should be undertaken according to the offset guidelines which are currently being updated by SANBI.  Any proposed offset strategy should link into the existing offset commitments to ensure a consolidated overall strategy rather than adopting a piecemeal approach Dieter Kassier, Wetland specialist 16 No detail on any commitment by KPS / Eskom regarding the MEYER, Dr James Letter: 08 No Wetland Offset Strategy for the proposed following could be found: TOPIGS SA (Pty) Ltd September 2014 Kusile Power Station 60 Year ADF Project has  Securing land; and been drafted nor approved by the DWS. The Assessing the financial implication of the offset strategy. I&AP’s attention is drawn to the fact that the Wetland Delineation and Impact Study was

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intended to identify wetlands within the study area and to determine and evaluate anticipated wetland impacts.

A draft wetland offset framework was presented in the DEIR. This process of developing a comprehensive wetland offset plan, with consultation from the Department of Water Affairs (now Department of Water and Sanitation) and SANBI, will be undertaken in the Water Use Licence Application phase, which is only kicking off at this stage of the EIA process. The wetland offset plan has therefore not yet been drafted, however consultation with key stakeholder will be undertaken during the WULA where the wetland offset plan will be made available for comment by key stakeholders. Mathys Vosloo, EAP 17 It is appreciated that any Wetland Offset Strategy is a last resort. MEYER, Dr James Letter: 08 The comments provided by the I&AP is noted. It remains thus unfortunate and unacceptable that the KPS / TOPIGS SA (Pty) Ltd September 2014 With the comment largely aimed at the Eskom initial authorization granted could thus be based on the authorisation of the Kusile Power Station itself provision of specialist calculations and predictions that at its current location, it is unfortunate that miscalculated the required ADF to such a significant margin that wetland offsets as a last resort has to be then culminated in a preferred site selection that will cause considered for the placement of the ADF. It is irreparable damage to such a key national resource. however a reality that must be dealt with, and to ensure that the best possible solution for the environment and sustainable development is found specialist recommendations must be followed and implemented. Mathys Vosloo, EAP 18 Additionally, TPSA takes note of the challenges to such a MEYER, Dr James Letter: 08 The comments provided by the I&AP is noted. strategy, including: TOPIGS SA (Pty) Ltd September 2014 The EAP will guide development of the  The DWA (now the DWS) has not officially endorsed the wetland offset strategy with significant input Guidelines. from the DWS, SANBI and wetland specialist The offset is seen as a “resource” that could be offset at any appointed for the project. appropriate geographical location and will not be stipulated by Mathys Vosloo, EAP the authorities to a specific land portion or property. 19 It follows that TPSA has no guarantee that should the 60 year MEYER, Dr James Letter: 08 The wetland offset strategy is one of the key ADF site be authorized based on a wetland offset strategy KPS / TOPIGS SA (Pty) Ltd September 2014 mitigation management measures that will be

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Eskom will employ such a strategy in the surrounding areas, and required by the Department of Water Affairs may in fact comply with authorization conditions by applying the and Sanitation, before approval of the Water mitigation measures elsewhere. Use License (WUL). Compliance with the wetland offset plan and conditions of the authorisation will be strictly enforced by the competent authority. Mathys Vosloo, EAP 20 It follows that the mitigation measures are crucial to the entire MEYER, Dr James Letter: 08 The EAP concurs with the importance of the process. Section 11 of the DEIR notes that: “The greatest TOPIGS SA (Pty) Ltd September 2014 implementation of mitigation to manage the negative impact of Site A is the direct destruction of 227 ha of environmental impacts associated with the wetlands within the development footprint, which can however proposed project. be mitigated through an extensive offset mitigation strategy that Sharon Meyer-Douglas, EAP is implementable for the entire Kusile Power Station development and is accepted by Eskom.” 21 The drinking water is of good quality and any mining operations VAN DALEN, Lenert Letter: 07 January There are existing mining operations upstream will have great impact. Landowner: Farm 2014 on the Kusile Power Station. With site A being Witklip identified as the preferred site alternative, impacts on water resources close to the Kusile Power Station is possible. The surface water quality at and upstream of the preferred site alternative A has been found to be impacted by agricultural and industrial activities adjacent and upstream of the preferred site by the hydrology and water quality specialist report (see Appendix F for all water related specialist studies). Therefore a comprehensive water quality management plan will have to be implemented to minimise impact on water resources. The DEIR found that proposed mitigation measures to protect water quality impacts can successfully be implemented, as recommended by the relevant specialists, thereby minimising the potential impact on water resources adjacent to preferred site alternative A. Mathys Vosloo, EAP 22 The affected areas fall within the Water Management Area with MEYER, Dr James Letter: 08 The EAP concurs with this statement and the the Wilge river the main drainage river and noted by GDARD TOPIGS SA (Pty) Ltd September 2014 importance of the Wilge River in the catchment (2009) as a priority catchment area for conservation of wetland has also been emphasised by the DWS. and aquatic biota. Mathys Vosloo, EAP

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Appropriate mitigation measures have been recommended, and must be implemented. Tobile Bokwe, Eskom

The Kusile Power Station and alternative A for the Kusile ADF fall within the Mpumalanga Province, with only Site B falling entirely within Gauteng. The remaining alternatives fall across the provincial boundary. However, GDARD (GDARD REQUIREMENTS FOR BIODIVERSITY ASSESSMENTS VERSION 2, 2012) includes quarternary catchment B20F on its list of priority catchments. In the Gauteng C- Plan (2011), the Wilge River quarternary catchment is further highlighted as a near- pristine catchment with the river categorized in an ecological category B. In order to maintain the river in this state, GDARD (2011) recommend that “at least 59% of the quaternary catchment must remain untransformed”. They further describe B category rivers as “Largely natural with few modifications. A small change in natural habitats and biota may have taken place but the ecosystem functions are essentially unchanged”. The importance of the Wilge River and its catchment is clear from the above, and this importance is recognized and highlighted in the wetland specialist report, contributing also to the selection of Site A as the preferred locality for the Kusile ADF. All site alternatives considered for the Kusile ADF fall within the Wilge River catchment, though Site B also falls within the Bronkhorstspruit catchment (the Bronkhorstspruit is itself a tributary of the Wilge). 23 Will the water be monitored? SMITH, Gert, Agri DEIR Public One of the mitigation measures included in the Mpumalanga Meeting, 20 August EMPr is that Kusile Power Station (KPS) must 2014 ensure regular water monitoring.

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Mathys Vosloo, EAP

Post meeting note: The project has applied for an Integrated Waste Management Licence and a Water Use Licence, both of these licences, if acquired, will have conditions for water monitoring. Mathys Vosloo, EAP

2.5 Agricultural Related Comments 1 There are a number of farming operations in the surrounding VAN DALEN, Lenert Letter: 07 January Site alternative A has been identified as the areas that will be affected & Bronkhorstspruit dam is close to as Landowner: Farm 2014 recommended preferred alternative. All the well. Witklip properties affected by site A are owned by 2 Our top soil on the farm is of high quality, we plant maize and Eskom, therefore there will be no direct the average we harvest is 8 tons per Ha which is very good. impacts on existing farming operations. A There will be a loss of income before we can harvest and then comprehensive Environmental Management plant again for food as well as income. Programme will also be implemented to avoid 3 ± 800 pigs as well as a number of cattle on the farm cannot be or at the very least minimise any potential re-located due to stress. indirect impacts on agricultural activities in the vicinity of the ash disposal facility. In the event the competent authority reject the EAP’s recommended site – Site A – and authorise another site alternative, then the land owner negotiation process will commence. Construction of the ADF should only commence once successful negotiations has been concluded with all affected land owners. Mathys Vosloo, EAP

2.6 Cumulative Impacts Related Comments 1 It has been noted in several documents pertaining to the New MEYER, Dr James Letter: 08 The following extract which provides summary Largo Colliery, Kusile Power Station, Kendal Power Station and TOPIGS SA (Pty) Ltd September 2014 of the approach that was taken for assessing related activities on Eskom Property, that the area is already the anticipated surface water impacts, heavily impacted upon by the coal mining and related activities illustrates that that the existing impacts were to the power stations, and that it cannot receive any further taken into account (refer to Part 6.1.7 and pollutant load or afford to suffer the loss of any wetland areas. Part 7.3 of the Surface Water Study included as Appendix F11 of the Final EIR) :

Part 6.1.7: Cumulative Impacts

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It is a requirement that the impact assessments take cognisance of cumulative impacts. In fulfilment of this requirement the impact assessment will take cognisance of any existing impact sustained from the operations, any mitigation measures already in place, any additional impact to environment through continued and proposed future activities, and the residual impact after mitigation measures. It is important to note that cumulative impacts at the national or provincial level will not be considered in this assessment, as the total quantification of external companies on resources is not possible at the project level due to the lack of information and research documenting the effects of existing activities. Such cumulative impacts that may occur across industry boundaries can also only be effectively addressed at Provincial and National Government levels”.

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A new section discussing cumulative impacts in more detail has been added to the specialist wetland report in Section 9.5 of the report. This includes a map showing the location of the various projects in relation to each other as well as the major water resources of the area. Dieter Kassier, Wetland specialist 2 Section 11 of the DEIR contains the following statement that MEYER, Dr James Letter: 08 Based on the results of the EIA Phase in seemingly recognizes the severity of the cumulative impacts yet TOPIGS SA (Pty) Ltd September 2014 particular the significance of the anticipated provides an EAP opinion that fails to provide any substantive impacts as well as the extent to which these evidence for exactly how the conclusion is then reached that the impacts can be mitigated to fall within an impacts will or can be appropriately mitigated: “acceptable level” formed the basis of the Environmental Assessment Practitioner

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Opinion provided in Part 11 of the FEIR. Although it is the opinion of the EAP that EA be granted for the implementation of the proposed Kusile Power Station 60 year ADF Project it is also recommended that EA be subjected to the stringent adherence to the mitigation which have been provided. Mathys Vosloo, EAP

2.7 Specialist Studies Comments 1 According to the DWA “Practical field procedure for the MEYER, Dr James Letter: 08 Wetlands were identified and delineated identification and delineation of wetlands and riparian areas” TOPIGS SA (Pty) Ltd September 2014 according to the delineation procedure as set (Edition 1, Sept 2005) it notes that: Mining is one of the main out by the “A Practical Field Procedure for the culprits responsible for the observation that in some catchments Identification and Delineation of Wetlands and over 50% of the wetland has already been destroyed, and the Riparian Areas” document, as described by DWA cannot allow wetland destruction to continue and that their DWAF (2005) and Kotze and Marneweck protection is required to regulate water resources. (1999). Using this procedure, wetlands were identified and delineated using the Terrain Unit Indicator, the Soil Form Indicator, the Soil Wetness Indicator and the Vegetation Indicator.

Wetland resources in the Mpumalanga Province and especially the catchment in question are under pressure from being severely impacted or destroyed. Assessment of developments will therefore have to be carefully considered and high confidence level recommendations followed to protect the remaining wetlands. For the Kusile Power Station to become operational an ash disposal facility will have to be constructed to ensure environmental responsible disposal of the ash produced during the electricity generation process. Therefore assessment of the development of the ADF must be undertaken based on sustainable development principles to ensure the best possible option for the environment is chosen. The consolidated assessment and recommendations from all

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specialist studies have cumulatively resulted in the identification of site A as the preferred alternative, even given the fact that 227 ha of wetlands will be compromised. It is therefore of utmost importance that mitigation and management measures be successfully implemented and monitored if authorisation of site A is granted by the competent authority. Mathys Vosloo, EAP

It is widely recognized that mining, especially opencast mining, can have a significant impact on the environment and especially wetlands and water resources. Current water quality concerns within the Upper Olifants River attest in part to this. Wetlands falling within the direct footprint of opencast mining activities will be permanently lost, while opencast mining also alters the behaviour of water in the landscape and can therefore also impact on adjacent wetlands. The importance of protecting and maintaining remaining wetland areas as part of the protection and management of water resources is recognized and acknowledged. Dieter Kassier, Wetland specialist 2 The Mpumalanga Biodiversity Conservation Plan Handbook MEYER, Dr James Letter: 08 The reference made by the IA&P to the (Ferrar & Lotter, 2007) notes that: “The conservation of this TOPIGS SA (Pty) Ltd September 2014 Mpumalanga Biodiversity Conservation Plan biodiversity and the ecosystem services that it delivers is Handbook (Ferrar & Lotter, 2007) is noted. A recognized as a legitimate and sustainable form of land use” number of Specialist Studies were carried out MEC Economic Development and Planning, MP. The MBCP to determine the land use activities suggests that “Irreplaceable, Highly Significant and Important surrounding the proposed Kendal Power and Necessary” areas should remain unaltered and be managed Station including the Soil and Land Capability by biodiversity”. Aquatic Ecosystems (rivers and wetlands) are Study (refer to Appendix F10 of the Final EIR) South Africa’s most important ecosystems. and Sustainability Study (refer to Appendix F12 of the Final EIR). Mathys Vosloo, EAP

2.8 Mining Right Related Comment 1 Mining and prospecting rights were disowned by government FOURIE, John E-mail:05 March It is my understanding that the landowner and allocated to whoever applied successfully. (SEE: Team Leader 2014 should know or be informed of who owns the

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Finance mining right to his property, and a consultation The landowner has no knowledge of who these rights were process is followed for prospecting and mining allocated to. right applications. In the mining related authorisation processes, also the landowner is informed by the consultancy who is conducting the consultation process of the application. Nicolene Venter, PPP (e-mail 05 March 2014)

2.9 GIS / Maps Related Comments / Requests 1 Requested a locality map of the proposed sites in relation to SINGER, David E-mail: 12 May With reference to my e-mail below, I would like their company’s property. 2014 to follow-up whether you had an opportunity to provide us with your company’s property details. I require the information so that I can send you the relevant map. Nicolene Venter, PPP (e-mail: 29 May 2014) Would you be so kind as to provide us with your company’s property details - you are most welcome to complete the attached form which will assist us. Thanking you in advance for the information. Nicolene Venter, PPP (e-mail: 12 May 2014)

2 Requested dgn/dxf files of the site alternatives for the ash SMITH, Cindy E-mail: 29 May The requested information was e-mail on 30 dumps. Environmental 2014 May 2014. Specialist: Mathys Vosloo, EAP Anglo-American

2.10 Kusile Power Station Related Comments 1 TPSA refers to previous comments and documentation MEYER, Dr James Letter: 08 The holder of the EA is required to ensure that submitted to Eskom/Kusile Power Station, Zitholele Consulting, TOPIGS SA (Pty) Ltd September 2014 all reasonable steps are taken to ensure and Competent Authorities, regarding the current construction compliance with the conditions of the EA. activities and proposed operational activities at the KPS in terms Regulation 69 of the NEMA EIA of: Regulations (2010) provides the Competent  Lack of meaningful response by the required authorities Authority with the mandate to take specific to ensure compliance to these conditions and various steps in the event where contravention with the licences and authorisations granted. EA conditions are suspected. The EAP can however not provide comment on the internal

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procedure adopted by the Competent Authority to monitor compliance. Mathys Vosloo, EAP

Also, it is recommended that the issues be directed to Kusile power station as they are more relevant to it than to the ash disposal facility Tobile Bokwe, Eskom 2 TPSA refers to previous comments and documentation MEYER, Dr James Letter: 08 Various Environmental Authorisation submitted to Eskom/Kusile Power Station, Zitholele Consulting, TOPIGS SA (Pty) Ltd September 2014 Processes have been carried out for numerous and Competent Authorities, regarding the current construction aspects / elements of the Kusile Power activities and proposed operational activities at the KPS in Station. The Environmental Authorisation terms of: Process (S&EIR Process) that has been  Unacceptable impacts on the environment and carried out for the project at hand (i.e. receiving water resources by storm water runoff from proposed project) however relates specifically KPS. to the construction of the Kusile Power Station 60 year ADF project. The baseline environmental description provided in Part 7 of the final EIR provides an overview of the current environmental conditions. Furthermore the baseline environmental description provided, also serves as a point of reference for determining the environmental consequences of the proposed 60 year ADF and associated project activities.

Part 7.7.4 of the final EIR provides a description of and method used to determine the baseline water quality. The concentration of the various water quality parameters was indicative of the impact of the surrounding land uses on the surface water resources. The surface water study however does not refer specifically to the impact of storm water runoff from the current Kusile Power Station construction on the associated surface water resources. Taking the aforementioned into account, the EAP cannot provide comment nor confirm that storm water runoff from the

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existing construction area have entered adjacent watercourses. Mathys Vosloo, EAP

It is still recommended that the issues be submitted to the appropriate project, and not to the ash disposal facility EIA process. Tobile Bokwe, Eskom 3 It is of great concern to TPSA that despite clear recognition of MEYER, Dr James Letter: 08 Ensuring compliance with the conditions the failure to adhere to the licence and RoD conditions, KPS TOPIGS SA (Pty) Ltd September 2014 contained in the Environmental Authorisation continues to impact the environment without implementing the (EA) issued for elements / activities of the recommended measures. The Contamination Study was Kusile Power Station remains with the holder completed in the 3rd Quarter of 2013, yet at the June 2014 KPS of the EA (Eskom SOC Limited). EMC it was acknowledge that the recommendations have not Mathys Vosloo, EAP been implemented due to “budgetary constraints in Eskom”. TPSA must follow the existing communication channels with the Kusile power station construction to address these issues. Tobile Bokwe, Eskom 4 It follows that the I&APs are concerned as to whether Eskom MEYER, Dr James Letter: 08 Ensuring compliance with the conditions can implement the mitigation measures that are essential (refer TOPIGS SA (Pty) Ltd September 2014 contained in the Environmental Authorisation to DEIR Section 11 EAP Opinion) to the authorisation of the 60 (EA) issued for elements / activities of the year ADF. Kusile Power Station remains with the holder of the EA (Eskom SOC Limited). Regulation 31(2)(n) of the NEMA EIA Regulations (2010) requires the EAP to provide a reasoned opinion as to whether the activity should or should not be authorised, and if the opinion is that it should be authorised, any conditions that should be made in respect of that authorisation. The EAP can however not provide comment on the capability of Eskom to implement the recommended mitigation measures and EA conditions, but it is reasoned that Eskom will comply with conditions of the EA being a responsible public entity that exercise the duty of care principle as part of the environmental responsibility policy. Mathys Vosloo, EAP

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5 TPSA maintains that its operations will not be able to continue MEYER, Dr James Letter: 08 The air quality specialist has concluded that without significant adverse impacts from the required 60 year TOPIGS SA (Pty) Ltd September 2014 with the recommended mitigation in place air ADF. quality impacts would not be significant beyond the ADF footprint. Water quality impacts were also found not to have a major impact if mitigation measures were implemented correctly. It is thus not expected that TPSA operations will suffer significant adverse impacts due to operation of the ADF. Monitoring stations in the vicinity of the TPSA operations should be maintained to monitor levels of pollutants at the specific locations. Mathys Vosloo, EAP

2.11 Communication / Consultation Comments 1 The invitation to attend a Focus Group Meeting and relevant MEYER, Dr James Letter: 08 The comment is acknowledged and noted. DEIR documentation was received by TOPIGS SA (Pty) Ltd TOPIGS SA (Pty) Ltd September 2014 Nicolene Venter, PPP (TPSA) Zitholele Consulting on 12 August 2014. 2 The Focus Group Meeting was attended on 20 August 2014 by The list of all stakeholders who attended the Dr JA Meyer, representing TPSA. Focus Group Meeting held on 20 August 2014, is included in the draft Minutes of the meeting (refer to Appendix C6 of the final EIR). Nicolene Venter, PPP 3 TPSA would also like to object to the fact that despite numerous All questions relating to the findings of the specialists having been involved and contracted to compile the various specialist studies posed by I&APs reports presented in the DEIR documentation made available, during the public meeting were included in the none of them were present during either of these two meetings. Public Meeting Minutes (refer to Appendix C6 This is seen as a major flaw that prevents key technical of the final EIR). In the instance where the questions from being answered fully. It transpired that questions EAP cannot provide a response to any of the asked were generally dealt with by blanket statements of “it will specialist studies, the comment / question be seen to” or “the specialists will attend to it”. This is raised by the I&AP has been submitted to the unsatisfactory for those taking the time to read the relevant specialist who, in turn, provided documentation and attend the meeting, notably for the Focus written feedback to the I&AP, either directly or Group Meeting, where it would have been prudent and in the CRR. reasonable to expect the specialists to be present to answer the Mathys Vosloo, EAP key concerns. 4 It is noteworthy that in the Site Selection and Screening Report The team acknowledges the reference to the (Appendix G of the DEIR), no specific mention is made of the omission of the inclusion of TOPIGS SA’s detail communicated by TPSA regarding the operational comments not included in the relevant PP requirements of the TOPIGS SA Genetics Facility, the Appendix. However, it is confirmed that the

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significance of TPSA in terms of the stability of the pork industry comments raised by TOPIGS SA to date is in South Africa and its major trading partners within the SACU included in the CRR. members. This is a significant omission that extends to the Kendal Poultry Farm and Breeder Farms, which these activities The site selection process is undertaken not simply poultry or pig farms or farming activities, but key during the initial stages of the project with breeder operations with high biosecurity requirements and available fine-scale and desktop information sensitive intensive operations requiring a high level of available at the time. Agricultural activities environmental management in order to maintain and realize the were considered in this light to help identify genetic potential inherent in the production systems. The land which site can be identified in more detail use activities and subsequent matrix results in the site selection through detailed specialist studies. What is do not appear to have engaged to a sufficient degree for these more important is to consider TPSA operations sensitive receptors to have been included or considered during the detailed site investigations that appropriately. It is accordingly insisted that these operations be followed the site selection process. comprehensively engaged and their operational environment assured with in the studies that follow. What is prudent for TPSA operations is that the development does not significantly impact on the commercial operations from the ADF development. Relevant specialist studies concluded that with implementation of mitigation measures and monitoring impacts will be mitigated to within acceptable levels and mostly confined to the development footprint. Potential impacts on water resources can with high confidence be managed through the identified mitigation measures, while air quality impacts can be confined to the site footprint given successful mitigation management.

Potential impacts emanating from TPSA were also considered as part of the cumulative impacts within the catchment.

The aquatic study for example reported the following: “Recorded at sites W2, W4 and W5 is taxon Cocconeis placentula (significantly more at site W4) indicative of nutrient enrichment which may be a result of agricultural inputs from fertilisers or runoff from livestock feedlots. W4 lies adjacent to Toppigs

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piggery.”

Site A was identified as the alternative which would result in the lowest inferred ecosystem cost as well as the lowest cost alternative to Eskom and electricity users. Furthermore the construction of the ADF on Site A will reduce the number of required dirty water dam controls (one only on the Klipfonteinspruit, more than 6.5 km from the Wilge River) thereby reducing the risk of water pollution and optimising the ability to mitigate impacts before reaching the Wilge River. The comparative alternative assessment provided in Part 8 of the FEIR explains the implications of each of the potential site alternatives, as well as the rationale for selecting Site A as the preferred Site Alternative. Mathys Vosloo, EAP 5 B Vorster, representing TPSA, also attended the Public The list of all stakeholders who attended the Participation Meeting, held on 20 August 2014 at El Toro EIA Phase Public Meeting held on 20 August Conference Centre Kendal at 18:00. 2014, is included in the draft Minutes of the meeting (refer to Appendix C6 of the final EIR). Nicolene Venter, PPP 6 During these meetings both Dr JA Meyer and B Vorster Verbal acknowledgement was given to the submitted written comments to the Zitholele Chair and noted that stakeholders upon receipt of the written a document would be submitted on 08 September 2014. comments and also acknowledged via e-mail on 08 September 2014 (refer to Appendix C2 of the final EIR). Nicolene Venter, PPP 7 TPSA refers to previous comments and documentation The baseline conditions (status quo) of the submitted to Eskom / Kusile Power Station, Zitholele Consulting, receiving environment (refer to Part 7 of the and competent authorities, regarding the current construction final EIR) served to provide a reference activities and proposed operational activities at the KPS in which according to which the significance of the unacceptable delays in communicating significant health risks to environmental consequences of the proposed the Interested and Affected Parties (I&APs) linked to these project can be determined. activities as evidenced by the monitoring and assessment conducted for the KPS. The stakeholder’s comments regarding communications shortcomings between Eskom

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and land owners is acknowledged, however the EAP cannot comment further as these issues falls outside the scope of this project (Kusile PS 60 yr ADF) and the EAP has no knowledge, other than described by the stakeholder, of the mentioned shortcomings. Mathys Vosloo, EAP 8 Is dit nie die week van die nuus nie? MOLL, Andreas E-mail: 24 June Die finalisering van die verslag (Konsep Landowner: Farm 2014 Omgewingsimpakverslag – DEIR) het ietwat Translation: Jakhalsfonteint langer geneem as verwag en is in die laaste (Bio-Select) fase van finalisering. Is this not the week of the news? Ek sal jou persoonlik in kennis stel sodra die verslag gereed is – ek sal jou ook kontak wanneer ons na vergaderingsdatums kyk, veral die fokusgroepvergadering met grondeienaars.

Translation: The finalisation of the report (Draft Environmental Impact Report – DEIR) has taken somewhat longer than expected and is in the last phase of finalisation.

I will notify you personally as soon as the report is ready – I will also contact you when we look at dates for the meetings, especially the focus group meeting with landowners. Nicolene Venter, PPP (e-mail 24 June 2014) 9 Kindly note that the Sub-Directorate: Environment and MUTHRAPARSAD, E-mail: 18 The DWA Regional Office (Mpumalanga) is Recreation does not accept documents via email due to tracking Namisha December 2013 registered on this proposed project as a purposes. Furthermore, the entry point is the Regional Office DWA commenting authority and Reports have been and not Head Office directly. Kindly liaise with the Regional and will be delivered to them for comment. Office fur further assistance. DWA National is also registered on the project database to ensure that they are informed regarding the proposed project. Nicolene Venter, PPP 10 Dankie vir die OIE Nuusbrief ontvang. Versoek afskrif van die PIENAAR, Hennie E-mail: 26 February Finale Bestekopnameverslag kan van die omgewingsimpakstudie wat gedoen is. Alcedo Boerdery 2014 internet afgelaai word by http://www.zitholele.co.za/kusile-ash,

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Translation: aangesien die dokument te groot is om per epos te stuur. Indien u nie kan aflaai nie, Thank you for the EIA Newsletter that was received. I request a kontak ons gerus en ons stuur ‘n CD. copy of the environmental impact assesment that was conducted. Translation:

The Final Scoping Report can be downloaded from the Internet at http://www.zitholele.co.za/kusile-ash, since the document is too large to send by e-mail. If you are unable to download it, please contact us and we will send you a CD. Leoni Lubbe, Administrator (e-mail 26 February 2014) 11 We have signed that there are no applications against the VAN DALEN, Lenert E-mail: 12 March Document has been forwarded to Eskom. property but we have attached a letter in our contract when 2014 Nicolene Venter, PPP purchasing the farm should this be of any importance/relevancy; 12 Requested to be removed from project database as he rented WOHLITZ, Ernst E-mail: 05 March Request acknowledged and removed from the farm Kortfontein from Miss Hanna van Aswegen and the rent Property Owner: 2014 project database. expired. Farm Kortfontein Nicolene Venter, PPP

2.12 General Comments 1 Het SMS ontvang vir die Aansoek om Afvalbestuurlisensie vir JANSE VAN E-mail: 15 February Hiermee die inligting rakende die kospakkies: Kusile Kragstasie. Ek sal graag aan die Impakstudie wil VUUREN, Pieter 2013 deelneem. 0828838605 of e-pos / [email protected], Graag wil ek ook aan jou vra om vir my meer inligting te stuur as [email protected] dit in jou vermoee is oor die kontrak wat hul nou het om kos pakkies aan die kontrakteurs asook die werkers van Kusile te Translation: maak. Herewith the information about the food Translation: parcels:

Received SMS about the Application for Waste Management 082 883 8605 or e-mail Licence for Kusile Power Stateion. I would like to participate in [email protected] / the Impact Assessment. [email protected] Nicolene Venter, PPP (e-mail: 19 February I also want to ask you to send me more information, if possible, 2014) about the contract they now have to provide food parcels to the contractors and the workers of Kusile. Dankie dat jy jou e-pos adres vir ons

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deurgestuur het – ons het dié ook op die projek databasis aangebring.

Vind asseblief aangeheg die Agtergrond- inligtingsdokument wat jou meer inligting rakende die voorgestelde projek gee.

Ek sal kyk of ek vir jou die inligting rakende die kospakkies aan die kontrakteurs kan bekom en sal dit dan vir jou deurstuur.

Translation:

Thank you for sending us your e-mail address – we have entered it into the project’s database.

Please find attached the Background Information document that will provide you with more information on the proposed project.

I will try to find you information about the food parcels for contractors and will send it on to you. Nicolene Venter, PPP (e-mail: 19 February 2014) 2 Accordingly TPSA requests that a collective Environmental MEYER, Dr James Letter: 08 Eskom has been made aware of the request of Monitoring Committee be established that takes due TOPIGS SA (Pty) Ltd September 2014 the I&AP to establish a collective cognizance of the cumulative effect of these activities and that Environmental Monitoring Committee be adherence to appropriate conditions that protect existing established that takes due cognizance of the agricultural activities, environmental, animal and public health, cumulative effect of these activities. The EAP be stipulated in any licence and/or authorisation granted. also recommends that, where possible, a collective EMC be established that will incorporate comments and discussion from all stakeholders in the catchment in question. Mathys Vosloo, EAP

3 Background to the TOPIGS SA Perspective: MEYER, Dr James Letter: 08 The background to the TOPIGS SA  As has been noted during the public participation process TOPIGS SA (Pty) Ltd September 2014 perspective provided by the I&AP is noted. TPSA operates a pig genetics production facility on the Mathys Vosloo, EAP

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farm Bossemanskraal 538JR, which is located on the western boundary of Kusile Power Station. This facility consists of several sites with pig genetic material produced and supplied in the form of female animals and boar semen (sow and boar lines) to more than 50% of the South African pig industry and to several other African countries, including the SACU members and major African trading partners with South Africa; and TPSA plays a crucial role in the stability and financial sustainability of the pig industry, not just in South Africa, but also in sub-Saharan Africa and that accordingly, the TPSA facility represents a key strategic component of the South African and African pig industry, and cannot have its operations compromised in any manner. 4 The activities related to the coal fired power stations of Kusile MEYER, Dr James Letter: 08 The suggestion provided by the I&AP relating and Kendal should be represented, monitored and managed at a TOPIGS SA (Pty) Ltd September 2014 to the monitoring and management of the collective Environmental Monitoring Committee level. related to the coal fired power stations of Kusile and Kendal Power Stations are noted by the EAP. Mathys Vosloo, EAP 5 As a downstream recipient of the Klipfonteinspruit and highly MEYER, Dr James Letter: 08 The EAP maintain that as per the conclusions affected party as a direct neighbour to the KPS, TPSA TOPIGS SA (Pty) Ltd September 2014 and recommendations of the specialist on this accordingly has a valid reason to doubt the proposal will in any project, potential impacts to the TPSA way meaningfully protect their operational environment operations can be successfully managed and adequately. minimised. Mathys Vosloo, EAP 6 The impacts from Kendal Power Station are also multiple. MEYER, Dr James Letter: 08 The following extract which provides summary Whilst it has been communicated that the EIA processes TOPIGS SA (Pty) Ltd September 2014 of the approach that was taken for assessing operate concurrently for continuous disposal at the current the anticipated surface water impacts, facility and the new 30 year facility, it is not clear to what extent illustrates that that the existing impacts were the combined impacts have been considered, notably for: taken into account (refer to Part 6.1.7 and  Proposed New 30 year ash disposal facility: DEA Ref Part 7.3 of the Surface Water Study included Number: 14/12/16/3/3/3/63 NEAS Reference Number: as Appendix F11 of the Final EIR) : DEA/EIA/0001508/2012; and This operation and related infrastructure appears (based on Part 6.1.7: Cumulative Impacts maps received) to be within close proximity to the existing ash It is a requirement that the impact disposal facilities (KPS 10 year co-disposal facility) and the assessments take cognisance of cumulative wetlands/water courses impacted by both the KPS 60 year ADF impacts. In fulfilment of this requirement the and the AAIC NLC. impact assessment will take cognisance of any existing impact sustained by the operations,

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any mitigation measures already in place, any additional impact to environment through continued and proposed future activities, and the residual impact after mitigation measures. It is important to note that cumulative impacts at the national or provincial level will not be considered in this assessment, as the total quantification of external companies on resources is not possible at the project level due to the lack of information and research documenting the effects of existing activities. Such cumulative impacts that may occur across industry boundaries can also only be effectively addressed at Provincial and National Government levels”.

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joins the Olifants River upstream of the Loskop Dam. Given the fact that the Olifants River feeds into several water supply storage facilities utilised by local settlements, the impact of deteriorating water quality, which makes the water less fit for use, has significant environmental as well as social and economic implications. Due to the fact that several upstream impacts are already occurring when considering significance rating for cumulative impacts for each of the proposed sites, the impact class will not change considerably compared to those shown in Table 16. However, should mitigation be put in place then the local cumulative impacts would reduce the significance rating for the local area but may not have much of a positive impact on the broader catchment. This would need to be assessed considering all other users in the catchment.” Mathys Vosloo, EAP 7 It follows that TPSA would seek a clear undertaking and contract MEYER, Dr James Letter: 08 Eskom will be legally obligated to abide by any in which KPS / Eskom provides the necessary mitigation TOPIGS SA (Pty) Ltd September 2014 environmental authorisation that may be measures that adequately protect its operational environment, issued in its name. This includes the failing which the KPS / Eskom will have to undertake its stipulations of the FEIR and EMPr. Regular relocation. compliance monitoring will be undertaken and audit reports circulated to Eskom and the DEA, and if non-compliances are identified and not rectified, the public can raise this concern with the Department of Environmental Affairs. Mathys Vosloo, EAP 8 The Tweefontein Colliery covering over 12 000 ha located to the MEYER, Dr James Letter: 08 Noted and considered during the EIA. area West of the Kendal Ash Disposal Facilities. TOPIGS SA (Pty) Ltd September 2014 Mathys Vosloo, EAP 9 No analytical evidence is provided to support the claim of MEYER, Dr James Letter: 08 Ensuring compliance with the conditions agricultural impacts being significant or adverse. It is also TOPIGS SA (Pty) Ltd September 2014 contained in the Environmental Authorisation unacceptable that none of the reports contained in the DEIR (EA) issued for elements / activities of the mention that the KPS has been contravening their RoD for Kusile Power Station remains with the holder several years by disposing of the human sewage generated on of the EA (Eskom SOC Limited). The EAP site at an unlicensed facility (Phola WWTP). Concerns in this cannot provide comment on the capability of regard have been made at the KPS EMC by TPSA, the DEA and the holder of the EA or any party employed by

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the DWA on several occasions and the detail and information the former, to comply with the EA conditions thereof is available and should be noted in connection with the for any authorised activity. ADF. Mathys Vosloo, EAP 10 Accordingly, TPSA maintains that the KPS / Eskom proposed MEYER, Dr James Letter: 08 Guarantees can never be provided as we are activity must guarantee that water and air quality will not TOPIGS SA (Pty) Ltd September 2014 living in a dynamic world that is ever changing deteriorate and that their rights to a sustainable operating over time. Eskom does commit to implement environment will not be compromised. all recommended mitigation measures and management actions, including regular compliance monitoring, to ensure that the proposed activity does not impact the water and air quality in the area adversely. Mathys Vosloo, EAP 11 The KPS/Eskom Contamination Study Final Contamination MEYER, Dr James Letter: 08 The following extract taken from the Surface Investigation at Kusile Power Station Rev 7 5 July 2013 Zitholele TOPIGS SA (Pty) Ltd September 2014 Water Study (refer to Part 5.2 of Appendix F11 Consulting Report No: 12828 to which TPSA commented on, of the final EIR) provides a description of the with some key points relevant to this comment document on the methodology that were employed to determine 60 year Ash Disposal Facility (ADF) noted as: the baseline water quality. Specific reference  Some important conclusions and statements are offered in to E.coli is made by the specialist in the below the CI report, namely: “The construction activities of Kusile extract. are impacting on the groundwater and surface water quality downstream of the site.” (Section 19). This impact “is seen in “Grab samples were taken at the points increased concentrations of E. coli” (section 19). indicated in Table 6 during the period 2008 to o “The principal source of this contamination appears to 2013. Once off sampling was also undertaken be sediments contained in the various surface water on the upper reaches of Wilge River just impoundments on site”. (section 19); before the Klipspruit tributary and further o ”However, the levels of the contaminants at the downstream on tributaries flowing into the property boundaries of Kusile exceed the RWQO which Wilge. This was mainly to determine the exposes the Kusile operations to a risk of legal baseline water quality in that area as these noncompliance with regard to its storm water discharge sampling points are in close proximity to where to the natural environment.” (section 19); the alternative Site G and Site B are to be o Steps to improve sewage management must be located. A summary of these results showing a implemented (detailed in section 19); and comparison of the 95th percentile concentration o The increase in turbidity levels is associated with the for each parameter against the interim increase in microbiological indicator organism counts RWQOs is shown in Table 7 and Table 8. The (section 6). overall chemical water quality within the study area is good. However some sampling points indicate high levels of total dissolved solids “Typically, baseline surface water quality data is obtained prior (TDS), conductivity (EC), fluoride (F), sulphate to proceeding with a project that has the potential to impact on (SO ) and iron (Fe), all indicative of pollution surface water..” “In the case of Kusile, no baseline surface from mining activities. These parameters were

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water quality was obtained.” (section 7.1) “The mine located mainly detected at the following points: SW1 upstream of SW1 is also contributing to the E. coli levels and SW7 both of which are tributaries that downstream of Kusile” (section 11). drain Kusile co-disposal area, spring 6 which is the most downstream point from New Largo “Typically, baseline surface water quality data is obtained prior mine on Klipfonteinspruit, and SW11 which is to proceeding with a project that has the potential to impact on at the confluence of the Wilge River and the surface water.” “In the case of Kusile, no baseline surface water Klipfonteinspruit. The overall microbiological quality was obtained.” (section 7.1) “The mine located upstream results show high levels of E. coli which is an of SW1 is also contributing to the E. coli levels downstream of indication of cattle and human impacts within Kusile” (section 11) the study area. In addition tilling of cultivated lands can also play a role in elevating the natural E.coli levels in the soil and with run-off would then impact on the surface water resources.

Additional sample taken in February 2013 at points KSA01- KSA09 (Table 8) show good chemical and physical water quality with some exceedances in iron and manganese concentrations), but the bacteriological quality at the time of sampling was generally poor”. Mathys Vosloo, EAP 12 It is regrettable that the report, whilst detailing the on-site MEYER, Dr James Letter: 08 The EAP cannot comment on the removal and sewage management and Sanitech removal (section 8.3.2), TOPIGS SA (Pty) Ltd September 2014 disposal of onsite sewage from the Kusile does not detail the final destination of the sewage removed. Power Station construction site at the Phola Specifically, the ability of Phola Wastewater Treatment Plant to Wastewater Treatment works as the current handle the 3 million liters of sewage per month is not discussed Kusile PS construction falls outside the scope or detailed. This was one of the key issues that were supposed of this study. to have been addressed. Failure to do so, within the perspective of KPS failing to provide evidence of load sheets for receipt of The EAP has recommended that sanitation the sewage waste at a licenced facility, still leaves significant facilities in the form of chemical toilets at the doubt regarding the environmental impact of KPS sewage and recommended toilet to worker ratio, be waste off-site. This topic is thus still unresolved and as a provided at strategic location within the ADF participant of the EMC TP will continue to argue that is must be construction site. The facilities will be serviced immediately rectified. If the final disposal of the waste by a competent and registered service provider generated on-site is not accounted for KPS cannot claim that it which will dispose of the sewage at a suitable has no “upstream” impact. licenced sewage facility only. Mathys Vosloo, EAP 13 The Waste Classification Report, Groundwater and Air Quality MEYER, Dr James Letter: 08 Ensuring compliance with the conditions Report (Appendix H and F1, F7 of the DEIR) refers. Section 2 of TOPIGS SA (Pty) Ltd September 2014 contained in the Environmental Authorisation

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the Waste Classification Report - Methods notes: (EA) issued for elements / activities of the  Zitholele collected two representative fresh ash samples Kusile Power Station remains with the holder from Kendal Power Station during 16 & 17 November 2012. of the EA (Eskom SOC Limited). The EAP  One of the samples was used for inorganic analyses and cannot provide comment on the capability of was submitted to Waterlab on 23 November 2012. the holder of the EA or any party employed by The inorganic results are then provided in Table 4.1 and the the former, to comply with the EA conditions waste classified as a Type 3 Waste requiring a Class C lining for any authorised activity. system. Mathys Vosloo, EAP 14 How much top soil goes on top of the ash? CHERRY, Andre, DEIR Focus Group 300 mm goes on top. Landowner Meeting, 20 August Charl Cilliers, Design Engineer 2014 15 Why is there ash shown on the conveyor belt cover [shown in CHERRY, Andre, DEIR Focus Group The picture on the slide was to show how the DEIR presentation]? Should it not be wet? Landowner Meeting, 20 August site will be rehabilitated. The picture that was 2014 used in the presentation was from Matimba Power Station just to illustrate the conveyor belt system. Charl Cilliers, Design Engineer

Post-meeting note: There will always be some degree of dust fallout directly associated with the conveyor system. The ash is conditioned to be damp when transported along the conveyor to minimise dust fallout around the conveyor. Mathys Vosloo, EAP 16 Commented that no dust suppression should be allowed as the CHERRY, Andre, DEIR Focus Group The design can be re looked at again, if ash should be kept wet when it is travelling on the conveyor belt. Landowner Meeting, 20 August required. If it cannot be watered down then the conveyor belt should be an 2014 Charl Cilliers, Design Engineer enclosed system. The ash is conditioned with water before it leaves the power station on a conveyor belt. This is done to ensure that dust outfall is minimised en route to the ash disposal facility. The dust suppression system on the other hand is also an integral part in the management of dust and particulate matter on the ADF itself. The operation of the ADF cannot work in the absence of the dust suppression system. Mathys Vosloo, EAP

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If the dust suppression system fails, the irrigation system can be used for dust suppression. However these are designed to be smaller sprinklers so they will have to be on for longer periods in order to get the coverage required. Irrigation will then need to be carried out by water tankers/bowsers.

If both the irrigation and dust suppression systems are out, water tankers/bowsers will need to be used. Temporary sacrificial soil cover can also be considered as well as compaction of the ash for areas that will be exposed for long periods of time.

If excessive winds are experienced from a specific direction, wind breaks may be installed to reduce dust blow. Charl Cilliers, Concept Design Engineer 17 Commented that it will be ideal to use Site C so that the ash can CHERRY, Andre, DEIR Focus Group Site C has its own constraints associated with blow onto Eskom property and not onto the famers land. Landowner Meeting, 20 August the site. Most significant constraints include 2014 the fact that wetlands on site C has already been set aside for wetland offset plan for an authorised Kusile project, and that people have been relocated previously from another area to site C, and as recommended by the social specialist should not be relocated again. 18 Only the landowners on the site alternatives were consulted and CHERRY, Andre, DEIR Focus Group There is forum called the Environmental not the neighbours, even during the site selection process. Not Landowner Meeting, 20 August Management Committee (EMC) where issues Eskom or the engineers consulted the neighbouring landowners. 2014 can be tabled, discussed and be addressed. The only people who visited their properties where the specialist Tobile Bokwe, Eskom during their specialist studies 19 How much aluminium is in the ash as this can be harmful CHERRY, Andre, DEIR Focus Group The ash classification was conducted on ash should it leaked into the groundwater, as it kills plants, and Landowner Meeting, 20 August samples taken from the Kendal Power Station, maize cannot grow in the soil that has been contaminated with 2014 since no ash is yet being produced for the aluminium. Kusile Power Station. Although the same type of coal will be used to fuel the Kusile Power Station, it cannot be determined for sure what the constituents, and concentrations of these

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constituents, in the ash produced at Kusile Power Station will be until samples of ash produced at Kusile is classified in terms of the waste regulations. Once ash is produced ash samples from the Kusile Power Station will be analysed and classified to determine its constituents. Mathys Vosloo, EAP

Aluminium was encountered in the waste classification but at a very small percentage of the total. The values encountered are below the Acceptable Risk Levels stated in the waste classification regulations. Charl Cilliers, Concept Design Engineer 20 If Kusile is managed like Kendal Power Station then there will be CHERRY, Andre, DEIR Focus Group Mr Leon Stapelberg commented that he could disastrous consequences. Currently the infrastructure at Kendal Landowner Meeting, 20 August not respond regarding Kendal Power Station’s Power Station is not managed properly and foresees this as 2014 infrastructure. One can only put so many happening at Kusile Power Station. checks and balances in place, and there is no perfect system and it can fail at any time. The attendees were also informed that cognisance need to be taken that living in this area, with all the developments taking place, the environment will change in the near future. Leon Stapelberg, Kusile Power Station

Post-meeting note: Challenges with the management of the Kendal Power Station infrastructure must be dealt with and rectified by Eskom. However, when dealing with the expected and potential impacts associated with the Kusile Power Station infrastructure, mitigation measures that will prove successful is identified and must be implemented to ensure the impacts are avoided, or minimised. It remains Eskom’s responsibility to ensure that in the event of failure an emergency response back-up system is in place to continue to mitigate the impact. It further remains the Interested and

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Affected Parties’ responsibility to raise such events or impacts with the Eskom Environmental Management Committee or the competent authority in order to address these impacts in terms of the authorisation granted. Mathys Vosloo, EAP 21 What is going to happen to the surrounding wetlands? CHERRY, Andre, DEIR Focus Group The ash disposal facility (ADF) is designed in Landowner Meeting, 20 August such a way that any run-off water will be 2014 channelled to holding dams from where it will be released back into the surrounding wetland systems. Mathys Vosloo, EAP

Post-meeting note: As part of the mitigation and rehabilitation strategy for the Kusile ADF, surrounding wetlands will be rehabilitated and monitored for signs of impact, while a comprehensive offset strategy will be put in place to offset the loss of wetlands within the ADF footprint. Mathys Vosloo, EAP 22 Mr Andre Cherry commented that he totally objects to Site A, CHERRY, Andre, DEIR Focus Group Ms Nicolene Venter acknowledged the especially when the wind blows then it will be blown in the Landowner Meeting, 20 August comment regarding the objection raised. direction of the landowners’ properties. 2014 Nicolene Venter, PPP

Post-meeting note: The air quality specialist identified potential impacts such as windblown ash and modelled the potential movement of the ash with and without mitigation in place. Conclusions from the exercise were that with mitigation successfully implemented it can be said with confidence that dust and ash can be limited to the ADF footprint. Furthermore, dust fallout monitoring will have to be done on neighbouring properties to measure effectiveness of the mitigation measures. Mathys Vosloo, EAP 23 If Site A is chosen then the system used for disposing the ash CHERRY, Andre, DEIR Focus Group There is always a possibility that the best should be of very high standard to ensure that when one system Landowner Meeting, 20 August designed system can fail.

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is down then another system must kick in, and a third system 2014 Leon Stapelberg, Kusile Power Station should the other two fail. Post-meeting note: The system used for controlling ash on the ash disposal facility is a dust suppression sprinkler system. This will be a new system, and in the event that the system fails the power station will employ water trucks and water bowsers to control dust on the site. Rehabilitation of the exposed ash will also be rehabilitated as soon as the area is stabilised to minimise windblown ash and dust fallout. Mathys Vosloo, EAP 24 Why are the minimum standards used for the liner design? CHERRY, Andre, DEIR Focus Group The standard that is used is the National Landowner Meeting, 20 August Environmental Management: Waste Act’s 2014 Waste Classification and Management Regulations (R634), National Norms and standards for assessment of waste for landfill disposal (R635), and National norms and standards for disposal of waste to landfill (R636). These regulations do not represent minimum standards but are prescribed by the Department of Environmental Affairs as the maximum interventions to be implemented to prevent pollution of land and water resources. Mathys Vosloo, EAP 25 Site C is the better site for the ADF. JANSEN VAN DEIR Focus Group All the issues and recommendation will be RENSBURG, Hans, Meeting, 20 August captured and submitted for decision making to Landowner 2014 the Department of Environmental Affairs (DEA). Should the landowners not be happy or in agreement with the DEA’s decision, then they will have an opportunity to appeal the decision that has been taken. Tobile Bokwe, Eskom

Post-meeting note: The statement that Site C is the better site for the ADF is considered unqualified as no explanation or reasons were given why it is considered the better site from the commenter.

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In terms of the EIA conclusions drawn a process was followed where environmental, socio-economic, and technical aspects were considered which led the project team to the conclusion that site C was not a preferred site for placement of the ADF. Mathys Vosloo, EAP 26 The decision has already been taken, this is just a process. JANSEN VAN DEIR Focus Group The team does not take a decision as to RENSBURG, Hans, Meeting, 20 August whether the project is approved or not. The Landowner 2014 only recommendation that the team makes is to ensure that the facility is placed in an area where it will have the least environmental impact (biophysical as well as social). Comments received from landowners, I&APs and stakeholders are also taken into consideration, but the final decision is taken by the DEA. Nicolene Venter, PPP

Post-meeting note: A process was followed during the EIA where potential developable areas were identified within 15 radius of the Kusile Power Station. Next feasible sites were identified, which was further investigated by a host of specialist to identify environmental, socio-economic and technical constraints and sensitivities. Based on the recommendations of these studies a

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preferred site was identified, which has now been recommended for consideration by the competent authority. The project team has therefore made a recommendation to the competent authority, which must however make the final decision regarding the merits of the alternative sites considered and the preferred site recommended. Mathys Vosloo, EAP 27 Are you aware that one of the largest open cast mines will be in SMITH, Gert, Agri DEIR Public The project is aware of the newly proposed the area? Mpumalanga Meeting, 20 August open cast mine. 28 Have all the properties of the alternative sites been purchased? 2014 No new property is required as Site A is already owned by Eskom. Mathys Vosloo, EAP

Post Meeting Note: At the EIA phase the alternative sites are only considered with consultation with land owners. Only after an environmental authorisation has been granted will negotiation with land owners and purchase agreements be finalised for the authorised alternative site. In the case of the Kusile 60-year ash dump recommended site, the property on which the recommended preferred site is located is already owned by Eskom. Mathys Vosloo, EAP 29 Have all the landowners been informed about this project? SMITH, Gert, Agri DEIR Public Landowners within the study area were Mpumalanga Meeting, 20 August identified and informed throughout the EIA 2014 process. Organisations such as AgriSA and TLU SA were also informed with the understanding that they will filter the information through to their members. Nicolene Venter, PPP 30 Will the ash have significant impact on air quality? The Air Quality Specialist did identify that there will be an impact on air quality but it will not be significant, after successful mitigation, and the impact will be below the standards and limits as set out in the National Environment Management: Air Quality Act.

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Mathys Vosloo, EAP 31 The venue for the meeting is not accessible for community MNGUNI, Thomas, DEIR Public There were challenges between the project members to attend the public meeting and there was no Greater Middelburg Meeting, 20 August team and the communities, and due to transport made available to the community Residents 2014 unforeseen circumstances, the public meeting Association had to be moved to this location (El Toro). Aware of the project deadlines but the only way to access the Nicolene Venter, PPP reports is at the library and this is a problem because there is not enough time to read the report; Post-meeting note: One of the reasons that the meeting venue Did not understand the technical jargon that was used in the was moved was due to the fact that Eskom presentations. It would have been nice to make the and the labour force was in wage negotiations presentations simpler; and with a risk of strikes deemed looming. Due to the identified potential risk it was identified that There should be another meeting for the community members having the meeting at the Phola Community that have not attended the meeting today. Hall could flare up tensions between Eskom and the work force. It was therefore decided, for safety of residents and the project team, to move the venue to the closest neutral venue, which was El Toro.

Ms Nicolene Venter, on behalf of Zitholele Consulting, acknowledged the comment and will take the matter forward for future projects.

The response for a meeting in Phola was acknowledged and will be presented to the team for consideration. Mathys Vosloo, EAP 32 There are many dangerous toxins in the ash e.g. lead, mercury, SHILUBONE, DEIR Public Exposure to toxin in the ash can happen in two aluminium etc. How sure are Zitholele that this will not affect the Khensani, Middelburg Meeting, 20 August ways:

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community as this can cause cancer, kidney problems etc? The Environmental Justice 2014 1. Through run off containing ash; or reason for the question was that there was an incident at Network (MEJN) 2. windblown ash. Hendrina Power Station where two kids were ill as a result of the The engineers are confident that the design of toxins caused by the ash. the ADF will prevent or minimise such incidents and the team is also confident that the mitigations recommended in the EMPr will address these situations. In terms of the windblown ash, the air quality specialist is confident with the mitigations that they have recommended such as dust suppression and rehabilitation of the ADF. If these mitigation measures are done correctly, it will limit the windblown dust to the footprint of the site. It is very unlikely that the community members will be affected if the mitigation measures are put into place and adhered to. Mathys Vosloo, EAP

Mr Leon Stapelberg (Eskom Holdings) further commented that he is unaware of any employees of Eskom working at power stations including Kusile Power Station, being diagnosed with any of the disease mentioned by Ms Shilubone. Leon Stapelberg, Kusile Power Station 33 Except the ash site for Kusile, Kendal is very close to Kusile MNGUNI, Thomas, DEIR Public The cumulative impacts are addressed in the Power Station and taking that into consideration, what Greater Middelburg Meeting, 20 August Report but on impact basis and not specifically cumulative impacts are there from all of these sites? Residents 2014 in detail on cumulative impacts. Association Mathys Vosloo, EAP

Mrs Nicolene Venter reported that she will forward the page number from the report to where it talks about cumulative impacts. Nicolene Venter, PPP

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recommendations. These recommendations were incorporated into the DEIR as presented by the specialists. Mathys Vosloo, EAP 34 Ms Khensani Shilubone also commented that it is not only the SHILUBONE, DEIR Public Nicolene Venter acknowledged the comment. power station that hires labour from outside the community but Khensani, Middelburg Meeting, 20 August Nicolene Venter, PPP the mines do the same thing. Environmental Justice 2014 Network (MEJN) 35 Is concerned about the water that will be used and asked NGWENYA, Lydia, DEIR Public Water will not be used from the Wilge River for whether the Wilge River will be able to supply the quantity of Guqa Community Meeting, 20 August the proposed project. Water will be obtained water required as there is already a shortage of water in Phola. Environmental 2014 from the water pipeline from Kendal Power Service Station that is currently supplying Kusile Power Station with water. Mathys Vosloo, EAP

37 Concern regarding the possible negative impact this will have on MNGUNI, Thomas, DEIR Public In terms of the air quality assessment done the community especially those that use land close to Kusile Greater Middelburg Meeting, 20 August and the mitigation measures as proposed in Power Station for growing crop as dust will settle on the crops Residents 2014 the EMPr will be sufficient to address the that will be harvested by the farmers. How will this impact be Association negative impact. mitigated? Mathys Vosloo, EAP 38 In the Water Act it stated that developments should stay clear of No matter which site is selected, wetlands will wetlands, with a 100m radius. In the presentation it is shown that be affected. this Act is not complied with and instead a wetland will be Leon Stapelberg, Kusile Power Station destroyed. How do we preserve the ecosystem if we destroy the

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wetlands? The decision regarding the wetlands was not taken lightly. The wetland impact was discussed at length with the Department of Water and Sanitation (DWS) and the South African National Biodiversity Institute (SANBI). Mathys Vosloo, EAP 39 The farmers also rely on borehole water. How will leachate and MNGUNI, Thomas, DEIR Public Eskom is already engaged in monitoring their runoffs into the boreholes be monitored? Greater Middelburg Meeting, 20 August groundwater sources via various boreholes, Residents 2014 and that there is a consultation process with Association farmers and community members that raise concerns regarding the quality of the water at their boreholes. On the Site A no negative effluence were identified in the boreholes. Leon Stapelberg, Kusile Power Station

The advantage of this ash facility is that it will be lined with an appropriately designed barrier system, according to existing environmental legislation. During the construction phase a groundwater specialist will be there to assist in any way possible to ensure that there are no leakages. Tobile Bokwe, Eskom 40 The Medical Research Council has done a study on the impacts MNGUNI, Thomas, DEIR Public Ms Nicolene Venter acknowledged the of lead on crops, and what they have found is that around the Greater Middelburg Meeting, 20 August comment and replied that the team will search Middleburg and Witbank areas there are heavy lead deposits on Residents 2014 for such a report on the Medical Research the crops. Association Council’s website. Should such a report not be found, then Mr Mnguni will be requested to send a copy of the Report to Zitholele Consulting. Nicolene Venter, PPP 41 How does Eskom carry the burden if something negative Eskom adheres to strict safety rules to happens? eliminate any possible negative impacts / incidents. Should these occur, Eskom responds responsibly and effectively with respect to incidents. Leon Stapelberg, Kusile Power Station 42 Why should Eskom take the risk to build the ash disposal facility MAKHUBELO, DEIR Public The system that will be built is known as a as it will contaminate the water at some point? Nomcebo, Meeting, 20 August closed system, which means zero impact Mpumalanga Youth 2014 outside the footprint of the ash facility. From

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Against Climate a technical point of view all coal fired Change (MYACC) power stations generate ash and the ash needs to be deposited somewhere. If there is no ash disposal facility then the power station will need to shut down. Leon Stapelberg, Kusile Power Station 3 SCOPING PHASE PROCESS COMMENTS

NO. COMMENTS, QUESTIONS AND ISSUES COMMENTATOR(S) SOURCE(S) RESPONSE(S)

3.1 Draft and Final Scoping Report Comments 1 We have a grain and pig farming business that needs Mr Lenert Van Dalen, Comment sheet on The environmental impact assessment will only expansion, which is costly. If renovated, will be compensated? L Van Dalen final scoping report be finalised by next year. Only then can We cannot put everything on hold until a definite decision is Boerdery sent on 23 August answers be provided to you. However, you made. 2012 cannot stop your expansion plans. When Eskom has to buy a person’s property, Eskom has a policy of compensating for the property as well as any improvements on the property. Willie Howell, EAP (2012)

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Mathys Vosloo, EAP (2014) 2 After reviewing the Final Scoping Report plan of study it was Shangoni Email sent on 20 The economic impact and sustainability noticed that no economic study will be done during the Management September 2012 assessment, including a social impact environmental impact assessment phase. We hereby request Services on behalf of assessment are included in the Environmental that an economic study is included to highlight the economical Eagles Pride Impact Assessment phase of the project. impacts on the farmers. Hatchery (Pty) The Sustainability, soil and land capability, and social impact assessments found that the impact on site B would be high. Site A was thus recommended from this perspective.

Site alternative A has been identified as the preferred alternative. All the properties affected by site A is owned by Eskom, therefore there will be no direct impacts on existing farming operations. A comprehensive Environmental Management Programme will also be implemented to avoid or at the very least minimise any potential indirect impacts on agricultural activities in the vicinity of the ash disposal facility. In the event the competent authority reject the EAP’s recommended site – Site A – and authorise another site alternative, then the land owner negotiation process will commence. Construction of the ADF should only commence once successful negotiations has been concluded with all affected land owners. Mathys Vosloo, EAP 3 After reviewing the application for the Final Scoping Report the Mr Livhuwani E-mail: 10 Zitholele Consulting take note of the fact that Department made the following findings: Siphuma, City of September 2012 the City of Tshwane noted and acknowledges a) The Department acknowledged the receipt of the Final Tshwane the findings as listed in their e-mail. Scoping Report for the proposed extension of the ash Environmental Mathys Vosloo, EAP disposal facility at the Kusile Power Station, Bronkhorstspruit Management b) The report indicated that the full list of water uses to be Department- identified during the early stages of the EIA phase. Environmental c) The report indicated that the optimal goal in building a waste Management and disposal facility and associated infrastructure is to effectively Parks Division minimise the negative environmental and social while ensuring safety, reliability and cost savings for the facility.

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d) The report indicated that Kusile Power Station will generate contracts / tenders that make these waste streams available to other parties who may available for these waste streams. e) The report indicated that New Largo is the only possible solution that may be large enough, but currently not approved or operational. f) The report indicated that the land owners along the alignment of the linear infrastructure that may be required for each of the alternative have also been notified. g) The Site Identification Report suggested that Sites A, B, C, A+G and F+G combined be taken forward to the Scoping and EIR phase of this project. 4 The Department supports the Final Scoping Report subject to The methodology and matrix for the site recommendations issued by the Department dated 22/02/2012: alternatives selection can be reviewed in a) The Department noted the sites selected for investigation Chapter 7, page 129 of the FEIR. during the EIA phase and recommends that a thorough It is confirmed that should an EA be granted investigation be conducted for the selected sites. that construction will be undertaken as per the b) The proposed activity must be constructed according to the approved EMPr. finalised and approved EMP. The EMP should include all the Mathys Vosloo, EAP above recommendations. The approved EMP is a legally binding document. An Environmental Control Officer (ECO) should be appointed for the proposed construction phase of the development to enforce the approved EMP. The appointment ECO details should be included within the EMP. 5 It is mentioned in the Scoping Report that there is a possibility of Mrs Annamie Focus group At present the New Largo operation is not disposing the ash in the open-cast void created by New Largo. Duvenhage, meeting on 20 July approved, and a billion Rand decision cannot Why is this not a sufficient solution? Bronkhorstspruit and 2012 at 10:00 to be based on a possibility. Assuming that New Wilge River present information Largo is approved it would be many years Conservancy regarding the before a pit of a suitable size is available inclusion of Site F before feasibility studies could be undertaken as a feasible to quantify the feasibility of in-pit disposal. alternative to be Studies undertaken on other operations of a taken forward to the similar nature have been inconclusive. EIA phase of the Furthermore, the Department of Water Affairs project has rejected the possibility of in-pit ashing based on the fact that no liner system can be successfully installed along vertical surfaces as would be required for the sides of the pit or void targeted to be disposed in. Options that could be considered and that have

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been done before is to have an ash disposal facility on top of an open cast pit with compacted material in the pit for rehabilitation i.e. to install the ash disposal facility on an area of open cast mining that has been appropriately backfilled and compacted; rather than in an opencast pit. Thus ash disposal can be shifted to a new location on New Largo in the future, should feasibility studies show that it is possible. This option is also only available for Areas A, F and G. None of the other areas identified (Areas B, D, E, H1-3 and I) allow for this later change in disposal operations, because of the significant cost to move all the supporting infrastructure, such as conveyor belts, electricity, roads etc. Mathys Vosloo, EAP 6 Some of the Key Concerns noted for the Draft Scoping Report Dr James Meyer, E-mail: 2 August No reference to pollutant constituents during that remain applicable include: Consultant for 2012 the Draft Scoping Phase as no specialist  Nowhere in the Draft Scoping Report is specific reference to TOPIGS SA (Pty) Ltd studies has been undertaken yet. these constituents noted, and although it may be argued that Willie Howell, EAP (2012) they are included by implication, it is argued that in order for meaningful public participation and acceptable EIA terms of Water related specialist studies has identified reference to be formulated, they should appear prominently background (status quo) water quality levels in the report with clear assurances that they will be subsequent to sampling of surface and ground established in terms of baseline values, potential hazardous water in and adjacent to the proposed site waste streams and monitored accordingly. Failure to do this alternative A. Surface water and groundwater transparently may result in various environmental and water sampling results can be considered in the licenses and authorizations to be granted without specific respective specialist studies provided in full in reference to the primary pollutants relevant. Appendix F of the DEIR.  It is argued that any water used in the process of Constituents of the ash, which represents a transporting, placing and storage of the waste streams (fly sample from the nearby Kendal Power Station, ash and coarse ash) should form a significant and critical has been determined and can be viewed in the part of the Draft Scoping Report and be included therein as Ash classification report in Appendix G of the part of the environment and subsequent EIA issues. DEIR. The ash has been classified as a low  Monitoring descriptions must be detailed for storm water hazardous waste and subsequently a class C drainage and monitoring boreholes, listing at the very least barrier system must be installed for the ash those prohibited discharges typically used for Special Limits disposal facility. by DWA. Clearer indications should be given regarding the handling of The transportation and disposal of ash to a

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waste from human effluent and other hazardous wastes disposal facility has been addressed in terms associated with the construction phase, both of the ash dump of the impacts associated with the activity, and conveyor systems. It is already noted by Kusile that Phola engineering requirements and designs Sewage plant cannot cope with the current load, yet Kusile will undertaken to minimise to impact of the activity show a significant increase in staff entering the site per day over on the receiving environment, and mitigation time (increase from 8500 currently to over 10000 by 2013 – measures recommended to further minimise EMC data). It is vital that any additional construction activities be the impact of ash on the environment. managed with due regard for the existing impacts and subsequent sensitivities of the receiving environment. Monitoring descriptions has also been included in the Draft EMPr, which can be viewed in Appendix I of the DEIR.

The scope of this project is only relevant to the development of the ash disposal facility. Existing sanitation issues associated with the construction of the Kusile Power Station is thus not part of the scope of this project. The management of human waste during the construction and operational phases of the ash disposal facility will be managed through chemical toilets serviced by an accredited service provider, and monitored for compliance by an independant Environmental Control Officer (ECO). No permanent facilities which will require tie-in into the existing sewerage systems of Phola will be constructed. Mathys Vosloo, EAP 3.1.1 Site Alternatives Comments 1 We would like to point out that the proposed site “B” is in Van Rensburg, E-mail: 11 January The Gauteng Department of Agriculture and Gauteng, whereas the power station is being built in Jordaan & Olivier 2012 Rural Development is a commenting authority Mpumalanga. Apart from the obvious administrative challenges Attorneys (on behalf on this assessment and have been included in that this cross-border operation may face, we also believe that of Hans van all communication. your consultation process as proposed, will not comply with Rensburg Boerdery Andre Venter, PPP Government Notice R.543 of June 2010, Chapter 2. In the cc) Background Information Document of September 2011, mention is made only of the relevant government departments in Mpumalanga, for instance the Mpumalanga Department of Economic Development, Environment and Tourism. No mention is made of the same authority in Gauteng.

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We believe that, especially in the light of the serious economic impact this facility will have on agriculture and the environment in Gauteng, as will be discussed in more detail later, failure to consult with the relevant departments in Gauteng, will render the process defective and therefor invalid. 2 Although we did not have access to information about the other Van Rensburg, E-mail: 11 January The potential impact on agriculture and all proposed sites for the ash disposal facility, it is evident that the Jordaan & Olivier 2012 water resources will be fully investigated during cost of this facility at site B will be substantially higher than that Attorneys (on behalf the EIA phase of this study. Please see and of the other proposed sites. This conclusion is based both on the of Hans van comment on the proposed Terms of Reference high value of the land on which the site is located, and on the Rensburg Boerdery for these studies to ensure all elements of fact that a corridor will have to be created and maintained if this cc) concern will be addressed. At completion of the site is chosen, as is evident from your map. This site is the specialist studies, the public will be given an furthest from the power station and that alone indicates a much opportunity to confirm acceptability of proposed higher operating cost than, say, Sites “A” and “C” which is right mitigation strategies and plans. next to the site. This should be a major concern as the project In addition to the specialist studies mentioned already seems to be more costly than anticipated. We hope that above, the engineering team will undertake a a study will be done to calculate the additional cost over the cost comparison of the various scenario’s lifespan of the power station, should this site be chosen, and including the cost of the conveyor, roads and that this will be taken into account when deciding on the viability pipelines to the proposed facility. of site “B”. To us, this site simply does not make economic Willie Howell, EAP (2012) sense. Furthermore we are concerned about the impact on the local It is confirmed that the development of site B farming community, and especially the irrigation and chicken would be the most costly option to implement, component thereof. Gauteng has relatively little irrigation land as was found by the Sustainability assessment and food production is paramount to the survival of the country. undertaken as part of the DEIR. It is, in our opinion, even more important than the provision of electricity. It is acknowledged that the development of the Lastly, it would be disastrous if the Gauteng water supply is ash disposal facility on Site B would have a affected by the proposed facility, and this alone should be significant impact on agricultural activities. reason enough to abandon this site as a possible choice. It is debatable whether food production is even more important than electricity generation. This statement eminates from the assumption that there will always be sufficient electricity. However, if key power generation projects such as this one does not continue, there is a real possibility load shedding will become a more permanent impact on our everyday activities. Therefore it is very likely that food security will be impacted if electricity supply is

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interrupted.

All potential impacts on surface and groundwater resources has been assessed in the DEIR and can be mitigated to acceptable levels. Mathys Vosloo, EAP (2014) 2 What will happen if all four proposed alternative sites for the ash Dr James Meyer, Public meeting on This could shorten the lifespan of the power disposal facility are given restrictive conditions and the approved Water Research 15 February 2012 at station or the ash disposal facility will be area becomes too small for a 60 year lifespan? Commission, Pretoria 14:00 to discuss spread over more than one site. and review the Draft Willie Howell, EAP (2012) Scoping Report. 3 Can we ask that Site C be removed from the list of alternative Mr Zweli Mpofu, Public meeting on Unfortunately all the sites will have some form sites as there are people currently residing on the property? Bravo Cooperative, 15 February 2012 at of impact to the local residents, and a particular Hartbeestfontein. 14:00 to discuss site cannot be left out at this early stage of the and review the Draft project prior to undertaking detailed studies, Scoping Report. especially social to determine the impact to all the sites. As part of the studies highlighted for the EIA, please refer to the scope of work for the social study to ensure that all your concerns will be addressed. Willie Howell, EAP (2012) 4 I live at Site B, but I am trying to be objective and look at this Mr Christiaan Gerber, Public meeting on The comment made that a ash disposal facility development as a South African. It makes no sense to move the Witklip 15 February 2012 at should be as close to a power station as whole development somewhere else, because an ash disposal 18:00 to discuss possible is noted. facility will always have a negative impact on its immediate and review the Draft Willie Howell, EAP (2012) environment. Scoping Report. 5 The cost of a project of this size is important and must be kept Mr Christiaan Gerber, Public meeting on When the site selection was done, the current as low as possible. Does it make sense to have a site, such as Witklip 15 February 2012 at four alternatives were the four most feasible Site B, so far away from the power station? 18:00 to discuss sites both when the financial costs of this and review the Draft development were included and excluded from Scoping Report. the calculations. During the site selection process, both the environmental and social investigations also came out with the current four alternatives. At this early stage in the project all the feasible alternatives are considered, as it is unknown what additional factors might influence cost at the other sites.

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Willie Howell, EAP (2012) 6 What about looking at sites on the other side of the N4 highway? Mr Christiaan Gerber, Public meeting on Building a conveyor belt under or over a Witklip 15 February 2012 at highway is very challenging from engineering 18:00 to discuss perspective. The area to the north of the N4 is and review the Draft also not flat enough and there is a long ridge Scoping Report. which makes it unsuitable for an ash disposal facility. Willie Howell, EAP (2012) 7 Why did the Scoping Report not state that the previous sites Mrs Annamie Focus group The sites identified in the Scoping Report were selected were not feasible and why were the implications not Duvenhage, meeting on 20 July identified using available information (such as addressed? Bronkhorstspruit and 2012 at 10:00 to published resources, other studies, and Wilge River present information desktop information). The available information Conservancy regarding the at present allows us to evaluate sites at a very inclusion of Site F high level. We have identified the top rated as a feasible sites i.e. sites most likely to be feasible, for alternative to be more detailed investigations. Therefore by taken forward to the default the more sensitive sites based on the EIA phase of the available high level desktop information were project eliminated. Willie Howell, EAP (2012)

8 When will the preferred site be pinpointed? Mrs Annamie Focus group The EIA process is expected to be done by Duvenhage, meeting on 20 July next year. The EIA will either receive Bronkhorstspruit and 2012 at 10:00 to environmental authorisation or not and if Wilge River present information successful, then another year can be expected Conservancy regarding the before construction starts. The preferred inclusion of Site F alternative will be identified during the Draft as a feasible Environmental Impact Report. alternative to be Willie Howell, EAP (2012) taken forward to the EIA phase of the project 9 Our site (Site F) was never included until now; can we assume Mrs Marietjie Boshof, Focus group Site F had to be included as an option. Should that this will be the chosen site? Landowner meeting on 26 July it be chosen, it will have to be in combination 2012 at 09:00 to with another site due to its small size. Site F present information was an option when the sites were selected, regarding the but just not included at that time. After the sites inclusion of Site F have been ranked, Site F came up as a viable as a feasible “combination” option and it was brought back alternative to be into consideration. It does not mean that this

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taken forward to the will be the chosen site, but it had to be EIA phase of the included. Only when the specialist studies have project been done can the best site be identified and recommended by the EIA process. Willie Howell, EAP (2012) 10 Is Site F the only site that cannot be used on its own? Mr Hentie Boshof, Focus group No, Site A + G and Site F + G will be used in Landowner meeting on 26 July combination, should these options come out as 2012 at 09:00 to the best options in the specialist studies. present information Combination sites will be shown on a map at regarding the the next meeting. inclusion of Site F Willie Howell, EAP (2012) as a feasible alternative to be taken forward to the EIA phase of the project 11 Why can’t the ash facility be built on Site A as originally Mr Leon Van Dyk Focus group There are a number of factors to consider for planned? I feel that we were placed under a misconception meeting on 26 July the site selection process such as: since Site F was not included from the start. The ash dump will 2012 at 09:00 to  The need for a 60 year ash disposal have long term effects, especially on farming. present information facility; regarding the  Technical and social matters and inclusion of Site F implications; and as a feasible  Legislation and its changes. alternative to be More sites needed to be included for the taken forward to the process to continue forward. Site A is closer to EIA phase of the the Kusile power station but it also has the project highest rankings in all fields. It will only be clear which site is most suitable after the specialist studies. Willie Howell, EAP (2012) 12 When will we know which area is affected? Mrs Tersia van Focus group The EIA process will take another year to get Vuuren, meeting on 26 July the necessary authorisation and to allow time MANYATHELA 2012 at 09:00 to for the specialist studies to be done. The AVENTURES present information preferred alternative will be identified during Witpoort regarding the the Draft Environmental Impact Report. inclusion of Site F Willie Howell, EAP (2012) as a feasible alternative to be taken forward to the EIA phase of the

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project 13 If Site F is selected as the preferred alternative, what will happen Mrs Carol Wentzel, Focus group It may be lost as part of the impact on the site. to the pan on this site? Bronkhorstspruit and meeting on 3 However, appropriate authorisation processes Wilge River August 2012 at will be followed prior to this pan being Conservancy 09:00 to present sacrificed. information Willie Howell, EAP (2012) regarding the inclusion of Site F as a feasible alternative to be taken forward to the EIA phase of the project 14 I would appreciate correspondence in Afrikaans if the farm, A. Van Asweging E-mail: 27 An intensive study by specialist will be Kortfontein’s wetlands, will be affected by environmental Belmoral Primary September 2012 performed on all the wetlands near the activities. School alternative sites. You will be kept up to date on this process in Afrikaans. Willie Howell, EAP (2012) 3.1.2 Technical Comments 1 Why did you move from a 500 m buffer around houses and other Mr Karel Rajchrt, Public meeting on The buffer zone was purely a technical structures to a 100 m buffer? There should be a big enough Witklip 15 February 2012 at exercise to find out what structures are on the distance between houses and an ash disposal facility, because 14:00 to discuss four alternative sites. There will definitely be an nobody wants to live near it. and review the Draft impact with an ash disposal facility of this size, Scoping Report. no matter where it is placed in the landscape, but through the EIA and the specialist studies we will endeavour to identify the most suitable site. Willie Howell, EAP (2012) 2 We need to discuss the exact route of the NMMP pipeline which Mr Robbie van Public meeting on Noted and Mr. Van Bulderen indicated that he runs past your proposed developments. Bulderen, Transnet 15 February 2012 at would send the final route alignment of the Pipelines 14:00 to discuss pipeline to Zitholele. and review the Draft Willie Howell, EAP (2012) Scoping Report. 3 What happens if the EIA is rejected? Mr Hans van Public meeting on Then the project cannot continue. This could Rensburg, Witklip 15 February 2012 at be catastrophic for the power generation of the 14:00 to discuss country as the Kusile Power Station will not be and review the Draft allowed to operate without this facility. Scoping Report. Willie Howell, EAP (2012) 4 This project is of national interest and therefore the DEA will not Mr Adriaan Loots, Public meeting on The DEA is the only authorising authority for

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reject this EIA. Will it not be better if an independent body take a Jakhalsfontein 15 February 2012 at this project and makes its decision based on decision on the EIA? 18:00 to discuss the study that Zitholele Consulting is and review the Draft undertaking. It is a legal requirement that Scoping Report. Zitholele remains independent from the applicant. Willie Howell, EAP (2012) 5 How wide will the footprint of the ash disposal facility be This will be determined by the engineering measured? Will there be a wide enough buffer zone around the specialist studies during the next phase. At this boundary of the facility. stage the preliminary sizes vary from 1300 – 1600 ha. In terms of the buffer zone, this will also be determined by the various specialist studies (air, noise, social). Once these studies have indicated the required buffer zone Eskom will have to negotiate with the landowners on how that buffer will be maintained. Willie Howell, EAP (2012) 6 Recommendations made by the City of Tshwane: Mr Livhuvani Letter on 22 Thank you, all these recommendations will be a) Measures should be put into place to ensure that no Siphuma, Executive February 2012 in taken into consideration at the relevant phases nuisance by way of noise, dust and smoke are caused to Director: response to the on this EIA. The comments related to the the public and surrounding environment. During site Environmental Draft Scoping various specialist studies have been included preparation and during the operation of the activity. These Management, City of Report. in the Scope of Works for the specialists. In measures should form part of the EMP. Tshwane addition the requirements for management b) An Emergency /Fire Response Plan approved by a qualified plans will be included in the EMP once the risk consultant must be included in the EIA report. specialist studies have been completed. c) The applicant must take note of the applications of the Air Willie Howell, EAP (2012) Quality Act, No 39 of 2004 and follow the requirements thereof. Responses on recommendations by City of d) A detailed storm water management plan must be compiled Tshwane: that ensures that storm water generated on site is a) These impact has been identified and discharged in such a way that the receiving environment is mitigations and recommendations made not adversely impacted upon. This plan should form part of by specialists in their individual specialist the EMP. reports. The specialists are confident that e) It is the responsibility of the applicant to comply with the implemented mitigation measures will be water use legislation and apply for water use licenses and successful in preventing or minimising the authorisation from the Department of Water Affairs where identified impacts. necessary. b) An Emergency Preparedness Plan was f) Adequate storm water management should be implemented developed by a qualified consultant to as part of the proposed activity to prevent erosion and manage any risks that may materialise sedimentation of the surrounding water resources. Sheet during all phases of the project.

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runoff from access roads should be curtailed and runoff c) The National Environmental Management: from exposed surfaces should be slowed down by the Air Quality Act (39 of 2004) has been strategic placement of berms. considered in the DEIR/FEIR by the air g) During construction, erosion berms should be installed to quality specialist during their specialist prevent gully formation. The following points should serve to study, as well as the EAP. guide the placement of erosion berms: d) A detailed storm water management plan  Where the track has a slope of less than 2%, berms was developed by the designing engineers must be installed every 50 metres; and included in the EIA and design  Where the track slopes between 2 and 10%, berms drawings. must be installed every 25 metres; e) The applicant is in the process of applying  Where the track slopes between 10 and 15%, berms for a Water Use Licence Application, must be installed every 20 metres; and where the track which will include the development of a slope is greater than 15%, every 10 metres. wetland offset management plan, and h) All areas affected by the proposed activity must be Integrated Waste and Water Management rehabilitated immediately after the completion of the Plan. proposed activity. The following should be included within f) Extensive storm water management the rehabilitation method and indicated within the EMP: measures has been recommended and  All areas of disturbed and compacted soils need to re- included in the design of the ash disposal profiled and compaction alleviated; facility. This includes clean and dirty water  Disturbed areas must be re-seeded with a combination separation, concurrent rehabilitation of the of different indigenous grass species; exposed area of the ADF, behind the  Rehabilitation shall be done to a coverage of at least advancing front. 80% indigenous species of the rehabilitated area; and g) Erosion berms will be constructed to aid in  On-going removal of alien vegetation from the area storm water management. must take place at least three months after the h) Concurrent rehabilitation of the exposed completion of the structures to prevent the area of the ADF, behind the advancing uncontrollable recruitment of species. front will be undertaken, as well as eradication of alien vegetation. Mathys Vosloo, EAP (2014) 7 Are there not plans for a 10 year ash dump facility at Kusile? Mrs Annamie Focus group There is a co-disposal facility, not an ash dump Duvenhage, meeting on 20 July facility already planned and approved. The co- Bronkhorstspruit and 2012 at 10:00 to disposal facility is designed to accept ash and Wilge River present information gypsum from the first unit of the power station Conservancy regarding the for a 5 year period. Thereafter it will receive the inclusion of Site F gypsum for the remaining life of the power as a feasible station. This structure will, thus, take 60-years’ alternative to be worth of gypsum from the power station. taken forward to the Willie Howell, EAP (2012) EIA phase of the project

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8 Why does a big ash facility need to be built, why can the ash not Mrs Annamie Focus group Kusile, and Eskom at large, is undertaking be used for other purposes, such as making bricks? Duvenhage, meeting on 20 July investigative projects to find companies to Bronkhorstspruit and 2012 at 10:00 to utilise the ash and gypsum. Wilge River present information The volumes of ash are just too large, and Conservancy regarding the currently there are not enough other uses to inclusion of Site F take all the ash. Eskom already has markets as a feasible where ash is sold, but only manages to alternative to be disperse 5% of its ash through sales. Thus a taken forward to the facility will still need to be built. EIA phase of the Willie Howell, EAP (2012) project 9 Where will the water for the Kusile power station be sourced? Mr Andries van Focus group The water for Kusile will be coming from the Vuuren meeting on 20 July integrated water supply system, through a MANYATHELA 2012 at 10:00 to pipeline from Kendal power station. AVENTURES present information Willie Howell, EAP (2012) 10 What happens to the excess water? Witpoort regarding the There is no excess water as it is a dry ash inclusion of Site F disposal facility. In the unlikely event that as a feasible excess water is generated for whatever alternative to be reason, such water will be used for ash control taken forward to the and the clean water will be put back into the EIA phase of the nearby streams. project Willie Howell, EAP (2012) 11 What is going to happen to the wildlife in the area? A terrestrial assessment will be done. Any red data species identified will be relocated. Animals tend to move themselves when things get too noisy, however plants need to be moved manually and are then stored in a nursery before being used in rehabilitation. This process also requires approval by provincial authorities. Willie Howell, EAP (2012) 12 How long does it take for the specialist studies to be done? Mrs Marietjie Boshoff, Focus group Specialist studies need to be done during a wet Landowner meeting on 26 July / dry period and a report needs to be written. It 2012 at 09:00 to can thus take up to a year. Specialist studies present information for this project are anticipated to finish by regarding the February 2013. inclusion of Site F Willie Howell, EAP (2012) as a feasible alternative to be taken forward to the

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EIA phase of the project 13 When will we know which site(s) are selected? Mr Hentie Boshoff, Focus group All stakeholders will be informed as soon as Landowner meeting on 26 July the specialist studies are done, through the 2012 at 09:00 to draft Environmental Impact Report. The present information specialist studies will determine which site(s) regarding the are selected and this will then be submitted to inclusion of Site F the Department of Environmental Affairs (DEA) as a feasible that must take the final decision. alternative to be Willie Howell, EAP (2012) taken forward to the EIA phase of the project 14 I know that water and ground sampling have been done; can it Mr Leon Van Dyk Focus group The reports should be done by the end of next be made available to us? meeting on 26 July year (2013). The specialist studies will also be 2012 at 09:00 to available to you. The decision for the present information information to be distributed is up to Eskom, regarding the but it should not be a problem. inclusion of Site F Willie Howell, EAP (2012) 15 How is the environmental monitoring done for pollution and as a feasible All environmental requirements will be stated in waste management? alternative to be the Environmental Management Programme taken forward to the (EMPr) and monitoring should be done EIA phase of the accordingly. The EMPr considers all project environmental factors and legislation. Willie Howell, EAP (2012)

The Draft EMPr has also been included in the DEIR and FEIR. An independent ECO will monitor pollution and waste management based on the monitoring approved by the competent authority after a decision has been reached. Mathys Vosloo, EAP (2014) 16 Are you aware that there are land claims on Site F? It has been Mr Karel Rajchert, Focus group Noted. However Eskom is busy with land rights published in the Government Gazette. Witklip meeting on 26 July and negotiations through their land and rights, 2012 at 09:00 to and legal departments. present information Willie Howell, EAP (2012) regarding the inclusion of Site F as a feasible

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alternative to be taken forward to the EIA phase of the project 17 What will happen if the ash facility was built and 30 years down Mr Hennie Pienaar, Focus group This question has two answers one from an the line Eskom realises that they made a mistake with the site Alcedo Boerdery meeting on 3 environmental perspective and one from a regarding water and wind impacts. What happens then? August 2012 at technical perspective. From an environmental 09:00 to present perspective all relevant concerns and issues information are investigated. This is why it is important for regarding the the public to partake in these meetings to raise inclusion of Site F issues. But if this does in fact happen the as a feasible responsibility will be on Eskom to fix the alternative to be problem. taken forward to the From a technical side it is important to EIA phase of the understand that everything is not designed and project built in one day. The construction will be split up into developmental phases. As we continue from one phase to the next and data changes or technology changes we implement that into the new phase and design. As the phases progress from one to the other a new Waste Management Licence application is required in which the DEA can decide not to grant it due to environmental impacts. Decisions in the past were purely made with regards to cost whereas all decisions now are based on a wide variety of specialist studies. Willie Howell, EAP (2012) 18 How does the specialist study work, is it only done for one day? Mr Karel Rajchrt, Focus group The specialists will undertake representative How effective is that? Witklip meeting on 3 field visits to inform the integrity of their reports. August 2012 at This process is well planned and effective. 09:00 to present Some of the specialist studies need to be done information during summer and winter and will require regarding the multiple visits. inclusion of Site F Willie Howell, EAP (2012) as a feasible alternative to be taken forward to the EIA phase of the project

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19 If the lining for the ash dump cracks, will there be a disaster Mrs Carol Wentzel, Focus group The design for the liner will be finalised in the management plan in place? Bronkhorstspruit and meeting on 3 next stage. The plastic liner that is used for the Wilge River August 2012 at ash dumps has a lifespan of 1000 years. This Conservancy 09:00 to present plastic liner is used with a clay liner underneath information it, which makes it very effective. The only regarding the substance that can attack the plastic is inclusion of Site F petrochemicals, but this will not be on the site, as a feasible even if there were petrochemicals on site it alternative to be would have no effect on the clay liner. taken forward to the Detection systems will inform Eskom as soon EIA phase of the as there is a shortfall in the liner and actions project can be taken to ensure that waste management is implemented before the waste reaches any water bodies. Willie Howell, EAP (2012) 20 What happens after the 60 years with regards to rehabilitation? Mrs Carol Wentzel, Focus group The rehabilitation process should be Who will take responsibility then and can the ash dump be fully Bronkhorstspruit and meeting on 3 concurrent. After 5 years, preparation is made rehabilitated? Wilge River August 2012 at for the next rehabilitation process to be Conservancy 09:00 to present implemented. Rehabilitation of the ash dump information will continue until a closure certificate is issued, regarding the which follows an authorisation process. The inclusion of Site F closure certificate has conditions, hence even as a feasible after the closure certificate is issued, Eskom alternative to be will still be responsible and liable for the ash taken forward to the dump. The ash dump can fully be rehabilitated EIA phase of the and self-sustaining. project Willie Howell, EAP (2012) 21 Although not directly detailed but nonetheless relevant the issue Dr James Meyer, E-mail: 2 August There is a co-disposal facility, not an ash dump of the disposal of gypsum from Kusile Power Station remains Consultant for 2012 facility already planned and approved. The co- uncertain. Clarity regarding the use of the co-disposal site TOPIGS SA (Pty) Ltd disposal facility is designed to accept ash and currently available and impacts thereof on the proposed sites is gypsum from the first unit of the power station required as is the future handling requirements thereof. for a 5 year period. Thereafter it will receive the gypsum for the remaining life of the power station. Willie Howell, EAP (2012) 22 When will the final decision be made on which site is selected? H. van Aswegen E-mail: 27 The Environmental Impact Study is a long Belmoral Primary September 2012 process and the specialist studies will only be School done by middle next year (2013). Only after the specialist studies has been collated will a comparative assessment be undertaken to

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determine the most feasible site. Willie Howell, EAP (2012)

3.1.3 Water Comments 1 This development will be an ecological disaster for the Wilge Mr Andre Roets Reply sheet on 5 The potential ecological consequences will be River. Landowner: Farm: October 2011 fully investigated during the next phase of this Nooitgedacht study. Please see and comment on the proposed Terms of Reference for this study to ensure all elements of concern will be addressed. At completion of the specialist studies, the public will be given an opportunity to confirm acceptability of proposed mitigation strategies and plans. Willie Howell, EAP (2012) 2 Investigate the following: Dr Paul Meulenbeld, Reply sheet on 10 This will be fully investigated during the next  Impact on water quality and the impact on the Wilge River; DWA October 2011 phase of this study. Also, please refer to the  The impact of Site C on adjacent land value, groundwater, Terms of Reference for the water quality the N14, R104 and dust that will be generated, must be specialist studies, and give comments. investigated. Willie Howell, EAP (2012)

Relevant specialist studies were undertaken as part of the EIA for the proposed development, which include a sustainability assessment, Social Impact Assessment, Groundwater assessment, Traffic Impact Opinion and Air Quality assessment. The finding of the specialist studies are summarised in the FEIR, and complete specialist studies included in the Appendix F of the FEIR. Mathys Vosloo, EAP (2014) 3 Documentation relevant to Water Research Commission Dr James Meyer, E-mail: 1 Please see and comment on the proposed Endocrine Disrupting Chemical (WRC EDC) projects and Water Research November 2011 Terms of Reference for this study to ensure all agricultural water use in the area must be investigated. Commission, Pretoria elements of concern will be addressed. At completion of the specialist studies, the public will be given an opportunity to confirm acceptability of proposed mitigation strategies and plans. Willie Howell, EAP (2012) 4 How will water running off the conveyor belt and the ash Mr Robbie van Public meeting on Sufficient prevention systems will be in place to

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disposal facility be prevented from contaminating the ground Bulderen, Transnet 15 February 2012 at collect all polluted water (clean and dirty water water resources? Pipelines 14:00 to discuss channels next to conveyors). This will be and review the Draft pumped to a collection pond where it will be Scoping Report. cleaned. Another system will collect clean rain water. The ash disposal facility will be designed to prevent any seepage. A barrier made from clay and plastic materials will form the foundation of the ash disposal facility. Willie Howell, EAP (2012) 5 We would like to see the perceived risk of the ash disposal Mr Stefan Vermaak, Public meeting on This Draft Scoping Report we present here facility to the water quality that is very vital to the agricultural Topigs 15 February 2012 at today is a desktop study of the current industry adjacent to Kusile Power Station. 14:00 to discuss situation. You should also discuss all the risks in your study, what could go and review the Draft However in order to accurately detail the wrong and how that can be mitigated. Scoping Report. impact of this proposed project, various Eskom already told me water quality cannot be guaranteed 15 specialist studies will be undertaken and we years from now. will ensure that your concerns are addressed through these studies. In terms of water the studies will include a surface water and a ground water study. Furthermore air quality and the resultant health impacts will also be investigated. Willie Howell, EAP (2012)

Potential surface and groundwater impacts has been investigated by the relevant specialist studies (see Appendix F), and is summarised in the DEIR. Surface water runoff will be impacted on a minor scale. Surface water quality impacts already exist from agricultural and industrial activities within the Kusile Power Station sub-catchment. Additional project impacts will be minor as engineering design and proposed mitigation measures can be successfully implemented to prevent project impacts on surface water. Potential groundwater impacts can also be effectively mitigated to within acceptable limits, should the impact occur. Surface and ground water resources that may be impacted by the Kusile

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Power Station ash disposal facility will be stringently monitored in accordance to the approved monitoring plans included in the FEIR by an independent ECO. Mathys Vosloo, EAP (2014) 6 At the next public meeting the water quality and air quality These two specialists will be at the next specialists must also be available for discussion. meeting. Willie Howell, EAP (2012)

The water quality and air quality specialists were not available to attend the public meeting during the DEIR, however, any comments or concerns could have been submitted to the EAP and specialists which would provide answers and responses to any queries and comments. Written comment from Topigs SA was received during the DEIR and specialist provided comments to these issues and concerns in this CRR. Mathys Vosloo, EAP (2014) 7 Why is ground water not prominently highlighted in Sections 6, 7 Dr James Meyer, Public meeting on This suggestion will be taken further and and 9 of the Draft Scoping Report? Water Research 15 February 2012 at ground water will be elevated to a higher Commission, Pretoria 14:00 to discuss priority for these Sections. and review the Draft Willie Howell, EAP (2012) 8 Could you also do a baseline study on ground water? Scoping Report. This will be done during the next phase of this EIA as part of the relevant specialist study. Willie Howell, EAP (2012) A groundwater impact assessment was undertaken during the EIA phase and can be viewed in the FEIR, or in Appendix F of this FEIR. Mathys Vosloo, EAP (2014) 9 The elements monitored and assessed in the groundwater This will be included in the scope of works for assessment should focus on the elements of concern particularly the water assessments to be undertaken in the the elements related to coal. next phase of the study. Willie Howell, EAP (2012) A groundwater impacts assessment was undertaken during the EIA phase and can be reviewed in Appendix F of this DEIR. Mathys Vosloo, EAP (2014)

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10 Do you need a Water Use License Application (WULA)? Mr Hans van Public meeting on Yes, an amendment to Kusile Power Station’s Rensburg, Witklip 15 February 2012 at existing WULA is needed for the ash disposal 14:00 to discuss facility. and review the Draft A WULA is a living document and will be Scoping Report. amended when new developments are planned that may have an impact on water resources. An application for an amendment can only be made once the EIA process is finalised and one of the four alternatives has been chosen as the ash disposal facility. Eskom is currently negotiating with the DWA to find out if a separate WULA is necessary or if an amendment to the existing WULA can be done. The DWA must also approve the design of the ash disposal facility. Willie Howell, EAP (2012)

The WULA process has been undertaken concurrently with the EIA process. Extensive consultation with the Department of Water Affairs has been undertaken from the site selection and Scoping phase to the specialist findings in the DEIR phase. The WULA will be completed after completion of the EIA process, and will involve further consultation with key stakeholders. Mathys Vosloo, EAP (2014) 11 In which direction does the water flow on Site B. Mr Adriaan Loots, Public meeting on From the desktop info it appears as if Site B is Jakhalsfontein 15 February 2012 at on a watershed and that the water could flow in 18:00 to discuss two directions (north and south). This will be and review the Draft investigated during the next phase of the study. Scoping Report. Willie Howell, EAP (2012)

Detailed studies during the DEIR found that Site B is located on top of a watershed with runoff occurring on four direction into 2 quaternary catchments. Mathys Vosloo, EAP (2014) 12 What happens if the ash facility leaches into the groundwater? Ms Ria Loots, Public meeting on This should not happen, because a barrier will

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Jakhalsfontein 15 February 2012 at first be built on which the ash will be placed. 18:00 to discuss The barrier will prevent leaching, with any and review the Draft potential leachate being collected inside the Scoping Report. system. However, should there be a problem, Eskom be able to prove to the DWA that the problem has been solved and what measures have been taken to prevent this from happening again. There will also be monitoring systems in place to detect any leaks before it can become a problem. There will also be an independent Environmental Control Officer (ECO) on site that must report all problems to the authorities. The Kusile Power Station has an Environmental Monitoring Committee that can be attended by any neighbour or stakeholder. This committee is also attended by the DEA and the DWA. Willie Howell, EAP (2012)

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monitoring points (ground and surface water as well as air pollution) with that of Anglo American for the whole area. Willie Howell, EAP (2012)

In the event a leak does occur, this will be identified very early on through the leachate detection system installed as part of the barrier. Mitigation measures that can be implemented include pollution cut-off curtains installed vertically below ground to prevent lateral movement of the pollution, and pumping of the groundwater to form a cone of depression which will prevent the pollutants and ground water mixing. Groundwater can then be reintroduced into the aquifer downstream. Mathys Vosloo, EAP (2014) 14 Draft Scoping Report (DEA Reference Number: 12/12/20/2412) Dr James Meyer, Email in response Please note that although the WULA states under point 2.1 that: Consultant for to the Draft Scoping application will be a separate application, the In terms of Section 24 of the Constitution: TOPIGS SA (Pty) Ltd Report on 24 water related issues will be assessed as part of “Everyone has the right February 2012. this EIA and that all water-related specialist ii) to an environment that is not harmful to their wealth or well- studies will be done to the level of detail being, and required for an IWULA. iii) to have the environment protected, for the benefit of present Willie Howell, EAP (2012) and future generations, through reasonable legislative and other measure that - prevent pollution and ecological degradation; - secure ecologically sustainable development and use of natural resources.” Within the relevant legal framework it may be noted that pollution control and waste management form an integral part of sustainable development, with a principle of using utmost caution when permission is granted for new developments. Environmental impact assessments form a critical aspect of the process. In section 2.5 it is noted that any WULs that may be required in terms of the NWA will be addressed separately as part of the overall Integrated Water Use Licensing Process for the Kusile Power Station and will not be addressed by authorization

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process of this EIA. It is argued that any water used in the process of transporting, placing and storage of the waste streams (fly ash and coarse ash) should form a significant and critical part of the Draft Scoping Report and be included therein as part of the environment and subsequent EIA issues. 15 Section 3.4.6 does note some detail regarding storm water Dr James Meyer, Email in response Comment noted and please note changes to drainage and monitoring boreholes, but no monitoring Consultant for to the Draft Scoping the FSR subsequent to the public meeting. description is provided. TOPIGS SA (Pty) Ltd Report on 24 Willie Howell, EAP (2012) Section 6 lists “Issues Identified to date”, and notes impacts to February 2012. surface water features and air quality amongst other, but Groundwater, surface water and air quality nowhere is groundwater listed. impacts has been investigated during the EIA Section 7 “Receiving Environment” also lists Surface Water (7.5) phase through relevant specialist studies. but no groundwater or subterranean water impacts are Potential impacts to these environmental mentioned anywhere. aspects remain a central focus in the DEIR. It is argued that this should have formed a key part of data Mathys Vosloo, EAP (2014) collection (7.5.1 – no reference to groundwater) as the area contains numerous groundwater abstraction points for both Domestic and Agricultural Water Use (Livestock and Irrigation). Section 8 “Potential Environmental and Social Impacts” does however list groundwater in Table 13, yes in Section 9 “Plan of Study for EIA” under 9.2, no water quality specialist is mentioned, neither is groundwater specifically listed. Whilst “ surface water assessment” and “geo-hydrology and hydrology assessment” do appear in 9.2 and the following terms of reference issues do mention “water sampling and analysis”; “ potential impact to baseline conditions”; and “inter- connectedness i.e surface water-groundwater” it is argued that water quality of both surface and groundwater must specifically be investigated from a water quality assessment of all the recognized constituents relevant to the water uses applicable and to the relevant waste stream. The same argument applies to the air quality assessment terms of reference with the specific issues of air quality (descriptive and appropriately determined) for health hazards to both public health, animals and plants (pastures & crops). It is argued that groundwater should be elevated in terms of prominence in the Draft Scoping Report as a key issue that will receive appropriate attention, including groundwater quality in terms of baseline conditions, potential hazardous contamination

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and monitoring of relevant and appropriate constituents to ensure no adverse impact. 16 Thank you for doing this study to keep our environment clean. Ms Gloria Comment sheet on This is the reason an Environmental Impact Our municipality cannot keep our water pure and it is Macuthwane, 1058 the Draft Scoping Assessment has been undertaken. Your contaminated. Phola Location Report on 31 gratitude has been noted. January 2012 Willie Howell, EAP (2012) 17 In relation to the other proposed sites, we believe the impact on Van Rensburg E-mail: 11 January Your concern is noted and in order to the environment would be greater as the proposed area is Jordaan & Olivier 2012 understand the impact that this facility might surrounded by dams and streams. The ash would inevitably find Attorneys on behalf of have a range of specialist studies have been its way into these streams and dams, polluting not only the Hans van Rensburg proposed for the EIA phase of the project immediate area but also the area downstream from the affected Boerdery cc including ground water, surface water and air area. It would in our opinion probably affect the quality of quality. These reports will be made available drinking water not to mention the living conditions of the to the public as part of the review of this project communities nearby. during the EIA phase. 2. The Kungwini (Bronkhorstspruit) Dam Please also note that the design of this facility This dam provides drinking water to the town of Bronkhorstspruit will include barrier systems to prevent surface but also to a large part of Pretoria. Although the dam is not and ground water contamination. adjacent to the facility it is nearby and we are concerned of the Willie Howell, EAP (2012) effect that a 40 to 60m high ash heap may have on the dam, especially in windy conditions. The dam is only 6,3 kilometres The air quality specialist study undertaken from the proposed site. during the EIA phase has concluded that with successful implementation of the recommended mitigation measures, all air quality impacts can be confined to the development footprint. Mathys Vosloo, EAP (2014) 18 When coal is burned, toxins in the coal are released into the Mr Kobus E-mail: 30 March Your comments received has been noted. smokestack. With modern air pollution controls, airborne toxins Duvenhage, 2012 in response to Willie Howell, EAP (2012) are captured through filtration systems before they can become Chairperson of the Draft Scoping airborne, and contained in a fine ash called coal ash, fly ash, or Bronkhorstspruit and Report After extensive consultation with the coal combustion waste. As a result, heavy metals such as Wilge River Department of Water Affairs, the option of in-pit mercury are concentrated in what the EPA (USA Environmental Conservancy Assoc, ashing was rejected based on the fact that Protection Agency) considers "recycled air pollution control PO Box 691, lining the sides of the void or pit with an residue”. Bronkhorstspruit, appropriate barrier system will be impossible. Coal ash contains large quantities of toxic metals, including 1020. The feasibility of on-pit disposal has not been mercury, arsenic, beryllium, cadmium, chromium, nickel, and investigated for the New Largo site, which is selenium likely the only alternative which can be Most often coal waste is disposed of in landfills or "surface considered with regards to on-pit ashing. This impoundments," which are lined with compacted clay soil, a technology will have to be thoroughly plastic sheet, or both. As rain filters through the toxic ash pits investigated and is not likely to be complete

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year after year, the toxic metals are leached out and pushed before Kusile Power Station will produce its downward by gravity towards the lining and the soil below. An first ash. Therefore an ash disposal facility will EPA study found that all liners eventually degrade, crack or tear, have to be constructed, and with site A located meaning that all landfills eventually leak and release their toxins next to New Largo mine, it is the only into the local environment. alternative that will allow future switching of The flue-gas desulfurization (FGD) process creates a wet solid ash disposal to an on-pit option, if this option residue containing calcium sulfide (CaSO3) and calcium sulfate does proves feasible and viable. Furthermore, (CaSO4). Scientific American finds coal ash is more radioactive Kusile Power Station is currently under than nuclear waste. Although nuclear power retains the stigma construction and will not become operational of producing dangerous radiation, "waste produced by coal unless a suitable ash disposal facility is plants is actually more radioactive than that generated by their developed in close vicinity to the power station. nuclear counterparts" in addition to known problems such as After the waste stream analysis undertaken polluting the air and causing acid rain. Coal contains small during the site identification process, it was amounts of uranium and thorium, which are concentrated "up to concluded that 95% of the ash produced will 10 times" in coal ash, a waste product of burning coal. have to be disposed to landfill. Therefore, in Coal ash can leech radioactivity into the surrounding order for the Kusile Power Station to become groundwater and soil, depending on where it is disposed. operational, a suitable ash disposal facility will Robert Finkelman, a former US Geological Survey (USGS) have to be developed and engineered in the researcher, said that people living around coal plants will vicinity of the power station. increase the amount of radiation they are exposed to by 5% Mathys Vosloo, EAP (2014) every year. In May 2009, the Environmental Integrity Project and Earth Justice released a report finding that the Bush Administration failed to release information suggesting an alarmingly high cancer threat for people who live near coal ash waste dumps. According to the study, the Bush Administration only made a portion of the data available, hiding the true extent of the health risks associated with coal ash disposal sites. In 2002, an EPA study showed significant risk of coal ash sumps, but requests for the data under the Freedom of Information Act were either denied or given documents with the estimates of cancer risk blacked out. A 2007 EPA assessment report found that people living near coal ash dump sites have as high as a 1 in 50 chance of getting cancer from drinking water contaminated by arsenic. It also determined that living near such dump sites raises an individual's risk of liver, kidney, lungs and other organ damage resulting from exposure to toxic metals in the ash. All sites identified are either endangered grassland or cultivated agricultural land.

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The biodiversity of site A is Important and Necessary Site B is high potential agricultural land under cultivation Site C is right next to a Highly Significant Area Pg 25 “Disposal of the ash waste stream to an open cast void or levelled spoils created by opencast coal mining may be possible, although this would need to be determined at huge expense, there are currently no open-cast voids large enough available within a feasible distance to consider this option further at this juncture. New Largo is the only possible solution that may be large enough, but is currently not approved or operational. This option may be feasible in the distant future, but is currently not considered feasible; and….” We demand that a comparative analysis of the impacts , advantages and disadvantages of placing this ash dump facility on mined out areas (rehabilitated) be done, compared to the high potential agricultural soils that is suggested in this scoping report. We reserve our right to comment further. 19 Is the Water Use Licence included in the process? Mrs Annamie Focus group A Water Use Licence is included in several Duvenhage meeting on 3 activities and managed through authorities. Bronkhorstpruit and August 2012 at The Water Use Licence for the co-disposal Wilge River 09:00 to present stack has recently been granted. The Water Conservancy information Use Licence will be applied for after this regarding the process. A separate process is will be followed inclusion of Site F for the WUL. as a feasible Willie Howell, EAP (2012) alternative to be taken forward to the EIA phase of the project 20 Who will do the wetland specialist studies? Mrs Carol Wentzel Focus group A specialist from Wetland Consulting Services, Bronkhorstpruit and meeting on 3 Dieter Kassier, will be performing the wetland Wilge River August 2012 at specialist study. Conservancy 09:00 to present Willie Howell, EAP (2012) 21 Using contaminated water for the ash stack surely has a bigger information The air quality study will determine the impact impact on our health and environment? regarding the of health issues. But the interaction should not inclusion of Site F be more dangerous to health and environment as a feasible as the water being used for the irrigation will alternative to be already be contaminated with whatever is in taken forward to the the ash disposal facility. The re-use of this

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EIA phase of the water is a means to prevent environmental project impacts. Willie Howell, EAP (2012) 22 Won’t the impact of contaminated water usage increase over Mrs Carol Wentzel Focus group It might but it is unlikely since the water stays time? Bronkhorstpruit and meeting on 3 in a closed of process of being used, catched Wilge River August 2012 at and re-used. Conservancy 09:00 to present Willie Howell, EAP (2012) information regarding the With the proposed engineering design clean inclusion of Site F water and surface water runoff is kept separate as a feasible from the ash disposal facility and is released alternative to be back into the environment, while dirty water taken forward to the from runoff of the ash disposal facility will be EIA phase of the intercepted before mixing with the clean water project and re-used in a closed system to aid in minimisation of potential impacts. Mathys Vosloo, EAP (2014) 3.1.4 Pollution (Dust, Fly ash, Air) Comments 1 The only foreseeable concern that may arise is the fugitive dust. Mr Oscar Olën E-mail: 31 October Noted. The potential impact of air pollution will We would like to see that proper modelling has been done to Afrisam 2011 be fully investigated during the EIA phase of project the possible scenarios arising with the dust. And what this study. mitigating measures will be put in place to reduce the impact of Willie Howell, EAP (2012) the dust on surrounding communities. Impact Phase Note: Please refer to the Air Quality Basic Evaluation Report included in the DEIR under Appendix F- Spcialist Reports. Mathys Vosloo, EAP 2 As a first step we would like to draw your attention to the Mr Rico Euripidou, E-mail: 13 January The waste classification will be undertaken, following debate on the eco-toxicology of coal and incinerator GroundWork, Friends 2012 and the relevant mitigation measures will be ash which we consider meets the criteria as a hazardous waste of the Earth South implemented. In addition to the waste as there is currently a very live debate here in South Africa, in Africa classification Eskom is currently undertaking a the USA, The UK and Europe about regulating coal and similar comprehensive health and toxicity assessment incinerator bottom ash as hazardous waste and the respective of ash produced at several of its current power regulatory authorities are currently trying to finalise their stations. This study will feed into the waste regulations. These centre on some major and legitimate classification and also form part of the EIA. concerns about the use of coal and bottom ash in sludge dams Willie Howell, EAP (2012) and unbound uses such as the replacement for aggregate and this summary touches upon some of the arguments. The storage

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of post-combustion wastes from coal plants threatens human health once the toxic residues have migrated into water supplies. In South Africa specifically the coal ash from this facility will have to undergo testing and evaluation as per the WASTE CLASSIFICATION AND MANAGEMENT REGULATIONS AND STANDARDS in terms of the NEM: Waste Act. All wastes will have to be classified in terms of these regulations and based on their classification, risk to health and ecotoxicity this will define their waste management. To illustrate a particular major health and ecological incident on coal ash disposal I have provided you with an example below illustrating an incident in the USA where it can cause a very serious environmental and human health risk: It has now been two years since an earthen dike holding back 1.1 billion gallons of coal slurry ruptured, unleashing a tsunami of dark gray sludge from the Tennessee Valley Authority's Kingston Fossil Plant in Harriman, Tennessee. The wave destroyed homes, surged into the yards of neighbours, and caused the nearby ponds and streams to overflow. More than 300 acres of land were covered in the slurry, and in the weeks after, the ash would travel as far as 30 miles downstream on the nearby Emory River. The environmental disaster for the first time raised the question of why coal-burning power plants are allowed to dump the fly ash waste—the fine, dust-like particles emitted when coal is burned to create power—into vast open pits. The ash, doused with water and left in these containment ponds for years, contains toxic elements like arsenic, mercury, and lead. But for decades, the disposal of the waste was left unregulated in the USA where power plants produce more than 130 million tons of the ash each year, and while 43 percent of it gets recycled into products like cement and wallboard, much of the rest remains on site at coal-fired power plants around the country. In October 2009, the EPA issued a proposed rule [5] that would have designated the ash as hazardous waste that needed special handling and would be regulated at the federal level. Unregulated coal ash disposal poses health risks to humans and the environment, as the toxic materials have been found to leach into groundwater at containment sites. Following this an assessment prepared for the EPA noted that the cancer risk from drinking water contaminated with arsenic—

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just one of the many hazardous substances in the ash—is 1,800 times EPA's regulatory limit. The Environmental Integrity Project has been looking extensively at data on contamination, identifying 137 sites [11] where toxic materials have leached into the groundwater. At some sites, they found arsenic and other heavy metals at up to 145 times what is permissible under federal guidelines. If EPA kicks in tougher federal regulations, these sites would be monitored more closely. There is no doubt that the ‘fly ash’ is hazardous waste and will need to be treated and disposed of at specialist facilities. Recent research indicates that there are potentially serious health and environmental impacts arising from the landfill disposal of fly ash even in modern containment landfill sites (Macleod, Duarte-Davidson et al. 2006; Macleod, Duarte- Davidson et al. 2007). This shows that the modelled exposure to children around the Wingmoor farm landfill site, one of the major fly ash disposal facilities in the UK, can exceed acceptable intakes of dioxin from the contamination in the fly ash. Whilst the bottom ash is often described as being ‘inert’ this is incorrect – bottom ash is never classed as ‘inert’ in the UK. The bottom ash is currently taxed as “inactive” waste for landfill tax purposes although this may be about to change as the default position in the recent Customs and Excise consultation is that the bottom ash should be taxed at the standard rate of landfill tax. In practice the designation of bottom ash is either as non- hazardous or hazardous waste. At the end of 2006 the UK Environment Agency indicated that they had tested some bottom ash samples and: “Levels of lead and zinc in a number of isolated compliance monitoring samples have exceeded the hazardous waste threshold for H14.” H14 is the hazardous waste criteria for ecotoxicity. Veolia, one of the major incinerator operators, has indicates (Veolia Environmental Services 2007) that when they had tested for metals and then used the recent Environment Agency WM2.2 assessment methodology to determine the whether the wastes were hazardous wastes about 40% of the samples from UK incinerators were found to be hazardous waste under the H14 criteria. This follows increasing concern about the environmental impact of combustion residues in disposal and utilisation, especially for the release of toxic

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substances such as heavy metals (such as arsenic, cadmium, chromium, copper, mercury, molybdenum, nickel and, particularly in relation to ecotoxicity, lead and zinc) together with soluble salts from the residues (Stegemann, Schneider et al. 1995; Hartenstein and Horvay 1996; Hunsicker, Crockett et al. 1996; Abbas, Moghaddam et al. 2003). The content of toxic metals present in the bottom ash from coal and municipal waste incinerators is usually 10-100 times larger than in natural soils (Theis and Gardner 1990). As a result of the toxicity associated with the heavy metals and other contaminants several researchers have concluded that bottom ash should be classified as a hazardous waste because of the ecotoxic properties it exhibits. Ferrari et al (Ferrari, Radetski et al. 1999) subjected municipal waste incineration bottom ash to a range of ecotoxicity tests in both the leachate and solid phase. Their results clearly demonstrated “a significant increase in all antioxidant stress enzyme activity levels across all plant tests even at the lowest test concentrations (solid phase and leachate)”. This was demonstrated to be a good indicator of solid or leachate phase toxicity. As with many other test regimes it is clear from this work that the bottom ash may not prove hazardous in all tests. This indicates that care must be taken with the test regimes and that selective testing could deliver apparently reassuring, and hence misleading, results. For ash to be demonstrated to be hazardous, however, a single failure of an appropriate test is sufficient. Ibáñez et al. (Ibáñez, Andrés et al. 2000) found that all four samples of MSW bottom ash from two incinerators (one in an industrial and the other in a rural area) contained chemicals at or above the hazardous waste range. It should be noted that this study was published even before zinc oxide and chloride had to be considered when assessing the hazardous classification of ash. More recently the work by Lapa et al (Lapa, Barbosa et al. 2002) on the EC Valomat project concluded: “all bottom ashes [including sample B1] should be classified as ecotoxic materials.” Radetski et al (Radetski, Ferrari et al. 2004) then investigated the genotoxic, mutagenic and oxidant stress potentials of

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municipal solid waste incinerator bottom ash leachates and reported: “The MSWIBA leachates were found to be genotoxic with the Vicia root tip micronucleus assay. These findings were confirmed by Feng et al. (Feng, Wang et al. 2007): In this study, our results clearly demonstrated that MSWIBA leachates had genotoxicity on Vicia faba root cells as other researches did (Radetski, Ferrari et al. 2004). Bekaert et al. (1999[1] demonstrated that the aqueous leachates from a landfill of MSWI ash had a significant genotoxicity on the amphibian erythrocytes. The United Nations Environment Program (UNEP) (UNEP and Calrecovery Inc 2005) warned in 2005 that whilst ash from incinerators has been reused in civil engineering works: “in industrialised countries, the most prevalent method of management is disposal of the ash in lined landfills to control the risk of underground pollution by soluble toxic chemicals leached out of the ash. UNEP continued: “Both fly ash and bottom ash contain chemical constituents that pose potential serious risks to operating personnel and the public. The chemical constituents of concern include heavy metals, dioxins, and furans”. Feng expressed surprise about countries that do not include bottom ash on their hazardous waste lists: However, in many countries and territories (such as USA, some OECD countries, China), Bottom ash is not included in the List of Hazardous Wastes, being dumped into landfills directly or after maturation (Gau and Jeng, 1998; (Ibáñez, Andrés et al. 2000);(Lapa, Barbosa et al. 2002)). Therefore, we suggested that the comprehensive evaluation of the environmental impacts of BA is necessary before decisions can be made on the utilization, treatment or disposal of bottom ash. Ore et al (Ore, Todorovic et al. 2007) examined the leachate from bottom ash that had been stored outside for six months for weathering (in a similar way to the proposals by Suez) and then used for road construction. They carried out several ecotoxicity tests and found a high initial release of salts and Cu in line with relatively high concentrations in laboratory generated MSWI bottom ash leachates presented in the literature (Meima and Comans 1999; Lapa, Barbosa et al. 2002). A mung bean assay using Phaseolus aureus revealed the toxicity of bottom ash leachate - which continued to the final tests three years later,

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albeit due to different compounds leaching. Leachates with significantly higher concentrations of Al, Cl, Cr, Cu, K, Na, NO2–N, NH4–N, total N, TOC and SO4 were generated in the road-section built on bottom ash when compared to the road-section built with conventional gravel. Compared to the leachate from gravel, the concentrations of Cl, Cu and NH4–N were three orders of magnitude higher, while those of K, Na and TOC were one order of magnitude higher. After 3 years of observations, while the concentrations of most components had decreased to the level in gravel leachate, the concentrations of Al, Cr and NO2–N in bottom ash leachates were still two orders of magnitude higher. The authors concluded that high concentrations of chloride emitted from the road can lead to increased toxicity to the recipient, e.g. for plants, and the bottom ash reused in a road construction could thus have a toxicological impact on the surroundings. A series of ring tests for ecotoxicity methods have been carried out in Europe (Becker, Donnevert et al. 2007; Moser 2008). These included sampling and testing of incinerator bottom ash from a Dutch incinerator (Cu 6,800 mg/kg; Zn 2,639 mg/kg; Pb 1,623 mg/kg) a high pH (about 10.5). The bottom ash was found to be ecotoxic in these tests even after it had been aged for several months (Römbke, Moser et al.). Very recently the UK Highways Agency (Highways Agency 2009) has banned the use of incinerator bottom ash in foaming cement because of a series of explosions on sites caused by hydrogen when the ash has been used (Mann 2009). The Environment Agency has admitted it does not "have 100% confidence" in its classification of incinerator bottom ash (IBA) as non-hazardous waste (ENDS 2009). It cannot therefore be assumed that the bottom ash would be suitable for re-use – and, properly assessed much of the bottom ash would almost certainly be hazardous waste. Finally it is noted that even when incinerator bottom ash is ‘recycled’ only part of the ash can be used. In Hampshire, for example, where particular efforts have been made to increase the acceptability of incineration only about 33% of the ash can be utilised according to Project Integra reports[2]. The landfill demand is therefore likely to be higher than suggested by operators. On the basis of the evidence available it is reasonable

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to conclude that bottom ash should be treated as hazardous waste and that future disposal options represent a potentially high risk and expensive addition to the costs of incineration. 3 I notice that a traffic study will be done. Has this started as yet? Ms Carla Davis, E-mail: 13 At present we are only in the Draft Scoping Site C is adjacent to the N4 Toll Road. The SANRAL Act, Act 8 Traffic Engineer, February 2012. Phase so no specialist studies have been of 1998 will apply regarding building lines and services within the Trans African completed as yet. Once the DEA has accepted building line. A 60m building line is applicable from the road Concessions (Pty) the Scoping Report (2-3 months) we will start reserve. Limited with the specialist studies and we will ensure Dust could be problematic. What measures will be taken to that you get a copy of the traffic report. ensure that dust will not blow onto the N4 Toll Road? What dust In addition the air quality assessment will monitoring will be done? This could be a safety hazard if it assess the problems related to dust deposition causes poor visibility on the N4 Toll Road. Dust is also a and visibility. nuisance as part of road maintenance, as frequent cleaning of Willie Howell, EAP (2012) roadside furniture, such as road signs, guard rails and guard rail reflectors would be required. Concerning traffic I will only be able comment on this once the traffic impact report has been submitted to us. 4 How will the dust/ash be controlled to prevent pollution? Mr Hans van Public meeting on Dust suppression with water will prevent ash Rensburg, Witklip 15 February 2012 at being blown away. Top soil that would have 14:00 to discuss been removed before the ash was placed will and review the Draft be put on top of the ash and vegetation will be Scoping Report. planted to anchor it. More detail on the dust suppression measures is provided in the Environmental Management Programme (EMPr) and air quality reports in the next phase of the EIA. Willie Howell, EAP (2012) Impacts of dust and air quality is discussed in the air quality impact assessment provided in Appendix F of this DEIR. Mathys Vosloo, EAP 5 There is a lot of dust at the Kendal power station. Mr Hans van Public meeting on The ash disposal facility at Kendal power Rensburg, Witklip 15 February 2012 at station was designed and built with old 14:00 to discuss technology. This facility is a long and thin and review the Draft structure with a large area exposed to the Scoping Report. wind. Ideally the Kusile ash disposal facility will be square in shape to reduce exposure to wind. Engineering aspects of the Kusile Ash Disposal Facility, however, be thoroughly investigated

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during the next phase of this EIA. Mitigation measures will be written into the Environmental Management Programme (EMProg) that must be adhered to during construction and the daily operation of the ash disposal facility. Eskom is also continuously investigating measures of how the dust pollution at Kendal can be reduced. Impact Phase Note: Engineering aspects of the ash disposal facility design was investigated in the EIA phase of the project and can be viewed in Appendix G of this DEIR. The ADF design was optimised to reduce the footprint of the facility while still ensuing capacity to receive the entire 60 years’ worth of ash produced. Mathys Vosloo, EAP 6 There must be no dust pollution. Mr Hans van Public meeting on The EIA will recommend various dust Rensburg, Witklip 15 February 2012 at management measures; the effective 14:00 to discuss implementation of these measures should and review the Draft reduce the dust. Please refer to the air quality Scoping Report. assessment that will be undertaken in the next phase of the EIA. Impact Phase Note: Please refer to the Air Quality Basic Evaluation Report included in the DEIR under Appendix F- Spcialist Reports. Mathys Vosloo, EAP 7 Why did you use a 75% waste stream and not a full 100% waste Dr James Meyer, Public meeting on A power station never runs at 100% for 60 stream in your calculations? Water Research 15 February 2012 at years. With downtime for maintenance and Commission, Pretoria 14:00 to discuss normal demand a figure of 75% is more and review the Draft realistic. Scoping Report. Willie Howell, EAP (2012) 8 What is the wind direction at Kusile Power Station? Mr Zweli Mpofu, Public meeting on The main wind direction is from the north west. Bravo Cooperative, 15 February 2012 at Willie Howell, EAP (2012) Hartbeestfontein. 14:00 to discuss and review the Draft Scoping Report. 9 Will the ash disposal facility be kept wet all the time to prevent Mr Adriaan Loots, Public meeting on Various studies will be done to find the most dust pollution? Jakhalsfontein 15 February 2012 at effective dust suppression method, but water

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18:00 to discuss suppression is a common method that will be and review the Draft practiced throughout the life of the facility in Scoping Report. exposed ash surfaces. Willie Howell, EAP (2012) 10 In the Schedule of Government Notice No. 32816 (24 Dec 2009) Dr James Meyer, Email in response Thank you for your comments. The the National Ambient Air Quality Standards are established Consultant for to the Draft Scoping constituents of concern mentioned in your (NEM: Act 34 of 2004), with section 2.3 on Ambient air quality TOPIGS SA (Pty) Ltd Report on 24 submission will be added to the scope of work measurement requirements stating that the assessment of all February 2012. for the relevant specialist study. ambient pollutant concentrations shall be conducted in terms of Willie Howell, EAP (2012) the relevant sections of the National Framework for Air Quality Impacts of the hazardous constituents of ash Management. Section 3 on National Ambient Air Quality being transported and disposed at the facility

Standards addresses SO2, NO2, Particulate matter, ozone, were investigated in the air quality assessment benzene, lead and carbon monoxide. undertaken during the EIA phase of the project. Although the Kusile Power Station is to use FGD to reduce many The air quality specialist report can be of these hazardous coal combustion products (specifically the scrutinised in Appendix F of this DEIR.

SO2 and NO2) concern still exists for list of potentially hazardous Mathys Vosloo, EAP constituents related to coal, combustion thereof, storage of combustion products and related activities, including transport of both coal and combustion products. It is widely published that concern for trace elements in FGD byproduct (e.g. arsenic, selenium and mercury) limits the utilization of FGD byproduct and that the release of FGD byproduct is a barrier impacting utilization thereof. It is also widely reported in the literature that trace elements may be captured by fly ash and coarse ash with consequent significant environmental concerns as many are reported to be carcinogenic, toxic and potential endocrine disruptors. The key carcinogenic elements most frequently cited include arsenic, cadmium, nickel and zinc, whilst toxicity concerns are most often reported for selenium and mercury. The scientific literature generally reports potentially hazardous trace elements associated with fly ash to be:  Arsenic  Aluminium  Antimony  Barium  Beryllium  Bromide  Cobalt  Chromium

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 Copper  Iron  Lanthanum  Lead  Manganese  Mercury  Molybdenum  Nickel  Selenium  Silicon  Strontium  Tungsten  Uranium  Vanadium In addition many macro elements are cited such as Fluoride, Sulphur and Nitrogen. Other potential hazards include PAHs and VOCs. Although many technologies to improve emissions quality exist and may be applicable to Kusile Power Station these do not totally remove the hazards and concern for hazardous constituents still exists. In some cases the removal of hazards from air in an attempt to improve the air quality and reduce air emissions may result in a higher non-airborne hazardous waste requiring disposal. According to studies published regarding health impacts associated with coal-fired power plants and disposal of coal combustion products concern exists for both air quality and water quality impacts. Numerous environmental studies also observe hazardous substances in a variety of exposure media, from soil to aquatic organisms utilized for human consumption. Public health studies cite 84 separate hazardous air pollutants to be associated with coal-fired power plants. There is thus a wealth of information in the scientific literature where the environmental aspects of trace elements in coal and coal combustion products (including fly ash) are reviewed and researched. Critically, it cannot be assumed that Kusile Power Station will automatically monitor the relevant pollutants as the current EMC process omits obvious elements relevant to establishing baseline concentrations that may be adversely affected or

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impacted by coal-fired power stations. As noted above, trace elements described in FGD by-products also include recognized potentially hazardous elements such as arsenic, selenium and mercury. Studies note that disposal of the ash may be accompanied by dissolution of calcium that may lower the pH and calcium concentration in the leachate facilitating the release of arsenic and mercury, which may be argued to represent a greater environmental hazard. It is thus argued that these constituents are known, internationally published and cited, and should be specifically included in any EIA process for the relevant sources, pathways and receptors. Key Concern: Nowhere in the Draft Scoping Report is specific reference to these constituents noted, and although it may be argued that they are included by implication, it is argued that in order for meaningful public participation and acceptable EIA terms of reference to be formulated, they should appear prominently in the report with clear assurances that they will be established in terms of baseline values, potential hazardous waste streams and monitored accordingly. Failure to do this transparently may result in various environmental and water licenses and authorizations to be granted without specific reference to the primary pollutants relevant. 11 Section 3.2.3 describes the waste streams in Table 4. Although Dr James Meyer, Email in response The calculations related to the potential volume some reasons were offered verbally at the public meeting on Consultant for to the Draft Scoping of ash to be disposed are based on the best 15/02/2012 at El Toro (Kendall) it remains unclear how the TOPIGS SA (Pty) Ltd Report on 24 information available at present. We will calculations for the approval of Kusile Power Station Ash Dump February 2012. endeavour through the design process to could be so underestimated to the point that the current 10 year finalise all these figures to a high level of Ash Dump Facility is only capable of handling 16 % of the waste confidence. stream envisaged. In the case of this EIA if the authorities place Although the calculations for Table 4 state a volume of ash similar restrictions on the proposed produced at 75% of the waste stream it is assumed this is meant development more than one site will be utilised to read of the “potential” waste stream. Despite the preferred to ensure that the full life of the station is approach (see point 1 above) being one that is conservative and covered. This objective (to provide a legislated one that should thus err on the higher risk side, this is not waste disposal facility for the life of the Kusile performed. Power Station) is the main purpose of the If the initial projections failed in forming a reasonable estimate of design team, hence if any restrictions apply to the required ash dump facility size and scope it is unclear how a particular or all sites, a motivation to use

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the Draft Scoping Process accommodates the same set of multiple sites will be provided. scenario circumstances from occurring again (as verbally Willie Howell, EAP (2012) explained for the 10 year ash dump). Should the WUL and other EIA restrictions be placed (apparently key reasons for the initial ash dump being inadequate) again in a manner to yield the same outcome, namely that the 60 year ash dump is also insufficient, then the Draft Scoping Report will not be applicable to the Kusile Power Station waste stream relevant, and may run the risk of having yet another additional waste stream burden that will require yet another similar process. It is argued that for the initial authorizations and licenses (specifically WULs) to be valid they should not misrepresent the actual waste stream specifics and that this Draft Scoping Report may be taken as an indication that the current authorizations and licenses were based on misleading calculations and thus require amendments or new compliance notices. 12 No mention is made of handling the waste stream from human Dr James Meyer, Email in response Noted – the issues pertaining to human and effluent and other hazardous wastes associated with the Consultant for to the Draft Scoping construction related wastes will be included in construction phase, both of the ash dump and conveyor TOPIGS SA (Pty) Ltd Report on 24 the FSR and highlighted in the relevant systems. February 2012. specialist studies. No indication is given of the number of people involved and The mitigation and management measures assurances to prevent contamination of the environment related to these will also be included in the (including wetlands, surface and groundwater) by their waste Environmental Management Programme that and construction-related hazards. will specifically be written for the construction It is argued that this should form part of the EIA process as phase of the project. construction can be assumed to be a process requiring a Willie Howell, EAP (2012) significant amount of time and people. The handling the waste stream from human effluent and other hazardous wastes associated with the construction phase, both of the ash disposal facility and conveyor systems has been investigated and addressed in the DEIR and Environmental Management Programme. Mathys Vosloo, EAP 13 The US EPA notes an increase in sites classified as High Dr James Meyer, Email in response Noted and the specialist studies scopes have Potential Hazard with reference to Coal Combustion Residues Consultant for to the Draft Scoping been expanded to include source, pathway and the scientific literature (peer-reviewed journals) dealing with TOPIGS SA (Pty) Ltd Report on 24 receptor analysis on all the relevant studies. coal combustion products, byproducts and related waste, February 2012. Willie Howell, EAP (2012) continue to note a range of environmental concerns affecting a Monitoring protocols have been proposed for wide range of receptor types, including aquatic, human and measuring of the relevant pollutants in the

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animal. relevant specialist studies. See Appendix F for To date, key critical data gaps exist in the Kusile EMC the air quality, groundwater and surface water Monitoring reports, with no meaningful response to requests for specialist studies. specific constituents (pollutants and hazardous substances) to Mathys Vosloo, EAP be monitored to establish current air quality, groundwater quality or surface water quality. It is thus a concern that failure to have the list noted under point 1 included in the EIA process will render those affected by the proposed ash dump open to the same lack of monitoring data which would effectively prevent an assessment of impact. The sources, pathway and receptor approach is fundamental to the assessment of hazards and risks and accepted world-wide, and implied in the relevant NEMA and NWA Acts. Observation in terms of sampling, analytical determination and transparent reporting, of the relevant potentially hazardous constituents should be included for all these aspects (waste stream and other possible sources; pathways as relevant, e.g. air, soil, water, plant; for relevant receptor types). 14 An issue was raised about dust control and how it will be Mr Warren Kok, Focus group Dust is a problem at ash disposal facilities. managed. Zitholele Consulting meeting on 20 July Studies will be undertaken to quantify this 2012 at 10:00 to impact. Typical dust control measures include present information controlled irrigation on the facility, covering with regarding the vegetation, etc. inclusion of Site F Willie Howell, EAP (2012) as a feasible alternative to be taken forward to the EIA phase of the project 15 Traditional methods of dust control do not work. Other methods Mrs Annamie Focus group This is true, and is noted for the record. must be found. Duvenhage, meeting on 20 July Willie Howell, EAP (2012) Bronkhorstspruit and 2012 at 10:00 to Dust control methods has been included in the Wilge River present information engineering designs and include concurrent Conservancy regarding the and continuous rehabilitation of the ash inclusion of Site F stabilised areas behind the advancing ash as a feasible stack front, and installation of dust suppression alternative to be system that will keep the surface of the taken forward to the exposed ash moist to prevent windblown ash. EIA phase of the The air quality report has further recommended project planting of trees and vegetation around the ash

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disposal facility, besides wetting of the ash facility. This approach has shown successful containment of dust and ash during the modelled simulations. See Appendix F for the air quality, groundwater and surface water specialist studies. Mathys Vosloo, EAP 16 There is no proper monitoring of dust and dust control present at Dr James Meyer, Focus group Thank you and this is noted for the record. Kusile. Consultant for meeting on 20 July Specialists will be requested to review this TOPIGS SA (Pty) Ltd 2012 at 10:00 to during their detailed investigations, and present information propose better monitoring of this facility for the regarding the EMP. inclusion of Site F Willie Howell, EAP (2012) as a feasible alternative to be Post meeting note: taken forward to the Kusile has got a dust monitoring programme, EIA phase of the and measures, e.g. water suppression, binding project chemical. On a monthly basis, monitoring is done through a dust bucket system. Kusile has an ASTM standard which it is in compliance with. Willie Howell, EAP (2012) 17 A big concern is the pollution implications with the ash facility. It Mrs Annamie Focus group This is noted for the record. Specialist studies is going to pollute the air, water and soil, also have health Duvenhage, meeting on 20 July will address these concerns and quantify the implications and lead to land degradation and reduce crop Bronkhorstspruit and 2012 at 10:00 to impact. production. We are also concerned about the visual impact of Wilge River present information Willie Howell, EAP (2012) the ash dump and the impact to our property values Conservancy regarding the inclusion of Site F Potential surface and groundwater impacts has as a feasible been investigated by the relevant specialist alternative to be studies (see Appendix F), and is summarised taken forward to the in the DEIR. Surface water runoff will be EIA phase of the impacted on a very minor scale. Surface water project quality impacts already exist from agricultural and industrial activities within the Kusile Power Station sub-catchment. Additional project impacts will be minor as engineering design and proposed mitigation measures can be successfully implemented to prevent project impacts on surface water. Potential groundwater impacts can also be effectively

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mitigated to within acceptable limits, should the impact occur. The social specialist has found that property values may have already been impacted in the study are with the development of the Kusile Power Station and New Largo mine. The impact is rated as moderate-low. Mathys Vosloo, EAP 18 How is the ash being kept from blowing away? Mrs Carol Wentzel, Focus group The ash is managed through irrigation systems Bronkhorstspruit and meeting on 3 using water from the plant. Water generated Wilge River August 2012 at from the ash stack is used as top up irrigation Conservancy 09:00 to present water. No water will be taken from the nearby information streams or rivers. regarding the Willie Howell, EAP (2012) inclusion of Site F as a feasible alternative to be taken forward to the EIA phase of the project 19 Whilst the issue of air quality and dust suppression is noted in Dr James Meyer, E-mail: 2 August The EIA will recommend various dust the draft scoping report and during the presentations the Consultant for 2012 management measures. An air quality specialists have all admitted to the fact that despite the TOPIGS SA (Pty) Ltd assessment will be undertaken in the next mitigation measures that may be put in place some impact from phase of the EIA. dust and ash-particle fallout will occur. Impact Phase Note: It was noted by the specialists that this currently occurs at Waste byproducts from the FGD process to be Kendal ash disposal site. installed at the Kusile Power Station falls This is a major concern for not only public health but the outside the scope of this EIA, and shall agricultural production activities currently underway by the therefore not be responded to. landowners potentially affected. The Witbank area currently shows elevated air This affects animal health directly by sensitive pulmonary quality impacts. It was however found that air exposure pathways and related respiratory and subsequent quality impacts associated with the transport systemic adverse effects, and indirectly by grazing quality. Crop and disposal of ash on the ash disposal facility production may obviously also be adversely affected by fallout, will not elevate the status quo pollution levels. product quality and long-term soil effects. Furthermore, with the successful It is proposed that this aspect needs to be addressed more fully implementation of the recommended mitigation and comprehensively by a workshop/specialist/stakeholder measures, this impact can be confined to interaction where these issues and the issues noted below are within the development footprint. dealt with: Please refer to the Air Quality Basic Evaluation National Ambient Air Quality Standards are established (NEM: Report included in the DEIR under Appendix F-

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Act 34 of 2004), with section 2.3 on Ambient air quality Specialist Reports. measurement requirements stating that the assessment of all The draft EMPr (Appendix I) also address the ambient pollutant concentrations shall be conducted in terms of recommendations proposed for dust the relevant sections of the National Framework for Air Quality management. Management. Section 3 on National Ambient Air Quality Mathys Vosloo, EAP

Standards addresses SO2, NO2, Particulate matter, ozone, benzene, lead and carbon monoxide but monitoring needs to include a comprehensive list of potentially hazardous constituents related to coal, combustion thereof, storage of combustion products and related activities, including transport of both coal and combustion products. Additional key elements include:  trace elements in FGD byproduct (e.g. arsenic, selenium and mercury)  trace elements captured by fly ash and coarse ash with consequent significant environmental concerns as many are reported to be carcinogenic, toxic and potential endocrine disruptors. The key carcinogenic elements most frequently cited include arsenic, cadmium, nickel and zinc, whilst toxicity concerns are most often reported for selenium and mercury. Potentially hazardous trace elements associated with fly ash include: Arsenic; Aluminium; Antimony; Barium; Beryllium; Bromide; Cobalt; Chromium; Copper; Iron; Lanthanum; Lead; Manganese; Mercury; Molybdenum; Nickel; Selenium; Silicon; Strontium; Tungsten; Uranium; Vanadium. Macro elements include Fluoride, Sulphur and Nitrogen. Other potential hazards include PAHs and VOCs. According to studies published regarding health impacts associated with coal-fired power plants and disposal of coal combustion products concern exists for both air quality and water quality impacts. Numerous environmental studies also observe hazardous substances in a variety of exposure media, from soil to aquatic organisms utilized for human consumption. Public health studies cite 84 separate hazardous air pollutants to be associated with coal-fired power plants. Given the sensitivity of the catchment involved for all the sites in terms of wetlands and surface water, and the reliance on groundwater by many of the affected landowners, water quality impacts need to be

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monitored for the same constituents noted above for air quality. In addition, as noted in the previous comments submitted, concerns regarding Turbidity, Suspended Solids, COD, Ammonia and microbiological indicator organisms are also valid due to the impacts for construction activities and stormwater runoff. These should thus also be monitored to assess environmental impact on a continuous basis as it is understood that the construction of the ash disposal facility or facilities will not be a single event but rather an ongoing process as storage requirements increase over time. 3.1.5 Noise Comments 1 Will there be noise buffer zones? Mr Adriaan Loots, Public meeting on The noise levels will be in line with that of an Jakhalsfontein 15 February 2012 at agricultural zone. A noise assessment is one of 18:00 to discuss the specialist studies that will be undertaken and review the Draft during the next phase and included in this Scoping Report. assessment will be recommendations related to noise buffers. Willie Howell, EAP (2012) The noise assessment concluded that noise levels will be within acceptable limites and noise impacts can be kept far enough away from noise receptors to successfully mitigate the potential impact. The noise assessment can be viewed in Appendix F. Mathys Vosloo, EAP 2 What will the noise impact be? Mrs Annamie Focus group A noise specialist study has been included in Duvenhage meeting on 20 July the EIA, and it will determine this and provide Bronkhorstspruit and 2012 at 10:00 to mitigation. Wilge River present information Impact Phase Note: Conservancy regarding the The noise assessment concluded that noise inclusion of Site F levels will be within acceptable limites and as a feasible noise impacts can be kept far enough away alternative to be from noise receptors to successfully mitigate taken forward to the the potential impact. The noise assessment EIA phase of the can be viewed in Appendix F. project Mathys Vosloo, EAP 3.1.6 Agriculture Comments 1 The proposed Site B takes up most of my farm. The remaining Mr Hans Jansen van Reply sheet on 30 Noted. If the site is the preferred and

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land will not make it economically viable to continue farming. Rensburg September 2011 recommended site, through the EIA process, Landowner: Farm: appropriate engagement and negotiations will Witklip be held with the landowner, by Eskom once DEA authorises a particular site. Willie Howell, EAP (2012) Site alternative A has been identified as the preferred alternative. All the properties affected by site A is owned by Eskom, therefore there will be no direct impacts on existing farming operations. A comprehensive Environmental Management Programme will also be implemented to avoid or at the very least minimise any potential indirect impacts on agricultural activities in the vicinity of the ash disposal facility. In the event the competent authority reject the EAP’s recommended site – Site A – and authorise another site alternative, then the land owner negotiation process will commence. Construction of the ADF should only commence once successful negotiations has been concluded with all affected land owners. Mathys Vosloo, EAP 2 I farm with organic export berries. This development will mean Mr Andreas Moll Reply sheet on 7 The potential impact on agriculture will be fully the end of our farming activities and our existence. (A detailed Landowner: Farm October 2011 investigated during the next phase of this presentation of the farming activities that will be destroyed by Jakhalsfontein study. Please see and comment on the this development can be found in the attached documentation.) proposed Terms of Reference for this study to ensure all elements of concern will be addressed. At completion of the specialist studies, the public will be given an opportunity to confirm acceptability of proposed mitigation strategies and plans. Willie Howell, EAP (2012) Site alternative A has been identified as the preferred alternative. All the properties affected by site A is owned by Eskom, therefore there will be no direct impacts on existing farming operations. A comprehensive Environmental Management Programme will also be implemented to avoide or at the very least

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minimise any potential indirect impacts on agricultural activities in the vicinity of the ash disposal facility. In the event the competent authority reject the EAP’s recommended site – Site A – and authorise another site alternative, then the land owner negotiation process will commence. Construction of the ADF should only commence once successful negotiations has been concluded with all affected land owners. Mathys Vosloo, EAP 3 Site B will affect one portion of my farm, but since all three Mr Hennie Reply sheet on 22 Noted. Please note that the potential impact on portions are being managed as one unit, all three portions will Terblanche October 2011 agriculture will be fully investigated during the eventually be affected. Landowner: Farm: next phase of this study. If the site is the Bossemanskraal preferred and recommended site, through the EIA process, appropriate engagement and negotiations will be held with the landowner, by Eskom. Willie Howell, EAP (2012) Impact Phase Note: Site alternative A has been identified as the preferred alternative. All the properties affected by site A is owned by Eskom, therefore there will be no direct impacts on existing farming operations. A comprehensive Environmental Management Programme will also be implemented to avoid or at the very least minimise any potential indirect impacts on agricultural activities in the vicinity of the ash disposal facility. In the event the competent authority reject the EAP’s recommended site – Site A – and authorise another site alternative, then the land owner negotiation process will commence. Construction of the ADF should only commence once successful negotiations has been concluded with all affected land owners. Mathys Vosloo, EAP 4 Site B will adversely affect agricultural land. There are various Mr P.J. Schreuder Reply sheet on 16 The potential impact on agriculture and all wetlands and dams that will be negatively affected by your October 2011 water resources will be fully investigated during

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development. Pollution from the ash disposal facility will affect the next phase of this study. agricultural operations, the wetlands and dams. There is also an The oil pipeline will be confirmed and the oil pipeline that is not marked on your map. feasibility of the site, with such infrastructure, will be investigated. Willie Howell, EAP (2012) Impact Phase Note: Site alternative A has been identified as the preferred alternative. All the properties affected by site A is owned by Eskom, therefore there will be no direct impacts on existing farming operations. A comprehensive Environmental Management Programme will also be implemented to avoid or at the very least minimise any potential indirect impacts on agricultural activities in the vicinity of the ash disposal facility. In the event the competent authority reject the EAP’s recommended site – Site A – and authorise another site alternative, then the land owner negotiation process will commence. Construction of the ADF should only commence once successful negotiations has been concluded with all affected land owners. Mathys Vosloo, EAP 5 This development will adversely affect agricultural land. Mr Hennie Pienaar Reply sheet on 24 The potential impact on agriculture will be fully Alcedo October 2011 investigated during the next phase of this study. Please see and comment on the proposed Terms of Reference for this study to ensure all elements of concern will be addressed. At completion of the specialist studies, the public will be given an opportunity to confirm acceptability of proposed mitigation strategies and plans. Willie Howell, EAP (2012) Impact Phase Note: The loss of agricultural land, even on site A which is the preferred site and Eskom owned, will be inevitable. A number of envinmental, social, technical and economic aspects were considered during the comparative assessment

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of the alternative sites, therefore loss of agricultural land on Site A must be considered acceptable. Please refer to the Soils & Land Capability Report included in the DEIR under Appendix F- Specialist Reports. Mathys Vosloo, EAP 6 My farm Jakhalsfontein Portion 31 is due north of the proposed Mr Adriaan Loots Reply sheet on 18 The potential impact on agriculture and all Site B. Gala Boerdery October 2011 water resources will be fully investigated during  The farm Jakhalsfontein has a JR number of 528 and not the next phase of this study. Air pollution will 258. also be investigated. Please see and comment  I supply vegetables to a variety of businesses such as on the proposed Terms of Reference for this Woolworths in a 120 km radius. We are dependent on good study to ensure all elements of concern will be quality water to supply high quality vegetables. Our water addressed. At completion of the specialist originates from your Site B. studies, the public will be given an opportunity  Six new houses with a value of around R2 million are being to confirm acceptability of proposed mitigation used to plant the vegetables in. These structures cannot be strategies and plans. moved. Willie Howell, EAP (2012)  We provide labour to unemployed people and especially Impact Phase Note: women from area. If this ash disposal facility is going to be Site alternative A has been identified as the built on Site B, many employment opportunities will be lost. preferred alternative. All the properties affected  The wetlands north of Site B will be adversely affected. This by site A is owned by Eskom, therefore there water eventually ends up in Loskop Dam, a major irrigation will be no direct impacts on existing farming source. operations. A comprehensive Environmental  Many animals are directly dependent on the wetlands for Management Programme will also be survival. implemented to avoide or at the very least  Air pollution will have a negative impact on the vegetable minimise any potential indirect impacts on famers next to Site B. agricultural activities in the vicinity of the ash disposal facility.  All farming activities next to Site B will be negatively In the event the competent authority reject the affected. EAP’s recommended site – Site A – and authorise another site alternative, then the land owner negotiation process will commence. Construction of the ADF should only commence once successful negotiations has been concluded with all affected land owners. Mathys Vosloo, EAP 7 We farm on Witklip 12 and will be directly affected by Site B. Mr CJ Gerber E-mail: 26 October Noted. The potential impact on agriculture and This development will affect a fountain on my property which Landowner: Farm 2011 all water resources will be fully investigated also provides water to other farmers, such as Eagles Pride Witklip during the next phase of this study.

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Hatchery, as well. Willie Howell, EAP (2012) Agricultural land in Gauteng is already marginalised. Dumping Impact Phase Note: waste in Gauteng that will be created in Mpumalanga will have a Site alternative A has been identified as the financial impact on Gauteng farmers. preferred alternative. All the properties affected by site A is owned by Eskom, therefore there will be no direct impacts on existing farming operations. A comprehensive Environmental Management Programme will also be implemented to avoid or at the very least minimise any potential indirect impacts on agricultural activities in the vicinity of the ash disposal facility. In the event the competent authority reject the EAP’s recommended site – Site A – and authorise another site alternative, then the land owner negotiation process will commence. Construction of the ADF should only commence once successful negotiations has been concluded with all affected land owners. Mathys Vosloo, EAP 8 With regard to the above proposed site for the establishment of Van Rensburg E-mail: 11 January Your comment is noted and considered. an ash disposal facility, on the farm Witklip 539, Jakhalsfontein Jordaan & Olivier 2012 Willie Howell, EAP (2012) 258 and Nooitgedacht 525, as well as the proposed conveyor Attorneys on behalf of corridor over various farms including Bossemanskraal 538 JR Hans van Rensburg (the site marked as “Site B” on your map), we would like to make Boerdery cc the following comments on behalf of our client, who owns the farm Witklip 539 JR and parts of the farm Bossemanskraal 538 JR. Please take note that these comments are based on our initial assessment of the situation and, as additional information comes to hand, we may expand on our arguments set out herein. 9 1. The farm Witklip Van Rensburg E-mail: 11 January It is noted that the agricultural impact and air The entire proposed site “B” is situated on prime agricultural Jordaan & Olivier 2012 quality impacts of the proposed development, land, affecting approximately 250 hectares of irrigated land. Attorneys on behalf of especially Site B is a concern. In order to Currently crops such as corn, potatoes and peas are produced Hans van Rensburg address this concern an Agricultural Potential under irrigation. Apart from the area directly affected, the whole Boerdery cc Study has been included in the list of studies to farming business of our client will be ruined as the farm is be undertaken so that this aspect can be fully integrated and the remainder of the farm cannot be sustained understood. Please see and comment on the independently from that part of it. Crops on that land but also on proposed Terms of Reference for this study to the rest of the farm are irrigated from dams whose water quality ensure all elements of concern will be

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will no doubt be affected by the ash. addressed. At completion of the specialist 2. The farm Bossemanskraal studies, the public will be given an opportunity Immediately adjacent to, and approximately 1,5 km from the to confirm acceptability of proposed mitigation proposed site on the farm Bossemanskraal, my client has a strategies and plans. Reference will also be broiler facility where approximately 1,75 million chickens are made to recommendations from the Kusile reared every year. We are concerned about the effect the ash power station EIA process, and its may have on the health of the chickens and also on the quality Environmental Authorisation. of the product and the safety to consumers. Willie Howell, EAP (2012) 3. The Conveyor Corridor area The area earmarked for the conveyor is also agricultural land. Post-meeting note: Although it may not affect our client directly we are aware of Site alternative A has been identified as the many farmers who may be adversely affected, among which is a preferred alternative. All the properties affected large-scale pig farm. by site A is owned by Eskom, therefore there 4. The farm Groenfontein will be no direct impacts on existing farming One of the major players in the chicken industry in Gauteng, operations. A comprehensive Environmental namely Eagles Pride, has one of its’ major hatcheries as well as Management Programme will also be about 36 broiler houses on the property immediately adjacent to implemented to avoid or at the very least the proposed site. They have informed us that they are busy minimise any potential indirect impacts on conducting their own environmental impact assessment through agricultural activities in the vicinity of the ash their agents and will give their comments in due course. disposal facility. Although we are not authorised to give an opinion on their In the event the competent authority reject the behalf, we are aware of a number of reasons why the ash will EAP’s recommended site – Site A – and negatively impact their facility, and possibly to the extent that it authorise another site alternative, then the land may have to close down entirely. These reasons shall also owner negotiation process will commence. apply, to a large extent, to the chicken facility on the farm Construction of the ADF should only Bossemanskraal, belonging to our client. commence once successful negotiations has been concluded with all affected land owners.

Further, the air quality specialist study concluded that dust and air quality impacts associated with the transport and disposal of ash can be successfully mitigated to within the development footprint, therefore impacts will not be felt as far as Site B. Mathys Vosloo, EAP 10 Invaluable agricultural land needed for food production will go to Mr Christiaan Gerber, Public meeting on This will be investigated during the specialist waste if it is used for this ash disposal facility. Witklip 15 February 2012 at studies during the next phase. 18:00 to discuss Willie Howell, EAP (2012) and review the Draft Site alternative A has been identified as the Scoping Report. preferred alternative. All the properties affected

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by site A is owned by Eskom, therefore there will be no direct impacts on existing farming operations. A comprehensive Environmental Management Programme will also be implemented to avoid or at the very least minimise any potential indirect impacts on agricultural activities in the vicinity of the ash disposal facility. In the event the competent authority reject the EAP’s recommended site – Site A – and authorise another site alternative, then the land owner negotiation process will commence. Construction of the ADF should only commence once successful negotiations has been concluded with all affected land owners.

The loss of agricultural land, even on site A which is the preferred site and Eskom owned, will be inevitable. A number of environmental, social, technical and economic aspects were considered during the comparative assessment of the alternative sites, therefore loss of agricultural land on Site A must be considered acceptable. Please refer to the Soils & Land Capability Report included in the DEIR under Appendix F- Specialist Reports. Mathys Vosloo, EAP 11 With regard to the establishment of an ash disposal facility, on Mr JP Joubert, E-mail: 29 The potential impact on agriculture, the the farms Witpoort 563 JR and Nooitgedacht 564 JR, (the site Joubert Boerdery February 2012 in economy and all water resources will be fully marked as “Site G” on your map), we would like to make the response to the investigated during the next phase of this following comments: Draft Scoping study. Economic farm unit Report Willie Howell, EAP (2012) We have been farming on this land for many years, and we have over the years established farming activities on the farms Site alternative A has been identified as the Witpoort and Nooitgedacht. This forms an economic farming preferred alternative. All the properties affected unit and, should this proposed site be chosen, it will divide the by site A is owned by Eskom, therefore there unit in such a way that it will no longer be possible to farm will be no direct impacts on existing farming economically on the adjoining part of these farms. This will operations. A comprehensive Environmental mean the end of our farming operation, which will also result in Management Programme will also be

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25 workers losing their income. implemented to avoid or at the very least Integrity of water resources and air minimise any potential indirect impacts on The Wilge River and three smaller streams run through this agricultural activities in the vicinity of the ash proposed area. These water resources are used by the disposal facility. community and many farmers for irrigation of crops and also as In the event the competent authority reject the drinking water, especially for cattle. We believe that the EAP’s recommended site – Site A – and presence of the ash heap will pollute these resources to the authorise another site alternative, then the land extent that it will no longer be suitable for any of these purposes. owner negotiation process will commence. This will have a wide socio-economic impact on the area as a Construction of the ADF should only whole. We understand that water is a scarce resource and it is commence once successful negotiations has difficult to see why this could be deemed a suitable area for an been concluded with all affected land owners. ash heap of this size. Apart from the water, we are also deeply concerned about pollution of the air and how it will affect the The loss of agricultural land, even on site A people working and living in the area. which is the preferred site and Eskom owned, Financial implications will be inevitable. A number of environmental, This proposed area is mainly on fertile agricultural land that is social, technical and economic aspects were suitable for the production of various crops. Land suited for considered during the comparative assessment crops is more expensive than land that is suitable only for of the alternative sites, therefore loss of grazing, and typically more people are employed on such fertile agricultural land on Site A must be considered land. If this area (Site G) is compared to area Site C, it is acceptable. evident that Site C consists of a smaller portion of fertile land, Please refer to the Soils & Land Capability thereby not only rendering that area a cheaper proposition in Report included in the DEIR under Appendix F- terms of land prices, but also in terms of the number of people Specialist Reports. who may be adversely affected. Apart from this, we understand that a portion of this land already belongs to ESKOM. Further, the air quality specialist study Even more so, Site A is located on land which already belongs concluded that dust and air quality impacts to ESKOM. associated with the transport and disposal of Recommendations: ash can be successfully mitigated to within the We propose that Site C or Site A, being closer to the site of the development footprint, therefore impacts will plant be chosen, as this will not only have a smaller financial not be felt as far as Site G. impact on the project as a whole but will also not affect as many Mathys Vosloo, EAP people, land or water resources. We sincerely believe that it will have a much smaller impact on the local economy too, especially as much of that land already belongs to Eskom. 12 MANYATHELA AVENTURES on the farm Witpoort offers the Mr Andries van E-mail: 1 March The potential impact on the economy activities following activities to its clients: Vuuren 2012 in response to on neighbouring properties and all water  Hunting; MANYATHELA the Draft Scoping resources will be fully investigated during the  Mountain biking; AVENTURES Report next phase of this study.  Horse riding, Witpoort Eskom does have regular monitoring of the  Fishing, soil, water, air in the area of Kusile Power

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 Walking; and Station.  Abseiling. Willie Howell, EAP (2012) Other economic activities on the farm include chicken, game, cattle and sheep farming. the air quality specialist study concluded that It is a known fact that dust/ash from such a facility cannot be dust and air quality impacts associated with the fully controlled and that it will pollute neighbouring properties. transport and disposal of ash can be This pollution will have a serious impact on all the activities we successfully mitigated to within the currently have on our property. development footprint, therefore impacts will We understand that Kusile is of national interest. Eskom must, not be felt as far as Site G. however, look after the interests of its neighbours by doing Mathys Vosloo, EAP regular monitoring of the soil, water, air and vegetation to ensure that the surrounding area is not adversely affected. 13 What happens if only portion of the farm is used for the ash Mr Leon Van Dyk Focus group That will be negotiated between Eskom and facility? meeting on 26 July the landowner. 2012 at 09:00 to Willie Howell, EAP (2012) present information regarding the inclusion of Site F as a feasible alternative to be taken forward to the EIA phase of the project 14 Is the vegetation on the rehabilitated ash dump edible? Mrs Carol Wentzel, Focus group It is in fact edible and not toxic, but ultimately Bronkhorstspruit and meeting on 3 you do not want any animals grazing on the Wilge River August 2012 at rehabilitated ash disposal facility as the Conservancy 09:00 to present vegetation is removed and the ash will be information exposed to the elements. regarding the inclusion of Site F as a feasible alternative to be taken forward to the EIA phase of the project 15 Eagles Pride Hatchery (Pty) Ltd currently have chicken farming Shangoni Email sent on 20 The receipt of the email was acknowledged operations in the form of a hatchery and rearing farms on Management September 2012 with the following response given: portions 5 & 23 of Nooitgedacht 525 JR. Family members reside Services on behalf of Please advise your client that Alternative B on portions 7 of Nooitgedacht 525 JR and portion 6 of Witklip Eagles Pride nearest to their property is just one of five 539 JR. Hatchery (Pty) alternative sites that will be investigated during

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this environmental impact assessment. The area is established in the poultry industry which also The economic impact on neighbouring farmers supports Hyline and Fairacres who breed with parent stock. will be addressed during the Social Impact Assessment. After reviewing your Site Selection and Screening Report it is Willie Howell, EAP (2012) evident that if site B is selected this will have a direct impact on their chicken farming operations. The following impacts are Site alternative A has been identified as the envisaged: preferred alternative. All the properties affected  Visual impact from the ash dump and conveyor by site A is owned by Eskom, therefore there system, will be no direct impacts on existing farming  Loss of agriculture land, operations. A comprehensive Environmental  Impact of chicken farming operations (chickens can Management Programme will also be experience respiratory problems), implemented to avoide or at the very least  Air pollution from ash dumps, minimise any potential indirect impacts on  Social impact on residents and workforce of Eagles agricultural activities in the vicinity of the ash Pride Hatchery (Pty) Ltd, disposal facility.  Decrease in value of properties, In the event the competent authority reject the  Impacts on surface water bodies and groundwater on EAP’s recommended site – Site A – and which Eagles Pride Hatchery (Pty) Ltd is dependant. authorise another site alternative, then the land owner negotiation process will commence. Construction of the ADF should only commence once successful negotiations has been concluded with all affected land owners.

Further, the air quality specialist study concluded that dust and air quality impacts associated with the transport and disposal of ash can be successfully mitigated to within the

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development footprint, therefore impacts will not be felt as far as Site B. Mathys Vosloo, EAP 3.1.7 Compensation Comments Apart from the obvious financial implications for our client and for Van Rensburg E-mail: 11 January Your comment is noted and the cost of land 1 the other farmers mentioned in section 2 above, the proposed Jordaan & Olivier 2012 and the operating of the facility and its site “B” is, as mentioned, situated on prime and licensed Attorneys on behalf of conveyors will be part of a cost-benefit analysis irrigated land. It will be on, or directly affect, approximately 250 Hans van Rensburg done by the technical team. Furthermore, land hectares of this high-value land, the value of which is Boerdery cc analysis will follow the recognised evaluation approximately R80,000 (Eighty Thousand Rands) per hectare. procedures, and appropriate engagement will Apart from this there is the cost of the corridor, which, though we be undertaken. have no estimate of the amount, must be substantial. Apart from Willie Howell, EAP (2012) the capital cost, it will incur substantial monthly running costs including health and safety costs and security. Once a site has been chosen, will Eskom buy the properties as Mr Christiaan Gerber, Public meeting on Eskom will buy all the properties on the chosen 2 land is needed or will all the properties on the site be bought out Witklip 15 February 2012 at site at the same time. The property could then in the beginning? 18:00 to discuss be rented out to the previous owner until it is and review the Draft needed for the ash disposal facility. Scoping Report. Willie Howell, EAP (2012) If only a portion of a property falls within a site, will the whole Mr Adriaan Loots, Public meeting on This must be discussed between Eskom and 3 property be bought out, or just the small part inside the site. Jakhalsfontein 15 February 2012 at the individual owners. Apart from being paid a 18:00 to discuss market-related price, a landowner will also be and review the Draft compensated for improvements on the Scoping Report. property. Willie Howell, EAP (2012) How will the pan on Site F be compensated for? Mrs Carol Wentzel Focus group If the pan is lost completely, it should be 4 Bronkhorstpruit and meeting on 3 mitigated through off site mitigation or Wilge River August 2012 at implementation of appropriate offsets for the Conservancy 09:00 to present pan. information Mathys Vosloo, EAP regarding the inclusion of Site F as a feasible alternative to be taken forward to the EIA phase of the project 3.1.8 Social Comments

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1 The people in Bronkhorstspruit need employment on Eskom Mr Aaron Skhosana Reply sheet on 20 Noted. This aspect will be addressed in the projects. At Kusile Power Station people from other provinces Mazolman Partners October 2011 project’s Social Impact Study. are working, but we cannot find a job with Eskom Network Willie Howell, EAP (2012)

The social specialist study undertaken recommends that unskilled and semi-skilled labour that may be require during the construction or operation phases of the project be sourced from the local communities. Mathys Vosloo, EAP 2 Irrigated crops in general provide higher employment than non- Van Rensburg E-mail: 11 January This concern will be addressed by the Social irrigated crops and land used for grazing. For crops like Jordaan & Olivier 2012 Impact Assessment proposed for the EIA potatoes, temporary labour is often used in the harvesting Attorneys on behalf of phase. season and for some of these labourers this is their only source Hans van Rensburg Willie Howell, EAP (2012) of income.Although the ash disposal facility will probably create Boerdery cc some employment, it will adversely affect not only these farm Post-meeting note: workers but also the many people employed by the various The ash disposal facility will have very minor chicken facilities in the area. indirect impact on agricultural activities therefore job shedding should not occur. Please refer to the Social Impact Assessment Report included in the DEIR under Appendix F- Specialist Reports. Mathys Vosloo, EAP 3 Can you show me on the map where the families who have been Mr Zweli Mpofu, Public meeting on The families have been moved to an area that displaced due to the power station have been moved? Bravo Cooperative, 15 February 2012 at now falls in Site C. Hartbeestfontein. 14:00 to discuss Willie Howell, EAP (2012) and review the Draft Scoping Report. 4 What about the social impact on us, because we have already Mr Zweli Mpofu, Public meeting on The social impact assessment to be done been moved once. Bravo Cooperative, 15 February 2012 at during the next phase will investigate this in Hartbeestfontein. 14:00 to discuss great detail. The reason for this is that all and review the Draft properties in the area have been treated Scoping Report. equally for the purpose of this study. Willie Howell, EAP (2012)

Post-meeting note: The social specialist study recommended that the impact of ADF on previously resettled households is very high. Therefore Site C is not ideal due to the presence of a resettled

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households. Please refer to the Social Impact Assessment Report included in the DEIR under Appendix F- Specialist Reports. Mathys Vosloo, EAP 5 Land owners and affected parties do not have the financial Mr Andries van Focus group You may ask that Eskom be made responsible resources to undertake monitoring to ensure that this facility is Vuuren meeting on 20 July to undertake the monitoring and make this not polluting, can we ask for monthly monitoring to be done? MANYATHELA 2012 at 10:00 to available for public consumption. Eskom is AVENTURES present information currently undertaking monitoring for the current Witpoort regarding the Kusile Operations and reports this at an inclusion of Site F Environmental Monitoring Committee (EMC) as a feasible meeting, held every 6 weeks, where public alternative to be stakeholders are able to attend. It may be taken forward to the possible to combine the monitoring undertaken EIA phase of the for this project with existing efforts. project A standard requirement of a Waste Management License (WML), which will be required for this type of facility, is extensive monitoring and reporting. Willie Howell, EAP (2012) 6 What part does heritage play? There are distinctive circles on Noted. A heritage impact assessment will be some farms from previous inhabitants. My farm also has a small undertaken during the impact assessment cave with bushman drawings. phase. Willie Howell, EAP (2012) The Heritage Impact Assessment identified heritage resources on all of the alternative sites. Permits from the heritage authority must be obtained to remove or destroy these heritage resources. Mathys Vosloo, EAP 7 As was noted by the stakeholders and affected land owners Dr James Meyer, E-mail: 2 August The recommendations submitted will be taken present at the meeting referred to above the primary mechanism Consultant for 2012 into account when drafting the EMPr. of protection for interested and affected parties remains a TOPIGS SA (Pty) Ltd combination of:  A commitment on behalf of Eskom/Kusile to monitor the relevant constituents and parameters that may impact on the environment and affected parties.  An agreement or undertaking on behalf of Eskom/Kusile to adhere to standards set for upper limits of pollution for the relevant sources applicable to the construction, operation and maintenance of the proposed ash waste disposal site/s.

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 The implementation of environmental management plans that offer sufficient protection to the current land uses.  Provision of all monitoring data within a reasonable timeframe to the interested and affected parties.  Regular engagement with the interested and affected parties.

It is proposed that this take the form of an Environmental Monitoring Committee similar to that currently in operation by Kusile Power Station.

However, as these meetings already provide many specialist reports relating to the construction (and future operation) of the power station itself and do not necessarily relate specifically to the Ash Disposal Facility/s it is proposed that a separate forum be established to focus on the Ash Disposal Facility/s. 8 A key concern noted in the initial comments submitted remains Dr James Meyer, E-mail: 2 August Many possible options or alternative sites are that there appears to be an on-going adjustment to scope of Consultant for 2012 investigated during the scoping phase of an waste disposal facility or facilities required: TOPIGS SA (Pty) Ltd EIA. This is done in order to be as thorough as  The initial projections failed in forming a reasonable possible during the assessment phase of the estimate of the required ash dump facility size and scope EIA when specialists do their work to find the and it was previously argued that it was unclear how the site with the least impact from an Draft Scoping Process would prevent the same set of environmental, social and economic scenario circumstances from occurring again (as verbally perspective. explained for the 10 year ash dump). Impact Phase Note:  This has now occurred as predicted by the inclusion of yet The inclusion of Site F has not increased the another potential site and possible use of a combination of volume requirements of the ash disposal sites (as presented on 20 July 2012). facility, but has simply added another feasible  The fact that more reasons have presented themselves alternative to already challenging sites. since the initial draft scoping report warranting the inclusion Furthermore, conditions surrounding the of another site (site F) suggests that landowners have a development of the 10 year ash disposal valid concern that additional sites may yet again be included facility is not part of the scope of this EIA, at later stages with a similar set of reasons put forward to therefore no further comment will be made motivate for yet another set of waste disposal requirements. regarding the circumstances associated with  This implies that landowners are potentially expected to the 10 year ADF. continually re-evaluate the challenges that may impose The capacity of the designed ash disposal themselves on their environment. facility on Site A has been undertaken by  These landowners should have the certainty to plan their professional engineers and is regarded as own development/expansions/ land use programmes, yet scientifically defensible. There exist no reason this is clearly very hard to do given the high degree of to doubt the findings regarding the volume of

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uncertainty that exists regarding the true requirement for ash to be produced and the size of the facility Kusile Power Station. footprint unless proven otherwise. Please refer  The request is thus that Eskom/Kusile not delay the process to Appendix G for the engineering design unnecessarily but commit with scientifically defensible reports and drawings. motivation the true capacity and site requirements and that Lastly, Site A, which is completely Eskom the selection and proposal be put forward for the necessary owned, has emerged as the preferred site authorisations. alternative that will be recommended to the  It was noted previously that this should have been competent authority. Therefore land owners completed to a far greater degree of certainty when the can continue unabated with their planning initial authorization was granted for the location of the Kusile activities. Power Station. Mathys Vosloo, EAP  Whilst this problem may not necessarily relate to the actions/decision making responsibilities of Eskom/Kusile Power Station, and may be significantly influenced by relevant authorities involved in the processes, it should not be at the cost of current existing landowners and activities in the area. 3.1.9 Communication Comments 1 As affected parties we would like a regular review and feasibility Mrs Annamie Focus group In-pit ashing has been rejected by the study for in-pit ashing to be included in the EMP of the EIA Duvenhage, meeting on 20 July department of Water Affairs due to the fact that application to ensure that this study is done, and reported to Bronkhorstspruit and 2012 at 10:00 to a barrier system cannot be successfully authorities and stakeholders. Wilge River present information installed along vertical surface associated with Conservancy regarding the a pit or void. A review of the feasibility of in-pit inclusion of Site F ashing can only continue if new technology or as a feasible innovation emerges that will make vertical alternative to be barrier systems possible. taken forward to the The Bronkhorstspruit and Wilge River EIA phase of the Conservancy will be kept informed throughout project the EIA process as prescribed in the EIA Regulations. An EIA Newsletter was distributed in December 2013 to inform I&APs of the status of the project and the DEIR will be made available (advertised in various newspapers and notification letter sent to all registered I&APs) from Tuesday 29 July until Monday 08 September 2014. Mathys Vosloo, EAP 2 Trans African Concessions (TRAC) is the operator / Ms Carla Davies E-mail: 28 October A traffic specialist study has been concessionaire of the N4. The provision of a conveyor belt in the Traffic Engineer 2011 commissioned to address this concern. Please

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road reserve or ‘building line’ adjacent to the N4 would need to TRAC see and comment on the proposed Terms of be acceptable to TRAC and SANRAL. Reference for this study to ensure all elements We require additional information regarding the possibility of of concern will be addressed. At completion of additional vehicles on the N4 during construction and the the specialist studies, the public will be given operational phase of this project. an opportunity to confirm acceptability of proposed mitigation strategies and plans. Willie Howell, EAP (2012) The traffic assessment can be viewed in Appendix F of this DEIR. Mathys Vosloo, EAP 3 Will the whole area of the ash disposal facility be developed Mr Robbie van Public meeting on No, it will be developed step-by-step. before any ash is accepted? Bulderen 15 February 2012 at Development of the ADF and barrier system Transnet Pipelines 14:00 to discuss will be undertaken in 5 year increments, with and review the Draft five years of barrier system being installed with Scoping Report. each increment. Mathys Vosloo, EAP 4 Construction waste material must also be investigated in this Dr James Meyer, Public meeting on The construction phase will be dealt with EIA. Water Research 15 February 2012 at extensively in the EMPr. Commission, Pretoria 14:00 to discuss Willie Howell, EAP (2012) 5 What will be done with the gypsum? and review the Draft During the first few years of operation the Scoping Report. gypsum and the ash will both be stored on the 10 year ash disposal facility until construction of the 60 year ash disposal facility has commenced. Then only gypsum will be stored on the smaller facility which will have a dedicated barrier for gypsum and ash on the bigger facility. Willie Howell, EAP (2012)

6 Why can you not throw the ash in the open pit of the coal mine? Mr Hans van Public meeting on That will not be possible in the first 10 to 15 Rensburg, Witklip 15 February 2012 at years of operation, because there is a big lag 14:00 to discuss between digging out the coal and having an and review the Draft open pit to place the coal into. Scoping Report. When Kusile Power Station starts operating, coal will be brought in by conveyor belt from Mr Christiaan Gerber, Public meeting on the Phola Washing Plant while the proposed Witklip 15 February 2012 at New Largo Colliery is being constructed. 18:00 to discuss It is also unknown what will happen to the and review the Draft groundwater if ash and gypsum is added to the Scoping Report mine pit. Studies need to be done to find out

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what will happen to groundwater 15 to 20 years after this ash and gypsum have been added. Eskom and Anglo American will be investigating this during the next few years. The DWA does not like back fill, because there are still too many uncertainties regarding groundwater pollution. Willie Howell, EAP (2012) In-pit ashing has been rejected by the department of Water Affairs due to the fact that a barrier system cannot be successfully installed along vertical surface associated with a pit or void. Mathys Vosloo, EAP 7 When does the construction for the ash dump start, if the ash Mr Andries van Focus group Construction is planned to start 2015 and disposal facility affects our property directly will we be given Vuuren meeting on 20 July commissioning is planned to start 2017. It is ample time to relocate? MANYATHELA 2012 at 10:00 to important to realise that the I&AP’s need fair AVENTURES present information time frames in order to make arrangements. A Witpoort regarding the two year timeframe can be expected. inclusion of Site F Willie Howell, EAP (2012) 8 Are there construction plans for new roads for the ash facility? as a feasible Access and maintenance roads has been alternative to be planned for the ash disposal facility and taken forward to the conveyor platform, Please review the EIA phase of the engineering report and designs in Appendix G. project Mathys Vosloo, EAP 3.1.10 General Comments 1 How can we comment and to whom? Mr Zweli Mpofu, Public meeting on Send all comments to Zitholele Consulting. The Bravo Cooperative, 15 February 2012 at contact details can be found on all Hartbeestfontein. 14:00 to discuss documentation available here at the meeting. and review the Draft Willie Howell, EAP (2012) Scoping Report.

4 EIA FOR KUSILE POWER STATION AND TEN YEAR ASH DISPOSAL FACILITY COMMENTS

NO. COMMENTS, QUESTIONS AND ISSUES COMMENTATOR(S) SOURCE(S) RESPONSE(S)

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1 I just want clarification. Which was the original site as you are Rev. Andrew Reply sheet: 13 The original EIA did include planning for an ash calling this an extension? Manning, Anglican October 2011 disposal facility for the station as part of the Why did the original planning not take the life of the project into Communion EIA authorisation process. Through the account and not adequately provide for a suitable ash disposal Environmental Environmental Authorisation, the Department site. Network of Environmental Affairs enforced development Please provide any relevant comment or details of the technical and execution of a site layout that would avoid investigations in the original application regarding the Ash and minimise impacting on wetlands. To this Disposal site or other related infrastructure so that we can align end, a wetland delineation study was ourselves with the work done to date. undertaken, which resulted in a reduction on A copy of the existing Kusile Environmental Authorisation would available land that could be used for the also assist the interested and affected parties to align ashing. Furthermore, the Water Use Licence themselves with where we are in the process. also required that the project avoid and minimise impacts on water resources (wetlands and drainage lines). Through the need to avoid these sensitive systems, it became necessary for the project to consider other sites for the development of the ash disposal facility. The word extension is used in terms of extending the infrastructure at the Power Station, not necessarily an extension of the ashing facility. Copies of previous EIAs are available on the Eskom website www.eskom.co.za/eia and the link Kusile power station. Willie Howell, EAP (2012) 2 How can you plan a power station without including an ash Mr Hans van Public meeting on The EIA for the power station left sufficient disposal facility for the total life span of the power station? Your Rensburg, Witklip 15 February 2012 at space for an ash disposal facility for the total planning was not good enough. 14:00 to discuss life span of the power station. The Department and review the Draft of Environmental Affairs, however, in its Scoping Report. conditions attached to the Environmental Authorisation, delineated all the water courses on the land where the power station and ash disposal facility had to be developed. Another condition stated that flue gas desulphurisation (FGD) technology be used, which will add another waste – gypsum. This only left enough space for the power station and a 10-year ash disposal facility. Willie Howell, EAP (2012)

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3 Did the original EIA not under estimate the size of the ash Dr James Meyer, Public meeting on No, the initial EIA investigated an area of over disposal facility? Water Research 15 February 2012 at 1000 hectares for the ash disposal facility. Commission, Pretoria 14:00 to discuss The Department of Environmental Affairs and review the Draft (DEA), however, in its conditions attached to Scoping Report. the Environmental Authorisation, delineated all the water courses on the land where the power station and ash disposal facility had to be developed. Another condition was that flue gas desulphurisation (FGD) technology must be used, which will add another waste – gypsum. This only left enough space for the power station and a 10-year ash disposal facility. Willie Howell, EAP (2012) 4 Where can I get the EIA done for the power station? Mr Stefan Vermaak, Public meeting on This study was not done by the current team of Topigs 15 February 2012 at consultants, Zitholele Consulting and can be 14:00 to discuss found on the Eskom website: and review the Draft www.eskom.co.za/eia Scoping Report. Willie Howell, EAP (2012)