Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province

PROPOSED MAIZE WET MILL PLANT, VEREENIGING, GAUTENG PROVINCE

Basic Assessment Report

Erf 188 and a portion of Portion 237 of the farm Leeuwkuil 596 IQ

Prepared for: Project Jordan Holding Company (Pty) Ltd

GDARD Reference No.: Gaut 002/18-19/E2290 SLR Project No. 720.19124.00001 November 2018 For Interested and Affected Party Review Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

DOCUMENT INFORMATION

Title Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province Applicant Project Jordan Holding Company (Pty) Ltd Project Manager Alex Pheiffer Project Manager e-mail [email protected] Authority Reference No. GDARD: Gaut 002/18-19/E2290 SLR Project No. 720.19124.00001 Keywords Maize wet mill, Emfuleni, Sedibeng, Vereeniging, Basic Assessment, environmental authorisation, controlled emitter Report Date November 2018 Report Status For Interested and Affected Party Review

REPORT COMPILATION

REPORT COMPILED BY: Alex Pheiffer

………………………………………………… Alex Pheiffer Senior Environmental Consultant

REPORT REVIEWED BY: Jonathan Crowther

………………………………………………… Jonathan Crowther EMPA: Operations Manager

BASIS OF REPORT

This document has been prepared by an SLR Group company with reasonable skill, care and diligence, and taking account of the manpower, timescales and resources devoted to it by agreement with Project Jordan Holding Company (Pty) for part or all of the services it has been appointed by the Client to carry out. It is subject to the terms and conditions of that appointment. SLR shall not be liable for the use of or reliance on any information, advice, recommendations and opinions in this document for any purpose by any person other than the Client. Reliance may be granted to a third party only in the event that SLR and the third party have executed a reliance agreement or collateral warranty. Information reported herein may be based on the interpretation of public domain data collected by SLR, and/or information supplied by the Client and/or its other advisors and associates. These data have been accepted in good faith as being accurate and valid. SLR disclaims any responsibility to the Client and others in respect of any matters outside the agreed scope of the work. The copyright and intellectual property in all drawings, reports, specifications, bills of quantities, calculations and other information set out in this report remain vested in SLR unless the terms of appointment state otherwise. This document may contain information of a specialised and/or highly technical nature and the Client is advised to seek clarification on any elements which may be unclear to it. Information, advice, recommendations and opinions in this document should only be relied upon in the context of the whole document and any documents referenced explicitly herein and should then only be used within the context of the appointment.

Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

PROPOSED MAIZE WET MILL PLANT, VEREENIGING, GAUTENG PROVINCE

EXECUTIVE SUMMARY

Introduction The applicant, Project Jordan Holding Company (Pty) Ltd, is facilitating the environmental application process for the proposed maize wet mill plant which would be developed and operated as a majority Black Owned (>51%) plant. The proposed maize wet mill plant would be located on Erf 188 of Leeuwkuil Ext 5 and a portion of Portion 237 of the farm Leeuwkuil 596 IQ, on Stout Close (off Lager Road) in the Emfuleni Local Municipality in the Sedibeng District Municipality. The proposed plant would occupy an area of approximately 16.2 ha.

The proposed wet mill plant would process raw non-GMO maize to produce glucose and starch products. Glucose and starch are used as ingredients in the manufacturing of beverage and food products. A number of by-products would also be produced that can be used for animal feed or in the paper and textile industry. The proposed plant would have a capacity to process between 1 200 and 2 000 tons of maize per day.

The development and operation of the proposed maize wet mill plant includes activities listed under the Environmental Impact Assessment (EIA) Regulations 2014 (as amended), promulgated in terms of Chapter 5 of the National Environmental Management Act, 1998 (No. 107 of 1998) (NEMA). Such listed activities are prohibited from commencing until authorisation is obtained from the competent authority, which in this case is the Gauteng Department of Agriculture and Rural Development (GDARD). The activities that are triggered require a Basic Assessment (BA) process to inform the GDARD’s decision on the application for environmental authorisation. In addition, the proposed project also requires authorisation from the Department of Water and Sanitation (DWS) for specific water uses under Section 21 of the National Water Act, 1998 (No. 36 of 1998) (NWA).

SLR Consulting (South Africa) (Pty) Ltd (SLR) has been appointed as the independent environmental consultant to undertake the BA process for the proposed maize wet mill plant.

This executive summary provides a synopsis of the Basic Assessment Report (BAR).

Opportunity to comment on the bar This BAR has been distributed for a 30-day comment period from 09 November to 10 December 2018 in order to provide Interested and Affected Parties (I&APs) with an opportunity to comment on any aspect of the proposed project and the findings of the BA process. Copies of the full report have been made available on the SLR website (at https://slrconsulting.com/za/slr-documents/) and at the Vereeniging Public Library. Electronic copies (compact disk) of the report can be requested from SLR, at the contact details provided below.

Any comments should be forwarded to SLR at the contact details provided below. For comments to be included in the updated BAR that is submitted to GDARD for decision-making, comments should reach SLR by no later than 10 December 2018.

SLR Consulting (South Africa) (Pty) Ltd Attention: Alex Pheiffer or Clive Phashe

PO Box 1596, Cramerview 2060 (if using post please call SLR to notify us of your submission)

Tel: (011) 467 0945 Fax: (011) 467 0978 E-mail: [email protected] or [email protected]

Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

Basic Assessment process Steps undertaken to date during the Basic Assessment process are outlined below.  An I&AP database has been compiled using information obtained during a social scan of the project area, a deed search of adjacent landowners, responses to the advertisements, site notices and notification letter, and attendance at meetings.  A notification background information document (BID) was distributed for a 30-day registration and comment period.  Press advertisements were placed in two local newspapers (namely Sedibeng Ster and Vereeniging Ster). Site notices were placed at the site boundary and along Lager Road.  Focused stakeholder meetings and a public information sharing meeting were held.  An application form and declaration of interest were submitted to GDARD.  Specialist input was provided on the likely impact of the proposed project on the biophysical, socio- economic and cultural aspects of the environment.  Draft BAR has been made available to I&APs for a 30-day comment period. A copy of the executive summary was enclosed with the notification letter sent to all I&APs registered on the project database.

The following steps will be undertaken in the remainder of the Basic Assessment process:  All comments received during the review period will be included in the BAR submitted to GDARD for consideration and decision-making.  After GDARD has reached a decision, all I&APs on the project database will be notified of the outcome of the application and the reasons for the decision and the statutory appeal period.

Project timelines Should environmental authorisation be granted it is anticipated that construction of the facility would take approximately two years to complete. The intended timing is to start with detailed design and construction in second quarter of 2019. Construction activities are expected to take place 24 hours a day for seven days a week. Construction facilities would be removed at the end of the construction phase (unless incorporated into the operational phase facilities).

The plant is expected to be operational by Year 2021. The minimum operational life of the plant would be for 20 years, however, the opportunity exists to extend this period. The plant would operate 24 hrs a day, with 4 x 8 hour continuous shifts to allow for a changeover of shifts without interrupting the processing operations.

Overview of the project The plant would process a maximum of 2 000 tons per day of non-GMO maize which would be cleaned, steeped, ground and refined to produce approximately 1 710 tons of glucose and starch products as well as various by-products (corn oil, fibre, gluten, and germ).

A conceptual process flow is provided below.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

Main facilities associated with the proposed maize wet mill plant C - Contractors area - Security and access control - Corn off-loading, cleaning and storage silos - Steeping, milling and drying area - By-product load out area - Refinery plant, tank farm and load out area - Chemical intake and storage tanks - Warehouses and spent carbon storage area - Boiler house (including coal storage and dosing) - Access, weigh-bridges and guard houses - Internal roads - Workshops and truck wash O - Treatment plant (for water supply) - Waste water (industrial effluent) treatment plant - Offices and administration block (including - Service infrastructure (including switching station canteen and parking areas) and underground cables from the Leeuwkuil - Utilities (water tanks, air compressors, cooling substation, water supply pipeline, domestic sewer tower, transformers, fire control room, quality package plant and storm water facilities) control room including laboratories) Key activities associated with the proposed maize wet mill plant - Site establishment including storm water controls - Equipment, pipework and utilities installations - Clearing of vegetation in accordance with the - Transportation of construction phase materials and vegetation management procedures staff (via existing roads) C - Stripping and stockpiling of soil resources and - Collection, storage and removal of construction earthworks in accordance with soil plan related waste - Foundations, structures and roads - Landscaping - Arrival and departure of personnel (in shifts) - Maize preparation, milling and refinery - Delivery of raw materials and other supplies by - Final product and by-product storage and O truck and removal of waste by truck transportation - Storage of incoming materials - Associated services and support activities C – Construction; O - Operations

Summary of potential impacts Potential impacts associated with the project have been identified by the EIA project team with input from specialists and I&APs. The range of environmental issues considered in the BA was given specific context and focus through consultation with specialists, authorities and I&APs. All identified impacts are considered in a cumulative manner such that the impacts of the current baseline conditions on and surrounding the site and those potentially associated with the project are discussed and assessed together. The assessment has assumed the relocation of the Wise Owl pre-school prior to construction.

A summary of the potential impacts in the unmitigated and mitigated scenarios is provided in the table below. The mitigated assessment assumes that technical design controls, as included in the project scope, together with mitigation measures included in the environmental management programme (EMPr) would be included in the detailed design of the plant and implemented when the plant is constructed and operated.

Significance of impacts Potential impact Without With mitigation mitigation Loss of agricultural soil resources through physical disturbance M L Loss of agricultural soil resources through contamination M VL Loss of terrestrial habitat and biodiversity through physical disturbance M (C) L (C) VL (O) Insignificant (O) Disturbances of aquatic habitat and related biodiversity through changes in flow L VL and water quality Alteration of drainage patterns affecting the flow of water in downstream systems M VL Discharges from project affecting the quality of downstream freshwater resources Assessed under aquatic habitats above Contamination of groundwater quality affecting the aquifer M VL Increase in ambient air concentrations H L Increase in malodourous compounds VL VL Increase in disturbing noise levels affecting potential human receptors M L

Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

Significance of impacts Potential impact Without With mitigation mitigation Alteration of the visual environment M L Economic impact (positive and negative) H+ VH+ Social benefits associated with employment and economic development L+ M+ Changes in land value VL VH+ Reduction in grazing land affecting livelihoods of local farmers L VL+ Disturbance to third party road users by project-related traffic H L+ Increase in safety risks to third parties and communities H Insignificant Change in land use affecting sense of place L VL Disturbance of ground resulting in damage to heritage resources No impact VH – Very High; H – High; M- Medium; L – Low; VL – Very Low; + denotes a positive impact; C – Construction; O - Operations

As a result of the technical design controls and mitigation measures included in the environmental management programme (EMPr) the majority of potential biophysical impacts associated with the proposed maize wet mill plant would be short term and limited either to the site or neighbouring land. These include impacts on soils, terrestrial habitats and biodiversity, drainage patterns, groundwater aquifers and the visual environment. The potential impacts on biophysical aspects are considered to be of LOW or VERY LOW significance with mitigation.

Potential discharge of treated effluent from the on-site sewage package plant and industrial waste water treatment plant could impact on the aquatic ecosystem in the downstream Vaal tributary. However the treatment plants would be designed to treat effluent to drinking water standards and therefore any impacts on downstream aquatic habitats are considered to be of VERY LOW significance with mitigation.

The nearest residential area to the project site is the staff accommodation associated with the correctional services. Potential noise impacts on this receptor group could be significant, especially at night. Noise controls that focus on mitigating noise emissions at source have been designed into the plant with the addition of a noise screen between the plant and the staff accommodation, especially close to the plant access point where vehicle traffic is predicted to have the highest impact. With these design controls and mitigation measures, potential noise impacts could be reduced to LOW significance.

Operational activities present the most potential for negative air quality impacts as these activities would be conducted over a long period. More significant impacts are predicted to occur due to PM2.5 and PM10 emissions from material handling extraction systems followed by SO2 emissions associated with the boiler plant. Design controls and additional mitigation (as recommended by the air quality specialist) would reduce potential impacts in an area with already elevated ambient concentrations. The impact on air quality and the related inhalation health impacts is considered to be of HIGH significance without mitigation and LOW significance with design controls and additional mitigation.

Where control systems are included in the engineering design and operation of the overall plant, potential odour related impacts would be minimised.

A reduction in grazing land used by the Emfuleni Livestock Group could affect the livelihoods of local farmers. Even without mitigation this is predicted by the specialist to be of LOW significance. Where the Emfuleni Livestock Group is given preference in Corporate Social Responsibility initiatives, the significance of potential impacts is considered to be VERY LOW positive.

The project has the potential to present safety risks to third parties through project-related traffic on public roads and uncontrolled access to the site. However with design controls and mitigation, potential impacts are either considered to be of INSIGNIFICANT significance. In the case of project-related traffic, proposed road and traffic upgrades would result in a LOW positive improvement of the road network.

Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

Economic impacts associated with transformation, employment and economic development are considered to be of HIGH significance even without mitigation. With mitigation this is considered to be of VERY HIGH significance. The substantial capital investment is likely to increase land values, unless other negative environmental and social impacts affect adjacent land use. It is intended for the plant to be owned by a majority Black-Owned company and to become a Level 2 Black Economic Empowerment (BEE) supplier. The project would generate significantly more employment and economic value than the site currently does. These factors would contribute to transformation, economic growth and socio-economic development in the area. The related social benefits are also considered to be positive in nature. Key to realising the MEDIUM positive mitigated significance of social benefits associated with increased employment and economic development is to recruit employees and procure services locally as far as possible and implement corporate social responsibility initiatives in the local area.

No impacts on heritage and cultural resources are expected as no heritage resources occur on the project site and palaeontological resources, if they do exist, would be located well below the foundations of the plant.

Proceeding with the project attracts potentially significant economic benefits and potential negative environmental and social impacts of high to low significance. Not proceeding with the project retains the status quo, but with a loss in employment and transformation opportunities, revenue generation and related social benefits, which could potentially be generated by the development. The project is located within an area earmarked for commercial and industrial development in the local municipality’s spatial development framework and, apart from the Wise Owl pre-school, is surrounded by commercial and industrial type activities.

Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

CONTENTS

EXECUTIVE SUMMARY ...... II 1 INTRODUCTION ...... 1-1 1.1 PURPOSE OF THIS REPORT ...... 1-1 1.2 PROJECT BACKGROUND ...... 1-1 1.3 SUMMARY OF AUTHORISATION REQUIREMENTS ...... 1-1 1.4 TERMS OF REFERENCE ...... 1-4 1.5 STRUCTURE OF THIS REPORT ...... 1-4 1.6 OPPORTUNITY TO COMMENT ...... 1-5 2 POLICY AND LEGISLATIVE CONTEXT ...... 2-1 2.1 LEGISLATION CONSIDERED IN THE PREPARATION OF THE BASIC ASSESSMENT REPORT ...... 2-1 2.2 GUIDELINES, POLICIES, PLANS AND FRAMEWORKS ...... 2-8 2.3 INTERNATIONAL FINANCE CORPORATION ...... 2-10 3 BA APPROACH AND METHODOLOGY ...... 3-1 3.1 DETAILS OF THE BA PROJECT TEAM ...... 3-1 3.2 QUALIFICATIONS AND EXPERIENCE OF THE EAPS ...... 3-1 3.3 QUALIFICATIONS, ASSUMPTIONS AND LIMITATIONS ...... 3-2 3.4 BASIC ASSESSMENT ...... 3-4 4 PROJECT DESCRIPTION ...... 4-1 4.1 GENERAL PROJECT INFORMATION ...... 4-1 4.2 DESCRIPTION OF THE PROPOSD MAIZE WET MILL PLANT ...... 4-2 4.3 CONSIDERATION OF ALTERNATIVES ...... 4-13 5 NEED AND DESIRABILITY ...... 5-1 5.1 NATIONAL POLICY AND PLANNING FRAMEWORK ...... 5-1 5.2 CONSISTENCY WITH POLICY AND PLANNING CONTEXT ...... 5-3 5.3 CONSISTENCY WITH NEMA PRINCIPLES ...... 5-4 5.4 SECURING ECOLOGICAL SUSTAINABLE DEVELOPMENT AND USE OF NATURAL RESOURCES ...... 5-6 5.5 PROMOTING JUSTIFIABLE ECONOMIC AND SOCIAL DEVELOPMENT ...... 5-6 6 DESCRIPTION OF THE AFFECTED ENVIRONMENT ...... 6-1 6.1 BIOPHYSICAL ...... 6-4 6.2 SOCIO-ECONOMIC ...... 6-13 6.3 HERITAGE AND CULTURAL RESOURCES...... 6-19 7 IMPACT DESCRIPTION AND ASSESSMENT ...... 7-1 7.1 IMPACT ON BIOPHYSICAL ENVIRONMENT ...... 7-1 7.2 IMPACT ON SOCIO-ECONOMIC ENVIRONMENT ...... 7-17 7.3 IMPACT ON HERITAGE RESOURCES (INCLUDING PALAEONTOLOGICAL RESOURCES) ...... 7-27 8 ENVIRONMENTAL MANAGEMENT PROGRAMME ...... 8-1 8.1 INTRODUCTION ...... 8-1 8.2 PLANNING AND DESIGN PHASE...... 8-1 8.3 CONSTRUCTION PHASE...... 8-8 8.4 OPERATIONS ...... 8-16 8.5 DECOMMISSIONING AND CLOSURE ...... 8-23 8.6 ENVIRONMENTAL AWARENESS AND TRAINING PLAN ...... 8-23 8.7 PROCEDURES IN CASE OF ENVIRONMENTAL EMERGENCIES ...... 8-26 9 CONCLUSIONS AND RECOMMENDATIONS ...... 9-1 10 REFERENCES ...... 10-1

APPENDICES APPENDIX 1: GDARD’S STANDARD BAR TEMPLATE ...... A APPENDIX 2: EAP UNDERTAKING ...... B APPENDIX 3: CURRICULA VITAE (INCLUDING REGISTRATIONS) OF THE PROJECT TEAM ...... C APPENDIX 4: PUBLIC PARTICIPATION PROCESS ...... D

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

APPENDIX 5: SURFACE WATER SPECIALIST REPORT...... E APPENDIX 6: SOILS AND CONTAMINATED SPECIALIST REPORT ...... F APPENDIX 7: TERRESTRIAL AND FRESHWATER SPECIALIST REPORTS ...... G APPENDIX 8: GROUNDWATER SPECIALIST REPORT ...... H APPENDIX 9: AIR QUALITY SPECIALIST REPORT ...... I APPENDIX 10: NOISE SPECIALIST REPORT ...... J APPENDIX 11: VISUAL SPECIALIST REPORT ...... K APPENDIX 12: TRAFFIC SPECIALIST REPORT ...... L APPENDIX 13: SOCIAL SPECIALIST REPORT ...... M APPENDIX 14: ECONOMIC SPECIALIST REPORT ...... N APPENDIX 15: HERITAGE SPECIALIST REPORT ...... O APPENDIX 16: PALAEONTOLOGICAL SPECIALIST REPORT ...... P

LIST OF TABLES TABLE 2-1: LEGAL FRAMEWORK ...... 2-1 TABLE 2-2: NEMA LISTED ACTIVITIES APPLIED FOR AS PART OF THE PROPOSED PROJECT ...... 2-3 TABLE 2-3: CATEGORY C LISTED WASTE MANAGEMENT ACTIVITIES ...... 2-4 TABLE 2-4: GENERAL AUTHORISATION WATER USES APPLICABLE TO THE PROPOSED PROJECT ...... 2-7 TABLE 2-5: GUIDELINE AND POLICY FRAMEWORK...... 2-8 TABLE 3-1: DETAILS OF THE BA PROJECT TEAM ...... 3-1 TABLE 3-2: QUALIFICATIONS, ASSUMPTIONS AND LIMITATIONS ...... 3-2 TABLE 3-3: TASKS UNDERTAKEN TO DATE DURING THE PUBLIC PARTICIPATION PROCESS ...... 3-6 TABLE 3-4: I&APS THAT SUBMITTED WRITTEN CORRESPONDENCE DURING THE PROCESS ...... 3-7 TABLE 3-5: REQUIREMENTS OF A BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS 2014 ... 3-7 TABLE 3-6: SPECIALIST STUDIES ...... 3-10 TABLE 3-7: CRITERIA FOR ASSESSING IMPACTS ...... 3-11 TABLE 4-1: APPLICANT DETAILS ...... 4-1 TABLE 4-2: PROPERTY LOCATION ...... 4-1 TABLE 4-3: OVERVIEW OF MAIZE WET MILLING PROCESS ...... 4-7 TABLE 4-4: EXPECTED TRAFFIC VOLUMES ...... 4-8 TABLE 4-5: EXPECTED WATER REQUIREMENTS ...... 4-8 TABLE 4-6: DISCHARGE CHANNEL DESIGN CHARACTERISTICS ...... 4-12 TABLE 4-7: EXPECTED STORAGE AND HANDLING OF PROCESS MATERIALS ...... 4-13 TABLE 4-8: PROJECT ALTERNATIVES CONSIDERED ...... 4-13 TABLE 5-1: CONSIDERATION OF THE NEMA PRINCIPLES IN RELATION TO THE PROPOSED PROJECT ...... 5-4 TABLE 6-1: MONTHLY RAINFALL AND EVAPORATION DATA ...... 6-4 TABLE 6-2: TEMPERATURE FROM THE SHARPEVILLE AQMS ...... 6-6 TABLE 6-3: ON-SITE AIR QUALITY MONITORING RESULTS RELATIVE TO THE SHARPEVILLE AQMS ...... 6-12 TABLE 6-4: ADJACENT LANDOWNERS ...... 6-14 TABLE 6-5: SURROUNDING LAND USES ...... 6-15 TABLE 7-1: IMPACT SUMMARY – PHYSICAL DISTURBANCE OF SOIL RESOURCES ...... 7-3 TABLE 7-2: IMPACT SUMMARY – CONTAMINATION OF SOIL RESOURCES ...... 7-4 TABLE 7-3: IMPACT SUMMARY – LOSS OF TERRESTRIAL HABITAT AND BIODIVERSITY ...... 7-6 TABLE 7-4: IMPACT SUMMARY – DISTURBANCES OF AQUATIC HABITAT AND RELATED BIODIVERSITY ...... 7-8 TABLE 7-5: IMPACT SUMMARY – ALTERATION OF DRAINAGE PATTERNS ...... 7-9 TABLE 7-6: IMPACT SUMMARY – CONTAMINATION OF GROUNDWATER ...... 7-11 TABLE 7-7: IMPACT SUMMARY – INCREASE IN AIR QUALITY ...... 7-13 TABLE 7-8: IMPACT SUMMARY – INCREASE IN ODOUR ...... 7-14 TABLE 7-9: IMPACT SUMMARY – INCREASE IN DISTURBING NOISE ...... 7-15 TABLE 7-10: IMPACT SUMMARY – ALTERATION OF THE VISUAL ENVIRONMENT ...... 7-16 TABLE 7-11: IMPACT SUMMARY – ECONOMIC IMPACT (POSITIVE AND NEGATIVE) ...... 7-18 TABLE 7-12: IMPACT SUMMARY – SOCIAL BENEFITS ...... 7-20 TABLE 7-13: IMPACT SUMMARY – CHANGES IN LAND VALUE ...... 7-21 TABLE 7-14: IMPACT SUMMARY – REDUCTION IN GRAZING LAND ...... 7-22

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

TABLE 7-15: IMPACT SUMMARY – PROJECT-RELATED TRAFFIC ...... 7-24 TABLE 7-16: IMPACT SUMMARY – SAFETY RISKS ...... 7-25 TABLE 7-17: IMPACT SUMMARY – CHANGE IN LAND USE ...... 7-26 TABLE 8-1: MANAGEMENT ACTION PLAN – PLANNING AND DESIGN ...... 8-2 TABLE 8-2: MEASURES TO BE INCLUDED IN THE DESIGN OF THE SITE AND PLANT ...... 8-3 TABLE 8-3: SITE-SPECIFIC SOIL MANAGEMENT AND REHABILITATION PLAN ...... 8-5 TABLE 8-4: WASTE MANAGEMENT PRACTICES FOR DOMESTIC AND INDUSTRIAL SOLID WASTE ...... 8-6 TABLE 8-5: ENVIRONMENTAL OBJECTIVES AND GOALS - CONSTRUCTION ...... 8-8 TABLE 8-6: MANAGEMENT ACTION PLAN - CONSTRUCTION ...... 8-10 TABLE 8-7: MONITORING PLAN - CONSTRUCTION ...... 8-12 TABLE 8-8: WATER MONITORING PARAMETERS ...... 8-14 TABLE 8-9: AIR QUALITY EVALUATION CRITERIA ...... 8-14 TABLE 8-10: ENVIRONMENTAL OBJECTIVES AND GOALS - OPERATIONS...... 8-16 TABLE 8-11: MANAGEMENT ACTION PLAN - OPERATIONS ...... 8-18 TABLE 8-12: MONITORING PLAN ...... 8-20 TABLE 8-13: WATER MONITORING PARAMETERS ...... 8-22 TABLE 8-14: AIR QUALITY EVALUATION CRITERIA ...... 8-22 TABLE 8-15: PROJECT-SPECIFIC EMERGENCY RESPONSE PROCEDURES ...... 8-27 TABLE 9-1: SUMMARY OF THE SIGNIFICANCE OF THE POTENTIAL IMPACTS ASSOCIATED WITH THE PROPOSED PROJECT ...... 9-1

LIST OF FIGURES FIGURE 1-1: REGIONAL SETTING ...... 1-2 FIGURE 1-2: LOCAL SETTING ...... 1-3 FIGURE 3-1: FLOW DIAGRAM SHOWING THE BA PROCESS ...... 3-5 FIGURE 4-1: SCHEMATIC REPRESENTATION OF THE PROPOSED MAIZE WET MILL PLANT ...... 4-4 FIGURE 4-2: CONCEPTUAL LAYOUT OF THE PROPOSED MAIZE WET MILL PLANT ...... 4-5 FIGURE 4-3: CONCEPTUAL PROCESS FLOW DIAGRAM OF THE PROPOSED MAIZE WET MILLING PROCESS..... 4-6 FIGURE 4-4: ACCESS TO THE PLANT INCLUDING PROPOSED UPGRADES ...... 4-9 FIGURE 6-1: ENVIRONMENTAL, SOCIAL AND SERVICE FEATURES OF THE STUDY AREA ...... 6-2 FIGURE 6-2: LAND USES OF THE STUDY AREA ...... 6-3 FIGURE 6-3: PERIOD, DAY- AND NIGHTTIME WIND ROSES FOR SHARPEVILLE AQMS (2014 TO 2016) ...... 6-5 FIGURE 6-4: SEASONAL WIND ROSES FOR SHARPEVILLE AQMS (2014 TO 2016) ...... 6-5 FIGURE 7-1: PERSPECTIVE OF THE PLANT IN RELATION TO THE PROJECT SITE ...... 7-2 FIGURE 8-1: PROPOSED MONITORING NETWORK ...... 8-15

LIST OF PHOTO PLATES PHOTO PLATE 6-1: PHOTOGRAPHS REFLECTING THE CURRENT STATUS OF THE PROJECT SITE ...... 6-1 PHOTO PLATE 6-2: PHOTOS SHOWING DRAINAGE FEATURES ASSOCIATED WITH THE PROJECT AREA ...... 6-7

Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

ACRONYMS AND ABBREVIATIONS

Acronym / Abbreviation Definition AQMS Air Quality Monitoring System BA Basic Assessment BAR Basic Assessment Report BBBEE Broad Based Black Economic Empowerment BEE Black Economic Empowerment BID Background Information Document CBD Central Business District CBS Critical Biodiversity Areas DEA Department of Environmental Affairs DWS Department of Water and Sanitation EAP Environmental Assessment Practitioner EC Electrical Conductivity ECO Environmental Control Officer EHS Environmental, Health and Safety EIA Environmental Impact Assessment ELM Emfuleni Local Municipality EO Environmental Officer EMPr Environmental Monitoring Programme ESA Ecological Support Areas GA General Authorization GCR Gauteng City Region GDARD Gauteng Department of Agricultural and Rural Development GDP Gross Domestic Product GMO Genetically Modified Organics GPEMF Gauteng Provincial Environmental Management Framework GPG Gauteng Provincial Government GPSDF Gauteng Provincial Spatial Development Framework GSDF Gauteng Spatial Development Framework HIA Heritage Impact Assessment I&APs Interested and Affected Parties IEM Integrated Environment Management LoS Level of Service MAP Mean Annual Precipitation MTSF Medium term Strategic Framework NAAQS National Ambient Air Quality Standards NAEIS National Atmospheric Emission Inventory System NDCR National Dust Control Regulations NDP National Development Plan NEMA National Environmental Management Act NEM:AQA National Environmental Management: Air Quality Act NEM:WA National Environmental Management: Waste Act NGP New Growth Path NHRA National Heritage Resources Act

NO2 Nitrogen dioxide NWA National Water Act

PM2.5 and PM10 Particulate Matter RO Reverse Osmosis SAAQIS South African Air Quality Information System SAB South African Breweries SAHRA South African Heritage Resources Agency SANS South African National Standards SAWQG South African Water Quality Guidelines

Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

Acronym / Abbreviation Definition SCC Species of Conservation Concern SDF Spatial Development Framework SDM Sedibeng District Municipality SHE Safety, Health and Environment SMME Small, Medium and Micro-sized Enterprises

SO2 Sulphur dioxide SPLUMA Spatial Planning and Land Use Management Act TWQR Target Water Quality Range UNFCC United Nations Framework Convention on Climate Change VTAPA Vaal Triangle Airshed Priority Area WHO World Health Organization WQO Water Quality Objectives WWTP Wastewater Treatment Works

Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

1 INTRODUCTION This chapter describes the purpose of this report, provides a brief description of the project background, summarises the legislative authorisation requirements, provides the study terms of reference, describes the structure of the report, and outlines the opportunity for comment.

1.1 PURPOSE OF THIS REPORT This Basic Assessment Report (BAR) has been compiled and distributed for review and comment as part of a Basic Assessment (BA) process that is being undertaken for a proposed maize wet mill plant in Vereeniging, Gauteng Province.

This BAR provides a description of the proposed project and the affected environment; summarises the BA process followed to date; identifies and assesses the key project impacts and presents management and mitigation measures that are recommended to enhance positive and limit negative impacts.

Interested and Affected Parties (I&APs) are asked to comment on the BAR (see Section 1.6). The document will then be updated into a final report, giving due consideration to the comments received. The BAR will be submitted to the Gauteng Department of Agriculture and Rural Development (GDARD) for consideration as part of the application for Environmental Authorisation in terms of Chapter 5 of the National Environmental Management Act, 1998 (No. 107 of 1998) (NEMA), as amended.

1.2 PROJECT BACKGROUND The applicant, Project Jordan Holding Company (Pty) Ltd, is facilitating the environmental application process for the proposed maize wet mill plant which would be developed and operated as a majority Black Owned (>51%) plant.

The proposed plant would be located on Erf 188 and a portion of Portion 237 of the farm Leeuwkuil 596 IQ. The property is owned by The South African Breweries (Pty) Ltd (SAB) and would be transferred to the new owner prior to construction. The project site is located within the Emfuleni Local Municipality in Vereeniging, Gauteng Province (see Figure 1).

SLR Consulting (South Africa) (Pty) Ltd (SLR) has been appointed as the independent environmental consultant to undertake the BA process for the proposed maize wet mill plant.

1.3 SUMMARY OF AUTHORISATION REQUIREMENTS The development and operation of the proposed maize wet mill plant includes activities listed under the EIA Regulations 2014 (as amended). Such listed activities are prohibited from commencing until written authorisation is obtained from the competent authority, which in this case is the GDARD. The activities that are triggered require a BA process in terms of the EIA Regulations 2014 (as amended). The BA process is used to inform the environmental authorisation application. It was agreed with GDARD during the pre-application meeting that the Basic Assessment Report (BAR) would be compiled in line with the NEMA requirements and that the Department’s BAR template would be filled in and attached as an appendix. Further detail is included in Section 2.1.

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Limpopo

± North West Gauteng ^ Mpumalanga

Free State KwaZulu-Natal

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Regional Setting

SLR Consulting (Africa) (Pty) Ltd P O Box 1596, Cramerview, 2060, South Africa Tel: +27 (11) 467-0945 Fax: +27 (11) 467-0978

720.19124.00001 November 2017 5 9 14 90 14 Unitas Park Limpopo (! Steel Park 485 (! 1 0 45 1 1 4 North West ± 6 Gauteng 0 Duncanville (! Mpumalanga 5 ^ 147 R54 80 14

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1425 4 1 720.19124.00001 October 2018 Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

In addition, the proposed project also requires authorisation from the Department of Water and Sanitation (DWS) for specific water uses under Section 21 of the National Water Act, 1998 (No. 36 of 1998) (NWA). Further detail is included in Section 2.1.4.

1.4 TERMS OF REFERENCE SLR, as the independent environmental assessment practitioner (EAP), is responsible for undertaking the required environmental regulatory process and conducting the public participation process. The terms of reference for the environmental regulatory process are to:  make application for Environmental Authorisation of the project in terms of NEMA;  ensure the BA is undertaken in accordance with the requirements of NEMA and the EIA Regulations 2014 (as amended);  ensure the BA is undertaken in an open, participatory manner to ensure that all potential impacts are identified;  undertake a formal public participation process, which includes the distribution of information to I&APs and provides the opportunity for I&APs to raise any concerns/issues, as well as an opportunity to comment on all BA documentation;  integrate all information, including the findings of the specialist studies and other relevant information, into a Basic Assessment Report to allow an informed decision to be taken on the proposed project.

1.5 STRUCTURE OF THIS REPORT This Basic Assessment Report has been prepared in compliance with Appendix 1 of the EIA Regulations 2014 (as amended) and is divided into various chapters and appendices, the contents of which are outlined below.

Section Contents Executive Provides a comprehensive synopsis of the Basic Assessment Report. Summary Chapter 1 Introduction Describes the purpose of this report, provides a brief description of the project background, summarises the legislative authorisation requirements, provides the terms of reference, describes the structure of the report, and outlines the opportunity for comment. Chapter 2 Legislative context Outlines the key legislative context applicable to the proposed project. Chapter 3 BA methodology Outlines the methodology for the assessment and consultation process undertaken in the BA. Also includes a summary of the public participation process undertaken to date and the results thereof. Chapter 4 Project description Provides general project information; a description of the proposed project; and a description of the project alternatives. Chapter 5 Need and desirability Provides an overview of the need and desirability for the proposed project by considering how the project is aligned with the strategic context of national development policy and planning, broader societal needs and regional and local planning, as appropriate. Chapter 6 Description of the affected environment Describes the existing biophysical and social environment that could potentially be affected by the proposed project. Chapter 7 Key project issues and impacts Describes key issues and impacts associated with the proposed project.

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Section Contents Chapter 8 Environmental Management Programme Describes action plans to be implement to mitigate potential impacts; provides monitoring and performance assessment requirements; environmental awareness training; and includes procedures in case of environmental emergencies. Chapter 9 Conclusions and Recommendations Presents the conclusions and recommendations for the project. Chapter 10 References Provides a list of the references used in compiling this report. Appendices Appendix 1: GDARD’s standard BAR template Appendix 2: EAP undertaking Appendix 3: Curricula vitae (including registrations) of the project team Appendix 4: Public participation process Appendix 5: Surface water specialist report Appendix 6: Soils and contaminated land specialist report Appendix 7: Terrestrial and freshwater specialist reports Appendix 8: Groundwater specialist report Appendix 9: Air quality specialist report Appendix 10: Noise specialist report Appendix 11: Visual specialist report Appendix 12: Traffic specialist report Appendix 13: Social specialist report Appendix 14: Economic specialist report Appendix 15: Heritage specialist report Appendix 16: Palaeontological specialist report

1.6 OPPORTUNITY TO COMMENT This BAR has been distributed for a 30-day comment period from 09 November to 10 December 2018 in order to provide I&APs with an opportunity to comment on any aspect of the proposed project and the findings of the BA process. Copies of the full report have been made available on the SLR website (at https://slrconsulting.com/za/slr- documents/) and at the Vereeniging Public Library. Electronic copies (compact disk) of the report can be requested from SLR, at the contact details provided below.

SLR Consulting (South Africa) (Pty) Ltd Attention: Alex Pheiffer or Clive Phashe

PO Box 1596, Cramerview 2060 (if using post please call SLR to notify us of your submission)

Tel: (011) 467 0945 Fax: (011) 467 0978 E-mail: [email protected] or [email protected]

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2 POLICY AND LEGISLATIVE CONTEXT This chapter outlines the key legislative context applicable to the proposed project and outlines the guidelines, policies and plans that have been taken into account during the BA process.

2.1 LEGISLATION CONSIDERED IN THE PREPARATION OF THE BASIC ASSESSMENT REPORT In accordance with the EIA Regulations 2014 (as amended), all legislation and guidelines that have been considered in the BA process must be documented. Table 2-1 below provides a summary of the applicable legislative context.

TABLE 2-1: LEGAL FRAMEWORK

Applicable legislation Relevance or reference National Environmental Management An outline of the legislation is presented in Section 2.1.1. The project will need Act, 1998 (No. 107 of 1998) (NEMA) to comply with the principles of NEMA. The project also triggers listed and EIA Regulations 2014, as activities. amended. National Environmental Management An outline of the legislation is presented in Section 2.1.2. The project will Waste Act, 2008 (No. 59 of 2008) require the storage of waste and therefore triggers listed waste management (NEM:WA) and associated regulations. activities. National Environmental Management An outline of the legislation is presented in Section 2.1.3. The project has Air Quality Act, 2004 (No. 57 of 2003) elements which fall under the category of Controlled Emitters. (NEM:AQA). National Water Act, 1998 (No. 36 of An outline of the legislation is presented in Section 2.1.4. The project includes 1989) (NWA) water uses requiring authorisation. National Heritage Resources Act, 1999 An outline of the legislation is presented in Section 2.1.5. The project needs to (No. 25 of 1999) (NHRA) take into consideration legislative requirements by the NHRA. National Environmental Management: This Act provides for the protection and conservation of ecologically viable Protected Areas Act, 2003 (No. 57 of areas representative of South Africa’s biological diversity and its natural 2003) (NEM:PAA) landscapes and seascapes. The proposed project footprint does not overlap with any existing protected areas or any areas identified for protected area expansion (see Section 6.1.5 for further information on protected areas). National Environmental Management This Act provides for the management and conservation of South Africa’s Biodiversity Act, 2004 (No. 10 of 2004) biodiversity and the protection of species and ecosystems that warrant national (NEM:BA). protection. It regulates the carrying out of restricted activities, without a permit, that may harm listed threatened or protected species or activities that encourage the spread of alien or invasive species and makes provision for the publication of bioregional plans and the listing of ecosystems and species that are threatened or in need of protection. Bioregional plans should be considered by competent authorities in their decision-making regarding an application for Environmental Authorisation. The proposed site footprint does not overlap with any CBAs or host listed threatened or protected species (see Section 6.1.5 for further information). Alien and Invasive Species Regulations (GN R 598 of 2014) as well as the Alien and Invasive Species List (GN R 864 of 2016) have been published to regulate the monitoring, control and eradication of listed invasive species. All land owners on whose land alien and invasive species occur must make the necessary arrangements to be compliant with these Regulations. These have informed the environmental management programme for the project. National Forests Act, 1998 (No 84 of This Act provides for the sustainable management and development of forests 1998) for the benefit of all, including providing special measures for the protection of certain forests and trees. Licensing is required for the destruction of certain indigenous trees. The proposed project would not entail any activities to which the Act applies.

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Applicable legislation Relevance or reference Conservation of Agricultural Resources The CARA provides for control over the utilization of the natural agricultural Act (No. 43 of 1983) (CARA) and the resources in order to promote the conservation of the soil, water sources, Conservation of Agricultural Resources vegetation and the combating of weeds and invader plants. Act Regulations, 1984 (GN No. 1048) Land owners on whose land declared weed species occur must make the necessary arrangements to be compliant with the CARA Regulations. The Spatial Planning and Land Use SPLUMA aims to develop a new framework to govern planning permissions and Management Act, 2013 (No. 6 of 2013) approvals, sets parameters for new developments and provides for different (SPLUMA) lawful land uses in South Africa. SPLUMA is a framework law, which means that the law provides broad principles for a set of provincial laws that will regulate planning. SPLUMA also provides clarity on how planning law interacts with other laws and policies. A town planning application is underway to extend Leeuwkuil Ext 5 to include a portion of Portion 237 as well as to rezone this extension to “Industrial 2”. Occupational Health and Safety Act, This Act provides for the health and safety of persons at work and the 1993 (No. 85 of 1993) and Major protection of persons other than persons at work against hazards to health and Hazard Installation Regulations safety arising out of or in connection with the activities of persons at work. Every employer shall provide and maintain, as far as is reasonably practicable, a working environment that is safe and without risk to the health of his employees. The applicant will need to ensure compliance with the requirements of the Act during both construction and operations. Such requirements are not considered in the BA.

2.1.1 National Environmental Management Act, 1998 The National Environmental Management Act, 1998 (No. 107 of 1998), as amended, establishes principles and provides a regulatory framework for decision-making on matters affecting the environment. All organs of state must apply the range of environmental principles included in Section 2 of NEMA when taking decisions that significantly affect the environment. Included amongst the key principles is that all development must be socially, economically and environmentally sustainable and that environmental management must place people and their needs at the forefront of its concern, and serve their physical, psychological, developmental, cultural and social interests equitably. The participation of I&APs is stipulated, as is that decisions must take into account the interests, needs and values of all I&APs.

Chapter 5 of NEMA provides a framework for the integration of environmental issues into the planning, design, decision-making and implementation of plans and development proposals. Section 24 provides a framework for granting of environmental authorisations. To give effect to the general objectives of Integrated Environmental Management (IEM), the potential impacts on the environment of listed or specified activities must be considered, investigated, assessed and reported on to the competent authority. Section 24(4) provides the minimum requirements for procedures for the investigation, assessment, management and communication of the potential impacts.

In terms of the management of impacts on the environment, Section 24N details the requirements for an Environmental Management Programme (EMPr). a. EIA Regulations 2014 The EIA Regulations, 2014 (as amended by GN No. 326 of 7 April 2017) promulgated in terms of Chapter 5 of NEMA provide for control over certain listed activities. These listed activities are detailed in Listing Notice 1 (as amended by GN No. 327 of 7 April 2017), Listing Notice 2 (as amended by GN No. 325 of 7 April 2017) and Listing Notice 3 (as amended by GN No. 324 of 7 April 2017). The undertaking of activities specified in the Listing Notices is prohibited until Environmental Authorisation has been obtained from the competent authority. Such Environmental Authorisation, which may be granted subject to conditions, will only be considered once there has been compliance with the EIA Regulations, 2014.

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The EIA Regulations, 2014 (as amended) set out the procedures and documentation that need to be complied with when applying for Environmental Authorisation. A Basic Assessment process must be applied to an application if the authorisation applied for is in respect of an activity or activities listed in Listing Notices 1 and/or 3 and a Scoping and EIA process must be applied to an application if the authorisation applied for is in respect of an activity or activities listed in Listing Notice 2. The proposed maize wet mill plant would only trigger activities specified in Listing Notice 1 (see Table 2-1) and therefore a BA process is required in order for GDARD to consider the application in terms of NEMA.

TABLE 2-2: NEMA LISTED ACTIVITIES APPLIED FOR AS PART OF THE PROPOSED PROJECT

Description of activity in relation to the No. Activity description proposed project Listing Notice 1 (as amended by GN No. 327 of April 2017) 2 (i) The development and related operation of facilities or Provision is included for back-up power infrastructure for the generation of electricity from a non- generation using diesel for instances when renewable resource where - Eskom supply is down. The design of the (i) the electricity output is more than 10 megawatts but less plant has a 15MW electrical load. than 20 megawatts; 8 The development and related operation of hatcheries or agri- The project is an agri-industrial operation industrial facilities outside industrial complexes where the outside an industrial complex covering an development footprint covers an area of 2 000 square metres or area of more than 2 000 m2. more. 14 The development and related operation of facilities or The plant will store a number of chemicals infrastructure, for the storage, or for the storage and handling, considered to be dangerous goods as well as of a dangerous good, where such storage occurs in containers diesel for backup power generation. The with a combined capacity of 80 cubic metres or more but not storage will be below 500m3. exceeding 500 cubic metres. 25 The development and related operation of facilities or The project will require wastewater (plant infrastructure for the treatment of effluent, wastewater or effluent) and domestic sewer treatment sewage with a daily throughput capacity of more than 2 000 plants. The combined ca daily throughput cubic metres but less than 15 000 cubic metres. capacity would be 5 654,5m3 per day. 27 The clearance of an area of 1 hectares or more, but less than 20 The development of the plant would require hectares of indigenous vegetation. clearance of approx. 16.2 hectares (ha) of indigenous vegetation. 28 (i) Residential, mixed, retail, commercial, industrial or institutional The development of the plant, located inside developments where such land was used for agriculture , game the urban area, will result in more than 5 ha farming, equestrian purposes or afforestation on or after 01 of land previously used for agriculture being April 1998 and where such development : developed as an industrial site. (i) will occur inside an urban area, where the total land to be developed is bigger than 5 hectares. b. Gauteng Provincial Environmental Management Framework Standard The Gauteng Provincial Environmental Management Framework (GPEMF) Phase 2 is a tool developed to streamline the requirements for an environmental impact assessment (EIA), reduce timeframes for approvals and to contribute towards reducing the cost of doing business in Gauteng. In this tool, a number of the NEMA listed activities are excluded from the requirement to obtain an environmental authorisation. These excluded activities are applicable only in Environmental Management Zones 1 and 5 of the GPEMF, 2015.

It is noted that while the proposed plant site falls within the extent of Zone 1 of the GPEMF, the activities which are triggered by the project are not excluded by the GPEMF, thus Environmental Authorisation will be required.

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2.1.2 National Environmental Management: Waste Act, 2008 The National Environmental Management: Waste Act, 2008 (No. 59 of 2008) (NEM:WA) regulates all aspects of waste management and has an emphasis on waste avoidance and minimisation. NEM:WA creates a system for listing and licensing waste management activities which may have a detrimental effect on the environment. a. Listed waste management activities Listed waste management activities are included in GN R 921 of November 2013. Category A and Category B listed waste management activities above certain thresholds are subject to a process of impact assessment and licensing. Category C listed waste management activities do not require a waste management license but are subject to the provisions of National Norms and Standards (GN R 926, November 2013).

The proposed maize wet mill plant would require the storage of coal ash which is a Category C activity (see Table 2-3), requiring compliance with the National Norms and Standards for Waste Storage (GN R. 926 of 2013).

TABLE 2-3: CATEGORY C LISTED WASTE MANAGEMENT ACTIVITIES

Description of activity in relation to the No. Activity description proposed project 2 The storage of hazardous waste at a facility that has the capacity The plant would temporarily store to store in excess of 80m3 hazardous waste at any one time , approximately 210m3 of coal ash for removal excluding the storage of hazardous waste in lagoons or the from site. temporary storage of such waste.

2.1.3 National Environmental Management: Air Quality Act, 2004 The National Environmental Management: Air Quality Act, 2004 (No. 39 of 2004) (NEM:AQA) regulates all aspects of air quality, including prevention of pollution and environmental degradation; providing for national norms and standards regulating air quality monitoring, management and control; and licencing of activities that result in atmospheric emissions and have or may have a significant detrimental effect on the environment. The NEM:AQA has established a National Framework for Air Quality Management with various standards being implemented. a. Minimum emission standards A liquid or solid fuel boiler can be classified in one of four categories under NEM:AQA:  A listed activity (Subcategory 1.2 – Liquid Fuel Combustion Installations, Subcategory 1.1 – Solid Fuel Combustion Installations) as per Section 21 of NEM:AQA, applicable to all liquid and solid fuel combustion installations used primarily for steam raising or electricity generation with a design capacity equal to or greater than 50 MW heat input per unit, based on the lower calorific value of the fuel used.  A controlled emitter as per Section 23(1) of NEM:AQA, applicable to any boiler with a design capacity equal to 10 MW but less than 50 MW net heat input per unit, based on the lower calorific value used.  Unclassified under NEM:AQA, applicable to boilers with a design capacity less than 10 MW heat input per unit, based on the lower calorific value used.  Or, in the case where a waste is co-fed with conventional fuels, a listed activity (Subcategory 1.6 – Waste Co-feeding combustion installations) as per Section 23(1) of NEM:AQA, applicable to all combustion installations co-feeding waste with conventional fuels in processes primarily used for steam raising or electricity generation.

Based on estimated coal use per boiler, the proposed boilers will have a design capacity greater than 10 MW but less than 50 MW net heat input (15.75 MW per boiler) and therefore fall within the category of controlled emitters. In 2013, the Minister published a declaration of small boilers as controlled emitters (the Small Boiler

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Declaration) (GN 831 of November 2013). Activities declared as controlled emitters do not require an air emission license but are subject to the provisions of the Declaration and would therefore require registration with the local authority as a controlled emitter. Minimum emission standards for small boilers are presented in the Air Quality specialist study (see Section 4 of Appendix 9).

Section 21 of NEM:AQA listed activities provide for emissions standards where the design capacity of a boiler is equal to or greater than 50 MW heat input per unit. Although this does not apply to the proposed project, the project is located within an airshed priority area where elevated ambient concentrations exist and therefore the proposed plant is being designed to comply with the Section 21 emission standards.

The use of natural gas for steam generation is restricted by the current national gas supply capacity constraints. In the event where natural gas proves feasible and sustainable as an alternative fuel source for the boilers, the emission standards associated with gaseous fuel-fired small boilers (using natural gas) would apply.

In terms of the Small Boiler Declaration, where a small boiler is fired simultaneously with two or more fuels, the emission standards for the main fuel shall be applicable.

The competent authority for this project is the Sedibeng District Municipality. b. National Ambient Air Quality Standards National Ambient Air Quality Standards (NAAQS) were determined based on international best practice for inhalable particulate matter (PM2.5), thoracic particulate matter (PM10), sulfur dioxide (SO2), nitrogen dioxide (NO2), carbon monoxide (CO), ozone, lead and benzene. The NAAQS permit a frequency of exceedance (FOE) of 1% per year (88 hours or 4 days per year for 1-hour and 24-hour average concentrations) for some pollutants. The NAAQS are presented in the Air Quality specialist study (see Section 4 of Appendix 9). Simulated ambient air pollutant concentrations were assessed against NAAQS, where PM2.5; PM10; SO2; and, NO2 were the criteria pollutants of concern in the assessment. c. National Dust Control Regulations The National Dust Control Regulations (NDCR) was gazetted on 1 November 2013 (No. 36974). The purpose of the regulations is to prescribe general measures for the control of dust in all areas including residential and light commercial areas. The regulations provide a guideline for monitoring and measuring dust fall. Dust fall is assessed for nuisance impact and not an inhalation health impact. The acceptable dust fall rates are presented in the Air Quality specialist study (see Section 4 of Appendix 9). Potential dust fall from the project was assessed against the NDCR. d. Air Quality Management Plan for the Vaal Triangle The Vaal Triangle Airshed was the first priority area in South Africa declared by the Minister in April 2006, and was identified as an area with poor ambient air quality that required specific air quality management action to rectify the situation. In May 2009 the DEA published the Air Quality Management Plan for the Vaal Triangle Airshed Priority Area. Regulations for implementing and enforcing the Vaal Triangle Airshed Priority Area Air Quality Management Plan were also promulgated. The implication of this is that all contributing sources in the area will be assessed to determine the emission reduction targets to be achieved over the subsequent years and air quality management measures for other significant sources (e.g. household fuel burning) would be sought and implemented.

The proposed maize wet mill falls within the Vaal Triangle Airshed Priority Area. New developments which are associated with atmospheric emissions, and hence the potential for contributing to air pollutant concentrations, are subject to focused scrutiny by national air pollution control officers. Emphasis is being placed on ensuring that best practice control measures are being proposed for implementation and that the development will not substantially add to the existing air pollution burden in the region. The design of the plant has taken this into consideration.

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e. National Atmospheric Emission Reporting Regulations The purpose of these Regulations is to regulate reporting of data and information from an identified point, non-point and mobile sources of atmospheric emissions to an internet-based National Atmospheric Emissions Inventory System (NAEIS) towards the compilation of atmospheric emission inventories. The NAEIS is a component of the South African Air Quality Information System (SAAQIS). Its objective is to provide all stakeholders with relevant, up to date and accurate information on South Africa's emissions profile for informed decision making. The project will record and provide data, as required. f. National Greenhouse Gas Emission Reporting Regulations The purpose of these Regulations is to introduce a single national reporting system for the transparent reporting of greenhouse gas emissions, which will be used:  to update and maintain a National Greenhouse Gas Inventory;  for the Republic of South Africa to meet its reporting obligations under the United Framework Convention on Climate Change (UNFCCC) and instrument treaties to which it is bound; and  to inform the formulation and implementation of legislation and policy.

The Regulations require that facilities with more than 10MWth installed capacity register at the Department of Environmental Affairs and report their greenhouse gas emissions on an annual basis. The proposed plant would need to report its energy emissions from the combustion of fuel as well as emissions from the wastewater treatment plant. g. National Pollution Prevention Plans Regulations The purpose of these Regulations is to prescribe that pollution prevention plans for greenhouse gases declared as priority air pollutants need to comply with Section 29(3) of the Act. A first pollution prevention plan must cover a period from the date of promulgation of these Regulations up to 31 December 2020 and the subsequent pollution prevention plans must cover periods of five calendar years each.

The estimated emission of the proposed plant would exceed 100 000 tons of CO2e per year, and therefore a pollution prevention plan in terms of the National Pollution Plan Regulations will be required once the plant is operational. h. Noise control In terms of the NEM:AQA, national standards for the control of noise may be prescribed, although none have been published to date under the NEM:AQA, and the Gauteng Noise Control Regulations published in 1999 still apply. These provide uniform minimum standards for noise regulation in Gauteng, accommodating circumstances of different areas. It prohibits noise nuisances and “disturbing noise” which is defined as “a noise level that causes the ambient noise level to rise above the designated zone level, or if no zone level has been designated, the typical rating levels for ambient noise in districts, as per SANS 10103 (2008)”.

It is believed that when published, national criteria will make extensive reference to SANS 10103 of 2008. This standard has been widely applied in South Africa and is frequently used by local authorities when investigating noise complaints. These guidelines, which are in line with those published by the IFC in their General EHS Guidelines (IFC 2007) and World Health Organisation (WHO) Guidelines for Community Noise (WHO 1999), were considered in the assessment. The guideline ratings are presented in the Noise specialist study (see Section 2 of Appendix 10).

2.1.4 National Water Act, 1998 The National Water Act, 1998 (No. 36 of 1998) (NWA) provides a legal framework for the effective and sustainable management of water resources in South Africa. It serves to protect, use, develop, conserve, manage and control water resources as a whole, promoting the integrated management of water resources with the participation of all stakeholders. This Act also provides national norms and standards, and the

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requirement for authorisation (either a Water Use Licence or General Authorisation) of water uses listed in Section 21 of the Act. The competent authority is the Department of Water and Sanitation (DWS). a. General authorisations A General Authorisation (GA) replaces the need for a water user to apply for a water use licence in terms of the NWA, provided that the water use is within the limits and conditions of the specific GA. Water uses applicable to the project and the related GA are listed in Table 2-4.

TABLE 2-4: GENERAL AUTHORISATION WATER USES APPLICABLE TO THE PROPOSED PROJECT

Description of activity in relation to the No. Water use proposed project 21(e) GA (GN R 1191 of 1999) permits the discharge of waste or water Excess treated effluent from the domestic containing waste into a water resource through a pipe, canal, sewer package plant and/ or the wastewater sewer or other conduit provided that the discharge is within the treatment plant would be discharged into limits and conditions set out in the authorisation. the existing storm water channel which feeds into a tributary of the Vaal. 21(f) GA (GN R 399 of 2004, as amended) permits the irrigation of any Treated effluent from the domestic sewer land with waste or water containing waste generated through package plant and/ or the wastewater any industrial activity or by a waterworks, provided that the treatment plant would be re-used to irrigate irrigation is within the limits and conditions set out in the rehabilitated and landscaped areas within authorisation. the plant boundary.

General Authorisation (GN R 509 of 2016) introduced the concept of the “regulated area of a watercourse" for Section 21(c) or (i) water uses. In terms of the Notice a regulated area includes: a. the outer edge of the 1 in 100 year flood line and /or delineated riparian habitat, whichever is the greatest distance, measured from the middle of the watercourse of a river, spring, natural channel, lake or dam; b. in the absence of a determined 1 in 100 year flood line or riparian area the area within 100m from the edge of a watercourse where the edge of the watercourse is the first identifiable annual bank fill flood bench (subject to compliance to section 144 of the Act ); or c. a 500 m radius from the delineated boundary (extent) of any wetland or pan.

No wetlands occur within 500 m of the project site. In addition all project infrastructure has been located outside the 1:100 year flood line of any watercourse and therefore Section 21(c) and (i) water uses are not triggered by the project development. b. Water quality Water quality standards applicable to the project include:  South African National Standard - SANS 241:2015 Drinking Water Standards.  In stream water quality guidelines quality guidelines for the Vaal Barrage Reservoir catchment, 2003 (I-SWQG) from ideal catchments background quality up to unacceptable ranges).  Target water quality standards set up in the South African Water Quality Guidelines - (SAWQG) 1996, where the Target Water Quality Range (TWQR) equal to the No Effect Range is that it specifies good or ideal water quality instead of water quality that is merely acceptable.  The wastewater discharge water quality objectives (WQO) applicable to the wastewater discharged from the Leeuwkuil WWTWs into the Vaal River.

These standards fall within the requirements of the IFC General Environmental, Health, and Safety (EHS) Guidelines for environmental wastewater and ambient water quality. These guidelines require that should local regulatory requirements be available, the residual wastewater and storm water from industrial processes should be disposed in compliance with these.

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2.1.5 National Heritage Resources Act, 1999 The National Heritage Resources Act, 1999 (No. 25 of 1999) (NHRA) provides for the identification, assessment and management of the heritage resources of South Africa. Section 38(1) of the NHRA lists development activities that would require authorisation by the responsible heritage resources authority. Activities considered applicable to the proposed project include:  The construction of a road, wall, powerline, pipeline, canal or other similar form of linear development or barrier exceeding 300 m in length;  Any development or other activity which will change the character of a site exceeding 5 000 m² in extent; and  Re-zoning of a site exceeding 10 000 m2.

The NHRA requires that a person who intends to undertake a listed activity notify the relevant provincial heritage authority at the earliest stages of initiating such a development. The relevant provincial heritage authority would then in turn, notify the person whether a Heritage Impact Assessment (HIA) should be submitted. However, according to Section 38(8) of the NHRA, a separate report would not be necessary if an evaluation of the impact of such development on heritage resources is required in terms of the Environment Conservation Act (No. 73 of 1989) (now replaced by NEMA) or any other applicable legislation. The decision- making authority should, however, ensure that the heritage evaluation fulfils the requirements of the NHRA and take into account in its decision-making any comments and recommendations made by the relevant heritage resources authority.

In light of the above, the background information document for the project was uploaded to South African Heritage Resources Association (SAHRA) on 12 July June 2018 (SAHRA Case No. 12707). Comments were received from SAHRA on 18 July 2018 outlining the Department’s requirements. These have been adhered to.

2.2 GUIDELINES, POLICIES, PLANS AND FRAMEWORKS The guidelines, policies and plans listed in Table 2-5 have been taken into account during the BA process and as part of specialist studies, where applicable.

TABLE 2-5: GUIDELINE AND POLICY FRAMEWORK

Guideline Governing body Relevance Public participation DEA The purpose of this guideline is to ensure that an adequate public guideline in terms of NEMA participation process is undertaken during the BA process. (2017) Guideline on need and DEA This guideline informs the consideration of the need and desirability desirability (2017) aspects of the proposed project. National Development Plan NPC The National Development Plan 2030 (NDP) is the overarching 2030 development planning policy for the country, to which all other development planning, in particular spatial planning must be aligned. The NDP outline South Africa’s Vision, and provides the Framework for eliminating poverty and reducing inequality by 2030. Medium-Term Strategic NPC Provides Government’s Strategic Plan for the 2014-2019 electoral Framework (MTSF) 2014- term. 2019 Gauteng Vision 2055 GPG The Gauteng Vision 2055 “plan”, envisages an integrated, globally (Gauteng City Region) 2012 competitive Gauteng City Region (GCR). This plan calls for: - Establishment of a shared vision and strategy - Enhanced co-operation and coordination amongst all regional stakeholders - Improved governance practices - Better urban management - A focus on acting together in the global arena.

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Guideline Governing body Relevance Gauteng Strategic Plan GPG In order to realise the NDP, Gauteng Provincial Government (GPG) has 2015-2019 taken active decisive steps to make Gauteng an integrated city-region characterised by social cohesion and economic inclusion over the next five-to-fifteen years. The Province has adopted a ten-pillar programme of Transformation, Modernisation and Re-industrialisation. Municipalities were tasked to integrate the ten-pillars into their IDPs. Gauteng Employment GPG Provides a set of strategic choices and programmes that will build a Growth and Development strong and sustainable Gauteng economy in which all can access Strategy, 2009-2014 economic opportunities and enjoy decent work. Gauteng Spatial GPG The Gauteng Spatial Development Framework (GSDF) 2030 envisions a Development Framework province that is an integrated, connected space that provides for the 2030 needs of all who are born in or drawn to the province. Economic growth is spread widely, beyond the core areas, to nodes and multi- modal activity corridors. To realise the spatial development vision, all developments in the province need to adhere to six spatial development principles: (i) liveability, (ii) concentration, (iii) connectivity, (iv) conservation, (v) diversity, and (vi) viability. Sedibeng Growth and SDM The shared, long-term vision set out in the Growth and Development Development Strategy Strategy is that by 2030 Sedibeng is well known as a leading (SGDS) 2 “Metropolitan River City” with a strong, diverse economy and high quality standard of living. It is a city success story where all its residents enjoy a healthy and safe environment and where everyone works, learns, earns and plays together. The Growth and Development Strategy provides a plan of action for growth and development that aligns with and translates national and provincial objectives into practical interventions. Sedibeng District SDM The IDP aims to guide the municipality in the collective endeavours of Municipality, Integrated building a better life for all our communities. The IDP aims to realize Development Plan (2017- the NDP and the SGDS through: 2021) - Reinventing the Economy; - Renewing our communities; - Reviving a Sustainable Environment; - Reintegrating the region; - Releasing Human Potential; - Good Governance; and - Deepening Democracy. Sedibeng District SDM The overarching key issues for spatial planning of the Sedibeng District Municipality, Spatial can be summarized as follows: Development Framework 1. Sedibeng needs to develop policies that support inherent strengths (2014- 2017) and intrinsic potentials of the area across municipal and provincial boundaries 2. Current disjointed policies need to be reformulated to address the strategic development of the District as a functional entity; 3. Law enforcement needs to be improved; 4. Policy and strategy is required for integrated planning, densification and the prevention of sprawl; and 5. Development needs to be focused on areas that will have the largest impact and will facilitate sustainable development by addressing the social, environmental and economic elements of the district. Vaal 21 Initiative SDM Vaal 21 initiative was introduced and approved by SDM to bring together all the municipalities along the Vaal River to leverage off the potential of the river to enhance development. The Vaal 21 initiative will be implemented through a set of GDS and IDP flagship projects. The Vaal 21 municipalities have committed themselves to collectively grow and stimulate the Vaal region economy.

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Guideline Governing body Relevance Emfuleni Local ELM The IDP reflects the municipalities’ alignment to the NDP, the GPG Municipality, Integrated programme of Transformation, Modernisation and Re- Development Plan industrialisation and the seven strategies of the SGDS. The ELM is (2017/18 – 2020/21) committed to fast-track and accelerate service delivery through the theme of ‘Getting the Basics Right: Our Programme for Restoration’. Emfuleni Local ELM The SDF is an overall strategic land development document that Municipality, Spatial provides municipal-wide strategic direction in terms of spatial Development Framework development patterns, the promotion of economic development in (2017-2025) close proximity to residential developments, the conservation of valued environmental assets, the enhancement of the effectiveness of public capital projects, the optimization of existing and planned municipal engineering infrastructure, the promotion of tourism and agricultural industries, and the reversing of distorted spatial human settlement patterns. The Emfuleni Spatial Development Framework (SDF) (Emfuleni, 2017) indicates that two of the key challenges of the local municipality are rapid population growth and deteriorating infrastructure. The development strategy aims to “strengthen the role of the Emfuleni area as the southern anchor of the Gauteng urban conurbation”. The SDF identifies several elements of this development strategy, the following three key aspects: - Urban infill and consolidation – the current fragmented urbanisation should be infilled, particularly between Sebokeng and Vereeniging and along the Vaal River - Movement pattern and transportation structure - between Vanderbijlpark, Vereeniging, and Sebokeng CBDs - Nodal structure – development of the Vanderbijlpark, Vereeniging, and Sebokeng CBDs The project site is earmarked for industrial and commercial expansion in the SDF and will contribute towards the economic development and infill of industrial areas within the Vereeniging area. Western Cape Department DEA There is currently no legal framework in South Africa that specifically of Environmental Affairs governs the development of social impact assessments. The approach and Development Planning: adopted in this study was informed by this guideline as well as by the Guideline for Involving scale of the proposed development within the local context. Social Assessment Specialists in EIA Processes (Barbour, 2007)

2.3 INTERNATIONAL FINANCE CORPORATION

2.3.1 Equator Principles, International Finance Corporation (IFC) Performance Standards and World Bank guidelines The IFC performance standards are applied to a project to manage social and environmental risks and impacts throughout the life of an investment. There are eight performance standards which cover the following areas: social and environmental assessment and management system; labour and working conditions; pollution prevention and abatement; community health, safety and security; land acquisition and involuntary resettlement; biodiversity conservation and sustainable natural resource management; and indigenous people and cultural heritage.

In the event of international financing, the Performance Standards on Environmental and Social Sustainability developed by the IFC of the World Bank Group are considered suitable to guide the environmental work conducted at the project area.

The IFC applies the Performance Standards on Social and Environmental Sustainability (2012) to manage social and environmental risks and impacts to enhance development opportunities in its private sector

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financing in its member countries eligible for financing. The Performance Standards (2012) may also be applied by other financial institutions electing to apply them to projects in emerging markets. The ESIA has been carried out taking cognisance of the IFC Performance Standards.

In support of the performance standards a series of guideline documents have been compiled by the World Bank. The technical reference documents published in the International Finance Corporation (IFC) Environmental, Health and Safety (EHS) Guidelines provide general and industry specific examples of Good International Industry Practice (GIIP). The General EHS Guidelines are designed to be used together with the relevant Industry Sector EHS Guidelines. a. Air quality The EHS Guidelines’ general approach to air quality (IFC, 2007) states that projects should prevent or minimize impacts by ensuring that:  Emissions do not result in pollutant concentrations that reach or exceed the relevant national ambient air quality guidelines and standards, or in their absence, the current World Health Organisation (WHO) Air Quality Guidelines (AQG) or other internationally recognised sources.  Emissions do not contribute a significant portion to the attainment of relevant ambient AQG or standards. The Guideline suggests a contribution of less than 25% of the applicable ambient air quality standards to allow additional, future development in the same airshed.

The General EHS Guidelines state that at project level, impacts should be estimated through qualitative or quantitative assessments using baseline air quality assessments and atmospheric dispersion models. The dispersion model should be internationally recognised and able to consider local atmospheric, climatic and air quality data as well as the effects of downwash, wakes or eddy effects generated by structures and terrain features (IFC, 2007). The General EHS Guidelines also provides guidance with respect to:  projects located in degraded airsheds or ecologically sensitive areas;  points sources and stack heights;  emissions from small combustion facilities (3 to 50 MW (thermal) rated heat input capacity);  fugitive sources;  ozone depleting substances;  land based mobile sources;  greenhouse gases;  monitoring; and  air emissions prevention and control technologies.

These guidelines have been taken into consideration in the air quality specialist study. b. Noise The SANS 10103 of 2008 standard is in line with those published by the IFC in their General EHS Guidelines (IFC 2007) and World Health Organisation (WHO) Guidelines for Community Noise (WHO 1999). These were considered in the assessment. The criteria applied to this study are the IFC noise guideline levels for industrial and residential, institutional and educational receptors and the increase in noise levels of 3 dBA above background levels. c. Water The South African water quality standards (see Section 2.1.4) fall within the requirements of the IFC General EHS Guidelines for environmental wastewater and ambient water quality. These guidelines require that should local regulatory requirements be available, the residual wastewater and storm water from industrial processes should be disposed in compliance with these.

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3 BA APPROACH AND METHODOLOGY This chapter outlines the assessment methodology and I&AP consultation process followed in the BA process.

3.1 DETAILS OF THE BA PROJECT TEAM As noted in Chapter 1, SLR has been appointed as the independent EAP to undertake the BA for the proposed maize wet mill plant. The details of the EAP project team that are undertaking this BA are provided in Table 3-1.

SLR has no vested interest in the proposed project other than fair payment for consulting services rendered as part of the BA process and has declared its independence as required by the EIA Regulations 2014 (as amended). An undertaking by the EAP is provided in Appendix 2.

TABLE 3-1: DETAILS OF THE BA PROJECT TEAM

General Organisation SLR Consulting (South Africa) (Pty) Ltd Postal address PO Box 1596, Cramerview, 2060 Tel No. (011) 467 0945 Fax No. (011) 467 0978 Name Tasks and roles Email Jonathan Crowther (SLR) Report and process reviewer [email protected] Alex Pheiffer (SLR) Management of the BA process, including public [email protected] consultation, process review, specialist study review and report compilation Clive Phashe (SLR) Project assistant and public consultation [email protected]

3.2 QUALIFICATIONS AND EXPERIENCE OF THE EAPS Jonathan Crowther is the Operations Manager of SLR for the Environmental Management Planning and Approvals team in Africa. He holds a Master’s Degree in Environmental Science (from the University of Cape Town) and has 30 years of relevant experience. He has expertise in a wide range of environmental disciplines, including EIAs, EMPs, Environmental Planning and Review and Public Consultation. Jonathan is a Registered Professional Natural Scientist (PrSciNat) (Environmental Science) and a Certified Environmental Practitioner of South Africa (CEAPSA). He is also a member of the International Association of Impact Assessment South Africa (IAIAsa).

Alex Pheiffer holds a Master’s Degree in Environmental Management (from the Rand Afrikaans University) and has over 16 years of experience in a range of environmental disciplines, including EIAs, EMPs, Licensing, Environmental Auditing and Monitoring, Review and Public Consultation. She has expertise in a wide range of projects. She is a Registered PrSciNat (Environmental Science) and is a member of the International Association of Impact Assessment South Africa (IAIAsa).

Clive Phashe holds a Bachelor of Science in Life and Environmental Sciences from the University of Johannesburg. Clive is an Environmental Intern with SLR and has over a year’s experience within the environmental consulting field. Clive has assisted in a variety of mining projects since joining the company.

Relevant curricula vitae (including proof of registrations) are attached in Appendix 3.

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3.3 QUALIFICATIONS, ASSUMPTIONS AND LIMITATIONS The assumptions and limitations pertaining to this BAR are presented in the table below.

TABLE 3-2: QUALIFICATIONS, ASSUMPTIONS AND LIMITATIONS Aspect Qualifications, assumptions and limitations General - It is assumed that SLR has been provided with all relevant project information and that it was correct and valid at the time it was provided, - There will be no significant changes to the project description or surrounding environment between the completion of the BA process and implementation of the proposed project that could substantially influence findings and recommendations with respect to mitigation and management. - Specialists assessed potential impacts from the construction and operational phases separately. These have been assessed collectively in the BAR by the EAP, using the information provided by specialists. This provides an assessment of the overall project. Cumulative - All identified impacts are considered in a cumulative manner such that the impacts of the current assessment baseline conditions on and surrounding the site and those potentially associated with the project are discussed and assessed together. - A second development is planned in the same industrial area and within a similar timeframe. Where required potential cumulative impacts are presented. Climate data - No on-site weather station exists in the area and therefore climatic and meteorological data was sourced from nearby stations. Given the relatively flat nature and absence of significant topographical features, this is considered suitable for this study. Water quality - Water quality data for both surface- and groundwater is based on a single sampling run and therefore does not provide an indication of seasonal variation. Terrestrial - The assessment was confined to the study area and did not include neighbouring areas except ecology where service infrastructure associated with the project was situated outside the study area. - The data presented in this report are based on a single site visit undertaken in March 2018. On-site data was significantly augmented with all available desktop data and specialist experience in the area, and the findings of the assessment are considered to be an accurate reflection of the ecological characteristics of the study area. - With ecology being dynamic and complex, some aspects (some of which may be important) may have been overlooked. It is, however, expected that most floral and faunal communities have been accurately assessed and considered. Aquatic - The portion of the unnamed tributary of the Vaal River that flows past the site to the south and on ecology the southern side of the R28 has been canalised into an artificial earth canal. Although this system has some characteristics associated with rivers it is largely a segment of the system. Furthermore, at the time of the field assessment it was clear that large volumes of untreated or partially treated sewage effluent were being released into the system. For this reason, it was not deemed necessary to undertake detailed eco-status assessments of this system. - All freshwater resources identified within the investigation area were delineated in fulfilment of Regulation GN509 of the NWA on a desktop level with limited field verification; however, these resources were not assessed individually. - A large extent of the natural occurring vegetation has been removed due to seasonal veld fires. Therefore, the use of vegetation species in aid of the delineation of the watercourse proved to be limited in the entire study area. - The freshwater resource delineation is regarded as a best estimate of the freshwater resource boundaries, based on the site conditions present at the time of assessment. Groundwater - Groundwater boreholes provide information for a specific area within the site and therefore should not be relied on for geology in the wider area or as an indication of the presence (or not) of dolomites. Air quality - A 1-month site-specific monitoring campaign was undertaken to assess the applicability to the site of the ambient monitoring data sourced from the Sharpeville AQMS. The duration of the monitoring campaign was considered sufficient for this purpose. - Sulfite emissions from the maize steeping process were not quantified as emission factors are not available to quantify emissions from these process steps. Control systems, however, have been planned in order to minimise emissions and prevent occupational exposure. - Refining of maize sugars into liquid product streams may result in emissions of chloride and volatile organic compounds. These emission streams will be fitted with off-gas scrubbing systems to minimise emissions.

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Aspect Qualifications, assumptions and limitations Noise - Estimates of road traffic were made with the provided truck information. The vehicle speeds and road conditions were assumed. Trucks were assumed to travel at 40 km/h on access road and 15 km/h on-site. - The quantification of sources of noise was limited to the operational phase of the project. Construction and closure phase activities are expected to be similar or less significant and its impacts only assessed qualitatively. Noise impacts will cease post-closure. - All activities were assumed to be 24 hours per day, 7 days per week. Visual - The extent of the study area was determined by the zone of potential influence, which in this study related to a radius of 2,0km around the Project site. At 2,0km and beyond the Project would recede into background views and or be screened by existing buildings, vegetation or infrastructure Traffic - Trip rate: Based on the description of the development, vehicle trip generation rates for light manufacturing were considered to determine the expected developments trips to be generated. - Future traffic growth: Considering the current economic growth rate, as well as the location of the project site, a 3% annual growth rate was assumed. This is in line with the growth rates recommended by the South African Trip Data Manual. - Trip distribution: Trip distribution was based on the location of the site; access in relation to the surrounding road network; and the existing traffic volumes, travel patterns as well as the land use nature of the proposed development. Demographic - Demographic data was sourced from the Census 2011 and 2016 data and is assumed to reflect the data current socio-economic situation. Social - The study was conducted during the early phase of the BA process, and therefore has used information available at that time, including relevant biophysical specialist studies and issues drawn from the Public Participation Process. - It is assumed that the information provided by key stakeholders via interviews and correspondence is an accurate reflection of the current situation or circumstances. Economics - Income generated was provided for a period of 10 years. An average annual number was determined and applied to calculate the income over 20 years of operation. Operational downturn, which is the gradual decrease in production and labour towards end of life of operation, is not reflected in these numbers. - To determine the capital value of the total wages, the average salary of a construction worker as supplied by the Department of Labour was utilised. - A discount factor (a financial factor which, when multiplied by a predicted future cash flow from a loan or some other form of debt, gives its present value) of 10% as advised by the client was used to calculate the net present value calculations. - Present value calculations were applied over a period of 22 years (2 years construction and 20 operational years). - Information used in some of the agricultural calculations was sourced from third parties. Errors with this information could possibly affect the results of the calculations and therefore the assessment. - Maximum annual yields were assumed for each crop type, which is a conservative approach. - Land values were based on available information as indicated in the specialist report, however, the true value of the land is determined by a range of factors and can therefore be higher or lower than the value used in this report, although the land values used are considered appropriate for this study. - Available municipal land valuation records were utilised to determine valuation rates for vacant land as well as land containing infrastructure. Heritage and - The heritage survey may have missed heritage resources that could have been covered with grass cultural or vegetation whilst others may be located below the surface and may only be exposed once resources development commences. As a result, the mitigation makes provision for a chance find procedure. - The palaeontology study made use of the borehole core logs from two boreholes drilled on site during the groundwater study. Based on the logs, although the rocks are of the correct age and primary context, it is assumed that the formation and layout of the gravels, weathered clays, weathered shales and quartzites do not contain any fossils.

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3.4 BASIC ASSESSMENT

3.4.1 Objectives In accordance with Appendix 1 of the EIA Regulations 2014 (as amended), the objectives of a BA process are to:  determine the policy and legislative context within which the proposed activity is located and how the activity complies with and responds to the policy and legislative context;  identify the alternatives considered, including the activity, location, and technology alternatives;  describe the need and desirability of the proposed alternatives;  through the undertaking of an impact and risk assessment process inclusive of cumulative impacts which focused on determining the geographical, physical, biological, social, economic, heritage, and cultural sensitivity of the sites and locations within sites and the risk of impact of the proposed activity and technology alternatives on these aspects to determine - (i) the nature, significance, consequence, extent, duration, and probability of the impacts occurring; (ii) the degree to which these impacts can be reversed, may cause irreplaceable loss of resources; and can be avoided, managed or mitigated;  through a ranking of the site sensitivities and possible impacts the activity and technology alternatives will impose on the sites and location identified through the life of the activity to: (i) identify and motivate a preferred site, activity and technology alternative; (ii) identify suitable measures to avoid, manage or mitigate identified impacts; and (iii) identify residual risks that need to be managed and monitored.

This BA process consists of a series of steps to ensure compliance with these objectives and the EIA Regulations 2014. The process involves an open, participatory approach to ensure that all impacts are identified and that decision-making takes place in an informed, transparent and accountable manner. A flowchart indicating the generic BA process is presented in Figure 3-1.

3.4.2 Pre-application authority consultation Meetings took place with regulatory authorities to inform the project plan and any related authorisation processes. These are outlined below. Meeting notes are included in Appendix 4.

 A pre-application meeting took place with GDARD on 15 June 2018. The purpose of the meeting was to provide notification and introduce the project to the competent authority; provide an overview of the environmental-legal context; discuss key procedural aspects with the competent authority and provide an opportunity to raise any initial comments in relation to the project and environmental authorisation process.

 A meeting was held with the DWS on 13 July 2018. The purpose of the meeting was to discuss the lack of capacity at the municipal Leeuwkuil waste water treatment works and inform the handling of domestic sewer and industrial effluent from the project and the positioning of the attenuation pond in support of the project’s storm water management system as well as the potential discharge from the project. This information was used to inform the project plan and potential authorisation requirements.

 A meeting was held with the Air Quality Control officer from the Sedibeng District Municipality on 30 August 2018. The purpose of the meeting was to present the draft findings of the air quality specialist study and discuss the related mitigation that would be included in the Basic Assessment Report. The outcome of this meeting was used to inform the project plan and related air quality abatement measures.

In addition to the above the project’s background information document (BID) was loaded onto the SAHRA website on 11 June 2018 (Case No. 12574). SAHRA has indicated that they will make comment on receipt of the Basic Assessment Report. SAHRA correspondence is presented in Appendix 4.

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WE ARE HERE

FIGURE 3-1: FLOW DIAGRAM SHOWING THE BA PROCESS

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3.4.3 Public participation process

A public participation process is being undertaken to inform the BA process. A record of the public participation process undertaken pre submission of the environmental authorisation application is outlined in Table 3-3. The purpose of the public participation process was to notify landowners, land users and other key stakeholders of the proposed project and to provide them with opportunity to raise any initial issues or concerns regarding the proposed project. Supporting documentation is presented in Appendix 4.

TABLE 3-3: TASKS UNDERTAKEN TO DATE DURING THE PUBLIC PARTICIPATION PROCESS Steps Details I&AP A preliminary I&AP database has been compiled using information obtained during a social scan of the identification project area and a deed search of adjacent landowners. Additional I&APs were added to the database following responses to the advertisements, site notices and notification letter, and attendance at the focussed stakeholder and public information sharing meetings. To date approximately 89 I&APs have been registered on the project database. It is recorded that the following State Departments/Organs of State/Service providers have been notified and afforded the opportunity to participate in the pre-application public participation process: - Emfuleni Local Municipality and ward councilors; - Sedibeng District Municipality; - South African Heritage Resource Association; - Department of Water and Sanitation; - Transnet Limited; - Eskom and Telkom; - Gauteng Provincial Government (GPG): Department of Agriculture, Forestry and Fisheries; - GPG: Department of Roads and Transport; - GPG: Department of Economic Development; - GPG: Department of Rural Development and Land Reform. Background All identified I&APs were notified of the proposed project by means of a BID. The BID was distributed Information for a 30-day registration and comment period from 26 June 2018 to 26 July 2018. The purpose of the Document BID was to convey information on the proposed project and environmental regulatory process, to invite (BID) I&APs to the public information sharing meeting, to invite I&APs to register on the project database and provide initial comment. Site notices Press advertisements were placed in two local newspapers: and adverts - Sedibeng Ster 13 June 2018; and - Vereeniging Ster, 19 June 2018. Site notices were placed at the site boundary and along Lager Road. Stakeholder Focused stakeholder meetings were held with key stakeholders as follows: meetings - 19 July 2018: Representative of the Vereeniging Correctional Services and staff housing; - 20 July 2018: Ward 11 Councilor and representatives of the Mpho Bodibe Development Forum; - 20 July 2018: Representative of the Wise-Owl Pre-school; - 20 July 2018: Owner of the Cash&Carry located at the Fresh Produce Market; - 20 July 2018: Representatives of the Emfuleni Livestock Executive Committee; - 26 July 2018: Acting Manager of the Sedibeng Fresh Produce Market; and - 03 August 2018: Ward 12 and Ward 15 Councilors. The purpose of the meetings was to give I&APs information on/an introduction to the proposed project and the environmental assessment process and to provide I&APs with an opportunity to ask questions, raise any issues and concerns and provide input on environmental sensitivities and potential impacts. Public A public information sharing meeting was held at the General Smuts High School on 26 July 2018. The information meeting was attended by six people. The purpose of the meetings was to give I&APs information on/an sharing introduction to the proposed project and the environmental assessment process and to provide I&APs meeting with an opportunity to ask questions, raise any issues and concerns and provide input on environmental sensitivities and potential impacts.

In addition to the various meetings that were held, approximately 15 written submissions were received from I&APs during the public participation process (see Appendix 4).

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TABLE 3-4: I&APS THAT SUBMITTED WRITTEN CORRESPONDENCE DURING THE PROCESS

State Departments and Organs of State Commission on Restitution of Land Rights: Gauteng Sedibeng District Municipality GPG: Department of Rural Development and Land Reform GPG: Department of Water and Sanitation SAHRA: South African Heritage Resources Agency General I&APs Nometi Maphutsi Nkosana Nhlapo Mmamotheo Priscilla Moche Moisi Mankotseng Striving To Satisfy 37 Trading and Projects Matshidiso Mthimkulu Malekgere Mary Nhlapo Sibusiso Mtshali Sigi Avashoni Nevondo

All written comments received have been collated and responded to in a Comments and Responses Report (see Appendix 4). In summary, issues raised related mainly to:  employment opportunities, especially for locals and the youth;  ownership, investment, procurement and sponsorship opportunities for locals;  training and skills development;  relocation of the Wise Owl pre-school;  reduction in grazing land;  odour, noise, air quality and water quality impacts;  use of roads and traffic impacts;  safety of local inhabitants related to influx of job seekers;  heritage resources; and  water supply and usage.

3.4.4 Compilation of the BAR This BAR has been prepared in compliance with Appendices 1 and 4 of the EIA Regulations 2014 (see Table 3-5) and has been informed by comments received during the pre-application Public Participation Process.

TABLE 3-5: REQUIREMENTS OF A BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS 2014

Section Requirements Location in report Appendix 1: Content of Basic Assessment Report 3(1)(a) (i & ii) Details and expertise of the Environmental Assessment Practitioner (EAP) who prepared Section 3 and the report, including a CV. Appendix 3 (b) The location of the activity, including: (i) the 21 digit Surveyor General code of each cadastral Section 4.1 land parcel; or (ii) where available, the physical address and farm name; or (iii) where the required information in items (i) and (ii) is not available, the coordinates of the boundary of the property or properties; (c) A plan which locates the proposed activity or activities applied for at an appropriate scale, or, if it Section 4 is: (i) a linear activity, a description and coordinates of the corridor in which the proposed activity or activities is to be undertaken; or (d) A description of the scope of the proposed activity, including: (i) all listed and specified activities Sections 2.1 and triggered; (ii) a description of the activities to be undertaken, including associated structures and 4 infrastructure. (e) A description of the policy and legislative context within which the development is proposed Section 2 including (i) an identification of all legislation, policies, plans, guidelines, spatial tools, municipal development planning frameworks and instruments that are applicable to this activity and are to be considered in the assessment process, and (ii) how the proposed activity complies with and responds to the legislation and policy context, plans, guidelines, tools frameworks, and instruments.

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Section Requirements Location in report (f) A motivation for the need and desirability for the proposed development including the need and Section 5 desirability of the activity in the context of the preferred location. (h) A full description of the process followed to reach the proposed preferred activity, site and - location within the site, including: (i) details of all the alternatives considered; Section 4 (ii) details of the public participation process undertaken in terms of Regulation 41 of the Section 3.4 Regulations, including copies of the supporting documents and inputs; (iii) a summary of the issues raised by interested and affected parties, and an indication of the Section 3.4.3 and manner in which the issues were incorporated, or the reasons for not including them; Appendix 4 (iv) the environmental attributes associated with the alternatives focusing on the geographical, Section 6 physical, biological, social, economic, heritage and cultural aspects; (v) the impacts and risks identified for each alternative, including the nature, significance, Section 7 consequence, extent, duration and probability of the impacts, including the degree to which these impacts (aa) can be reversed; (bb) may cause irreplaceable loss of resources; and (cc) can be avoided, managed or mitigated. (vi) the methodology used in determining and ranking the nature, significance, consequences, Section 3.4.6 extent, duration and probability of potential environmental impacts and risks associated with the alternatives; (vii) positive and negative impacts that the proposed activity and alternatives will have on the Section 7 environment and on the community that may be affected focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects; (viii) the possible mitigation measures that could be applied and level of residual risk; Section 8 (ix) the outcome of the site selection matrix; Section 4.3 (x) if no alternatives, including alternative locations for the activity were investigated, the Section 4.3 motivation for not considering such; and (xi) a concluding statement indicating the preferred alternatives, including preferred location of Section 4.3 the activity. (i) A full description of the process undertaken to identify, assess and rank the impacts the activity Section 7 will impose on the preferred location through the life of the activity , including-: (i) a description of all environmental issues and risks that were identified during the environmental impact assessment process; and (ii) an assessment of the significance of each issue and risk and an indication of the extent to which the issue and risk could be avoided or addressed by the adoption of mitigation measures; (j) An assessment of each identified potentially significant impact and risk, including- Section 7 (i) cumulative impacts; (ii) the nature, significance and consequences of the impact and risk; (iii) the extent and duration of the impact and risk; (iv) the probability of the impact and risk occurring; (v) the degree to which the impact and risk can be reversed; (vi) the degree to which the impact and risk may cause irreplaceable loss of resources; and (vii) the degree to which the impact and risk can be avoided, managed or mitigated; (k) Where applicable, a summary of the findings and impact management measures identified in Sections 6 and 7 any specialist report complying with Appendix 6 to these Regulations and an indication as to how these findings and recommendations have been included in the final report; (l) An environmental impact statement which contains -(i) a summary of the key findings of the Section 9 environmental impact assessment (ii) a map at an appropriate scale which superimposes the proposed activity and its associated structures and infrastructure on the environmental sensitivities of the preferred site indicating any areas that should be avoided, including buffers; and (iii) a summary of the positive and negative impacts and risks of the proposed activity and identified alternatives ; (m) Based on the assessment, and where applicable, impact management measures from specialist Section 8 reports, the recording of the proposed impact management outcomes for the development for inclusion in the EMPr ; (n) Any aspects which were conditional to the findings of the assessment either by the EAP or Section 9 specialist which are to be included as conditions of authorisation; (o) A description of any assumptions, uncertainties, and gaps in knowledge which relate to the Section 3.3 assessment and mitigation measures proposed;

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

Section Requirements Location in report (p) A reasoned opinion as to whether the proposed activity should or should not be authorised, and Section 9 if the opinion is that it should be authorised, any conditions that should be made in respect of that authorisation; (q) where the proposed activity does not include operational aspects, the period for which the Not applicable environmental authorisation is required, the date on which the activity will be concluded, and the post construction monitoring requirements finalised; (r) An undertaking under oath or affirmation by the EAP in relation to: (i) the correctness of the Appendix 2 information provided in the reports; (ii) the inclusion of comments and inputs from stakeholders and l&APs; (iii) the inclusion of inputs and recommendations from the specialist reports where relevant; and (iv) any information provided by the EAP to interested and affected parties and any responses by the EAP to comments or inputs made by interested and affected parties; (s) Where applicable, details of any financial provisions for the rehabilitation, closure, and ongoing Not applicable post decommissioning management of negative environmental impacts; (t) Any specific information that may be required by the competent authority; and Not applicable (u) Any other matters required in terms of section 24(4)(a) and (b) of the Act . Not applicable Appendix 4: Content of the EMPr 1 An EMPr must comply with section 24N of the Act and include - (a) Details of: (i) the EAP who prepared the EMPr; and (ii) the expertise of that EAP to prepare Section 8.1 and an EMPr , including a curriculum vitae; Appendix 3 (b) a detailed description of the aspects of the activity that are covered by the EMPr as identified by Section 8.1 the project description; (c ) a map at an appropriate scale which superimposes the proposed activity , its associated Section 8.1 structures, and infrastructure on the environmental sensitivities of the preferred site, indicating any areas that should be avoided, including buffers; (d) a description of the impact management outcomes, including management statements, Section 8 identifying the impacts and risks that need to be avoided, managed and mitigated as identified through the environmental impact assessment process for all phases of the development including - (i) planning and design; (ii) pre-construction activities, (iii) construction activities, (iv) rehabilitation of the environment after construction and where applicable post closure; and (v) where relevant, operation activities. (e) deleted - (f) a description of proposed impact management actions, identifying the manner in which the Section 8 impact management outcomes contemplated in paragraphs (d) will be achieved, and must, where applicable, include actions to - (i) avoid, modify, remedy, control or stop any action, activity or process which causes pollution or environmental degradation; (ii) comply with any prescribed environmental management standards or practices; (iii) comply with any applicable provisions of the Act regarding closure, where applicable; and (iv) comply with any provisions of the Act regarding financial provisions for rehabilitation, where Not applicable applicable; (g) the method of monitoring the implementation of the impact management actions contemplated Section 8 in paragraph (f); (h) the frequency of monitoring the implementation of the impact management actions Section 8 contemplated in paragraph (f); (i) an indication of the persons who will be responsible for the implementation of the impact Section 8 management actions; (j) the time periods within which the impact management actions contemplated in paragraph (f) Section 8 must be implemented; (k) the mechanism for monitoring compliance with the impact management actions contemplated Section 8 in paragraph (f); (l) a program for reporting on compliance, taking into account the requirements as prescribed by Section 8 the Regulations; (m) an environmental awareness plan describing the manner in which - (i) the applicant intends to Section 8 inform his or her employees of any environmental risk which may result from their work; and (ii) risks must be dealt with in order to avoid pollution or the degradation of the environment

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

Section Requirements Location in report (n) any specific information that may be required by the competent authority Not applicable (2) Where a government notice gazetted by the Minister provides for a generic EMPr such Not applicable generic EMPr as indicated in such notice will apply.

3.4.5 Specialist studies A full suite of specialist studies have been undertaken to inform the BA process. The specialist studies involved the gathering of data (desktop and site visit, where applicable) relevant to identifying and assessing environmental impacts that may occur as a result of the proposed project. These impacts have been assessed according to pre-defined rating scales (see Section 3.4.6 below). Specialist studies included recommended mitigation measures to minimise potential impacts or optimisation measures to enhance potential benefits as well as monitoring requirements, where required. These have been incorporated into the EMPr. The methodologies applied to each specialist study are included in the specialist reports attached as appendices to this BAR.

Specialists who provided input to the BA process are listed in the table below (Table 3-6).

TABLE 3-6: SPECIALIST STUDIES Specialist field Name and Surname Company Expertise Surface water Kevin Bursey SLR South Africa (Pty) Ltd Hydrologist Soils and agricultural Carl Steyn SLR South Africa (Pty) Ltd Land quality remediation potential specialist Terrestrial ecology Marelie Meintjies Scientific Terrestrial Services Biodiversity specialist Aquatic ecology M. Mbangezeli Scientific Aquatic Services Biodiversity specialist Groundwater Gwendal Madec SLR South Africa (Pty) Ltd Hydrogeologist Air quality Terri Bird Airshed Planning Professionals Air quality specialist Noise Reneé von Gruenewaldt Airshed Planning Professionals Noise specialist Visual Graham A Young Graham A Young Landscape Architect Landscape architect Social Danielle Sanderson Nomad Socio Economic Management Social scientist and Consultancy (Pty) Ltd Economics Werner Neethling Mercury Financial Consultants Economist Traffic Basetsana Kgatle WSP Traffic and Transportation Technologist Heritage Dr Julius CC Pistorius Dr Julius CC Pistorius Archaeologist Palaeontology Dr Marion Bamford Palaeobotanist

3.4.6 Integration and assessment The specialist information and other relevant information has been be integrated into the BAR, which includes an Impact Assessment and Environmental Management Programme (EMPr).

Both the criteria used to assess the impacts and the method of determining the significance of the impacts is outlined in Table 3-7. This method complies with the method provided in the EIA guideline document. Part A provides the approach for determining impact consequence (combining intensity, extent and duration). Impact consequence and significance are determined from Part B and C. The consequence rating is considered together with the probability of occurrence in order to determine the overall significance of each impact. The interpretation of the impact significance is given in Part D.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

TABLE 3-7: CRITERIA FOR ASSESSING IMPACTS PART A: DEFINITIONS AND CRITERIA* Definition of SIGNIFICANCE Significance = consequence x probability Definition of CONSEQUENCE Consequence is a function of intensity, spatial extent and duration Criteria for ranking of VH Severe change, disturbance or degradation. Associated with severe consequences. May the INTENSITY of result in severe illness, injury or death. Targets, limits and thresholds of concern environmental continually exceeded. Substantial intervention will be required. Vigorous/widespread impacts community mobilization against project can be expected. May result in legal action if impact occurs. H Prominent change, disturbance or degradation. Associated with real and substantial consequences. May result in illness or injury. Targets, limits and thresholds of concern regularly exceeded. Will definitely require intervention. Threats of community action. Regular complaints can be expected when the impact takes place. M Moderate change, disturbance or discomfort. Associated with real but not substantial consequences. Targets, limits and thresholds of concern may occasionally be exceeded. Likely to require some intervention. Occasional complaints can be expected. L Minor (Slight) change, disturbance or nuisance. Associated with minor consequences or deterioration. Targets, limits and thresholds of concern rarely exceeded. Require only minor interventions or clean-up actions. Sporadic complaints could be expected. VL Negligible change, disturbance or nuisance. Associated with very minor consequences or deterioration. Targets, limits and thresholds of concern never exceeded. No interventions or clean-up actions required. No complaints anticipated. VL+ Negligible change or improvement. Almost no benefits. Change not measurable/will remain in the current range. L+ Minor change or improvement. Minor benefits. Change not measurable/will remain in the current range. Few people will experience benefits. M+ Moderate change or improvement. Real but not substantial benefits. Will be within or marginally better than the current conditions. Small number of people will experience benefits. H+ Prominent change or improvement. Real and substantial benefits. Will be better than current conditions. Many people will experience benefits. General community support. VH+ Substantial, large-scale change or improvement. Considerable and widespread benefit. Will be much better than the current conditions. Favourable publicity and/or widespread support expected. Criteria for ranking VL Very short, always less than a year. Quickly reversible the DURATION of L Short-term, occurs for more than 1 but less than 5 years. Reversible over time. impacts M Medium-term, 5 to 10 years. H Long term, between 10 and 20 years. (Likely to cease at the end of the operational life of the activity) VH Very long, permanent, +20 years (Irreversible. Beyond closure) Criteria for ranking VL A part of the site/property. the EXTENT of L Whole site. impacts M Beyond the site boundary, affecting immediate neighbours H Local area, extending far beyond site boundary. VH Regional/National

PART B: DETERMINING CONSEQUENCE INTENSITY = VL Very long VH Low Low Medium Medium High Long term H Low Low Low Medium Medium DURATION Medium term M Very Low Low Low Low Medium Short term L Very low Very Low Low Low Low Very short VL Very low Very Low Very Low Low Low INTENSITY = L Very long VH Medium Medium Medium High High Long term H Low Medium Medium Medium High DURATION Medium term M Low Low Medium Medium Medium Short term L Low Low Low Medium Medium Very short VL Very low Low Low Low Medium

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

INTENSITY = M Very long VH Medium High High High Very High Long term H Medium Medium Medium High High DURATION Medium term M Medium Medium Medium High High Short term L Low Medium Medium Medium High Very short VL Low Low Low Medium Medium INTENSITY = H Very long VH High High High Very High Very High Long term H Medium High High High Very High DURATION Medium term M Medium Medium High High High Short term L Medium Medium Medium High High Very short VL Low Medium Medium Medium High INTENSITY = VH Very long VH High High Very High Very High Very High Long term H High High High Very High Very High DURATION Medium term M Medium High High High Very High Short term L Medium Medium High High High Very short VL Low Medium Medium High High

VL L M H VH A part of the Whole site Beyond the Extending far Regional/ site/ property site, affecting beyond site National neighbours but localised EXTENT

PART C: DETERMINING SIGNIFICANCE PROBABILITY Definite/ VH Very Low Low Medium High Very High (of exposure to Continuous impacts) Probable H Very Low Low Medium High Very High Possible/ M Very Low Very Low Low Medium High frequent Conceivable L Insignificant Very Low Low Medium High Unlikely/ VL Insignificant Insignificant Very Low Low Medium improbable VL L M H VVH CONSEQUENCE

PART D: INTERPRETATION OF SIGNIFICANCE Significance Decision guideline Very High Potential fatal flaw unless mitigated to lower significance. High It must have an influence on the decision. Substantial mitigation will be required. Medium It should have an influence on the decision. Mitigation will be required. Low Unlikely that it will have a real influence on the decision. Limited mitigation is likely required. Very Low It will not have an influence on the decision. Does not require any mitigation Insignificant Inconsequential, not requiring any consideration. *VH = very high, H = high, M= medium, L= low and VL= very low and + denotes a positive impact.

3.4.7 Completion of the BAR Following closure of the BAR commenting period, all comments received will be incorporated and responded to in a Comments and Responses Report. Where required the BAR will be updated to address comments received. The final report including I&AP comments will be submitted to GDARD for consideration and decision-making. Registered I&APs will receive notification of the final submission to GDARD.

After the GDARD has reached a decision registered I&APs will be notified of the outcome of the application, the reasons for the decision and details of the appeal process.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

4 PROJECT DESCRIPTION This chapter provides general information on the proposed project, a description of the proposed maize wet milling activities and a description of alternatives considered.

4.1 GENERAL PROJECT INFORMATION

4.1.1 Applicant details

The applicant for the project is Project Jordan Holding Company (Pty) Ltd. Details are provided in Table 4-1 below. It is intended for the plant to be owned by a majority Black-Owned company and to become a Level 2 Black Economic Empowerment (BEE) supplier. The shareholding would most likely comprise a BEE sponsor, owner and manager (O&M) and corporate investors.

TABLE 4-1: APPLICANT DETAILS Name: Project Jordan Holding Company (Pty) Ltd Address: P.O. Box 7750, Centurion Responsible person: Duncan Pask

4.1.2 Project locality The location of the proposed maize wet mill plant is outlined in Table 4-2.

TABLE 4-2: PROPERTY LOCATION Aspect Detail Farm: Erf 188 of Leeuwkuil Ext 5 and a portion of Portion 237 of the farm Leeuwkuil 596 IQ. Physical address: Stout Close, off Lager Road, Vereeniging Surveyor General 21 digit code: Erf188 T0IQ00000000059600237 Property size: Approximately 243 000 m2 (24.3 ha). Development footprint size: Approximately 162 000 m² (16.2 ha) Zoning: Erf 188 is zoned “Special – Industrial and commercial purposes and any other uses with consent of the council”. An application to rezone Erf 188 to “Industrial 2” is underway. There is also a town planning application underway to extend Leeuwkuil Ext 5 to include a portion of Portion 237 as well as to rezone this extension to “Industrial 2”. The plant site would then be referred to as Erf 189 of Leeuwkuil Ext 5. The current zoning of Portion 237 is agriculture. The area is earmarked for industrial expansion in the Emfuleni Local Municipality’s spatial development framework (SDF) 2017 – 2025. Local municipality Emfuleni Local Municipality in the Sedibeng District Municipality Centre coordinates of site: 26°39’741”S 27°54’473”E

4.1.3 Project timeline Should environmental authorisation be granted it is anticipated that construction of the facility would take approximately two years to complete. The intended timing is to start with detailed design and construction in second quarter 2019. The plant is expected to be operational by Year 2021. The minimum life of the plant would be for 20 years, however, the opportunity exists to extend this period.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

4.2 DESCRIPTION OF THE PROPOSD MAIZE WET MILL PLANT

4.2.1 Project phases The project will comprise two distinct phases, namely construction and operation. The decommissioning and closure phase is considered at a high level in order to understand the potential for residual impacts. a. Construction The key construction activities associated with the proposed project include:  site establishment including storm water controls;  clearing of vegetation in accordance with the vegetation management procedures;  stripping and stockpiling of soil resources and earthworks in accordance with soil management plan;  foundations and structures;  roads;  equipment, pipework and utilities installations;  transportation of construction phase materials and staff (via existing roads);  collection, storage and removal of construction related waste;  landscaping.

The construction phase facilities would include:  parking area for cars and equipment;  mobile site offices;  portable change houses and ablution facilities;  contractor’s laydown areas;  workshops and washbays;  stores for the storing and handling of fuel, lubricants, solvents, paints and construction materials;  construction waste collection and storage facilities;  temporary electricity supply (diesel generators);  portable water supply (bowsers);  portable diesel supply (bowsers);  soil stockpiles;  water management infrastructure;  security and access control.

Activities are expected to take place 24 hours a day for seven days a week. Construction facilities would be removed at the end of the construction phase (unless incorporated into the operational phase facilities). b. Operations The key operational activities associated with the proposed project include:  arrival and departure of personnel (in shifts);  delivery of raw materials and other supplies by truck and removal of waste by truck;  storage of incoming materials;  maize preparation, milling and refinery;  final product and by-product storage and transportation;  associated services and support activities.

The main facilities would include:  corn off-loading, cleaning and storage silos;  steeping, milling and drying area;  by-product load out area;  refinery plant, tank farm and load out area;  chemical intake and storage tanks;  warehouses and spent carbon storage area;

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

 boiler house (including coal storage and coal dosing area)  access, weigh-bridges and guard houses;  internal roads;  offices and administration block (including canteen and parking areas);  workshops and truck wash;  reverse osmosis plant (for water supply);  waste water (industrial effluent) treatment plant;  service infrastructure (including switching station and underground cables from the Leeuwkuil substation, water supply pipeline, domestic sewer package plant and storm water facilities);  utilities (including water tanks, air compressors, cooling tower, transformers, fire control room, quality control room including laboratories).

The proposed facility would operate 24 hrs a day, with 4 x 8 hour continuous shifts to allow for a changeover of shifts without interrupting the processing operations.

A schematic representation of the proposed maize wet mill plant and conceptual site layout is provided in Figure 4-1 and Figure 4-2, respectively. The plant and related services are located outside of any 1:100 year flood lines. c. Decommissioning and Closure Although the life of the plant and its infrastructure has been designed for a 20-year operational life as assessed in this report, with scheduled maintenance and ongoing equipment replacement/upgrades, it is likely the plant would operate for for a significantly longer period. The duration of operations would ultimately be subject to industry and market economy drivers. Given that the plant is likely to operate for many decades, a specific decommissioning and closure plan has not yet been developed.

At the time when the facility is decommissioned and closed the local environment and regulatory context would likely have changed significantly from the current state. Future use of the site has not been considered, but given the location it is unlikely to be anything other than commercial or industrial use. It is therefore not currently reasonable or feasible to undertake a comprehensive assessment of the decommissioning and closure related impacts.

At least two years prior to the planned closure of the facility, the owner should develop a plan for decommissioning and closure. Closure planning should be undertaken in terms of the regulatory framework relevant at the time, with cognisance of the local environmental conditions and planned land uses. To ensure management of environmental impacts, the decommissioning plan should (depending on the future use) consider the following broad objectives:  making the facility safe;  removal of any excess materials and products;  dismantling of the equipment;  sale and final disposal of all components;  decontamination of any contaminated areas;  final disposal of wastes; and  rehabilitation of the site to a condition suitable for an end land use.

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Product Storage Processing Plant and Loading

Warehouse Offices and Support Services and Administration Facilities

By-product Storage and Loading Coal Storage and Boilers Raw Material Off-loading and Storage Silos

(3D Schematic provided by Plant Design Team (Cemsan)) FIGURE 4-1: SCHEMATIC REPRESENTATION OF THE PROPOSED MAIZE WET MILL PLANT Legend

(! Schools .! Project -Specific Boreholes Main Roads Water Supply Pipeline Project Site Low (Transformed) Secondary Grassland

1 1:100yr Floodline Bh1 2 .! 12 Ac 11 ces 3 10 13 s R 4 6 7 14 KEY: oa 9 d 5 01 Warehouse 16 8 15 28 02 Spend Carbon Area 17 25 26 03 Refinery Product & By Product Weigh Bridge (! 21 13 22 04 Water Tank 29 18 27 05 Compressor 20 30 23 24 06 Cooling Tower 19 07 Truck Wash 31 08 Refinery Load Out 33 35 34 32 09 Tank Farm 36 10 Maltose Area 11 Chemical & ServiceTanks 38 (! 37 12 Canteen 39 Bh2 13 Garden .! 14 Refinery Future Expansion Area 15 Fructose Area 16 Coal Weigh Bridge 40 17 Corn Weigh Bridge 18 Coal Dosing Area 19 Coal Storage Area 20 By ProductLoadout 21 Drier Area 22 Wet Mill Area 23 CSLEvap Area 24 Steep Area 25 Control Room 26 Transformer 27 Wet Mill Future Expansion Area 28 Main Offices 29 Maintenance Workshop 30 Maintenance Warehouse 31 Brocken Corn Load Out 32 Corn Truck Intake (! 33 Corn Cleaning 34 Corn Storage Silos 35 Switch Station 36 Sewage Package Plant 37 Attenuation Pond 38 Future Expansion 39 Waste Water Treatment 40 Existing Substation (! PROPOSED MAIZE WET MILL PLANT

Figure 4-2

(! Meters Conceptual Layout of the proposed 0115 230 460 wet mill plant

Scale: 1 : 8 500 @ A4 SLR Consulting (Africa) (Pty) Ltd P O Box 1596, Cramerview, 2060, South Africa Projection:Transverse Mercator WG27 Tel: +27 (11) 467-0945 Fax: +27 (11) 467-0978 Datum: WGS84 Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community 720.19124.00001 October 2018 Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

4.2.2 Maize wet mill processing The proposed plant’s primary raw material would be non-GMO maize. The plant would process a maximum of 2 000 tons per day of non-GMO maize which would be cleaned, steeped, ground and refined to produce approximately 1 710 tons of glucose and starch products as well as various by-products. The glucose and starch products would be used as ingredients in the manufacturing of beverage and food products. The by- products (fibre, gluten, and germ) would typically be sold as animal feed or for use in the paper and textile industries.

The proposed maize wet milling process is illustrated conceptually in Figure 4-3 below and described in further detail in Table 4-3.

FIGURE 4-3: CONCEPTUAL PROCESS FLOW DIAGRAM OF THE PROPOSED MAIZE WET MILLING PROCESS

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

TABLE 4-3: OVERVIEW OF MAIZE WET MILLING PROCESS Activity Description Inputs Wastes Product Transportation Raw materials would be transported to site via trucks, which would pass over weigh- Maize (in silos) Packaging - and storage of bridges before off-loading materials at designated storage areas. Coal (in enclosed coal Spillages incoming raw storage area) (contained) materials Activated carbon (in a warehouse) Plant process materials (in service tanks) Maize Intake Prior to processing, the corn would be mechanically cleaned to remove dust, broken Maize Cobs, husks, - and Preparation corn and foreign materials. Water containing sodium stones, etc In order to soften the kernels and separate the hull, germ and fibre from each other, metabisulphite Air emissions (from the cleaned corn would then be steeped for 32 to 36 hours in 50 degrees Celsius Steam (produced by boilers) water containing sodium metabisulphite. The steep water would be heated by means boilers) of five boilers which would provide the required steam demand. Natural gas is being proposed as an alternative fuel source for the boilers and would be considered should it prove feasible and sustainable, given the current national gas supply capacity constraints. Milling The steeped water would then be drained off and the maize coarsely ground in de- Softened maize kernels Steeped effluent Corn oil (by- germ mills to free the germ from the grain. The germ would then be separated, dried Heat (for drying – and slurry washing product) and corn oil would be extracted as a by-product. produced by the coal-fired effluent (treated in Germ meal (by- The maize would then be ground in attrition mills, with germ meal remaining as a by- boilers) on-site waste water product) product. Following germ separation, the slurry would be washed, ground and Water treatment plant) Fibre (by-product) screened to separate the starch and gluten from fibrous material. The fibre would Air emissions Gluten (by- then be extracted as a by-product. The starch and gluten would then pass through a product) centrifugation process whereby gluten would be removed and dried as a by-product. Refinery The starch would then be processed in the refinery where starch conversion would Starch Spent carbon Starches take place through the addition of enzymes and activated carbon to produce final Enzymes Glucose products. Activated carbon Final product The final products and by-products would be stored in silos and then be loaded and - - - and by-product trucked to the respective customers. transportation

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

4.2.3 Associated services and support facilities Services required to support the construction and operation of the plant are outlined in the sections below. a. Access and transport The site would be accessed via the Sybrand van Niekerk Freeway (R59) and Boy Louw Street (R58) (Figure 1-2). Access to the plant would be via the existing Stout Close, off Lager Road (Figure 4-4). As part of the town planning application, the following road upgrades are proposed:  Stout Close would be controlled by a priority side stop with traffic on the Lager Road, having the right of way.  The width of Lager Road from Pilsner Stout (at the SAB Depot) leading to Stout Close would be widened to at least 7m to accommodate heavy vehicles.  Two taxi drop-off facilities would be established along Boy Louw Street (R28) on the upstream and downstream of the intersection of Boy Louw Street (R28) and Lager Road.

Internal roads would be established to allow for efficient movement of vehicles within the plant. These roads would be surfaced.

Transport of construction workers and operational personnel would be by car, taxi and bus. Transport of raw materials to and products from the facility would be by truck. An indication of the expected traffic volumes is provided in Table 4-4 below. Project traffic would make use of the existing R59, R28, Lager Avenue and Stout Close.

TABLE 4-4: EXPECTED TRAFFIC VOLUMES Construction Operations Item Mode of transport Return trips* Mode of transport Return trips* Equipment and machinery TLBs, graders, 24 per day - - excavators, rollers, tipper trucks, water carts Consumables, materials and Trucks, vans 8 per day Trucks, vans 4 per day solid waste Raw materials (maize and coal) - - 30 and 35 ton 136 per day trucks Product - - 32 ton trucks 96 per day By-products - - 30 ton trucks 36 per day * Return trips = trip in + trip out. b. Water supply and use Water would be required during the construction phase for domestic use, dust suppression, concrete mixing, washing vehicles and equipment, fire-fighting, earthworks and landscape irrigation.

During the operational phase water would be required for domestic use, maintenance activities, utilities, fire- fighting, milling and refining and landscape irrigation. An indication of the expected water requirements is provided in Table 4-4 below.

TABLE 4-5: EXPECTED WATER REQUIREMENTS Average volume per day Use Construction Operations Domestic use 40 m3 (at peak) 10,5 m3 Construction use 300 m3 (at peak) - Plant use - 10 140 m3

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PROJECT SITE

A. Site access road (Stout Close, off Lager Road) B. Theunis Kruger Street-Boy Louw Street intersection

TO PROJECT SITE

LAGER ROAD

C. Boy Louw Street-Lager Road intersection (Sourced from traffic specialist study)

FIGURE 4-4: ACCESS TO THE PLANT INCLUDING PROPOSED UPGRADES Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

Water would be sourced from Rand Water via the Emfuleni Local Municipality. A pipeline from the De Villiers Avenue Rand Water connection point would be established to provide water to the plant (see Figure 4-2). During construction water may be brought to site via portable bowsers until such time as the pipeline has been established. A service agreement would be put in place with the municipality once a supply agreement has been concluded.

Water required for the food processing component would need to be treated in an onsite reverse osmosis (RO) or ultrafiltration water treatment plant prior to use to ensure suitable water quality for the process. Rejects from the treatment plant would be processed at the effluent waste water treatment plant.

A network of pipelines would be required to distribute water within the plant site.

Water would be stored in above-ground storage tanks (with a 12 hr storage capacity – 5 000 m3). In addition on-site fire water storage would make provision for 50 l/s supply for 4 hours (720 m3).

A summary of the water balance is presented below:  Water supplied = 422,5 m3/hr  Water losses (within the system) = 186,5 m3/hr  Waste water (to be treated) = 235,5 m3/hr. c. Electrical power During the construction phase, temporary electricity supply would be sourced from on-site diesel generators. Power requirements would be less than that needed for the operational phase.

Permanent electrical power would be sourced from the Emfuleni Local Municipality. The electrical supply would be via an 11 kV underground cable connection from the Eskom substation located just west of the R59 (Figure 4-2). The substation would be upgraded to cater for the project. The maximum demand would be 15 MVA (15 MW). Within the plant a substation and transformer would provide stepdown to 400 V.

Diesel generators would be available for backup and emergency supply. d. Steam generation Heat is required to generate steam and for drying of process materials. A boiler house comprising eight boilers (five in use and three on stand-by) is planned for the project. The boiler house would be located in an enclosed building. Where coal is used to fire the boilers the boiler house would include coal storage and coal dosing areas. Each boiler would then use 63 tons of coal/day to meet a steam demand of 110 tons/hour.

Natural gas is being proposed as an alternative fuel source for the boilers and would be considered should it prove feasible and sustainable, given the current national gas supply capacity constraints. e. Storm water A conceptual storm water management plan was developed for the site by SCIP Engineering. This has been incorporated into the surface water specialist report (Appendix 5). The plan was compiled to facilitate the route planning and locating of storm water drainage system elements in relation to the proposed layout of the plant and the physical characteristics of the site.

Storm water generated up-gradient of the project site would be diverted by a perimeter cut-off drain and would channel water into the open area, east of the project site. This storm water would ultimately feed into an existing concrete lined storm water channel on the eastern side of the site along the R59. This existing channel conveys surface water under the R28 to the Vaal Tributary, 1km south of the project site (Figure 4-2).

Storm water generated within the plant would be collected and managed on the ground surface, where after an underground piped drainage system would convey accumulated run-off from each catchment area within

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

the plant to a new attenuation pond. The drainage system would cater for the 1:5 year return period storm. The capacity required for the attenuation pond to cater for storm water runoff from the plant site would be 11 500 m3 (catering for a 1:25 year post-development flood). After attenuating the storm water, it would be discharged into the existing concrete lined channel which would take the storm water through the culvert under the R28 towards the Vaal Tributary. The storm water management system would be designed to meet the design standards of the Emfuleni Local Municipality. f. Domestic sewer Portable toilets and temporary ablution facilities would be utilised during the construction phase. Portable toilets would be serviced by external service providers on a regular basis.

During the operational phase, domestic sewage would be pumped to an on-site sewage package plant with a treatment capacity of 2.5 kl/d. It is planned to establish a bio-reactor treatment system. The treatment process and plant would be comprised of the following:  Collection under gravity through a stilling well situated within a multi-configured pre-digester;  Sewage then enters the digester through an energy dissipater – the digester is designed to provide a hydraulic residence period of 12 hours to two days where biological activity is achieved through anaerobic processes;  From the digester, the supernatant is conveyed to a chemical and hydraulic equalisation environment to minimise temporal variability in the aerobic component of the treatment process;  Aerobic conditions occur in a bio-reactor which is a submerged fixed media environment designed for a specific hydraulic residence, rise rate and specific cod loading rate;  Carbonaceous degradation and nitrification is achieved through the controlled input of dissolved oxygen  Final clean water discharge from the bio-reactor into a disinfection chamber for biocidal treatment and discharge.

The tanks would either be placed above or below ground depending on the ground conditions. A maximum tank footprint size of 50 m2 is envisaged.

A conservancy tank would be established for times of maintenance. Treated effluent would be discharged into the environment via the existing drainage channel to the east of the site (see Point i below). g. Solid waste The types of waste that could be generated during the construction and operational phases include general domestic, non-hazardous waste (packaging, office waste), general industrial, non-hazardous waste, scrap metal and machinery/vehicle parts, material off cuts, used packaging, building rubble and redundant concrete, chemicals/chemical contaminated containers and material, used oil and lubricants, contaminated soil from accidental spills, coal ash, spent activated carbon, medical waste (such as swabs, bandages), sewage (from portable toilets) and sludge from the sewer package plant and sludge from waste water treatment plant.

The waste management practises for the project, including the method for handling and storage of the wastes, are included in the EMP (see Section 8, Table 8-4). The plant would temporarily store approximately 210 m3 of coal ash for removal from site. For all other waste it is estimated that less than 20m3 of general waste and less than 35m3 of other hazardous waste would be generated per day by the project.

No on-site landfill (waste disposal) facilities are planned. h. Industrial effluent An on-site waste water treatment plant would treat effluent produced by the maize wet mill process and support facilities. The plant would receive effluent waste from the evaporator, wet mill scrubber, cooling tower blow down, spillages within the plant, water treatment plant reject (if this is passed to the treatment

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

plant), the refinery and truck wash. Any coal spillages in the boiler house would be contained within the boiler house.

The treatment plant would have the capacity to treat approximately 5 652 m3/day. It is anticipated that the plant would include:  Solids filter;  Calamity tank;  Settling tank;  Equalization tank;  Anaerobic digester;  Aerobic digester;  Clarifier.

The effluent would be treated to meet the same discharge limits provided for in the Leeuwkuil water use license. Treated effluent would be re-used in non-food related processes as far as possible. All other treated effluent would either be discharged to the environment via a discharge channel or alternative feasible uses identified.

Informed by the discharge rates and project local topography, a conceptual design of the channel to discharge effluent and storm water from the site to the existing channel is provided below (Table 4-6). The channel was sized using the Manning’s equation to ensure that the flow capacity of the channel is able to convey a maximum discharge flow of 6,6 m3/s during extreme storm events.

A conceptual design of the effluent and storm water discharge channel was based on calculated discharge rates and topography (details are provided in Table 4-6) The channel was sized using the Manning’s equation to ensure that the flow capacity of the channel is able to convey a maximum discharge flow of 6.6 m3/s during extreme storm events.

TABLE 4-6: DISCHARGE CHANNEL DESIGN CHARACTERISTICS

Components Design characteristics Channel Shape Trapezoidal Design flow 6,6 m3/s Left side slope 2 m Normal depth 1 m Right side slope 2 m Bottom width 2,5 m Channel Slope 0,002 m/m Roughness Coefficient (n) 0,015 s/m1/3 Top width 3,5 m Flow Area 3 m2 Wetted Perimeter 4,736 m Hydraulic Radius 0,4 m Velocity 2,2 m Flow Type Subcritical m3/s

In addition to the above, the channel would be:  lined with low permeability material or concrete lined to be able to resist erosion;  sloped to allow for uniform flow away from the site as much as is possible, and prevent any backwater effects at the project site  control velocity at the outlet to prevent channel degradation and erosion.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

i. Storage and handling of process materials A number of process materials require storage on site. Some of these materials are considered to be dangerous goods. The combined capacity of dangerous goods stored on site would be less than 500 m3. Materials requiring storage on site together with the proposed storage method are outlined in Table 4-7.

TABLE 4-7: EXPECTED STORAGE AND HANDLING OF PROCESS MATERIALS Substance Storage method Corn Cool, dry – In silos Meta biSulphite Cool, dry – In bags Hydrochloric acid Liquid – In storage tank(s) Caustic soda Liquid – In storage tank(s) Virgin Activated Carbon Cool, dry – In bags Enzymes (Alpha Amylase, GlucoAmylase, Isomeraze) Well sealed containment – In plastic containers CationicResin Cool, dry – In bags AnionicResin Cool, dry – In bags Chromotographic Resin Cool, dry – In bags

Magnesium (as 100% MgSO4 form) Cool, dry – In bags OR Liquid – In storage tank(s) Filter Aid Cool, dry – In bags Fuel Storage tanks

All dangerous goods would be stored in bunded areas on impervious floors with a capacity to contain 110% of a spill. Emergency spill kits would be used to clean up spills outside of bunded areas. j. Security and access control The site will include a formal site boundary with 24 hr access and security control provided at the entrance on Stout Close.

4.2.4 Employment The proposed project is anticipated to generate approximately 800 jobs (at peak) during the construction phase. Operation of the facility would create approximately 210 employment opportunities with 50 employees per 8 hour shift. Employees would be sourced, as much as is possible, from local communities and the greater Vereeniging area.

During construction the proposed project is anticipated to generate approximately 800 jobs (at peak). Operation of the facility would create approximately 210 employment opportunities; 50 employees per 8 hour shift. Employees would be sourced, as much as is possible, from local communities and the greater Vereeniging area.

4.3 CONSIDERATION OF ALTERNATIVES The consideration of alternatives and how they are considered are described in Table 4-8 below.

TABLE 4-8: PROJECT ALTERNATIVES CONSIDERED No. Alternatives Description 1. Property or Locality alternatives 1.1 Property and Vereeniging was selected as the target area for the proposed project as it is an area with good location on regional transport linkages and has the required services and infrastructure. The pre-feasibility site phase confirmed the availability of basic services to the facility. Sedibeng and Emfuleni municipalities require economic stimulation and would benefit from a project of this magnitude. Local and regional planning documents indicate that there are a number of areas identified for commercial and industrial development/expansion. Consideration was given to commercial, logistical, environmental, social and technical factors

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No. Alternatives Description during the pre-feasibility. Erf 188 and a portion of Portion 237 were selected as the preferred site for the proposed plant and no fatal flaws were noted. In proposing the plant layout consideration was given to a number of local features, adjacent land users and access, operational efficiency, geotechnical and hydrological parameters. The preferred plant layout as presented was significantly influenced by adjacent land uses and potential geotechnical constraints. Only the preferred site and layout have been assessed in the BAR. 2. Design alternatives 2.1 Boiler fuel Coal and gas have been considered as fuel types for the boilers. Given the current national gas supply capacity constraints, coal has been included and assessed in this report. Should it prove feasible and sustainable natural gas would be considered in the future as an alternative fuel source for the boilers. 3. Utilities alternatives 3.1 Effluent The Emfuleni Leeuwkuil water care works was considered for the treatment of domestic and treatment industrial effluent from the project site. The water care works is significantly under capacity and therefore alternative solutions were considered by the project civil design team. The most feasible options for the project are to establish an on-site sewage package plant and on-site industrial effluent waste water treatment plant. These have been assessed in the BAR. 3.2 Power supply The main power supply for the plant will be Eskom; this is due to the reasonably substantial power demand of the project. Alternative power sources for domestic power requirements such as solar panels and/or solar water geysers will be considered as part of the detailed design. 3.3 Water supply Water will be sourced from Rand Water via Emfuleni Local Municipality. A large volume of water is required for the food processing plant. Borehole abstraction was considered as an alternative supply option however, due to the presence of dolomites on site extracting groundwater from them could present a potentially significant risk to the overall plant stability. 4. “No-Go” alternative 4.1 No-go The No-Go alternative represents the option not to proceed with the proposed maize wet mill project. The assessment of this option requires a comparison between the options of proceeding with the project with that of not proceeding with the project. Proceeding with the project attracts potential transformation and economic benefits and potential negative environmental and social impacts. Not proceeding with the project retains the status quo, but with potential loss in transformation and employment opportunities and revenue generation and related social benefits, which could potentially be generated by the development. As the land in question is earmarked for industrial development it is thus possible for another development to be established should the wet maize mill project not proceed. The benefits from such an alternative development may less, depending on the nature of alternative. There is no mitigation option available to the proponent to avoid the “no-go” alternative, as proceeding with the development is at the discretion of the decision-makers. From an economic perspective, the project will contribute positively towards the local, regional and national economy through its capital investment, transformation imperatives, creation of employment opportunities and revenue generation potential. This contribution will be far greater than the current status quo. The project furthermore has the potential to create opportunities for supplier and enterprise development. Implementing management measures and commitments as outlined in the EMP will ensure that the project is executed within the framework of sustainable development, which will ensure that potential negative impacts are minimised and positive impacts enhanced. For the purpose of this assessment, the status quo was considered in the unmitigated scenario in comparison to establishing the proposed development in the mitigated scenario.

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5 NEED AND DESIRABILITY The DEA guideline on need and desirability (GN R891, 20 October 2017) notes that while addressing the growth of the national economy through the implementation of various national policies and strategies, it is also essential that these policies take cognisance of strategic concerns such as climate change, food security, as well as the sustainability in supply of natural resources and the status of our ecosystem services. Thus, the over-arching framework for considering the need and desirability of development in general is taken at the policy level through the identification and promotion of activities / industries / developments required by civil society as a whole. The DEA guideline further notes that at a project level (as part of a BA process), the need and desirability of the project should take into consideration the content of regional and local plans, frameworks and strategies.

In light of the above, this section aims to provide an overview of the need and desirability of the proposed project by firstly, highlighting maize wet milling in the South African context and, secondly, how this industry is aligned with the strategic context of national development policy and planning, broader societal needs and regional and local planning, as appropriate.

5.1 NATIONAL POLICY AND PLANNING FRAMEWORK This section aims to provide an overview of the regional and local policy and planning context relating to the proposed maize wet mill plant.

5.1.1 National Development Plan 2030 The National Development Plan (NDP) 2030 provides the context for all growth in South Africa. The NDP provides a broad strategic framework, setting out an overarching approach to confronting poverty and inequality through the promotion of development, based on the six focused and interlinked priorities. One of the key priorities is “faster and more inclusive economic growth”. In order to transform the economy and create sustainable expansion for job creation, an average economic growth exceeding 5% per annum is required. The NDP sets out that transforming the economy also requires changing patterns of ownership and control.

It is also acknowledged that environmental challenges are in conflict with some of these development initiatives. As such, it is emphasised that there is also a need to:  protect the natural environment;  enhance the resilience of people and the economy to climate change;  reduce carbon emissions in line with international commitments;  make significant strides toward becoming a zero-waste economy; and  reduce greenhouse gas emissions and improve energy efficiency.

5.1.2 New Growth Path The New Growth Path (NGP) (2011) reflects the commitment of Government to prioritise employment creation in all economic policies and sets out the key drivers and sectors for employment which will be the focus of Government. The sectors identified for prioritisation include infrastructure, agriculture, mining, manufacturing, tourism and the green economy.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

5.1.3 Regional and Local Policy and Planning Framework This section aims to provide an overview of the regional and local policy and planning context relating to the proposed development.

Gauteng The Gauteng Provincial Spatial Development Framework 2030 (PSDF) sets out the key spatial challenges faced by the Province and the proposed spatial policies, which have been formulated to address these challenges. As such, it supports the spatial development vision to achieve the Gauteng of 2030, an integrated, connected space that provides for the needs of all who are born in or drawn to the province. Economic growth is spread widely, beyond the core areas, to nodes and multi-modal activity corridors. To realise the spatial development vision, all developments in the province need to adhere to six spatial development principles: (i) liveability, (ii) concentration, (iii) connectivity, (iv) conservation, (v) diversity, and (vi) viability.

Four interrelated spatial development strategies are to be followed: 1. Capitalising on proximity, by directing higher densities closer to economic nodes and public transport networks, and improving conditions in areas closer to economic opportunities, to ensure even greater benefits for the people and economy of these areas. 2. Managing new settlement development, to prioritise infill development and densification, rather than expanding residential development outwards, so new settlements are functional and integrated units of the polycentric provincial network and based not only on the availability of land. 3. Building an economic network, through a system of high-order nodes and activity corridors, developing economic clusters that benefit from synergies and unlock the advantages of agglomeration. 4. Creating a viable and productive hinterland, by protecting valuable resources and high potential agricultural land from harmful development, and managing water resources fugally and effectively.

To realise the specific provincial spatial, economic and social objectives, two instruments are proposed: (i) spatial development coordination; and (ii) spatial targeting. These two instruments will be used to coordinate government action, target public investment and crowd in private sector investment to achieve a balanced, polycentric provincial spatial network/form.

Sedibeng Integrated Development Plan and Spatial Development Framework The Local Government: Municipal Systems Act, (Act 32 of 2000) stipulates that all Municipalities are required to prepare an Integrated Development Plan and that a Spatial Development Framework (SDF) be a component of the IDP. The Spatial Planning and Land Use Management Act (SPLUMA) provides a framework for spatial planning and land use management and Chapter 4 addresses the preparation requirements and content of an SDF.

The Sedibeng District Municipality IDP (2017 to 2021) articulates the broad development approach for the district municipal area, within which the development planning for each local municipality is contextualised. The IDP aims to realize the NDP, the Gauteng Strategic Plan and the Sedibeng Growth and Development Strategy through its seven pillars being:  reinventing the economy;  renewing our communities;  reviving a sustainable environment;  reintegrating the region;  releasing human potential;  good governance; and  deepening democracy.

As such, it sets out the strategies and deliverables for each priority area as well as detailing sector plans and projects.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

The SDF developed by the SDM forms an integral element of the IDP. The SDF seeks to address numerous spatial and developmental challenges of the District, such as:  fragmented and dispersed settlement patterns;  dilapidated and minimal bulk services infrastructure;  high levels of unemployment;  lack of investment in developable land;  industrial decline;  non-functional public transport system;  lack of investment in the agriculture and tourism sectors respectively; and  environmental degradation and water challenges.

The SDF aims to inter alia promote the well-being of the people in the area by proposing development strategies that would promote sustainable development. The SDF notes that “the economy of the Sedibeng District is not performing well relative to other areas of Gauteng”. Various economic projects have been identified to address this. Of relevance in this case: “Establishing mechanisms that benefit owners and potential end users for releasing large parcels of potentially economically productive land for development”. The SDF notes that large amounts of developable land are vacant within the current Urban Development Boundaries.

The SDF has identified a precinct development plan for the Vereeniging Fresh Produce Market site. This aims to allow for its expansion and renovation, as well as for the accommodation of subsidiary businesses (e.g. wholesale). It is also makes provision for the creation of sites suitable for new commercial and light industrial developments, improvement of local accessibility and connectivity with the immediate surroundings.

Emfuleni Local Municipality The Emfuleni Local Municipality’s IDP (2017/18 – 2020/21) identifies industry and commercial projects as key economic activities. The Emfuleni Municipality’s SDF (2017) forms an integral component of the IDP. The SDF identifies the Leeuwkuil industrial area as a target for densification and indicates that vacant industrial stands within this industrial area should become occupied before additional land is made available for industrial and commercial development within Emfuleni. Leeuwkuil should be reserved for commercial and light industrial uses. Heavy industrial uses should be excluded from this development to avoid polluting uses next to the existing and proposed residential areas neighbouring this industrial area. The location of Leeuwkuil next to the R59 makes it suitable for commercial uses, which require access from major roads.

5.2 CONSISTENCY WITH POLICY AND PLANNING CONTEXT The previous sections have considered the policy and planning context at national, regional and local level, which are relevant to the proposed maize wet mill plant. As highlighted above, there is a drive from national and provincial Governments to stimulate development and grow the economy of South Africa with a strong focus on job creation in all sectors. Industry and agriculture have been identified as drivers of economic growth and job creation, and are furthermore considered particularly important in the Gauteng provincial economy.

The proposed project is considered to be consistent with and in support of the broad national policy framework for the development of industry and agriculture in South Africa. At the regional level, it is deemed consistent with the Gauteng PSDF and the SDF of Sedibeng and will contribute to the regional GDP. The proposed project would be located inside of the urban edge, where residential, commercial and industrial land uses are considered appropriate. At the local level the proposed maize wet mill plant will be located within the existing Leeuwkuil industrial area that is the target of increased density and compactness. The project will have local benefits through the provision of employment opportunities and stimulation of opportunities for local goods and service providers.

One of the major goals in developing the project is to create a unique opportunity for new Black economic entrant(s) in the manufacturing industry. The intention is that the proposed maize wet mill plant will be

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

majority Black Owned. The project will also contribute toward meeting the conditions imposed on Anheuser- Busch InBev SA/NV in its merger with SABMiller.

5.3 CONSISTENCY WITH NEMA PRINCIPLES The national environmental management principles contained in NEMA serve as a guide for the interpretation, administration and implementation of NEMA and the EIA Regulations. In order to demonstrate consistency with the NEMA principles, a discussion of how these principles are taken into account during the BA process is provided in Table 5-1 below.

TABLE 5-1: CONSIDERATION OF THE NEMA PRINCIPLES IN RELATION TO THE PROPOSED PROJECT National Environmental Management Principles Comment (2) Environmental management must place people and their needs Industry and agriculture has been identified as a key at the forefront of its concern, and serve their physical, driver of economic growth and job creation and as such psychological, developmental, cultural and social interests the proposed maize wet mill plant is anticipated to serve equitably. the developmental interests of people. The BA process also serves to identify the needs and interests of potentially affected parties and to address issues and concerns raised through the course of the study. (3) Development must be socially, environmentally and Government has set development goals aimed at economically sustainable. reducing poverty, unemployment and inequality. The contribution of the industry and agricultural sectors in this regard is promoted in the national, regional and local policy and planning frameworks, thus the proposed development is deemed acceptable in principle. The specific sustainability of the proposed project has been assessed in the BA process. (4)(a) Sustainable development requires the consideration of all The BA process considers potential social, economic, relevant factors including the following: biophysical impacts that could result through the (i) That the disturbance of ecosystems and loss of biological implementation of the proposed maize wet mill plant. diversity are avoided, or, where they cannot be altogether Measures have been identified to avoid, minimise avoided, are minimised and remedied; and/or remedy potential pollution and/or degradation of (ii) that pollution and degradation of the environment are the environment that may occur as a result of the avoided, or, where they cannot be altogether avoided, are proposed project. minimised and remedied; (iii) that the disturbance of landscapes and sites that constitute the nation’s cultural heritage is avoided, or where it cannot be altogether avoided, is minimised and remedied; (iv) that waste is avoided, or where it cannot be altogether avoided, minimised and re-used or recycled where possible and otherwise disposed of in a responsible manner; (v) that the use and exploitation of non-renewable natural resources is responsible and equitable, and takes into account the consequences of the depletion of the resource; (vi) that the development, use and exploitation of renewable resources and the ecosystems of which they are part do not exceed the level beyond which their integrity is jeopardised; (4)(a)(vii) that a risk-averse and cautious approach is applied, Assumptions, uncertainties and limitations associated which takes into account the limits of current knowledge about the with the compilation of the BA Report are discussed in consequences of decisions and actions; and Section 3.3. Compliance with the various legislative requirements is presented in Section 2. (4)(a)(viii) that negative impacts on the environment and on The BA process considers and assesses the identified people’s environmental rights be anticipated and prevented, and potential social, economic and biophysical impacts of the where they cannot be altogether prevented, are minimised and project (refer to Section 7). The EMPr provides the remedied. recommended management measures to mitigate the significance of identified impacts (refer to Section 8). (4)(b) Environmental management must be integrated, The BA process that is being followed recognises that all acknowledging that all elements of the environment are linked and elements of the environment are linked and

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National Environmental Management Principles Comment interrelated, and it must take into account the effects of decisions interrelated. GDARD, as the decision-making authority, on all aspects of the environment and all people in the will be responsible for taking all aspects of the environment by pursuing the selection of the best practicable environment, including whether or not the potential environmental option. impacts of the project would unfairly discriminate (4)(c) Environmental justice must be pursued so that adverse against any person, into consideration when making a environmental impacts shall not be distributed in such a manner as decision regarding the proposed project. to unfairly discriminate against any person, particularly vulnerable and disadvantaged persons. (4)(d) Equitable access to environmental resources, benefits and The proposed maize wet mill plant is not anticipated to services to meet basic human needs and ensure human well-being limit access to environmental resources that meet basic must be pursued and special measures may be taken to ensure human needs. access thereto by categories of persons disadvantaged by unfair discrimination. (4)(e) Responsibility for the environmental health and safety The applicant is committed to comply with consequences of a policy, programme, project, product, process, environmental health and safety consequences of its service or activity exists throughout its life cycle. existing operation and will continue to do so in relation to the proposed glass bottle manufacturing plant. (4)(f) The participation of all interested and affected parties in The public participation process has been undertaken in environmental governance must be promoted, and all people must accordance with the requirements of the EIA Regulations have the opportunity to develop the understanding, skills and 2014 (see Section 3.4.3). capacity necessary for achieving equitable and effective participation, and participation by vulnerable and disadvantaged persons must be ensured. (4)(g) Decisions must take into account the interests, needs and The BA process will take into the account the interests, values of all interested and affected parties, and this includes needs and values of all I&APs, through the submission of recognizing all forms of knowledge, including traditional and comments on the proposed project. Thus, the decision- ordinary knowledge. makers will have all the necessary information before them on which to base an informed decision. (4)(h) Community wellbeing and empowerment must be promoted The BA Report prepared for the proposed project will be through environmental education, the raising of environmental made available to communities for review and comment awareness, the sharing of knowledge and experience and other (see Section 1.6). appropriate means. (4)(i) The social, economic and environmental impacts of activities, The BA process considers identified potential social, including disadvantages and benefits, must be considered, economic, biophysical impacts of the project in an assessed and evaluated, and decisions must be appropriate in the integrated manner. The significance of these impacts light of such consideration and assessment. has been assessed (see Section 7). (4)(j) The right of workers to refuse work that is harmful to human The owners and managers of the plant would be health or the environment and to be informed of dangers must be required to comply with the requirements of the respected and protected. Occupational Health and Safety Act. An Environmental Awareness Plan has been prepared, which will require staff be informed about any aspects of their work that may pose a danger to the environment (refer to Section 8). (4)(k) Decisions must be taken in an open and transparent manner, As mentioned previously, the public consultation process and access to information must be provided in accordance with the is being undertaken in accordance with the law. requirements of the EIA Regulations 2014 (as amended) and will allow for the distribution of the BA Report for public review and comment. This information will be provided in an open and transparent manner. (4)(l) There must be intergovernmental co-ordination and The public participation process for the proposed project harmonisation of policies, legislation and actions relating to the provides an opportunity for the Organs of State to environment. provide comment on the proposed project and address any potential conflicts between policies or other developmental proposals administered by them that may be in conflict with the proposed project before decision-making. (4)(m) Actual or potential conflicts of interest between organs of It is not anticipated that the proposed project would state should be resolved through conflict resolution procedures. result in any conflicts between organs of state. (4)(n) Global and international responsibilities relating to the GDARD, as the decision-making authority, will be environment must be discharged in the national interest. responsible for taking cognisance of any international obligations that could have an influence on the project.

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National Environmental Management Principles Comment (4)(o) The environment is held in public trust for the people, the The BA process considers and assesses the identified beneficial use of environmental resources must serve the public potential social, economic, biophysical impacts of the interest and the environment must be protected as the people’s project (refer to Section 7). common heritage. (4)(p) The costs of remedying pollution, environmental degradation The owners and managers of the plant will be and consequent adverse health effects and of preventing, responsible for the implementation of the measures controlling or minimizing further pollution, environmental damage included in the EMPr. or adverse health effects must be paid for by those responsible for harming the environment. (4)(q) The vital role of women and youth in environment The public participation process for the proposed project management and development must be recognised and their full has been and will continue to be inclusive of women and participation therein must be promoted. the youth. (4)(r) Sensitive, vulnerable, highly dynamic or stressed ecosystems, The BA process undertaken for the proposed project has such as coastal shores, estuaries, wetlands and similar systems identified relevant sensitive and/or vulnerable areas and require specific attention in management and planning assessed potential impacts if applicable. Appropriate procedures, especially where they are subject to significant human mitigation measures have been proposed where resource usage and development pressure. required.

5.4 SECURING ECOLOGICAL SUSTAINABLE DEVELOPMENT AND USE OF NATURAL RESOURCES The proposed maize wet mill plant requires non-GMO maize as a raw material which is then processed to produce a number of products and by-products. The only waste stream produced by the process is industrial effluent which is treated and re-used on-site as far as possible. The entire maize kernel is processed and used.

A full suite of detailed studies on the affected environment have been conducted for the proposed project. Key aspects are summarised in the relevant baseline sections. The nature of large industrial developments is such that impacts on biodiversity, habitats and ecosystem services are probable. To limit such impacts it is necessary to locate industrial developments at sites of low sensitivity. The proposed project site is located within an established industrial area that is located within the urban boundary of Emfuleni. The site has been impacted on by historical agriculture and current overgrazing and urbanisation. It does not contain any sensitive ecological features nor forms part of a system providing significant ecological services. Water for the project will be sourced from Rand Water via the Emfuleni Local Municipality and therefore no water will be abstracted from the site or from nearby water resources.

The findings of the specialist studies found that potential impacts associated with the proposed development can be mitigated to an acceptable level with the effective implementation of design control measures and mitigation measures. Specific mitigation measures are outlined in the EMPr (refer to Section 8).

5.5 PROMOTING JUSTIFIABLE ECONOMIC AND SOCIAL DEVELOPMENT Community/society priorities are officially expressed through public documents including the provincial and municipal growth and development strategy and spatial development framework documents. The Emfuleni Local Municipalities SDF 2025 identifies that Emfuleni requires approximately 700 ha of land for industrial and commercial development during the period 2017-2020 and an additional 240 ha during the period 2020-2025. The SDF 2025 aims to increase the density and compactness of the region by targeting development on appropriate parcels of land. In this regard the proposed maize wet mill site falls within an area defined in the SDF 2025 as an Industrial and Commercial Expansion Zone. The area is noted as being “an established industrial area, which is still largely vacant”. It is proposed in the SDF 2025 that the vacant industrial stands within this industrial area become occupied before additional land is made available for industrial and commercial development within Emfuleni. Leeuwkuil should be reserved for commercial and light industrial uses.

The social and economic specialist studies identified that the proposed project could benefit society and the surrounding communities both directly and indirectly by generating additional employment at the proposed

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operation and by stimulating the local economy, transformation through service and supply chain requirements. Direct economic benefits would be derived from wages, taxes and profits. Indirect economic benefits would be derived from the procurement of goods and services and the spending power of employees. Through employment, persons at the facility would also gain skills involved in the maize wet mill sector.

In addition to the direct and indirect economic impacts discussed above, the project through its corporate social investments and transformation imperative, would contribute towards the local economic development in the area. The operation of the plant is anticipated to have the following positive socio- economic benefits to its employees and surrounding communities:  development of skills through its skills development plan;  learnership programmes to provide learners with an occupational qualification;  investment in infrastructure development through local economic development and integrated development programmes; and  supplier and enterprise (SMME) development.

Alternative land uses for the property were considered by the specialist to be agriculture (and more specifically commercial maize farming which would yield the best economic results) or other commercial/industrial type developments. When considering maize farming (over the entire open area and not just the project site), the economic study has calculated that the economic benefits of the plant (over a 20 year period) are predicted to significantly outweigh the potential revenue of R2.3 million over 22 years that may be realised from commercial farming. Given that the proposed project is an industrial type activity that aligns with the municipalities SDF, no alternative industrial activities were assessed (Mercury Financial Consultants, 2018).

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

6 DESCRIPTION OF THE AFFECTED ENVIRONMENT This chapter provides baseline information on relevant environmental (geographical, physical, biological, social, economic, heritage and cultural) aspects associated with the project site and has been informed by specialist studies undertaken as part of the BA process. Specialist reports are included as appendices to this report.

To provide a visual context of the project site, photographs reflecting the pre-development status of the site (taken in August 2018) are presented below (Photo Plate 6-1).

This baseline chapter should be read with reference to Figure 6-1 and Figure 6-2.

Photo 1: Looking north (site in the foreground) Photo 2: Looking south across the site

Photo 3: Looking east across the site Photo 4: Looking west across the site

Photo 5: Proposed access point (Stout Close)

PHOTO PLATE 6-1: PHOTOGRAPHS REFLECTING THE CURRENT STATUS OF THE PROJECT SITE

6-1

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!! SLR Consulting (Africa) (Pty) Ltd P O Box 1596, Cramerview, 2060, South Africa

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!! 720.19124.00001 October 2018

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! ! ! ! ! Limpopo Unitas Park ± Steel Park North West Gauteng Mpumalanga Duncanville ^

R54 Free State KwaZulu-Natal Legend Land Use Proposed Site R59 (! Place Names Suuply Water Pipeline 26 Main Roads Land Use 90 Railways 104 Cemetery ! Powerlines Leeuwkuil 92 161 Commercial Areas Gas Pipeline Correctional Services 93 134 91 Tributaries Correctional Services Staff Accomodation 86 River Industrial Areas 26/596 94 SDF Informal livestock fair grounds Adjacent Properties 186 Leeuhof Leeuwkuil water care works Project Site School, Pre-School, Hostel and Sports Ground 26/596 RE/237 Substation Urban Areas with Residencial and Commercial Uses 61 26/596 Grazing 1/238 RE/238 Historical Asphalt Storage Yard

26/596 Kilometers R28 Vereeniging 26/596 0 0.25 0.5 1 Scale: 1:40 000 Projection:Transverse Mercator WG27 Leeuwkuil Watercare Datum: WGS84 Works Discharge Point R kj E I V I PROPOSED MAIZE WET MILL PLANT R Sharpeville L A A V

Figure 6-2: Service Layer Credits: Source: Esri, Leeuwkuil Dam DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, Land Uses of the Study Area IGN, and the GIS User Community

R42 SLR Consulting (Africa) (Pty) Ltd P O Box 1596, Cramerview, 2060, South Africa Tel: +27 (11) 467-0945 Fax: +27 (11) 467-0978

720.19124.00001 October 2018 Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

6.1 BIOPHYSICAL

6.1.1 Climate The project area falls within the Highveld climatic zone, which is generally associated with a cool temperate climate with high extremes between maximum summer and winter temperatures. The area is characterised by summer rainfall with a mean annual precipitation of 662 mm. The area is prone to frost. a. Rainfall and evaporation Rainfall data was sourced from the nearest Department of Water and Sanitation (DWS) managed rain gauge station, Vaalplaats, and from the Water Resources of South Africa manual (WR2012). The adopted mean annual precipitation (MAP) for the project area is 659.2 mm (obtained by calculating the average rainfall of the three rain gauges) (Table 6-1). Most rainfall occurs during summer. Examination of the daily rainfall records for Vaalplaats indicates that while the mean annual precipitation (MAP) is fairly low, there has been significant rainfall on occasions (up to 54% of MAP in 30 days and 80% of MAP in 60 days) (SLR, 2018b).

Average monthly evaporation sourced from the Vaalplaats station indicates an annual evaporation of 1 259 mm (Table 6-1). From the data it is clear that evaporation far exceeds rainfall (SLR, 2018b).

TABLE 6-1: MONTHLY RAINFALL AND EVAPORATION DATA

Month Rainfall (in mm) Evaporation (in mm) Vaalplaats 438734 W 438550 W Average Vaalplaats - S-Pan Vaalplaats - Open Water January 122.1 69.7 64.2 85.3 178.8 150.2 February 92.3 95.5 95.4 94.4 147.1 129.4 March 80.3 101.0 105.1 95.5 135.7 119.4 April 50.9 98.3 122.4 90.5 102.2 89.9 May 21.1 81.0 74.7 58.9 78.4 68.2 June 8 75.6 73.1 52.2 59.2 50.3 July 7.2 41.9 54.2 34.4 64.8 53.8 August 9.9 18.4 19.5 16.0 92.5 74.9 September 23.1 6.9 7.5 12.5 129.1 104.6 October 72.6 5.6 6.5 28.2 161.3 130.7 November 100.3 7.6 7.4 38.4 168.6 138.3 December 115.1 22.5 20.8 52.8 180.1 149.5 Total 702.9 624.1 650.8 659.2 1497.8 1259.2 b. Wind Wind data for the period 2014 to 2016 sourced from the Sharpeville air quality monitoring station (AQMS), located 4.5 km south west of the project site, shows that the period wind flow is dominated by north-westerly winds, followed by winds from the north-east (Figure 6-3). Calm conditions occurred 8.5% of the period. Day- time winds were more frequently higher than 5 m/s, and predominantly from the west and north-west. Night- time (18:00 to 05:00) showed more calm conditions (12.7%) with winds equally dominant from the north-east and north-west.

The seasonal wind field shows winds from the north-east and north-west during autumn and winter with winds from the north-east more dominant during summer. Spring-time winds show a predominance of north- westerly winds with the winds more frequently above 5 m/s (Figure 6-4). Winter has the highest frequency of calms at 14%, while spring shows the lowest frequency of calm conditions (3.9%) (Airshed Planning Professionals, 2018a).

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(Sourced from air quality specialist study) FIGURE 6-3: PERIOD, DAY- AND NIGHTTIME WIND ROSES FOR SHARPEVILLE AIR QUALITY MONITORING STATION (2014 TO 2016)

(Sourced from air quality specialist study) FIGURE 6-4: SEASONAL WIND ROSES FOR SHARPEVILLE AIR QUALITY MONITORING STATION (2014 TO 2016) Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

c. Air temperature Monthly temperatures statistics for hourly data recorded at the Sharpeville AQMS (2013 to 2015) show that minimum temperatures can drop below 0°C between June and September, while maximum temperatures exceed 30°C between August and April (Table 6-2). The period reported for the Sharpeville AQMS is within the range of the long-term average for the area; however, the maximum for Sharpeville (39.1°C) is higher than the long-term average. While elevated air temperatures can assist with pollutant dispersion, heat waves (area average is 4 heat waves per year) can be associated with periods of poor dispersion. Similarly, cold temperatures in winter are generally associated with near-surface inversion layers and poor dispersion conditions (Airshed Planning Professionals, 2018a).

TABLE 6-2: TEMPERATURE FROM THE SHARPEVILLE AQMS

Month of Year Long-term Temperature (a) Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec (1950 – 2000) Minimum 8.2 3.0 7.0 1.1 -1.7 -5.7 -5.0 -3.8 -1.2 2.9 5.9 9.1 -6.4 Average 21.8 21.7 20.0 17.1 13.9 10.8 10.4 13.8 18.5 20.2 20.9 21.7 16.8 Maximum 39.1 34.6 33.2 31.7 29.1 26.4 24.6 30.4 32.7 35.3 36.4 36.7 35.9 Notes: Schulze et al. (2008)

6.1.2 Topography The project site lies at an elevation of between 1 440 and 1 460 m above mean sea level. The site is flat with a slight fall to the south east (Figure 6-1) (SLR, 2018b). No distinct topographical features occur on or surrounding the site.

6.1.3 Surface water a. Catchment The project site falls within the Upper Vaal Water Management Area 8 (WRC, 2012) and quaternary catchment C22F. The quaternary catchment has an area of 440 km2 and a mean annual runoff of 9.91 million m3. The site is located centrally in the northern part of the quaternary catchment (SLR, 2018b). b. Freshwater resources No natural freshwater resources (including watercourses or wetlands) occur on or within 500 m of the proposed plant site (see Section 6.1.6). The unnamed tributary of the Vaal River is the nearest freshwater resource to the project site, located approximately 850 m south west of the project site. Further south is the Leeuwkuil dam, located approximately 2 km south west of the project site (Figure 6-1). c. Drainage systems Runoff from the project site is via sheet flow which subsequently drains into a formal (municipal) concrete- lined storm water drainage channel associated with the R59 (Figure 6-1). This channel receives storm water from the project site and the R59 highway, and lies at an elevation slightly below the project site. The channel drains south before joining the R58 channel at a point approximately 650 m south of the site. At this point it flows under the R28, via a culvert, to join an unnamed tributary of the Vaal River. The unnamed Vaal tributary flows east and then south in a concrete-lined channel (Photo Plate 6-2). The unnamed tributary feeds into the Vaal River approximately 4 km downstream of the project site (SLR, 2018b).

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

R28 drainage channel close to the confluence with R59 Confluence of the R59 and R28 channels flowing drainage channel underneath the R28 Road

Vaal tributary upstream of the confluence Concrete lined Vaal tributary downstream of the confluence

PHOTO PLATE 6-2: PHOTOS SHOWING DRAINAGE FEATURES ASSOCIATED WITH THE PROJECT AREA c. Flood lines Flood lines catering for the 1:50 and 1:100 year storm events have been determined for the unnamed Vaal tributary. Flood lines indicate that high water levels during a flood event within the unnamed Vaal tributary would cause backwater effects and flooding north of the R28 (Figure 6-1) (SLR, 2018b). As indicated previously the location of the proposed project falls beyond the 1:100 year flood line. d. Water quality Surface water within the unnamed Vaal Tributary was sampled in August 2018 and analysed to provide an indication of the pre-development baseline water quality. The two sampling locations included (see Figure 6-1):  Upstream (P1): Located upstream of the Leeuwkuil Wastewater Treatment Works (WWTW), located 1.5 km south-west of the project site.  Downstream (P2): Located downstream of the confluence with the existing storm water channels.

A full suite of analysis was undertaken. Only those with published standards have been summarised. The water quality results indicated the following (SLR, 2018b):  The two sites have very similar water quality for all parameters, despite the downstream location being below the Leeuwkuil WWTW (although the discharge point of the WWTW is not along this watercourse, a number of sewer pipelines cross this tributary), and being expected to have higher concentrations.  Electrical conductivity (EC) ranges between 82 and 84 mS/m and exceeds all standards except the SANS 241 Aesthetic limits. This is attributed to the elevated levels of ions, such as chloride, calcium, magnesium, manganese and sodium. Furthermore, the elevated EC also translates to elevated total dissolved solids which exceed the SAWQG TWQR for domestic and irrigation use.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

 The elevated ions can be attributed to the diffuse anthropogenic sources located upstream of the WWTW where organic salts and inorganic matter can be washed off the streets and/or discharge points from industrial sites upstream.  The poor water quality draining from upstream is also evident in the elevated dissolved organic carbon (higher than the 5mg/l SAWQG TWQR for domestic uses). Although it has no direct health implications, it is an indicator of the organic material content of the water as further supported by extremely high faecal coliforms (>100 000 counts/100ml) rendering the water unacceptable and unsafe for any use. The presence of faecal pollution could be emanating from upstream communities and could include contributions from domestic sources and warm-blooded animals.  Selenium levels slightly exceed the SANS 241 Drinking water chronic limits. Selenium could be emanating from upstream industrial runoff as it is used in a variety of industrial processes.

The detailed water quality results are presented in Appendix 5.

6.1.4 Soils and agricultural potential a. Soil types The soils are classified as Avalon Form 3200 Mafikeng Family. A typical soil profile consists of a dark brown sandy loam Orthic A horizon, underlain by a eutrophic yellow brown apedal B1 Horizon, underlain by a mottled soft plinthic B2 horizon with increased clay content. The amount of water that can be held in the soil after excess water has drained away (that is, the field capacity) is very high; the soils can hold water for long periods (SLR, 2018c). b. Physical characteristics The average cation concentrations of potassium, calcium and magnesium are on the lower threshold of the normal guideline range for soils. The average cation concentration for sodium and phosphorus are low. The low phosphorus concentration could be an indication of historical fertilisation of the area. The soil pH ranges from 5.50 to 6.50 indicating an acidic to slightly acidic soil. The electrical conductivity is low and does not pose a risk to plant growth (SLR, 2018c).

No evidence of contamination was noted and concentrations are considered to represent baseline conditions (SLR, 2018c). c. Agricultural potential The soil is considered to have a medium to low dryland agricultural potential due to poor internal drainage which will become waterlogged during wet seasons. The plant effective depth is around 1 m with some moisture storage below this. In the dry season this could provide good crop production potential. The topsoils are sandy and have low natural fertility and would require careful nutrient management for crop production. The soils are not considered to be highly erodible although sodium accumulation in the subsoil could indicate some erosion potential if the topsoil is lost due to poor management practices (SLR, 2018c).

Although a portion of the site is zoned agricultural, it is earmarked for industrial and commercial use in the municipalities’ spatial development framework.

6.1.5 Terrestrial ecology a. Floral ecology Vegetation on site and along the proposed water supply pipeline route is identified as Soweto Highveld Grassland. Although this vegetation type is classified as Endangered, a field investigation undertaken by Scientific Terrestrial Services in March 2018 found that the study area is no longer representative of this vegetation type, due to historic and ongoing anthropogenic activities. The proposed plant site was historically used for crop cultivation (prior to 1980) and although the vegetation has recovered to the extent that it is considered as ‘indigenous vegetation’ (as defined by the EIA Regulations, 2014), ecologically it is considered

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

as secondary grassland. Secondary grasslands are grasslands that have undergone extensive modification and then been allowed to return to a ‘grassland’ state but are significantly different with respect to species composition, vegetation structure, ecological functioning and ecosystem services. The proposed plant site is currently subjected to extensive livestock grazing and is dominated by increaser 2 and 3 grass species such as Sporobolus africanus, Eragrostis chloromelas, and Aristida congesta. These species are indicative of overgrazing. The forb layer is dominated by Berkheya carlinopsis and Haplocarpha lyrate, as well as alien invasive species such as Verbena aristigera, Verbena bonariensis and Tagetes minuta. The vegetation is generally uniform across the site (Scientific Terrestrial Services, 2018).

Along the proposed water supply pipeline route, the vegetation has been transformed by industrial, urban and residential development. The plant species composition was dominated by alien invasive species such as Bidens pilosa, Tagetus minuta, and Verbena bonariensis (Scientific Terrestrial Services, 2018). b. Faunal ecology The study area has historically been utilised for crop cultivation, and although the area has managed to re- establish itself to some extent, the area is currently subjected to continuous grazing by domestic livestock. This together with the construction of the roads, railways lines as well as industrial and residential development has resulted in degradation of the habitat of the area. As such the habitat integrity is considered to be moderately low (Scientific Terrestrial Services, 2018).

The faunal diversity associated with the study area is considered to be moderately low and comprised mainly of common faunal species adapted to high levels of anthropogenic activities. Species encountered during the field assessment included avifaunal species such as Vanellus coronatus (Crowned Lapwing), Euplectes progne (Long-tailed Widowbird), Bubulcus ibis (Cattle egrit), Streptopelia capicola (Cape Turtle Dove); reptile species such as Lamprophis cepensis (Brown House Snake) as well as invertebrate species such as Junonia natalica (Yellow Pansy), Apis mellifera (Honey Bee), and Diaphone eumela (Cherry Spot) (Scientific Terrestrial Services, 2018).

Habitat and food availability is considered intermediate as although the area has been significantly modified as a result of current and historic anthropogenic activities, and alien floral species were present, the majority of the area has managed to recover to some extent providing habitat and a food source for a variety of common faunal species (Scientific Terrestrial Services, 2018). c. Species of Conservation Concern No floral or faunal species of conservation concern (SCC) were noted during the field investigation. Although two floral SCC are indicated to likely occur within the study area, namely Crinum bulbispermum and Hypoxis hemerocallidea, these species were not observed during the field survey. Due to the degraded nature of the project site, surrounding infrastructure developments and no connectivity to a larger open space corridor, it is deemed unlikely that any SCC occur within or would utilise the study area (Scientific Terrestrial Services, 2018). d. Conservation characteristics The conservation characteristics of the study area extracted from available literature resources and databases is summarised below (Scientific Terrestrial Services, 2018).  The site is not protected in terms of the NEM:PAA. The nearest protected area is the Leeuwkuil Nature Reserve, located about 1.4 km south west of the site. There are no other protected or conservation areas situated within 5 km of the study area. The study area does not fall within a focus area as per the National Protected Areas Expansion Strategy (2009) and as such is not earmarked for conservation within the near future.  There are no Important Bird Areas within 5km of the site.  Although the Soweto Highveld Grassland has a conservation status of endangered (Mucina and Rutherford), under the National Threatened Ecosystems (2011) listing it is considered as a ‘vulnerable ecosystem’. The site and the associated bulk service infrastructure is not associated with any areas or

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

features of conservation concern, namely Critical Biodiversity Areas (CBAs), Ecological Support areas (ESAs), wetlands, rivers or ridges according to the Gauteng Conservation Plan (V3.3) (see Figure 6-1). e. Ecological sensitivity The terrestrial ecological sensitivity was informed by the presence or potential for floral and faunal SCC, habitat integrity and levels of disturbance, threat status of the habitat type, the presence of unique landscapes and overall levels of diversity. In this regard, the secondary grassland habitat is considered to be of moderately low sensitivity, due to historic and ongoing anthropogenic activities such as historic crop cultivation, livestock grazing, as well as infrastructure development such as roads, railways, industrial and residential development. The transformed habitat is considered to be of low ecological importance and sensitivity as the area has been transformed to hardened surfaces or is associated mainly with alien invasive plant species (Scientific Terrestrial Services, 2018).

The conservation objective identified by the specialist for the secondary grassland is to optimise development potential while improving biodiversity integrity of surrounding habitats and managing edge effects while the conservation objective for the transformed habitat is to optimise development potential (Scientific Terrestrial Services, 2018).

6.1.6 Aquatic ecology a. Freshwater resources No natural freshwater resources (including watercourses or wetlands) occur on the project site or within 500 m of the development footprint.

According to the NFEPA database, there is one wetland feature categorized as natural, located approximately 450 m east and up-gradient of the site. Field work verified that this feature is artificial with no wetland features (Scientific Aquatic Services, 2018). b. Conservation characteristics The conservation characteristics of the project site based on available literature resources and databases is summarised below (Scientific Aquatic Services, 2018).  The study area is located within a subWMA currently not considered important in terms of fish species or freshwater resource conservation.  According to the NFEPA database, there are no rivers located within the study area or the immediate vicinity of the 500 m radius investigation area.  According to the Gauteng Conservation Plan (V3.3) the site and the associated bulk service infrastructure is not associated with any areas or features of wetlands or rivers (see Figure 6-1).

6.1.7 Geology The geology of the site is defined by the Vryheid Formation of the Ecca Group which is part of the Karoo Supergroup. The Ecca Group is an early Permian marine filled system whereby the formations of the late Ecca Group are shallow marine facies followed by fluvial sedimentation. The Vryheid Formation is a facies of the Rippon Formation which consists of massive greywackes, arenites, mudstone and carboniferous shale. Ecca Group sediments on site consist of intercalated shales and quartzitic sandstone, with the quartzitic sandstone predominating, and some occurrence of mudstone (SLR, 2018a). Boreholes drilled on site intersected shale and quartzite of the Rippon Formation (Ecca Group) under approximately 15 m of a tertiary alluvial layer, comprising gravel and clay (SLR, 2018d).

The Karoo sediments are in turn underlain by dolomites of the Malmani sub-group of the Chuniespoort Group, Transvaal Supergroup. The dolomite in the area is expected to be encountered at variable depths below the Ecca Group sediments. Previous third party geotechnical investigations conducted over a wider area recorded dolomite being encountered at depths of between 15 and 40 m below ground level (mbgl).

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

However, boreholes drilled as part of this investigation to depths of between 55 m and 60 m, respectively, did not intersect dolomite. It is therefore assumed that the dolomite in the area of the drilled boreholes occurs at depths greater than 60 mbgl (SLR, 2018d).

The occurrence of dolomites influences the presence of groundwater and may present a potential risk of subsidence and/or sinkhole formation.

6.1.8 Groundwater a. Aquifer characteristics Two boreholes were drilled to a depth of 55 m and 60 m respectively, to inform aquifer parameters of the site and to support future monitoring (Figure 6-1). The two boreholes intercepted the same formation type and their transmissivity was of the same magnitude, representing a fractured aquifer. Groundwater was struck at various depths within the Rippon Formation. The boreholes are considered by the specialist to be low yielding (with a blow yield of <1 m3/hr). The Rippon Formation has a low permeability and water circulates slowly within the formation. With the nature of the underlying rock formations as well as the subsurface clay-rich formation, the underlying aquifer is defined as an aquitard, providing good protection against potential groundwater pollution (SLR, 2018d). An aquitard is a zone that restricts the flow of groundwater from one aquifer to another and comprises material with low hydraulic conductivity.

As indicated above, the aquiferous dolomites of the Malmani Group were not encountered during the groundwater investigation and could possibly occur at depths below the extent of the drilled boreholes (> 60 mbgl) (SLR, 2018d).

According to the Aquifer Vulnerability/Classification/Susceptibility Maps of South Africa, the aquifer has a low vulnerability and classifies as a minor aquifer with a resulting low susceptibility to contamination (SLR, 2018d). b. Groundwater levels and flow Static water levels in the on-site boreholes were observed at 3.10 mbgl and 3.45 mbgl, respectively (SLR, 2018d). It is assumed that groundwater flow is from north to south. c. Water quality Water quality from on-site boreholes exceeded the SANS 241:2015 operational limits for aluminium (Al), the aesthetic limits for iron (Fe) and both operational and aesthetic limits for turbidity. The operational guideline value gives an indication of quality related to the operating of machinery. The aesthetic guideline value gives an indication of concentrations at which the water will be tainted in respect to taste, odour and colour; it does not pose an unacceptable health risk when this value is exceeded. Turbidity can be attributed to high inorganic parameters such as aluminium and iron levels. Elevated turbidity can also be a result of particulate matter liberated during well installation (SLR, 2018d). d. Groundwater users Groundwater users for drainage region C22F and within a 3 km radius of the project site were identified from the National Groundwater Archive (NGA) (Figure 6-1). The nearest groundwater boreholes to the project site are located approximately 1 km south east, at an abandoned but occupied property, 1.7 km north, at commercial/private properties and 2 km west, at a private property (SLR, 2018d).

6.1.9 Air quality The project site falls within the Vaal Triangle Airshed Priority Area (VTAPA). The priority area was declared as a result of poor ambient air quality. The ambient air quality has been influenced by industries, mines, power stations, household fuel combustion, vehicle tailpipe emissions, entrained dust and wind erosion from

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

exposed areas. Pollutants of concern for the proposed project, namely particulate matter (PM2.5 and PM10), sulfur dioxide (SO2) and nitrogen dioxide (NO2) are discussed below. a. Ambient air quality monitoring Several AQMS are located across the VTAPA and are owned and managed by National and District government departments, as well as industry partners. The closest station to the proposed site considered by the air quality specialist to be representative of ambient air quality at the site is the Sharpeville station (Airshed Planning Professionals, 2018a).

Verified data for the period 1 January 2014 to 31 December 2016 was obtained and analysed (Airshed Planning Professionals, 2018a). Non-compliance with the applicable NAAQS was recorded for:

 PM10 and PM2.5 daily and annual concentrations for all years summarized Local sources contributing to PM2.5 concentrations at low wind speeds include domestic fuel burning, informal waste burning, and vehicle entrainment on unpaved roads. While local sources also contribute to PM10 concentrations, the highest PM10 concentrations are associated with wind speeds above 6 m/s and originate to the north and north-east.

 Annual average NO2 concentration in 2015 Sources contributing to NO2 concentrations at Sharpeville originate to the north-west and north- north-east of the station at wind speeds above 8 m/s. Local sources contribute at low speeds and could be associated with vehicle activity and domestic fuel burning.

Ambient SO2 concentrations monitored at Sharpeville were compliant with the NAAQS. Sources of SO2 near the Sharpeville station include a source to the south east contributing the highest concentrations at wind speeds between 1 and 4 m/s; lower concentrations from the south-east and east contribute at wind speeds greater than 4 m/s. A contribution from the north-west also contributes at all wind speeds. b. On-site monitoring campaign

A short-term on-site air quality monitoring campaign was conducted between April/May 2018 for PM10, PM2.5, NO2 and SO2. Results from the monitoring campaign are discussed below.

TABLE 6-3: ON-SITE AIR QUALITY MONITORING RESULTS RELATIVE TO THE SHARPEVILLE AQMS Pollutant On-site results Relative to the Sharpeville AQMS

PM10 - Daily NAAQ limit exceeded on six days. - Comparison with Sharpeville daily - Days of exceedance were not associated with above averages over same period shows good average wind speeds and overnight temperatures were correlation. relatively low, suggesting poor dispersion conditions for - Long-term average concentrations at accumulated particulates. Sharpeville station may be conservative relative to those at site.

PM2.5 - Only one exceedance of current daily NAAQ limit was - Day with the highest measured recorded. Suggests a very localised source at Sharpeville concentration did correspond with the

station. Comparison with the PM2.5 measured at the highest concentration measured at Sharpeville station is poor, where 15 days were recorded Sharpeville station. to exceed the NAAQ limit concentration. - Long-term average concentrations at Sharpeville station may be conservative relative to those at site.

SO2 - Calculated ambient concentrations show compliance - Concentrations are lower than with the annual NAAQS. concentrations measured at Sharpeville - Sampling points with highest concentrations were the but this could be due to the campaign Correctional Services site and the substation. length (1 month) and timing (prior to

NO2 - Annualised concentrations are likely to be compliant winter). with annual standard. - Sharpeville station therefore considered - Sampling point with the highest concentrations was the representative of the concentrations on substation, where concentrations could be associated site. with vehicle exhaust emissions along the R59.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

c. Potential receptors Potential receptors were identified by the air quality specialist to include areas where the public is likely to be inadvertently exposed. These include known nearby hospitals and schools as well as nearby residential, industrial and commercial areas. Further detail is included in Section 6.2.1.

6.1.10 Noise a. Ambient noise environment Baseline noise levels were measured at five locations in and around the site in November 2017 (Airshed Planning Professionals, 2018b).

On-site day-time levels are comparable to what is typically expected within rural/suburban areas, as are levels at the closest residential establishment (correctional services staff accommodation) and off-site west of Lager Road (open field). At the informal residential structures south of the R28 and the residential area to the east of the R59, the day-time noise levels typical of urban areas prevailed primarily due to traffic noise. The residential area the east of the R59 recorded the highest day-time noise levels.

Due to the presence of main roads and high traffic volumes (on the R59 and R28), baseline night-time noise levels are somewhat higher at the residential areas than typically expected within suburban areas. b. Potential receptors Potential receptors were identified by the noise specialist to include places of residence, community areas such as schools and hospitals and any publicly accessible areas that may be affected by noise generated by processing and transport activities.

The impact of an intruding industrial noise on the environment rarely extends over more than 5 km from the source. Potential receptors within 5 km of the project site were identified by the noise specialist (Airshed Planning Professionals, 2018b). Further detail is included in Section 6.2.1.

6.1.11 Visual a. Visual resource value / Scenic quality The area is urban to peri-urban in character with a strong industrial component. It comprises a mixture of land use interspersed with open land and intersected with road, rail and utility rights of way (see Section 6.2.1). Overall the scenic quality rating is low to moderate because of the general sense of deterioration / degradation to the landscape, the presence of industry, power and rail utility activities along with areas of litter and the presence of alien invader tree species (Young, 2018). b. Sense of Place The sense of place derives from the combination of all landscape types and their impact on the senses. The activities and land-uses within the area are common within the sub-region and show signs of deterioration due to industrial and utility activities. The general landscape does not evoke a strong or positive sense of place (Young, 2018).

6.2 SOCIO-ECONOMIC

6.2.1 Land use a. Surface rights The proposed plant site is owned by The South African Breweries (Pty) Ltd (SAB). Land immediately adjacent to the site is owned by the SAB, Department of Public Works and Telkom SA Ltd (Table 6-4). Further afield, land is owned by the Emfuleni Local Municipality (ELM), Transnet Ltd, private companies and individuals.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

TABLE 6-4: ADJACENT LANDOWNERS Farm Portion Title deed Owner Leeuwkuil 596IQ Remaining Extent Portion 238 T92196/2016 The South African Breweries (Pty) Ltd Remaining Extent Portion 237 T92196/2016 186 T7954/1997 Transnet Ltd 86 T8059/1952 Department of Public Works 92 T3789/1953 134 T37299/2013 93 T19955/1972 Telkom SA Ltd b. Land use on the project site The project site is open land comprising secondary grasslands (see Section 6.1.5). It is located in a partially developed, mostly industrial area to the west of the Vereeniging Central Business District (CBD). The area is earmarked for industrial and commercial use in the municipalities’ spatial development framework (Emfuleni Local Municipality, Spatial Development Framework (2017-2025)) (Figure 6-2). The land is unfenced and used for informal livestock grazing by the Leeuwkuil Communal Kraal (information sourced during stakeholder meetings) (discussed further below).

Historically the land was used as a residential area and then as an air force and army base in the 1950s (information sourced during stakeholder meetings). It used to be government property. Signs of previous cultivation are visible from historical aerial imagery (Scientific Terrestrial Services, 2018). c. Land uses surrounding the project site Given the project’s location within an urban area, the surrounding area comprises a variety of mixed formal and informal land uses (Table 6-5, Figure 6-2). There are no known tourism activities located in the study area (Young, 2018).

Transport infrastructure includes the R59 freeway (east), R28 road (south), Lager Road (west) and rail (north, west and south) (see Section 6.2.2).

Third party service and utility infrastructure is listed below:  An Eskom substation to the east of the site, located adjacent to the R59. A 132kV overhead powerline runs from the substation south along the R59 and then along the R28 before turning left down Lager Road and feeding into the Sharpeville area. The proposed project would upgrade and source power from the substation.  An underground electrical line that runs across the project site from east to west. It is assumed that this line feeds the facilities along Lager Road.  A Sasol gas pipeline that runs along the western boundary of the R59.  Pipeline network associated with the Leeuwkuil Water Care works.  Emfuleni/Rand Water supply pipeline, feeding from the Vereeniging CBD to the SAB depot and surrounding area.  Communication infrastructure. c. Land claim The Department of Rural Development and Land Reform has indicated that there is a single land claim over the Farm Leeuwkuil 596 IQ. It has been indicated that the claim has been made by an individual who is a direct descendant of an individual who was a sharecropper on an undefined portion of the property. It is not clear if the claim affects a portion of Farm Leeuwkuil 596 IQ relevant to the project. Correspondence related to the land claim is included in Appendix 4.

The claim is not being processed by the Land Claims Commission as it was made in terms of the Restitution of Land Rights Amendment Act, 2014, which has been declared invalid by the Constitutional Court.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

TABLE 6-5: SURROUNDING LAND USES Land use Name Description Distance and direction from site Neighbouring Open land Used for informal livestock grazing by the Leeuwkuil Communal Kraal Adjacent (south and east) land that forms Vereeniging Correctional Staff houses (18, accommodating married staff who work at the prison - up to 36 people) and Adjacent (north) part of the Centre Staff Quarters single quarters (house approximately 27 people). ‘Leeuwkuil Open Serve/Telkom Service yards and storage. Adjacent (north west) Commercial and Department of Roads and Service yards and storage. Adjacent (west of plant and Industrial Area’ Transport (Gautrans) north of access road) Main arterial road Sybrand van Niekerk Freeway (R59) 200 to 250 m east SAB Depot Dispatch depot, offices, storage, and warehouses. Adjacent (west and south west) Vereeniging Correctional Prison and associated amenities comprising a central lock-up facility and a small awaiting-trial 100 to 150 m north Centre facility (total of between 600 and 1000 inmates at the facility at any time; prisoners are allowed outside for a maximum of one hour per day). A total of 243 employees at the facility, most of who travel to the prison via department-provided busses and vehicles. Wise Owl Pre-school Nursery School with five staff and up to 112 learners (aged between 3 and 6 years old). The 200 m west of plant and 70 m school services parents who come from Sebokeng and work in Vereeniging and Vanderbijlpark. south of access road Some parents work at the correctional services. (It should be noted that the intention is to relocate the Wise Owl Pre-school in partnership with the local municipality.) Sedibeng Fresh Produce Market Open retail market for bulk fresh produce and packaged goods including a Cash&Carry 450 m south west Transnet rail siding and yard Rail yard for Transnet Freight Rail and associated administration and operational buildings 700 m west Residential Leeuhof Suburban with small, free-standing houses with small yards. Community comprises low to 350 m east medium household incomes. Area is degraded, with poor roads and inadequate solid waste management. It’s understood that these houses were built during the 1950s or 1960s when government employees were relocated from the Leeuwkuil industrial area due to the development of an air force base. Duncanville and Unitas Park Suburban comprising residential and commercial activities. Residential is partly medium-density 850 m north middle-income, suburban houses and partly low-density small-holdings. Leeuwkuil Communal Kraal Informal accommodation used by herdsmen and shepherds. Approximately 30 people sleep at 850 m south the kraals overnight. Roods Gardens Mixed residential and commercial agricultural small holdings. Houses appear to be middle- 1 km west income, although some properties appear to be derelict. Vereeniging Suburban comprising residential and commercial activities. Community comprises low to medium 1.1 km east household incomes. Sharpeville, Dickinsonville and Suburban residential and commercial township with low- to middle-income free-standing houses 2 to 3 km south west Tshepiso with small yards. Homer, Steelpark Suburban comprising residential and commercial activities. Residential component is medium- 1.7 to 2.8 km north west

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

Land use Name Description Distance and direction from site density, middle-income. Education, Residential areas to the east A number of known schools and hospitals/clinics. Two of the nearest schools to the project site 720 m to 1 km south east hospital, clinics, (General Smuts High School and Eureka school) include a boarding school and hostel, respectively. (nearest) recreational Residential areas to the west A number of known schools and hospitals/clinics are located within Sharpeville. 1.8 to 2 km south west (nearest) Industrial / Leeuhof / Duncanville Industrial Light industrial and commercial including bulk distribution, agricultural equipment and motor 500 m north and 700 m north Commercial area vehicle retail and repair, construction suppliers and equipment hire, wheat mill. east Vereeniging Industrial area Mixed industrial including showgrounds, abattoir and rendering plant, agricultural and beverage 900 m south east distribution, go-cart track. Old municipal cemetery including the Vereeniging/Boer concentration camp cemetery. Leeuwkuil Water Care Works Waste water treatment facility 1.1 km south west Agricultural Leeuwkuil Communal Kraal Kraals (owned by various individuals), enclosures for other livestock (such as pigs and chickens) 900 m south and informal facilities (toilets and cooking areas) for people who work at the site. Farmers are represented by the Emfuleni Livestock Committee. Majority of farmers/livestock owners are registered with local farming organisations. Kraals were positioned at this site around the year 2000 by the ELM as the previous site was developed into the Tshepiso township. Open land Any open land in the surrounding area is used for informal livestock grazing by the Leeuwkuil - Communal farmers. Informal trade Various These included food-sellers (non-perishable food stuffs) and recycling activities (glass bottles, scrap metal, plastic) within the industrial area and surrounding residential areas. Adopted from (Nomad Consulting, 2018); information sourced during stakeholder meetings.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

6.2.2 Traffic a. Road network The site is accessed from and located east of Lager Road which is a Class 4a road aligned north-south. This road has two lane carriageway from the intersection with the R28 Road until just south of the SAB depot. From this point, the road is a narrow single lane carriageway per direction. This road provides access to various facilities located within the Leeuwkuil Industrial and Commercial area.

The Sybrand Van Niekerk Freeway (R59/P156/2) is a Class 1 major arterial road located approximately 150 m east of the site. This dual carriageway road follows a north-south alignment with two lanes per direction. Boy Louw Street (R28/P88-1) is a Class 2 collector street (with two lanes per direction) south of the site which follows an east-west alignment. These roads fall under the jurisdiction of the Emfuleni Local Municipality (WSP, 2018) (Figure 6-1). b. Local traffic Traffic counts conducted in February 2018 indicated that weekday traffic peaks at all local intersections occur between 7 and 8 am in the morning and 4 and 5 pm in the afternoon. The Boy Louw Street and Theunis Kruger Street intersection currently operates (for most directions) below acceptable levels of service. All of the other local intersections operate at acceptable levels of service (LOS in terms of SIDRA) (WSP, 2018). c. Rail network A Transnet industrial rail siding approximately is located 900 m west of the site with an associated railway network which runs north from the siding and then branches to the east and west, and south of the siding turning to the east.

6.2.3 Socio-economic profile The proposed project is located within Vereeniging, in the Gauteng Province, approximately 50 km south south-west of Johannesburg. This area falls within the Emfuleni Local Municipality (ELM) and the Sedibeng District Municipality (SDM). The Sedibeng District Municipality (SDM) is situated on the southern tip of the Gauteng Province. Emfuleni Local Municipality (ELM) is the western-most of three local municipalities comprising the Sedibeng District.

The Gauteng Province is the economic hub of South Africa, contributing approximately 35% towards the South African gross domestic product (GDP). In 2015, it accounted for 32% of total employment in South Africa and 37% of South African manufacturing employment. The economic challenges adversely affecting the national growth rate include high poverty levels, inequalities in terms of incomes and opportunities as well as youth unemployment.

Some key points on the demographic profile of the ELM relative to the district and province are listed below and were sourced from the social (Nomad Consulting, 2018) and economic (Mercury Financial Consultants, 2018) specialist reports (see Appendix 13 and Appendix 14, respectively).  The total population of the ELM is approximately 730 000 (78% of the SDM and 5% of the province). The population of this municipality is characteristic of an urban population in South Africa, with a gender split of 49% male and 51% female and a high youth population suggesting in-migration of job seekers into this industrial and commercial area.  The high population density of the ELM can be accounted to the urbanised nature of the municipality and the high-density informal and low-cost settlements located in the Sharpeville, Sebokeng and other low-income residential areas around Vereeniging and Vanderbijlpark.  The population comprises mostly seSotho speaking (52%), black Africans (85%).  Education levels within the ELM are low. This is similar to the SDM but slightly lower when compared to the province.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

 Approximately 65% of the ELM population is economically active with the official unemployment rate at roughly 35%. This is slightly higher than that for the SDM (32%). The unemployment rate of the ELM may be a result of the influx of job seekers to the area due to the high density of industrial and commercial activities.  Formal housing, home ownership and rates of municipal service delivery (flush toilets, refuse removal, piped water and electricity) are generally high compared to district and provincial averages.

The site falls within Ward 11 of the ELM, and is flanked by Wards 12 and 15. For the most part the demographic profile of these wards is similar to that of the ELM (Nomad Consulting, 2018). The wards have a slightly higher percentage of males to females (which could suggest the inward migration of job seekers) and lower unemployment rate to that of the ELM. Most common tenure status is rented accommodation (70%), of which almost three-quarters pay rent and less than a third have rent-free occupation. Only 26% percent of households are owned by those living there (paid off or still paying off) indicating that only a quarter of the population within the wards has access to income for bonds, and the longevity in their jobs and community to purchase a home.

The most common tenure status is rented accommodation (47%), 19% live in rent-free accommodation, and 31% own their own properties. This indicates that less than a third of the population within the study area has access to stable incomes and longevity in the community to purchase a home.

The ELM has two main city/town centres, namely, Vereeniging and Vanderbijlpark and has access to well- maintained road networks. The proposed project is located on the western outskirts of Vereeniging, 2 km west of the Vereeniging CBD. The economy of the ELM is dominated by the manufacturing sector (41%), followed by community services (22%) and finance (16%) (Mercury Financial Consultants, 2018).

Vereeniging is currently one of the most important industrial manufacturing centres in South Africa, with its main products being iron, steel, pipes, bricks, tiles and processed lime. Vereeniging furthermore has several Eskom thermal power plants. Unfortunately the steel industry has been shrinking, having grown only 1% over the last 30 years and available production capacity has not been utilised in the past few years. The steel manufacturing industry is at risk due to lack of new technology, quality of local steel and labour action (Mercury Financial Consultants, 2018). Many jobs have been lost in the steel and related industries.

From 2001 to 2013 the overall number of people living in poverty in the ELM increased by 21.8%. This rate is similar but slightly lower when compared to the district (26.3%) and significantly lower when compared to the province (65.3%). The overall poverty gap has increased over this same period by 204.2%. A similar trend is seen between ELM, SDM (at 2.7.7%) and the province (at 318.3%) (Mercury Financial Consultants, 2018).

The economic challenges faced in the region are similar to those faced on a provincial level and include a poor performing economic growth rate, high poverty levels, inequalities in terms of incomes, limited employment opportunities as well as youth unemployment (Mercury Financial Consultants, 2018).

The Leeuwkuil area of the ELM is a partially developed area, earmarked for future commercial and light industrial development (Urban Dynamics Gauteng, 2017). No housing or occupation occurs on the project site. The current land use of the site, namely informal livestock grazing, is the only current beneficial use of the site and means that the site has very limited direct, indirect or induced effects on the local, regional and national economy. Limited formal employment (in the form of paid herdsmen and shepherds aged between 20 and 40 years old) results from the site and there is no contribution towards socio-economic development. The livestock, which can number up to 1000 head, are owned by about 50 members of the Emfuleni Livestock Committee who reside within the Emfuleni area. The site comprises about 10% of the grazing which the communal kraal have access to.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

6.3 HERITAGE AND CULTURAL RESOURCES Although the Leeuwkuil and greater Vereeniging area has a long development history, with coal having been discovered in the region in 1879, no heritage resources as outlined in Section 3 of the National Heritage Resources Act (No 25 of 1999) were identified on or immediately surrounding the project site. Heritage resources of cultural importance occur within the greater Vereeniging area. These include the Vereeniging/Boer concentration camp cemetery located in the old municipal cemetery, Voortrekker Monument, Pelindaba and Vuka cemeteries in Sharpeville (associated with the Sharpeville massacre) (Pistorius, 2018).

From a palaeontological perspective the project site lies on the shales and sandstones of the Vryheid Formation, Ecca Group that are early Permian in age. These rocks are of the correct age and could host fossil plants of the Glossopteris flora. The SAHRIS palaeontological map indicates that area is highly sensitive. However, logs from two boreholes drilled on site show that there are no potentially fossiliferous rocks above 35 m in the north and above 25 m in the south. The rocks comprise only gravels, weathered clays, weathered shales and quartzite; these would not preserve any fossils because they are fluvially reworked gravels or very weathered clays which would have destroyed any possible fossils (Bamford, 2018).

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

7 IMPACT DESCRIPTION AND ASSESSMENT The potential impacts described in this chapter have been identified by the EIA project team with input from specialists and I&APs. The sequence in which these issues are listed are in no order of priority or importance. The assessment and rating of potential impacts has been informed by specialist studies. These are attached as appendices to the BAR.

All identified impacts are considered in a cumulative manner such that the impacts of the current baseline conditions on and surrounding the site and those potentially associated with the project are discussed and assessed together.

The mitigated assessment assumes that technical design controls, as included in the project scope (see Section 4), would be included in the detailed design of the plant and implemented when the plant is constructed and operated.

To provide context on the layout of the plant on the project site, a 3D schematic representation of the plant has been superimposed onto an aerial topographical map (Figure 7-1).

7.1 IMPACT ON BIOPHYSICAL ENVIRONMENT

7.1.1 Issue: Loss of agricultural soil resources through physical disturbance Description of impact Construction and operation of the infrastructure and related services has the potential to damage soil resources through physical disturbance including removal, compaction and/or erosion.

Soil, and more specifically topsoil, is considered a valuable resource that supports a variety of ecological systems including providing a growth medium for most vegetation. Its disturbance and loss should be prevented wherever this is avoidable. Given the potential for the plant to have a life in excess of 20 years, and the site’s location within an area earmarked for commercial or industrial development, the loss of soil is considered from the perspective of its agricultural value.

Impact assessment Site preparation and earthworks will require the removal and stockpiling of soil. Improper recovery and separation of soils could result in topsoil being left under infrastructure or mixed with fill and spoil material and thus lost. Improper handling of the soils could compromise the soil structure and functionality. Vehicle movement and machinery could result in the compaction of soils. In the case of compaction the soils’ functionality would firstly be compromised through a lack of rooting ability and aeration, and secondly the compacted soils are likely to erode because with less inherent functionality there would be little chance for the establishment of vegetation and other matter that naturally protects the soils from erosion. Disturbed and exposed soils are susceptible to erosion (through action of wind or water) as a result of the lack of vegetative cover and friability of the soil structure. Eroded soils, although the erodibility of the soils on site is not considered to be high, would be lost from the area of disturbance.

The above impacts are expected to occur during the construction phase. It is expected that a site boundary would be established at the start of construction and that impacts would therefore be limited to the project site. During operations, once landscaping has taken place, no further physical disturbance of soils is expected.

Stripping and handling of soils would affect the inherent functionality of the soil and the soil would be permanently lost from the area. The soils on site are however considered to be of low to moderate agricultural potential. With mitigation that ensures beneficial uses are identified for the soil the significance of any impacts can be reduced. The loss of agricultural soil resources through physical disturbance is considered to be of MEDIUM significance without mitigation and LOW significance with mitigation (see Table 7-1 below).

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(Sourced from the visual specialist study) FIGURE 7-1: PERSPECTIVE OF THE PLANT IN RELATION TO THE PROJECT SITE Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

Mitigation The following measures are recommended (see EMPr in Section 8):  Identify beneficial uses for excess topsoil that cannot be used on site. This could include sale to third parties.  Establish the site boundary (as presented in this report) at the start of construction and keep all activities within this boundary.  Restrict vehicle and machinery movement to designated areas.  Strip, store and maintain soils in line with the soil management plan (this includes measures for erosion control).  Rehabilitate and landscape disturbed areas not occupied by infrastructure.

Monitoring The following monitoring is recommended (see EMPr in Section 8):  Visual inspections of disturbed areas for erosion and rehabilitation status.

TABLE 7-1: IMPACT SUMMARY – PHYSICAL DISTURBANCE OF SOIL RESOURCES

Issue: Loss of agricultural soil resources through physical disturbance Phases: Planning and Design, Construction Criteria Without Mitigation With Mitigation Intensity Moderate change or disturbance Moderate change or disturbance Duration Long-term Short-term Extent Whole site A part of the site Consequence Medium Low Probability Definite Probable Significance Medium Low

Loss of soils due to other developments within the same area could contribute to cumulative impacts. The area, however, is earmarked for industrial use as Nature of cumulative impacts part of the ELM SDF and therefore a cumulative loss of soils across the earmarked area is unavoidable. Degree to which impact can be The loss of in-situ soils is irreversible, however where mitigation can be applied reversed the soil can be used for beneficial uses. Degree to which impact may High cause irreplaceable loss of resources Degree to which impact can be Moderately high mitigated Once soil is removed from in situ and handled, the area of land and natural soil Residual impacts functionality would be permanently lost.

7.1.2 Issue: Loss of agricultural soil resources through contamination Description of impact Construction and operation of the plant site and related services has the potential to damage soil resources through contamination.

Soil, and more specifically topsoil, is considered a valuable resource that supports a variety of ecological systems including providing a growth medium for most vegetation. Its disturbance and loss should be prevented wherever this is avoidable. Given the potential for the plant to have a life in excess of 20 years, the loss of soil is considered from the perspective of its value as a growth medium to support rehabilitation and landscaping of disturbed areas post construction and its beneficial use to third parties where excess soil cannot be used on site.

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The loss of soil and related agricultural potential and its impact on land uses is discussed separately in Section 7.2.4 below.

Impact assessment Contamination of soil resources could occur through potential spillages from the use and handling of fuels, lubricants and other potential contaminants. Additionally dirty surface water runoff or effluent from activity areas and poor waste management practices could result in soil contamination. This could alter the soil composition, negatively impacting on the chemistry of the soils such that current growth conditions are impaired. Contamination of soils also has the potential to indirectly (through runoff and seepage) impact surface and groundwater resources (discussed further in Sections 7.1.6 and 7.1.7).

Sources of contamination exist during both the construction and operational phases. During operations it is expected that the scale and frequency of contaminant events would be relatively low given the control measures that are planned for the project. Contamination of soil resources is considered to be of MEDIUM significance without mitigation and VERY LOW with mitigation (see Table 7-2 below).

Mitigation: The following measures are recommended (see EMPr in Section 8):  Prevent and manage spills.  Manage waste generated on site.  Handle major spillage incidents in accordance with the emergency response procedure.

Monitoring The following monitoring is recommended (see EMPr in Section 8):  Visual inspections of disturbed areas for signs of contamination.

TABLE 7-2: IMPACT SUMMARY – CONTAMINATION OF SOIL RESOURCES

Issue: Loss of agricultural soil resources through contamination Phases: All Criteria Without Mitigation With Mitigation Intensity Prominent change or disturbance Moderate change or disturbance Duration Medium term Short term Extent A part of the site A part of the site Consequence Medium Low Probability Probable Conceivable Significance Medium Very Low

Contamination incidents from surrounding land uses could add to the loss of Nature of cumulative impacts resources if not mitigated. Degree to which impact can be Partially reversible where bioremediation of soils takes place. reversed Degree to which impact may High cause irreplaceable loss of resources Degree to which impact can be High mitigated Residual impacts With mitigation, no residual impacts are expected.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

7.1.3 Issue: Loss of terrestrial habitat and biodiversity through physical disturbance Description of impact Construction of the plant infrastructure and related services has the potential to damage soils and vegetation and the biodiversity these support through physical removal and disturbances, both direct and indirect.

Natural habitat and biodiversity are considered important natural resources that support sustainable ecological systems and ultimately provide ecosystem services that add value to human life. Although the site potentially hosted Soweto Highveld Grassland (classified as Endangered) it currently consists of secondary grassland, which had previously undergone extensive modification and then subsequently returned to a ‘grassland’ state. The secondary nature of the vegetation, ongoing grazing regime and development in surrounding areas has resulted in limited species diversity and a habitat that is considered to be of moderately low to low ecological importance and sensitivity.

Impact assessment Site preparation and earthworks would result in removal of vegetation and soils. The development of infrastructure over these areas would completely transform the site, rendering it unavailable as habitat for flora and fauna. Vehicle and machinery movement, material storage and handling and other construction activities are likely to result in trampling of vegetation and compaction of soils in the adjacent areas. This would dramatically reduce the habitat quality and alter biodiversity. Such areas could be partially restored during landscaping and rehabilitation such that certain naturally occurring flora and fauna occupy the site. Approximately 16.2 ha would be permanently lost as natural habitat, while the balance of the property (~8 ha) would be of reduced value to naturally occurring biodiversity.

The increased level of activity (the presence of people, vehicles, machinery and related noise) would render the site and adjacent surrounds less suitable as habitat for faunal species, except those adapted to high levels of anthropogenic activities. The loss and transformation of habitat as well as increased levels of disturbance would also render the site less suitable as a corridor for the movement of biodiversity between remaining habitats in the region. The establishment and spread of alien invasive floral species as a result of disturbances could further degrade habitat and limit food availability of various faunal species.

The above impacts are expected to mainly occur during the construction phase. It is expected that a site boundary would be established at the start of construction and that direct impacts would therefore be limited to the project site. During operations, once landscaping has taken place and a site boundary established, no further physical disturbance of vegetation is expected. However, the activity and noise disturbances would continue for the duration of the operation. The impact on the terrestrial biodiversity resources is considered to be of MEDIUM (during construction) and VERY LOW (during operations) significance without mitigation and LOW (during construction) and INSIGNIFICANT (during operations) significance with mitigation (see Table 7-3 below).

Mitigation The following measures are recommended (see EMPr in Section 8):  Implement soil mitigation measures.  Manage waste.  Utilize locally appropriate, indigenous plant species in the landscaping.  Promote natural landscapes rather than park-type landscapes.  Manage alien invasive plant species.  Handle major spillage incidents in accordance with the emergency response procedure.

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TABLE 7-3: IMPACT SUMMARY – LOSS OF TERRESTRIAL HABITAT AND BIODIVERSITY

Issue: Loss of terrestrial habitat and biodiversity through physical disturbance Phases: All Criteria Without Mitigation With Mitigation Intensity Moderate change or disturbance Minor (Slight) change or disturbance (Minor during operations) (Negligible during operations) Duration Long-term, to end of operations Medium-term (Medium-term during operations) (Very short during operations) Extent Beyond the site boundary, affecting Whole site. immediate neighbours Consequence Medium Low (Low during operations) (Very Low during operations) Probability Definite/ Continuous Definite/ Continuous (Possible during operations) (Conceivable during operations) Significance Medium Low (Very Low during operations) (Insignificant during operations)

The loss of natural habitat would be cumulative with other historic and ongoing transformation of grassland for development. The area is earmarked Nature of cumulative impacts (municipal and provincial level) for development and does not form part of provincial biodiversity conservation targets. Removal of the facility and rehabilitation of the land would reverse the impact, Degree to which impact can be at least in part. However, this is considered unlikely. Once developed as an reversed industrial site, future use would likely remain industrial/commercial. The impact is not reversible. Degree to which impact may Low. The site does not host any species of conservation concern or other cause irreplaceable loss of irreplaceable resources. resources Degree to which impact can be Moderate. mitigated Residual impacts The permanent loss of approximately 16.2 ha of natural habitat.

7.1.4 Issue: Disturbances of aquatic habitat and related biodiversity through changes in flow and water quality Description of impact Aquatic habitats are considered important natural resources that support sustainable ecological systems and ultimately provide essential ecosystem services (e.g. water purification, water retention, flood reduction). The nearest natural freshwater resource to the site is the Vaal tributary. Adjacent to the site, a man-made concrete drainage channel ultimately feeds, via the Vaal tributary, into the Vaal River, which is of strategic importance to Gauteng. The aquatic habitat in the Vaal tributary is currently of low ecological state and sensitivity. Water quality and aquatic habitats in these systems are under threat due to anthropogenic stresses.

Contaminated run-off from the site during the construction phase and the release of treated effluents from the sewage package plant and waste water treatment plant have the potential to affect freshwater habitats through changes in flow and water quality, thus affecting aquatic biodiversity in the downstream environment.

Impact assessment Earthworks during construction could increase sediment loads in storm water runoff and contaminants arising from spillages of fuels, lubricants and paints as well as poor waste management could reach the drainage channel adjacent to the site (150 m south east) and be transported downstream to the Vaal tributary. This

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would further reduce the poor water quality in the Vaal tributary and impact aquatic habitat and related biodiversity.

During operations attenuated storm water from the site would be considered clean and therefore would not contribute to any contamination impacts.

The sewage package plant and waste water treatment plant would be designed and operated to achieve effluent qualities compliant with the quality parameters in the Leeuwkuil Water Care Works licence (Department of Water and Sanitation, 2014) (i.e. Drinking Water Standards). The released effluent would enter the Vaal tributary just upstream of the Leeuwkuil Water Care Works’ discharge point. Baseline water quality in the Vaal tributary (as at August 2018) is poor with numerous parameters (e.g. electrical conductivity, chloride, calcium, magnesium, manganese, sodium and faecal coliforms) exceeding the SANS 241:2015 Drinking Water Standards and in-stream water quality guidelines for the Vaal Barrage Reservoir catchment. The baseline water quality has already caused a change in the aquatic biodiversity. Where poor quality discharge is released into the environment, this would further degrade aquatic habitats and related biodiversity. Where discharge of treated effluent is at the same quality as the majority of the flow in the Vaal tributary, it is not anticipated to cause a detectable impact to freshwater habitat or aquatic biodiversity. The discharged water quality would be better than the baseline water qualities (as at August 2018) in the Vaal tributary.

The discharge volumes from the sewage package plant and the industrial waste water treatment plant would be 30% of the discharge flows from the Leeuwkuil water care works to the Vaal tributary. The biodiversity specialist is of the opinion that this additional flow would not significantly alter the aquatic habitats or related biodiversity within the system.

Construction impacts would be of short duration and would occur away from the natural water resource. Any contamination, if significant, could be long-term. During operations impacts are likely to be limited to those associated with discharge from the site during upset conditions, as soils/vegetation would not continue to be disturbed, contaminants would be contained and handled in bunded areas and under normal conditions, spare capacity (conservancy tanks) would be provided within the system to support maintenance activities. Large discharges from the storm water attenuation pond would only occur during high storm events, which would likely flush the system.

Disturbance of the downstream natural aquatic habitat and related biodiversity is assessed to be of LOW significance without mitigation and VERY LOW significance with mitigation (see Table 7-4 below).

Mitigation The following measures are recommended (see EMPr in Section 8):  Undertake the primary earthworks activities in the drier winter months.  Implement soil mitigation measures.

Monitoring The following monitoring is recommended (see EMPr in Section 8):  Test the quality of the effluent to ensure that only effluent of an acceptable standard is being released to the receiving environment.  Monitor water quality in the Vaal tributary.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

TABLE 7-4: IMPACT SUMMARY – DISTURBANCES OF AQUATIC HABITAT AND RELATED BIODIVERSITY

Issue: Disturbances of aquatic habitat and related biodiversity through changes in flow and water quality Phases: All Criteria Without Mitigation With Mitigation Intensity Minor change or disturbance Minor (Slight) change or disturbance Duration Long term, to end of operations Short-term Extent Local area, extending far beyond the Local to the site site boundary Consequence Medium Low Probability Conceivable Conceivable Significance Low Very Low

Nature of cumulative impacts The contribution of the project to the cumulative impact is insignificant. Degree to which impact can be The impact would largely be reversed on cessation of discharge. reversed Degree to which impact may Unlikely. Existing ambient conditions in the Vaal tributary are such that the cause irreplaceable loss of discharge is unlikely to cause irreplaceable loss. resources Degree to which impact can be Mitigation is not required as it forms plant of the plants design and operating mitigated conditions. Residual impacts None.

7.1.5 Issue: Alteration of drainage patterns affecting the flow of water in downstream systems Description of impact Water for the project will be sourced from Rand Water via the Emfuleni Local Municipality and therefore no water will be abstracted from the site or from nearby water resources.

The project will introduce large areas of impermeable land cover, which could if not mitigated, increase the volume of runoff generated during a storm event. This could alter drainage patterns and result in the flooding of downstream systems (flash floods). Where any discharges take place this could increase flows within downstream systems and the risk of flooding. Discharges from the project site include treated domestic sewer effluent, treated industrial plant effluent and attenuated storm water.

Impact assessment A storm water management plan has been developed for the site as required by the municipality as part of the rezoning of the land and the development of the site within an urban area. Implementation of the plan would result in increased runoff flows due to hardstanding areas within the plant. The plan includes provision for an upstream perimeter cut-off drain to minimise the volume of runoff entering the site and a separate system for the collection and handling of potentially dirty runoff (which would be kept to a minimum). In addition, an attenuation pond would be used to absorb the increased runoff volumes and attenuate the flow to a 1:5 year pre-development flood. The pond capacity would accommodate a volume of 350 m³/ha or the 1:25 year post-development run-off accumulated by the site, whichever is the greatest. The attenuation pond overflow would accommodate the 1:50 year flood. These storm water management measures would ensure that storm water run-off would have minimal effects on the natural flow regime, under normal rainfall events.

Operation of the sewage package plant would result in the generation of 2,5 m3 of treated sewage effluent per day (0,00007 m3/s), while the industrial waste water treatment plant would generate 5 652 m3 of industrial effluent per day (0,07 m3/s). While a number of alternatives for reuse and recycling of the treated investigated, it is likely that some (or all) of the treated effluents would be discharged to the Vaal tributary, via the concrete channel. In dry periods the flow in the Vaal tributary is driven by discharge from the Leeuwkuil Water Care Works, which is licenced to discharge 7.3 million m3 per annum (0,23 m3/s) (Department of Water and Sanitation, 2014). The discharge volumes from the sewage package plant and the

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industrial waste water treatment plant would be 30% of the licensed discharge flow from the Leeuwkuil water care works.

Alterations to drainage patterns would commence at the start of the construction phase as the site is developed, and reach a maximum discharge volume during operations. Without considering the flood-lines and in the absence of storm water controls, this could result in a prominent change in drainage patterns. With planned design controls and mitigation, only storm events greater than 1:50 would likely result in noticeable increases in runoff and collection within the system. This would, however, be for short periods of time, during/following a storm event.

An alteration of drainage patterns affecting the flow of water in downstream systems is assessed to be of MEDIUM significance without mitigation and VERY LOW with mitigation (see Table 7-5 below).

Mitigation The following measures are recommended (see EMPr in Section 8):  Maintain the storm water management system.  Undertake regular inspections and maintenance of the channel.  Reuse and recycle treated effluent within the plant as far as possible.  Maintain a dynamic climatic water balance for the site to inform water uses on site, attenuation of storm water and discharge requirements.

Monitoring The following monitoring is recommended (see EMPr in Section 8):  Measure flows within the plant and discharge volumes on a continuous basis (i.e. flow meters).

TABLE 7-5: IMPACT SUMMARY – ALTERATION OF DRAINAGE PATTERNS

Issue: Alteration of drainage patterns affecting the flow of water in downstream systems Phases: All Criteria Without Mitigation With Mitigation Intensity Prominent change or disturbance Minor change or disturbance Duration Only during/following flood events Only during/following flood events Extent Beyond the site boundary, affecting A part of the property immediate neighbours Consequence Medium Very Low Probability Probable Possible Significance Medium Very Low

Where developments take place downstream of the site and within the same Nature of cumulative impacts sub-catchment, discharges (depending on the discharge flow and rate) could increase flow in the system and increase the risk of downstream flooding. Degree to which impact can be Fully on cessation of discharge. reversed Degree to which impact may Unlikely. cause irreplaceable loss of resources Degree to which impact can be High with the implementation of appropriate engineering design. mitigated Residual impacts None expected.

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7.1.6 Issue: Discharges from the project affecting the quality of downstream freshwater resources Potential contamination impacts on surface water resources as a result of runoff or discharge from the project has been assessed from the perspective of aquatic ecosystems (see Section 7.1.4). It is assumed that if impacts on freshwater resources are mitigated in a way that addresses potential impacts on the aquatic ecosystem, then any potential impacts on human uses of downstream resources would indirectly be mitigated. A separate assessment has therefore not been included.

Water for the project will be sourced from Rand Water via the Emfuleni Local Municipality and therefore no groundwater will be abstracted from the site. Borehole abstraction was considered as an alternative supply option; however, due to the presence of dolomites on site this option presents potentially significant risks to the overall plant stability and has not been considered further.

7.1.7 Issue: Contamination of groundwater quality affecting the aquifer Description of impact Groundwater is a valuable resource and is defined as water which is located beneath the ground surface in rock pore spaces and in the fractures of lithologic formations. Activities on surface can result in seepage of contaminants into the groundwater system.

Impact assessment Seepage from spillages of fuels, lubricants and other potential contaminants as well as dirty surface water runoff or untreated effluent from activity areas could result in contamination of groundwater resources. Based on the material, expected size and expected frequency of spills a moderate reduction in groundwater quality could occur. Even though sources of contamination can be temporary in nature, related potential contamination can be long term. It is expected, however, that any potential contaminant plume would be restricted to the plant site due to the slow circulation of groundwater within the geological formations that occur on site. The nearest known groundwater users to the site are located between 1 and 2 km from the site (based on the DWS National Groundwater Archive). The aquifer on site (the Rippon Formation) has a low permeability and water circulates slowly within the formation therefore contaminant impacts on third party users are not anticipated.

During construction, spills and related seepage would be of short duration. Although the incident could be of short duration, potential contamination could occur for longer periods. During operations contamination of the aquifer is unlikely given the control measures that are planned for the project. Contamination of the aquifer is assessed to be of MEDIUM significance without mitigation and VERY LOW significance with mitigation (see Table 7-4 below).

Mitigation The following measures are recommended (see EMPr in Section 8):  Implement spill prevention, waste and effluent design controls measures.  Implement soil mitigation measures.

Monitoring The following monitoring is recommended (see EMPr in Section 8):  Monitor groundwater quality.

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TABLE 7-6: IMPACT SUMMARY – CONTAMINATION OF GROUNDWATER

Issue: Contamination of groundwater quality affecting the aquifer Phases: Planning and Design, Construction Criteria Without Mitigation With Mitigation Intensity Moderate change or disturbance Minor (Slight) change or disturbance Duration Long-term Medium-term Extent Whole site A part of the site boundary Consequence Medium Low Probability Probable Conceivable Significance Medium Very Low

Developments within the area could contribute to groundwater impacts Nature of cumulative impacts depending on the type of development and if it is associated with any potential groundwater contamination sources. Degree to which impact can be Possible with pumping and treatment, although due to the dolomites this reversed would need to be done in a manner that mitigates stability risks. Degree to which impact may Unlikely, with mitigation. cause irreplaceable loss of resources Degree to which impact can be High mitigated Once soil is removed from in situ and handled, the area of land and natural soil Residual impacts functionality would be permanently lost.

7.1.8 Issue: Increase in ambient air concentrations Description of impact Development of the site and operation of the plant presents activities that would contribute to current elevated ambient air concentrations. Pollutants of concern associated with the proposed project include particulate matter (PM), sulfur dioxide (SO2) and nitrogen dioxide (NO2). The site is located within the Vaal Triangle Airshed Priority Area where existing land use currently results in reduced ambient air quality. Ambient concentrations for PM2.5 and PM10 in the region have been recorded to exceed South African daily and annual average limits. The existing land uses in the region together with the proposed project present the potential for elevated/cumulative impacts.

The construction phase presents activities that are temporary in nature. The operational phase would present more long term activities and related emission sources. It is expected that residential and educational facilities would be most vulnerable to health risks from air quality. The assessment assumes that the Wise Owl pre-school would be relocated prior to construction. Potential air quality impacts on biodiversity are discussed in Section 7.1.3.

Greenhouse gas (CO2e) emissions from the operations are likely to arise primarily from fuel combustion in the boilers/vehicles (direct) and the consumption of imported electricity (indirect).

Impact assessment During construction dust generated from vegetation clearing, soil grubbing, material handling and the movement of vehicles on unsurfaced areas may contribute to elevated particulate matter levels in the air. In addition wind erosion from exposed materials could also contribute to elevated particulate matter levels. This could result in increased dustfall on a local scale and higher particulate matter loads. Emissions would also be generated by vehicles and other combustion-driven equipment (e.g. generators) that release nitrogen oxides (NOX), carbon dioxide (CO2), carbon monoxide (CO) and volatile organic compounds (VOC). With mitigation, and given that the construction phase is short term/temporary, the overall intensity and consequence of potential impacts would be low. The related significance is considered to be LOW without mitigation and VERY LOW with mitigation (Airshed Planning Professionals, 2018a).

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Operational activities present the most potential for negative air quality impacts. Atmospheric emissions would be generated from fuel combustion in the boilers (sources of SO2 and NOX), entrainment from vehicles on paved roads and materials handling (contributing to increased dustfall and particulate fractions), emissions generated by vehicle engines and other combustion-driven equipment (e.g. generators) (sources of NOX, CO2, CO and VOC). These activities would be conducted over a long period.

For the operational phase, air quality modelling predicted the following:

 PM10 and PM2.5 concentrations would be in non-compliance with the National Ambient Air Quality Standards (NAAQS) over the short- (up to 3 500 m off-site) and long-term (up to 460 m off-site).

 Simulated SO2 concentrations would be in non-compliance with the hourly, daily, and annual standards beyond the site boundary, if the boilers operate at the Minimum Emission Standards for controlled emitters.

 Simulated annual NO2 concentrations would comply with the annual NAAQS.  Dustfall rates would be below the National Dust Control Regulations (NDCR) limits for residential areas and non-residential areas off-site.

Following the initial modelling that informed the results above, additional scenario modelling was undertaken for the boilers to inform additional mitigation requirements. In this regard, with additional mitigation, the model predicted that compliance with PM10, PM2.5 and SO2 NAAQS could be achieved. The more significant impacts are expected for PM2.5 and PM10 emissions. For PM2.5 and PM10 the IFC contribution guideline would be met at 300 m and 100 m, respectively, from the facility. For SO2 the predicted emissions would be 8% of the NAAQS and would fall within the IFC contribution guideline.

The assessment considers the more significant impacts associated with PM2.5 and PM10 emissions. The impact on air quality and the related inhalation health impacts is considered to be of HIGH significance without mitigation and LOW significance with design controls and additional mitigation (see Table 7-7 below).

Mitigation The following measures are recommended (see EMPr in Section 8):  Design and manage the boiler plant as per the Subcategory 1.1 listed activity.  Mitigation of emissions from the maize and dry maize-product handling using cyclones, fabric filters, or a combination.  Mitigation of vehicle entrainment emissions from the paved access roads using a mechanical sweeper; strict enforcement of speed limits (maximum 20 km/h on access roads); covers for vehicles; and regular clean-ups of road spillages.

Monitoring The following monitoring is recommended (see EMPr in Section 8):  Ambient air quality and dustfall monitoring.  Emissions monitoring in accordance with the reporting requirements for Section 23 controlled emitters.  Emissions monitoring of maize wet mill control system chimneys.  Implementation of the reporting procedures.

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TABLE 7-7: IMPACT SUMMARY – INCREASE IN AIR QUALITY

Issue: Increase in ambient air concentrations Phases: All Criteria Without Mitigation With Mitigation Intensity Prominent change, disturbance or Minor change, disturbance or nuisance nuisance Duration Long-term Long-term Extent Local area, beyond the site boundary Whole site Consequence High Medium Probability Probable Possible Significance High Low

The baseline PM2.5 and PM10 concentrations are already non-compliant with Nature of cumulative impacts NAAQS. Depending on the type of developments within the area, additional contributions to air quality impacts could occur. Degree to which impact can be Low. reversed Degree to which impact may Possible. cause irreplaceable loss of resources Degree to which impact can be High. mitigated With design controls and mitigation it is unlikely that air quality health issues Residual impacts would be felt beyond the life of the project.

7.1.9 Issue: Increase in malodourous compounds Description of impact The maize wet milling and refining processes and industrial effluent waste water treatment plant could cause malodourous compounds to be released into the environment. These could result in SO2 pungent odours from slurries, a burnt odour, acrid odours when total volatile organic compound (TVOC) contain acetic acid and acetaldehyde, rancid odours when TVOC profiles contain butyric and valeric acids and fruity smells from a range of aldehyde compounds. Various malodour compounds, including hydrogen sulfide (H2S), could be released from the waste water treatment plant. It is expected that residential and educational facilities would be most vulnerable to this type of disturbance from the proposed project. The assessment assumes that the Wise Owl pre-school would be relocated prior to construction. Potential impacts would be associated with the operational phase only.

Impact assessment Emissions of malodourous compounds from the facility were not quantified due to the detailed information required to quantify emissions (which was not available at this stage). To understand the potential for significant odour impacts, the annual average TVOC concentrations were conservatively assumed to be representative of benzene concentrations (to compare with the NAAQS). Air quality modelling of project emissions predicted that TVOC concentrations could exceed the annual benzene NAAQS if all TVOCs are assumed to be benzene. Exceedances of the benzene NAAQS would be possible up to 300 m from site boundary. However, the TVOC profile is likely to include many compounds and therefore compliance with the benzene standard is expected (Airshed Planning Professionals, 2018a).

The air quality specialist is of the opinion that where control systems are included in the engineering design and operation of the overall plant, potential impacts could be minimised. Other existing processes resulting in malodourous emissions in the vicinity of the project, including a large scale municipal waste water treatment works and an abattoir with a rendering plant, are likely to mask impacts from the proposed plant. The related significance is considered to be VERY LOW, even without mitigation (see Table 7-8 below).

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Mitigation As the impact is of very low significance, no mitigation is required. However design controls would be required.

Monitoring The following monitoring is recommended (see EMPr in Section 8):  Passive monitoring of TVOCs during regular short-term campaigns.  Periodic emissions measurements campaigns.

TABLE 7-8: IMPACT SUMMARY – INCREASE IN ODOUR

Issue: Increase in malodourous compounds Phases: All Criteria Without Mitigation With Mitigation Intensity Minor change, disturbance or Minor change, disturbance or nuisance nuisance Duration Medium-term Medium-term Extent Whole site Whole site Consequence Low Low Probability Possible Possible Significance Very Low Very Low

Developments within the area that contribute malodourous compounds could contribute to nuisance impacts on third party receptors. The developments, Nature of cumulative impacts however, are likely to fit within the existing and planned commercial/industrial use of the area. Degree to which impact can be Low. reversed Degree to which impact may Not applicable. cause irreplaceable loss of resources Degree to which impact can be High. mitigated Malodourous compounds would only be produced for the life of the plant and Residual impacts therefore no residual impacts expected.

7.1.10 Issue: Increase in disturbing noise levels affecting potential human receptors Description of impact Construction and operation of the plant as well as project-related traffic presents activities that would contribute to current ambient noise levels. Project activities have the potential to cause a noise disturbance and/or nuisance at potentially sensitive receptors. A maximum increase in noise levels of 3 dBA above background levels was used to inform the assessment (IFC noise guideline). For a person with average hearing acuity, an increase of less than 3 dBA in the general ambient noise level is not detectable (Airshed Planning Professionals, 2018a).

Noise pollution will have different impacts on different receptors because some are very sensitive to noise and others are not. It is expected that residential and educational facilities would be most vulnerable to noise disturbances from the proposed project. The assessment assumes that the Wise Owl pre-school would be relocated prior to construction. Potential noise impacts on biodiversity are discussed in Section 7.1.3.

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Impact assessment Noise modelling predicted that during the day an increase of 3.8 dBA is expected along the southern boundary of the correctional services buildings/property and at the correctional services staff accommodation (potentially affecting four staff houses) (an increase of 3.2 dBA). At night, the modelling predicted an increase of 3.3 dBA along the southern boundary of the correctional services buildings/property. This could result in moderate change or discomfort to human receptors. These predicted increases in noise levels are expected to result in ‘little’ to ‘sporadic’ reaction from the correctional services and staff accommodation during the day and the correctional services at night. No other receptors are predicted to have an increase in noise levels of above 3 dBA.

When considering material handling and vehicle movement on site, these will make use, to varying degrees, of reverse alarms and hooters. If unmitigated these could result in numerous noise complaints, especially where these activities take place at night.

Impacts are expected in both the construction and operational phases. The impact on human noise receptors is considered to be of MEDIUM significance without mitigation and LOW significance with design controls and mitigation (see Table 7-9 below).

Mitigation The following measures are recommended (see EMPr in Section 8):  Keep all equipment and machinery in proper working order.  Minimise vehicle-related noise emissions.  Implement an equipment and vehicle maintenance programme.  Register and address any noise complaints.

Monitoring The following monitoring is recommended (see EMPr in Section 8):  Undertake noise monitoring at the correctional services staff accommodation and livestock fairgrounds.  Where monitoring indicates unacceptable impacts at receptors, consider and implement additional mitigation measures in line with specialist recommendations.

TABLE 7-9: IMPACT SUMMARY – INCREASE IN DISTURBING NOISE

Issue: Increase in disturbing noise levels affecting potential human receptors Phases: All Criteria Without Mitigation With Mitigation Intensity Moderate change, disturbance or Negligible change, disturbance or discomfort nuisance Duration Long-term, to end of operations Long-term, to end of operations Extent Beyond the site boundary, affecting Whole site immediate neighbours Consequence Medium Low Probability Probable Probable Significance Medium Low

Developments within the area could contribute to noise impacts on third party Nature of cumulative impacts receptors. The developments, however, are likely to fit within the existing and planned commercial/industrial use of the area. Degree to which impact can be Low. reversed Degree to which impact may Not applicable. cause irreplaceable loss of resources

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Degree to which impact can be High. mitigated With mitigation it is unlikely that noise induced stress and related health issues Residual impacts would be felt beyond the life of the project.

7.1.11 Issue: Alteration of the visual environment Description of impact Development of the plant and related services infrastructure has the potential to alter the visual environment and aesthetics of the site.

Visual/aesthetic value is the emotional response derived from the experience of the environment with its natural and cultural attributes. The response is usually to both visual and non-visual elements and can embrace sound, smell and any other factors having a strong impact on human thoughts, feelings and attitudes (Young, 2018).

Impact assessment Development of the site will result in a series of structures which do not currently exist. These structures would have a physical presence and would change the fabric and character of the landscape. However, within the context of existing industrial developments along the R59 highway and on nearby sites, the proposed structures would not contrast strongly with existing activities or facilities. While the site is highly visible, the most prominent public views are from the R59 and R28 roads. The users of these roads are likely to be sensitised to industrial development in this area. Residents of Leeuhof, the Correctional Services complex and institutions to the east of the R59 highway could have a higher sensitivity to the project. Other than for local road users, the visual exposure to the project would generally be a middle ground or more distant view.

The visual impact would occur incrementally during construction, reaching a peak as the structures are erected and then declining partially as the cladding, finishes and landscaping are installed. The impact on the visual environment is considered to be of MEDIUM significance without mitigation and of LOW significance with design controls and mitigation during operations (see Table 7-10 below). Limited mitigation is available during the construction phase however, this is only expected to be for a two year period.

Mitigation The following measures are recommended (see EMPr in Section 8):  Implement dust suppression during construction.  Maintain tree screens along the north, east and south of the site.  Maintain landscaped areas as natural landscapes rather than park-type landscapes.  Undertake regular maintenance and upkeep of the aesthetics of the plant.

TABLE 7-10: IMPACT SUMMARY – ALTERATION OF THE VISUAL ENVIRONMENT

Issue: Alteration of the visual environment Phases: All Criteria Without Mitigation With Mitigation Intensity Moderate change, disturbance or Minor (Slight) change, disturbance or discomfort nuisance Duration Long term, to end of operations Long term, to end of operations Extent Local area, extending far beyond site Beyond the site boundary, affecting boundary. immediate neighbours Consequence High Medium Probability Possible/frequent Conceivable Significance Medium Low

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The development fits within the existing and planned commercial/industrial Nature of cumulative impacts use of the area. Thus while the change is noticeable at the site scale, it is not considered significant at the area scale. Removal of the facility and rehabilitation of the land would reverse the impact. Degree to which impact can be However, this is considered unlikely. Once developed as an industrial site, reversed future use would likely remain industrial/commercial. The impact is not reversible. Degree to which impact may While the visual environment and aesthetics of the site will be altered, the cause irreplaceable loss of development will have its own character and no irreplaceable loss is resources anticipated. Degree to which impact can be Appropriate use of architectural style, building materials and landscaping can mitigated mitigate that visual impact to a large degree. No residual impact is anticipated. Once built the structure will form part of the Residual impacts altered visual environment and aesthetics of the site.

7.2 IMPACT ON SOCIO-ECONOMIC ENVIRONMENT

7.2.1 Issue: Economic impact (positive and negative) Description of the impact The development of a project of this nature has the potential to impact on the economy both positively through potential growth in the industry and agricultural sectors and diversification of the local economy and negatively through the potential loss of existing economic activities. This section focuses on the potential positive and negative economic impacts associated with the project and assesses these collectively.

The loss of grazing land affecting the livelihoods of farmers is assessed separately in Section 7.2.4.

Impact assessment There is predicted to be a direct positive economic impact on the local, regional and national economies in both the construction and operational phases. Approximately 800 temporary and 210 permanent jobs would be created in the construction and operational phases respectively. Direct benefits would be derived from wages, taxes and profits. Indirect benefits would be derived through the procurement of goods and services, and the increased spending power of employees. Positive economic impacts could include (Mercury Financial Consultants, 2018):  Revenue generation of approximately R42.9 billion over the life of the project in present terms;  An estimated amount of R36.8 million (for the construction phase) and R1.4 billion (over the life of the plant) in present value would be spent on employment;  Increase in secondary sectors supported by the demand of the project for construction materials, equipment, goods and services required for the ongoing plant operations.

In addition to the direct and indirect economic impacts discussed above, the project will through its corporate social investments and transformation imperatives, would contribute towards the local economic development in the area. The operation of the plant is anticipated to have the following positive socio- economic benefits to its employees and surrounding communities:  development of skills through its skills development plan;  learnership programmes to provide learners with an occupational qualification;  investment in infrastructure development through local economic development and integrated development programmes;  supplier and enterprise (SMME) development.

The land needed for the project is owned by SAB and would likely be transferred or sold to the future owners of the plant. Therefore no negative economic loss is expected, even in the unmitigated scenario.

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When considering alternative feasible land uses for the project site such as agriculture (and more specifically maize farming which would yield the best economic results), the economic study has calculated that the economic benefits of the plant (over a 20 year period) are predicted to significantly outweigh the potential revenue of R2.3 million of 22 years that may be realised from commercial farming and the loss in value of alternative land uses.

The impact would occur from the start of the construction phase through to the operational phase. The overall significance is likely to be a HIGH positive without mitigation increasing to a VERY HIGH positive with mitigation (see Table 7-11 below).

Mitigation The following measures are recommended (see EMPr in Section 8):  Implement recruitment and procurement policies and procedures  Implement local corporate social investment strategies  Implement influx management plan  Implement health management plan for employees.

TABLE 7-11: IMPACT SUMMARY – ECONOMIC IMPACT (POSITIVE AND NEGATIVE)

Issue: Economic impact (positive and negative) Phases: All Criteria Without Mitigation With Mitigation Intensity Prominent change or improvement Substantial change or improvement Duration Long-term Very long, permanent Extent Local area, extending far beyond the Local area, extending far beyond the site boundary site boundary Consequence High Very High Probability Probable Probable Significance High (positive) Very High (positive)

Any other feasible developments within the area would contribute to a Nature of cumulative impacts positive economic impact. Degree to which impact can be Not applicable reversed Degree to which impact may Not applicable cause irreplaceable loss of resources Degree to which impact can be High mitigated Positive economic impacts could extend beyond the life of the plant through Residual impacts training and skills development.

7.2.2 Issue: Social benefits associated with employment and economic development Description of the impact Employment and economic development has the potential to improve livelihoods of individuals living in the local area through increased disposable income for individuals and households and the flow of revenue into local services and support sectors.

Impact assessment Unemployment is a key issue for the Vereeniging area. There are a high number of job seekers and discouraged workers, in part due to due to general economic downturn in South Africa and the decline in the steel and mining sectors. New employment opportunities are likely to be of direct economic benefit at the

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local and regional level. The number of new employment opportunities may, however, be limited for local people, as professional and skilled positions are likely to be brought in from other areas of South Africa or from outside South Africa. In addition, contractors may make use of existing staff during construction, which could limit the real number of new skilled, semi-skilled and unskilled opportunities. Despite this, there is likely to be an increase in employment locally, as the high number of opportunities during construction (800) is likely to have a notable impact on the temporary employment sector. During operations, it is expected that any skilled individuals brought into the area would likely become local residents, potentially contributing towards local economic stability.

The direct impact of employment opportunities and indirect local economic improvement as well as local economic investment and development could contribute towards improving the quality of life for local communities. This may include increased disposable income for individuals and households. A potential positive local social impact could occur in the construction and operational phases.

The investment of capital into a new development project, such as the proposed project and the operation of the plant, would likely have a trickle-down effect in terms of supporting local industries and the flow of revenue into local services and construction sectors. This in turn supports the development of the local economy through enabling businesses to grow or maintain their economic contribution. Where economic benefits are spread out over municipal or regional economies, the economic impact on local communities would likely be diluted.

The proposed development, although sponsored initially by corporate investors, would be majority Black- Owned and would be the first Black-Owned maize wet mill plant in South Africa. The Special Vehicle Company (SPV) would ultimately be responsible for the construction and operation of the facility. It is anticipated that the Broad-Based Black Economic Empowerment (BBBEE) partner may be a consortium of companies and/or individuals, who may be from the local area (Vereeniging) or further afield (Johannesburg/another province).

The degree to which this impact would benefit local people and communities depends on a number of factors. This includes, the number of new opportunities realised locally (i.e. not through existing contractors who have staff or people brought in from outside the local area), and the manner in which income is used to benefit households and individuals (that is, spending on positive aspects such as education and food versus on negative social behaviour such as drug and alcohol abuse). The latter aspects are outside of the control of this project, but the former can be improved through specific internal policy development and implementation.

The degree to which this impact would benefit local people and communities depends on the number of new opportunities realised locally (i.e. not through existing contractors who have staff) and the manner in which income is used to benefit households and individuals (that is, spending on positive aspects such as education and food versus on negative social behaviour such as drug and alcohol abuse).

Social benefits during the construction phase would be temporary (for a period of two years) and would likely be diluted due to the largely industrialised nature of the area and the very large local urban population. Greater benefits, however, could be secured where local labour and procurement are prioritised during the construction phase. A similar situation is expected during the operational phase, although employment could be longer and for the duration of the plant’s operations. Nonetheless, the promotion of employment in South Africa is always supported and is seen as a direct positive benefit of the project. Permanent employment of local people would help in improving the livelihoods of individuals living in the local area.

The impact would occur from the start of the construction phase through to the operational phase. The overall significance is likely to be a LOW positive without mitigation increasing to a MEDIUM positive with mitigation (see Table 7-12 below). Key to realising the mitigated significance is to recruit employees and procure services locally as far as possible.

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TABLE 7-12: IMPACT SUMMARY – SOCIAL BENEFITS

Issue: Social benefits associated with employment and economic development Phases: All Criteria Without Mitigation With Mitigation Intensity Minor change or improvement Minor change or improvement (Negligible during construction) Duration For the construction period (2 years) For the construction period (2 years) and then long term, to end of and then long term, to end of operations operations Extent Regional / National Regional / National Consequence High High (Low during construction) (Medium during construction) Probability Unlikely Conceivable (Probable during construction) (Probable during construction) Significance Low (positive) Medium (positive)

Any other feasible developments within the area would contribute to positive Nature of cumulative impacts social benefits. Degree to which impact can be Not applicable, as this is a positive impact. reversed Degree to which impact may Not applicable, as this is a positive impact. cause irreplaceable loss of resources Degree to which impact can be Possible for mitigation to increase the positive significance of potential mitigated impacts. Residual impacts can occur, either positive or negative, depending on the manner in which income is used to benefit households and individuals (that is, Residual impacts spending on positive aspects such as education and food versus on negative social behaviour such as drug and alcohol abuse).

7.2.3 Issue: Changes in land value Description of the impact Development and operation of the site could impact on land values both positively and negatively. Positive impacts are observed where the project site value is expected to increase due to the capital investment and the fact that land zoned for industrial purposes in the project locality is valued higher than agricultural land. Negative impacts are observed when the value of land surrounding operations is compromised by unacceptable negative environmental and social impacts.

Impact assessment Based on municipal valuations, the value of land with infrastructure is significantly higher than that for vacant land or even vacant agricultural land with medium agricultural potential. This provides an indication that the establishment of infrastructure will significantly increase the value of the land (Mercury Financial Consultants, 2018). Even without mitigation, an increase in property value is expected.

In the unmitigated scenario it is probable that land surrounding the project would experience unacceptable social and environmental impacts, which would likely cause a loss in related land values. In the scenario

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where the project successfully implements the stipulated environmental and social management measures, these impacts can be managed to acceptable levels. Although it is difficult to predict the potential changes in land value of surrounding properties, with mitigation it is expected that these would be positive (Mercury Financial Consultants, 2018).

The overall significance is likely to be a VERY LOW negative without mitigation increasing to a VERY HIGH positive with mitigation (see Table 7-12 below).

Mitigation The measures recommended in the EMPr (see Section 8) should be implemented to prevent unacceptable negative environmental and social impacts.

TABLE 7-13: IMPACT SUMMARY – CHANGES IN LAND VALUE

Issue: Changes in land value Phases: All Criteria Without Mitigation With Mitigation Intensity Moderate change or disturbance Prominent change or improvement Duration Long term Permanent Extent Beyond the site boundary, affecting Beyond the site boundary, affecting neighbours neighbours Consequence Medium High Probability Unlikely Probable Significance Very Low Very High (positive)

Any other feasible developments within the area could contribute to changes Nature of cumulative impacts in land value, either positively or negatively. Degree to which impact can be Reversing negative impacts would be possible. reversed Degree to which impact may Not applicable cause irreplaceable loss of resources Degree to which impact can be High mitigated Changes in land value could extend beyond the life of the plant depending on Residual impacts the post-operational land use.

7.2.4 Issue: Reduction in grazing land affecting livelihoods of local farmers Description of impact The project site is open land comprising secondary grasslands which is used for informal livestock grazing. The dryland agricultural potential of soils that would be disturbed by the project is considered to be medium to low due to poor internal drainage which becomes waterlogged during wet seasons. The topsoil is sandy and has low natural fertility and would require careful nutrient management for crop production.

The livestock grazing is undertaken by the Emfuleni Livestock group through the Leeuwkuil Communal Kraal. Development of the plant, with an area of 24.3 ha, would result in a permanent change and a loss of this land for grazing purposes.

A portion of the proposed project site (Erf 188) is zoned Special Use while the remaining portion of the site is formally zoned for agricultural use. The proposed development is in keeping with the proposed and surrounding land use for the area, namely industrial use and will contribute towards the economic development and infill of industrial area within the Vereeniging area as indicated in the Spatial Development Framework.

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Impact assessment The site constitutes approximately 8% of the total informal grazing land used within the immediate area of the kraals and is used throughout the year. The site is located on privately-owned land (owned by SAB) and there is no formal agreement in place (legal or verbal) to use this site for grazing. However, this land together with the surrounding vacant land is indicated to have been used informally for grazing for about 18 years (by the Emfuleni Livestock Executive Committee). The proximity of the site to the kraals is a key factor in its daily use however other areas already used for grazing can continue to be used. While the livestock owners do not have any legal right to the use of the land, they do rely on the land to support their livelihoods.

The loss of grazing land, especially in winter, could result in the farmers needing to buy additional feed to supplement grazing of the cattle. Although this is already a common practise during winter months and when the grass has been burned. The specialist is of the opinion that the loss of grazing land is unlikely to undermine future grazing practices but may increase existing grazing pressures.

The impact would occur from the start of the construction phase through to the operational phase. The overall significance is likely to be a LOW negative without mitigation increasing to a VERY LOW positive with mitigation where potential socio-economic benefits are realised (see Table 7-14 below).

Mitigation No direct mitigation is possible as potential alternative land in the area is already being used for grazing. However, as the impact is of low significance, mitigation is not required. The only concession would be for grazing to continue on areas surrounding the plant until such time as the landowner chooses to develop or sell the land. Where Corporate Social Responsibility initiatives (or similar plans) are considered for the project preference should be given to the Emfuleni Livestock Group (see EMPr in Section 8).

TABLE 7-14: IMPACT SUMMARY – REDUCTION IN GRAZING LAND

Issue: Reduction in grazing land affecting livelihoods of local farmers Phases: All Criteria Without Mitigation With Mitigation Intensity Minor change or disturbance Negligible change (positive) Duration Long term Long term Extent Whole site Whole site Consequence Medium Low Probability Possible Possible Significance Low (negative) Very low (positive)

Where other developments are established within the kraal’s informal grazing Nature of cumulative impacts area, the cumulative loss of grazing land would increase. Degree to which impact can be Unlikely reversed Degree to which impact may The loss of land as a resource for informal grazing would be permanent. cause irreplaceable loss of resources Degree to which impact can be Possible to some extent through Corporate Social Responsibility initiatives. mitigated Residual impacts No residual impacts expected

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7.2.5 Issue: Disturbance to third party road users by project-related traffic Description of impact The road network surrounding the site is a well-established public road network used for motorised and non- motorised transport as well as by pedestrians. Increased traffic on existing public road networks and introduction of heavy vehicles, in both the construction and operational phases, can result in reduced road capacity, greater accidents (for people and animals) and/or increased road damage. This in turn can put pressure on the relevant roads authority to increase the maintenance programmes and/or upgrade the roads.

The assessment below considers the level of service (LoS) (road capacity) affecting third party road users and safety related impacts of third party road users. From a capacity perspective, only intersections that were found to operate at an unacceptable LoS with the addition of the project are considered below.

Impact assessment Project-related traffic has the potential to cause congestion on the roads due to an increase in light and heavy vehicles, degrade roads due to the type of vehicles and/or a result in a number of incidents which could cause serious injury and/or death to third parties including pedestrians and animals. This applies to both the construction and operational phases. The construction phase would present abnormal heavy loads, although these are expected to be infrequent, while the construction and operational phases would require the transport of materials, some of which would be hazardous. In the absence of mitigation, the use of the Boy Louw Street (R28) and Theunis Kruger Street intersection and the access point to the plant would present a potential risk to third party road users. The intersection of Boy Louw Street (R28) and Theunis Kruger Street intersection already operates at an unacceptable/problematic LoS and no formal access to the project site exists. The project has the potential to worsen this situation. With design controls the LoS of Boy Louw Street (R28) and Theunis Kruger Street intersection would improve to between Good and Very Good while the access to the site would have a LoS of Very Good.

The overall significance is likely to be a HIGH (negative) without mitigation improving to LOW (positive) with design controls and mitigation (see Table 7-15 below).

Mitigation The following measures are recommended (see EMPr in Section 8):  Maintain road and traffic upgrades.  Maintain all equipment and vehicles in proper working order  Take care when placing signage in close proximity of access points.  Co-ordinate the transport of any abnormal heavy loads with the relevant roads department.  Comply with Hazchem requirements for the transport of any hazardous substances.  Report any issues pertaining to damages and poor road conditions in close proximity of the project to the applicable authority and custodian of the respective roads.  Handle any road accident involving or caused by project related traffic in accordance with the emergency response procedure.

Monitoring The following monitoring is recommended (see EMPr in Section 8):  Monitor and evaluate use of relevant road intersections.

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TABLE 7-15: IMPACT SUMMARY – PROJECT-RELATED TRAFFIC

Issue: Disturbance to third party road users by project-related traffic Phases: All Criteria Without Mitigation With Mitigation Intensity Moderate disturbance Prominent improvement Duration Long term Short term Extent Local area, beyond the site boundary Whole site Consequence High Medium Probability Definite Conceivable Significance High (negative) Low (positive)

Not expected, as the assessment took into account the future land use of the Nature of cumulative impacts whole site (light manufacturing) and not only the project’s contribution. This provides for 35 % spare capacity in the proposed road upgrades. Degree to which impact can be Any accidents that occur as a result of project related traffic is non-reversible. reversed Degree to which impact may Could result in serious injury or death of people or animals. cause irreplaceable loss of resources Degree to which impact can be High mitigated Any accidents that occur as a result of project related traffic would likely have Residual impacts residual impacts. The potential for accidents would, however, cease if and when operations cease.

7.2.6 Issue: Increase in safety risks to third parties and communities Description of the impact The development and operation of the plant includes a number of activities that could present safety risks to third parties and surrounding communities. Safety risks as a result of project-related traffic are assessed in Section 7.2.5.

Impact assessment There will be a change in nature of the site during the construction phase, as the site currently comprises open grassland. The risk to the pre-school is considered to be the main potential impact but the applicant has committed to support the local municipality in the relocation of the pre-school. This process has already been initiated.

The introduction of construction activities, large machinery and vehicles, and the presence of a large number of construction workers could negatively affect public safety. The safety risk to the herdsmen and cattle (grazing around the site and crossing Boy Louw Street) and pedestrians (crossing the open land) could be increased during construction. The site is, however, likely to be fenced off to prevent accidental or deliberate access to the site.

An influx of people to the site or area in search of employment opportunities could pose safety risks to local businesses, land users and residents at the correctional services accommodation if unrest occurs.

In the absence of mitigation, any potential injury to third parties, infrastructure or animals could be severe and have a long term impact.

The overall significance is likely to be HIGH without mitigation reducing to INSIGNIFICANT with planning, design controls and mitigation (see Table 7-16 below).

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Mitigation The following measures are recommended (see EMPr in Section 8):  Fence the site at the start of construction to prevent accidental or deliberate access to the site.  Maintain security and access control.  Undertake regular patrols of the plant perimeter.  Undertake community awareness programme.  Handle any injury or death in accordance with the emergency response procedure.

TABLE 7-16: IMPACT SUMMARY – SAFETY RISKS

Issue: Increase in safety risks to third parties and communities Phases: All Criteria Without Mitigation With Mitigation Intensity Prominent change or disturbance Negligible change or disturbance Duration Long-term Long-term Extent Beyond the site boundary, effecting Beyond the site boundary, effecting neighbours neighbours Consequence High Low Probability Probable Unlikely Significance High Insignificant

Unless multiple developments occur in the area at the during the same time Nature of cumulative impacts period, cumulative impacts are unlikely. Degree to which impact can be Any accidents that occur as a result of uncontrolled third party access to the reversed site would be non-reversible. Degree to which impact may Could result in serious injury or death of people or animals. cause irreplaceable loss of resources Degree to which impact can be High mitigated Any accidents that occur as a result of access to the site would likely have Residual impacts residual impacts.

7.2.7 Issue: Change in land use affecting sense of place Description of the impact The development of the site from open grassland to an industrial site will change the nature of the site. A number of impacts of varying spatial scale and significance have been identified through the EIA process. These have the potential to change the way the site is experienced. The activities and land-uses within the area are common within the sub-region and show signs of deterioration due to industrial and utility activities. The general landscape does not evoke a strong or positive sense of place (Young, 2018). The more significant receptor groups are expected to be the informal grazing activities, residential areas and commercial facilities located within 300 m of the project site and to a lesser extent, similar land uses up to approximately 2 km from the site (Nomad Consulting, 2018).

Potential air quality and noise impacts have been assessed in Sections 7.1.8 and 7.1.10 respectively. The assessment below assumes that the pre-school would be relocated prior to construction.

Impact assessment The proposed development will be industrial in nature and will transform the largely underdeveloped site of open grassland into an industrial facility. The proposed development would, however, correspond with the industrial nature of some of the surrounding land uses (e.g. fresh produce market, substation, service yards, and the SAB depot) and is consistent with the areas being zoned as industrial.

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The only community/group that uses the proposed development site is the cattle herders, and there is no apparent social connection to the site, other than informal use (i.e. grazing) (Nomad Consulting, 2018). Other nearby land uses such as residential and educational areas are expected to have varying levels of social connection to the area surrounding the site. The development does, however, correspond with the industrial nature of some of the surrounding land uses (e.g. substation, service yards, and the SAB depot) and is consistent with the area being zoned as industrial (Nomad Consulting, 2018).

Changes introduced into the existing landscape as a result of the project would start at the construction phase and continue through to operations. It is expected that once the development is in place and the presence of the plant becomes a familiar component of the environment, the operational phase should have a negligible change on the overall sense of place.

In the absence of mitigation, a minor change or disturbance to the sense of place is expected. With mitigation this can be reduced. The overall significance is likely to be a LOW without mitigation and VERY LOW with mitigation (see Table 7-17 below).

Mitigation The following measures are recommended (see EMPr in Section 8):  Effective implementation of all mitigation measures as outlined in the EMPr to reduce the overall impact on the environment and surrounding land uses.

TABLE 7-17: IMPACT SUMMARY – CHANGE IN LAND USE

Issue: Change in land use affecting sense of place Phases: All Criteria Without Mitigation With Mitigation Intensity Minor change or disturbance Negligible change or disturbance Duration Long-term Long-term Extent Beyond the site boundary, affecting Beyond the site boundary, affecting immediate neighbours immediate neighbours Consequence Medium Low Probability Possible Conceivable Significance Low Very Low

The development fits within the existing and planned commercial/industrial Nature of cumulative impacts use of the area. Thus while the change is noticeable at the site scale, it is not considered significant at the area scale. Removal of the facility and rehabilitation of the land would reverse the impact, Degree to which impact can be at least in part. However, this is considered unlikely. Once developed as an reversed industrial site, future use would likely remain industrial/commercial. The impact is not reversible. Degree to which impact may While the sense of place will be altered, the development will have its own cause irreplaceable loss of character and no irreplaceable loss is anticipated. resources Degree to which impact can be Appropriate use of architectural style, building materials and landscaping as mitigated well as on-going maintenance can mitigate the impact to a large degree. No residual impact is anticipated. Once built the structure will form part of the Residual impacts altered environment and aesthetics of the site.

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7.3 IMPACT ON HERITAGE RESOURCES (INCLUDING PALAEONTOLOGICAL RESOURCES)

7.3.1 Issue: Disturbance of ground resulting in damage to heritage resources Description of impact Construction of the plant infrastructure and related services has the potential to damage or uncover heritage resources through direct physical disturbance.

Heritage resources are places or objects of cultural significance and are protected by the National Heritage Resources Act, 1999. The Heritage Impact Assessment undertaken for the site did not identify any heritage resources on the site. The desktop Palaeontological Impact Assessment indicated that although the region potentially has fossils, borehole drilling on the site did not identify sediments which could contain fossils.

Impact assessment Given that no heritage resources, of the type and range outlined in Section 3 of the National Heritage Resources Act, 1999 occur on the site, no impact is anticipated during the construction or operational phase. Once excavations commence it is, however, possible that heritage resources may be exposed by project activities, and in such cases a Chance Find Protocol must be implemented.

Mitigation No mitigation measures are recommended, except in the case of the uncovering of a heritage resource:  Implement Chance Find Protocol (see Section 8.7).

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8 ENVIRONMENTAL MANAGEMENT PROGRAMME

8.1 INTRODUCTION This Environmental Management Programme (EMPr) has been complied as part of the Basic Assessment process and in compliance with Appendix 4 of the EIA Regulations 2014 (as amended). The purpose of this EMPr is to ensure that impacts associated with the project are avoided and, where they cannot be avoided, are kept to a minimum and rehabilitated. The EMPr, which has as its basis the technical design controls and mitigation measures listed in the Basic Assessment Report, sets environmental objectives and actions against which the project’s environmental performance can be measured.

For each of the planning and design, construction and operation phases, the EMPr presents the related environmental objectives and goals, roles and responsibilities, management action plans and monitoring requirements.

On an ongoing basis, new activities will be identified and addressed and obsolete ones removed, particularly when new or changed methods and/or equipment are used. If required, the EMPr will be amended as required and submitted to GDARD for approval.

The details and expertise of the EAP who prepared the EMPr are included in Section 3.

The activities covered by the EMPr are described in detail in Section 4. A map of the proposed activity is included in Section 4. No environmental sensitivities exist on or near the project site and therefore apart from the 1:100 year flood line there are no areas that need to be avoided or any applicable buffers.

8.2 PLANNING AND DESIGN PHASE This section caters for the planning and design phase which would be undertaken pre-construction and would be used to inform contractor contracts.

8.2.1 Environmental objectives and specific goals The environmental objectives and goals outlined for each phase of the project (see Section 8.3 for construction and Section 8.4 for operations) will be taken into account during the planning and design phase.

8.2.2 Roles and responsibilities The Applicant (holder of the environmental authorisation) is ultimately responsible for the implementation of the EMPr and the financial cost of all environmental control measures. The applicant must ensure that any person acting on its behalf complies with the conditions / specifications contained in this EMPr. The applicant must ensure that the planning and design of the project includes the control measures outlined in Section 8.2.3.

8.2.3 Management action plan The pre-construction action plan is presented in tabular format (see Table 8-6). The action plan must be implemented during the planning and design phase (pre-construction). The responsible party would be the applicant/Owners and Managers of the plant.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

TABLE 8-1: MANAGEMENT ACTION PLAN – PLANNING AND DESIGN

Aspect Control measures Relocation of  Prior to construction, relocate the Wise Owl pre-school to a site with suitable zoning for an educational facility of this nature and where it would remain suitable for the school the Wise Owl children that attend. pre-school  Clearly communicate relocation plans in a manner that ensures transparency. Management  Develop an environmental management system for the site. The system will be based on the principles of ISO 14001 and provide for resources, planning, controls, evaluation system and improvement. The management system will be implemented from the start of construction.  Appoint a suitable Environmental Control Officer (ECO) for the duration of the construction works to monitor compliance with the EMPr and act as a liaison between local communities and the project.  Plan for environmental awareness and training of employees as per Section 8.6. Approvals  Apply for relevant authorization under the National Water Act and adhere to any conditions.  Apply for relevant approvals from the roads authorities and adhere to any conditions.  Apply for any necessary Sasol wayleaves and adhere to any conditions. Scope and  Plan and design the plant in line with the project scope outlined in Section 4 of the BAR as well as the measures detailed in Table 8-2 below. footprint  Limit the project footprint to that proposed. Physical disturbance must be less than 20 ha.  Locate the plant outside of the 1:100 year flood line. 3  Limit storage of dangerous goods to less than 500 m .  Back-up power generation using diesel must be less than 20MW. Procedures  Develop procedures for: - incident response and management; - the storage, handling and transportation of waste from site in line with the requirements of the NEM:WA Norms and Standards; - alien invasive plant management; - rehabilitation and landscaping; - equipment and vehicle maintenance including a schedule. Method  Develop method statements for the following: statements - site clearance, preparation and earthworks; - fire control; - batching; - spill clean-up; - storage and handling of dangerous goods. Monitoring  As a general approach, the site will ensure that the monitoring programmes comprise the following: - a formal procedure; - appropriately calibrated equipment; - where samples require analysis they will be preserved according to laboratory specifications; - an accredited, independent, commercial laboratory will undertake sample analyses; - parameters to be monitored will be identified in consultation with a specialist in the field and/or the relevant authority; - if necessary, following the initial monitoring results, certain parameters may be removed from the monitoring programme in consultation with a specialist and/or the relevant authority; - monitoring data will be stored in a structured database; - data will be interpreted and reports on trends in the data will be compiled by an appropriately qualified person; - both the data and the reports will be kept on record for the life of plant.

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Aspect Control measures Stakeholder  Develop a stakeholder communication and engagement strategy and plan that includes communication mechanisms, a database that recognises all stakeholder groups, engagement meaningful and transparent communication, information sharing (including safety risks associated with the project, addressing grievances and reporting back on monitoring results), on-going monitoring to ensure that the strategy is up to date, and follow up auditing.  Develop a formal complaints (grievance) procedure that incorporates measures for receiving, responding, tracking and recording complaints and grievances from all stakeholders. All registered complaints will be documented, investigated in a timeously manner and efforts made to address the area of concern where possible. Where required specific monitoring must take place. Economic and  Plan and develop a majority Black-Owned plant that meet’s transformation imperatives. social  Develop recruitment and procurement policies and procedures that: development - prioritise local employment, with a focus on semi-skilled and skilled positions being made available to local people as far as possible; - source contractors and service providers from within Emfuleni Local Municipality, and specifically Vereeniging, where possible; - provide training and skills development to the youth, prospective employees and local businesses; - establish a procurement mentorship programme for local and black owned businesses including youth and women owned businesses.  Develop local corporate social investment strategies in consultation with the relevant authorities. Give preference to the Emfuleni Livestock Group.  Develop a policy and plan for influx management that allows for collaboration with government authorities and landowners.  Develop a policy and plan for health management and awareness for employees inclusive of sex education, HIV/AIDS and related illnesses, drug and alcohol abuse, and personal development. Plan for capacity building with key stakeholders such as health and social welfare.

TABLE 8-2: MEASURES TO BE INCLUDED IN THE DESIGN OF THE SITE AND PLANT

Aspect Control measures Resource use  Include energy efficiency within the design of the plant as far as possible.  Maximise re-use of water within the plant. Earthworks and  Design and plan the plant to support the requirements outlined in Table 8-3. rehabilitation Spill prevention  In the design of the plant make provision for: - Hardstanding with engineered containment measures will be provided in all areas where potential contaminants could be released to the environment. - Dedicated areas will be provided for fixing and washing of equipment and machinery. These areas should be surfaced and bunded to contain spills at source and with sufficient capacity to contain 110% of the total spill. Where required silt/oil traps should be installed. - Where activities are required away from these areas appropriate bases and containment must be used. - Handling and storage of chemicals and hazardous substances will be undertaken in designated areas. These areas should be covered, surfaced and bunded to contain spills at source and with sufficient capacity to contain 110% of total spilled materials. Waste  Design and plan the plant to support the requirements outlined in Table 8-4. Effluent  Design the treatment plants in line with an authorisation in terms of the National Water Act.  Design the treatment plants to meet the discharge limits below:

- Conductivity: <10 mS/m - pH: 6.5-8.5 pH units - Chemical Oxygen Demand (COD): <10 mg/l - Ammonia (NH4): <0.2 mg/l - Chloride (Cl): <25 mg/l - Flouride (F): <0.05 mg/l - Alkalinity (CaCO3): <40 mg/l - Nitrate (NO3): <0.1 mg/l - Phosphate (PO4): 0.05 mg/l - Sulphate (SO4): <20 mg/l - Faecal coliforms: 0 counts/100ml -

 Include conservancy tanks in the design of the treatment plant to store effluent during periods of maintenance.  Prevent untreated effluent from entering the clean storm water system.  Discharge effluent in line with an authorisation in terms of the National Water Act.

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Aspect Control measures  Provide for flow meters within the plant and at the discharge point. Storm water and  Develop a storm water management plan that separates clean and dirty water run-off, diverts upstream run-off around the site and attenuates run-off to meet pre- flood development flows.  Design energy dissipation measures for the attenuation pond, for a 1:100 year storm event, to reduce the flow and prevent erosion. Upgrade storm water channels, if required, in consultation with other developers.  Ensure the discharge channels have suitable gradient and liner to provide effective operation and prevention of erosion.  Develop a dynamic climatic water balance for the site to inform water uses on site, attenuation of storm water and discharge requirements. Air  Design the plant to meet Section 21 emission standards for Subcategory 1.1 listed activity (Solid Fuel Combustion Installations). This could include a wet scrubber at the boiler house to remove SO2 and particulates, extraction units with fabric filters on the grain processing plant, a specialized particulate removal system (e.g. ESP or filter bags), low NOX burners.  Procure and use low sulfur coal.  Provide for a single stack of 41 m in height for the boiler house. Odour  At the maize steeping process, enclose and vent the process equipment and include wet scrubbing of extracted process gases.  Keep gluten and feed drying temperature below 423°C.  At the feed driers, include ionizing wet-collectors, with the possible addition of an alkaline wash before and after ionizing.  At the industrial waste water treatment plant include chemical control to minimise formation of H2S and other malodourous compounds. Noise  Where possible, plan for non-routine noisy activities to take place during day-time hours.  Limit heavy vehicle traffic to hours between 06:00 and 18:00 as far as possible.  Alternatives to the traditional reverse ‘beeper’ alarm such as a ‘self-adjusting’ or ‘smart’ alarm should be considered where these do not hamper health and safety requirements.  In the design of the plant make provision for: - Equipment selected and method statements should result in the lowest sound power levels. Vendors/contractors should provide guarantees to this effect. - Noisy plant and equipment should be sited as far away from NSRs as possible. - As far as is practically possible, noise generating components will be enclosed. - A noise screen/barrier will be placed between the site and the correctional services staff accommodation (guidance is included in the specialist study). Visual  In the design of the plant make provision for: - Only removing vegetation where this is necessary. - Establish tree screens along the north, east and south of the site. - Utilize locally appropriate, indigenous plant species in the landscaping. - Paint structures with colours that reflect and compliment the surrounding landscape. - Cladding and external surfaces of structures should be articulated or textured to create interplay of light and shade. - Install light fixtures that provide precisely directed illumination. - Avoid high pole top security lighting along the periphery of the site. - Minimise the number of light fixtures, including security lighting, to the minimum required. Traffic  In the design of the plant make provision for: - Traffic upgrades as per specialist study. - Provide signage, road markings and traffic calming measures where relevant in consultation with the roads authority. - Take care when placing signage in close proximity of access points.  Co-ordinate the transport of any abnormal heavy loads with the relevant roads department.  Comply with Hazchem requirements for the transport of any hazardous substances.

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TABLE 8-3: SITE-SPECIFIC SOIL MANAGEMENT AND REHABILITATION PLAN

Aspect Action plan and control measures Delineation of areas  Delineate project infrastructure footprints at the start of construction. to be stripped  Topsoil stripping must only occur within delineated project infrastructure footprints. Delineation of  Soil stockpile areas must be clearly marked on the ground and on the site layout map. stockpiling areas  Stockpiling areas must be located within the site boundary near to the end use of the soil to limit handling and to promote reuse of soils in the correct areas.  Soil stockpiles must be located away from waste handling areas. Stripping and  The top 60 cm (greater if available) of soil removed during earthworks must be considered as topsoil. handling of soils  Topsoil must be stockpiled separately from other soils, fill and spoil materials. and vegetation  No foreign materials should be mixed with topsoil.  Soils should be handled in dry weather conditions as far as practically possible so as to minimise erosion and cause as little compaction as possible.  Movement of soils should be done in single actions wherever possible to reduce compaction, increase the viability of the seed bank and protect the soil structure.  Vegetation should be removed in a staged manner, where possible, to limit erosion.  Indigenous vegetation that is stripped should be stored as part of the utilizable soil.  As far as possible stripped soil must be used on site in landscaping of the site.  Topsoil may only be used for final shaping and landscaping and not as fill or spill.  Identify beneficial uses for excess topsoil that cannot be used on site. This could include sale to third parties. Stockpile  Soil stockpile height should be restricted to between 4 and 5 meters to avoid compaction and damage to the underlying soils. For extra stability and erosion protection, management stockpiles may be benched.  Soil stockpiles to include run-off and erosion (by water and wind) control measures especially where stockpiles will remain for more than 1 year and/or one rainy season.  Movement on top of soil stockpiles should be limited to avoid topsoil compaction and subsequent damage to the soils and seedbank.  Routine monitoring of stockpiles should take place. Protection of soils,  Construction roads, equipment and material staging and storage areas should be delineated at the start of construction. where possible  Operation of heavy vehicles and machinery, including delivery of materials should be confined to delineated sites to minimise compaction of soils.  No unnecessary off road or off-site driving should be allowed.  Non-infrastructure areas should be re-vegetated as quickly as possible to limit erosion and dust formation.  Where storm water flow is concentrated or discharged to the environment, controls which reduce the velocity and erosive energy of these waters must be implemented.  Water should be sprayed on roads to suppress dust. Prevent and  Provide sufficient quantities of appropriate spill kits for use on site. These should be available at all times. manage spills  Handle major spillage incidents in accordance with the emergency response procedure (see Section 8.6).  Any contaminated soil should be remediated appropriately. Options could include in-situ bio-remediation (where feasible), bio-remediation at a dedicated area within the site (<500 kg treatment capacity) or removal and disposal in accordance with SANS 10234 (classification and offsite disposal at a permitted hazardous waste facility). Rehabilitation and  Soils across non-infrastructure areas, disturbed during construction, should be loosened to alleviate compaction and vegetated as quickly as possible. landscaping  All wastes, except inert materials, should be removed prior to the placement of soils.  Utilisable soil should be redistributed in a manner that achieves a stable soil of approximately uniform thickness, consistent with the landscaped/rehabilitated area.  Placement of topsoil should be done in consultation with a specialist and in a manner that supports the sustainability of the landscaped/rehabilitated area.  Only indigenous plant species* should be used across landscaped/rehabilitated area.  Erosion control measures must be implemented to ensure that the topsoil is not washed or blown away and that erosion gulleys do not develop.  Alien invasive plant species must be removed from the site*.  Routine monitoring of the landscaped/rehabilitated area should take place. *Non- invasive, exotic tree species may be utilized for screening (noise and visual) where indigenous species are not fit-for-purpose.

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TABLE 8-4: WASTE MANAGEMENT PRACTICES FOR DOMESTIC AND INDUSTRIAL SOLID WASTE Aspect Action plan and control measures Classification  Waste management procedures for the site should cover the storage, handling and transportation of waste from the site. and record  Contractors responsible for waste management must be made aware of the procedures prior to their appointment. keeping  Management actions for each waste stream must be reviewed annually to assess whether there are alternative uses for the material. Alternative uses should be prioritized over the disposal option.  Wastes (except those listed in Annexure 1 of the Waste Regulations) should be classified in accordance with SANS 10234 within 180 days of generation.  Waste should be re-classified every five (5) years, or within 30 days of a modification to the process or activity that generated the waste, changes in raw materials or other inputs, or any other variation of relevant factors.  Ensure safety data sheets for hazardous waste (prepared in accordance with SANS 10234) are available where required in terms of the Regulations.  Maintain an accurate and up to date record of the management of the wastes generated, which records must reflect: - the classification of the wastes; - the quantity of each waste generated, expressed in tons or m3 per month; - the quantities of each waste that has either been re-used, recycled, recovered, treated or disposed of; and - by whom the waste was managed.  If activities generate more than 20 kg of hazardous waste per day, then the facility must register with the Gauteng Waste Information System and submit records as required by the National Waste Information Regulations.  Written evidence of safe disposal of waste to licensed disposal facilities must be kept.  Waste related records must be retained for a period of at least 5 years and should be made available to the Department on request.  Any container or storage impoundment holding waste must be labelled, or where labelling is not possible, records must be kept, reflecting: - the date on which waste was first placed in the container; - the date on which waste was placed in the container for the last time when the container was filled, closed, sealed or covered; - the dates when, and quantities of, waste added and waste removed from containers or storage impoundments, if relevant; - the specific category or categories of waste in the container or storage impoundment as identified in terms of the National Waste Information Regulations, 2012; and - the classification of the waste in terms of Regulation 4 once it has been completed (if required). On-site waste  Littering must not be permitted. management  No waste may be buried or burned on site.  Waste generated on-site must be: - separated into general and hazardous waste. - further separated into recyclable and non-recyclable wastes where appropriate. - placed in appropriate containers.  Designated waste collection points or storage areas must be established on site at locations that do not pose risk to the quality of storm water runoff.  Ensure that there are sufficient collection points with adequate capacity and that these are serviced frequently.  Provide sanitary facilities with adequate capacity and that are serviced frequently during construction.  No waste may be stored outside of the demarcated construction site.  Inert building and demolition waste may be stored in stockpiles, which must not exceed demarcated areas and should be located away from storm water flow paths.  General waste should be placed in designated bins or skips for temporary storage.  Hazardous wastes should be placed in designated, labelled containers with a lid or under cover for temporary storage. Such containers must be placed in a designated area marked as “Hazardous Waste Area”.  Waste may not be mixed or treated where this would reduce the potential for re-use, recycling or recovery; or result in treatment that is not controlled and not permanent.  Waste may be blended or pre-treated to enable potential for re-use, recycling, recovery or treatment; or reduce the risk associated with management of the waste.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

Aspect Action plan and control measures Off-site waste  Unless collected by the municipality, it must be ensured that wastes are directed to a qualified waste management contractor for management at an appropriately licensed management facility, except where not required.  Only qualified waste management subcontractors should undertake the waste transport.  Wastes that consist of re-useable containers or packaging should be returned to suppliers.  Recyclable materials must be passed onto legitimate waste recyclers.  Where waste is destined for disposal, it must be ensured that it is assessed in accordance with the Norms and Standards for Assessment of Waste for Landfill Disposal set in terms of section 7(1) of the NEMWA prior to the disposal of the waste to landfill.  It must be ensured that the disposal of waste to landfill is done in accordance with the Norms and Standards for Disposal of Waste to Landfill set in terms of section 7(1) of the NEMWA.  General wastes should only go to appropriately licensed facility.  Hazardous wastes should only go to appropriately licensed facility.  Contractors must provide an inventory of each load of waste collected and of proof of delivery to the waste management facility or disposal at a licensed facility.  Waste management related records must be retained for a period of at least 5 years.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

8.2.4 Monitoring programme The purpose of the monitoring programme is to review the site’ impact on various aspects of the environment and to report on changes needed to the management programme as proposed in this report.

Monitoring during the planning and design phase would include reviewing any detailed designs and related contractor document to ensure compliance with the requirements of the EMPr. This would be the responsibility of the Applicant/Owners and Managers.

The water and air monitoring programmes as outlined in Section 8.3 must be initiated prior to construction to establish a pre-construction baseline.

8.3 CONSTRUCTION PHASE This section will form the basis for the environmental specifications that the Contractor, in terms of the construction contract, will be obliged to adhere to during construction. This section will be included in the contract documentation for the construction phase and will thus form a binding agreement between the Contractor and the Holder.

8.3.1 Environmental objectives and specific goals for management of identified environmental impacts Environmental objectives and goals to control, remedy or stop potential impacts emanating from the site which may impact on communities and I&APs are outlined below (Table 8-5).

TABLE 8-5: ENVIRONMENTAL OBJECTIVES AND GOALS - CONSTRUCTION Aspect Environmental objective Goals Security and To prevent physical harm to third parties and To prevent and control unauthorised access to access control animals. the site. Soil To prevent unnecessary loss of soil resources. To ensure the beneficial use of soil stripped from the project footprint. Vegetation To prevent unacceptable disturbance of To avoid loss of natural resources. biodiversity and related ecosystem functionality Water and To prevent and minimise contamination of To avoid contamination of natural resources. aquatics resources and unacceptable loss of aquatic ecosystems and related functionality. Air quality To prevent unacceptable air quality related To operate responsibly within the ambit of the impacts. existing ambient site conditions. Noise To limit excessive noise pollution from project To operate as a responsible neighbour. activities and facilities. Visual To limit excessive visual impacts. To develop a plant that is aesthetically pleasing and appropriate for its location. Stakeholders To support open and transparent To support open and transparent communication between the project and communication between the project and stakeholders. stakeholders. Socio- To enhance positive and minimise negative To work together with existing structures and economic economic impacts. organisations. To prevent unacceptable impacts on surrounding To establish and maintain a good working land uses and their economic activity. relationship with surrounding stakeholders. Traffic To reduce the potential for project-related To ensure the use of public roads is done in a impacts on third party road users. responsible manner. Heritage To prevent unacceptable loss of resources and To protect heritage resources where possible. related information. If disturbance is unavoidable, then mitigate impact in line with regulatory requirements.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

8.3.2 Roles and responsibilities The implementation of the construction phase EMPr requires the involvement of several stakeholders, each fulfilling a different but vital role to ensure sound environmental management. Key personnel during the construction phase would include:  Construction Manager / Resident Engineer: Shall act as the applicant’s on-site implementing agent and has the responsibility to ensure that their obligations are executed in compliance with the EMPr. Any on-site decisions regarding environmental management are ultimately the responsibility of the Construction Manager / Resident Engineer. The Construction Manager / Resident Engineer shall assist the ECO where necessary.  Contractor: Shall implement all provisions of the EMPr and ensure that all staff, including subcontractors, are familiar with the EMPr and aware of environmental issues and related mitigation. Each Contractor shall appoint a competent individual as the on-site Environmental Officer (EO). The EO must be appropriately trained in environmental management and must possess the skills necessary to impart environmental management to all personnel involved in the contract.  Environmental Officer (Contractor employee): Shall be responsible for monitoring, reviewing and verifying the Contractor’s compliance with the EMPr on a daily basis and that related method statements are adhered to at all times.  Environmental Control Officer (independently appointed by the applicant): Shall be responsible for monitoring, reviewing and verifying the overall compliance with the EMPr. The ECO shall play an active role in ensuring environmental awareness on site and that the necessary environmental authorisations and permits have been obtained. The ECO shall visit the site monthly during construction, or more frequently as required during the initial stages of construction. The ECO shall communicate directly with the Construction Manager / Resident Engineer. Should problems arise on site that cannot be resolved between the ECO and the Construction Manager / Resident Engineer, the ECO shall take the matter up with the applicant. If the applicant does not respond the ECO shall take the matter up with GDARD. The ECO will act as the primary liaison between local communities and the project.

Copies of the EMPr shall be made available to the Engineer, Resident Engineer, Contractor, Environmental Officer and the Environmental Control Officer. Copies of this EMPr shall be kept at the site office(s).

8.3.3 Management action plan The construction action plans are presented in tabular format together with timeframes for each action (see Table 8-6). The action plan includes the frequency for implementing the mitigation measures and identifies the responsible party.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

TABLE 8-6: MANAGEMENT ACTION PLAN - CONSTRUCTION Action plan Aspect Action plan and control measures Timeframe Frequency Responsible parties Design controls  Construct site in a manner that ensures compliance with the design controls outlined Entire construction phase Continuous Construction Manager in Section 4 of the BAR as well as the measures detailed in Section 8.2 of the EMPr. Security and access  Establish and maintain security control measures. From start Continuous Construction Manager control  Undertake regular patrols of plant perimeter. From start Weekly Security personnel  Implement community awareness programme. From start At start and then quarterly ECO  Handle any injury or death in accordance with the emergency response procedure Emergency As required Construction Manager (see Section 8.7). Stakeholder  Implement the stakeholder communication and engagement strategy. From start Continuous, quarterly Construction Manager engagement meetings  Implement and maintain the formal complaints (grievance) procedure. From start Continuous ECO Soil and vegetation  Implement soil management and rehabilitation plan. From start Continuous Construction Manager management  Implement alien invasive plant management plan. From start Continuous Construction Manager  Implement waste management plan and maintain waste management systems From start Continuous Construction Manager (Table 8-4).  Maintain containment measures in proper working conditions and with sufficient capacity.  Handle major spillage incidents in accordance with the emergency response Emergency As required Construction Manager procedure (see Section 8.7). Effluent  Undertake the primary earthwork activities for the discharge channel in the drier Drier winter months Once off Construction Manager management winter months.  Implement soil management and rehabilitation plan. From start Continuous Construction Manager  Monitor water quality in the Vaal tributary. As per Section 8.3.4 As per Section 8.3.4 Construction Manager Storm water  Maintain storm water management system. From start Continuous Construction Manager management  Maintain a dynamic climatic water balance for the site to inform water uses on site, From start Continuous Construction Manager attenuation of storm water and discharge requirements. Air quality  Reduce fugitive PM emissions through the sweeping of roads. From start Continuous Construction Manager management  Implement dust suppression. During dry periods As required Construction Manager  Reduce vehicle entrainment emissions from the paved access roads using a From start Continuous Construction Manager mechanical sweeper, strict enforcement of speed limits (maximum 20 km/h on access roads), and regular clean-ups of road spillages. As per Section 8.3.4 As per Section 8.3.4 Construction Manager  Monitor ambient air quality. Noise management  Maintain all equipment and vehicles in proper working order. From start Continuous Construction Manager  Implement an equipment and vehicle maintenance plan. From start As per schedule in plan Construction Manager  Any change in the noise emission characteristics of equipment will serve as trigger for From start As required Construction Manager withdrawing it for maintenance. Records will be kept for auditing purposes.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

Action plan Aspect Action plan and control measures Timeframe Frequency Responsible parties  Maintain road surfaces regularly to repair potholes and any damages. From start As required Construction Manager  Avoid unnecessary idling times at all times. From start Continuous Construction Manager  Minimise the need for trucks/equipment to reverse. From start Continuous Construction Manager  When reversing, vehicles should travel in a direction away from receptors if possible. From start Continuous Construction Manager  Conduct noise monitoring. As per Section 8.3.4 As per Section 8.3.4 Construction Manager Traffic management  Maintain road and traffic upgrades. From start Continuous Construction Manager  Maintain all equipment and vehicles in proper working order. From start Continuous Construction Manager  Report any issues pertaining to damages and poor road conditions in close proximity From start As required Construction Manager of the project to the applicable authority and custodian of the respective roads.  Handle any road accident involving or caused by project related traffic in accordance Emergency As required Construction Manager with the emergency response procedure (see Section 8.7). Socio-economic  Implement recruitment and procurement policies and procedures. From start As required Construction Manager development  Implement local corporate social investment strategies. From start As required Construction Manager  Implement influx management plan. From start As required Construction Manager  Implement health management plan for employees. From start As required Construction Manager

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

8.3.4 Monitoring programme The purpose of the monitoring programme is to review the site’ impact on various aspects of the environment and to report on changes needed to the management programme as proposed in this report.

A monitoring programme is included in Table 8-7. Figure 8-1 provides the location of monitoring points. The programme includes EMPr monitoring and performance assessment as well as the monitoring of environmental aspects including water resources, air and noise.

TABLE 8-7: MONITORING PLAN - CONSTRUCTION Location of Key performance Method of Responsible Reporting Thresholds / Recommended Impact Parameter Frequency monitoring indicator monitoring person mechanism standards action EMPr MONITORING AND PERFORMANCE ASSESSMENT Monthly EMPr, EA Internal reports Site inspection (ECO) conditions, Construction Implement Overall impact and verification External audit EMPr and EA project scope as Site activities Compliance Manager, EO additional measures of the project of monitoring report for conditions provided for in and ECO Annually where required data submission to this report GDARD As above As above and including including photographic Construction Weekly (EO) Implement Overall impact EMPr and EA method Site activities Compliance record, incident Manager, EO Monthly Internal reports additional measures of the project conditions statements and register, and ECO (ECO) where required procedures complaints register WATER See Table 8-13- Receiving Implement initial analysis to watercourse – ECO and Compare against Surface water As a minimum additional measures include full list. upstream and appropriately Internal and baseline quality baseline maintain baseline Grab sampling Monthly in consultation with Once trends are downstream of qualified external reports and authorisation quality quality authorities and established this discharge point specialist limits specialist list will be (Figure 8-1)

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

Location of Key performance Method of Responsible Reporting Thresholds / Recommended Impact Parameter Frequency monitoring indicator monitoring person mechanism standards action revised to monitor Boreholes as Maintain baseline parameters of shown in quality; however, if Compare against Groundwater concern more Figure 8-1 – can be contamination does Internal and baseline quality baseline Grab sampling Monthly regularly and amended with migrate off site external reports and authorisation quality other input from corrective action must limits parameters less specialist be taken. frequently Supply volumes At supply point Internal and Compare against Water use - Flow meters Continuous and use and within plant external reports service agreement BIOMONITORING Receiving Implement Aquatic watercourse – ECO and Aquatic As a minimum As a minimum additional measures habitats and upstream and SASS5, Rapid appropriately Every six ecosystem maintain baseline Internal report maintain baseline in consultation with ecosystems downstream of Assessment qualified months health conditions conditions authorities and baseline discharge point specialist specialist. (Figure 8-1) AIR No visible dust Visual, photos, plume in Compliance with non- dust buckets immediate vicinity Implement Continuous residential limits at using American of sources. additional measures Dust with Internal and Dustfall See Figure 8-1. source and residential Society of Evaluation criteria in consultation with generation ECO and quarterly external reports limits at receptors off- Testing and adopted for this authorities and appropriately reporting site Materials (ASTM) project can be specialist. qualified method revised with input specialist from air specialist. Continuous Measure rainfall, evap, with Internal report and Climate Meteorological On-site temperature, wind Daily records Not applicable Not applicable monthly database data reporting NOISE At correctional 55 dBA during the day Day and night 55 dBA during the Implement ECO and Increase in dBA services and 45 dBA during the measurements Annually day and 45 dBA additional measures appropriately Internal and ambient noise accommodation night with suitable during the night in consultation with qualified external reports levels Livestock instruments (see GDARD and noise dB Below 85 to 90 dB specialist Annually Below 85 to 90 dB fairgrounds Appendix 10) specialist.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

Location of Key performance Method of Responsible Reporting Thresholds / Recommended Impact Parameter Frequency monitoring indicator monitoring person mechanism standards action SOCIAL >5 complaints or Implement Progress on Document Development’s observations additional measures Negative social implementation of review, impact on local Surrounding areas ECO Monthly Internal report Corporate in consultation with impacts policies and plans complaints communities sponsorship or authorities and No. of complaints register support specialist.

TABLE 8-8: WATER MONITORING PARAMETERS In field measurements pH Turbidity Electrical conductivity Total dissolved solids Laboratory analysis pH Total dissolved solids Carbonate as CO3 Alkalinity as CaCO3 Bicarbonate as HCO3 Sodium Chloride Electrical conductivity Free and Saline Ammonia as N (NH3) Nitrate as N (NO3) Hydrocarbons ICP- scan for trace metals (dissolved concentrations) Calcium Sulphate Suspended solids Orthophosphate (as P) Manganese Potassium Faecal coliform units (FCU) Fluoride

TABLE 8-9: AIR QUALITY EVALUATION CRITERIA Pollutant Limit values Frequency of exceedance

Dustfall rate (mg/m2/day) Occurrences per year Dustfall – residential areas D < 600 Two within a year, not sequential months Dustfall – non-residential areas 600 < D < 1200

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Legend

!( Unitas Park Steel Park !( .! Surface Water Sampling Points ± .! Ground Water Sampling Boreholes .! Dust Monitoring Sites !( Duncanville Access Road Water Supply Pipeline Drainage Channels (Man-Made) Watercourses Proposed Site Project site !( A1 .! Bh1 A4 .! .! A2 .! Bh2 !( Leeuhof A3 .! .! P1 .! Vaal tributary P2 .!

!( Vereeniging

Kilometers 0 0.5 1 2 Scale: 1:37 786 @ A4 !( Sharpeville Projection:Transverse Mercator WG27 Datum: WGS84 PROPOSED MAIZE WET MILL PLANT

Figure 8-1

Service Layer Credits: r e iv R l a a V Proposed Monitoring Network

SLR Consulting (Africa) (Pty) Ltd P O Box 1596, Cramerview, 2060, South Africa Tel: +27 (11) 467-0945 Fax: +27 (11) 467-0978

720.19124.00001 October 2018 Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

8.4 OPERATIONS

8.4.1 Environmental objectives and specific goals for management of identified environmental impacts Environmental objectives and goals to control, remedy or stop potential impacts emanating from the site which may impact on communities and I&APs are outlined below (Table 8-10).

TABLE 8-10: ENVIRONMENTAL OBJECTIVES AND GOALS - OPERATIONS Aspect Environmental objective Goals Security and To prevent physical harm to third parties and To prevent and control unauthorised access access control animals. to the site. Water and To prevent and minimise contamination of To avoid contamination of natural resources. aquatics resources. To operate as a responsible neighbour. To maintain pre-development flows and prevent flooding of downstream activities. To prevent the unacceptable loss of aquatic ecosystems and related functionality. Air quality To prevent unacceptable air quality related To operate responsibly within the ambit of pollution impacts. the existing ambient site conditions. Noise To limit excessive noise pollution from project To operate as a responsible neighbour. activities and facilities. Visual To limit excessive visual impacts. To maintain a plant that is aesthetically pleasing and appropriate for its location. Stakeholders To support open and transparent communication To support open and transparent between the project and stakeholders. communication between the project and stakeholders. Socio- To promote local employment and maximise local To work together with existing structures and economic socio-economic benefits. organisations. To enhance positive and minimise negative To maintain a good working relationship with economic impacts. surrounding stakeholders. To minimise the loss of socio-economic conditions To negatively impact existing land uses as due to relocation. little as possible. To prevent unacceptable impacts on surrounding land uses and their economic activity. Traffic To reduce the potential for project-related impacts To ensure the use of public roads is done in a on third party road users. responsible manner.

8.4.2 Roles and responsibilities The implementation of the operational EMPr requires the involvement of several stakeholders, each fulfilling a different but vital role to ensure sound environmental management. Key personnel during the operational phase would include:  Plant Manager: Shall ensure overall compliance with the EMPr. Any on-site decisions regarding environmental management are ultimately the responsibility of the Plant Manager. The Plant Manager shall provide the necessary support to the SHE, Stakeholder and Human Resources Manager  SHE Manager: Shall be responsible for monitoring, reviewing and verifying the overall compliance with the EMPr. The SHE Manager shall play an active role in ensuring environmental awareness on site and that the necessary environmental authorisations and permits have been obtained. The SHE Manager shall communicate directly with the Plant Manager. The SHE Manager shall ensure that the monitoring programmes and audits are scoped and included in the annual budget, identify and appoint appropriately qualified specialists/engineers to undertake the programmes, and appoint specialists in a timeously manner to ensure work can be carried out to acceptable standards.

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 Stakeholder Manager: Shall be responsible for implementing and maintaining the stakeholder engagement plan which would include regular information sharing meetings with stakeholders, facilitate open and transparent dialogue between the site and stakeholders, maintaining a grievance and complaints register.  Human Resources Manager: Shall manage labour-related aspects, liaise with the relevant structures in terms of Corporate Social Investment strategies and commitments, ensure that commitments are developed and implemented in a timeously fashion and establish and maintain good working relations with surrounding communities and land users.

Copies of the EMPr shall be kept on site at all times.

8.4.3 Management action plans The operations management action plan is presented in tabular format together with timeframes for each action (see Table 8-11). The action plan includes the frequency for implementing the mitigation measures and identifies the responsible party. This section will form the basis for the environmental specifications that the owner/operator will be obliged to adhere to during operations.

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TABLE 8-11: MANAGEMENT ACTION PLAN - OPERATIONS Action plan Aspect Action plan and control measures Timeframe Frequency Responsible parties Maintenance  Maintain facilities in proper working condition to ensure compliance with the design Entire operations phase Regularly Plant and SHE controls and EMPr commitments. Managers  Upkeep the aesthetics of the plant to minimize negative visual impacts.  Undertake inspections of facilities and use these to inform improvements on site. Security and access  Establish and maintain security control measures. From start Continuous Plant Manager control  Undertake regular patrols of plant perimeter. From start Weekly Security personnel  Implement community awareness programme. From start At start and then quarterly Stakeholder Manager  Handle any injury or death in accordance with the emergency response procedure Emergency As required HR Manager (see Section 8.7). Stakeholder  Implement the stakeholder communication and engagement strategy. From start Continuous, quarterly Construction Manager engagement plan meetings  Implement and maintain the formal complaints (grievance) procedure. From start Continuous ECO Vegetation  Implement waste management plan and maintain waste management systems From start Continuous SHE Manager management plan (Table 8-4).  Maintain containment measures in proper working conditions and with sufficient From start Continuous SHE Manager capacity.  Maintain park-type landscapes. From start Continuous SHE Manager  Handle major spillage incidents in accordance with the emergency response Emergency As required SHE Manager procedure. Effluent  Conduct regular testing of the effluent quality to ensure that only effluent of an As per Section 8.4.4 As per Section 8.4.4 SHE Manager management plan acceptable standard is being released to the receiving environment.  Monitor water quality in the Vaal tributary. As per Section 8.4.4 As per Section 8.4.4 SHE Manager  Handle any significant contamination incident in accordance with the emergency Emergency As required SHE Manager response procedure (see Table 8-15). Storm water and  Reuse and recycle treated effluent within the plant as far as possible. From start Continuous SHE Manager flood management  Measure flows within the plant. From start Continuous SHE Manager  Measure discharge volumes on a continuous basis (i.e. flow meter). As per Section 8.4.4 As per Section 8.4.4 SHE Manager  Maintain a dynamic climatic water balance for the site to inform water uses on site, From start Continuous Plant Manager attenuation of storm water and discharge requirements.  Handle any significant flood or failure incident in accordance with the emergency Emergency As required SHE Manager response procedure (see Table 8-15). Air quality  Manage (and design) the boiler plant as per the Subcategory 1.1 listed activity. Planning and Design Continuous SHE Manager management Ensure that an 85% control efficiency is achieved on the grain and solid products extraction systems.  Mitigation of emissions from the maize and dry maize-product handling using From start Continuous SHE Manager

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Action plan Aspect Action plan and control measures Timeframe Frequency Responsible parties cyclones, fabric filters, or a combination. As required SHE Manager  Implement dust suppression. During dry periods  Reduce vehicle entrainment emissions from the paved access roads using a From start Continuous SHE Manager mechanical sweeper (to achieve an 80% control efficiency), strict enforcement of speed limits (maximum 20 km/h on access roads), covers for vehicles and regular clean-ups of road spillages. As per Section 8.4.4 As per Section 8.4.4 SHE Manager  Monitor emissions and ambient air quality. As per Section 8.4.4 As per Section 8.4.4 SHE Manager  Implementation of the reporting procedures. Noise management  Maintain all equipment and vehicles in proper working order. From start Continuous SHE Manager  Implement an equipment and vehicle maintenance plan. From start As per schedule in plan SHE Manager  Any change in the noise emission characteristics of equipment will serve as trigger for From start As required SHE Manager withdrawing it for maintenance. Records will be kept for auditing purposes.  Maintain road surfaces regularly to repair potholes and any damages. From start As required SHE Manager  Avoid unnecessary idling times at all times. From start Continuous SHE Manager  Minimise the need for trucks/equipment to reverse. From start Continuous SHE Manager  When reversing, vehicles should travel in a direction away from receptors if possible. From start Continuous SHE Manager  Conduct noise monitoring. As per Section 8.4.4 As per Section 8.4.4 SHE Manager Traffic management  Maintain road and traffic upgrades. From start Regularly SHE Manager  Maintain all equipment and vehicles in proper working order. From start Regularly SHE Manager  Comply with Hazchem requirements for the transport of any hazardous substances. As required As required SHE Manager  Report any issues pertaining to damages and poor road conditions in close proximity From start As required SHE Manager of the project to the applicable authority and custodian of the respective roads.  Handle any road accident involving or caused by project related traffic in accordance Emergency As required SHE Manager with the emergency response procedure (see Table 8-15). Socio-economic  Implement recruitment and procurement policies and procedures. From start As required Stakeholder and HR development plan  Implement local corporate social investment strategies. From start As required Managers  Implement influx management plan. From start As required  Implement health management plan for employees. From start As required

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

8.4.4 Monitoring programme The purpose of the monitoring programme is to review the site’ impact on various aspects of the environment and to report on changes needed to the management programme as proposed in this report.

A monitoring programme is included in Table 8-12. Figure 8-1 provides the location of monitoring points. The programme includes EMPr monitoring and performance assessment as well as the monitoring of environmental aspects including water resources, air, noise, and transport.

TABLE 8-12: MONITORING PLAN Location of Key performance Method of Responsible Reporting Thresholds / Recommended Impact Parameter Frequency monitoring indicator monitoring person mechanism standards action EMPr MONITORING AND PERFORMANCE ASSESSMENT EMPr, EA Site inspection Monthly Internal reports Implement Overall impact conditions, and verification External audit EMPr and EA Site activities Compliance SHE Manager additional measures of the project project scope as of monitoring Annually report for GDARD conditions where required per this report data submission WATER See Table 8-13- Comply with relevant Internal and Compare against At discharge point Grab sampling Monthly initial analysis to water quality limits external reports authorisation limits include full list. Receiving Surface water Once trends are watercourse – Compare against As a minimum quality established this upstream and Internal and baseline quality maintain baseline Grab sampling Monthly Implement list will be downstream of external reports and authorisation quality additional measures revised to discharge point limits SHE Manager in consultation with monitor (Figure 8-1) and authorities and parameters of Boreholes as Maintain baseline appropriately water specialist concern more shown in quality; however, if Compare against qualified Groundwater regularly and Figure 8-1 – can be contamination does Internal and baseline quality Grab sampling specialist Monthly quality other amended with migrate off site external reports and authorisation parameters less input from corrective action must limits frequently specialist be taken. Surface water Discharge In-stream flow Compare against At discharge point Flow meter Continuous Implement flow volumes objectives set by DWS Internal and authorisation corrective measures Supply volumes At supply point external reports Compare against Water use - Flow meters Continuous where required and use and within plant service agreement

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

Location of Key performance Method of Responsible Reporting Thresholds / Recommended Impact Parameter Frequency monitoring indicator monitoring person mechanism standards action BIOMONITORING As a minimum Receiving Every six SHE Manager Internal report maintain baseline Implement watercourse – months Aquatic Aquatic As a minimum and conditions additional measures upstream and SASS5, Rapid habitats and ecosystem maintain baseline appropriately After in consultation with downstream of Assessment Until impacts of ecosystems health conditions qualified incident and Annual report authorities and discharge point incident no longer specialist then submitted to DWS. specialist. (Figure 8-1) noticeable quarterly AIR PM , PM , SO NAAQS limits SHE Manager Every six Internal and Implement Air emissions 2.5 10 2 At site boundary Ambient NAAQS limits and NO2 (Table 8-14) and months external reports additional measures appropriately in consultation with NDCR for residential Internal and NDCR for Dust fallout TSP At site boundary Dust buckets qualified Continuous GDARD and areas external reports residential areas specialist specialist. ODOUR Passive during At nearest SHE Manager Implement < 200 µg/m3 short-term Regular Internal reports < 200 µg/m3 receptors and additional measures Nuisance campaigns TVOCs appropriately in consultation with odours Emissions qualified Every six GDARD and At source measurements Internal reports specialist months specialist. campaigns NOISE At correctional 55 dBA during the day Day and night SHE Manager 55 dBA during the Implement Increase in dBA services and 45 dBA during the measurements and Annually day and 45 dBA additional measures Internal and ambient noise accommodation night with suitable appropriately during the night in consultation with external reports levels Livestock instruments (see qualified GDARD and noise dB Below 85 to 90 dB Annually Below 85 to 90 dB fairgrounds Appendix 10) specialist specialist. SOCIAL Implement Development’s Awareness of additional measures Negative social Meaningful Document and Stakeholder Every three impact on local Surrounding areas Internal report communication in consultation with impacts stakeholder records process review Manager months communities channels, authorities and specialist.

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Proposed Maize Wet Mill Plant, Vereeniging, Gauteng Province November 2018

TABLE 8-13: WATER MONITORING PARAMETERS In field measurements pH Turbidity Electrical conductivity Total dissolved solids Laboratory analysis pH Total dissolved solids Carbonate as CO3 Alkalinity as CaCO3 Bicarbonate as HCO3 Sodium Chloride Electrical conductivity Free and Saline Ammonia as N (NH3) Nitrate as N (NO3) Hydrocarbons ICP- scan for trace metals (dissolved concentrations) Calcium Sulphate Suspended solids Orthophosphate (as P) Manganese Potassium Faecal coliform units (FCU) Fluoride

TABLE 8-14: AIR QUALITY EVALUATION CRITERIA Pollutant Averaging Limit values Frequency of exceedance Compliance date

period Concentration (µg/m³) Dustfall rate (mg/m2/day) Occurrences per year PM2.5 24 hour 40 - 4 1 January 2016 – 31 December 2029 24 hour 25 - 4 1 January 2030 1 year 20 - Not applicable 1 January 2016 – 31 December 2029 1 year 15 - Not applicable 1 January 2030

PM10 24 hour 75 - 4 Immediate 1 year 40 - Not applicable Immediate

SO2 1 hour 350 - 88 Immediate 24 hours 125 - 4 Immediate 1 year 50 - Not applicable Immediate

NO2 1 hour 200 - Not applicable Immediate 1 year 40 - Not applicable Immediate Benzene - 5 Not applicable Immediate Dustfall – residential areas - - D < 600 Two within a year, not sequential months - Dustfall – non-residential areas - - 600 < D < 1200 -

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8.5 DECOMMISSIONING AND CLOSURE No planning has been undertaken for decommissioning and closure. The facility owner should develop a plan for decommissioning and closure at least two years prior to the planned closure of the facility. Closure planning should be undertaken in terms of the regulatory framework relevant at the time, with cognisance of the local environmental conditions and planned land uses.

To ensure management of environmental impacts, the decommissioning plan should (depending on the future use) consider the following broad objectives:  making the facility safe;  removal of any excess materials and products;  dismantling of the equipment,  sale and final disposal of all components,  demolition of structures;  decontamination of any contaminated areas;  the final disposal of wastes; and  the rehabilitation of the site to a condition suitable for an end land use.

8.6 ENVIRONMENTAL AWARENESS AND TRAINING PLAN This section includes an environmental awareness plan for the site. The plan describes how contractors or employees would be informed of environmental risks which may result from their work, the manner in which the risk must be dealt with in order to avoid contamination or degradation of the environment and the training required for general environmental awareness and the dealing of emergency situations and remediation measures for such emergencies. This plan will be applied from the start of construction through operations.

All contractors that conduct work on the site would be bound by the content of the EMPr and a contractual condition to this effect shall be included in all such contracts entered into. If contractors are used, the responsibility for ensuring compliance with the EMPr would remain with the owners and managers of the plant.

The purpose of the environmental awareness plan is to ensure that all personnel and management understand the general environmental requirements of the site. In addition, greater environmental awareness must be communicated to personnel involved in specific activities which can have a significant impact on the environment and ensure that they are competent to carry out their tasks on the basis of appropriate education, training and/or experience. The environmental awareness plan should enable the site to achieve the objectives of an environmental policy.

This environmental awareness plan applies to both the construction and operational phases.

8.6.1 Environmental policy The environmental policy would be displayed prominently at the entrance and key notice boards. The core objectives of the environmental policy are described below.  To minimise impact on the environment (including social) wherever possible.  To comply with all applicable environmental legislation and the commitments contained in the Environmental Management Programme (EMPr).  To ensure that all employees, contractors and sub-contractors: o Are aware of the impact of their activities on the environment o Are informed about the measures required to prevent, mitigate and manage environmental impacts o Apply these principles whilst carrying out their work.

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 To establish and maintain a good relationship with stakeholders and other I&APs with regard to the activities on site.  To develop a localised environmental strategy with the local authority and relevant stakeholder groups.  To provide relevant and constructive consultation/public participation on the management of the potential environmental impacts posed by the site.

8.6.2 Steps to achieve the environmental policy objectives The environmental policy would be realised by setting specific and measurable objectives. It is proposed that new objectives are set throughout the life of the plant. Initial objectives are outlined below.  Management of environmental responsibilities: o Appoint an Environmental Manager at senior management level, who will be provided with the necessary resources to carry out the management of all environmental aspects of the site as a primary function, for example: . compliance with environmental legislation and EMPr commitments; . implementing and maintaining an environmental management system; . developing environmental emergency response procedures and coordinating personnel during incidents; . managing routine environmental monitoring and data interpretation; . environmental trouble shooting and implementation of remediation strategies; . closure planning (when required).  Communication of environmental issues and information: o Carry out meetings, consultations and progress reviews and include: . set the discussion of environmental issues and feedback on environmental projects as an agenda item at all company board meetings; . provide progress reports on the achievement of policy objectives and level of compliance with the approved EMPr to the GDARD; . ensure environmental issues are raised at monthly management meetings and relevant meetings at all levels; . ensure environmental issues are discussed at all general liaison meetings with local communities and other interested and affected parties.  Environmental awareness training: o Environmental awareness training would be provided to all individuals at a level of detail specific to the requirements of their job, but would generally comprise: . Basic awareness training for all prior to granting access to site (e.g. short video presentation requiring registration once completed). Employees and contractors who have not attended the training will not be allowed on site; . General environmental awareness training will be given to all employees and contractors as part of the Safety, Health and Environment (SHE) induction programme. All non-plant personnel who will be on site for more than five days must undergo the SHE induction training; . Specific environmental awareness training will be provided to personnel whose work activities can have a significant impact on the environment (e.g. workshops, waste handling, sanitation, effluent treatment, etc.).  Review and update the environmental topics identified in the EMPr.  Design all projects to minimise impact on the environment.  Maintain records of all environmental training, monitoring, incidents, corrective actions and reports.

8.6.3 Training objectives and general contents of the environmental awareness plan An environmental awareness plan ensures that training needs are identified and that appropriate training is provided. The environmental awareness plan should communicate:

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 the importance of conformance with the environmental policy, procedures and other requirements of good environmental management;  the significant environmental impacts and risks of individuals’ work activities and explain the environmental benefits of improved performance;  individuals’ roles and responsibilities in achieving the aims and objectives of the environmental policy; and  the potential consequences of not complying with environmental procedures.

To achieve the objectives of the environmental awareness plan the general contents of the training plans should be as follows:  Module 1 – Basic training plan applicable to all personnel entering the site: o Short (15min) presentation to indicate the site layout and activities at specific business units together with their environmental aspects and potential impacts. o Individuals to sign off with site security on completion in order to gain access to the site.  Module 2 – General training plan applicable to all personnel at the site for longer than 5 days: o General understanding of the environmental setting of the plant (e.g. local communities and proximity to natural resources). o Understanding the environmental impact of individuals’ activities on site (e.g. excessive production of waste, poor housekeeping, energy consumption, water use, noise, etc.). o Indicate potential site specific environmental aspects and their impacts. o The site’s environmental management strategy. o Identifying poor environmental management and stopping work which presents significant risks. o Reporting incidents. o Examples of poor environmental management and environmental incidents. o Procedures for emergency response and cleaning up minor leaks and spills.  Module 3 – Specific training plan dependent on the employees work specification: o Environmental setting of the workplace (e.g. proximity of residential areas and natural resources, etc.); o Specific environmental aspects and the impact of these aspects. o Site’s duty of care. o Purpose and function of the environmental management system.

Individuals required to complete Module 3 (Specific training module) would need to complete Modules 1 and 2 first. On completion of Module 3, individuals would be subject to a short test (written or verbal) to ensure the level of competence has been achieved. Individuals who fail the test would be allowed to re-sit the test after further training.

The actual contents of the training modules would be developed based on a training needs analysis.

Key personnel would be required to undergo formal, external environmental management training (e.g. how to operate the environmental management system, waste management and legal compliance).

In addition to the above the site would:  Conduct refresher training/presentations on environmental issues for employees (permanent and contractors) at regular intervals.  Promote environmental awareness using relevant environmental topic posters displayed at strategic locations on the site. These topics would be changed monthly, and would be reviewed annually by the SHE Manager to ensure relevance.  Participate and organise events which promote environmental awareness, some of which would be tied to national initiatives e.g. National Arbour Week, World Environment Day and National Water Week.

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8.7 PROCEDURES IN CASE OF ENVIRONMENTAL EMERGENCIES Emergency procedures apply to incidents that are unexpected and that may be sudden, and which lead to serious danger to the public and/or potentially serious contamination of, or detriment to the environment (immediate and delayed). Procedures to be followed in case of environmental emergencies are described in Section 8.7.2 below. The procedures will be applied from the start of construction through operations.

8.7.1 General Emergency Procedure The general procedure that should be followed in the event of all emergency situations is outlined below.  During construction, the Construction Manager and ECO must be notified of an incident upon discovery;  During operations, the Plant and SHE Managers must be notified of an incident upon discovery;  Area to be cordoned off to prevent unauthorised access and tampering of evidence;  If dams or storm water controls are partially or totally failing and this cannot be prevented, the emergency siren is to be sounded (nearest one available). After hours the Plant Manager on shift must be notified;  Take photographs and samples as necessary to assist in investigation;  The SHE Department must comply with Section 30 of the National Environmental Management Act (107 of 1998) such that: o The Environment department must immediately notify the Director-General (DEA, DWS, as appropriate), the South African Police Services and relevant fire prevention service, the provincial head of GDARD or municipality, the head of the regional DWS office and any persons whose health may be affected, of: . the nature of the incident; . any risks posed to public health, safety and property; . the toxicity of the substances or by-products released by the incident; and . any steps taken to avoid or minimise the effects of the incident on public health and the environment. o The SHE department must as soon as is practical after the incident: . take all reasonable measures to contain and minimise the effects of the incident including its effects on the environment and any risks posed by the incident to the health, safety and property of persons; . undertake clean up procedures; . remedy the effects of the incident; and . assess the immediate and long term effects of the incident (environment and public health). o Within 14 days the SHE department must report to the Director-General (DEA, DWS, as appropriate), the provincial head of GDARD and the local municipality, the head of the regional DWS office such information as is available to enable an initial evaluation of the incident, including: . the nature of the incident; . the substances involved and an estimation of the quantity released; . the possible acute effects of the substances on the persons and the environment (including the data needed to assess these effects); . initial measures taken to minimise the impacts; . causes of the incident, whether direct or indirect, including equipment, technology, system or management failure; and . measures taken to avoid a recurrence of the incident.

8.7.2 Identification of Emergency Situations Project-specific emergency situations that have been identified together with specific emergency response procedures are outlined in Table 8-15.

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TABLE 8-15: PROJECT-SPECIFIC EMERGENCY RESPONSE PROCEDURES Item Emergency Situation Response in addition to general procedures 1 Spillage of chemicals, Where there is a risk that material will contaminate the land (leading to a loss of resource), surface water and/or engineering substances, groundwater, the site will: waste  Notify users downstream of the contamination incident.  Identify and provide alternative resources should contamination impact adversely on the existing environment.  Cut off the source of the spill) and make the infrastructure ‘safe’.  Contain the spill (e.g. construct temporary earth bund around source) or redirect the spill to a contained area.  Pump excess hazardous liquids on the surface to temporary containers for appropriate disposal.  Remove hazardous substances from damaged infrastructure to an appropriate storage area before it is removed / repaired. 2 Discharge of dirty water or Apply the principals listed for Item 1 above. effluent to the environment To stop spillage from the dirty water system the site will:  Pump dirty water to available containment.  Apply for emergency discharge as a last resort. 3 Groundwater  Use the downstream monitoring borehole as a scavenger well to pump out the polluted groundwater for re-use in the contamination water circuit (hence containing the contamination and preventing further migration). Ensure this pumping will not affect the dolomites and stability of the ground.  Investigate the source of contamination and implement control/mitigation measures. 4 Burst water pipes (loss of  Shut off the water flowing through the damaged area and repair the damage. resource and erosion)  Apply the principals listed for Item 1 above if spill is from the dirty/process water circuit. 5 Failure of surface water  Evacuate the area downstream of the failure. control infrastructure  Using the emergency response team, rescue/recover and medically treat any injured personnel and/or animal (where applicable).  Temporarily reinstate/repair storm water diversions during the storm event (e.g. emergency supply of sandbags).  Close the roads affected by localised flooding or where a storm water surge has destroyed crossings/bridges. 6 Risk of drowning from  Attempt rescue of individuals from land by throwing lifeline/lifesaving ring. falling into water dams  Get assistance of emergency response team whilst attempting rescue.  Ensure medical assistance is available to recovered individual (where applicable). 7 Fire  Evacuate employees from areas at risk.  Notify downwind residents and industries of the danger.  Assist those in imminent danger/less able individuals to evacuate until danger has passed.  Provide emergency fire-fighting assistance with available trained personnel and equipment.

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Item Emergency Situation Response in addition to general procedures 8 Road traffic accidents  The individual discovering the accident (be it bystander or able casualty) must raise the alarm giving the location of the incident. Able personnel at the scene should shut down vehicles where it is safe to do so.  Access to the area should be restricted and access roads cleared for the emergency response team.  Vehicles must be made safe first by trained professionals (e.g. crushed or overturned vehicles).  Casualties will be moved to safety by trained professionals and provided with medical assistance.  Medical centres in the vicinity with appropriate medical capabilities will be notified if multiple seriously injured casualties are expected. 9 Uncovering of graves and  Personnel discovering the grave or site must inform the Environment Manager immediately. sites  An accredited heritage specialist must be notified of the find immediately. Measures to be implemented in line with the specialist recommendations.  Prior to damaging or destroying any grave, permission for the exhumation and relocation of graves must be obtained from the relevant descendants (if known), the National Department of Health, the Provincial Department of Health, the Premier of the Province and the local Police.  The exhumation process must comply with the requirements of the relevant Ordinance on Exhumations, and the Human Tissues Act, 65 of 1983.

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9 CONCLUSIONS AND RECOMMENDATIONS This chapter summarises the key findings of the study.

The applicant, Project Jordan Holding Company (Pty) Ltd, is facilitating the application for the proposed maize wet mill plant which would be developed and operated as a majority Black Owned (>51%) plant. The proposed wet mill plant would process raw non-GMO maize to produce glucose and starch products. Glucose and starch are used as ingredients in the manufacturing of beverage and food products. A number of by- products would also be produced that can be used for animal feed or in the paper and textile industry. The proposed plant would have a capacity to process between 1 200 and 2 000 tons of maize per day.

Specialist input was provided on the likely impact of the proposed project on the biophysical, socio-economic and cultural aspects of the environment. The findings of the specialist input and other relevant information have been integrated and synthesised into this draft BAR. The two main objectives of this draft BAR are, firstly, to assess the environmental significance of impacts resulting from the proposed maize wet milling activities and to suggest ways of mitigating negative impacts and enhancing benefits, and secondly to provide I&APs with an opportunity to comment on the proposed project.

A summary of the assessment of potential environmental impacts associated with the proposed project is provided in Table 9-1. The assessment has assumed the relocation of the Wise Owl pre-school prior to construction. The mitigated assessment assumes that technical design controls, as included in the project scope, together with mitigation measures included in the environmental management programme (EMPr) would be included in the detailed design of the plant and implemented when the plant is constructed and operated.

TABLE 9-1: SUMMARY OF THE SIGNIFICANCE OF THE POTENTIAL IMPACTS ASSOCIATED WITH THE PROPOSED PROJECT

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Significance of impacts Potential impact Without With mitigation mitigation Reduction in grazing land affecting livelihoods of local farmers L VL+ Disturbance to third party road users by project-related traffic H L+ Increase in safety risks to third parties and communities H Insignificant Change in land use affecting sense of place L VL Disturbance of ground resulting in damage to heritage resources No impact VH – Very High; H – High; M- Medium; L – Low; VL – Very Low; + denotes a positive impact; C – Construction; O - Operations

Operational activities present the most potential for negative air quality impacts as these activities would be conducted over a long period. More significant impacts are predicted to occur due to PM2.5 and PM10 emissions from material handling extraction systems followed by SO2 emissions associated with the boiler plant. Design controls and additional mitigation (as recommended by the air quality specialist) would reduce potential impacts in an area with already elevated ambient concentrations. The impact on air quality and the related inhalation health impacts are considered to be of HIGH significance without mitigation and LOW significance with design controls and additional mitigation.

Where control systems are included in the engineering design and operation of the overall plant, potential odour related impacts would be minimised.

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project would generate significantly more employment and economic value than the site currently does. These factors would contribute to transformation, economic growth and socio-economic development in the area. The related social benefits are also considered to be positive in nature. Key to realising the MEDIUM positive mitigated significance of social benefits associated with increased employment and economic development is to recruit employees and procure services locally as far as possible and implement corporate social responsibility initiatives in the local area.

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10 REFERENCES

Airshed Planning Professionals. (2018a). Air quality specialist report for a proposed maize wet mill plant, Vereeniging, Gauteng. Report Ref: 17SLR25.

Airshed Planning Professionals. (2018b). Noise specialist study: Proposed maize wet mill facility, Vereeniging, Gauteng. Report Ref: 17SLR18N.

Bamford, P. M. (2018). Palaeontological Impact Assessment for the proposed maize wet mill plant (Project Jordan) on Farm Leeuwkuil 596IQ, Vereeniging, Gauteng Province.

Barbour, T. (2007). Guideline for Involving Social Assessment Specialists in EIA Processes. . Western Cape Department of Environmental Affairs and Development Planning, February 2007 .

Department of Water and Sanitation. (2014). Emfuleni Local Municipality: Leeuwkuil Waste Water TReatment Works, License No. 08/C22F/FG/2676.

IFC. (2007). General Environmental, Health and Safety Guidelines.

IFC. (2007). General Environmental, Health and Safety Guidelines. World Bank Group.

Mercury Financial Consultants. (2018). Economic assessment report for the proposed maize wet mill plant. Report Ref.: 1/1.

Nomad Consulting. (2018). Social Impact Assessment, Proposed maize wet mill, Leeuwkuil, Vereeniging, Gauteng. Nomad Consulting, South Africa.

Pistorius, D. J. (2018). A Phase I Heritage Impact Assessment study for the proposed maize wet mill plant in Vereeniging in the Gauteng Province.

SANS 10103. (2008). The measurement and rating of environmental noise with respect to annoyance and to speech communication. Pretoria: Standards South Africa.

Scientific Aquatic Services. (2018). Fresh water resource assessment as part of the Environmental Assessment and Authorisation Process for the proposed Project Jordan; near Vereeniging, Gauteng province. Report Ref. 218150.

Scientific Terrestrial Services. (2018). Terrestrial ecological scan investigation as part of the environmental authorisation process for the proposed maize wet mill plant, near Vereeniging Gauteng Province. Report Ref.: STS 180028.

SLR. (2018a). Geotechnical Site Investigation. Project No. 720.19124.00002.

SLR. (2018b). Surface water study for a Maize Wet Mill Plant. Report Ref.: 2018-WG8, SLR Project No. 720.19124.00003. SLR Consulting (South Africa) (Pty) Ltd.

SLR. (2018c). Soil and contaminated land assessment for the proposed maize wet mill plant near Vereeniging, Gauteng. Report Ref.: SLR Project No. 720.19124.00007, SLR Consulting (South Africa) (Pty) Ltd.

SLR. (2018d). Groundwater study for the Proposed MAize Wet Mill PLant, Vereeniging, Gauteng. SLR Project No. 7SN.19124.00006. SLR Consulting (South Africa) (Pty) Ltd.

Urban Dynamics Gauteng. (2017). Emfuleni Spatial Development Framework 2017-2025.

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WRC. (2012). Water Resources of South Africa Manual WR2012. WRC Report No. TT 380/08, Water Research Commission, Pretoria.

WSP. (2018). Traffic impact assessment. Report Ref. No. 24738.

Young, G. A. (2018). Visual Impact Assessment, Maize wet mill plant. Final.

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