Addendum Environmental Impact Report (Eir) for the Proposed Regional General and Hazardous Waste Management Facility in the Eastern Cape

ADDENDUM ENVIRONMENTAL IMPACT REPORT (EIR) FOR THE PROPOSED REGIONAL GENERAL AND HAZARDOUS WASTE MANAGEMENT FACILITY IN THE EASTERN CAPE

DEA REFERENCE NO: 14/12/16/3/3/3/106

Prepared by

EOH Coastal & Environmental Services The Point, Suite 408 - 4th Floor 76 Regent Road, Sea Point Cape Town South Africa

Prepared for

Coega Development Corporation Coega Business Centre Corner Alcyon Road & Zibuko Street Zone 1, Coega IDZ Port Elizabeth, 6100

DRAFT FOR PUBLIC REVIEW

SEPTEMBER 2016

Addendum Environmental Impact Report, September 2016

EOH Coastal and Environmental Services Report Title: Addendum Environmental Impact Report (EIR) for the Proposed Regional General And Hazardous Waste Management Facility in the Eastern Cape Report Version: Draft Version 2 Project Number: 292

Name Responsibility Signature Date

M. Hardy EAP/Project Manager June 2015

K. Whittington-Jones Review September 2016

WS Rowlston Revision 1 May 2016

WS Rowlston Final August 2016

EOH Coastal & Environmental Services i Coega Development Corporation Addendum Environmental Impact Report, September 2016

EXECUTIVE SUMMARY

The purpose of this Addendum Environmental Impact Report (EIR) for the Proposed Regional General and Hazardous Waste Management Facility in the Eastern Cape is to respond to issues raised by the Department of Environmental Affairs in its March 2014 letter rejecting the July 2010 EIR, and in interactions with the Coega Development Corporation prior to and subsequent to the rejection.

The following conclusions have been drawn in response to the department’s enquiries.

Upgrading the Motherwell to Addo road (R335) The section of the R335 between its junction with the N2 highway on the south-eastern side of Motherwell and its intersection with the R342 near Coerney Railway Station, north of Addo, was declared as National Road R335, Section 1, by Government Notice No 733, published in the Government Gazette No 40085 on 22nd June 2016.

Communication with staff at SANRAL’s Port Elizabeth office indicates that the procurement of consulting engineering services for the design review of this road is currently being investigated, with a view to commencing the upgrade in two to three years. In the meantime SANRAL will be maintaining the road through a maintenance contract.

Land issues Negotiations are in progress between PPC Ltd and CDC to acquire the land for the proposed waste facility.

The CDC will undertake the required rezoning process once the necessary authorisations (environmental authorisation and waste management licence) have been secured from DEA.

PPC has provided information that shows that the site for the proposed waste management facility is included inside the boundary of the mining right for its quarrying activities. This being the case it will be necessary to obtain approval from the Minister of Mineral Resources, in terms of s53 of the Mineral and Petroleum Resources Development Act, to use the surface of the land in a way that may be contrary to any object of the act.

Thermal processing of waste The current design of the facility does not include a thermal treatment facility of any kind, including incineration.

Validity and completeness of impact ratings There is no good reason to dispute or alter any of the significance ratings attached to the impacts identified by the specialists, or to question the measures they proposed to mitigate the effects of the impacts.

Examination of the impacts identified by the specialists in the July 2010 EIR indicates that they cover all the requirements of the most recent environmental and waste management listed activities.

In response to an enquiry by the Eastern Cape Provincial Air Quality Officer, clarification has been added about the way in which the impacts of volatile organic compounds (VOCs) were determined, and an estimate has been made of the maximum annual rates of greenhouse gas emissions from the landfill.

EOH Coastal & Environmental Services i Coega Development Corporation Addendum Environmental Impact Report, September 2016

Submission of an integrated application for environmental authorisation and waste management licence An integrated application has been prepared, based on the listed activities in the 2014 NEMA EIA Regulations, and the 2013 NEM: Waste Act Regulations.

The Permit Application Report prepared by Jones & Wagener in 2008 will be submitted with the integrated application, but by agreement with DEA the report will be updated as a condition of the authorisation, before any further work is undertaken on the facility.

Period of validity of the environmental authorisation It is recommended that: (i) The CDC and Enviroserv maintain regular contact to ensure that the status of the Aloes II waste facility in respect of its remaining life is known to each party. (ii) The Environmental Authorisation for the proposed new waste management facility is granted for the longest allowable period (10 years in the December 2014 EIA Regulations), and that no unnecessary barriers are put in the way if extending the validity of the authorisation, should 10 years prove to be too short a period. (iii) The department allows the greatest possible flexibility in specifying the period for which the Waste Management Licence is issued, the conditions attached to any amendments to the licence that may prove to be necessary, and the period within which renewal of the licence must be applied for.

Public review

This Addendum report and the integrated application will be made available for public review for a 30-day period before it is submitted to the department. No changes have been made to the 2010 Environmental Impact Report or the 2008 Permit Application report, but links will be provided to electronic copies of these reports for ease of reference.

Comments from the public will be collated and responses prepared, and any necessary changes made to the Addendum before it is submitted to the department for a decision.

EOH Coastal & Environmental Services ii Coega Development Corporation Addendum Environmental Impact Report, September 2016

TABLE OF CONTENTS

1. INTRODUCTION ...... 1 1.1 Background ...... 1 1.2 Activities to Date ...... 2 1.3 Submission and Rejection of the Environmental Impact Report ...... 3 1.4 DEA Guidance on the Way Forward ...... 4 1.4.1 Before the rejection of the FEIR ...... 4 1.4.2 After the rejection of the FEIR ...... 4 1.5 Terms of Reference ...... 4 1.6 The Project Team ...... 5 2. RESPONSES TO THE REJECTION OF FINAL ENVIRONMENTAL IMPACT REPORT ...... 7 2.1 Motherwell to Addo Road ...... 7 2.1.1 Anticipated traffic volumes ...... 7 2.1.2 Responsibility for upgrading the road ...... 7 2.2 Land Issues...... 8 2.2.1 Expropriation of land from PPC Limited ...... 8 2.2.2 Consent from the landowner ...... 8 2.2.3 Rezoning of the land for waste disposal ...... 8 2.3 Thermal Processing of Waste...... 8 2.4 Specialist Studies ...... 8 2.4.1 Validity of impact ratings ...... 8 2.5 Integrated Environmental Authorisation / Waste Management Licence application ...... 9 2.6 Motivation for the period of validity of the EA ...... 9 3. REVIEW OF APPLICABLE LISTED ACTIVITIES ...... 11 3.1 Regulatory requirements ...... 11 3.2 Completeness of impact assessment ...... 14 4. REVIEW OF THE SIGNIFICANCE OF IMPACTS ASSESSED PREVIOUSLY ...... 17 4.1 Introduction ...... 17 4.2 Flora ...... 17 4.3 Fauna ...... 18 4.4 Geology and Geohydrology ...... 18 4.5 Tourism ...... 18 4.6 Visual ...... 18 4.7 Air Quality ...... 19 4.7.1 Greenhouse gases ...... 20 4.7.2 Volatile organic compounds ...... 21 4.8 Heritage ...... 21 4.9 Land Use...... 21 4.10 Transport...... 22 4.11 Social ...... 22 5. CONCLUSIONS AND WAY FORWARD ...... 23 References ...... 25 APPENDIX A: DEA Rejection Letter ...... 26 APPENDIX B: 2010 EIR Findings and Conclusions ...... 28 APPENDIX C: Specialist Letters of Opinion ...... 35 APPENDIX D: Landowner Notification ...... 39 APPENDIX E: Declaration of Section 1 of the R335 as a national road ...... 40 APPENDIX F: PPC Mining Area...... 44

EOH Coastal & Environmental Services iii Coega Development Corporation Addendum Environmental Impact Report, September 2016

FIGURES

Figure 1.1: General location of the proposed GHWMF ...... 3 Figure 4.1: Changes on and around the site 2006(left) and 2016 (right) ...... 17 Figure 4.2: Location of the waste site and nearby wind energy facilities ...... 19

TABLES

Table 3.1: NEMA EIA Regulations December 2014 – Applicable listed activities ...... 11 Table 3.2: NEM: WA Regulations November 2013 - Applicable listed activities ...... 13 Table 4.1: Estimated maximum annual GHG emissions ...... 20

LIST OF ABBREVIATIONS

AEL Atmospheric Emission Licence CDC Coega Development Corporation CES EOH Coastal & Environmental Services DEA Department of Environmental Affairs EIA Environmental Impact Assessment EIR Environmental Impact Report EMP Environmental Management Plan or Programme GHWMF General & Hazardous Waste Management Facility IDZ Industrial Development Zone PPC PPC Limited VOC Volatile Organic Compound

EOH Coastal & Environmental Services iv Coega Development Corporation Addendum Environmental Impact Report, September 2016

1. INTRODUCTION

1.1 Background

The Coega Development Corporation (CDC) and the Nelson Mandela Bay Municipality (NMBM) have identified the need for the establishment and operation of a new regional General and Hazardous Waste Management Facility (GHWMF) in the Eastern Cape to serve the municipality, the Coega IDZ, and the surrounding areas.

General waste generated in the area is currently disposed of at the Arlington landfill in Port Elizabeth and other general waste disposal sites. Hazardous waste is disposed of at the privately- owned Aloes High Hazard (H:H) waste management facility, or at the municipally-owned Koedoeskloof Low Hazard (H:h) waste management facility.

The designations H:H and H:h for hazardous waste management facilities are used in the Minimum Requirements for Waste Disposal by Landfill published by the Department of Water Affairs & Forestry. This was the national standard for landfill sites from its first publication in 1994 until it was superseded by regulations and national standards published in terms of the National Environmental Management: Waste Act in 20131. The H:h designation means that a landfill can accept wastes with hazard ratings of 3 (moderate hazard) and 4 (low hazard), while an H:H site can accept wastes with hazard ratings 3 and 4, as well as wastes with hazard ratings of 1 (extreme hazard) and 2 (high hazard).

The National Norms and Standards for Disposal of Waste to Landfill (GN R.636) sets out a classification system for landfills, illustrates the engineering design requirements for the containment barriers for each class of landfill, and describes of the types of waste that may be accepted for disposal at each class of landfill. The types of waste that may be accepted for disposal at a landfill are defined, in the National Norms and Standards for the Assessment of Waste for Landfill Disposal (GN R.635), in terms of the total and leachable concentrations of particular elements and chemical substances in a waste2.

According to this scheme the type of waste that will be sent for disposal at the proposed GHWMF will be Type 1 waste (the highest concentrations of elements and chemicals in waste that may be disposed of in a landfill), which may only be disposed of at a Class A landfill (the most protective containment barrier).

Although EnviroServ’s Aloes H:H landfill site (Wells Estate, Port Elizabeth) was extended by the construction of an additional cell in 2013, there is limited potential for further expansion of the facility. Accordingly it is expected to reach the end of its operational life within the next two decades. The Koedoeskloof H:h waste facility (between Uitenhage and Despatch) is limited in the types and volumes of hazardous waste that may be disposed of there. It is anticipated that the further development of the Coega Industrial Development Zone (IDZ) and associated industries will increase the demand for hazardous waste disposal facilities in the NMBM area.

It will therefore be necessary to ensure that, when there is no more airspace available at the Aloes II site, the ability to deal with hazardous wastes in the region is not interrupted, even for a short period. This means that there must be another operating facility in the vicinity of Port Elizabeth and the Coega IDZ, ready to accept hazardous waste immediately the Aloes II site reaches its capacity.

1 Waste Classification and Management Regulations (GN R.634); National Norms and Standards for the Assessment of Waste for Landfill Disposal (GN R.635), National Norms and Standards for the Disposal of Waste to Landfill (GN R.636), all published on 23rd August 2013 in Government Gazette No 36784. 2 Total Concentration Threshold (TCT) means the total concentration threshold limit, and Leachable Concentration Threshold (LCT) means the leachable concentration threshold limit, for particular elements or chemical substances in a waste, expressed as mg/kg, which are prescribed in section 6 of the Norms and Standards

EOH Coastal & Environmental Services 1 Coega Development Corporation Addendum Environmental Impact Report, September 2016

After detailed investigations a suitable site was identified for the proposed GHWMF, which will be a High Hazard (H:H) site, but which will also be a co-disposal facility (that is, it will accept both hazardous and general waste). The site is located approximately 30 km from Port Elizabeth along the R335 road from Motherwell to Addo (see Figure 1.1 below), and is located in the higher-lying areas a short distance west of the lower-lying areas of the Sundays River Valley. The property portions in question are currently owned by PPC Limited, who mines limestone on the properties for feedstock for its Port Elizabeth cement manufacturing plant.

1.2 Activities to Date

The process of obtaining environmental authorisation (EA) for the project and acquiring a waste management licence began in 2002. Project-related activities since that time are listed below:  2002: Application to Authorities – National offices in Pretoria (the Department of Environmental Affairs (DEA) for the EIA application, and the then Department of Water Affairs and Forestry (DWAF, now DWS) for the waste licence).  2003: Scoping Phase completed.  2006: Site Ranking completed.  2007: Feasibility Report completed.  2010: Draft EIR & Permit Application Report (PAR) completed.  2010: Final EIR & PAR - submission and presentation to DEA Waste directorate.  2011 & 2013: DEA site visits.  2012: Presentation to the Coega IDZ Environmental Liaison Committee (ELC).  2013: Submission of Integrated Application form to DEA.  March 2014: Letter of Rejection of Final EIR from DEA.  April 2014: CDC’s response to DEA Letter of Rejection.  May 2014: Presentation to ELC.  October 2014: Letter to DEA requesting extension of application / keep application open  April 2015: Meeting with DEA confirming process for completion of the EIA.  September 2016: Public review of Draft Addendum to EIR (current)  October 2016: Submission of Final addendum to EIA to DEA.

EOH Coastal & Environmental Services 2 Coega Development Corporation Addendum Environmental Impact Report, September 2016

Figure 1.1: General location of the proposed GHWMF

1.3 Submission and Rejection of the Environmental Impact Report

The Final Environmental Impact Report (FEIR) for the project was submitted to DEA in September 2010 and again in December 2012.

In March 2014 DEA wrote to the CDC rejecting the EIR because: (i) Concern was raised by the NMBM concerning the proposed site for the development in connection with the construction of the Motherwell to Addo Road and the expropriation of land from PPC. (ii) Interested and Affected Parties (I&APs) objected to the proposed development based on the indication in the scope of the project that there is a possibility of a thermal processing treatment plant or incinerator. (iii) The specialist studies done are out-dated, dating as far back as 2006, and the Department is unable to make an informed decision based on such studies.

As a result of these concerns the CDC was requested by DEA to:  Provide clarification on the issues and concerns raised by the NMBM and I&APs.  Provide confirmation from all specialists that the impacts identified and their significance have not changed with time.  Comply with the requirements of Regulations 56 and 57 of GN R.543 (NEMA EIA Regulations 2010) with regard to the allowance of a comment period for I&APs on all reports to the competent authority for decision making. Note: The letter of rejection was written in March 2014, during the currency of the June 2010 EIA Regulations. Subsequently, in December 2014, revised EIA Regulations came into effect. Section 40(1) of the 2014 EIA Regulations specifies at least a 30-day consultation period for all documents prior to submission to the regulatory authorities, and this coheres with the most recent (April 2015 – see 1.4.2 following) instruction from DEA in this regard.

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1.4 DEA Guidance on the Way Forward

1.4.1 Before the rejection of the FEIR Before the rejection of the FEIR CDC had held discussions with DEA’s Waste Directorate in 2012 and 2013, who directed that the following information must be submitted to the department before any construction may commence on the site:  Consent must be obtained from the landowner (PPC).  The land must be rezoned to waste disposal.  Proof that the budget for the Addo Road upgrade has been provided for. (The R335 must be upgraded by the time proposed facility is operational - this is a recommendation made in the EIA reporting to date, and is motivated to become a condition of environmental authorisation).

1.4.2 After the rejection of the FEIR After the rejection of the FEIR guidance on the above requirements was provided by DEA to CDC at two meetings subsequent to the rejection of the EIR, as follows: Advice from CDC Environmental Liaison Committee (ELC) meeting, May 2014  DEA indicated that, besides letters from the specialists, DEA also requires confirmation from the EAP that ratings used in the EIA remain the same.  A comment period of 21 days is required for the Addendum to the FEIR – comments to be submitted to DEA with copies to the EAP. (Source: Item 5.3.4 in CDC 2015)

Guidance from DEA on the EIA Application, April 2015  Addendum to EIR: CDC must appoint an EAP to draft an addendum to the EIR, focussing on a response to the 3 issues that were raised in DEA’s rejection letter of March 2014. Public participation (30 days) must be conducted in this regard.  Permit Application Report: DEA advised that the Permit Application Report (PAR) need not be amended at this stage. It must be amended before the final design stage, and this will be a condition of the Environmental Authorisation. The final design of the facility must be approved by DEA prior to construction.  DEA advised that CDC appoint an EAP to complete the EIA and to ensure that all December 2014 Listed Activities are assessed in the EIA. An updated EIA application form must therefore be submitted.  Addo Road: DEA queried why the Addo Road was part of the EIA application, as there are many road users; not just those that will be related to the proposed waste facility.  Environmental Authorisation validity: DEA advised that the Addendum to the EIR should include a motivation for the validity period of the Environmental Authorisation. (Source: Items 5.4.2, 5.4.3, 5.4.4. 5.4.5 & 5.4.8 in CDC 2015)

1.5 Terms of Reference

EOH Coastal & Environmental Services (CES) was appointed by the CDC in August 2015 to progress the application for environmental authorisation, with the following Terms of Reference: 1. Prepare and submit an Addendum to the Final Environmental Impact Report in order to obtain an Environmental Authorisation and acquire a Waste Licence. The Addendum will address the following: (i) The three issues raised in the DEA rejection of the Final EIR. (ii) Submission of updated application form. (iii) Ensure that all relevant Listed Activities in the December 2014 NEM: EIA Regulations are assessed in the EIA. Those that were not assessed must be included in the Addendum to the FEIR.

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(iv) Confirm that the impact significance ratings in the original EIA remain the same. (v) Confirm the reasons for the inclusion of the Addo Road upgrade in the original EIA. (vi) Obtain written confirmation from all specialists of the validity of the original specialist studies; (vii) Provide a motivation for DEA to grant the maximum validity period for the environmental authorisation. 2. Undertake the necessary public participation, including a 30-day public review and comment period. 3. Hold a pre-consultation meeting with the authorities and make two presentations at the Coega ELC meeting.

It should, however, be noted that, in accordance with advice given to CDC by DEA at a meeting held on 16th April 2015, “… the Permit Application Report (PAR) need not be amended at this stage. It must be amended before/at final design stage, which will be a condition of the Environmental Authorisation. The final design of the facility must be approved by DEA prior to construction.” Since the Permit Application Report (PAR) was prepared in December 2008 (Jones & Wagner 2008) the NEM: Waste Act and new waste-related Regulations have been promulgated that prescribe new waste and landfill classification systems and revised landfill liner designs and requirements. Consequently, the PAR will need to be amended, but this will be done in terms of a Condition attached to the EA, and is not addressed in this Addendum Report.

1.6 The Project Team

EOH CES has been involved in the EIA process in association with Bohlweki-SSI Environmental (now Royal Haskoning DHV) since its inception, with two of CES’s current staff members, Marc Hardy and Kevin Whittington-Jones, being engaged on the project since 2008 and 2006 respectively. A brief professional profile of the consultants is provided below:

Mr Marc Hardy (Principal Environmental Consultant/Project Manager) Marc holds a M. Phil (Environmental Management) from Stellenbosch University’s School of Public Management and Planning. His professional interests include environmental impact reporting for linear, energy and large infrastructure projects, strategic environmental reporting, environmental and social due diligence studies and compliance reviews for development financing institutions, environmental auditing and compliance monitoring. Before entering the consulting field he gained extensive experience in the EIA regulatory field whilst in the employ of the Gauteng Department of Agriculture, Conservation and Environment being responsible for the review of infrastructure projects such as the Gautrain Rapid Rail Link and representing the Department on various spatial and environmental planning project steering committees. In his time with CES Marc has been responsible for the planning and management of projects and research/specialist teams and support staff, the preparation and management of project budgets in excess of $500 000, as well as being responsible for the management of the CES Maputo, Mozambique office. He is currently managing the EIA processes for large infrastructure, renewable energy, commercial agriculture and mining developments throughout Africa (mostly to World Bank and International Finance Corporation Performance Standards).

Dr Kevin Whittington Jones (Study Leader/Environmental Assessment Practitioner) Kevin holds a PhD in Environmental Biotechnology and has been involved in integrated waste management, environmental management and bioremediation since 1998, when he joined the Department of Biotechnology, Rhodes University. He currently holds the position of Executive at EOH CES and is registered as an auditor with the Roundtable on Sustainable Biomaterials (RSB). His professional interests include environmental business risk/due diligence assessments, integrated waste management, environmental management systems and technical assistance related to international E&S Standards. Kevin has been involved in a number of greenfield industrial ESIA projects across Africa, both as Project Manager and / or as a waste management specialist. These ESIAs span a range of sectors including thermal power production (wood biomass and HFO), wind energy, mining (heavy mineral sands, copper, iron, monazite and

EOH Coastal & Environmental Services 5 Coega Development Corporation Addendum Environmental Impact Report, September 2016 graphite), large-scale forestry plantations, smelters (manganese and pig iron), steel mills, a brewery and bio-fuels (palm oil and sugarcane-to-ethanol). As such, he is familiar with a wide range of industrial, and agro-industrial, processes and the associated environmental, health and safety risks.

Mr Bill Rowlston (Principal Consultant) Bill holds a First Class Honours degree in civil engineering from the University of Salford, England (1971). He worked for 11 years in the English water sector before joining the South African Department of Water Affairs and Forestry, where he worked for 25 years> He contributed to the development of the National Water Policy and the National Water Act, and compiled and edited the National Water Resource Strategy, First Edition (2004), much of which he wrote. Bill joined CES as a Director in 2007. In addition to working as project manager, water resources and traffic specialist on a number of large ESIAs and ESHIAs in South Africa and in other African countries, he has undertaken environmental and social due diligence studies, compliance reviews and audits for a range of proposed and operational projects:

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2. RESPONSES TO THE REJECTION OF FINAL ENVIRONMENTAL IMPACT REPORT

2.1 Motherwell to Addo Road

2.1.1 Anticipated traffic volumes The estimated volume of heavy goods traffic that will be generated by the proposed waste management facility during its planned 20-year life, and which will use the Motherwell to Addo road (R335) as part of the route to and from site, is 100 loaded trips per day, rising over time to 250 loaded trips a day, and resulting in an equal number of unloaded return trips (Bohlweki 2010). It was therefore not unreasonable for the EIA to include an assessment of the condition of the potential routes to and from the site. Nor was it unreasonable for the EIA to include recommendations about how the condition of the road should be improved, in the interests of traffic safety on the road under increased trafficking.

Since the transport study was concluded new estimates have been made of the likely volumes of hazardous waste that the proposed new facility will be required to accept (see Jones & Wagner 2008). In addition, information from Enviroserv Waste Management (Pty) Ltd indicates that volumes of waste arriving at the Aloes waste management facility have decreased in recent years, and this could mean that the volumes of traffic using the R335 to access the proposed facility may be reduced to between one third and one half of the estimates in the EIR. However, the construction of a new cell at Aloes in 2013 is likely to extend the life of the facility for up to 20 years if present levels of waste generation continue. Accordingly it will be necessary to make new estimates of traffic volumes that will be using the R335 nearer to the time when the new facility will be required. Factors influencing the time frames for the new facility are addressed in section 2.6 following.

Given the extreme importance of road safety in the transport of hazardous materials, whatever the volumes of traffic required to do so eventually turn out to be, it was not unreasonable for the EIA to recommend that all roads that are to be used as access routes to the proposed waste facility, including the R335, should be upgraded to improve traffic safety before the commencement of use by traffic to the waste management facility. This should be seen in the light of concerns put forward by the Sundays River citrus growing industry representatives, regarding the addition of large numbers of heavy vehicles carrying hazardous material to the existing volumes of traffic transporting produce past the GHWMF site to port for export, and the use of the R335 as a tourist route into the Sundays River Valley.

2.1.2 Responsibility for upgrading the road There was, however, no suggestion in the EIA Report that the responsibility for upgrading the road, and therefore the costs of the necessary work, should be borne by the NMBM, nor was there any suggestion that the costs of the work should be borne by the CDC. The EIA clearly acknowledges that the road is the responsibility of the Provincial Department of Roads and Transport. The Provincial Department of Roads and Transport has stated that it is committed to upgrading Addo Road regardless of the proposed waste site development and once upgraded; the recommended design standard of Addo Road will be able to accommodate the heavy vehicle traffic that will be generated by the waste facility. (Bohlweki 2010, s13.8, p206) Since the EIR was completed the section of the R335 between its junction with the N2 highway on the south-eastern side of Motherwell and its intersection with the r342 near Coerney Railway Station, north of Addo, was declared as National Road R335, Section 1, by Government Notice No 733, published in the Government Gazette No 40085 on 22nd June 2016. (See Appendix E)

EOH Coastal & Environmental Services 7 Coega Development Corporation Addendum Environmental Impact Report, September 2016 maintaining the road through a maintenance contract. (See Appendix E)

In accordance with DEA’s views expressed to the CDC, the road upgrade will be regarded as being completely separate from the environmental authorisation for the proposed waste management facility, and it is not expected that there will be any conditions attached to the authorisation that refer to the road upgrade.

2.2 Land Issues

2.2.1 Expropriation of land from PPC Limited Expropriation of the land has not been considered by any of the parties involved in the project, and negotiations are in progress between PPC Ltd and CDC to acquire the land for the proposed waste management facility.

2.2.2 Consent from the landowner

Negotiations are in progress between PPC Ltd and CDC to acquire the land for the proposed waste facility.

2.2.3 Rezoning of the land for waste disposal The CDC will undertake the required rezoning process once the necessary authorisations (environmental authorisation and waste management licence) have been secured from DEA.

Information provided by PPC (see Appendix E) shows that the site for the proposed waste management facility is included inside the boundary of the mining right for its quarrying activities. This being the case it will be necessary to obtain permission from the Minister of Mineral Resources, in terms of s53 of the Mineral and Petroleum Resources Development Act, to “use the surface of any land in any way which may be contrary to any object of the Act or which is likely to impede any such object.”

2.3 Thermal Processing of Waste

It was clearly stated in the 2010 EIR (top of page vi, among others) that the current design of the facility does not include a thermal treatment facility (where the term thermal treatment includes any waste treatment technology that involves high temperatures in the processing of the waste feedstock, and includes incineration).

Infrastructure to facilitate such treatment is not included in the application for a waste management licence (see Chapter 3). Should the addition of such a facility be considered in the future it will have to be the subject of an EIA process in terms of NEMA, together with a parallel process to acquire an atmospheric emissions licence in terms of NEM: Air Quality Act and its associated regulations that prevail at the time.

2.4 Specialist Studies

2.4.1 Validity of impact ratings Each of the specialist studies is discussed in turn in Chapter 4, in the context of the impacts assessed previously (summarised in Appendix B), and considering any changes that have occurred on and around the site of the proposed facility (discussed in section 4.1).

It was not possible to contact all of the specialists who worked on the July 2010 EIR to obtain their written opinions on the continuing relevance of the results of their studies. Some of them had left the companies for whom they worked when they conducted the studies, and their current whereabouts could not be determined. Others could not be contacted using the contact details available at the time of the studies.

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As a result it was only possible to obtain letters of opinion from four of the specialists, and their comments are included in the text. For the other studies an opinion was expressed by EOH CES, based on an assessment of the original studies and the changes that have occurred on and around the site. It was concluded that there was no good reason to dispute or alter any of the significance ratings attached to the impacts identified by the specialists, or to question the measures they proposed to mitigate the effects of the impacts.

2.5 Integrated Environmental Authorisation / Waste Management Licence application

An integrated application for environmental authorisation and a waste management licence has been prepared for submission to DEA. The application will be submitted to the department with the December 2008 Permit Application Report, July 2010 EIR and this Addendum report as supporting documentation.

DEA has indicated that the Permit Application Report prepared by Jones & Wagener in 2008 need not be updated now to reflect changes since its preparation, but that it must be updated and approved by the department as a condition of the authorisation, before any further work is undertaken on the design of the facility.

The listed activities to which the application relates are set out in Chapter 3 of this report, and are taken from:  The NEMA EIA Regulations, December 2014 (GN R.983, 984 & 985)  The NEM: Waste Act Regulations, November 2013 (GN R.921)

An assessment is provided in Chapter 4 of the extent to which the July 2010 EIR provides assessments of the impacts relating to all the listed activities from the most recent listing notices for both acts.

Prior to submission to the DEA, the Addendum Report and the Integrated Application will be made available for public comment for 30 days. No changes have been made to the 2010 EIR or the 2008 Permit Application report, but links will be provided to electronic copies of these reports for ease of reference.

2.6 Motivation for the period of validity of the EA

At this stage it is not possible to develop a firm project schedule for the design and construction of the waste management facility.

Information from Enviroserv Waste Management (Pty) Ltd, which operates the existing Aloes hazardous (H:H / Class A) waste management facility in Port Elizabeth, indicates that the implementation of the NEM: Waste Act’s waste management hierarchy by many waste generators, combined with the progressive reduction in the volumes of domestic waste submitted to the site and the construction of an additional cell in 2013, has resulted in a reduction in the volumes of waste received at the facility. Enviroserv estimate that the consequential extension of the operating life of the facility is likely to be for an additional 20 years, until around 2035. This period may, however, be reduced if the volumes of hazardous waste generated in the region, particularly from increased industrial activity in the Coega IDZ, increases significantly in the future. The current volumes of wastes dealt with at the Aloes facility are between 5 000 and 6 000 tons per month. (Source: pers comm Ms S Alcock, EnviroServ, 5th May 2016.)

The economic viability threshold of waste receipt at a hazardous waste facility is around 4 000 tonnes/month, and it is therefore not economically viable to operate two H:H / Class A waste management facilities in the region. It is nevertheless necessary to ensure that, when there is no more airspace available at the Aloes facility, the ability to deal with hazardous wastes in the region is not interrupted, even for a short period. This means that there must be another operating facility in the vicinity of Port Elizabeth and the Coega IDZ, ready to deal with hazardous waste

EOH Coastal & Environmental Services 9 Coega Development Corporation Addendum Environmental Impact Report, September 2016 immediately the Aloes facility reaches its capacity and must be closed.

The design and construction of the proposed new facility is likely to take at least five years. The design of such a facility is costly, and will not commence in earnest until all necessary authorisations have been secured from the regulatory authorities. Two of these authorisations will be the Environmental Authorisation and the Waste Management Licence, both from DEA.

By agreement between the department and CDC, one of the conditions that will be attached to the Environmental Authorisation will be to revise and update the Permit Application Report prepared by Jones & Wagener in December 2008, and to submit the revised report in as a condition of the environmental authorisation, before the issue of the Waste Management Licence for the facility. Construction of the facility will not commence until the licence has been issued.

In addition, certain detailed site surveys, followed by search, rescue and relocation programmes recommended by vegetation and faunal specialists (notably in respect of the Critically Endangered Albany Adder) will have to be undertaken immediately before the commencement of site clearance works.

In view of the factors involved in determining the date on which the proposed new facility will need to be operational it is recommended that: (i) The CDC and Enviroserv maintain regular contact to ensure that the status of the Aloes II site in respect of its remaining life is known to each party. (ii) The Environmental Authorisation for the proposed new waste site is granted for the longest allowable period (10 years in the December 2014 EIA Regulations), and that no unnecessary barriers are put in the way if extending the validity of the authorisation, should 10 years prove to be too short a period. (iii) The department allows the greatest possible flexibility in specifying the period for which the Waste Management Licence is issued, the conditions attached to any amendments to the licence that may prove to be necessary, and the period within which renewal of the licence must be applied for.

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3. REVIEW OF APPLICABLE LISTED ACTIVITIES

3.1 Regulatory requirements

The proposed GHWMF requires environmental authorisation and a waste management licence, as prescribed by the respective sets of legislation and regulations governing these processes and approvals. These are: (i) The National Environmental Management Act (NEMA), 1998 (Act 107 of 1998 as amended), and the December 2014 Environmental Impact Assessment (EIA) Regulations, December 2014 (GN R982, 983, 984 & 985). (ii) The National Environmental Management: Waste Act (NEM: WA), 2008 (Act 59 of 2008, as amended), and the List of activities that have, or are likely to have a detrimental effect on the environment, November 2013 (GN R.921). The applicable listed activities included in the integrated Environmental Authorisation and Waste Management Licence application are tabulated in Tables 3.1 and 3.2 respectively.

Table 3.1: NEMA EIA Regulations December 2014 – Applicable listed activities Listing Activity Notice number Description of Activity and related project activity GN R.983 11 The development of facilities or infrastructure for the transmission and distribution of (BA) electricity- (iv) outside urban areas or industrial complexes with a capacity of more than 33 but less than 275 kilovolts; or It will be necessary to construct a powerline to connect the site to the closest Eskom powerline. The capacity of the new powerline will be more than 33kV but less than 275kV. Voltage will be stepped down on site as required. GN R.983 12 The development of – (BA) (iv) dams, where the dam, including infrastructure and water surface area, exceeds 100 square metres in size; (x) buildings exceeding 100 square metres in size; (xii) infrastructure or structures with a physical footprint of 100 square metres or more; where such development occurs- (a) within a watercourse; or within 32 metres of a watercourse The development will include the construction of buildings and infrastructure exceeding 100m2 within 32m of watercourses located on the site. Infrastructure will include: Lined landfill structures, leachate and contaminated stormwater containments, offices and stores. The EIA Report indicates that there are drainage lines crossing the site, which are regarded as watercourses by DWS. GN R.98 14 The development of facilities or infrastructure, for the storage, or for the storage and (BA) handling, of a dangerous good, where such storage occurs in containers with a combined capacity of 80 cubic metres or more but not exceeding 500 cubic metres. Hazardous wastes are defined as dangerous goods. The types of hazardous wastes expected to be received at the site are described in Jones and Wagener’s Permit Application Report, December 2008: Appendix B, Section 4 and Table 1 (pp83-85). The table is reproduced in Part D of the integrated application. Approximately five million cubic metres of airspace is required for a twenty-year site life, including for co-disposal and cover requirements. GN R.983 19 The infilling or depositing of any material of more than 5 cubic metres into, or the (BA) dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock of more than 5 cubic metres from - (i) a watercourse;

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Listing Activity Notice number Description of Activity and related project activity The construction of roads and the laying of pipelines will require the infilling and depositing of material in excess of 5m3 in the drainage lines that cross the site, and which are regarded as watercourses by DWS. GN R.984 4 The development of facilities or infrastructure, for the storage, or storage and handling of (EIA) a dangerous good, where such storage occurs in containers with a combined capacity of more than 500 cubic metres. Hazardous wastes are defined as dangerous goods. The types of hazardous wastes expected to be received at the site are described in Jones and Wagener’s Permit Application Report, December 2008: Appendix B, Section 4 and Table 1 (pp83-85). The table is reproduced in Part D of the integrated application. GN R.984 15 The clearance of an area of 20 hectares or more of indigenous vegetation. (EIA) The footprint of the hazardous waste facility will exceed 30 hectares. Clearance of more than 20ha of indigenous vegetation is probable. GN R.985 4 (b)Iii)(ee) Eastern Cape: The development of a road wider than 4 metres with a reserve (BA) less than 13,5 metres, in critical biodiversity areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans; New roads wider than 4m will be constructed on the site. The site in in a CBA2 (near natural). GN R.985 10 (a)(II)(EE) Eastern Cape: The development of facilities or infrastructure for the storage, or (BA) storage and handling of a dangerous good, where such storage occurs in containers with a combined capacity of 30 but not exceeding 80 cubic metres, in critical biodiversity areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans; Hazardous wastes are defined as dangerous goods. The site is in a CBA2 (near natural).

GN R.985 12 (a)(ii) Eastern Cape: The clearance of an area of 300 square metres or more of indigenous vegetation. The hazardous waste site will be approximately 30 ha in extent. The site in in a CBA2 (near natural). It is certain that it will be necessary to clear of more than 300 square metres of indigenous vegetation is certain. GN R.985 14 (a)(ii)(ff) Eastern Cape: The development of – (iv) dams, where the dam, including infrastructure and water surface area, exceeds 100 square metres in size; (x) buildings exceeding 100 square metres in size; (xii) infrastructure or structures with a physical footprint of 100 square metres or more; where such development occurs- (a) within a watercourse; or within 32 metres of a watercourse The site is in a CBA2 (near natural). The development will include the construction of buildings and infrastructure exceeding 10m2 within 32m of watercourses located on the site. Infrastructure will include lined landfill structures, leachate and contaminated stormwater containments, offices and stores. The EIA Report indicates that there are drainage lines crossing the site, which are regarded as watercourses by DWS. GN R.985 18 (b)(ii)ee) Eastern Cape: The widening of a road by more than 4 metres, or the lengthening of a road by more than 1 kilometre. The site is in a CBA2 (near natural). It may be necessary to widen or lengthen existing roads to facilitate access to the site or within its boundaries.

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Table 3.2: NEM: WA Regulations November 2013 - Applicable listed activities Listing Activity Description of Activity and related project activity Notice number GN R.921 (A) 2 The sorting, shredding, grinding, crushing, screening or bailing of general waste at a (BA) facility that has an operational area in excess of 1000m2 General waste will be sorted and/or ground and bailed prior to burial. GN R.921 (A) 3 The recycling of general waste at a facility that has an operational area in excess of 500m2, (BA) excluding recycling that takes place as an integral part of an internal manufacturing process within the same premises. General waste will be recycled in an area which has an operational area in excess of 500m2. GN R.921 (A) 4 The recycling of hazardous waste in excess of 500kg but less than 1 ton per day calculated as a (BA) monthly average, excluding recycling that takes place as an integral part of an internal manufacturing process within the same premises. Hazardous waste in excess of 500kg (but less than 1 ton) per day will be recycled at the facility. GN R.921 (A) 5 The recovery of waste including the refining, utilisation, or co- processing of waste in excess of 10 (BA) tons but less than 100 tons of general waste per day or in excess of 500kg but less than 1 ton of hazardous waste per day, excluding recovery that takes place as an integral part of an internal manufacturing process within the same premises. It is anticipated that there will be recovery or processing of waste where viable. Inert waste will also be used in the co-disposal of solid and/or liquid waste during the internment process. GN R.921 (A) 6 The treatment of general waste using any form of treatment at a facility that has the capacity to (BA) process in excess of 10 tons but less than 100 tons. The treatment of general waste is anticipated to take place at the facility in order to facilitate the co- disposal processes referred to above. GN R.921 (A) 7 The treatment of hazardous waste using any form of treatment at a facility that has the capacity to (BA) process in excess of 500kg but less than 1 ton per day excluding the treatment of effluent, wastewater or sewage. The treatment of hazardous waste is anticipated to take place at the facility in order to facilitate the co-disposal processes, as well as neutralisation of acids and alkalis, precipitation of heavy metals, oxidation of cyanide and reduction of chromate. GN R.921 (A) 9 The disposal of inert waste to land in excess of 25 tons but not exceeding 25 000 tons, excluding (BA) the disposal of such waste for the purposes of levelling and building which has been authorised by or under other legislation. Significant volumes of inert waste are also expected to be buried at the proposed facility. GN R.921 (A) 12 The construction of a facility for a waste management activity listed in Category A of this Schedule (BA) (not in isolation to associated waste management activity). The proposed facility will require the construction of the associated infrastructure needed to operate the hazardous waste facility. GN R.921 (B) 1 The storage of hazardous waste in lagoons excluding storage of effluent, wastewater or sewage. (S+EIA) There will be temporary storage facilities for the storage and/or solid hazardous wastes prior to treatment and burial at the landfill. GN R.921 (B) 3 The recovery of waste including the refining, utilisation, or co- processing of the waste at a facility )S+EIA) that processes in excess of 100 tons of general waste per day or in excess of 1 ton of hazardous waste per day, excluding recovery that takes place as an integral part of an internal manufacturing process within the same premises. The recovery plant for heavy metals and other valuable materials, if quantities warrant it, has also been included in the proposed facility’s operational capacity processes. GN R.921 (B) 4 The treatment of hazardous waste in excess of 1 ton per day calculated as a monthly average; (S+EIA) using any form of treatment excluding the treatment of effluent, wastewater or sewage. As above. GN R.921 (B) 5 The treatment of hazardous waste in lagoons, excluding the treatment of effluent, wastewater or (S+EIA) sewage. Preliminary designs for the proposed facility include a small waste stabilisation, immobilisation and micro-encapsulation plant. This will require a containment (lagoon) structure.

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Listing Activity Notice number Description of Activity and related project activity GN R.921 (B) 6 The treatment of general waste in excess of 100 tons per day calculated as a monthly average, (S+EIA) using any form of treatment. General waste exceeding 100 tons per day as a monthly average will be treated on the site, in the plant described in (B) 5 above. GN R.921 (B) 7 The disposal of any quantity of hazardous waste to land. (S+EIA) Hazardous waste will be buried at the landfill. GN R.921 (B) 8 The disposal of general waste to land covering an area in excess of 200m2 and with a total capacity (S+EIA) exceeding 25 000 tons. General waste will be buried at the landfill. The landfill is expected to be 30 hectares in size. GN R.921 (B) 9 The disposal of inert waste to land in excess of 25 000 tons, excluding the disposal of such waste (S+EIA) for the purposes of levelling and building which has been authorised by or under other legislation.

Significant volumes of inert waste are also expected to be buried at the proposed facility. GN R.921 (B) 10 The construction of a facility for a waste management activity listed in Category B of this Schedule (S+EIA) (not in isolation to associated waste management activity). The proposed facility will require the construction of the associated infrastructure needed to operate the hazardous waste facility. GN R.921 (C) 1 The storage of general waste at a facility that has the capacity to store in excess of 100m3 of (See Note) general waste at any one time, excluding the storage of waste in lagoons or temporary storage of such waste. The waste site will store general waste in excess of 100m3. GN R.921 (C) 2 The storage of hazardous waste at a facility that has the capacity to store in excess of 80m3 of (See Note) hazardous waste at any one time, excluding the storage of hazardous waste in lagoons or temporary storage of such waste. The waste site will store hazardous waste in excess of 80m3. GN R.921 (C) 5 The extraction, recovery or flaring of landfill gas. (See Note) Landfill Gas Management systems are incorporated into the preliminary design of the proposed facility to control volatile gas build up in case this occurs. Note: Category C activities require compliance with the relevant requirements or standards, in this case Norms and Standards for Storage of Waste, 2013, and Standards for Extraction, Flaring or Recovery of Landfill Gas, 2013.

3.2 Completeness of impact assessment

The following impacts were identified, assessed and rated for their significance by the specialists during the EIA, and mitigation or enhancement measures proposed.

Specialist Study Description of Impact assessed and rated Flora  Integrity and functioning of Mesic Succulent Thicket  Integrity and functioning of Bontveld  Loss of endemic, protected and rare/endangered species – Mesic Succulent thicket  Loss of endemic, protected and rare/endangered species – Bontveld  Introduction and spread of alien plant species, weeds and invader plants Fauna  Loss and fragmentation of habitats  Loss of faunal diversity  Barriers to animal movement  Loss of Species of Special Concern  Increase in problem animals and alien species  Increased disturbance and mortality due to road traffic  Changes in natural fire regime  Pollution

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Specialist Study Description of Impact assessed and rated  Loss or reduction of ecosystem functioning Geology and Geohydrology Construction  Excavation and site preparation resulting in the disruption of natural runoff conditions  Groundwater contamination of existing boreholes  Storage and stockpiling areas for construction material resulting in soil and groundwater contamination  Construction camp and temporary infrastructure such as workshops, wash bays. - soil, surface water and groundwater contamination  Domestic sewage - soil, surface and groundwater contamination  Storm water on and around site impacting on natural surface water flow in drainage lines  Groundwater recharge - Improving groundwater recharge  Fuel storage and distribution point - soil and groundwater contamination Operation  Waste disposal -soil, surface and groundwater contamination  Leachate holding dams Surface and groundwater contamination  Leachate treatment facilities - soil and surface water and eventually groundwater contamination  Leachate seepage from disposal cells. Soil, surface and groundwater contamination  Waste storage areas (temporary storage, recycling facilities). Soil, surface and groundwater contamination  Sewage disposal (septic tank systems) Surface and groundwater contamination  Runoff and storm water management on and around site. Surface and groundwater contamination  Washing areas (Vehicles, re-useable containers, etc) Surface and groundwater contamination  Workshops Surface and groundwater contamination Decommissioning  Closure/ capping of individual waste disposal cells Uncontrolled leachate generation and build-up of leachate level  Treating / disposal of surplus leachate and storm water in holding dams at final closure Contamination of ground and surface water resources  Maintenance of storm water control system. Soil erosion at closed disposal cells  Maintenance of capping Uncontrolled leachate generation  Maintenance of water monitoring systems (boreholes and surface water) and maintaining a sampling and analysis programme after closure according to permit conditions Quality deterioration of water resources Tourism  Perception before decision to visit  Perception of experience in the area  Visual  Wind/Smell  Traffic  Limitation of future tourism development in areas adjacent to the facility Visual  Viewer perception in area of likely visual impact  View from R335  View from other roads  Construction of access roads Air Quality Construction and Operation  PM10  Dustfall  Health Risk  Cancer Risk  Odour Post Closure

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Specialist Study Description of Impact assessed and rated  Health Risk  Cancer Risk  Odour Heritage  Construction may cause loss of archaeological remains Land Use and Resettlement  Physical displacement and resettlement  Rezoning for waste disposal  Landowner consent  Proximity of registered airfields  Future land use planning and development  Certification of citrus farms Transport  Increase in heavy vehicle traffic  Increased risk of vehicle accidents  Deterioration of existing road condition  Impacts on tourist traffic Socio-Economic Pre-Construction and Construction  Relocation of households and / or population segments  Arrival of construction workers  Influx of job seekers  Outflow of labourers  Compensation for the site  Direct formal employment opportunities to local individuals  Indirect employment opportunities to local individuals  Sense of place  Integration with local community  Physical splintering  Safety and security  Noise pollution  Attitude formation against the project (risk for social mobilization)  Additional demand on municipal services  Access Roads  Pollution and fire risk  Sanitation Operation  Arrival of operational workers  Direct formal employment opportunities to local individuals  The implementation of a Disaster Management Plan  Safety risk  Spatial development  Waste Management Decommissioning  Loss of employment opportunities  Direct formal employment opportunities to local individuals  Leachate Management

From the above it can be concluded that the impact assessment was comprehensive, and that all listed activities in Table 3.1 (NEMA EIA Regulations 2014) and Table 3.2 (NEM Waste Act Regulations 2013) were adequately covered by the specialist studies.

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4. REVIEW OF THE SIGNIFICANCE OF IMPACTS ASSESSED PREVIOUSLY

4.1 Introduction

This chapter details relevant substantive changes in the significance of previously-identified, assessed and reported impacts, and also notes where there are no significant changes that are observable or reportable. The concluding section of the 2010 Final EIR Executive Summary, which summarises the impact descriptions and the conclusions drawn from the assessment of the impacts, is reproduced in Appendix B as a reference to this chapter.

Significant changes have occurred around the site since the specialist studies were conducted. PPC Ltd’s mining operation has progressed eastwards, and a wind energy facility has been constructed close to the site on or near to previously-mined areas. The site itself has not been significantly altered by these activities, except for changes to an existing unsurfaced road that crosses the site diagonally from north-east to south-west, which has been widened to accommodate construction traffic for the erection of three turbines south of the site (see Figure 4.2 below). The road is also intended to provide access to the turbines for maintenance and repair purposes. Apart from this the two aerial images of the site in Figure 4.1 below indicate that the actual site has not changed to any significant extent in the last ten years.

Figure 4.1: Changes on and around the site 2006(left) and 2016 (right)

4.2 Flora

The report was prepared by Mr Joggie van Staden of Bohlweki SSI Environmental, now a division of Royal Haskoning DHV. Mr van Staden has left Bohlweki’s employment, his present whereabouts are not known and he is not contactable by telephone.

Mr Roy de Kock, one of EOH CES’s botanical specialists has written as follows:

EOH Coastal & Environmental Services 17 Coega Development Corporation Addendum Environmental Impact Report, September 2016

The full text of Mr De Kock’s letter is in Appendix C-2.

4.3 Fauna

Professor William R Branch, currently Curator Emeritus: Herpetology at Bayworld (Port Elizabeth Museum), conducted the original faunal study. He has written recommending that a detailed conservation plan for the critically endangered Albany Adder, including pre-construction surveys, must be prepared and implemented, and that this should be made a condition of the Environmental Authorisation. The full text of Professor Branch’s letter is included as Appendix C-4, from which it should be noted that he has not suggested that additional studies should be conducted prior to the application being considered by DEA.

4.4 Geology and Geohydrology

The underlying geology of the area will not have changed. The nature of geohydrology is such that no changes of any significance will occur to the groundwater regime over a period of ten years unless either the rate of aquifer recharge, or the use of water in the area, or both have changed significantly. Annual rainfall has not varied greatly over the long-term average since 1960 (SAWS, www.1stweather), and there have been no major new water-use projects developed in the area that could affect the baseline conditions. One of the reasons is because borehole yields are generally low, water quality is generally poor, with the result that groundwater use in the area is limited. Accordingly it was not considered necessary to request the specialist to provide supporting motivation for not revising the conclusions of the report. The significances of the impacts therefore remain unchanged from those reported in the specialist study.

4.5 Tourism

The impacts of the facility on tourism were found by the specialist to be generally negative, based to a small extent on visual, odour and traffic impacts, but to a greater extent on the notion that environmentally-conscious tourists may decide not to visit the Sundays River valley generally, and the Addo Elephant National Park in particular, because they consider a hazardous waste site to be environmentally harmful. Whether or not this belief is reasonable the impacts identified by the specialist and their significance remain unchanged.

4.6 Visual

In section 9.1.4 of the EIR – Visual Impact Index - the specialist who conducted the visual impact assessment notes: Scattered patches of visual exposure could occur along the R335 at a distance of about 6 km, but it is highly unlikely to raise awareness to potential observers. This is especially true for southbound traffic, which would not be able to see the facility. The footprint and its associated infrastructure would not be visible from most of the other roads in the study area.

Subsequently, in section 9.4.3 – Impact Analysis – the specialist writes:

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Footprint F (Grassridge 190) is a valley infill site and ranks as an ideal location for the hazardous waste processing facility. It has the most contained area of visual impact and lends itself to the highest level of successful impact mitigation measures. This is due to the enclosed nature of the valley within which it resides. The fact that the facility is theoretically visible from the R335 is not a major cause for concern. The likelihood of it ever being noticed or recognised as a landfill from a distance of 6 km is slim to negligible, as the site would never appear in its entirety.

Since the EIA for the waste facility was conducted the InnoWind Grassridge WEF has been constructed to the south and south-east of the site for the proposed waste facility. The WEF comprises 23 wind turbines, and these large structures have substantially altered the landscape. Two other WEFs to the west (Ukomeleza – 8 turbines) and to the south (Ukomeleza II – 22 turbines) of the waste facility site (see Figure 4.2), are in the planning stages and, if successful in the DoE REIPPP bid process, will be constructed in the near future. They will add to the visual alteration to the landscape of the area, and it is probable that these very large structures will occupy the attention of passing motorists, or the occupants of a tour bus, rather than what little of the proposed waste facility will be visible from the R335 road.

Notes: (i) The Grassridge WEF exists and is operating. (ii) The Ukomeleza and Ukomeleza II WEFs are in the planning stage. Figure 4.2: Location of the waste site and nearby wind energy facilities

The 2010 EIR rated the potential visual impact of the GHWMF as negligible, largely because of the topography of the valley area in which it will be located, and the distance of the R335 from the site, meaning that it is improbable that people in the Sundays River Valley or travelling along the R335 will be aware of the facility. Accordingly there is no compelling reason to alter the already low visual impacts of the facility that were identified in the specialist study.

4.7 Air Quality

No changes are necessary to the previously assessed air quality impacts. The specialist has written to confirm the continuing validity of the results of the study: the letter is included as Appendix C-1.

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However, at the August 2015 meeting of the Coega Environmental Liaison Committee the Eastern Cape Provincial Air Quality Officer recommended that more work was required to address the generation of greenhouse gases (GHGs) and the effects of volatile organic compounds (VOCs).

The identification of the landfill gases of concern and the quantification of the gaseous emissions were based on the classification of the waste streams expected to arrive at the waste facility. The annual volume of waste delivered to the facility is expected to increase approximately linearly for the first 10 or 11 years of the facility’s 20-year life, remaining relatively constant thereafter for the remaining constant until full capacity is reached. The rate of emission of gases is approximately proportional to the total volume of waste in the landfill, and will reach a maximum at year 20, when the site has reached its full capacity. Thereafter the rate of emission is expected to decrease approximately exponentially.

4.7.1 Greenhouse gases The emission of greenhouse gases from the landfill was not explicitly considered in the air quality study. However, the maximum rates of emission for three bulk gases were estimated as follows:

 Carbon dioxide (CO2): 1 462m³/hr  Methane (CH4): 1 279 m³/hr  Hydrogen (H2): 1.8m³/hr

Apart from water vapour, carbon dioxide and methane are the most abundant greenhouses gases in the atmosphere. The global warming potential - a simple measure of the radiative effects of emissions of the gas relative to an equal mass of CO2 emissions - of methane is 25.

The other major greenhouse gases, sensu the International Panel on Climate Change, are nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulphur hexafluoride (SF6), all of which were selected for inclusion in the air quality study. The maximum 95th percentile rates of emission of these gases were calculated to be zero at year 20 (AQ Report Table 4-9). The estimated maximum annual emissions of GHGs from the landfill are shown in Table 4.1

Table 4.1: Estimated maximum annual GHG emissions

Max bulk Max bulk Max bulk Global Max annual Density GHG emissions 3 emissions emissions Warming emissions 3 (kg/m ) (m /hr) (kg/hr) (tpa) Potential (t-CO2eq)

CO2 1 462 1.842 2 693 23 591 1 23 591

CH4 1 279 0.668 854 7 484 25 187 107

Total 31 075 210 698

In January 2016 a draft notice was published declaring greenhouse gases as priority pollutants. At the same time draft regulations were published requiring persons who conduct certain production processes to prepare Pollution Prevention Plans if their annual emissions exceed 0.1 megatonnes - 100 000 tonnes – of carbon dioxide equivalent (CO2eq).

The list of production processes that will be affected by this requirement (Annexure A of the draft regulations) does not include waste management. However, the expected rate of waste arriving at the facility is such that the threshold of 100 000 tonnes CO2-eq is likely to be exceeded in the first year of operation or very shortly thereafter. Given the nature of the facility it will be prudent for the owners / operators of the facility to contemplate preparing a pollution prevention plan in accordance with the regulations, and preparing to monitor, evaluate and report on the implementation of the plan.

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4.7.2 Volatile organic compounds The potential impacts of VOCs emitted from the waste site were considered in terms of non- carcinogenic health risks, cancer risks, and odour nuisance, all of which are comprehensively reported in the specialist air quality study report.

Particulates and dust

No exceedances of the ambient South African standards for PM10 were predicted to occur at any of the sensitive receptors, while slight dustfall levels (<250 mg/m²/day) were predicted to occur at all of the sensitive receptors located around the proposed GHWMF site.

Non-carcinogenic health risks The hazard quotient for chronic exposures from the landfill is predicted to be 0.012. The hazard quotients for the landfill are therefore predicted to be less than 1.0 (where fractions greater than 1 represent threshold exceedances) for all exposure periods at all sensitive receptors.

Cancer risk Total maximum incremental cancer risk levels were predicted to be less than ~ 1 in 3.5 million for the proposed landfill operations. The maximum cancer risk calculated at an external sensitive receptor site (farm Rooidam, about 4 km distant from the site) was 1 in 45 million.

Odour nuisance No odour threshold exceedances were predicted to occur due to on-site concentrations of odoriferous gasses. The maximum predicted concentration of an odoriferous compound as a fraction of the odour threshold was 0.04 OU/m3 (ethyl mercaptan), where a fraction greater than 1 indicates threshold exceedances and therefore a potential odour impact.

4.8 Heritage

The heritage specialist, Mr Jonathan Kaplan of the Agency for Cultural Resource Management, has written and confirmed that:  The specialist archaeological study did not encounter any important archaeological resources. Early, Middle and Later Stone Age archaeological remains were documented, but occur in a severely disturbed and degraded context.  No significant archaeological remains are likely to be negatively impacted during construction of the facility.  No one proposed or proposed alternative site is preferred over the other.  The area in which the proposed facility will be located is not considered to be a threatened archaeological landscape.  As long as the recommendations contained in the August 2004 reports are adhered to, there are no objections to the authorization of the proposed development.

By implication there is no need to repeat the study or to conduct any further investigations of the preferred site. Mr Kaplan’s letter is included as Appendix C-3.

4.9 Land Use

As noted in the 2010 EIR, the proposed GHWMF presents no land use or zoning conflicts relative to the status quo as it was in 2010. The requirement to rezone the land to accommodate waste disposal is addressed in section 2.2.3 above.

There is, however, an existing farm track that bisects the landfill cell footprint, which has been upgraded recently to serve the construction and operational requirements of three wind turbines on the Grassridge WEF (see Figure 4.2 above). This road will need to be diverted to skirt around the boundary of the waste facility, either to the north and south, in consultation with the landowner and the owner / operator of the WEF to determine the optimal route. It is possible that electrical cables

EOH Coastal & Environmental Services 21 Coega Development Corporation Addendum Environmental Impact Report, September 2016 from the turbines to the on-site substation have been routed alongside the road, and these will also need to be re-routed to follow the alignment of the road diversion.

It is not anticipated that the construction and operation of the waste facility will be affected by PPC’s mining operations, which are progressing westward away from the site of the waste management facility, or by the existing Grassridge WEF. No land use conflicts are expected between the waste site and the two proposed Ukomeleza WEFs, should they be approved and constructed. The construction of the new WEFs will generate significant volumes of traffic, especially abnormal loads to transport the elements of the turbines to site, but this work will be completed well before it will be necessary to commence work on the waste management facility.

4.10 Transport

The 2008 transport study investigated the impacts of traffic volumes expected to be generated by the hazardous waste management facility on the road system between Port Elizabeth and the site of the facility. The study considered the effects of the growth of traffic volumes – waste-related and “normal” non-waste–related traffic - over a 20-year period. Growth was based on data from municipal and provincial traffic authorities that showed a 6% growth in daily average traffic volumes between 1997 and 2007. The study considered all the roads necessary to access the site, but focussed on the R335 road, which is already heavily trafficked by goods vehicles from the citrus- growing areas of the Sundays River Valley, local domestic and tourist traffic, and is not in a good condition.

Eight years later the principal conclusion from the study, that the R335 needs to be upgraded, is still valid. In June 2016 the road was declared to be a national road, and therefore became the responsibility of the South African National Roads Agency. The Agency has indicated its intention to commence work on upgrading the road in the next two or three years, and in the meantime to maintain the road in terms of a maintenance contract. Although DEA has questioned the inclusion of recommendations relating to the R335 in the 2010 EIR, and has stated (section 2.1) that the upgrade of the road and the authorisation of the waste facility must be regarded as separate issues, it is strongly recommended that the road is upgraded before the commencement of the waste facility’s operational activities, if the road traffic and safety impacts are to be mitigated to low negative significance as stated in the EIR.

The specialist also concluded that a rail link to the site from the existing Grassridge Railway Station, some 15.5km south west of the site, would not be economical. The estimated cost of the dedicated branch line site was R113.9million, which did not include the substantial costs of loading and off-loading facilities at source and destination. This is between 4.5 and 7.1 times the total cost of upgrading the existing road system. The differential is unlikely to have changed much in the eight years since the estimates were framed, and the conclusion that the rail option is not viable is still valid.

4.11 Social

There is no reason to suppose that the social and economic circumstances and conditions in the project-affected area that were assessed in the SIA have changed to such an extent that it will be necessary to re-evaluate the potential impacts, their significance, or the mitigation and enhancement measures proposed by the specialists.

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5. CONCLUSIONS AND WAY FORWARD

Upgrading the Motherwell to Addo road (R335) Since the EIR was completed the section of the R335 between its junction with the N2 highway on the south-eastern side of Motherwell and its intersection with the r342 near Coerney Railway Station, north of Addo, was declared as National Road R335, Section 1, by Government Notice No 733, published in the Government Gazette No 40085 on 22nd June 2016. SANRAL has indicated that the process of procuring engineering design services is in hand, and that necessary upgrades will be commenced in two or three years. In the meantime SANRAL will be maintaining the road via a maintenance contract.

Land issues Negotiations are in progress between PPC Ltd and CDC to acquire the land for the proposed waste management facility.

The CDC will undertake the required rezoning process once the necessary authorisations (environmental authorisation and waste management licence) have been secured from DEA.

The site for the proposed waste management facility is included inside the boundary of the mining right for its quarrying activities, and it will be necessary to obtain permission from the Minister of Mineral Resources, in terms of s53 of the Mineral and Petroleum Resources Development Act, to “use the surface of any land in any way which may be contrary to any object of the Act or which is likely to impede any such object.”

Thermal processing of waste The current design of the facility does not include a thermal treatment facility of any kind, including incineration.

In response to an enquiry by the Eastern Cape Provincial Air Quality Officer clarification has been added about the way in which the impacts of volatile organic compounds (VOCs) were determined, and an estimate has been made of the maximum annual rates of greenhouse gas emissions from the landfill.

Examination of the impacts identified by the specialists in the July 2010 EIR indicates that they cover all the requirements of the most recent environmental and waste management listed activities.

The Permit Application Report prepared by Jones & Wagener in 2008 will be submitted with the application, but by agreement with DEA the report will be updated as a condition of the authorisation, before any further work is undertaken on the facility.

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Period of validity of the environmental authorisation It is recommended that: (v) The CDC and Enviroserv maintain regular contact to ensure that the status of the Aloes II site in respect of its remaining life is known to each party. (vi) The Environmental Authorisation for the proposed new waste management facility is granted for the longest allowable period (10 years in the December 2014 EIA Regulations), and that no unnecessary barriers are put in the way if extending the validity of the authorisation, should 10 years prove to be too short a period. (vii) The department allows the greatest possible flexibility in specifying the period for which the Waste Management Licence is issued, the conditions attached to any amendments to the licence that may prove to be necessary, and the period within which renewal of the licence must be applied for.

Public review This Addendum report and the integrated application will be made available for public review for a 30-day period before they are submitted to the department. No changes have been made to the 2010 Environmental Impact Report or the 2008 Permit Application report, but links will be provided to electronic copies of these reports for ease of reference.

Comments from the public will be collated and response prepared, and any necessary changes made to the Addendum before it is submitted to the department for a decision.

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REFERENCES

Bohlweki-SSI Environmental. July 2010. Revised Final Environmental Impact Report (EIR) and Draft Environmental Management Plan (EMP) for the Proposed Regional General and Hazardous Waste Management Facility in the Eastern Cape.

CDC 2015: CDC Meeting No 01/2015, Regional General & H:H Waste Facility EIA, Enkundleni Boardroom, Coega Business Centre, Coega IDZ, 16th April 2015.

Jones & Wagener 2008: Coega Development Corporation, Proposed Grassridge Waste Disposal Facility Permit Application Report, Jones & Wagener, Report No.: JW119/08/B494 Rev 1, December 2008

Polity 2016: http://www.polity.org.za/article/pollution-prevention-plans-to-be-required-for-greenhouse-gas- emitter-following-paris-agreement-2016-02-01

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APPENDIX A: DEA REJECTION LETTER

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APPENDIX B: 2010 EIR FINDINGS AND CONCLUSIONS

The concluding section of the 2010 Final EIR Executive Summary is reproduced verbatim below.

The conclusions of this EIR are the result of comprehensive studies and specialist assessments. These studies were based on issues identified through the Scoping, Footprint Ranking and Final Feasibility Reports and the parallel process of public participation. The public consultation process has been rigorous and extensive, and every effort has been made to include representatives of all stakeholders in the process.

1. Flora Based on specialist analysis of the floral composition of the preferred footprint throughout the course of the EIA process the following has been concluded:  Presence of Rare and Endangered species: Although the diversity in habitat is low and the Mesic Succulent Thicket is in a poor condition there is still potential for Rare and Endangered species to occur within this vegetation type. Several healthy specimens of the sensitive species Syncarpha striata were recorded within Bontveld in a good condition which is located along the northern boundary of the site. This portion of the site should therefore be regarded as sensitive. However, due to the low species diversity of the Mesic Succulent Thicket (MST) vegetation on-site compared to pristine MST the impact of the proposed GHWMF on existing MST vegetation is deemed to be of low negative significance. Due to the limited availability of good condition Bontveld in the area surrounding the proposed GHWMF site as compared to the more prevalent MST, the impacts on the Bontveld habitat will be of increased negative significance at a Regional level.  Ecological function: The vegetation within the area of the proposed GHWMF footprint is providing the basic functions within the greater ecological system. Vegetative cover is medium. Although some limited erosion does occur within the game/livestock paths as well as on the old lands, the soil on the rest of the footprint is adequately covered and protected.  Uniqueness/conservation value: In general the footprint displays no specific or important features different from the vegetation in the surrounding area. The only area of real concern is the ecotone boundary between MST and Bontveld as well as the small section of Bontveld along the northern boundary of the site that needs to be protected.

Overall the impacts on floral habitat are deemed to be of low significance if appropriate mitigation measures are put in place for the construction and operational phases of the project.

2. Fauna Based on specialist analysis of the faunal composition of the preferred footprint throughout the course of the EIA process the following has been concluded:  Loss and fragmentation of habitats: Project actions associated with the construction of the proposed GHWMF and the development of transport links will result in the loss and fragmentation of sensitive habitats. The proposed waste facility on Footprint F will impact a variety of habitats, particularly Bontveld and MST. As the loss and fragmentation of habitats will be localised, and careful siting of the proposed GHWMF has directly avoided intact Bontveld habitat, the impact after mitigation will be low.  Loss of faunal diversity: Although the region for the proposed GHWMF has a rich faunal diversity, some vertebrate groups in the region are now characterised by reduced faunal diversity due to direct and indirect effects of previous and current land use. The loss of faunal diversity will be localised and the fauna is also relatively impoverished. The unmitigated impact will therefore be moderate, but with the possible rehabilitation of MST on closure this may be reduced to low significance.  Barriers to animal movement: The proposed GHWMF will result in habitat fragmentation and the construction of linear developments (road linkages and power lines). These will form barriers to animal movement within the region, both for terrestrial fauna and to the aerial flight

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routes of migrating birds. Impacts on animal movements will be greatest in regions with high habitat fragmentation, or where linear developments such as roads transect migratory paths. As the barriers to animal movements will be localised and many of the transport linkages already exist, the impact of the additional development will be of low significance.  Loss of Species of Special Concern (SSC): Project actions associated with the proposed GHWMF may result in the loss of Species of Special Concern. Project actions impacting SSC include the destruction and loss of sensitive habitats, particularly Bontveld, and increased mortality and disturbance due to increased road traffic and the possibility of bird species flying into powerlines during operation of the facility. The possible loss of SSC will be localised and usually of low impact for most SSC. However, because of the close proximity and possible presence of a Globally Critically Endangered species (the Albany adder) the impact will be of potentially moderate to high significance.  Increase in problem animals and alien species: Project actions associated with the construction of the proposed GHWMF and the development of transport links will result in an increase in problem animals and alien species. Their numbers in the area surrounding the proposed GHWMF may displace local fauna from its habitat; cause increased predation on local fauna and introduce or spread wildlife diseases. As the potential impact can be effectively controlled it will be of low significance.  Increased disturbance and mortality due to road traffic: Although the new roads associated with access to the proposed GHWMF are short, the operational phase of the facility will involve a significant increase in road traffic to and from the facility on existing roads. This will result in increased disturbance and faunal mortality due to increased road traffic over the long-term. An increase in faunal mortality due to increased road traffic will not be entirely avoided, but the impact will be of low significance.  Changes in natural fire regime: Changes in water flow dynamics following road construction and other developments that reduce vegetation cover, may reduce the water table locally, drying vegetation to unnatural levels and making it more susceptible to fire. Construction and planning of roads should anticipate an increased fire risk, and increased human population growth in the area will also lead to an increase in accidental fires.  Pollution: Pollution may result from periodic accidents, or from slow, ongoing contamination. Operation of the proposed GHWMF, particularly in relation to the use of liquid fuels, could result in periodic spillages. Heavy vehicle traffic is also associated with increased local pollution resulting from exhaust fumes, oil spillage and accumulation of rubber compounds from tyre wear. These pollutants can cause localised impacts. However, the impact on fauna will be low if correctly mitigated during the operational phase.  Loss or reduction of ecosystem functioning: Although there is a long history of agricultural use and transformation in the region, it still retains relatively high faunal and floral diversity and contributes to local ecosystem functioning. The impact can be proactively avoided and partially mitigated by avoiding direct loss of Bontveld habitat, wetlands, steep valley sides, and the limestone ‘rubble edge’ often associated with the ecotone between Bontveld and adjacent MST in the final siting of the GHWMF.

3. Geohydrology Based on the available geological and geohydrological information for the proposed site and the immediate surrounding farms, the preferred footprint is considered suitable for the development of the GHWMF waste provided the design, construction and operational requirements as specified in the DWEA guideline document are adhered to. The main reasons for the site being regarded a suitable area, are the following:  The geological conditions of the underlying formations, both in terms of lithology and depth extent are very favourable.  The static groundwater level in the vicinity of the site is of the order of 70 m below surface.  Borehole yields are generally very low as illustrated by the four recently drilled boreholes that were all dry on completion of drilling.  The groundwater quality in the region is generally poor to very poor and as a result very little use is being made of groundwater for domestic, stock watering or irrigation. The poor water quality is a direct result of the marine depositional conditions that existed during the formation

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of the geological formations hosting the groundwater.  The underlying formations, the Sundays River and Kirkwood formations, comprise of a very thick succession (estimated to be >300m) of predominantly siltstone and mudstone, with minor interlayered sandstone layers. These formations have a very low hydraulic conductivity and will prevent the migration of contaminants in the case of liner system failure.  The deep artesian aquifer associated with the Table Mountain Group sediments, is well protected from any contamination by the thick succession of Uitenhage Group sediments. That the latter sediments form an effective barrier to groundwater flow to the deeper aquifer.  The site is situated close to a local surface water divide and none of the drainage lines at or upstream of the site represent perennial flow conditions.  The Waste-Aquifer Separation Principle (WASP) analysis, which takes into consideration a number of geological, geohydrological, water use and design criteria, also indicated that the site can be classified as “suitable”.  No geological or geohydrological conditions within the study can be regarded as “fatal flaws” according to the definitions described in the DWEA guideline documents.

4. Tourism Based on specialist analysis of tourism in the area throughout the course of the EIA process the following has been concluded:  The Sundays River Valley is an important tourism destination that depends heavily on its image as an eco/wildlife destination. The Addo Elephant National Park is the key attraction in the area and is being marketed on environmental grounds i.e. the animals are free to roam across a large area, and the park has a range of biodiversity. The area thus appeals to the environmentally conscious tourist.  Internationally tourists are becoming more environmentally conscious and are basing their decision to visit a destination on environmental grounds. These tourists may thus decide not to visit the Sundays River Valley area if a GHWMF is located in the area due to the perception that these types of facilities are harmful to the environment.

Based on the above it should be stated that none of the footprints assessed during the course of the EIA process, including Footprint F, are ideal for such a facility as they are located in a tourism area that markets itself as an eco/wildlife destination that is environmentally sensitive. Although potential visual, odour and traffic impacts are predicted to be of low significance as it relates to their relationship with the overall predicted tourism impacts, perceptions of the facility prior to, and during, a visit to the area are deemed to be of high negative significance. Similarly, the development potential of any tourism related facilities in the GHWMF area will be limited as a result.

5. Visual Footprint F is a valley infill site and ranks as the preferred location for the GHWMF from a visual impact perspective for the following reasons:

 It has the most contained area of visual impact and lends itself to the highest level of successful impact mitigation measures. This is due to the enclosed nature of the valley within which it resides. The fact that the facility is theoretically visible from the R335 is not a major cause for concern. The likelihood of it ever being noticed or recognised as a landfill from a distance of 6 km is slim to negligible, as the site would never appear in its entirety.  The selection of Footprint F as the preferred alternative, even with its own associated visual impact concerns, highlights the need to shield the facility from observers travelling along the R335. The benefit of this footprint placement is that no one travelling from Port Elizabeth to Addo, or the Greater Addo Elephant National Park, would even be aware of the existence of this facility through accidental observation. This is due to the fact that the footprint is far removed from the R335 and because of the hidden nature of the infill site.  The associated benefits of placing the waste processing facility on mining land, where borrow materials could be sourced without breaking new ground and clearing large tracts of land,

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counts in Footprint F’s favour. The mining and quarrying activities and a waste processing facility are complimenting land-uses, as opposed to the potential conflict between waste processing and agriculture/cattle and game farming/tourism and eco-tourism.  Another clear benefit of this footprint's placement is its closer proximity to Port Elizabeth from where most of the waste to be treated will be transported. The distance of 4 km does not sound like much, but over a period of 20 years it would translate to a considerable amount of kilometres. This, and the fact that access will be afforded by a private road, minimises the visual impacts associated with the increase in heavy vehicle traffic to and from the facility. This increase in heavy vehicle traffic might raise awareness of the fact that such a facility exists in the vicinity.

6. Air Quality The odour, nuisance, dust and health impacts of the candidate site for the GHWMF were assessed. The main findings of the study are as follows:  Particulates (PM10): No exceedances of the current or proposed ambient South African standards for PM10 were predicted to occur at any of the sensitive receptors included in the study for any of the scenarios. The impacts from landfill activities associated with the Scenario 1 transport option (refer to Chapter 13) were predicted to be the least significant and will result in the lowest ground level PM10 concentrations at the majority of the sensitive receptors. The highest PM10 concentrations predicted as a result of emissions associated with the four scenarios were predicted to occur at Rooidam.  Particulates (Dustfall): Slight dustfall levels (<250 mg/m²/day) were predicted to occur at the all of the sensitive receptors located around the proposed GHWMF site. Overall, the impacts from landfill activities associated with Scenario 1 were predicted to be the least significant and will result in the lowest dustfall levels at the majority of the sensitive receptors. Dust emissions from of activities associated with Scenario 2 transport option were predicted to result in the highest dustfall levels at most of the sensitive receptors. The highest dustfall levels as a result of emissions associated with Scenarios 1 and 2 were predicted to occur at Rooidam while the highest dustfall levels as a result of emissions associated with Scenarios 3 and 4 were predicted to occur at Centlivres.  Non-carcinogenic exposures: None of the pollutants considered in this study flagged for the proposed GHWMF. The hazard quotient for chronic exposures for the proposed landfill was predicted to be 0.012. The hazard quotient for the site was therefore predicted to be less than 1.0 for all exposure periods.  Cancer risks: Total maximum incremental cancer risk levels were predicted to be less than ~ 1 in 3.5 million for the proposed landfill operations and would therefore be regarded as acceptable by the regulatory authorities. The maximum cancer risk at the sensitive receptors as a result of emissions from the proposed landfill site was predicted to occur at Rooidam (~ 1 in 45 million).  Odour impacts: No odour threshold exceedances were predicted to occur due to on-site concentrations of odoriferous gasses. Off-site odour impacts were predicted to be far below the acceptable 3 OU/m³ odour unit level at all the sensitive receptors.

7. Heritage The study has shown that Footprint F was suitable for the proposed facility as potential impacts on heritage resources are deemed to be of low significance.

8. Land Use The assessment of possible land use impacts included the potential for resettlement of individuals, fatal flaws associated with the proximity to airfields, rezoning issues and potential impacts on the citrus industry. The key findings of this aspect of the study were that:  Footprint F will require the resettlement of one household, but the number of people involved is small and if the recommendations are implemented it could be undertaken in a satisfactory manner.

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 Although it has not yet been confirmed that the site can be rezoned for waste disposal, no reasons have been given as to why this should not be possible.  The proximity of registered airfields would not constitute a fatal flaw.  Any future land use planning or development in the area will have to be cognizant of the constraints the GHWMF and associated buffer zone may impose on certain land uses. Similarly, should the facility be authorised, these constraints must be incorporated into any future spatial planning frameworks that are developed or revised at local and regional level.  Based on a review of the EUREPGAP® regulations, it is considered unlikely that the establishment of a regional waste disposal facility would impact negatively on the certification of citrus farms to the north-east of the site.

9. Transport The transport study has estimated the costs for the transportation of waste to the proposed regional general and hazardous waste disposal facility by road and by rail with the following findings:  A cost comparison between these two modes of transport concluded that the road options are far more economical than the rail options. The cost of upgrading the roads to Footprint F were estimated at R 16.0 million and R 24.2 million for gravel and tar respectively. The Province is committed to upgrading Addo Road regardless of the proposed waste site development and once upgraded to the recommended design standard it will be able to accommodate the heavy vehicle traffic that will be generated by the operational waste facility. It can therefore be concluded that transportation of waste by road is the better option.  If an environmental authorisation is not given to extend the life of the Aloes hazardous waste facility beyond 2016, the new site at Grassridge will need to become operational prior to this. As PPC will still be mining their land north of the P1954 road until after 2012, it is recommended that the P1958 be regravelled for use by construction phase vehicles travelling to the site from the R335 (Addo Road).  A new 0,5 km access road should be constructed from P1958 to the site to replace the currently disused skew junction where P1954 joins P1958. It is essential that the Addo Road (R335) be upgraded from the R334 to P1958 junction before the waste facility becomes operational. Similarly, it is recommended that the P1958, as well as all other haul routes to the facility that are currently gravel roads, are upgraded to bitumen standard and fulfil the same design criteria as that proposed for the R335 (Addo Road).  If an environmental authorisation is granted to extend the life of the Aloes hazardous waste facility, the decision on whether to upgrade P1954 or regravel P1958 can be delayed until it is known when PPC will complete their mining operations north of P1954. If these operations are completed by the time the new waste facility is required, the upgrading of P1954 and the relocation of its junction on R335 is preferred, because it will result in a shorter travel distance than via P1958 for the majority of waste vehicles that will use the R335 coming from Port Elizabeth and the Coega IDZ.  It can therefore be concluded that transportation of waste by road is the better option, provided that the Addo Road between the R334 and P1958 junctions is upgraded before the operation of the waste facility commences.

10. Social Based on the findings of the SIA, it can be concluded that the social environment in general poses no fatal flaws to the development of the proposed regional GHWMF provided that the identified mitigation measures, as recommended for inclusion in the EMP, are implemented and adhered to, particularly where construction activities either take place or pass through in close proximity to residential areas. It is believed that such activities could affect the quality of lives of these households in terms of noise, dust, safety and security. In summation:  The pre-construction and construction phase of the proposed project is characterised by a number of negative impacts. This is mainly due to the nature of the activities that take place during these phases. The same holds true for the operational phase of the proposed project. Most of the negative impacts within these various phases can be mitigated successfully. There

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are also a number of positive impacts, which could be further enhanced if managed effectively. These impacts mostly relate to a temporary change in the employment and economic profile of the local area by means of employment opportunities, which in turn leads to a positive economic impact on local households.  The geographic, demographic, biophysical and socio-cultural processes all have a number of negative impacts. However all of these impacts can be mitigated successfully if effectively managed. Economic impacts as a result of the project are for the most part positive in nature, which is mainly due to the economic investment and development that will take place in the community as a result of the project. Although the expected construction impacts across all the change processes are mostly negative, these impacts are for the most part only temporary in nature and only expected to last over the construction period, which is approximately 12 months.  Operational impacts are expected to last over the longer term and therefore would have a prolonged effect on especially the biophysical environment in terms of an effective waste management strategy. People are more inclined to get “used” to the facility in their area if waste management strategies are applied effectively and with due diligence. Based on the findings of this report, it can be concluded that the overall significance of impacts on the social environment will be low.

I&AP ISSUES, CONCERNS AND COMMENTS ON THE DRAFT EIR

The major areas of I&AP concern relating to the establishment of the facility are as follows:  Waste incineration  Potential impacts on the citrus industry  Traffic and transport corridor impacts owing to the current state of the R335  Illegal dumping and litter along transport routes  Tourism impacts  Impacts on PPC’s operations  Overall management and monitoring of the operational facility

It is anticipated that these concerns have been suitably addressed in this revised report. These issues and concerns have been incorporated in the Draft EMP as well as the recommendations for conditions of environmental authorisation contained in Chapter 17. For a detailed account of these issues and concerns please refer to Chapter 16, as well as the Issues and Responses Register that is included as an appendix to this report.

OVERALL CONCLUSION

This report has investigated the preferred footprint (F) on Grassridge 190 Remainder for the siting of the GHWMF. Footprint F was selected as the most preferable site for the proposed facility as the result of an extensive screening and preliminary assessment process that culminated in a Final Feasibility Report that determined that this site was the least environmentally sensitive of all alternatives taken into consideration.

The results of the studies undertaken within this report provide an assessment of both the potential benefits and potential negative impacts anticipated as a result of the proposed GHWMF. The studies conclude that there are no environmental fatal flaws that should prevent the proposed project from proceeding and that the majority of impacts should be regarded as either low or moderate provided that the recommended mitigation and management measures are incorporated into the Final Construction and Operational EMP’s and effectively implemented. It must be mentioned that the Draft EMP will have to be further refined and submitted for authority approval once detailed design information is made available, and the preferred operator and construction contractor appointed.

Based on the balance of advantages and disadvantages associated with the proposed facility, there would not appear to be any significant reasons why the proposed development should not

EOH Coastal & Environmental Services 33 Coega Development Corporation Addendum Environmental Impact Report, September 2016 proceed. It is hoped that all significant issues and concerns raised by I&APs have been addressed through the revision of the EIR where relevant, and more specifically, in the recommendations for conditions of environmental authorisation put forward by the EAP.

I&APs have been afforded the opportunity to review this Revised Draft EIR on the significance of the potential impacts associated with the proposed facility. The purpose of this report is to provide a full environmental assessment of the proposed GHWMF in order to fulfil the requirements of informed decision making by the relevant authorities in terms of their respective authorisation and permitting mandates. It should be noted that the more technical details to the design and operation of the proposed facility are contained in the Draft Permit Application Report and, as such, both documents should be read in conjunction with each other.

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APPENDIX C: SPECIALIST LETTERS OF OPINION

C-1: Air Quality Specialist Study

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C-2: Flora Specialist Study

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C-3: Archaeological Specialist Study

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C-4: Faunal Specialist Study

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APPENDIX D: LANDOWNER NOTIFICATION

Appendix D-1: Landowner Notification

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APPENDIX E: DECLARATION OF SECTION 1 OF THE R335 AS A NATIONAL ROAD

Appendix E-1: Government Gazette Notice

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Appendix E-2: Correspondence with SANRAL

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APPENDIX F: PPC MINING AREA

Source: Adapted from e-mail communication from Mr Hugo Badenhorst, PPC Risk Manager, 17th August 2016

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