Zitholele Consulting Reg. No. 2000/000392/07

PO Box 6002 Halfway House 1685 South Africa Thandanani Park, Matuka Close Halfway Gardens, Midrand Tel + (27) 11 207 2060 Fax + (27) 86 674 6121 E-mail : [email protected]

REPORT ON

WASTE MANAGEMENT LICENSE APPLICATION FOR THE ZIMCO ALUMINIUM COMPANY (ZIMALCO), A DIVISION OF THE ZIMCO GROUP (PTY) LTD, BENONI, GAUTENG PROVINCE

FINAL SCOPING REPORT & PLAN OF STUDY FOR EIA

DEA Ref. No: 12/9/11/L1290/3

Report No : 12984-46-Rep-004-FSR-Rev0

Submitted to:

Zimco Aluminium Company, a Division of the Zimco Group (Pty) Ltd P.O. Box 5044 Benoni South 1502

DISTRIBUTION:

2 Copies - Zimco Aluminium Company, a Division of the Zimco Group (Pty) Ltd 1 Copy - Zitholele Consulting (Pty) Ltd – Library 1 Copy - Ekurhuleni Metropolitan Municipality

November 2013 12984

Directors : S Pillay (Managing Director); N Rajasakran (Director); Dr RGM Heath (Director) November 2013 i 12984

EXECUTIVE SUMMARY

Introduction

The existing Zimco Aluminium Company (Zimalco), a Division of the Zimco Group (Pty) Ltd, is a secondary aluminium smelter situated in the Benoni Industrial Sites, Benoni, in the Gauteng Province. The study site is situated in the jurisdiction of the Ekurhuleni Metropolitan Municipality. The operation recycles aluminium scrap and primary metal to produce aluminium foundry ingot, powder and master alloys which are then sold. The facility also processes aluminium dross to extract the metallic aluminium.

The site is approximately 43 000m2 in extent. The processing of aluminium dross occurs in an area of approximately 10 000m2 in size. Activities undertaken on site are listed in Government Notice 718 of 2009 (List of Waste Management Activities that have, or are likely to have a detrimental effect on the environment) and therefore environmental authorisation in the form of a Waste Management License is required in terms of the National Environmental Management: Waste Act (Act 59 of 2008) [NEMWA]. The listed activities triggered by the operations at Zimalco fall under both Category A and Category B of GN 718 (2009) and therefore a full Scoping and Environmental Impact Assessment is being undertaken as part of the Waste Management License Application. In response to the promulgation of the NEMWA and the related GN 718, and with a spirit of maintaining legal compliance, Zimalco is being proactive in its undertaking of the required registration and licensing of its on-site waste management activities.

This document, the Draft Scoping Report and Plan of Study for EIA, forms part of the Scoping Phase for this project. After submission to the Department of Environmental Affairs (DEA), this document will be made available for public review and comment. Input from potential stakeholders will further inform the document before submission of the Final Scoping Report for approval.

Legal Framework

The existing activities require Licensing in terms of the National Environmental Management: Waste Act (Act 59 of 2008). The supporting Environmental Impact Assessment will be undertaken in accordance with the requirements of the National Environmental Management Act (Act 107 of 1998) and the EIA Regulations (R. 543 of 2010). In addition, consideration has been given to various other legislative pieces such as the National Environmental Management: Air Quality Act (Act 39 of 2004), amongst others. The existing operation triggers activities listed in both Category A and Category B of GN 718 (2009) and as such requires the undertaking of a full Environmental Impact Assessment in order to obtain Licensing.

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Scoping Phase

The Scoping Phase is a legal requirement in terms of the EIA Regulations (2010) and the National Environmental Management Act (Act No. 107 of 1998, as amended). Scoping is the instrument used for determining issues and concerns related to the project, and involves consultation with the public and relevant authorities. Public participation was encouraged by:

 the placement of notification advertisements in a local and provincial newspaper;

 the distribution of Background Information Documents (BIDs) to neighbours and surrounding properties; and

 the placement of site notices on site.

These measures will be undertaken in accordance with the Regulations to ensure that any potential Interested and Affected Parties (I&APs) are notified of the project and given the opportunity to raise any specific issues or concerns. All issues raised during the Scoping Phase will be included in the Comments and Responses Report that will be submitted with the Final Scoping Report.

This Draft Scoping Report describes the existing conditions on site and identifies the potential impacts of the existing operation on the current environmental conditions. This report also includes the methodology that will be used to determine the significance of the identified potential impacts during the Environmental Impact Assessment (EIA) phase. Lastly, this report includes the proposed Plan of Study that will be followed during the EIA phase.

Study Approach

The compilation of this Draft Scoping Report was undertaken with the collation of desktop information, applicant consultation and site visits. A baseline environmental assessment was undertaken by means of site visits and the review of the existing information. Additional input received from identified stakeholders during the public participation process will further inform the contents of this Report.

Baseline Environment

The description of the baseline environment addresses all aspects of the receiving environment, including air quality, geology and topography, terrestrial flora and fauna, hydrology, noise, archaeological and culturally important sites, land use and visual nature. The Environmental Impact Assessment phase will include a detailed investigation of the identified impacts in order to determine their extent and nature (significance).

Way Forward

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This Draft Scoping Report will be made available to stakeholders and Interested and Affected Parties for review and comment. Any comments received will be addressed within the Final Scoping Report and the Comments and Responses Report which will be compiled as a component of the Stakeholder Engagement Process. Once the Scoping Report has been finalised, it will be submitted to the relevant authority (National Department of Environmental Affairs) for comment and approval. Once the Scoping Report and Plan of Study for EIA has been approved by the competent authority, the Environmental Impact Assessment phase of the project can be undertaken.

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TABLE OF CONTENTS

SECTION PAGE 1 INTRODUCTION...... 1 1.1 Environmental Assessment Practitioner ...... 4 1.2 The Applicant & Landowner ...... 5 1.3 Relevant Stakeholders ...... 5 2 CURRENT ACTIVITY DESCRIPTION ...... 6 2.1 Property Description & Location ...... 6 2.2 Description of the Proposed Activity ...... 11 2.2.1 Activity Description ...... 11 2.3 Support Services ...... 15 2.4 Waste Classification ...... 15 3 BASELINE ENVIRONMENT ...... 19 3.1 Regional Climate ...... 19 3.2 Geology & Topography ...... 20 3.3 Hydrology and Hydrogeology ...... 21 3.4 Flora ...... 27 3.5 Fauna ...... 31 3.6 Noise ...... 31 3.7 Archaeological and Culturally Important Sites ...... 31 3.8 Land Use ...... 32 3.9 Visual Nature ...... 32 3.10 Socio-Economic Context ...... 32 4 NEED & DESIRABILITY OF THE PROPOSED ACTIVITY ...... 33 5 ALTERNATIVES ...... 34 5.1 Consideration of Alternatives ...... 34 5.1.1 Alternative Site on Property ...... 34 5.1.2 Alternative Properties ...... 34 5.1.3 Alternative Activity ...... 35 5.1.4 Alternative Design / Technology / Operation ...... 35 5.2 No-Go Alternative ...... 35 6 RELEVANT LEGISLATION ...... 36 6.1 Applicable Legislation ...... 36 6.1.1 The Constitution of the Republic of South Africa (Act 108) of 1996 ..36 6.1.2 National Environmental Management Act (Act 107 of 1998, as amended) ...... 37 6.1.3 EIA Regulations under NEMA (Regulations 543, 544, 545 and 546 of 2010) ...... 38 6.1.4 National Environmental Management: Waste Act (Act 59 of 2008)...38 6.1.5 Government Notice R. 718 ...... 39 6.1.6 National Heritage Resources Act (Act 25 of 1999) ...... 40 7 POTENTIAL ENVIRONMENTAL IMPACTS ...... 41 7.1 Flora and Fauna ...... 41 7.2 Surface Water ...... 42 7.3 Ground Water ...... 42 7.4 Culturally Important or Heritage Sites ...... 42 7.5 Visual Impacts ...... 42 7.6 Air Quality Impacts ...... 43 7.7 Traffic Impacts ...... 44 7.8 Noise ...... 44 7.9 Socio-Economic Impacts ...... 44 7.10 Safety ...... 44

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7.11 Cumulative Impacts ...... 45 8 IMPACT ASSESSMENT METHODOLOGY ...... 45 8.1 Specialist Studies ...... 45 8.2 Stakeholder Input ...... 45 8.3 Impact Assessment and Criteria Rating ...... 46 9 STAKEHOLDER ENGAGEMENT ...... 47 9.1 Regulation 54 of the EIA Regulations (2010) ...... 47 9.2 Notification of I&APs ...... 48 9.2.1 Newspaper Advertisements...... 48 9.2.2 On site notice ...... 48 9.2.3 Background Information Document (BID) ...... 48 9.2.4 Public Meeting...... 49 9.3 Register of Interested & Affected Parties ...... 49 9.4 Issues Raised by I&APs (Issues Report) ...... 49 10 PLAN OF STUDY FOR EIA ...... 52 10.1 Introduction ...... 52 10.2 Objectives ...... 52 10.3 Description of Tasks to be undertaken for EIA ...... 52 10.3.1 Description of the affected environment ...... 52 10.3.2 Public Participation Process ...... 53 10.3.3 Specialist Reports ...... 53 10.3.4 Specific Project Detail ...... 53 10.3.5 Impact Assessment ...... 53 10.3.6 An Environmental Impact Statement ...... 54 10.3.7 An Environmental Management Programme Report (EMPr) ...... 54 10.3.8 Waste Management Plan ...... 54 10.4 Stages of Authority Consultation ...... 54 10.5 Method for Impact Assessment ...... 55 10.6 Proposed Public Participation ...... 56 10.7 Proposed EIA Report Skeleton ...... 57 11 CONCLUSIONS AND RECOMMENDATIONS ...... 60 12 REFERENCES ...... 62

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LIST OF FIGURES

Figure 1: Process flow diagram illustrating the Scoping and EIA Process...... 3 Figure 2: Topocadastral map illustrating the location of the project area (Source: Zitholele Consulting, 2013) ...... 8 Figure 3: Aerial image illustrating the location and layout of the site in the Benoni Industrial Sites area (Source: Zitholele Consulting, 2013)...... 9 Figure 4: Site layout map illustrating the various existing buildings and structures on the site (Source: Zimalco, 2013)...... 10 Figure 5: Photographs illustrating the incoming dross storage bunkers at the Zimalco facility (photos taken by EAP during site visit)...... 12 Figure 6: Diagram illustrating the process flow for the processing of aluminium dross at Zimalco (Source: Zimalco, 2013)...... 14 Figure 7: Graph illustrating the average monthly minimum and maximum temperatures for Benoni (Source: World Weather Online, 2013)...... 19 Figure 8: Graph illustrating the average monthly rainfall for the study area (Source: World Weather Online, 2013)...... 20 Figure 9: Map illustrating the topography of the study site and surrounding area (Source: Zitholele Consulting, 2013)...... 23 Figure 10: Map illustrating the geology of the study site and surrounding area (Source: Zitholele Consulting, 2013)...... 24 Figure 11: Map illustrating the soil types associated with the study site and surrounding areas (Source: Zitholele Consulting, 2013)...... 25 Figure 12: Map illustrating the surface hydrology in the region of the study site. The site is located in quaternary catchment C22C (Source: Zitholele Consulting, 2013)...... 26 Figure 13: Map of South Africa illustrating the various biomes of vegetation units as identified in Low & Rebelo (1996) accessed at http://www.plantzafrica.com/vegetation/biomes1.pdf...... 27 Figure 14: Map illustrating the project site (outlined in yellow) in relation to environmentally sensitive areas around the study area (Zitholele Consulting, 2013)...... 28 Figure 15: Map illustrating the vegetation types associated with the study site and surrounding areas (Source: Zitholele Consulting, 2013)...... 29 Figure 16: Map illustrating the agricultural potential of the property and surrounding areas (Source: Zitholele Consulting, 2013)...... 30

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LIST OF TABLES

Table 1: Contact details of EAPs ...... 4 Table 2: Contact details for the proponent and landowner...... 5 Table 3: GPS points for the corners of the study site (Source: Google Earth, 2013)...... 7 Table 4: Table listing the various waste streams from the Zimalco operations and their classifications (Source: Zimalco, 2013)...... 16 Table 5: Impact Assessment table for Calculation of Significance ...... 46 Table 6: Impact Ratings and the Implicated Significance ...... 47 Table 7: Register all Interested and Affected Parties for the project to date...... 50 Table 8: Proposed content to be included in EIR...... 57

LIST OF APPENDICES

Appendix A: Environmental Assessment Practitioner CV Appendix B: WML Application Form Appendix C: Correspondence from Competent Authority Appendix D: Correspondence to Stakeholders Appendix E: Project Location Map Appendix F: Newspaper advertisement Appendix G: Site Notices Appendix H: Background Information Document and Registration Sheet Appendix I: Stakeholders database Appendix J: Comments and Response Report

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LIST OF ACROYNYMS

BID Background Information Document

CO2 Carbon Dioxide DEA National Department of Environmental Affairs DWAF / DWA Department of Water Affairs and Forestry now Department of Water Affairs EAP Environmental Assessment Practitioner EBOSS Ekurhuleni Biodiversity and Open Space Strategy EIA Environmental Impact Assessment EMM Ekurhuleni Metropolitan Municipality GDARD Gauteng Department of Agriculture and Rural Development GHG Greenhouse Gases IAIA International Association for Impact Assessment IDP Integrated Development Plan NEMA National Environmental Management Act (Act 107 o f 1998), as amended NEMWA National Environmental Management: Waste Act (Act 59 0f 2008) PFC Perfluorocarbon (Greenhouse gas emitted during Aluminium production) SDF Spatial Development Framework WMA Water Management Area WML Waste Management License Zimalco Zimco Aluminium Company

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1 INTRODUCTION

The Zimco Aluminium Company (a Division of the Zimco Group (Pty) Ltd), from here on referred to as Zimalco, is described as a global scale secondary aluminium producer specialising in Foundry Alloys, Master Alloys, Deoxidants and Powders. The bulk of Zimalco’s business is found in the supply of world-class products manufactured to international standards, to markets around the globe. Raw materials are obtained from all the country’s aluminium converters and scrap metal merchants, as well as from the primary producers (Zimalco, 2013).

The site operates as an aluminium smelter, recycling aluminium scrap and primary metal scrap metal to produce aluminium foundry ingot, powder and master alloys, which are sold. In addition, Zimalco also processes aluminium dross to extract metallic aluminium.

In terms of the requirements of the National Environmental Management: Waste Act (NEMWA) (Act 59 of 2008) and Government Notice 718 (2009), a Waste Management License Application and full Environmental Impact Assessment process are required for the waste management activities and processes undertaken by Zimalco. The existing operation triggers several of the listed activities that have, or are likely to have a detrimental effect on the environment (GN 718 of 2009).

This Scoping Report and Plan of Study for a full Environmental Impact Assessment (EIA) is being undertaken as part of the Waste Management License Application for the Zimco Aluminium Company (Zimalco) located in Benoni, Gauteng Province.

This Waste Management License Application and Final Scoping Report were submitted to the National Department of Environmental Affairs (DEA) for licensing of the following listed activities:

 Regulation 718 (2009), Category A, Activity 3 (1): “The storage, including the temporary storage, of general waste at a facility that has the capacity to store in excess of 100m3 of general waste at any one time, excluding the storage of waste in lagoons.”

- This activity is triggered by the temporary storage of various general waste streams stemming from the operations on site. These include damaged wooden pallets, domestic waste, tyres, aluminium scrap, paper, plastic bags and bulk bags and, on occasion, building rubble.

 Regulation 718 (2009), Category A, Activity 3 (2): “The storage, including the temporary storage, of hazardous waste at a facility that has the capacity to store in excess of 35m3 of hazardous waste at any one time, excluding the storage of hazardous waste in lagoons.”

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- This activity is triggered by the temporary storage of aluminium dross on site before processing takes place. Aluminium dross has a high metal content and is classified as hazardous waste.

 Regulation 718 (2009), Category A, Activity 3 (8): “The recovery of waste including the refining, utilisation, or co-processing of the waste at a facility that has the capacity to process in excess of three tons of general waste or less than 500kg 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 of aluminium from scrap metal to produce aluminium foundry ingot, powder and master alloy products.

 Regulation 718 (2009), Category B, Activity 4 (2): “The reuse and recycling of hazardous waste.”

- Although most of the aluminium dross processed on site is received from external sources, the operation does produce some of its own aluminium dross from its aluminium smelting activities. This aluminium dross is then recycled to extract the metallic aluminium for further use.

 Regulation 718 (2009), Category B, Activity 4 (3): “The recovery of hazardous waste including the refining, utilisation or co-processing of waste at a facility with a capacity to process more than 500kg of hazardous waste per day, excluding recovery that takes place as an integral part of an internal manufacturing process within the same premises or unless the Minister has approved re-use guidelines for the specific waste stream.”

- The processing of aluminium dross received from external sources to extract metallic aluminium.

The general process for the Scoping and EIA phases of this project is illustrated in the diagram below (Figure 1).

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1. EAP appointed by proponent

2. Obtain relevant documents and information from proponent

3. Compilation and submission of Application Forms and Draft Scoping Report to DEA Public Notification

Public participation process Public Consultation

Issues Report

4. Scoping Phase Liaison with DEA & Proponent

Specialist Compilation of Final Scoping Report Biodiversity Studies

Compilation of Plan of Study for EIA

Receive approval for Scoping Report and Plan of Study; Proceed with EIA Phase

Public Notification

Public participation process Public & Authority Consultation

Issues Report

Description of Activity Information 5. EIA Phase

Description & Assessment of Alternatives

Impact Assessment

Compilation and submission of EIA Report

Receive Record of Decision (ROD) for the application from the Competent Authority

Figure 1: Process flow diagram illustrating the Scoping and EIA Process.

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1.1 Environmental Assessment Practitioner

Envirokey Management Services cc was the independent environmental consultancy appointed to undertake the Waste Management License Application and Scoping and EIA Process for the existing waste management activities undertaken at the Zimalco operation. As of 01 September 2013, Envirokey Management Services cc was absorbed by Zitholele Consulting. The contact details and experience of the Environmental Assessment Practitioners (EAPs) are provided below.

Table 1: Contact details of EAPs

Name of EAP: Moses Mathebula

Company: Zitholele Consulting

Qualifications: BA Hons (Geography)

Associations: International Association for Impact Assessments (IAIA)

Postal Address: PO Box 6002, Halfway House, Midrand, 1685

Contact number: 011 207 2060

Contact email: [email protected]

Moses Mathebula, the author of this Scoping Report, is an Environmental Consultant working for Zitholele Consulting (Pty) Ltd and will be project managing the Waste Management License Application and the related Scoping and EIA Processes for the facility. Mr Mathebula has two years working experience in the field of environmental consulting and undertaking Environmental Authorisation processes and is a member of the International Association for Impact Assessments (IAIA). Mr. Mathebula also has nine (9) years of experience in the academic sector in Environmental Management and Environmental Impacts Assessment processes. Mr Mathebula has an Honours Degree (Geography) from the University of Limpopo.

Moses Mathebula is working under the supervision of an experienced EAP, Ms Sharon Meyer. Ms Meyer has 13 years of experience and affiliations to IAIA. Ms Meyer has a BSc Honours (Geography & Environmental Management) and an MSc (Zoology) and is registered as a Professional Natural Scientist with the South African Council for Natural Scientific Professionals, (Pr. Sci. Nat. 400293/05).

Zitholele Consulting has no vested interest in Zimalco, the Zimco Group (Pty) Ltd, or the project.

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1.2 The Applicant & Landowner

Table 2 below provides the contact details for the applicant and the landowner. The applicant, Zimco Aluminium Company (Zimalco) is a division of the Zimco Group (Pty) Ltd. The property is owned by the Zimco Group (Pty) Ltd. Therefore, no landowner notification is necessary as the Zimalco operation belongs to the parent group.

Table 2: Contact details for the proponent and landowner.

Zimco Aluminium Company (Zimalco) – a Division of the Name of Applicant: Zimco Group (Pty) Ltd (Mr. Gary Munn – Technical Manager)

Postal Address: P.O. Box 5044, Benoni South, 1502

Contact Person: Gary Munn

Contact details: 011 914 4300 / [email protected]

Name of Landowner: Zimco Group (Pty) Ltd

Postal Address: P.O. Box 519, Germiston, 1400

Contact Person: Mr. Wouter Verwey

Contact details: 011 827 5413 / [email protected]

1.3 Relevant Stakeholders

Relevant stakeholders were identified and notified of the intent to undertake the Waste Management License Application and Scoping and EIA processes for the existing operations at Zimalco.

Background Information Documents (BIDs) outlining the nature of the Waste Management License Application and Scoping and EIA processes were delivered to the identified stakeholders at the initiation of the Public Participation Process. In addition, site notices were placed along the facility boundaries and notification advertisements were placed in the local newspapers (Star and Benoni City Times).

The various stakeholders identified during the notification period include the following:

 Adjacent and surrounding neighbours within 100 metres from the site;

 The local ward councillor (Ward 29, Ekurhuleni Metropolitan Municipality);

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 Ward councillors from immediately surrounding Wards 30, 31 and 32;

 Ekurhuleni Metropolitan Municipality – Environmental Department; and

 Ekurhuleni Metropolitan Municipality – Waste Management Department.

The stakeholder engagement includes a 30-day notification period, followed by a 30-day period for the review and comment of the Draft Scoping Report. The stakeholder engagement process is more fully described in Section 9 of this Final Scoping Report.

2 CURRENT ACTIVITY DESCRIPTION

2.1 Property Description & Location

The Zimalco operations are situated at 3 Falkirk Street, Industrial Sites, Benoni Ext 12 in the Gauteng Province. The properties are described as Erven 7391 and 7876, Benoni Ext 12. The property is located in the Benoni Industrial Sites area and falls within the urban edge boundary. The locality of the project site is illustrated in Figure 2 and Figure 3. The existing operation falls within the jurisdiction of the Ekurhuleni Metropolitan Municipality.

The entire property is 42 880m2 in extent, while the dross processing area within this property is approximately 10 000m2 in extent. The area is zoned as Industrial land use. Zimalco has been operational on this site since approximately 1960. Prior to the purchase of the property by the Zimco Group (Pty) Ltd, it is understood that the following activities were undertaken during the history of the site:

 Pre-1960: Undeveloped marsh and farm land

 Around 1960: An on-site vehicle garage was constructed in the northwest corner of the site.

 Around 1965: Commencement of metal storage on-site.

 Around 1972: Commencement of metal processing on-site.

 Around 1994: Commencement with the processing of aluminium dross.

 1996: The Zimco Group (Pty) Ltd purchased the property.

The project site houses several buildings, including the main office block, a comminution plant, a conversion plant, the dross plant, a master alloys plant, an alloys plant, a powder plant and various raw materials storage areas. There are also several workshops including a maintenance workshop, a vehicle workshop, an engineering workshop and an electrical workshop. The site also houses a finished product store, a safety training centre and a canteen and infirmary. The site plan illustrating the various buildings and structures on site is provided as Figure 4. The incoming dross is stored on the north-western portion of the site in covered bunkers. The dross is kept separated by source as the recovery rates vary.

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Surrounding land uses include industrial and residential uses. The property is surrounded by the industrial area of Boksburg East on the western side, and the residential township of Wattville on the eastern side. The project site is accessible from Falkirk Street which is accessed via Van Dyk Road/Atlas Road (M43). Atlas Road provides access to the N12 highway approximately six kilometres north of the project site. The N17 highway is located approximately three kilometres south of the site and can be accessed via Heidelberg Road (R23).

Table 3 lists the GPS co-ordinates for the corners of the site.

Table 3: GPS points for the corners of the study site (Source: Google Earth, 2013).

GPS Point Latitude Longitude A 26˚ 13’ 30.15” S 28˚ 17’ 39.34” E B 26˚ 13’ 28.60” S 28˚ 17’ 43.87” E C 26˚ 13’ 38.72” S 28˚ 17’ 48.31” E D 26˚ 13’ 39.25” S 28˚ 17’ 43.51” E

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.

Figure 2: Topocadastral map illustrating the location of the project area (Source: Zitholele Consulting, 2013)

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Figure 3: Aerial image illustrating the location and layout of the site in the Benoni Industrial Sites area (Source: Zitholele Consulting, 2013).

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Figure 4: Site layout map illustrating the various existing buildings and structures on the site (Source: Zimalco, 2013).

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2.2 Description of the Proposed Activity

2.2.1 Activity Description

The site operates as a secondary aluminium smelter recycling aluminium scrap and primary metal scrap, to produce aluminium foundry ingot, aluminium powder and master alloys which are sold. In addition to this, the processing of aluminium dross is undertaken in order to extract metallic aluminium.

Aluminium Processing

Zimalco processes secondary aluminium raw materials by melting and casting these into aluminium alloys, foundry ingot and powdered products. During this process aluminium dross is generated as a by-product. Aluminium raw material is sourced from recyclers as well as from other primary sources. The aluminium destined for recycling can be divided into two categories: pre-consumer by-products from the production of primary aluminium; and scrap, associated with the post-consumer aluminium. The aluminium by-products and scrap are sorted, baled, cropped, and then processed by melting and casting to produce the ingots, aluminium alloys and powders for subsequent commercialisation. The dross, which is generated from the melting process, is recycled as much as possible to remove the metallic content. The remaining dross is collected by an independent third party (Bumatech) for further processing. When dross is contaminated and cannot be utilised by Bumatech, it is collected and disposed of at the Holfontein landfill facility through Enviroserve.

Dross Processing

Aluminium dross is a by-product of the aluminium smelting process. The dross is classified as hazardous waste. Aluminium dross can be mechanically processed to separate the residual aluminium metal from the aluminium oxide.

Dross from other external sources is also processed at Zimalco to remove the metallic content. Some of the metal is removed from this sourced dross and is turned into usable alloy for Zimalco use, or is sent back to the supplier. The remaining metallic-free dross from this process is either sold off to a tertiary processor (Bumatech) or is collected and disposed of at the Holfontein landfill site. The general process includes receiving the material, sorting, melting (during which the metal is removed) and producing the final products.

i. Receipt of Aluminium Dross

The aluminium dross material is received from various sources (primary aluminium smelters), including BHP Billiton’s Hillside and Bayside facilities (on the east coast) and Mozal (Mozambique). External transport companies, contracted to the individual foundries

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are used to transport the material to Zimalco. The incoming dross is sorted according to origin (as they have different recovery rates). The incoming dross is stored by truckload in ten (10) covered (under roof) bunkers. The dross is then individually sorted. The dross receiving and preparation area is illustrated with photographs in Figure 5.

Figure 5: Photographs illustrating the incoming dross storage bunkers at the Zimalco facility (photos taken by EAP during site visit).

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ii. Sorting

The individual truckloads of dross are sorted via mechanical means into various size fractions, separating the smaller portions from the larger material. This is accomplished through screening. Use is made of a triple deck screen, Trommel screen and a Steinline ball mill.

The larger fractions (oversize) are melted as are, while the smaller size fractions are processed using a Jaw Crusher and a Hammer Mill before being screened again and sent through another ball mill and a Ponson mill. As illustrated in the process flow diagram (Figure 6), each piece of equipment has its own extraction system (filters). iii. Melting

The extracted metal is then melted in special furnaces in the melting plant. Zimalco makes use of six (6) gas fired furnaces. There are also two (2) induction furnaces which are rarely used. The gas furnaces make use of natural gas supplied from Sasol. The melted metal is cast into 600kg to 700kg sows. The sows are stacked and stored in the storage facilities for use in the Zimalco process or are sent back to the supplier for further use. iv. Disposal

The dross is exothermic and needs to be cooled in the dross cooler system which speeds up the cooling process. In addition, after being processed at Zimalco, the remaining dross is stored in steel bins for cooling. The remaining dross, once cooled, is then either sold off to a tertiary processor (who makes brickettes for the steel industry) or is collected and disposed of at the Holfontein landfill facility. The waste dross is collected from the designated area on the premises by Enviroserve for disposal at their Holfontein facility. The furnace cleanings are also disposed of at the Holfontein facility.

The facility receives between 1 200 and 1 500 tons of aluminium dross per month. In addition, Zimalco generates approximately 50 tons of aluminium dross per month from their smelting facilities. Approximately 1 000 tons per month of dross is produced after the aluminium dross processing operation. The majority of this waste material is collected by Bumatech for tertiary processing. The fraction that is contaminated (up to 300 tons per month) is stored separately for collection and disposal by Enviroserve.

The support services required for the existing process are preliminarily described in Section 2.3 of this Report. This Waste Management License Application and related Scoping and Environmental Impact Assessment include the activities as listed in Section 1 above.

ZITHOLELE CONSULTING

Dross Dross cooler cooler stack Incoming Dross

Triple deck discharge top bag filter SADEC 158m2 3 Sorting Skip hoist filtration rate 2m /sec

Triple deck discharge top Trommel bag filter SADEC 158m2 Triple deck screen screen

Steinline

ball mill Trommel screen and

Steinline bag filter – DCE

lant Vokes Unimaster filter are Jaw crusher 40m2 rate 1.4m3/sec

Operation Dross P Dross Melting Hammer mill Jaw crusher bag filter

Disposal Disposal Ball mill Screen

Hammer mill bag filter 160m2 3 Ponson mill area at rate 2.5m /sec

SADEC 72m2 filter Disposal or sold

Figure 6: Diagram illustrating the process flow for the processing of aluminium dross at Zimalco (Source: Zimalco, 2013).

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2.3 Support Services

The study site falls within the Urban Boundary in the Benoni Industrial Sites area and Zimalco is connected to the Council Services, such as potable water and sewer reticulation, provided by the Ekurhuleni Metropolitan Municipality. The following arrangements exist in terms of services:

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

 Water Supply: The site is serviced and potable water is supplied by the EMM. Sufficient capacity exists.

 Sewer Facilities: The study site is serviced and sewer facilities are connected to the Municipal services.

 Stormwater Management: Stormwater falling within the property is collected in the stormwater management system on site which is connected to the Municipal stormwater system in the area.

 Solid Waste Management: Zimalco implements a rigorous solid waste management system on the site. Solid waste stemming from the activities on site is separated and stored in various areas/containers to ensure the correct disposal. Hazardous waste and non-hazardous waste are kept segregated and the waste manifests for the disposal of hazardous waste are kept on file. Records are kept of the volumes of each type of waste stream. - Domestic waste is collected by the Municipal service provider on a weekly basis. - The waste dross material is either collected by Bumatech for further use or, in the event that it is contaminated, it is collected by Enviroserve and disposed of at the Holfontein landfill site.

A table listing the various waste streams, their classification and the means of disposal (or recycling where applicable) are provided in Table 4 in Section 2.4 of this Report. This information also forms part of the Waste Management License Application.

 Administration: Administration activities are undertaken in the main office block buildings located on the north-eastern portion of the site (illustrated in Figure 5).

2.4 Waste Classification

The following table lists the various waste streams emanating from the Zimalco operations and provides their classification.

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Table 4: Table listing the various waste streams from the Zimalco operations and their classifications (Source: Zimalco, 2013).

Physical Recyclable Hazardous Class as per Hazard Limited Registered Waste type Category Disposal Appearance Yes /No classification SANS 10228 rating Quantity disposal Building rubble GW30 Solid No N/A N/A N/A Landfill NA NA Damaged Wooden GW99 Solid Yes N/A N/A N/A Employees NA NA pallets Ekurhuleni waste Domestic waste GW01 Solid No N/A N/A N/A NA NA (weekly) Tyres GW54 Solid No N/A N/A N/A Maxipres NA Steel scrap GW53 - 01 Solid Yes N/A N/A N/A Mercants NA NA Rainbow paper Yes. Application Paper GW50 - 04 Solid Yes N/A N/A N/A NA recycling dd 20 Feb 2013 Plastic bags and GW51 - 02 solid Yes N/A N/A N/A Plastic recycler (TBA) NA Bulk bags Canteen waste GW01 Solid No N/A N/A N/A Ekurhuleni waste NA

300 t yes - Expires Aluminium dross HW16 - 02 Solid Yes 3170 4.3 3 Enviroserve /month 2015 yes - Expires Asbestos HW06 Solid No 2590 9 1 Enviroserve 1 kg 2015 yes - Expires Caustic Sludge HW05 Liquid No 1719 8 2 Enviroserve 1 liter 2015 Acidic Contaminated yes - Expires HW05 - 02 Solid No 3244 8 3 Enviroserve (when full) glassware 2015 Electronic waste HW18 -03 Solid Yes 3288 6.1 2 Desco NA yes - Expires Fluorescent tubing HW18 - 05 Solid No 2809 8 1 Enviroserve NA 2015 yes - Expires Food grease HW11 - 01 Liquid No 2810 6.1 3 Enviroserve NA 2015

Furnace linings HW05 - 03 Solid No 3288 6.1 3 Enviroserve NA yes - Expires 2015

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Physical Recyclable Hazardous Class as per Hazard Limited Registered Waste type Category Disposal Appearance Yes /No classification SANS 10228 rating Quantity disposal 23 April 2015 Solid and ClinX waste Health care waste HW20 - 02 No 3291 6.2 1 NA and 07 March Liquid management 2015 Solid and yes - Expires 26 Health care waste HW20 - 02 No 3291 6.2 1 Sharpmed none Liquid July 2014 Ink cartridges Solid No 3175 4.1 3 NA yes - Expires Laboratory acids HW05 - 01 Liquid No 1760 8 3 Enviroserve (when full) NA 2015 Lead acid Vehicle HW03 - 01 Solid Yes 3244 8 2 Fry's lead 1 liter batteries yes - Expires 18 Oil HW07 - 01 Liquid Yes 2810 6.1 3 Exol oil refinery NA February 2015 yes - Expires 03 Oil HW07 - 01 Liquid Yes 2810 6.1 3 Oilkol NA Oct 2014 Oily rags and yes - Expires 18 HW07 - 02 Liquid No 3077 9 3 Exol oil refinery NA shavings February 2015 2795 (if alkaline) Batteries HW03 - 07 Solid No 8 3 Enviroserve NA NA 2794 ( if acid) Old PPE – dross yes - Expires NA Solid No 3288 6.1 3 Enviroserve NA contaminated 2015 Old PPE – oil yes - Expires NA Solid No 2811 6.1 3 Enviroserve NA contaminated 2015 Old PPE – Acid yes - Expires NA Solid No 3244 8 3 Enviroserve NA contaminated 2015 Old PPE – caustic yes - Expires NA Solid No 3244 8 3 Enviroserve NA contaminated 2015 yes - Expires PCB HW04 - 01 Liquid No 2315 9 1 Enviroserve NA 2015 Ekurhuleni water Sewer waste HW21 Liquid No 2814 6.2 3 none NA services

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Physical Recyclable Hazardous Class as per Hazard Limited Registered Waste type Category Disposal Appearance Yes /No classification SANS 10228 rating Quantity disposal

Metro sanitary Sanitary HW20 - 01 Solid No 2814 6.2 1 none Solutions (14 days)

Sludge from yes - Expires HW02 - 02 Liquid No 2810 6.1 3 Enviroserve NA stormwater sumps 2015

Sludge from vehicle yes - Expires 18 HW07 - 01 Liquid No 2810 6.1 3 Exol oil refinery NA washbay February 2015 HW05 – 01 Unused chemicals Liquid No As per chemical As per chemical NA NA and 02

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3 BASELINE ENVIRONMENT

This chapter includes a description of the current environment, providing a baseline assessment of the current environmental condition of the site. The baseline environmental condition of the site will be taken into consideration for the determination of the existing and potential environmental impacts of the facility and its operations. Environmental factors that will be considered include, amongst others, the geology and topography of the site; flora and fauna; surface and ground water resources; and air quality.

3.1 Regional Climate

The study site is located in an area that experiences climate typical of the Highveld geographical region and falls within the summer rainfall region. The region is characterised by warm summers and mild to cold, dry winters. Severe frost can occur from mid-April to September and temperatures below freezing are common in winter. Summers are warm, however, temperatures seldom exceed 30˚C (EMM, 2009). The graph in Figure 7 illustrates the mean monthly maximum and minimum temperatures for the Benoni area.

Figure 7: Graph illustrating the average monthly minimum and maximum temperatures for Benoni (Source: World Weather Online, 2013).

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The mean annual precipitation for this region is between 715mm and 735mm with more than 80% of rainfall occurring between October and April (summer months). Hail can be expected periodically. A graph illustrating the average rainfall in the study area is provided in Figure 8. North-easterly to north-north-easterly winds blow during summer, with northerly and north- westerly winds blowing during winter and spring. The winds are described as usually gentle with strong winds experienced only 15% of the time and generally occurring from late winter to early spring (EMM, 2009).

Figure 8: Graph illustrating the average monthly rainfall for the study area (Source: World Weather Online, 2013).

3.2 Geology & Topography

The Ekurhuleni Metropolitan Municipality is located on a continental divide that forms part of the major watershed between the rivers that drain west and those that drain east. On a regional scale the area is generally considered as flat with a few outstanding topographical features such as pans and some undulating plains and ridges. Benoni falls within an area identified as “plains with pans” (EMM, 2009). A map illustrating the local topography in the area of the study site is provided in Figure 9.

According to the information provided by Zimalco on the site history, the study site is located on an eroded cover sequence (10 to 15m thick) of Karoo-age (Mesozoic) sedimentary rocks which lie unconformably upon Archaen Witwatersrand Supergroup rocks. The Karoo rocks

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comprise two geological formations, namely the Vryheid Formation near the surface with the Dwyka Formation beneath. The Vryheid Formation (part of the Ecca Group) consists of sandstones and shales with occasional coal beds and the underlying Dwyka Formation consists of tilites and shales. Figure 10 illustrates the underlying geology of the study site and surrounding area.

Jurassic-age dolerite intrusions are known to occur approximately one kilometre to the south-east and south-west of the site. A north-south trending lineament occurs adjacent to the western boundary of the site. This lineament is an aeromagnetic anomaly and may represent a large dolerite dyke. The site soil cover is estimated to be in the order of 1m thick and is expected to comprise residual silty or clayey sands with silty colluvial topsoil at surface.

A number of open pits from which refractory clay was previously mined are present to the north-west of the site, indicating that the uppermost layers of the Vryheid Formation (particularly the shale bands) are highly weathered. The thickness of clayey residual soil may extend to greater than 3m in places. Bedrock is present under the site at a depth of around 6m; however, this depth varies across the site. A soils map for the area is presented in Figure 11.

3.3 Hydrology and Hydrogeology

The study area falls within the western edge of Quaternary Catchment C22C which falls within the Upper Vaal Water Management Area (WMA 8). Quaternary Catchment C22B is located to the west of the site (Figure 12). Major rivers in this Water Management Area include the Wilge, Liebenbergsvlei, Mooi and Vaal Rivers, although none of these are located in close proximity to the project site (DWAF, 2007).

Information provided by Zimalco indicates that the ground surface in the area slopes gently towards the east and the natural land drainage is also expected to be in this direction. The nearest surface watercourse is reported to be the Withook Spruit which is located approximately 1km south-east of the property. Two surface water bodies are also located in proximity to the site (as visible in Figure 12). The Leeupan pan is located approximately 1.6km south-east of the site. Leeupan is fed by the Withook Spruit and it is assumed groundwater may also contribute to this pan. The pan itself is closed with no surface outflow. The Glenshaft Pan is situated approximately 2km north-east of the study site adjacent to a sewerage treatment works which also has a small water body associated with it.

In terms of the hydrogeology of the site, it is reported that a perched water table may develop on the contact between the soil cover and the highly weathered Vryheid Formation shales after heavy rains. Groundwater occurrences within the Karoo-age sedimentary formations will most probably be associated with sandstone layers or fractures. The weathered rock layers near-surface and the shale layers within the succession are expected

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to represent aquitards and aquicludes. The groundwater volume is expected to be low due to the limited recharge area and the groundwater quality is expected to be poor.

Due to the age and the crystalline nature of the Witwatersrand Supergroup basement rock, groundwater is expected to be concentrated only along faults and fissures in the basement rock. The site history report indicates that groundwater depth varies greatly during the year with a depth of approximately 2 to 3m reported during the summer wet period. During the dry winter, it is reported that the depth to groundwater increased significantly. No information on the groundwater quality below Zimalco exists and there are no sample holes on site.

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Figure 9: Map illustrating the topography of the study site and surrounding area (Source: Zitholele Consulting, 2013).

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Figure 10: Map illustrating the geology of the study site and surrounding area (Source: Zitholele Consulting, 2013).

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Figure 11: Map illustrating the soil types associated with the study site and surrounding areas (Source: Zitholele Consulting, 2013).

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Figure 12: Map illustrating the surface hydrology in the region of the study site. The site is located in quaternary catchment C22C (Source: Zitholele Consulting, 2013).

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3.4 Flora

The study area falls within the Grassland Biome (Figure 13) as classified by Low and Rebelo (1996). Grassland is the second largest biome in South Africa, covering approximately 24% of the country’s surface area. This biome is found in Highveld areas that experience summer rainfalls and frost in winter. The grassland biome is regarded as the third richest area in terms of plant species diversity. In the grassland biome trees are usually absent, while geophytes occur abundantly (DEA, 2010).

Figure 13: Map of South Africa illustrating the various biomes of vegetation units as identified in Low & Rebelo (1996) accessed at http://www.plantzafrica.com/vegetation/biomes1.pdf.

The study site is located within the Soweto Highveld Grassland vegetation type (Figure 15). This vegetation type occurs in gently to moderately undulating landscapes on the Highveld plateau and supports short, to medium-high, dense, tufted grassland dominated almost entirely by Themeda triandra and accompanied by a variety of other grasses such as Elionurus muticus, Eragrostis racemosa, Heteropogan contortus and Tristachya leucothrix. This vegetation type is considered endangered with a conservation target of 24%. Only a handful of patches are statutorily conserved (including Waldrift, Krugersdorp, Leeuwkuil, Suikerbosrand and Rolfe’s Pan Nature Reserves). Almost half the area of this vegetation type has already been transformed by cultivation, urban sprawl, mining and building of road infrastructure (Mucina and Rutherford, 2006).

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Zimalco is an existing site located within an existing industrial area. No natural vegetation occurs on site. Confirmation was received from the GDARD Biodiversity Section that no specialist biodiversity assessments were required for this site.

The agricultural potential of the general area is described as “very low to none” as indicated in the Agricultural Potential map in Figure 16. The area some distance south of the project site is characterised by high agricultural potential. However, this area is also designated as environmentally sensitive and is classified by GDARD’s Conservation Plan (C-Plan) as “Important Areas” areas and “Ecological Support Areas” (Figure 14). Important and irreplaceable areas form part of the Critical Biodiversity Areas (CBAs) for the GDARD Conservation Plan. Ecological Support Areas often surround the CBAs and are important in terms of sustainability of the environmentally sensitive areas.

Figure 14: Map illustrating the project site (outlined in yellow) in relation to environmentally sensitive areas around the study area (Zitholele Consulting, 2013).

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Figure 15: Map illustrating the vegetation types associated with the study site and surrounding areas (Source: Zitholele Consulting, 2013).

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Figure 16: Map illustrating the agricultural potential of the property and surrounding areas (Source: Zitholele Consulting, 2013).

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3.5 Fauna

No noticeable faunal species were readily identified during the site visits. The project site is located within a built-up industrial area and a low-cost residential township (Wattville) is located directly east of the site. It is not expected than many faunal species will frequent this area due to the level of anthropogenic disturbance.

According to the EMM’s Biodiversity and Open Space Strategy (2009) a total of 21 threatened bird species occur within the EMM. In addition, the threatened Striped Harlequin snake (Homoroselaps dorsalis), the near-threatened Giant Bullfrog (Pyxicephalus adspersus), and the vulnerable Rough-haired golden mole (Amblysomus hottentotus) also occur within the EMM. As indicated, the Gauteng Department of Agriculture and Rural Development did not request any specialist biodiversity investigations for the study site.

3.6 Noise

Sources of noise in the general surrounding area include noise generated by traffic utilising Van Dyk Road located west of the project site as well as from the various industrial operations located around and in the vicinity of the project site. Surrounding land uses to the south, west and north include various industrial and manufacturing operations. The residential township of Wattville is located directly east of the site and would be the main receptor of noise impacts outside the site. The Brakpan Aerodrome is located south of the site and may contribute to ambient noise levels depending on the flight paths of aeroplanes.

The main sources of noise generated at Zimalco result from the operation of the crushing and screening equipment, as well as the operation of various heavy machinery and equipment on site. Noise generated by the machinery is significantly muffled due to the majority of the activities taking place within the warehouse infrastructure. Heavy vehicles delivering or collecting materials may contribute to ambient noise.

3.7 Archaeological and Culturally Important Sites

The project site has been located at the current premises in various forms since approximately 1965. The property was purchased by the Zimco Group around 1996 and has been operating as a metal processing facility since roughly 1972. All infrastructure and buildings already exist on the site. The activity will not be changing, but merely applying for licensing under the current environmental legislation. It is, therefore, motivated that it is unlikely that any artefact of cultural value or historical significance remains on the site and that the continuing operation will not make any new significant impact.

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3.8 Land Use

The current zoning of the property is “industrial”. The property is located within the Industrial Sites area of Benoni South. Surrounding land uses include industrial and manufacturing activities to the north, south and west, with the Wattville residential township located to the east. The Actonville residential area is located beyond Wattville to the north-east of the study site. A small vacant area (approximately 50m x 150m) on the south-eastern end of the site, as well as a vacant piece of land approximately 14 000m2 in extent, serves as a buffer zone between the powder plant on site and the surrounding residential area.

The Brakpan Aerodome is located south of the project site (the edge of the field is approximately 500m from the site boundary). The Leeupan pan is located 1.5 kilometres south-east of the study area and a large vacant tract of land is located beyond the industrial area, approximately one kilometre south-west of the site.

3.9 Visual Nature

The Zimalco aluminium smelting operation is not intrusive on the visual aspect of the area as the facility is situated within an industrial land use zone. In addition, the facility is walled and the majority of the operations occur within the warehouse infrastructure on site.

3.10 Socio-Economic Context

The Ekurhuleni Metropolitan Municipality exists within the Gauteng Province. The Municipality encompasses a total area of approximately 2 000km2 that accommodates a total population of ±2.5 million. This constitutes 28% of Gauteng’s population. The population density is approximately 1 250 people per km2, making Ekurhuleni one of the most densely populated areas in the country and province (EMM, 2010).

The Ekurhuleni Metropolitan economy accounts for nearly a quarter of the Gauteng economy, which in turn contributes over a third of the national GDP. Ekurhuleni contributes ±7% to the country’s spending power and ±7.4% to the nation’s production. Many of the province’s plants for production of goods and commodities are located in Ekurhuleni. Manufacturing accounts for 28% of total production in Ekurhuleni. The downside of the manufacturing sector is that globalisation has a definitive impact on the structure of production and on the demand for labour. Ekurhuleni plays the role of the “workshop of the economy”, with the production of structural steel and fabricated metal products serving as inputs into other areas’ economies (EMM, 2010).

The economically active population is 52% and the household income and per capita income exceed the national average by 10% and 33% respectively. The percentage of people living in poverty is 29% in Ekurhuleni and the current unemployment rate is 40%. Many people in Ekurhuleni still live in overcrowded informal settlements without adequate access to engineering and social infrastructure. High levels of HIV and AIDS and other poverty-related

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diseases such as TB are experienced in the poor communities and access to health care is inequitable (EMM, 2010).

The Wattville Township located adjacent to the project site forms part of “Twenty Priority Townships Programme” which focuses on the upliftment and development of previously disadvantaged communities. The EMM prioritised the Wattville area to be fast tracked in terms of the eradication of backlogs in basic services, roads and stormwater and social facilities (EMM, 2010).

4 NEED & DESIRABILITY OF THE PROPOSED ACTIVITY

The existing facility operates as an aluminium smelter recycling aluminium scrap and primary metal scrap to produce aluminium foundry ingot, powder and master alloys which are then sold. Zimalco is considered as a secondary aluminium producer and as such plays an important role in the recycling of materials. Secondary aluminium is recovered from the processing of various kinds of aluminium scrap including wire and cable, wrought alloys, casting alloys, used beverage cans, turnings, packaging, and dross (a mixture of metal, alumina and other materials). The recycling of aluminium is very important, since the residues of this material can be reused without any loss of quality. The metal obtained in this way is called secondary aluminium.

For primary aluminium production, there are environmental concerns about greenhouse gases and land use for mining and disposal of red mud (Bayer process residue) and smelter wastes. In addition, primary aluminium production is extremely energy-intensive. In comparison to primary aluminium production, the secondary process (the recovery of aluminium from scrap to produce secondary aluminium ingot) consumes significantly less energy (about 5-10% of the energy required to produce primary aluminium), reducing environmental damage from electricity production as well as from raw materials extraction and processing. This significant energy difference is particularly important in the current South African context and forms part of the emphasis on the importance of aluminium recycling in today’s society and in the aluminium industry. Furthermore, fluorocarbon gases are not produced with secondary smelting. The principal greenhouse gas is carbon dioxide

(CO2) and because of the lower energy consumption, very much less pollution is emitted to the atmosphere than that produced in primary smelting. Moreover, the secondary process generates between five to nine times less solid wastes and consumes much less water (OECD, 2010).

Due to the properties of aluminium (high malleability, high electrical conductivity and low weight), it is an essential productive input in many industries (notably aviation and automotive industries). There are multiple industrial uses, as well as for manufacturing. The aluminium produced can be used as a raw material in the manufacture of a broad range of other goods, including but not limited to buildings, cables, packaging, and transportation (including automobiles). Consumers benefit from aluminium production because the use of aluminium in the manufacturing process allows goods to be produced cheaper than when

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other materials would need to be used. The aluminium smelting industry results in job creation, the generation of export foreign exchange revenues and an increase in investment and infrastructure development.

The overarching environmental benefit is that Zimalco diverts a potentially large waste stream (aluminium scrap) from already capacity-constrained landfills. Recycling the aluminium materials also aids in a large reduction of the energy requirements as compared to primary aluminium producers and there are significantly fewer emissions into the atmosphere as opposed to primary producers. Aluminium scrap is recycled to produce various products that can then be considered as commodities. The recycling of aluminium makes sense from both an economic and environmental perspective.

Zimalco provides employment for approximately 156 staff on site. The operation also attracts financial investment into the local municipality. Spin-off industries from the operation also contribute to positive socio-economic growth. Moreover, Zimalco’s Waste Management Strategy promotes waste reduction at source, recycling and reuse of materials. The environmentally safe disposal of any remaining waste material is a last resource. These practises (and the operation as a whole) give effect to the objectives of the National Environmental Management: Waste Act 59 of 2008, which envisages the reuse, recycling and recovery of waste. Such initiatives should be encouraged as long as proper management measures are implemented to prevent or mitigate any potential negative impacts that may result from the activity.

5 ALTERNATIVES

5.1 Consideration of Alternatives

5.1.1 Alternative Site on Property

The operations and facilities at Zimalco have been designed and arranged as required to maximise efficiency of all processes. Areas for storage of incoming raw materials for processing, aluminium dross and the various waste streams have been designated and form part of the whole site layout. The entire property is utilised for the various activities undertaken there. Minimal space remains for shifting around waste storage areas. The existing locations on site are considered the most feasible in terms of the entire operation.

5.1.2 Alternative Properties

This waste management license application is site specific, as the facility has been operational on the site for approximately two decades. Moving Zimalco to another site or location would not be financially feasible and would also result in much larger environmental impacts as a result of the construction activities that would be required to establish new buildings and infrastructure. The objective of this Scoping Report, therefore, is to identify the

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existing and potential impacts of the existing operation on the receiving environment. No location alternatives have been investigated.

5.1.3 Alternative Activity

Zimalco is the largest Secondary Aluminium smelter in South Africa. Therefore, investigating an alternative activity for the property is not a viable option. The company provides a service in that it recycles waste materials from other industries and reduces the amount of scrap aluminium metal and aluminium dross that would need to be disposed of at already limited hazardous waste disposal sites. Moreover, the company is taking proactive measures to ensure that it is compliant with the relevant environmental legislation.

5.1.4 Alternative Design / Technology / Operation

Zimalco benefits from experience gained since its inception and stands out as a leader in technical innovation. In addition, it has access to the most advanced international technology through information exchange with research groups and other leading suppliers of aluminium. Currently there are no alternative designs/technology that would improve the operations.

5.2 No-Go Alternative

Should the Waste Management License not be granted for the existing secondary aluminium smelter, it is anticipated that the facility and operations will need to shut down. This would result in the loss of 156 jobs and the related negative impact on the local economy. Moreover, a valuable service provided by Zimalco would be lost (i.e. the recycling of aluminium scrap and aluminium dross). It is unclear whether the operation would be shifted to an alternative location, as doing so would still require Waste Management Licensing. As indicated throughout this document, the processing of secondary aluminium is far less energy-intensive and generates far fewer environmental impacts than primary aluminium production.

Should the No-Go Option be identified as the preferred alternative, then the applicant will need to consider alternative options for this site. If authorisation is not obtained, or the No- Go Alternative is chosen, the existing operation cannot continue and one of the following situations may occur:

 The Company may sell the property and since the area is zoned industrial, the site may be used for some alternative industrial activities. It is also likely that a new environmental authorisation process would need to be undertaken for the new activity. Without knowing the details, it is impossible to assess what the environmental impacts of such (a potential new industry) would be.

 Decommissioning of the site will not occur other than potentially removing the machinery and equipment from the site. The buildings and infrastructure are likely to

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remain, and as indicated, another industrial activity is likely to be implemented within the existing infrastructure.

6 RELEVANT LEGISLATION

Several legislative acts and regulations apply to the existing activities and operations at Zimalco. The legislation relevant to the existing activities is listed and discussed below. The relevant licensing of the site will be implemented in terms of these Acts and will consider the purposes of these Acts.

6.1 Applicable Legislation

 The Constitution of the Republic of South Africa (Act 108 of 1996);

 National Environmental Management Act (Act 107 of 1998, as amended);

 EIA Regulations under NEMA (Regulations 543 of 2010);

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

 National Environmental Management: Waste Act (Act 59 of 2008); and the

 Government Notice R. 718 published under Section 19(1) of NEMWA.

In addition to the national legislation, various documents published by the Ekurhuleni Metropolitan Municipality will also be reviewed during the course of the Environmental Impact Assessment. These include documents such as the EMM Air Quality Management Plan (2005), the EMM Energy & Climate Change Strategy (2006), the Environmental Policy for EMM, Ekurhuleni Biodiversity and Open Space Strategy (2009), and the Ekurhuleni Development Guide (2010) which incorporates the various SDFs and IDP.

6.1.1 The Constitution of the Republic of South Africa (Act 108) of 1996

In terms of environmental rights and obligations, Section 24 of the Bill of Rights states that:

“Everyone has the right:

a) to an environment that is not harmful to their health or well-being; and b) to have the environment protected for the benefit of present and future generations, through reasonable legislative and other measures that – i. prevent pollution and ecological degradation; ii. promote conservation; and iii. secure ecologically sustainable development and use of natural resources while promoting justifiable economic and social development.”

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Thus, implications for the existing activity include the obligation to ensure that the operations do not result in pollution and/or ecological degradation and that the activity is ecologically sustainable while promoting justifiable economic and social development.

6.1.2 National Environmental Management Act (Act 107 of 1998, as amended)

The National Environmental Management Act 107 of 1998 (NEMA), as amended, provides the legal framework that ensures the environmental rights guaranteed in Section 24 of the Constitution. NEMA establishes a set of principles that serve as a guideline for any authorities or organs of state when exercising their powers during the decision-making process. These principles include, amongst others, the following:

- Pollution must be avoided or minimised or remedied; - Waste must be avoided or minimised, reused or recycled; - Negative environmental and social impacts must be minimised; and

- Responsibility for the environmental consequences of a policy, project, product or service applies throughout its life cycle.

NEMA also introduces the duty of care concept, which is based on the policy of strict liability. This duty of care extends to the prevention, control and rehabilitation of significant pollution and environmental degradation. It also dictates a duty of care to address emergency incidents of pollution. If degradation or pollution cannot be prevented, then appropriate measures must be taken to minimise or rectify such pollution. These measures may include:

- Assessing the impact on the environment; - Informing and educating employees about the environmental risks of their work and ways of minimising these risks; - Ceasing, modifying or controlling actions which cause pollution or degradation; - Containing pollutants or preventing movement of pollutants; - Eliminating the source of pollution; and

- Mitigating the effects of the pollution.

NEMA also makes provision for the participation of all interested and affected parties in the decision making process. Thus, decisions must take into account the interests, needs and values of all interested and affected parties and stakeholders.

This EIA is being undertaken to comply with the requirements of the National Environmental Management Act and the NEMA EIA Regulations (GN R.543). The activities undertaken at Zimalco do not trigger any of the listed activities as laid out in Listing Notices 1, 2 and 3 (GN R.544, GN R.545 and GN R546). The licensing of the waste management activities must be authorised by the National Department of Environmental Affairs (DEA). An EIA Report and EMP document will be prepared upon completion of this Scoping Phase and will be

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submitted to the DEA for Licensing of the existing activities in accordance with the National Environmental Management: Waste Act (discussed below).

6.1.3 EIA Regulations under NEMA (Regulations 543, 544, 545 and 546 of 2010)

The EIA Regulations promulgated under the National Environmental Management Act (Act 107 of 1998, as amended) replaced the regulations under the Environment Conservation Act (Act No. 73 of 1989). The latest revision of the EIA Regulations came into effect on 02 August 2010. The EIA Regulations focus mainly on creating a framework for co-operative environmental governance. The publication outlines the responsibilities of the competent authority, the environmental assessment practitioner and the potential polluter. Requirements for the environmental authorisation processes (Basic Assessments and Full Environmental Impact Assessments) are provided, and include information requirements and the requirements for the public participation process.

The Zimalco operation requires a Waste Management License in terms of NEMWA, and as such a full Environmental Impact Assessment (EIA) process is being undertaken. The EIA process will comply with the requirements of the EIA Regulations of 2010.

6.1.4 National Environmental Management: Waste Act (Act 59 of 2008)

The National Environmental Management: Waste Act (NEMWA) aims to reform the law regulating waste management in South Africa. One of the goals of NEMWA is to protect health and the environment by providing reasonable measures for the prevention of pollution and ecological degradation and for securing ecologically sustainable development. The Waste Act further provides for the licensing and control of waste management activities and for compliance and enforcement thereof.

The Waste Act recognises that sustainable development requires the avoidance of waste generation and where the generation of waste cannot be avoided; it should be minimised, re- used, recycled or recovered. Safe disposal of waste to a landfill should be viewed as a last resort. NEMWA also recognises that under certain circumstances, waste can be viewed as a resource that can offer economic opportunities.

The objectives of the Waste Act include the protection of health, well-being and the environment by providing reasonable measures for:

- Minimising the consumption of natural resources; - Avoiding and minimising the generation of waste; - Reducing, re-using, recycling and recovering waste; - Treating and safely disposing of waste as a last resort; - Preventing pollution and ecological degradation; - Promoting and ensuring the effective delivery of waste services;

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- Remediating land where contamination presents, or may present, a significant risk of harm to health or the environment; and

- Achieving integrated waste management reporting and planning.

NEMWA has further provided for the publication of listed waste management activities that may have detrimental effects on the environment. An application for a waste management license is being compiled as the operation triggers several of these listed activities.

6.1.5 Government Notice R. 718

A list of Waste Management Activities which have, or are likely to have, a detrimental effect on the environment has been published under Section 19(1) of the National Environmental Management: Waste Act No. 59 of 2008.

No person may commence, undertake or conduct a waste management activity listed in Government Notice No. 718 unless a license has been issued in respect of that activity. The listed waste management activities are divided into two groups, Category A and Category B, defining whether a Basic Assessment Process or a Full Environmental Impact Assessment Process must be conducted as part of the waste management license application. The operations at Zimalco trigger activities listed in both Category A and Category B, and as such a full Environmental Impact Assessment is being undertaken.

The following listed activities apply to the existing operation at Zimalco:

 Regulation 718 (2009), Category A, Activity 3 (1): “The storage, including the temporary storage, of general waste at a facility that has the capacity to store in excess of 100m3 of general waste at any one time, excluding the storage of waste in lagoons.” - This activity is triggered by the temporary storage of various general waste streams stemming from the operations on site. These include damaged wooden pallets, domestic waste, tyres, aluminium scrap, paper, plastic bags and bulk bags and, on occasion, building rubble.

 Regulation 718 (2009), Category A, Activity 3 (2): “The storage, including the temporary storage, of hazardous waste at a facility that has the capacity to store in excess of 35m3 of hazardous waste at any one time, excluding the storage of hazardous waste in lagoons.” - This activity is triggered by the temporary storage of aluminium dross on site before processing thereof takes place. Aluminium dross has a high metal content and is classified as hazardous waste.

 Regulation 718 (2009), Category A, Activity 3 (8): “The recovery of waste including the refining, utilisation, or co-processing of the waste at a facility that has the capacity to process in excess of three tons of general waste or less than 500kg of hazardous

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waste per day, excluding recovery that takes place as an integral part of an internal manufacturing process within the same premises.” - The recovery of aluminium from scrap metal to produce aluminium foundry ingot, powder and master alloy products.

 Regulation 718 (2009), Category B, Activity 4 (2): “The reuse and recycling of hazardous waste.” - Although most of the aluminium dross processed on site is received from external sources, the operation does produce some of its own aluminium dross from its aluminium smelting activities. This aluminium dross is then recycled to extract the metallic aluminium for further use.

 Regulation 718 (2009), Category B, Activity 4 (3): “The recovery of hazardous waste including the refining, utilisation or co-processing of waste at a facility with a capacity to process more than 500kg of hazardous waste per day, excluding recovery that takes place as an integral part of an internal manufacturing process within the same premises or unless the Minister has approved re-use guidelines for the specific waste stream.” - The processing of aluminium dross received from external sources to extract metallic aluminium.

6.1.6 National Heritage Resources Act (Act 25 of 1999)

The National Heritage Resources Act (Act 25 of 1999) was introduced to ensure protection of South Africa’s important heritage features. The protection of archaeological and paleontological sites and material is the responsibility of a provincial heritage resources authority. The NHRA covers the following areas of heritage value:

 Archaeology and Cultural Heritage;

 Palaeontology; and

 Meteorites.

Thus, all archaeological objects, paleontological material and meteorites discovered on site are the property of the state. The NHRA sanctioned the establishment of the South African Heritage Resources Agency (SAHRA) in 1999. SAHRA is tasked with protecting heritage resources of national significance.

The site has been operational as a metal processing plant since the early 1970s. Any impacts that may have been generated on culturally important or historical sites cannot be identified or mitigated at this late stage. It is motivated that no further impacts to such potential sites will be generated as the activities will remain the same. The entire site is utilised for the processing of secondary aluminium. For this reason, a Heritage Impact Assessment has not been undertaken on this site.

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7 POTENTIAL ENVIRONMENTAL IMPACTS

The site has been operational in one form or another for the last 50+ years and no indigenous habitat remains on site. The majority of the site has been used for buildings and infrastructure. The remainder of the site is paved. The current ecological condition of the site can thus be described as inconsequential. Areas to the north, west and east of the site are built up (industrial and/or manufacturing facilities north and west, and the residential township of Wattville to the east). A small portion of vacant land exists to the south of the site. This land has been purchased by Zimalco and is maintained as a buffer area around the powder plant and the residential area (Tamboville) located beyond it to the south. The vacant portion of land is located outside the site boundaries and is currently grassed over.

The environmental issues and potential impacts that currently are, and likely will continue to be generated by the aluminium smelter have been preliminarily identified in this Report and are discussed below. The nature and extent of these potential impacts will be addressed during the EIA Phase. Possible cumulative impacts will also be identified. Moreover, additional issues or impacts may be identified during the public participation process. These are included in this Report and will be investigated in the EIA Phase. Impact identification and assessment will be thoroughly investigated during the EIA phase of the application.

7.1 Flora and Fauna

The historical and existing activities undertaken on site, together with the buildings, infrastructure and paving situated on site have rendered the site with no natural vegetation or habitat. The continued operation of the aluminium smelter and the related waste management activities is thus not expected to impact significantly on habitat or biodiversity on the site itself.

The surrounding land is built up with both industrial and commercial land uses, as well as the Wattville residential township. A small portion of land located directly south of the project site is vacant and functions as a buffer zone between the powder plant on site and the neighbouring residential area. This vacant land portion is grassed over and does not provide any ecological significance.

The level of anthropogenic disturbance and activity in the study area most likely discourages the presence of many faunal species, although it is likely that some common bird species may make use of any trees/shrubs in the neighbouring residential areas.

The Gauteng Department of Agriculture and Rural Development indicated that no specialist biodiversity investigations were required for this study area. The expected impact on the surrounding floral and faunal communities has been identified as a low risk.

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7.2 Surface Water

There are no rivers, wetlands, pans or other surface water bodies present on the project site or in the immediately surrounding area. Stormwater runoff on site is contained in the site’s stormwater management system which in turn connects to the municipal system. Dirty water from the wash bay is collected in a sump and flows into the sewer system.

The Withook Spruit is the nearest surface watercourse (approximately 1km south-east of the property). The Withook Spruit feeds the Leeupan pan which is located approximately 1.6km south-east of the site. The Leeupan Pan is a closed pan with no surface outflow system. The Glenshaft Pan is situated approximately 2km north-east of the study site adjacent to a sewerage treatment works which also has a small water body associated with it.

It is not expected that the operations and activities at Zimalco will generate any direct impact on these surface water features. Contamination can be caused by run-off which is polluted as a result of the activities on the site. Proper waste management and ensuring good ‘housekeeping’ on the site will minimise this potential risk. Additional potential impacts on surface water will be assessed during the EIA phase of the project.

7.3 Ground Water

No boreholes are located at the project site and there is no information on the quality of the groundwater below Zimalco. Potential impacts on groundwater may arise if dangerous substances are allowed to leak onto bare soil and potentially leach into the ground. However, the entire site is paved and it is unlikely that groundwater pollution will occur as a result of the current activities on site. Areas where aluminium dross is stored are concretised and under roof, therefore rainwater does not leach through the material.

7.4 Culturally Important or Heritage Sites

The project site has been operated as a metal processing facility since the early 1970s. Any impacts that may have been generated on cultural or historical sites cannot be mitigated at this late stage. The activity on site will not be changing, but merely applying for licensing in accordance with the current environmental legislation. It is, therefore, motivated that it is unlikely that any artefact of cultural or historical value remains on site and that the continuing operation will not make any new significant impact in this regard.

7.5 Visual Impacts

The Zimalco aluminium smelter is not intrusive on the visual aspect of the area as the facility is situated within an industrial land use zone. Additionally, the operations take place mostly within the warehouse infrastructure on site. Aluminium dross and scrap aluminium storage areas are designated and kept tidy. The entire site is walled and these storage areas are not

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visible from outside the facility. The potential aesthetic impact of the facility on the surrounding area is considered as a low risk.

7.6 Air Quality Impacts

The most significant environmental impact associated with aluminium smelters relates to air quality. Primary aluminium producers are very energy intensive and the furnaces are known to emit significant amounts of greenhouse gases (GHGs), such as carbon dioxide and perfluorocarbons (PFCs). Greenhouse gas emissions are produced during the provision of energy for smelters (e.g. coal-fired power stations), as well as smelters directly emitting

PFCs and carbon dioxide (CO2).

However, it is also known that secondary aluminium producers are much less energy intensive (using approximately 6% of the energy utilised by primary aluminium producers) and therefore are responsible for significantly less GHG emissions. Moreover, secondary aluminium smelters do not produce perfluorocarbons. The Zimalco secondary aluminium production process utilises natural gas for their furnaces. The potential exists that these may generate NOx, the precursor to ozone.

At the Zimalco operation, each piece of equipment has its own extraction system (scrubbers and/or filters) for dust extraction and to minimise emissions into the atmosphere. Several furnaces are operated on the site (both electrical and natural gas). Zimalco holds two registration certificates in terms of the Atmospheric Pollution Prevention Act (1965) and is currently undertaking an application for an Air Emissions License in terms of the National Environmental Management Air Quality Act (Act 39 of 2004). The certificates are for the following processes:

i. Scrap aluminium is melted in furnaces. The molten aluminium is transferred to holding furnaces and cast into ingots. Molten aluminium is transferred to the powder plant for processing into aluminium powder.

ii. In the Master Alloys section primary aluminium is melted in induction furnaces and cast into ingot sows.

iii. The screening and milling of aluminium dross using conveyors, trommel screen, jaw crusher, hammer mill, vibrating screens, ball mills, bag filters, hoods and ducting.

The appliances and measures to prevent air pollution will be discussed in detail in the Environmental Impact Report. Dust monitoring adjacent to the temporary storage of the waste dross is also undertaken on site.

The AEL application is being undertaken as a separate process from the Waste Management License Application.

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7.7 Traffic Impacts

Traffic to and from the smelter is limited to the delivery of materials as well as the collection and removal of product and waste materials. Other traffic is related to the arrival of staff at work for shifts. Zimalco is situated at the end of a cul-de-sac in an industrial area and it is not expected that traffic generated as a result of the operation of the facility will have a significant impact on other road users in this area. The access to the site will not affect any main road traffic.

7.8 Noise

The location of the aluminium smelting facility is within an industrial land use area. The residential township of Wattville is located to the east and adjacent to the facility. This residential area is considered as a sensitive receptor. However, noise generated by the operations and activities on site are significantly muffled due to most activities taking place within the warehouse infrastructure. Heavy vehicle traffic for delivering and collecting from the facility may contribute to ambient noise. Operational hours are 24 hours a day throughout the year. Noise disturbance to the adjacent community is thus most likely to be problematic during the evening.

Noise generation will most significantly impact the employees stationed at these areas within the facility. All staff are provided with the appropriate personal protection equipment and signage on site indicates at which areas ear plugs should be used.

7.9 Socio-Economic Impacts

Zimalco incorporates a beneficial use of scrap aluminium and aluminium dross (recycling the material and transforming it into ingot for subsequent use in industry and manufacturing); effectively diverting these potential waste streams from being disposed of at already stressed landfill sites.

Zimalco employs and provides long-term job security for 156 permanent staff members. On- site training and skills development takes place. Zimalco also contributes financial stimulation to the local economy, as well as generating export foreign exchange revenues. The socio-economic impact of the facility is considered as positive and will be further investigated during the EIA phase of the project.

7.10 Safety

Impacts to safety are limited to the employees of Zimalco. Due to the nature of the operation (aluminium smelting), certain hazards are inherent. Safety risks to employees include the physical hazard of burns resulting from working with the hot molten metal. Other safety risks include chemical hazards (inhalation of fumes) as well as smelter dusts. All staff are provided with, and are required to wear the relevant personal protection equipment.

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It is not anticipated that the operation will generate safety risks to the general public as the site is walled and strict access control is implemented.

7.11 Cumulative Impacts

The most significant cumulative impact would be related to air quality as the facility is based in an industrial area. This and other potential cumulative impacts will be considered and assessed in the EIA phase of this project.

8 IMPACT ASSESSMENT METHODOLOGY

8.1 Specialist Studies

The Biodiversity Section of the Gauteng Department of Agriculture and Rural Development was contacted regarding the project site. Shape files for the study site were sent to the Department in order for them to determine whether any specialist biodiversity investigations were required in terms of their Conservation Plan. The Department indicated that no specialist biodiversity assessments were required for the site in question.

8.2 Stakeholder Input

The Public Participation process did not identify additional potential impacts for investigation. The Comments and Responses Report included in the Final Scoping Report captured the comments received during the initial Public Participation process of this application.

Stakeholders were provided with an opportunity to provide input into this process by registering as Interested and Affected Parties (I&APs) during the Notification Period. I&APs submitted written comments and/or issues regarding the proposed application. In addition, stakeholders had the opportunity to review all documentation related to the application. No additional issues were raised during the public review period. The Comments and Responses Report will be continually updated throughout the phases of the project.

Public Meetings, as required, will be scheduled during the Scoping and Environmental Impact Assessment Phases during which the Waste Management License Application and potential impacts of the operation can be discussed.

The Minutes from any public meetings or focus group meetings will be included in the respective Environmental Impact Report so that any comments or issues raised during the meetings can be reviewed by the competent authority and considered during the decision- making process.

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8.3 Impact Assessment and Criteria Rating

The impact assessment methodology proposed for this development is based on the ISO14001 principle of activities, aspects and impacts.

Activities are the physical activities that are carried out during the project during design, construction, operations and decommissioning of the development proposed for the site;

Environmental aspects are elements of the activities that interact with the environment and include biophysical and socio-economic elements.

 Impacts are defined as changes in the biophysical or socio-economic environment as a result of the aspects.

Each impact identified within the Scoping Phase of the study is given a significance rating. The significance rating is obtained by implementing this equation:

Significance = (Consequence of impact) x (Probability of impact)

The consequence of an impact is the sum of extent, duration, severity and degree of irreplaceable loss of the resource. All consequences of an impact are measured as cumulative impacts, taking into account the existing impacts on the resource. The significance of an impact can be measured as positive or negative.

Table 5: Impact Assessment table for Calculation of Significance Category Description Score Site only 1 Local 2 Extent Provincial 3 National 4 Global 5 Immediate short-term (less than 3 months) 1 Construction or decommissioning period 2 Duration For the life of the operation 3 Permanent 5 Will have an insignificant impact on the resource 1 Intensity of Will generate an impact of low intensity 2 impact on resource Will generate an impact of moderate intensity 3 Will have a very significant impact on the resource 4 No/minor irreplaceable loss 0 Irreplaceable Partial irreplaceable loss 1 loss of resources Major loss of irreplaceable resources 2 Full loss of irreplaceable resources 5

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Category Description Score Improbable 0.5 Possible but unlikely 1 Probability Probable 2 Highly probable 3 Definite 4

Once the impact has been assessed using the above significance categories, a rating is calculated. The rating will indicate a specific significance of the impact as illustrated by the table below. By identifying whether the impact is positive or negative, the significance will be read from the relevant portion of the table.

By calculating the significance rating of the impact, one can evaluate whether a negative impact can be mitigated and managed efficiently, or whether the impact is a fatal flaw, and thereby disallowing the proposed development from being approved. A positive impact could be a motivation to the proposed development and by assigning significance to the positive impact; this provides comparative information to decision-makers for approval or denial of the application.

Table 6: Impact Ratings and the Implicated Significance Score Significance >60 Fatal flaw (unacceptable impact)

40 to 60 High significance Impact Impact

Negative Negative 20 to 39 Moderate significance

19 to 0 Low significance

0 to 25 Low significance

26 to 45 Moderate significance Impact Impact Positive Positive >45 High significance

9 STAKEHOLDER ENGAGEMENT

9.1 Regulation 54 of the EIA Regulations (2010)

The stakeholder engagement / public participation process for this Waste Management License Application was undertaken in accordance with the requirements referred to in Section 27(a) and outlined in Regulation 54 of the EIA Regulations (Regulation 543 of 2010). Upon receipt of the project reference number from the DEA, the public participation process was initiated with the public notification period. This was also followed by Scoping Phase stakeholder engagement and will again be followed by the EIA Phase stakeholder engagement.

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9.2 Notification of I&APs

Upon receipt of the project reference number from the DEA, the following steps were taken to notify any interested and affected parties of the intention to undertake the Waste Management License Application process and the related Scoping and Environmental Impact Assessment for the existing Zimco Aluminium Company (Zimalco) located in Benoni South, Gauteng.

9.2.1 Newspaper Advertisements

Newspaper advertisements providing notice of the proposed Waste Management License Application and the proposed undertaking of an Environmental Impact Assessment, as well as contact details for the environmental assessment practitioner (EAP) were published in both a local (Benoni City Times) and a national newspaper (The Star). During the Scoping Phase, additional advertisements were placed to announce the availability of the Draft Scoping Report for public review and comment. Copies of the notification advertisements are provided in Appendix A-3. Copies of the advertisements announcing the Scoping Phase are included in this Report.

9.2.2 On site notice

Two “A2”-sized site notices were displayed at the entrance to the site and along the boundary between the study site and the Wattville Township. The site notices provided notification of and the details of the application along with the contact details of the EAP. The site notices fulfilled the requirements as stipulated in the EIA Regulations (2010). Photographs of the site notices placed at the study site are included as Appendix A-1.

9.2.3 Background Information Document (BID)

Background Information Documents were prepared and delivered to the surrounding industries as well as the residents immediately adjacent to the project site in the Wattville Township.

Notification letters and copies of the BID were also emailed to the following identified authorities and stakeholders:

 The local ward councillor (Ward 29, Ekurhuleni Metropolitan Municipality);

 Ward councillors from immediately surrounding Wards 30, 31 and 32;

 Ekurhuleni Metropolitan Municipality – Environmental Department; and

 Ekurhuleni Metropolitan Municipality – Waste Management Department.

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The Background Information Document included details of the existing operations at Zimalco for which the application is being submitted along with the details of the EAP. Property and location details were provided along with a map illustrating the location of the study site. An I&AP Registration form was provided encouraging any potential I&APs to register as such. A copy of the BID is included as Appendix A-2.

9.2.4 Public Meeting

No public meeting was conducted during the Scoping Phase of this application. However, public meetings, as may be required, will be scheduled during the EIA phases of the project. I&APs will be invited to attend such meetings to discuss the project. Any meetings held will be minuted and copies of the Meeting Minutes will be appended as Appendix A-4 of the EIA Report. Moreover, all issues, queries or concerns raised at any such meetings will be documented in the Comments and Responses Report that will be compiled and attached as Appendix A-5.

9.3 Register of Interested & Affected Parties

A Register of any Interested and Affected Parties was compiled and will be maintained throughout the project. The list will be continuously updated throughout the various phases of the project (Notification, Scoping and EIA phases). The Register of I&APs is included as Table 7 below.

9.4 Issues Raised by I&APs (Issues Report)

I&APs were notified of the availability of the Draft Scoping Report for public review and comment. No further comments and/or concerns were received during the review period. Feedback from the I&APs during the notification period was limited to registration as I&APs.

In addition, all recorded comments and issues (during the notification period) will be carried over to the EIA Phase for further assessment against specialist studies to determine if there are any significant risks as per comments raised.

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Table 7: Register all Interested and Affected Parties for the project to date. Register of Interested and Affected Parties ZIMALCO WML & EIA Updated: 12 November2013

NAME AFFILIATION CONTACT NUMBERS EMAIL ADDRESS

Identified Authorities

Ekurhuleni Metropolitan Edenvale CCC Mr. Stuart Green Municipality cnr Hendrik Potgieter Divisional Head: (011) 999 2006 [email protected] Environmental Resource and Van Riebeeck Legislative Compliance Management 1st Floor, Room 205

Ekurhuleni Metropolitan Edenvale CCC Municipality cnr Hendrik Potgieter Ms Cecilia Rakgoale (011) 999 3316 [email protected] Environmental Resource and Van Riebeeck Management 1st Floor, Room 205

Ekurhuleni Metropolitan Mr. Ahmed Loonat Municipality (082) 560 8293 [email protected] Ward 29 Councillor Affected Ward Cllr

Mr. Stephan Jabulani Ekurhuleni Metropolitan Sibiya Municipality (073) 325 6646 [email protected] Ward 30 Councillor Neighbouring Ward Cllr

Ekurhuleni Metropolitan Ms Shauné Le Roux Municipality (074) 179 7001 [email protected] Ward 31 Councillor Neighbouring Ward Cllr

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NAME AFFILIATION CONTACT NUMBERS EMAIL ADDRESS

Ekurhuleni Metropolitan Mr. Johan Hendricks Municipality (082) 518 4393 [email protected] Ward 32 Councillor Neighbouring Ward Cllr

I&APs that registered during the Notification Phase

Ekurhuleni Metropolitan Cnr Van Riebeeck Ave Municipality and Hendrik Potgieter Mr. Hannes Butler (t) 011 999 6114 Environmental Resource [email protected] Street Principal Admin Officer (f) 086 775 8239 Management PO Box 25, Edenvale, Department 1610

I&APs that registered during the Scoping Phase

I&APs that registered during the EIA Phase

To be completed within the EIA Phase of the project

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10 PLAN OF STUDY FOR EIA

10.1 Introduction

The process that was followed for the compilation of the Plan of Study for EIA complies with the requirements outlined in Regulation 28(n) of the Environmental Impact Assessment Regulations (Reg. 543 of 2010). This Plan of Study refers to the second phase of the EIA process, i.e. the Environmental Impact Assessment (EIA) Phase, which is aimed at investigating the potential for, and the significance of, the environmental impacts associated with the proposed development.

A comprehensive EIA is required as follow up to the Scoping Phase. In accordance with the Application Procedure, potential environmental issues are identified during the Scoping Phase. These issues, along with any additional identified impacts are then investigated and assessed during the EIA Phase. This Plan of Study for EIA will outline the sequence of actions to be taken in order to complete the EIA process and submit the EIR to the competent authority (National Department of Environmental Affairs) for decision-making.

10.2 Objectives

The goal of the Plan of Study for Environmental Impact Assessment is to define the proposed approach to the environmental impact assessment of the application. As stipulated in the EIA Regulations (2010), the Plan of Study should include the following elements:

i. A description of the tasks that will be undertaken as part of the environmental impact assessment process, including any specialist reports or specialised processes, and the manner in which such tasks will be undertaken;

ii. An indication of the stages at which the competent authority will be consulted;

iii. A description of the proposed method of assessing the environmental issues and alternatives, including the option of not proceeding with the activity; and

iv. Particulars of the public participation process that will be conducted during the environmental impact assessment process.

10.3 Description of Tasks to be undertaken for EIA

The following section describes the identified tasks that are required to form part of the EIA Process:

10.3.1 Description of the affected environment

A description of the affected environment must be provided. Zitholele Consulting will provide an indication of the ecological condition of the affected environment.

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10.3.2 Public Participation Process

The following public participation process is proposed for the EIA Phase:

i. Placement of a newspaper advertisement in a national and/or local newspaper.

ii. Official notification of all registered I&APs from the Notification Period and Scoping Phase.

iii. Registration of any new I&APs.

iv. Public and/or focus group meetings

v. Circulation of Draft Environmental Impact Report (EIR) to I&APs for comment, with a 30 day response period.

vi. Submission of final EIR to the National Department of Environmental Affairs (DEA).

Consultation with I&APs regarding the possible significance of impacts and suitable mitigation measures will take place during the Public Participation Process.

10.3.3 Specialist Reports

During the preparation of the WML Application Form and the Draft Scoping Report, the GDARD Biodiversity Section was consulted regarding the requirement for any specialist biodiversity assessments. No specialist biodiversity investigations were identified for the project site.

An Environmental Management Programme Report (EMPR) and a supporting Waste Management Plan (in accordance with the requirements of NEMWA) will be compiled as part of the EIA Phase.

An Air Emissions License (in terms of NEM:AQA) is being applied for independently from the Waste Management License Application.

10.3.4 Specific Project Detail

The existing aluminium smelting operation and associated waste management activities forming part of the Licensing application will be described in detail. Process flow diagrams indicating inputs and outputs will be included.

10.3.5 Impact Assessment

The impact assessment will provide an evaluation of impacts prior to mitigation, as well as proposed mitigation measures, and then evaluate the impacts after mitigation. The potential environmental impacts identified in the study will be quantified as far as possible and the

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significance of the impacts will be assessed according to specific criteria as discussed below in Section 10.5.

10.3.6 An Environmental Impact Statement

An environmental impact statement will be provided as part of the EIA. The opinion of the EAP as to whether or not the activity should be authorised will also be included.

10.3.7 An Environmental Management Programme Report (EMPr)

A Draft Environmental Management Programme Report (EMPr) for the existing facility will be provided with the EIA Report. The DEMPr will not include plans for the construction phase as the facility already exists and no additional construction is expected. The DEMPr will be compiled for the operational and potential decommissioning phases.

The DEMPr will identify environmental targets and objectives and will describe the methods and procedures that need to be followed (such as the mitigation and monitoring of potential impacts) to achieve these goals and objectives. The DEMPr will be compiled in such a manner that it can be easily incorporated into the daily management of the site.

The DEMPr aims to provide environmental responsibility and a management framework within which all existing and future activities will occur, as well as providing for the protection of any potentially sensitive areas.

10.3.8 Waste Management Plan

A Waste Management Plan for the existing facility and operations will be compiled in accordance with the requirements of the National Environmental Management: Waste Act (Act 59 of 2008). The existing waste management systems will be assessed and a waste management strategy for the operations identified. This Waste Management Plan will form a component, or will be combined with the EMP for ease of use by the proponent.

10.4 Stages of Authority Consultation

Consultation with the competent authority, the National Department of Environmental Affairs (DEA), will be ongoing. It is anticipated that authorities will provide relevant feedback and comment on the Scoping Report and Plan of Study for EIA, as it informs the content of the EIR. A site visit or meeting with DEA: Waste Directorate should be scheduled at their earliest convenience. In addition, consultation with the relevant entities at the Ekurhuleni Metropolitan Municipality will be undertaken during both the Scoping and EIA Phases of the project.

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10.5 Method for Impact Assessment

The impact assessment methodology proposed for this development is based on the ISO14001 principle of activities, aspects and impacts.

 Activities are the physical activities that are carried out during the project during design, construction, operations and decommissioning of the development proposed for the site;

 Environmental aspects are elements of the activities that interact with the environment and include biophysical and socio-economic elements.

 Impacts are defined as changes in the biophysical or socio-economic environment as a result of the aspects.

Each impact identified within the Scoping Phase of the study is given a significance rating. The significance rating is obtained by implementing this equation:

Significance = (Consequence of impact) x (Probability of impact)

The consequence of an impact is the sum of extent, duration, severity and degree of irreplaceable loss of the resource. All consequences of an impact are measured as cumulative impacts, taking into account the existing impacts on the resource. The significance of an impact can be measured as positive or negative.

Impact Assessment table for the Calculation of Significance. Category Description Score Site only 1 Local 2 Extent Provincial 3 National 4 Global 5 Immediate short-term (less than 3 months) 1 Construction or decommissioning period 2 Duration For the life of the operation 3 Permanent 5 Will have an insignificant impact on the resource 1 Intensity of Will generate an impact of low intensity 2 impact on resource Will generate an impact of moderate intensity 3 Will have a very significant impact on the resource 4 No/minor irreplaceable loss 0 Irreplaceable Partial irreplaceable loss 1 loss of resources Major loss of irreplaceable resources 2 Full loss of irreplaceable resources 5

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Category Description Score Improbable 0.5 Possible but unlikely 1 Probability Probable 2 Highly probable 3 Definite 4

Once the impact has been assessed using the above significance categories, a rating is calculated. The rating will indicate a specific significance of the impact as illustrated by the table below. By identifying whether the impact is positive or negative, the significance will be read from the relevant portion of the table.

Impact Ratings and the implicated Significance. Score Significance >60 Fatal flaw (unacceptable impact)

40 to 60 High significance Impact Impact

Negative Negative 20 to 39 Moderate significance

19 to 0 Low significance

0 to 25 Low significance

26 to 45 Moderate significance Impact Impact Positive Positive >45 High significance

By calculating the significance rating of the impact, one can evaluate whether a negative impact can be mitigated and managed efficiently, or whether the impact is a fatal flaw, and thereby disallowing the proposed development from being approved. A positive impact could be a motivation to the proposed development and by assigning significance to the positive impact; this provides comparative information to decision-makers for approval or denial of the application.

10.6 Proposed Public Participation

The steps outlined in Section 10.3.2 above will form the basis of the EIA Phase Public Participation Process. The stakeholder database developed during the Scoping Phase will be used as a reference to ensure that stakeholders are involved and participate in the rest of the EIA process. During the EIA Phase, stakeholders will be notified of the continuation of the project to the EIA Phase. Information regarding the progress of the application and licensing process will be provided. Stakeholders will receive notification when the Draft Environmental Impact Report (EIR) is available for review and comment. Any comments received from stakeholders will be incorporated into the final EIR before submission to the

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competent authority. The stakeholders will also be informed as to whether or not the Waste Management License is granted and the appeal procedure will be explained.

10.7 Proposed EIA Report Skeleton

The following report skeleton provides an example of the proposed content that the Environmental Impact Report will contain.

Table 8: Proposed content to be included in EIR. 1. INTRODUCTION & BACKGROUND

1.1. Environmental Authorisation 1.2. Environmental Assessment Practitioner 1.3. The Proponent & Landowner 1.4. Relevant Stakeholders 1.5. Relevant Authorities

2. PROPOSED ACTIVITY

2.1. Property Description 2.2. Activity Description 2.3. Relevant Legislation Reviewed for this Application

3. POTENTIAL ENVIRONMENTAL IMPACTS

3.1. Description of the Current Environment

3.1.1. Surrounding Land Uses 3.1.2. Climate 3.1.3. Geology & Topography 3.1.4. Surface Water 3.1.5. Ground Water 3.1.6. Fauna & Flora 3.1.7. Heritage & Archaeology 3.1.8. Visual Nature 3.1.9. Ecological Condition 3.1.10. Socio-Economic Climate

3.2. Potential Environmental Impacts of Current and Proposed Activities

3.2.1. Surrounding Land Uses 3.2.2. Climate 3.2.3. Geology 3.2.4. Surface Water 3.2.5. Ground Water 3.2.6. Fauna & Flora 3.2.7. Heritage & Archaeology 3.2.8. Visual Nature 3.2.9. Ecological Condition 3.2.10. Socio-economic Climate

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3.3. Methodology for Assessing Impacts

3.3.1. Specialist Studies 3.3.2. Impact Assessment Criteria and Rating

4. STAKEHOLDER ENGAGEMENT

4.1. Section 54 of the EIA Regulations (2010)

4.2. Notification of I&APs

4.2.1. Newspaper Advertisement 4.2.2. On-site Notices 4.2.3. Background Information Document 4.2.4. Public Meeting

4.3. List of Registered I&APs

4.4. Issues Raised by I&APs (Issues Report)

5. MOTIVATION FOR NEED AND DESIRABILITY

5.1. Socio-economic

5.2. Biophysical Environment

6. POTENTIAL ALTERNATIVES

6.1. Identification of Alternatives

6.2. Socio-economic Impacts of Alternatives

6.3. Biophysical Impact of Alternatives

6.4. Methodology for Assessing Alternatives (including No-Go Option)

6.4.1. Environmental Criteria 6.4.2. Significance Rating System

7. IMPACT ASSESSMENT

7.1. Impact Assessment Methodology

7.2. Comparative Assessment of Alternatives

7.3. Specialist Findings and Recommendations

7.4. Identified Environmental Issues

8. MITIGATION OF ENVIRONMENTAL ISSUES

8.1. Agricultural Potential

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8.1.1. Existing Impacts 8.1.2. Potential Impacts of Activity without Mitigation 8.1.3. Proposed Mitigation Measures 8.1.4. Potential Impacts of Activity with Mitigation 8.1.5. Cumulative Impacts

8.2. Air Quality

8.2.1. Existing Impacts 8.2.2. Potential Impacts of Activity without Mitigation 8.2.3. Proposed Mitigation Measures 8.2.4. Potential Impacts of Activity with Mitigation 8.2.5. Cumulative Impacts

8.3. Cultural Heritage

8.3.1. Existing Impacts 8.3.2. Potential Impacts of Activity without Mitigation 8.3.3. Proposed Mitigation Measures 8.3.4. Potential Impacts of Activity with Mitigation 8.3.5. Cumulative Impacts

8.4. Fauna

8.4.1. Existing Impacts 8.4.2. Potential Impacts of Activity without Mitigation 8.4.3. Proposed Mitigation Measures 8.4.4. Potential Impacts of Activity with Mitigation 8.4.5. Cumulative Impacts

8.5. Flora

8.5.1. Existing Impacts 8.5.2. Potential Impacts of Activity without Mitigation 8.5.3. Proposed Mitigation Measures 8.5.4. Potential Impacts of Activity with Mitigation 8.5.5. Cumulative Impacts

8.6. Ground Water

8.6.1. Existing Impacts 8.6.2. Potential Impacts of Activity without Mitigation 8.6.3. Proposed Mitigation Measures 8.6.4. Potential Impacts of Activity with Mitigation 8.6.5. Cumulative Impacts

8.7. Surface Water

8.7.1. Existing Impacts 8.7.2. Potential Impacts of Activity without Mitigation 8.7.3. Proposed Mitigation Measures

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8.7.4. Potential Impacts of Activity with Mitigation 8.7.5. Cumulative Impacts

8.8. Socio-economic Impacts

8.8.1. Existing Impacts 8.8.2. Potential Impacts of Activity without Mitigation 8.8.3. Proposed Mitigation Measures 8.8.4. Potential Impacts of Activity with Mitigation 8.8.5. Cumulative Impacts

8.9. Visual Impact

8.9.1. Existing Impacts 8.9.2. Potential Impacts of Activity without Mitigation 8.9.3. Proposed Mitigation Measures 8.9.4. Potential Impacts of Activity with Mitigation 8.9.5. Cumulative Impacts

9. ASSUMPTIONS OR UNCERTAINTIES

10. EAP OPINION ON AUTHORISATION

11. CONCLUSIONS

12. ENVIRONMENTAL IMPACT STATEMENT

12.1. Summary of Key Findings of Impact Assessment

12.2. Comparative Assessment of Identified Alternatives

12.3. Draft EMPR

12.3.1. Details and expertise of EMPR Author 12.3.2. Description of activities addressed in EMPR 12.3.3. Proposed management and mitigation measures

13. REFERENCES

14. APPENDICES

11 CONCLUSIONS AND RECOMMENDATIONS

The Final Scoping Report, will be submitted to the competent authority (DEA) for review and approval. Once the Scoping Report and Plan of Study for EIA have been approved by the National Department of Environmental Affairs, the EIA Phase of the environmental authorisation process will be undertaken.

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The Scoping Report has identified potential environmental impacts that may result from the operation of the Zimco Aluminium Company facility. Brief descriptions of the process to be followed, the relevant legislation and a description of the activities have been provided.

The EIA Report will provide a detailed description of the existing activities and infrastructure on site and the potential impacts of the secondary aluminium smelter (processing of scrap aluminium and aluminium dross) on both the social and biophysical environments. The activities as described in the project description will be assessed on both an individual as well as a cumulative level with respect to the project in its entirety.

The EIA phase will include the assessment of impacts, a comparative evaluation of any existing alternatives, and an impact statement providing motivation for or against the existing facility in terms of the environmental risks. The results of the EIA phase will provide sufficient information to facilitate decision making by the relevant authorities. The EIA will also provide mitigation and management options to minimize any impacts that may be generated. These will be outlined in the EIR and will be detailed in the accompanying EMPr.

ZITHOLELE CONSULTING (PTY) LTD

Moses Mathebula Sharon Meyer Project Manager Project Associate

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12 REFERENCES

Constitution of the Republic of South Africa. 1995: Act No 107 of 1996. Pretoria: Government Printer.

Department of Environmental Affairs (DEA). 2010. DEA Environmental Information, accessed from www.environment.gov.za/enviro-info/nat/biome.htm in June 2013.

Department of Water Affairs and Forestry (DWAF). 2007: External Guideline: Generic Water Use Authorisation Application Process. Pretoria. DWAF.

Ekurhuleni Metropolitan Municipality. 2010. Development Guide. Published by the Directorate: Communications & Marketing. Germiston. South Africa.

Ekurhuleni Metropolitan Municipality. 2009. Ekurhuleni Biodiversity and Open Space Strategy (EBOSS) Report.

Environmental Impact Assessment (EIA) Regulations. 2010: Regulation 543 of 2010. Pretoria, Government Printer.

Mucina, L. and M.C. Rutherford (Eds.). 2006. Vegetation Map of South Africa, Lesotho and Swaziland. South African National Biodiversity Institute, Pretoria.

National Environmental Management Act (NEMA). 1998: Act No107 of 1998 (as amended). Pretoria. Government Printer.

National Environmental Management: Waste Act (NEMWA). 2008: Act No. 59 of 2008. Pretoria. Government Printer.

OECD, Environment Directorate. 2010. OECD Global Forum on Environment: Focusing on Sustainable Materials Management. Materials Case Study 2: Aluminium (Working Document). Accessed at http://www.oecd.org/environment/waste/46194971.pdf in June 2013.

National Heritage Resources Act (NHRA). 1999: Act No. 25 of 1999. Pretoria. Government Printer.

Zimalco website accessed at http://www.zimalco.co.za/company.htm in May 2013.

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Appendix A: Environmental Assessment Practitioner CV

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Appendix B: WML Application Form

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Appendix C: Correspondence from Competent Authority

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Appendix D: Correspondence to Stakeholders

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Appendix E: Project Location Map

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Appendix F: Newspaper advertisements

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Appendix G: Site Notices

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Appendix H: BID and Registration Sheet

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Appendix I: Stakeholder Database

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Appendix J: Comments and Response Report

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