ENVIRONMENTAL IMPACT ASSESSMENT:
Proposed establishment of an aluminium smelter within the Coega Industrial Development Zone, Port Elizabeth, South Africa
Final Scoping Report
July 2002
ENVIRONMENTAL IMPACT ASSESSMENT:
Proposed establishment of an aluminium smelter within the Coega Industrial Development Zone, Port Elizabeth, South Africa
FINAL SCOPING REPORT JULY 2002
For Authority Review
Report compiled by Paul Lochner, Frauke Münster, Rob Hounsome, and Sarah Davies, CSIR Sandy Wren, Sandy and Mazizi Consulting ALUMINIUM PECHINEY PAS 2005 SMELTER
PURPOSE OF THIS REPORT
The Final Scoping Report forms part of a The Final Scoping Report is available for series of reports and information review by authorities prior to a decision documents that will be issued during the being made by the Eastern Cape environmental impact assessment process provincial Department of Economic Affairs, for the Aluminium Pechiney PAS 2005 Environment and Tourism (DEAE&T) on project, which proposes the construction whether to: and operation of an aluminium smelter within the Coega Industrial Development · Issue an authorization to undertake the Zone. activity with or without conditions; · Require that the information in the The Final Scoping Report includes Final Scoping Report be supplemented environmental issues and concerns by an Environmental Impact Report; identified by specialist consultants and · Decline the application. Aluminium Pechiney, as well as those raised to date by the public and authorities Although not available for public comment, through a series of public meetings, the Final Scoping Report can be viewed networking and focus group meetings, an by the public on the Internet at open day and from written http://smelter.csir.co.za as well as at the correspondence. The following information following libraries: was provided to stakeholders in order to facilitate the identification of environmental Nelson Mandela Metropole Libraries: issues and concerns: Govan Mbeki, New Brighton, Motherwell, Zwide, Newton Park, Walmer, Chatty, · The Draft Scoping Report (this was West End, Despatch, Uitenhage, sent to key stakeholders, and made KwaNobubhle, Gelvandale, KwaMagxaki, available in local libraries and on the KwaZakhele, Linton Grange, University of Internet for a period of three weeks PE, Vista University and PE Technikon from release); Cape Town: UCT Government · A Question & Answer Booklet (sent to Publications Department all stakeholders on the database). · Summary of the Draft Scoping Report The terms of reference which have been (sent to all stakeholders on the defined for the specialist studies are an database). important outcome of this Scoping study. · A website (http://smelter.csir.co.za) These were developed based on technical which provided links to relevant sites scoping inputs from specialists, Aluminium which provide further information. Pechiney and the EIA team; and the public and authority Scoping process. All stakeholders were invited to comment on the Draft Scoping Report and raise additional issues and concerns.
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TABLE OF CONTENTS
PURPOSE OF THIS REPORT ...... i TABLE OF CONTENTS ...... ii LIST OF TABLES ...... iv LIST OF FIGURES ...... iv DEFINITIONS ...... v ABBREVIATIONS...... viii
1. INTRODUCTION...... 1 1.1 Background...... 1 1.2 Rationale for the project...... 1 1.3 The requirement for an Environmental Impact Assessment...... 1 1.4 Objectives of the Scoping Report...... 2 2. INTRODUCING ALUMINIUM PECHINEY...... 3 3. DESCRIPTION OF THE PROPOSED PROJECT...... 4 3.1 The Coega Industrial Development Zone...... 4 3.2 Selection of the Coega IDZ as a potential site for the aluminium smelter...... 6 3.3 Proposed location of the aluminium smelter within the Coega IDZ...... 7 3.4 Overview of the Aluminium Pechiney PAS 2005 project...... 8 3.4.1 Import and storage of raw materials...... 9 3.4.2 The potline...... 10 3.4.3 The carbon plant and rodding shop...... 12 3.4.4 The casthouse...... 13 3.4.5 Export of aluminium ingots...... 13 3.5 Associated infrastructure requirements...... 13 3.5.1 Electricity supply...... 13 3.5.2 Port facilities...... 13 3.5.3 Transport infrastructure...... 14 3.5.4 Water supply...... 14 3.5.5 Housing...... 14 3.6 Workforce required for the project...... 14 3.6.1 Construction workforce...... 14 3.6.2 Operation workforce...... 15 3.7 Project schedule...... 15 4. DESCRIPTION OF THE AFFECTED ENVIRONMENT...... 16 4.1 Introduction...... 16 4.2 Location...... 16 4.3 The biophysical environment...... 16 4.3.1 Climate...... 16 4.3.2 Geology...... 17
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4.3.3 Water resources...... 17 4.3.4 Vegetation...... 17 4.3.5 Fauna...... 18 4.3.6 The marine ecosystem...... 19 4.4 Socio-economic environment...... 20 4.4.1 Employment and human development...... 20 4.4.2 In-migration...... 20 4.4.3 Infrastructure and services...... 21 4.5 Economic activities...... 21 5. DESCRIPTION OF THE ENVIRONMENTAL ASSESSMENT PROCESS...... 23 5.1 Roles and responsibilities of roleplayers in the EIA process...... 25 5.2 The focus of the EIA...... 26 5.3 Consideration of alternatives...... 27 5.4 The Scoping phase...... 29 5.4.1 Objectives of the Scoping phase...... 30 5.4.2 Key components of Scoping...... 30 5.4.3 Steps in the Scoping phase...... 33 6. ENVIRONMENTAL ISSUES ASSOCIATED WITH THE CONSTRUCTION AND OPERATION OF AN ALUMINIUM SMELTER...... 41 6.1 Identification of key environmental issues...... 41 6.2 Issues and responses...... 43 6.2.1 Air quality (including effects on human health, plants and agriculture) issues...... 43 6.2.2 Water resource and liquid waste management issues...... 50 6.2.3 Materials handling and solid waste management issues...... 51 6.2.4 Issues related to water discharges to the marine environment...... 53 6.2.5 Socio-economic issues...... 54 6.2.6 Traffic and transportation issues...... 58 6.2.7 Macro-economic issues...... 59 6.2.8 Noise issues...... 61 6.2.9 Issues related to visual impacts...... 61 6.2.10 Additional environmental issues...... 63 6.2.11 Issues related to the EIA and public participation process...... 65 6.2.12 Issues related to Aluminium Pechiney project proposal...... 70 6.2.13 Issues related to the management of the Coega IDZ and the proposed Port of Ngqura...... 75 6.3 Linkages between key environmental issues...... 78 7. REVISED TERMS OF REFERENCE FOR THE SPECIALIST STUDIES...... 80 7.1 Generic Terms of Reference for all specialist studies...... 80 7.2 Specific Terms of Reference for the specialist studies...... 81 7.2.1 Air quality study...... 81 7.2.2 Water resource management and liquid waste management study...... 83 7.2.3 Materials handling and solid waste management study...... 84 7.2.4 Study of water discharges to the marine environment...... 85 7.2.5 Socio-economics study...... 86
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7.2.6 Traffic and transportation study...... 86 7.2.7 Macro-economics study...... 87 7.2.8 Noise study...... 87 7.2.9 Visual impact study...... 88 8. REFERENCES...... 88
LIST OF TABLES
Table 1: Proposed Project Schedule for the PAS 2005 project...... 15 Table 2: Specialist studies...... 33
LIST OF FIGURES
Figure 1: Map showing the location of the Coega IDZ relative to Port Elizabeth...... 5 Figure 2: Map of the Coega Industrial Development Zone showing the location of the metallurgical cluster in which the proposed aluminium smelter would be located...... 8 Figure 3: Aerial view of the proposed Aluminium Pechiney smelter within the Coega IDZ...... 10 Figure 4: Aluminium production process...... 11 Figure 5: EIA process flow diagram (based on South African EIA Regulations)...... 24 Figure 6: Identifying the focus of the Aluminium Pechiney EIA with respect to the aluminium lifecycle...... 26 Figure 7: Detailed Scoping process showing key roles and interactions between the proponent, the consultant, the authorities, the CDC, NPA and I&APs...... 34 Figure 8: Decision-making framework for identification of key issues for the Aluminium Pechiney EIA...... 42 Figure 9: Linkages between key environmental issues associated with the proposed aluminium smelter...... 79
LIST OF APPENDICES
Appendix A: Advertisements for the Aluminium Pechiney EIA Process Appendix B: Interested and Affected Parties and Stakeholder Groups Appendix C: Letters of Invitation to Participate in the Aluminium Pechiney EIA Process Appendix D: Issues and Concerns Raised at Public Meetings Appendix E: Issues and Concerns Raised at Networking Meetings Appendix F: Issues and Concerns Raised at Focus Group Meetings Appendix G: Comments Form Appendix H: Correspondence received from Stakeholders
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DEFINITIONS
Alternatives A possible course of action, in place of another, that would meet the same purpose and need (of proposal). Alternatives can refer to any of the following but are note limited hereto: alternative sites for development, alternative site layouts, alternative designs, alternative processes and materials. In Integrated Environmental Management the so-called “no go” alternative refers to the option of not allowing the development and may also require investigation in certain circumstances.
Alumina Alumina is the name given to the raw material, aluminium oxide (Al2O3), which is used in the smelting process to produce aluminium. It is a white powdery oxide produced through refining of bauxite. Aluminium Aluminium (in metallic form) is a relatively lightweight metal which is highly corrosion resistant, an excellent thermal conductor, non-magnetic, non-toxic and highly workable. End uses of aluminium include building and construction materials, electrical products, packaging and containers, cooking utensils, the aeronautical, automotive industries and leisure goods industries. Aluminium is produced by a smelting process which separates the aluminium from alumina (aluminium oxide) through electrolytic reduction. Anchor tenant Anchor tenants acts as catalysts for further investment (including improvements in local infrastructure and services) and as a magnet for other economic activities. They usually involve large-scale projects and in the construction and operational phases, present major employment and other economic opportunities for local enterprises Anode An anode is the name given to a positive electrode in a reduction cell. The anode used in the aluminium industry provides the positive electrical contact. The anode block is consumed during the smelting process. Assessment The process of collecting, organising, analysing, interpreting and communicating data that is relevant to some decision. Baking furnace The anodes produced at the paste plant are baked at about 1100°C in an oil- fired furnace for several weeks in order to give them mechanical and conductivity properties. Bath This is the name given to the electrolytic medium within the pot through which the electric current is passed in the aluminium smelting process. Bath is made up of cryolite, alumina and aluminium fluoride. Bauxite Aluminium ore which is refined to produce alumina. Butt crushing plant At the butt crushing plant the spent anodes which are recovered from the potline are crushed in order for them to be used for the production of new anodes. Casthouse Liquid aluminium which is extracted from the potline is transported to the casthouse where it is cast into aluminium ingots. Cathode A cathode is the name given to the negative electrode in a reduction cell. The cathode used in the aluminium industry provides the negative electrical contact as well as serving as the lining of the pot in which the smelting process takes place. Cryolite A mineral (sodium aluminium fluoride) which the main component of bath in the aluminium smelting process.
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Dross The skimmings on the surface of the molten aluminium which are removed because they contain impurities which could affect the quality of the aluminium metal produced in the smelter. Dry scrubbing The process whereby potential gaseous pollutants such as fluoride are attracted onto a solid substance and thereby removed from the air. An alternative approach is “wet scrubbing” but this has the disadvantage of producing additional liquid waste and may lead to corrosion. Electrolysis When electricity is passed through a liquid solution of an ion or an electrolyte, a chemical reaction called electrolysis occurs. The energy from the electric current breaks chemical bonds. In the aluminium smelting process this enables the separation of aluminium from alumina (aluminium oxide). Environment The biophysical, social, economic, cultural, political and historical context within which people live and within which development takes place. Environmental A change resulting from the effect of an activity on the environment, whether impact desirable or undesirable. Impacts may be the direct consequence of an organisation’s activities or may be indirectly caused by them. Environmental An Environmental Impact Assessment (EIA) refers to the process of identifying, impact assessment predicting and assessing the potential positive and negative social, economic and biophysical impacts of any proposed project, plan, programme or policy which requires authorisation of permission by law and which may significantly affect the environment. The EIA includes an evaluation of alternatives, as well as recommendations for appropriate mitigation measures for minimising or avoiding negative impacts, measures for enhancing the positive aspects of the proposal, and environmental management and monitoring measures. Environmental issue A concern felt by one or more parties about some existing, potential or perceived environmental impact. Fume treatment The fume treatment centre (FTC) extracts and recycles fluoride, poly-aromatic centre hydrocarbon containing tar and dust from emissions created by the anode baking process. Gas treatment The gas treatment centres have the primary role of recycling the fluoride and centre dust captured from the pots. Industrial An Industrial Development Zone is an area identified for industrial development. Development Zone The aim is to attract domestic and foreign investment into industrial and commercial parks by providing serviced industrial sites with purpose-built infrastructure. Ingot Bars of aluminium metal which are produced as the final product of the primary aluminium smelting process. Integrated IEM provides an integrated approach for environmental assessment, environmental management, and decision-making and to promote sustainable development management and the equitable use of resources. Principles underlying IEM provide for a democratic, participatory, holistic, sustainable, equitable and accountable approach. Interested and Individuals or groups concerned with or affected by an activity and its affected parties consequences. These include the authorities, local communities, investors, work force, consumers, environmental interest groups and the general public. Key issue An issue raised during the Scoping process that has not received an adequate response and which requires further investigation before it can be resolved.
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Liquid pitch Pitch is a heavy, sticky, tar-like by-product derived from the coking of coal. It is used as a binding agent for the petroleum coke in the anode blocks, prior to baking. Listed activities Development actions that are likely to result in significant environmental impacts as identified by the Minister of Environmental Affairs and Tourism in terms of Section 21 of the Environment Conservation Act. Megawatt A measure of power, equal to 1 000 kilowatts or 1 million Watts. This is the unit used to quantify the electricity required by a given system. Negative impact A change that reduces the quality of the environment (for example, by reducing species diversity and the reproductive capacity of the ecosystem, by damaging health, or by causing nuisance). Paste plant At the paste plant crushed petroleum coke and spent anode butts (the remainder of the anode which was not consumed in the potline) are mixed with liquid pitch to form an anode paste which is compacted into anode blocks prior to baking. Petroleum coke Petroleum coke is the main carbon source for the anode blocks. It is imported from overseas and is made from oil derivatives, which are regarded as a by- product by oil refineries. Pitch fume The pitch fume treatment centre (PFTC) treats PAH containing tar and dust treatment centre emissions from the paste plant. Positive impact A change which improves the quality of life of affected people or the quality of the environment. Pot The pot is the steel shell within which the aluminium smelting process takes place. Otherwise referred to as electrolytic reduction cells. Potline Pots are electrically connected and arranged in long buildings called potrooms. Two potrooms constitute a potline. Potlinings Potlinings consist of the refractory bricks that are used to insulate the steel shell of the pot (to contain the heat and prevent damage to the steel shell) and the carbon blocks that form the cathode. Reduction Reduction is an electrochemical process that involves the transfer of electrons from one atom to another. Reduction forms part of the electrolysis process. Relevant authority The environmental authority on national, provincial or local level entrusted in terms of the Constitution and in terms of the designation of powers in Notice No. R. 1184 of 5 September 1997 with the responsibility for granting approval to a proposal or allocating resources. Rodding shop Newly manufactured anodes are attached to an electrical conducting stem in the rodding shop before being transported to the potline. Scoping This refers to the process of determining the spatial and temporal boundaries (the extent) for the EIA and key issues to be addressed in an environmentall assessment. Smelting Aluminium smelting refers to the separation of aluminium from aluminium oxide. Spent Potlinings The potlinings which have reached the end of their useful life and which need to be replaced and disposed of.
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ABBREVIATIONS
A2O3 Alumina (Aluminium Oxide) AP Aluminium Pechiney
CO2 Carbon dioxide CDC Coega Development Corporation CSIR Council for Scientific and Industrial Research DEAT Department of Environmental Affairs and Tourism (National) DEAE&T Department of Economic Affairs Environment & Tourism (Eastern Cape) DSR Draft Scoping Report EIA Environmental Impact Assessment EIR Environmental Impact Report FTC Fume Treatment Centre GTC Gas Treatment Centre I&AP Interested and Affected Party IEM Integrated Environmental Management IDZ Industrial Development Zone KV Kilovolt MW Megawatt NMMM Nelson Mandela Metropolitan Municipality PAH Poly-aromatic hydrocarbon PFTC Pitch Fume Treatment Centre PPP Public Participation Programme POP Persistent Organic Pollutants ROD Record of Decision SEA Strategic Environmental Assessment SMME Small, Medium and Micro Enterprises
SO2 Sulphur dioxide SPL Spent potlining
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1. INTRODUCTION
1.1 Background
Aluminium Pechiney, a French company listed on the French Commercial Register, is planning to construct a new aluminium smelter to meet rising demands for aluminium. The project, known as PAS 2005, would increase Aluminium Pechiney’s aluminium production by approximately 485,000 tonnes per annum.
In an international site selection study, Aluminium Pechiney identified 11 potential sites for locating this smelter (The site screening process is described in more detail in section 3.2). This analysis led to more detailed investigations of three of the preferred sites, these being within the Coega Industrial Development Zone (IDZ) in South Africa, and sites in Australia and Argentina. Due to recent economic instability in Argentina, the more detailed studies for this site were stopped. At present, engineering, planning and environmental studies are underway at the South African and Australian sites.
The feasibility studies will provide information on which the investment decision will be taken by Aluminium Pechiney. In investigating the environmental feasibility of the proposed smelter at the Coega IDZ site, Aluminium Pechiney has commissioned the CSIR (Environmentek), together with Sandy & Mazizi Consulting (who will carry out the public participation process) and a team of specialists, to conduct an Environmental Impact Assessment (EIA).
1.2 Rationale for the project
Aluminium Pechiney conducted a market analysis, which indicated an anticipated rise in demand for aluminium of 2,5% per annum, up to the year 2010. In order to meet this growing demand Aluminium Pechiney is investigating the feasibility of establishing a new aluminium smelter.
1.3 The requirement for an Environmental Impact Assessment
In terms of the Environment Conservation Act (Act 73 of 1989) an Environmental Impact Assessment (EIA) is required for those activities which have the potential to have a detrimental impact on the environment. Activities requiring an EIA have been specified by regulations issued by the Department of Environmental Affairs and Tourism (Government Notice R. 1182, 5 September 1997) and include scheduled processes listed in the Second Schedule to the Atmospheric Pollution Prevention Act (Act 45 of 1965). This schedule includes aluminium processes and therefore Aluminium Pechiney’s proposal to construct and operate an aluminium smelter within the Coega IDZ requires an EIA.
An EIA refers to the process of identifying, predicting and assessing the potential positive and negative social, economic and biophysical impacts of any proposed project, plan,
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Definition of the term “Environment”
The term “environment” refers not only to the “green” environment (the biophysical components such as land, water, air, soils, plants and animals) but also to the social, economic, cultural, political and historical components of the environment.
The objective of the EIA is to provide decision-makers with relevant and objective environmental information to determine whether or not the proposal will support sustainable development and, subsequently, whether or not to accept or reject the application or proposal.
The goals for sustainable development in the southern African region:
· Acceleration of economic growth with greater equity and self-reliance; · Improving the health, income and living conditions of the poor majority; · Ensuring equitable and sustainable use of the environment and natural resources for the benefit of present and future generations.
Source: United Nations Department of Economic and Social Affairs, 1997
1.4 Objectives of the Scoping Report
The Scoping Phase of the EIA refers to the process of determining the spatial and temporal boundaries (the extent) for the EIA and key issues to be addressed in an environmental assessment. This is done through a technical analysis involving the project proponent and specialists with experience in EIAs for aluminium smelters; and a consultation process with interested and affected parties (I&APs). The main purpose of Scoping is to focus the environmental assessment on a manageable number of important questions and to ensure that only significant issues and reasonable alternatives are examined.
The objective of the Draft Scoping Report is to provide information to stakeholders (including the public and the authorities) on the proposed project in order to allow stakeholders to identify any additional issues and concerns which may not yet have been identified through the technical Scoping process.
The Final Scoping Report is the consolidated report describing the proposal, the EIA process (including the scope of the study), and the environmental issues and concerns raised by stakeholders through Scoping. This report is submitted to the authorities for review and to
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2. INTRODUCING ALUMINIUM PECHINEY
Aluminium Pechiney is a French company listed on the French Commercial Register. Aluminium Pechiney is one company within The Pechiney Group, focussed on the production of primary aluminium and aluminium products. Other core business of The Pechiney Group includes the production of packaging materials, production of ferroalloys and international trade. Aluminium Pechiney is the fourth largest primary aluminium producer in the world, and the world leader in design and supply of aluminium production technology. The company conducts bauxite mining, alumina refining and aluminium smelting operations in a total of five countries.
Pechiney’s guidelines for Environment, Health and Safety
1. To ensure transparency in issues concerning environmental protection, health and safety, in particular by evaluating and publishing achievements and performances measured by selected indicators applicable to the Group’s activities. 2. To ensure regulatory compliance of operations and facilities, as well as compliance with the internal standards the Group is developing to align its practices. 3. To ensure continuous improvement of employees’ health and safety conditions and those of Group subcontractors. 4. To continue to reduce the environmental impact of the Group’s past, current or future activities as well as of its products, by limiting emissions and waste, optimising processes, managing the risk of accidents, remediating any damage done, and developing partnerships with customers and suppliers. 5. To develop products that are more considerate of the environment by analysing their life cycles, from design to recycling. 6. To implement the best available and most economically viable technology in new investments and the best environmental practices throughout the Group. 7. To manage industrial risks through efficient identification and ranking procedures, as well as by the implementation of appropriate prevention and protection measures and their ongoing adaptation. 8. To organise a scientific health watch activity to detect and control new risks.
Source: Pechiney, 2001, Environment, Health & Safety Report
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3. DESCRIPTION OF THE PROPOSED PROJECT
3.1 The Coega Industrial Development Zone
The Coega IDZ consists of 17 000 hectares of land 20 km north-east of Port Elizabeth, in the Eastern Cape Province in South Africa (Figure 1). It is the first IDZ to be established in South Africa, and forms part of the South African government’s vision for the country to become one of the world’s key manufacturing centres. Through the provision of serviced land and world-class infrastructure, the Coega Development Corporation (the operators of the Coega IDZ) aims to attract investors to the IDZ.
The establishment of the Coega Industrial Development Zone follows extensive economic feasibility and environmental assessment studies. A Strategic Environmental Assessment (SEA) was conducted in 1996 to assess the opportunities and constraints to developing the area as an IDZ and the development of a deepwater port at Coega. The objective was to ensure that environmental issues were focused on sufficiently early in the planning and decision-making process so as to avoid the shortcomings of project-specific EIAs which are generally unable to address the cumulative effects of large-scale development projects. The SEA included an evaluation of the “No Go” option and an assessment of whether there were any environmental considerations considered so important that industrial development should not proceed at all.
The outcome of the SEA was that no environmental fatal flaws were identified which would prohibit further planning of the Coega IDZ and the Port of Ngqura. A fatal flaw is an environmental constraint that is considered so important that development should not proceed at all, or requires significant changes to be environmentally feasible. The SEA identified a number of conditions and recommendations which should be implemented in order to ensure that viable economic opportunities are not foreclosed; the conservation status of the Algoa Bay islands and terrestrial ecosystems is secured; local labour and resources are used and negative impacts on local communities are minimised or avoided; and systems for the effective management and disposal of wastes and the control of pollution are established. Recommendations included the implementation of a Strategic Environmental Management Plan; a phased approach to building and operation; detailed measures to maintain or enhance environmental qualities and reduce pollution; ongoing public and stakeholder participation; and the recommendation that planning for the IDZ is linked to that of the Port Elizabeth-Uitenhage area and the Eastern Cape region.
An EIA was subsequently conducted in 1999 to assess the impacts associated with changing land-use from agriculture to an industrial development zone. The finding of this EIA was that, subject to the implementation of an Environmental Management System for the IDZ and the implementation of the recommendations suggested in the EIA, the positive impacts of the proposed IDZ seemed to outweigh the negative impacts. Authorisation for the rezoning of the land to allow the creation of the Coega IDZ has been granted in May 2002 in a revised Record of Decision issued by the national Department of Environmental Affairs and Tourism. The authorization stipulates a number of conditions that must be met. .
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Su nd ay s R iv er Colchester # Co eg a R iv Legend er Railways Roads UITENHAGE Powerlines # Coega# Approximate IDZ Location S wa rtk op St Croix Island s R AirportIndustria DESPATCH iv er Jahleel Island Jagtvlakte Motherrwellll r Joorst Park Brenton Island WellsEstate Wells Estate Formal residentialarea Townshiparea Informalresidentialarea Industrial area Kw Bluewater Bay aZ ak Saltworks he le
New # Brighton Algoa Bay Kilometers # PORT ELIZABETH 012345 Port Elizabeth Harbour N March1997 King's Beach W E S Q Summerstrand Sea View PE Airport # Ú Skoenmakerskop Cape Recife #
Figure 1: Map showing the location of the Coega IDZ relative to Port Elizabeth
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The proposal to build a new deepwater port at the mouth of the Coega River has also undergone an EIA and has been authorised subject to the adherence to the conditions attached to the revised Record of Decision and the implementation of the recommendations made by the EIA.
3.2 Selection of the Coega IDZ as a potential site for the aluminium smelter
A screening process was undertaken by Aluminium Pechiney to identify suitable international locations for constructing and operating an aluminium smelter. Eleven potential sites were identified, located in:
· Southern Africa · Australia · North America · Central America · South America · Arabian gulf.
Each of these sites has been subjected to an initial screening process, based on available information and informed assumptions. The main criteria used in this initial screening process were:
Energy supply (energy represents one third of the operating cost). · source (hydraulic, gas, other) · size of the energy resources · commercially available power (including aspects such as availability, security of supply and length of supply contract).
Site · topography, ground quality , climate · port and road infrastructure.
Environment · flora and fauna impact · existing situation (other industry in the area) · impact on employment · social impact.
Tax conditions · corporate tax, metal sale tax · depreciation rules, exemptions.
Raw materials and metal logistics · transportation cost · market location, finished product grade and shape.
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Risks inherent to the country · political stability · safety of people and goods.
Aluminium Pechiney used a model to convert the above factors into costs, which were then used as a basis for comparing the sites. At present, all 11 sites are still considered as potential sites, however, the results of the modelling exercise led to more detailed feasibility investigations at three of the sites. These are:
· Coega, South Africa · Australia · Argentina.
For these three sites, Aluminium Pechiney commenced with site engineering studies to obtain accurate figures that can be used in their economic model, in order to check the assumptions.
Due to recent economic instability in Argentina, the more detailed studies for this site were stopped. At present, engineering, planning and environmental studies are underway at the South African and Australian sites. South Africa (Coega) is currently the preferred site, due partly to a strategic agreement having been reached with Eskom in March 2002 to secure energy supply for the project. Ongoing negotiations and investigations are, however, still underway to source additional information and obtain strategic agreements to enable Aluminium Pechiney to make a final selection decision. This includes the information and decisions provided through the Environmental Impact Assessment process.
3.3 Proposed location of the aluminium smelter within the Coega IDZ
The aluminium smelter is proposed to be located in Zone 5 of the Industrial Development Zone, within the area identified as the metallurgical cluster (Figure 2). The area under consideration for the location of the aluminium smelter lies on the farm Swartekoppen 302. The particular portions involved are:
· 302/12 · 302/13 · 302/14 · 302/15 · 302/33 · 302/36 · 302/47.
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Metallurgical cluster
Figure 2: Map of the Coega Industrial Development Zone showing the location of the metallurgical cluster in which the proposed aluminium smelter would be located.
3.4 Overview of the Aluminium Pechiney PAS 2005 project
The proposed smelter would be operated on a continuous basis (24 hours, 365 days per year) using new generation smelting technology (AP50) developed by Aluminium Pechiney. AP50 smelting technology operates at 500,000 amperes of electricity in comparison to the previous AP30 and AP18 technology which operated at 300,000 and 180,000 amperes respectively. AP50 smelting technology has been selected as it represents significant capital and operating cost advantages.
The proposed smelter is being designed to produce approximately 485,000 tonnes of aluminium metal per annum.
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Summary of PAS 2005 project details
Plant Area Approx. 80 hectares Number Potlines 1 Number Potrooms 2 Length of Potrooms 1200 meters Number of electrolysis cells (“pots”) 336 Production Capacity Approx. 485,000 tons/year Alumina consumption Approx. 931,000 tons/year Petroleum Coke consumption Approx. 180,000 tons/year Liquid Pitch consumption Approx. 38,000 tons/year Electricity demand Approx. 860 MW Electricity supply 3 x 132 kV lines Water usage Approx. 600,000 m3/year Fuel Oil usage Approx. 31,780 tons/year
The proposed smelter consists of 3 major process components:
· one Potline with 336 pots (electrolytic cells); · one Carbon Plant and Rodding Shop for production of anodes; · one Casthouse for pouring ingots.
There exists the potential for a second potline to be constructed at a later stage.
Figure 3 provides an aerial view of the proposed smelter reflecting its location relative to the N2 highway and the proposed Port of Ngqura. The aluminium production process, as applying to Aluminium Pechiney’s proposed operation within the Coega IDZ, is shown in Figure 4.
3.4.1 Import and storage of raw materials
Major raw materials required for the smelting process are:
· fresh alumina · petroleum coke · aluminium fluoride; and · liquid coal tar pitch.
All of these materials would be imported by ship to dedicated port facilities within the proposed Port of Ngqura at Coega. Due to the small quantities of aluminium fluoride which need to be imported, the option exists for this material to be imported via Port Elizabeth harbour.
Fresh alumina and coke would be transported by dedicated ships, which carry loose, dry- bulk material. Alumina and coke are unloaded by vacuum onto an enclosed conveyor system. The material would be transported by a conveyer belt to the smelter site for storage in sealed vessels (possibly silos or domes) for alumina, while coke would be stored in an A- frame shed. Initially the alumina would be delivered approximately every three weeks.
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Figure 3: Aerial view of the proposed Aluminium Pechiney smelter within the Coega IDZ
Aluminium fluoride would probably be imported in 1 tonne bulker bags or 25kg layer bags and transported by truck to the site for storage and use.
Liquid pitch would be shipped to the Port of Ngqura in a dedicated, heated ship, stored at the port and, unless a heated pipe is practical, transported by truck from the port to the smelter site.
3.4.2 The potline
The smelting process uses electrical energy to break the bonds between aluminium (Al) and oxygen (O) in the alumina (Al2O3) in order to produce liquid aluminium.
2Al2O3 + 3C → 4Al + 3CO2
This process occurs in large steel containers called reduction pots, which are arranged in long buildings called potrooms. Two potrooms constitute a potline. The potline proposed for the Coega IDZ would consist of 2 elongated potrooms measuring 1200m x 30m. Each room would house a line of 168 pots in two groups of 84 pots, electrically connected. There would be 336 pots in total in the potline.
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Figure 4: Aluminium production process
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Each pot represents one large electrolytic cell. They are lined with carbon blocks and refractory bricks to insulate the pots and contain the heat. This potlining also forms the positive contact (the cathode) for the electric current which is passed through a molten “bath” of sodium aluminium fluoride (cryolite), alumina and aluminium fluoride in the pots. Carbon anodes (made of petroleum coke and pitch) are used to conduct electricity into the pots. The anode block is consumed during the smelting process. The heat generated by passing the electric current through the cell maintains the bath in liquid form at about 950°C.
A steel-reinforced structure supports the overall pot including the anodes, cathode shell, a hooding system and the alumina supply hopper. The supply hopper automatically feeds fluoride enriched alumina from the Gas Treatment Centre into the pots where it is dissolved in the molten cryolite.
Liquid aluminium is tapped periodically from the pots by vacuum suction and transferred to the casthouse and holding furnaces in refractory lined steel crucibles.
Associated with the potline are two Gas Treatment Centres (GTC's) positioned between the potrooms to receive emissions from the pots. In addition to carbon dioxide (CO2), emissions consist primarily of fluoride, sulphur dioxide and dust. The GTC’s are dry scrubbing units, having the primary role of recycling almost all the fluoride and dust captured from the pots.
The dry scrubbing system is not efficient at SO2 abatement. Alumina is used as a scrubbing agent to extract the fluoride from the emissions. The ‘fluorinated alumina’ is then directed into the pots.
3.4.3 The carbon plant and rodding shop
The carbon anodes are gradually consumed during the smelting process. The expected life of an anode is approximately 640 to 770 hours, so they are replaced on a rotating schedule. Due to this high demand for anodes, they would be manufactured on site in a carbon plant by a 3-stage process:
· Paste plant - Green (unbaked) anodes would be produced by crushing petroleum coke and spent anode butts (the remainder of the anode which was not consumed in the potline) then mixing it with liquid pitch to form an anode paste and compacting the paste into anode blocks. · Baking furnace - The anodes are baked at about 1100°C in an oil-fired furnace for several weeks in order to give them mechanical and conductivity properties; and · Rodding shop - Anodes are then attached to electrical conducting rods in the rodding house and transported to the potline.
Associated with the anode-baking furnace is a fume treatment centre (FTC) to extract and recycle fluoride, poly-aromatic hydrocarbon (PAH) containing tar and dust from emissions created by the anode baking process. This is a dry scrubbing unit, also utilising raw alumina
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There is also a pitch fume treatment centre (PFTC) associated with the paste plant. This is a dry scrubbing unit that treats PAH containing tar and dust emissions from the paste plant, using particulate coke as the scrubbing agent. This ‘enriched coke’ is recycled into the paste plant.
3.4.4 The casthouse
Molten aluminium metal is extracted from the pots by a vacuum and siphoned into large ladles. Specific vehicles transport ladles to the casthouse. Metal is siphoned from the ladles into holding furnaces in preparation for casting. Various alloying elements can be added to the metal to attain specific qualities and strengths (for differing customer requirements). The metal is then cast into ingots and bundled for shipping. Aluminium dross or skimmings is a by-product of the casting step due to some re-oxidation of aluminium.
3.4.5 Export of aluminium ingots
The final product of the aluminium smelting process would be in the form of aluminium ingots. The ingots would be stacked and trucked to the port from the smelter, loaded onto ships and exported.
3.5 Associated infrastructure requirements
3.5.1 Electricity supply
The operation of an aluminium smelter within the Coega IDZ would require 860 MW. An EIA has already been conducted for the construction of powerlines for the 120km stretch between Poseidon and Grassridge. Eskom, the power supplier, are in the process of initiating an EIA for the extension of the Grassridge substation and the construction of additional 132 kV powerlines for the final 20km between Grassridge and the Coega IDZ. The proposed extension of the power supply includes three lines for the Pechiney smelter, as well as additional lines for Port Elizabeth and the Coega IDZ.
3.5.2 Port facilities
The decision by Pechiney to conduct more in depth feasibility studies for the construction and operation of the aluminium smelter within the Coega IDZ is based on the expectation that the proposed deepwater port will be developed at Coega. Without these port facilities the project is considered unviable. Environmental authorisation for the construction of the Port of Ngqura has been granted with the provision that the conditions attached to the Record of Decision are met.
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Dedicated port facilities would be established for vacuum unloading of alumina and petroleum coke. Liquid pitch would also be unloaded at a dedicated unloading station and stored at the port prior to transfer to the smelter site. A metal storage site would be established adjacent to the port for interim storage of the aluminium ingots prior to ship loading.
The port facilities required for unloading and storing raw materials and storing and loading the finished products would be constructed in conjunction with the development of the Port of Ngqura.
3.5.3 Transport infrastructure
The development of the IDZ infrastructure includes the construction of additional roads and 6 conveyer belts to transport materials between the port and the IDZ. One of these conveyer belts would be used to transport alumina and coke from the port to the Aluminium Pechiney smelter. The development of this infrastructure is the responsibility of the Coega Development Corporation (CDC).
3.5.4 Water supply
The aluminium smelter would require approximately 600,000 m3/year. An agreement has been reached between the CDC and the Nelson Mandela Metropolitan Municipality (NMMM) for the municipality to supply water to the IDZ.
3.5.5 Housing
A construction village would need to be constructed to house those construction workers who would not be sourced locally. The responsibility for the construction and maintenance of this village is still to be finalised between Aluminium Pechiney and the CDC. The proposed location for the construction village is Well’s Estate.
3.6 Workforce required for the project
3.6.1 Construction workforce
The total number of constructions workers is still to be assessed according to the typical South African standard of construction. The workforce is expected to peak at approximately 6,000 people for a period of 12 months during the construction phase, with the average workforce during construction estimated at 4,500 workers. The workforce would be sourced locally where possible, however, it is likely that some of the semi-skilled workforce would come from outside the immediate vicinity.
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3.6.2 Operation workforce
Operation of the smelter would require approximately 750 full-time, permanent, long-term employees. About 550 of these positions would be occupied by semi-skilled and skilled waged employees, spread over three shifts of 8 hours per day. The minimum educational qualification for semi-skilled positions would be Grade 10 or 11 and skilled positions would require a Matric (Grade 12) certificate or equivalent. There would be about 200 highly skilled technical and management positions. An additional 200 to 300 direct subcontractors would be employed for smelter operations.
3.7 Project schedule
Aluminium Pechiney initiated the feasibility studies and the approvals process in early 2002. The commencement of construction is planned for early 2003 in order for the smelter to become operational in early 2005, as is detailed in the proposed project schedule below (Table 1).
Table 1: Proposed Project Schedule for the PAS 2005 project
Activity Schedule Preferred site confirmed 2002 Environmental Impact Assessment and approvals 2002 Construction 2003 / 2004 First metal Early 2005 Full metal capacity reached End 2005
Construction is anticipated to commence in early 2003 and last for a period of 26 months. The first metal production is planned for early 2005 and the plant is expected to operate at full capacity production 8 months later. The duration of the project from beginning of the construction to operation at full capacity is therefore expected to be 34 months. The life of the project is expected to be 30 to 40 years.
The proposed site is currently uncleared and undeveloped, so initial construction would require the development of a suitable site upon which to build the smelter and an access road to the site. Site and earthworks are scheduled to commence in late 2002. Site preparation is the responsibility of the Coega Development Corporation and associated impacts fell within the scope of the Rezoning EIA.
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4. DESCRIPTION OF THE AFFECTED ENVIRONMENT
4.1 Introduction
This chapter provides the background information about the Coega IDZ area that may help the reader to understand the possible effects of the proposed aluminium smelter on the environment. The affected environment includes the social, economic and biophysical environment that could be affected by, or could affect the development. This information has been sourced from previous EIAs and therefore some of the details may have changed since these were compiled. However, the information is sufficient to provide the overall context within which this EIA is being conducted.
Overall, the environment of the Eastern Cape coastal area is a very diverse and interesting one. Biophysically, it contains a great variety of landscapes, habitats and species that are uncommon in other regions, as well as a largely unspoilt coastline. Socio-economically it is one of the most impoverished regions of South Africa, but may have the highest potential to experience continued improvement in living conditions if the resources of the area are managed sustainably.
4.2 Location
The Coega IDZ lies at the mouth of the Coega River, between the Sundays River (to the east) and the Swartkops River (to the west), approximately 20 km north-east of Port Elizabeth, Eastern Cape province. The IDZ is situated within the Nelson Mandela Metropole, which includes the former Port Elizabeth, Uitenhage and Despatch municipalities.
4.3 The biophysical environment
4.3.1 Climate
The Coega IDZ is situated at the transition between the temperate and subtropical bioclimatic zones. Therefore, it receives rainfall throughout the year, with two peaks in autumn (May to June) and spring (August to September). The highest monthly averages from 1980 to 1996 were from the months of May, June and August (CES 2001). The annual average rainfall is about 400 mm (Coetzee et al. 1996).
The Coega IDZ area experiences topographical or gradient winds for most of the year; these may vary from westerly to west-south-westerly (41% of the time) to easterly (15% of the time). The Coega area is most windy during the day, and any dust carried by the wind would be carried for considerable distances (CSIR 1997). However, during the night the atmosphere is very stable, and this reduces the dispersion of any pollutants in the air. As a result, inversion layers can be created, with pollutants trapped beneath a layer of cooler air.
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4.3.2 Geology
The Eastern Cape coastline has a complex geology, mostly consisting of sedimentary formations such as sandstone, mudstone, limestone, conglomerate and tillite (CEN 1997). A section of the Table Mountain sandstone complex underlies Algoa Bay and its islands (Jahleel, St Croix, Bird and Brenton). The Coega IDZ is underlain by limestone and calcareous sand blown onshore by the wind.
The Swartkops River runs through quartzites of the Table Mountain Group in its upper reaches (beyond the IDZ), and across the Bokkeveld shales closer to the coast. The shales tend to be poorly drained. The lower reaches of the Coega River are composed of marine sediments deposited into a basin underlain by Table Mountain quartzites and Bokkeveld shales.
The ‘Coega Fault’ is a seismically active fault line running from the Groendal Dam and meeting the coast just west of the Coega River mouth.
In the Coega IDZ area, deep red sandy clay soils overlie the limestone substrata. These soils are deeper and better developed than the soils of the Port Elizabeth area. Further east, the soils grade into the deep coastal sands of the Alexandria Dunefield.
4.3.3 Water resources
The catchment of the Coega River covers approximately 550 km2, and is 45 km long and 15 km wide (CSIR 1997). The Coega River runs through a sandy bed 400 to 1000 m wide. The river has been canalised to the north of the salt works.
The Coega Ridge Aquifer underlies the southern part of the IDZ. This aquifer was formed by Table Mountain quartzites and sandstones, and is confined by Cretaceous formations of the Coega basin near the coast. The aquifer is one of the few artesian systems in southern Africa, and the only one in South Africa. Consequently, the artesian system is protected by law under Government Proclamations No. 260 (1957) and No. 958 (1958).
4.3.4 Vegetation
The Eastern Cape is the meeting place of six of the seven biomes of South Africa (Low and Rebelo 1998). Forest, thicket, grassland, fynbos, Nama Karoo and savanna occur, and give rise to a high diversity of vegetation types. This habitat diversity is the basis for the very high conservation and tourism value of the Eastern Cape. The presence of game lodges such as Shamwari and the planned expansion of large conservation areas such as Addo Elephant National Park indicate the potential for conservation to increase in importance in the Eastern Cape.
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Vegetation in the area of the Coega IDZ originally consisted of Mesic Succulent Thicket of the thicket biome (Cowling 1984, Low and Rebelo 1998). The foredunes and hummock dunes would have been backed by dune forest, and this in turn would have been backed by a mosaic of Mesic Succulent Thicket and Bontveld. Bontveld is in itself a finer mosaic of grassland interspersed with clumps of thicket vegetation. Bontveld is restricted to calcrete substrata, where deeper soils occur in depressions, allowing the thicket species to thrive in patches (CES 2001). A significant portion of the thicket has been cleared for farming and mining activities, but the remaining extent of thicket in the Coega area is the largest remaining in the country. CES (2001) identified sensitive portions of the ‘back-of-port’ area, extending from the foredunes to the N2 highway. In that study, the Mesic Succulent Thicket was deemed to be moderately to highly sensitive to development, and Bontveld to be highly sensitive. The Record of Decision for both the Rezoning EIA and the Subsequent Port of Ngqura EIA stipulate that the remaining patches of both the Bontveld vegetation and the Mesic Succulent Thicket must be fenced off and protected from mechanical destruction and infestation with alien vegetation prior to construction.
4.3.5 Fauna
Invertebrates
The fauna of the Coega IDZ area is mainly important for its birds, reptiles and invertebrates. Information on the invertebrate fauna, apart from butterflies, is scarce. One endemic grasshopper and three butterflies of interest have been recorded for the Coega area. The grasshopper, Acrotylos hirtus, is endemic to the dunefields of Algoa Bay. Three Lycaenid butterflies (coppers and blues) have been identified as rare or have very restricted distributions in the Coega area. These are Aloeides clarki (a small copper), Lepidochrysops bacchus (a small blue) and Peocilimitis pyroeis (a small copper).
Vertebrates
Amphibians It is not known how many amphibian (frog) species occur in the Coega area, but the Eastern Cape has a diverse amphibian fauna, including 34 taxa (species and subspecies – CSIR 1997). Generally, frogs are useful bio-indicator species, as their reliance on both aquatic and terrestrial habitats at different stages of their life cycle, their need for damp habitats, and their permeable skin makes them vulnerable to pollutants and other anthropogenic effluents.
Reptiles The reptile fauna of the Coega area is particularly diverse, containing 56 species of lizards, chameleons, snakes, tortoises and sea turtles. Of these, 22 species are either Red Data or CITES listed or are endemic to the area or peripheral to the usual range of the species (CES 2001). These include eight lizards, two monitors, one gecko, one chameleon, three snakes, three tortoises and the four globally endangered sea turtle species. The most restricted
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Birds Among the avifauna, coastal birds figure prominently (see below), although the thicket vegetation is home to a diversity of species. Among the large terrestrial birds, blue cranes (Anthropoides paradiseus), Stanley’s bustard (Neotis denhami), martial eagle (Polematus bellicosus) and the African marsh harrier (Circus ranivorus), secretary bird (Sagittarius serpentarius) and Knysna woodpecker (Campethera notata) are listed as Red Data species (Barnes 2000). However, none of these are known to breed in the Coega area.
Mammals Only two mammal species are endemic to the Coega area: Duthie’s golden mole (Chlorotalpa duthiae) and the pygmy hairy-footed gerbil (Gerbillurus paeba exilis), which occur in dune thicket (CES 2001). Both of these species are protected in terms of the conditions attached to the Rezoning EIA and the Subsequent Port of Ngqura EIA. The remaining 13 Red Data listed mammal species are widespread species, not restricted to the Coega area.
4.3.6 The marine ecosystem
A marine reserve has been proposed as part of the Greater Addo Elephant National Park Conservation Project. The proposed reserve would stretch from the eastern bank of the Coega River mouth (25º42’ East) to just east of Cape Padrone (26º30’ East); the seaward boundary is formed by latitude 33º52’ South. This area incorporates the St Croix island group near Coega (CSIR/IECM/Albany Museum 2002).
The coastal birds and seabirds of Algoa Bay rely on the scattered special habitats provided by estuaries and river mouths, rocky shores, dunefields, reefs and the offshore islands of Bird and St Croix. The islands support globally significant populations of Cape gannets (Morus capensis), African penguins (Spheniscus demersus) and Roseate terns (Sterna dougallii); and have been identified as an important bird area (Barnes 2000).
Anaulis australis is a very important marine diatom that forms the foundation of the food chain in Algoa Bay. Anaulis australis may be dependent on the freshwater inflow from aquifers (CSIR/IECM/Albany Museum 2002), and thus could be affected by groundwater availability and quality.
Marine turtles have global distributions and travel long distances between feeding and breeding grounds. The beaches of the Eastern Cape are extremely important nesting habitats, as are the northern KwaZulu-Natal beaches around St Lucia and Cape Vidal. Turtles feed on jellyfish, including bluebottles, squid, fish, crabs and other bottom-dwelling crustaceans, shrimps, prawns, and clams, corals and urchins; juveniles feed on sargasso
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Ten species of marine mammals can be seen in Algoa Bay. Southern right whales use the shallow waters of Algoa Bay to give birth and nurse their young, and 200 to 400 humpback dolphins (about 30 % of SA’s population) have the core of their habitat in Algoa Bay (Wooldridge et al., 1997). Dense concentrations of dolphins are located east of the Sundays River, using the surf zone as a feeding ground. The most easterly breeding colony of Cape Fur Seals Arctocephalus pusillus is located at Black Rocks in the Bird Island group (Wooldridge et al., 1997).
The fish fauna of Algoa Bay is typical of the eastern Agulhus Bank and is made up of South African endemics and wide-ranging species (Wooldridge et al., 1997). Levels of endemism are relatively high, with 34% of species being endemic to South Africa. The rocky reef areas around the islands of Coega, Jahleel and St. Croix are home to a host of fish species, and are also part of the nurseries of some sea breams and rock cods. Subtidal fishes of the surf zone hold key positions in the food web of Algoa Bay and are also important angling species. Algoa Bay is an important part of the nursery of juvenile fish including Kob and Elf (CSIR 1997).
4.4 Socio-economic environment
The population of the Nelson Mandela Metropole is about 1.2 million people, nearly 80 % of whom live in Port Elizabeth and the remainder in the Uitenhage area. This makes the Metropole South Africa’s fifth largest city. Settlements in close proximity to the IDZ include Colchester, Cannonville, Motherwell, Ibhayi and Amsterdamhoek. An initial assessment for the proposed Port of Ngqura port indicated that the population of Motherwell, the closest residential area to the Coega IDZ, may be growing at up to 4.5% per year (CES 2001).
4.4.1 Employment and human development
The unemployment rate in the Nelson Mandela Metropole is estimated at around 40%. This is exacerbated in the urban areas, where 50% to 60% of adults are unemployed. The human development index (HDI) for the Eastern Cape is the second lowest in the country, at 0.51. This is split very unevenly between the white community (0.94) and the black community (0.32) (CES 2001).
4.4.2 In-migration
The search for employment is a major factor driving migratory movements in South Africa. In the Eastern Cape, there is a growing trend of people moving towards the cities from farms and communal areas. This is largely based on the perception that better employment
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4.4.3 Infrastructure and services
Generally speaking, services are inadequate in the former township areas of the Eastern Cape. Particularly in the Motherwell area, access to schools, health and recreational facilities is scarce. A similar situation exists in many rural districts, and this situation almost definitely contributes to the steady migration of people to the cities in search of better living conditions.
Water Water from the Orange River is supplied through a transfer tunnel to the Fish River, and thence to the metropolitan area. However, the IDZ area lies over the Coega Ridge Aquifer, which supplies both industrial and household water needs in the area.
Energy supply Paraffin is the most common multi-use energy source for households in the Coega area. Other fuels are used for specific tasks, such as heating (wood), lighting (candles) and cooking (wood). Electricity is also used by those who have access to it.
Transport Most public transport is supplied by taxis, private vehicles and a bus service. Although there is a railway line entering the area, this does not seem to be used much for public transport.
Health care facilities The metropolitan area of Port Elizabeth has seven public and three private hospitals, and 21 clinics.
Recreation facilities Recreational angling from boats and from the shore is an important pastime of local communities. The reefs between St. Croix and Brenton and between St. Croix and Jahleel are regularly fished by private skiboat owners. Good catches of Kob and Reds are made just offshore east of Coega by private and commercial line fishermen (CSIR 1997).
4.5 Economic activities
The economy of the Eastern Cape has traditionally been reliant on heavy industry such as the motor industry, however, increasingly tourism as well as small, medium and micro enterprise (SMME) developments contribute to the economic base of the Nelson Mandela Metropole. In the Coega area, however, other activities also play a large part in people’s livelihoods:
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· 14% of the household heads in the Coega area, and 26% of the total workforce resident in the area are employed at the Markman industrial area;
· The Marine Growers Abalone Farm employs 30 – 60 people, and is producing in the region of 50 tonnes of abalone per year for export to the Far East, and supplying brood stock to other local abalone farms (Common Ground 2001);
· Commercial chokka fishermen have recently begun to exploit spawning concentrations of Liligo vulgaris east of St. Croix (Wooldridge et al., 1997). Good catches of Kob and Reds are made just offshore east of Coega by private and commercial line fisherman;
· The Coega salt works currently employ about 100-150 people;
· Commercial farming in the Coega area is focused on Angora goats (mohair), boer goats and dairy production;
· In a financial analysis, Kerley et al. (1995) clearly showed that ecotourism/ conservation in valley thicket (including mesic succulent thicket), is sustainable, can generate more income than a comparable pastoral operation, and is generally profitable.
· The proposed expansion of the Addo National Park has the potential to increase the contribution of the tourism sector to the region’s economy.
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5. DESCRIPTION OF THE ENVIRONMENTAL ASSESSMENT PROCESS
The EIA for Aluminium Pechiney’s proposed aluminium smelter within the Coega IDZ is being conducted in accordance with the EIA Guidelines issued by the Department of Environmental Affairs and Tourism (April 1998). This EIA is being prepared in close consultation with authorities and other stakeholders and has been structured to meet the regulatory requirements (Figure 5). Furthermore, the EIA will be prepared in accordance with international best practice, to meet the EIA process requirements of organisations such as the International Finance Corporation (IFC).
The EIA process incorporates three overlapping, interactive processes, namely a technical process, a process with the lead agents and authorities, and a public participation process.
The technical process includes development of an understanding of the technical issues involved in the project, development of terms of reference (ToRs) for specialist studies, undertaking the specialist studies and integration of the specialist findings into an Environmental Impact Report (EIR). This process involves discussion and information sharing between the CSIR EIA team, the specialists, Aluminium Pechiney, the Coega Development Corporation and the National Ports Authority. The latter two organizations are involved in this process due to the fact that both would provide infrastructure and services to Aluminium Pechiney, are responsible for management of compliance with ROD conditions for the IDZ and Port under which Aluminium Pechiney will be required to operate, and would be involved in the management of impacts associated with the project if this proceeds.
The Eastern Cape provincial Department of Economic Affairs, Environment & Tourism (DEAE&T) has been given the responsibility for issuing the decision on whether or not to authorise Aluminium Pechiney’s application to construct and operate an aluminium smelter within the Coega IDZ. Over the course of the EIA the CSIR will engage with DEAE&T and other relevant authorities (including the national Department of Environmental Affairs and Tourism) in order to ensure that issues and concerns raised by the authorities can be integrated and addressed at an early stage of the EIA process and to contribute towards the authorities’ understanding of potential environmental impacts and mitigatory measures.
The public participation process is being run by Sandy & Mazizi Consulting and is conducted concurrently with the technical and lead agent / authority processes.
As reflected in the Figure 5 a key component of the EIA is to ensure that stakeholder’s knowledge and concerns inform the environmental assessment. The EIA follows a step-by- step process, in consultation with stakeholders and specialists, to identify key issues and concerns related to the proposed development and to thoroughly investigate these. In this way it is possible to maximise the potential benefits of the proposed project for stakeholders as well as for Aluminium Pechiney; to mitigate the potentially negative impacts; and to identify any potential fatal flaws that may render the project environmentally unacceptable.
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Development Proposal (with alternatives)
Submit application to relevant authority
Consultations with key stakeholders
Plan of Study forScoping LEGEND Review of Plan by: Amend Plan Authorities Activities
Accept Plan Reports of Study Decisions Technical Scoping – Initiate Specialist Studies
Normal flow Public Scoping Process – Finalise Specialist Terms of References Possible iteration
ScopingReport Possible flow Report reviewed by: Amend Report Authorities, Specialists & I&APs
Accept Report
Consider application
Identify Key Issues and Alternatives which need further investigation
Plan of Study for EIA
Review of Plan by: Amend Plan Authorities
Accept Plan of Study
Complete Specialist Studies
EIA Report
Report reviewed by: Amend Report Authorities, Specialists & I&APs
Accept Report
Conditions Not Approved Consider application Approved of Approval Environmental Management Plan Appeal Monitoring System
Record of Decision Undertake development
Figure 5: EIA process flow diagram (based on South African EIA Regulations)
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5.1 Roles and responsibilities of roleplayers in the EIA process
In order to conduct an effective, efficient and equitable EIA process it is important to clarify the responsibilities of the various roleplayers.
Aluminium Pechiney (Applicant):
· Appoint suitable, independent consultants · Ensure adequate resources are available to conduct an effective, efficient & equitable EIA · Ensure that consultants are provided with all relevant information to conduct the EIA effectively · Ensure that consultant provides all relevant information to authorities
CSIR (Consultant):
· Be independent with no vested interest · Have the necessary qualifications and experience · Responsible for EIA process, info and reports · Provide relevant & objective info to authorities, the I&APs and the applicant · Ensure Public Participation is undertaken - Sandy & Mazizi Consulting cc · Ensure all environmental issues raised, and which fall within the scope of the EIA, are addressed or responded to
The CDC, NPA, Authorities (other than DEAE&T) and I&APS:
· Provide input and comment during various stages of the process · Identify environmental issues and concerns · Identify reasonable alternatives · Review of reports : o Draft Scoping Report (DSR) o Draft Environmental Impact Report (DEIR) · Provide input and comment within specific timeframes
Relevant Environmental Authority (Provincial DEAE&T):
· Efficient and expedient in evaluating proposals · Compliance with regulatory requirements · Inter-departmental co-operation and consultation · Consultation with applicant and consultant · Evaluation/review and decision-making · Requiring sufficient detail to make informed decisions
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5.2 The focus of the EIA
Primary aluminium smelting comprises one stage of the aluminium life cycle. This life cycle starts with the mining of bauxite. Bauxite is refined to produce alumina, which is the raw material used in primary aluminium smelting. The final product of the smelting process (the aluminium ingots) are processed further prior to being used in the production of manufactured goods. At the end of the manufactured product’s life, the scrap can be collected and recycled by a secondary smelting process. Secondary smelting process consumes up to 95% less energy than that required for the primary smelting process and aluminium can be repeatedly recycled without its quality being impaired.
A range of environmental impacts are associated with different stages of the life cycle. Although impacts associated with different stages may be highly significant, it is beyond the scope of this EIA to conduct an environmental assessment of the full aluminium life cycle. The focus of the EIA is therefore confined to the construction and operation of a primary aluminium smelter within the metallurgical cluster in the Coega IDZ (Figure 6).
Aluminium Pechiney EIA
Figure 6: Identifying the focus of the Aluminium Pechiney EIA with respect to the aluminium lifecycle
Aluminium life cycle assessment The International Aluminium Institute is undertaking a study to understand the positive and negative impacts of aluminium during the entire life cycle of the material and covering the main applications of aluminium. Reports of the use of aluminium in automobiles and in construction have been completed and can be found on the International Aluminium Institute’s website: http://www.world-aluminium.org Source: International Aluminium Institute (2002)
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The EIA does not include an assessment of occupational health and safety risks for employees working within the smelter. For example, the EIA will assess the impact of noise of the smelter on the surrounding area (measured from the boundary of the site) but not on employees working within the smelter. However, it must be pointed out that Aluminium Pechiney undertake, as a minimum, to meet the requirements of South African labour legislation, for example, the Occupation Health and Safety Act.
An assessment of the impacts associated with the potential future expansion of the smelter (to include a second potline) is beyond the scope of this EIA. If, at some stage in the future, a second potline is proposed, then this will require a separate EIA in accordance with national legislation.
Similarly, the assessment cannot consider the cumulative effects associated with other industries locating within the Coega IDZ in future and contributing to waste streams, emissions levels, traffic increases, noise levels or socio-economic impacts etc. There is currently no information available upon which to base such an assessment. The cumulative impacts can only be assessed when definite proposals for other projects are being considered. However, the specialist studies conducted for the Aluminium Pechiney EIA do take cognisance of the current situation and the existing stresses that may already exist. As such, the EIA does include the cumulative impacts on the current environment by taking cognisance of, for example, the current ambient air quality, current socio-economic characteristics of the area (e.g. poverty and unemployment levels) and the current capacity and status of existing waste disposal sites.
5.3 Consideration of alternatives
The identification of alternatives aims to provide a basis for the DEAE&T to make an informed decision based on the options available. Furthermore, the environmental impact assessment process also aims to identify those alternatives that, if the project is authorized and does proceed, would minimize potential negative impacts and enhance the positive aspects.
The alternatives presented in this EIA fall into two categories – those associated with the “No Go” alternative, and those associated with the “Go” alternative. Each of these two categories include a number of secondary level alternatives, which are outlined below and will be considered in the EIA.
Consideration of the “No Go” Alternative
1. Future development options for the region: The EIA will attempt to identify the potential opportunity losses/gains for the Eastern Cape, based on the premise that Aluminium Pechiney is not granted authorization for establishing an aluminium smelter within the Coega IDZ.
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Consideration of the “Go” alternative
1. Process and technology alternatives Based on the use of AP50 technology, specialist studies will consider alternatives which may be feasible and which could be incorporated into the proposal, taking into account the specific design constraints of the aluminium smelting process and technology used. These may include, for example, alternative noise mitigation measures, alternative emission reduction options and alternative material handling procedures.
2. Alternative associated infrastructure A detailed assessment of the impacts of associated infrastructure required by the project during construction and operation is beyond the scope of this EIA. These impacts will be, or are currently being, assessed in separate EIA processes. However, the Aluminium Pechiney EIA will include a set of principles to be taken into account in, for example, the design of the water supply and stormwater management system, transport infrastructure, and the construction village.
3. Alternative waste management options Alternatives for the management of different waste streams (solid, liquid and gaseous) will be considered, including the potential for minimization, reuse or recycling of waste. Alternative waste disposal options will be considered.
4. Alternative benefit enhancement mechanisms
The EIA will identify possible options that may improve the potential for the project to deliver on economic growth in the Eastern Cape region and South Africa and improve social equity in the distribution of these benefits, without compromising the ecological integrity of the surrounding area.
The following alternatives will not be considered further within this EIA process:
1. Alternative locations for development outside the Coega IDZ: Alternative sites were assessed by Aluminium Pechiney prior to the selection of the Coega IDZ as one of three sites at which to conduct further indepth studies (refer to section 3.2). Currently detailed engineering, planning and environmental studies are underway in Australia to assess the feasibility of this as an alternative to locating within the Coega IDZ.
2. Alternative locations for development within the Coega IDZ: Previous environmental assessment studies identified areas within the IDZ which would be best suited for particular types of industrial development, taking into account
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the geotechnical and biological characteristics of different areas. The current IDZ layout therefore includes a metallurgical cluster, automotive cluster, electronic and technical cluster, as well as “no go” areas for development.
3. Alternative site layouts: The proposed siting and layout of the smelter within the metallurgical cluster of the IDZ has been optimized for a range of aspects such as general site geotechnical conditions, proximity of proposed IDZ and Port infrastructures and their relationship with smelter material flows, and compatibility with IDZ “no go” areas.
4. Demand alternatives: The increasing demand for primary aluminium metal is a motivating factor for the Aluminium Pechiney project proposal. The option of meeting this demand through other means, such as aluminium recycling and secondary smelting, will not be assessed in this EIA. Secondary smelting is not an option that Aluminium Pechiney is considering as a feasible alternative for their proposed project and for meeting the projected demand growth. A secondary smelting project would therefore need to be proposed by another proponent, and evaluated on the basis of that particular proposal.
5. Alternative aluminium smelting technology: Existing aluminium smelters make use of older technology such as AP 18 and AP 30. While these are feasible technology alternatives, Aluminium Pechiney has selected to use the new generation AP 50 technology due to the significant capital and operating cost advantages that this presents.
6. Alternative economic sector development opportunities: These alternatives were taken into account in previous environmental assessments for the Coega IDZ. The EIA is based on the premise that industrial development within the IDZ can, if properly managed, coexist with the existing agricultural and tourism sectors in the region.
5.4 The Scoping phase
The EIA has now entered the Scoping phase which aims to identify key issues for more detailed assessment and to focus the EIA. The Scoping process has been designed to incorporate two complementary components: a technical process involving the environmental consultants, the technical specialists and Aluminium Pechiney; and a public participation process which includes I&APs and the relevant authorities.
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5.4.1 Objectives of the Scoping phase
The objectives of the Scoping Phase of an EIA are to: · identify the key issues of concern that should be addressed in the EIA Specialist Studies; · design the required work to understand and evaluate these key issues, and to address shortcomings in existing information; · define the scope of the project and the studies to be done in a way which would result in a thorough and scientifically defensible Environmental Impact Report (EIR) and, if the project proceeds at the end of the EIA, to ensure that the proposed development will be executed in an environmentally sound manner.
Sub-objectives of Scoping, which are directed at laying the foundation for the EIA, are as follows: · identify and inform a broad range of stakeholders about the proposed development, to empower them with sufficient information to be able to identify environmental issues and concerns for further investigation in the EIA process, and to provide ample opportunity to all parties to exchange information, and express their views and concerns; · obtain the buy-in of the stakeholders for the EIA process per se, so that they will accept the ultimate findings of the EIA; · understand and fully document the environmental issues underlying the concerns and questions raised by stakeholders to focus the study on reasonable alternatives and key issues.
5.4.2 Key components of Scoping
As mentioned above, the Scoping phase includes both public participation as well as a technical process. These are described in more detail below.
Public Participation Public participation in the Scoping Phase of the EIA is a vehicle to provide sufficient and accessible information to I&APs in an objective manner to assist I&APs identify environmental issues of concern, identify alternatives, and suggest opportunities to reduce potentially negative or enhance potentially positive impacts. Arising from the above, it is clear that public involvement is not a public relations exercise or part of a development proponents corporate social responsibility/community neighbour relations programmes. The primary function of public involvement is to provide a process of improved decision making whereby I&APs, technical specialists, the authorities and the development proponent work together to produce better decisions than if they had worked independently.
At the outset it is important to highlight two key aspects of public participation:
· There are practical and financial limitations to the involvement of all individuals within a public participation programme (PPP). Hence, public participation aims to
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reflect the environmental issues and concerns that are representative of societal sectors, not only that of individuals. The PPP has therefore been designed to be inclusive of the broadest possible range of sectors. · The PPP aims to raise a diversity of perspectives and is not designed to force consensus amongst I&APs. Indeed, diversity of opinion rather than consensus, is likely to enrich ultimate decision making. Therefore, where possible, the public involvement process aims to create awareness amongst all stakeholders (I&APs, the authorities, technical specialists and the development proponent) of the trade offs with regard to economic growth, social equity and ecological sustainability.
As public involvement is an integral part of Integrated Environmental Management (IEM), IEM principles apply. The Department of Environmental Affairs and Tourism (DEAT) has listed those most relevant to public involvement as follows:
· Meaningful and timeous participation of I&APs. · Focus on important issues. · Due consideration of alternatives. · Accountability for information used for decision-making. · Inclusivity (the needs, interests and values of I&APs must be considered in the decision-making process). · Encouragement of co-regulation, shared responsibility and a sense of ownership. · Dispute resolution.
To the above, one can add universally recognised public participation principles: · Inclusive consultation that enables all sectors of society to participate in the consultation and assessment processes. · Information is easily accessible (physically, in a language that I&APs can understand and non-technical) and sufficient to enable meaningful participation. · Grassroots people are actively empowered and capacitated to understand concepts and information with a view to active and meaningful participation. · Information accessibility is achieved by the use of a variety of dissemination vehicles, for example, by way of discussion documents, meetings, workshops, focus group discussions, and the printed and broadcast media. · Information is accurate and I&APs are afforded sufficient time to study material, to exchange information, and to make contributions at various stages during the assessment process. · I&APs are afforded the opportunity to input via a range of methods, for example, during briefing sessions, during public meetings or at public open days, written submissions and direct contact with members of the EIA Team.
The public involvement process is being undertaken in English and Xhosa, with selected documents, summaries and advertisements translated into Xhosa. I&APs were welcomed to use the language of their choice during meetings, with translations into Afrikaans, Xhosa or English being undertaken by the public participation team.
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The following outlines the key information documents used during the Scoping Process:
· Briefing Paper - All I&APs on the database (1184) were mailed a copy of the Briefing Paper which was translated in English and Xhosa. The purpose of this document was to introduce the project to I&APs and outline the EIA process and public participation process. It also provided the contact details and mechanisms available for I&APs to engage in the public participation process and raise their issues of concern. · Question & Answer Book - The Question and Answer Book was distributed to all I&APs on the database (1184). The purpose of this document has been to provide a broader understanding of the aluminium production process to develop the capacity of I&APs to raise environmental issues of concern for consideration in the EIA. · Summary of Draft Scoping Report - All I&APs on the database were provided with a copy of this document to provide them with an overview of the key environmental issues that had been raised at the time of release of the Draft Scoping Report. · Letters of notification - I&APs on the database were notified in writing of the availability of documents for public comment, time frames for comment and dates of public meetings held. · Public Meeting Presentation - The project proposal and the Draft Scoping Report were presented via a powerpoint presentation at all public meetings.
The public involvement consultants are keeping meticulous records of public involvement activities, comments received and responses to comments. Furthermore, proceedings of meetings are recorded, all of which enable the compilation of a comprehensive I&AP issues trail.
Technical process A set of specialist studies considered necessary for this EIA has been identified. This was considered reasonable on the basis of Pechiney’s world-wide aluminum industry experience, CSIR’s experience in undertaking EIAs for aluminium smelters in southern Africa, baseline information provided by existing studies for the Coega IDZ, and the CSIR’s experience from the Strategic Environmental Assessment for the Coega IDZ. The specialist studies have been initiated in parallel with the public Scoping process. This enables the specialists to analyse baseline information and set-up model studies that will assist the EIA team in understanding the key issues raised during the public Scoping phase. The findings of the Scoping process with the public and the authorities will inform the specialist studies, which will only be completed after the public Scoping process is finalised.
The specialist studies identified at the outset of the EIA are listed in the table below, together with the specialist(s) for each study. Several of the specialists have direct experience in undertaking technical studies for aluminium smelters.
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Table 2: Specialist studies
Specialist study Specialist(s) and their affiliation 1) Air quality Dr Mark Zunkel, CSIR This will also include : Yvonne Hong, CSIR Impacts of emissions on human health Riëtha Oosthuizen, CSIR Impacts of emissions on plants/agriculture Dr Amanda Botha, private consultant 2) Water resources and liquid waste Grant Mackintosh, CSIR management Philip de Souza, CSIR 3) Materials handling and solid waste Sanjeev Raghubir, CSIR management Auntony Mukhwanazi, CSIR Dr Sibbele Hietkamp, CSIR 4) Water discharges to the marine environment Stephen Luger, CSIR Dr Pedro Monteiro, CSIR Roy van Ballegooyen, CSIR Susan Taljaard, CSIR 5) Socio-economics Johan van der Walt, ACER Africa Xolisa Ngwadla, ACER Africa Dr Dieter Heinsohn, ACER Africa 6) Traffic and transportation Theuns Lamprecht, CSIR 7) Macro-economics Prof James Blignaut, University of Pretoria Prof NJ Schoeman, University of Pretoria 8) Noise Klaus Weber, Vibracoust 9) Visual impacts Bernie Oberholzer, Bernard Oberholzer Landscape Architects Quinton Lawson, Meirelles Lawson Architects
5.4.3 Steps in the Scoping phase
Scoping will be driven by public participation as well as technical inputs from the EIA team and the proponent. The eleven key steps in the Scoping process are described below and shown in Figure 7.
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CDC, NPA, PROPONENT: CONSULTANTS: AUTHORITIES & LEAD AUTHORITY Aluminium Pechiney CSIR, Sandy &Mazizi OTHER INTERESTED (DEAE&T*) Consulting AND AFFECTED PARTIES (I&APs)
Provide background § Pre-application § Attend pre-application information (project consultation consultation 1 description and site § Submit application & Plan § Review & accept Plan of screening) of Study for Scoping Study for Scoping
I&AP identification & Initial consultations with authorities and interest groups 2 registration
Project announcement § Adverts Register for process & 3 Review draft documents § Briefing paper review documents § Website
Consultation with I&APs Comment on EIA process 4 Attend public meeting § Focus groups and identify issues to be § Public meeting addressed in EIA
5 Compile Issues Trail
Prepare & distribute Draft Provide technical inputs Scoping Report 6 & review draft report Comment & review § Specialist inputs
Comments period Attend public meetings / 7 open days § Public meetings Attend meetings & comment on Draft Scoping Report § Open houses § Stakeholder capacity building sessions
8 Updated Issues Trail
9 Provide technical inputs Prepare & distribute Final Review & consideration of & review draft document Scoping Report application
Approved Not approved Accepted (issues Meeting with authorities, require further Attend authority meeting (with or without 10 CDC & NPA conditions) investigation)
EIA
Finalise Terms of Record of Decision 11 Reference for Specialist Studies
* Dept of Economic Affairs, Environment & Tourism
Figure 7: Detailed Scoping process showing key roles and interactions between the proponent, the consultant, the authorities, the CDC, NPA and I&APs.
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Step 1 Pre-application consultation and submit Plan of Study for Scoping
A pre-application consultation was held with Mr Leon Els and Mr Andries Struwig of the Department of Economic Affairs, Environment and Tourism (DEAE&T) on 7 March 2002, where it was established that DEAE&T is the relevant authority for this EIA process. This informed the preparation and submission of the Plan of Study for Scoping.
Step 2 I&AP identification, registration and the creation of an electronic database
The identification and registration of I&APs has been based on the existing Coega database which included 1184 I&APs at the start of the project. Identification and registration of I&APs will be ongoing for the duration of the study. Stakeholders from a variety of sectors, geographical locations (local, provincial, national, international) and/or interest groups have expressed an interest in the development proposal and been consulted as part of the public participation process, for example:
· National, Provincial and Local Government. · Coega Development Corporation and National Ports Authority of South Africa · Local interest groups, for example, rate payers associations and health groups · Agriculture (formal and informal) · Citrus Industry · Surrounding Land Owners · Industry and mining · Commerce · Tourism · Labour · Environment · Grassroots communities · Non Government and Community Based Organisations.
Although the list of potential I&APs appears inexhaustive, the establishment of an electronic database and the customization of existing information to suit the needs of this project assists in conducting the Public Participation Programme (PPP). As of the 1 July 2002, 1416 I&APs are registered on the database for the proposed Pechiney Aluminium Smelter project at Coega. Stakeholders for this EIA have been identified through the following mechanisms:
· The existing database for previous EIA's conducted for the Coega project · Responses to advertisements placed in print media (Appendix A) · Attendance at the Public Open Day, networking and focus group meetings · The proactive identification of I&APs based on the experience of the Specialist Consultants
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An additional mechanism to identify stakeholders is to ask other stakeholders during the course of networking to identify omissions from the existing database. I&APs on this database have received all project documentation (whether they request it or not); have been personally invited to attend public meetings and public open days as well as being notified of the availability of reports for their comment and input. Communication and capacity building with I&APs will be an ongoing activity for the duration of the EIA process. The main stakeholder groups included in the database are listed in Appendix B.
Step 3 Project announcement
The development proposal and associated environmental assessment process has been widely announced, with an invitation to the general public to register as I&APs and to actively participate in the PPP. This has been achieved via the following:
· A letter of invitation to all 1184 I&APs captured on the database at the outset of the EIA (Appendix C) · Print media advertisements in local and regional newspapers, requesting I&APs to register their interest in the EIA and attend an initial Public Meeting: o Die Burger o East Cape Weekender o The Herald · The dissemination of a Briefing Paper (with letters of invitation, to key stakeholders and also to I&APs who register as a result of advertising) covering: o A simplified rationale for and description of the development proposal. o A description of the environmental assessment process, including public involvement and, importantly, milestones where stakeholder input is critical. o An invitation to I&APs to participate, especially to attend public open days. · Provision of information on the website for the Aluminium Pechiney EIA, which is hosted by the CSIR (http://smelter.csir.co.za) · A “Question and Answer Booklet” to facilitate communication and understanding on the proposed project was distributed to all I&APs on the database.
Step 4 Consultation with I&APs (including authorities)
A number of consultation meetings have been held with authorities1 and key stakeholders. The purpose of these meetings is to provide I&APs with background information on the project, EIA and Public Participation Process in order for them to identify environmental issues and concerns for investigation in the EIA.
1 The involvement of the authorities is not in a decision making capacity. Rather, the authorities will be invited to participate and contribute issues/provide guidance in relation to Scoping and the EIA.
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The following types of meetings were held to facilitate input into the release of the Draft Scoping Report, namely, a public meeting, networking meetings and telephonic consultations.
A public meeting was held on 24 April 2002 at the Port Elizabeth City Hall, where I&APs had the opportunity to find out more about the EIA process and the proposed project, as well as to raise issues and concerns. Aluminium Pechiney’s technical manager and environmental manager for the PAS 2005 Smelter project were present at this meeting as well as representatives from the CSIR.
Networking meetings will form an ongoing activity for the duration of the project. They are generally one-on-one meetings between the Public Participation Consultant and a specific group, organisation and/or individual e.g. Wildlife and Environment Society, a Ward Committee and its structures, or affected Land Owners. Telephonic consultations were also held with key I&APs to obtain their initial inputs into the process.
Meetings will be arranged by the CSIR (as the independent consultant) with the authorities at local, regional and national level throughout the environmental assessment process, particularly when milestones are reached. It should be noted that all public involvement documents will also reach the authorities in their capacity as I&APs.
Step 5 Compile issues trail
Based on the initial process of networking and consultation, the public participation consultant compiled a draft issues trail that included all relevant comments provided at public meetings (Appendix D), networking meetings and telephonic consultation (Appendix E) or submitted via fax, email or telephone prior to the release of the Draft Scoping Report. The issues trail has been updated regularly during the Scoping phase.
Step 6 Prepare and distribute Draft Scoping Report
The Draft Scoping Report was then prepared based on environmental issues identified through both the specialist’s input and the public participation process. The CSIR obtained inputs from the EIA specialist team when evaluating and responding to issues raised through the public Scoping process. These technical inputs are important to understanding the nature and scope of issues to be addressed either through the Scoping Report or in the EIA.
The Draft Scoping Report was made available to the public through the following mechanisms:
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· A summary of the Draft Scoping Report and the Question and Answer Book for the PAS2005 EIA was mailed to all I&APs on the database; · A presentation on the Draft Scoping Report was made at a series of Public Meetings on 3, 4 and 5 June 2002 in the Nelson Mandela Metropolitan area; · The Draft Scoping Report was presented as a poster display at the public Open Day on 4 June 2002 in Port Elizabeth; · The Draft Scoping Report was mailed or hand delivered to key authorities and stakeholders; · Copies of the Draft Scoping Report were placed at public libraries in the Port Elizabeth-Despatch-Uitenhage area and the University of Cape Town; and · The Draft Scoping Report was placed on the EIA website hosted by the CSIR (http://smelter.csir.co.za).
I&APs and the general public were notified of the availability of the Draft Scoping Report as follows: · By written correspondence extending an invitation to all I&APs on the database to attend the Open Day and/or Public Meeting. · Advertisements placed in the following local and regional newspapers notifying I&APs of the availability of the Draft Report, Open Day and Public Meetings, namely o Die Burger o The Herald o East Cape Weekender.
I&APs will continue to be updated at various stages of the EIA process and be notified of timeframes and opportunities for participation and input.
Step 7 Obtaining comments on the Draft Scoping Report
A 21-day comment period was provided for the Draft Scoping Report. A number of opportunities have been provided for I&APs to interact around the Draft Scoping Report, namely, Open Day, Public Meetings, networking and focus group meetings. The primary purpose of these interactions was to discuss the report and obtain detailed comments from the general public and identify additional environmental issues and concerns for inclusion in the Final Scoping Report. These interactions are summarized below:
· Open Day - A public Open Day, to which all I&APs on the database were invited, was held on the 4 June 2002 at the PE City Hall. At this event the Draft Scoping Report was presented in the form of a poster display and I&APs were invited to interact with representatives of the CSIR and Aluminium Pechiney who were present to engage with I&APs around the document. A total of 41 I&APs are registered as having attended this meeting.
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· Public Meetings - The following Public Meetings, to which all I&APs on the database were invited, were held:
Date Venue Attendance 3 June 2002 Centenary Hall, New Brighton 206 4 June 2002 Raymond Mhlaba Sports Centre, Motherwell 64 5 June 2002 Valentine Hall, Addo 2 5 June 2002 Babs Madlakane Hall, Uitenhage 334
At the public meetings a presentation on the Draft Scoping Report and the proposed project was given to those present. Representatives of the CSIR and Aluminium Pechiney were present to engage with I&APs and respond to issues raised. Appendix D contains notes from the Public Meetings. Environmental issues raised by I&APs at these meetings have been included in the issues trail of this Final Scoping Report (chapter 6). In addition, all public meetings have been audio-recorded.
· Networking Meetings - These one-on-one meetings between the Public Participation Consultant and key groups, organisations and individuals are discussed in Step 4 above. They form an important component of the public participation process in developing the capacity of I&APs to participate in the process and the identification of environmental issues and concerns for consideration by the specialist consultants. Appendix E includes notes from these meetings.
· Focus Group Meetings - Three focus group meetings were held during the Scoping Phase of the EIA process. Focus group meetings are sector-based meetings as opposed to one-on-one meetings with an individual or a specific organisation. The purpose of these meetings is to develop the capacity of a specific sector to facilitate their input into and understanding of the EIA process. Sector meetings were held as follows:
Sector Participants Invited Attendance Environmental Environmental groups, authorities, academic 5 Sector institutions, and SANParks Labour Labour unions within Cosatu 148 Civil Society South African National Civics Organisation 74 (SANCO), alliance structures, ward representatives, community based organisations, NGOs, and Political Parties
At these meetings a detailed presentation was given on the Draft Scoping Report and I&APs were provided the opportunity to raise issues and concerns. Appendix F contains the notes from these meetings. The meeting with the environmental
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sector entailed a site visit to the Coega IDZ. As previous participation processes for the Coega project have entailed a site visit for the Civil Society and labour sectors, this was not done at this stage of the process.
Step 8 Updated Issues Trail
The Issues Trail contained in Chapter 6 has been updated by the Public Participation consultant, based on the feedback received during the Scoping process. Copies of written comments received via email, fax or mail are contained in Appendix H of this report.
Step 9 Final Scoping Report
The Final Scoping Report has been prepared based on the comments received on the Draft Scoping Report and is submitted to the authorities for review and authorization by DEAE&T. Although not intended for further public comment, the Final Scoping Report will be placed in public libraries, hosted on the EIA website and submitted to key stakeholders. All I&APs on the database will be informed via written correspondence of the availability of the report.
Step 10 Authority review of Final Scoping Report
The Final Scoping Report is submitted to DEAE&T and other authorities for review and decision-making. The report will also be presented to the DEAE&T and other authorities who are involved in the decision-making process.
Step 11 Finalise Terms of Reference for specialist studies
Once the key issues requiring further investigation have been identified and all comments from I&AP’s and the authorities received, the EIA team will review whether any additional issues need to be added to the specialist’s Terms of Reference, or whether any additional specialist studies are required. The finalized list of specialist studies and Terms of Reference will be compiled into the Plan of Study for the EIA.
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6. ENVIRONMENTAL ISSUES ASSOCIATED WITH THE CONSTRUCTION AND OPERATION OF AN ALUMINIUM SMELTER
6.1 Identification of key environmental issues
An important element of the Scoping exercise is to evaluate the issues that were raised during the public participation and technical processes and ensure that those that are identified as key issues are included within the scope of the assessment.
To assist in the identification of key issues the following criteria were used: 1. Whether or not the issue raised falls within the scope and responsibility of the Aluminium Pechiney EIA process? 2. Whether or not the issue raised has associated implications for environmental permit and licence applications? 3. Whether or not sufficient information is available to respond to the issues or concern raised without further specialist investigation.
The decision-making process is illustrated by Figure 8.
Several important principles are applied to the identification of key issues and the subsequent environmental impact assessment. These include:
· Maximum use of existing information. · Adoption of an impacts-driven approach. For example, as opposed to focussing volumes of sulphur dioxide emitted into the atmosphere, the assessment should focus on the impacts of changes in air quality such as adverse health effects. . An impacts-driven approach is an important element in ensuring that issues are properly scoped in the EIA process.
The following section (the “Issues Trail”) includes all environmental issues raised through the Scoping process. The reader is referred to Appendix H which includes all submissions received from various stakeholders to get a full overview of the extent and breadth of issues raised.
It should be noted that the objective of public participation in the EIA process is to work with stakeholder to identify key issues and concerns which require further assessment. It is not the objective of either process to capture and reflect public opinion connected with a particular proposal. Comments which were received through the Scoping process which were made either in support of, or opposition to, the Aluminium Pechiney proposal have therefore not been included.
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Does the issue fall within the scope of the EIA & Aluminium Pechiney responsibility?
YES NO
Environmental permit/ Issue not considered licence implications further in this EIA
Closure at Scoping Phase YES NO
Issue can be addressed Insufficient information Key Issue without further specialist to address issue investigation required
Response provided Specialist Study Key Issue in Final Scoping Report
Specialist Study Closure in EIA Closure at Scoping Phase Closure in EIA
Figure 8: Decision-making framework for identification of key issues for the Aluminium Pechiney EIA.
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6.2 Issues and responses
The purpose of this section is to reflect the environmental issues associated with the proposed project which were raised through the Scoping process and to identify those which are considered key issues requiring more detailed assessment. For each section a summary of the environmental issues identified through the technical scoping process is provided, followed by a summary of the environmental issues raised by I&APs and authorities through the various consultations and inputs to the Scoping phase.
Details of what will be considered by the specialists are reflected in the terms of reference provided in Section 7. The reader is reminded that the results of the specialist studies (listed in section 5.4.2) will be available to the I&APs through the Draft Environmental Impact Report.
6.2.1 Air quality (including effects on human health, plants and agriculture) issues
In the aluminum smelter, air emissions include: · alumina dust from handling facilities; · coke dust from coke handling;
· gaseous and particulate fluorides; sulphur dioxide (SO2); carbon dioxide (CO2); perfluorocarbons (CF4 and C2F6) and various dusts from the electrolytic reduction cells;
· gaseous and particulate fluorides; sulphur dioxide (SO2); tar vapor and carbon particulates from the baking furnace; · coke dust, tars, and polycyclic aromatic hydrocarbons (PAHs) from the green carbon and anode-forming plant; · carbon dust from the rodding room; and · fluxing emissions and carbon oxides from smelting, anode production, casting, and finishing.
The atmospheric emissions that have been identified as key concerns in previous EIAs of aluminium smelters in southern Africa are fluorides and sulphur dioxide (SO2).
Fluorides Gaseous fluorides evaporate from the molten electrolytic liquid in the form of hydrogen fluoride, which is a colourless, pungent liquid or gas that is highly soluble in organic solvents and in water. In nature, fluorides occur throughout the environment, but at very low levels that are not believed to be harmful to humans and may even be beneficial. Fluorides are released into the environment naturally through the weathering and dissolution of minerals, in emissions from volcanoes and in marine aerosols (tiny droplets of seawater picked up from the sea surface by wind). Anthropogenic sources of fluoride include industrial processes and manufacturing, use of fluoride-containing pesticides, as well as the controlled fluorination of drinking-water supplies. Virtually all foodstuffs contain at least trace amounts of fluorides.
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Fish and tea are particularly high in fluoride. Long-term exposure to high levels of fluoride may result in detrimental effects on human health, for example, effects on teeth and bones. However, fluorides and hydrogen fluoride have not been classified for carcinogenic effects. High dosage of fluorides on plants can result in the discolouration of the leaves and a reduction in plant production. Fluorides can work their way through the foodchain, for example from the atmosphere, to plants, to herbivores.
Sulphur dioxide Sulphur dioxide would be released from the petroleum coke and fuel oil used in the reduction process and in the anode baking furnace. Sulphur dioxide is a colourless, acrid gas formed by the burning of sulphur or sulphur-containing substances such as coal, coke and oil. It combines with water vapour or dust particles in the atmosphere to form rain droplets, which may result in acid rain. Rain is normally slightly acidic (pH 5.0-5.6) but the term “acid rain” is used when acidity reaches levels as high as pH 3. Acid rain has negative effects on vegetation and buildings. Sulphur is a micronutrient for plants but as soon as its concentrations reach beyond tolerance levels, it becomes toxic and dangerous to most living things. Sulphur dioxide can aggravate the state of health of people with existing health conditions, such as asthma, bronchitis, emphysema and other respiratory complaints. In extreme conditions, it can cause severe respiratory distress and result in heart failure. The acidic nature of the gas has an irritant effect at lower concentrations that can cause infections of the respiratory tract and general discomfort, mainly of the nose and throat.
Carbon dioxide Carbon dioxide gases are generated during the electrolysis process as the carbon in the anode reacts with oxygen in the molten electrolytic liquid, and from the combustion of fuels. Carbon dioxide is a greenhouse gas, which means that it absorbs the re-radiated long-wave radiation from the earth, thus resulting in the warming of the atmosphere.
Perfluorocarbons Primary aluminium production has also been identified as an anthropogenic source of emissions of two perfluorocarbon compounds (PFCs), tetrafluoromethane (CF4) and hexafluoromethane (C2F6). These compounds are generated during brief upset conditions, and are potent global warming gases when compared to carbon dioxide. They have long atmospheric lifetimes and up to 9200 times the equivalent greenhouse gas warming potential of carbon dioxide (International Aluminium Institute 2001).
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ISSUE RESPONSE 1.1 Scope of the Study 1.1.1 The air quality study needs to assess The air quality specialist study will assess the air the following: carbons, fluorides, impact emissions from the smelter against the air quality on the citrus industry, impact on guidelines proposed for the IDZ. These guidelines surrounding vegetation, impact on are based on international standards and are residential areas of Motherwell, designed not only to protect human health and Bluewater Bay, Addo, Despatch and welfare, but also the natural and built Uitenhage, impact on farm animals environment. In addition, the EIR will include (goat skins and hides). specialist inputs on potential impacts of air emissions on human health, natural vegetation and agriculture. 1.2 Air emissions 1.2.1 What kind of emissions will be produced The main types of emissions are summarised in and in what quantities? the introduction above, and will be described further in the specialist studies. The quantities of emissions will be confirmed by a mass-balance calculation done as part of the materials handling and solid waste management specialist study. These results will be incorporated into the air quality specialist study. 1.2.2 Will there be any visible plumes during An assessment of potential upset conditions will abnormal or non-standard operating be provided in the air quality specialist study. This conditions? will include an assessment of any visible plumes arising from such conditions. 1.2.3 The EIA needs to assess the emission These emissions will be taken into account in the levels that will not be recyclable and that air quality and the materials handling and waste will pass into the atmosphere. The management specialist study. impact of these residual emissions needs to be assessed in the specialist studies and in the EIA. 1.2.4 Primary aluminium production is a source of polycyclic aromatic hydrocarbons (PAH’s), which are termed Persistent Organic Pollutants (POP). The emissions of PAH from aluminium production are derived from the use of carbon anodes in the electrolysis process. PAHs exhibit all the characteristic POP properties: persistence, bio-accumulation, adverse effects and potential for long-range environmental transportation. Many of the PAHs are carcinogenic, and they also exhibit negative reproductive effects, as well as immune system inhibiting properties, genotoxicity and mutagenecity (Edlund 2001). The EIA should address the potential for the smelter emitting significant concentrations of PAHs. The EIA should further examine how PAH emissions can be reduced, or eliminated. 1.2.5 Are there any specialist studies which Experience from other modern smelters indicates will be dealing with the impacts there will be no significant odour impacts from the
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ISSUE RESPONSE associated with the smell associated Aluminium Pechiney smelter. This is discussed in with the development? One of the the air quality specialist study. emissions has been noted as sulphur dioxide. This is a pungent gas and may affect the surroundings in other ways apart from acid rain? 1.2.6 What will be the impact of emissions on Under normal operating conditions, no visible the Addo National Park expansion plumes would occur. The potential for visible project, especially with regards to visible plumes to occur during upset conditions will be plumes? assessed in the air quality specialist study. 1.2.7 The assessment should include This will be included in the air quality specialist emission dispersion maps (to gauge the study. extent and concentration of emissions over the landscape) and rate of deposition into the environment. 1.2.8 The air pollution impact assessment Emission figures have been provided by Pechiney needs to provide reliable and accurate and verified against recommended emission emission figures. standards. Reliable and accurate figures are required for permit applications as well. The air quality specialist study makes recommendations for routine emissions monitoring to verify emission values. 1.2.9 The specialist study or EIA needs to This information will be provided in the air quality identify how much the Pechiney Plant specialist study. will be contributing to the overall IDZ air quality limits. 1.3 Impact of Fallout on Fauna and Flora 1.3.1 The impact of emissions on fauna and The EIR will provide information on the potential flora within and beyond the limits of the impacts of emissions on flora and fauna, using IDZ need to be determined, assessed available research results. A specialist botanical and monitored. study has been commissioned to assess impacts of emissions on flora. Monitoring requirements will be recommended. 1.3.2 The rate and level of dispersion, as well The air quality specialist study will provide the rate as fallout out, need to be provided, as and level of dispersion and atmospheric fall-out. does the rate of decay or assimilation of This information will be used by the water fallout by the natural environment. The resource and liquid waste management specialist latter two issues have not been to assess impacts on water resources. The identified in the terms of reference for assessment adopts a worst-case scenario the air quality study. approach in assuming that no decay or assimilation of pollutants has taken place subsequent to emission and fallout. 1.3.3 With respect to the previous point, The EIR will include a specialist botanical input on specific attention needs to be paid to the the impact of air emissions on flora. impact of fallout on the 'green areas' identified within the IDZ. These areas have been identified due to their importance in the ecosystem. 1.3.4 The impact of atmospheric fallout on the The EIR will include a specialist botanical input on citrus industry needs to be assessed. It the impact of air emissions on flora. In particular, needs to be ensured the development this will identify potential impacts on the citrus does not have a negative impact on the industry. Sundays River Valley Citrus Industry.
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ISSUE RESPONSE 1.4 Health Impacts 1.4.1 What will be the impacts on the health of A human health risk component is included as people as a result of emissions, part of the air quality specialist study. especially in areas close to the smelter site, such as Motherwell? 1.4.2 In terms of international best practice, As far as international best practice is concerned, how far does a smelter have to be from there is no restriction on the distance between residential areas? residential areas and an aluminium smelter. The key criterion is to confirm that the smelter meets the air quality standards for human health. The assessment of potential impacts on human health (in the air quality specialist study) will take into account the distance from the smelter to the nearest residential areas. 1.4.3 The health risk assessment needs to At this stage it is not possible for the health risk assess cumulative impacts. assessment (being done as part of the Aluminium Pechiney EIA) to assess cumulative impacts from other industries in the IDZ, as no other industries are located within the IDZ.
The approach adopted by the CDC for managing cumulative effects of air emissions in the IDZ is to set limits for air quality for the entire IDZ. A recommended set of air quality limits was developed based on national and international standards. CDC has followed a precautionary approach and adopted 50% of these limits as the initial guidelines for the IDZ. CDC will move to the South African standards or guidelines as and when these match those of the World Health Organisation. The CDC already has three operational monitoring stations and good baseline data on current levels of air pollution. 1.4.4 If there are negative health impacts on The Air Quality study for this EIA will include a communities, who will be responsible for Health Risk Assessment that will predict if there dealing with this (eg. providing treatment are any significant human health risks/impacts or possibly compensation)? resulting from the smelter. Existing air quality is being monitored by CDC, which has 3 air quality monitoring stations in the Coega area. During operation, CDC will monitor all tenant’s emissions and check to ensure that they do not exceed the permits received from the authorities. Aluminium Pechiney will meet health requirements as stipulated in standard set for operational permits. Any claims would need to be dealt with according to South African law. 1.4.5 Where will the Motherwell residents go if The air quality specialist study will assess the this project impacted negatively on their potential impacts on human health, if any, health? including surrounding areas such as Motherwell. Relevant international (eg. World Bank) and national health standards will be used. Environmental management of the IDZ aims to ensure that surrounding communities are not
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ISSUE RESPONSE negatively affected and would not, therefore, need to be moved. 1.5 Global Impacts 1.5.1 The EIA should address measures that The emission of greenhouse gases by the smelter may be implemented to reduce, or will be investigated and assessed in the air quality eliminate, emissions of PFCs. specialist study, with comparisons provided 1.5.2 The release of large amounts of against national and international air quality greenhouse gases need to be taken into standards/guidelines. Measures will be consideration in greater detail. recommended for minimising emissions of 1.5.3 Will the levels of greenhouse gases greenhouse gases. emitted conform to national standards?
1.6 Monitoring Emissions 1.6.1 A clear statement must be made about Monitoring recommendations will be included in how Pechiney are going to monitor the air quality specialist study. emission and guarantee that emissions meet design specifications, not just after commissioning but 10 to 15 years down the line. 1.6.2 Pechiney must state how they are going The air quality specialist study will identify the to measure emissions from the plant, main sources of emissions (e.g. potline, carbon not only the pot lines, but specifically the plant, casthouse) and provide recommendations electrode (carbon) plant. So far it has for monitoring. This is to include PAH emissions. been stated that organic compounds (PAHs) are emitted from the electrode plant. Some of these may be carcinogenic and must be monitored. 1.6.3 Monitoring equipment must be sourced Permit requirements and the Environmental from local agents so that availability of Management System will establish guidelines for the equipment and its maintenance is the performance of monitoring equipment, enhanced. independent of where it is sourced. The final monitoring schedule will be addressed during the permitting process. 1.6.4 Ambient air quality standards for SA The air quality standards proposed for the IDZ need to be established and enforced. (refer to comment 1.7.1) are more stringent than Institutional capacity to monitor and the current South African guidelines. CDC will be enforce standards needs to be responsible for monitoring of ambient air quality developed. and enforcement of standards. CDC has indicated that a pollution levy will be applied to industries within the IDZ that will cover the costs of monitoring. 1.7 Air Quality Guidelines 1.7.1 What are the total allowable air quality A set of air quality guidelines for the IDZ were limits for the IDZ and do they take into recommended in the SEA (CSIR, 1997). These account WHO limits? guidelines take into account the international and national trends in air quality management and the current air quality of the IDZ area. They are stringent and based on international guidelines/standards from the USA, European Union, WHO and South Africa; and are considered to be conservative. CDC has followed a further precautionary approach and adopted 50% of these limits as the initial guidelines for the IDZ.
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ISSUE RESPONSE 1.8 Cumulative Impacts 1.8.1 There is a need to look at the The approach adopted for managing cumulative cumulative effects of air emissions in the effects of air emissions in the IDZ is to set limits entire IDZ so that one can foresee what for air quality for the entire IDZ. A recommended will be coming. set of air quality limits was developed based on national and international standards. CDC has followed a precautionary approach and adopted 50% of these limits as the initial guidelines for the IDZ. CDC will move to the South African standards or guidelines as and when these match those of the World Health Organisation. The CDC already has three operational monitoring stations and good baseline data on current levels of air pollution. 1.9 Other air quality issues 1.9.1 Incentives for compliance and non- In line with Principle 4p of the National compliance need to be established. Environmental Management Act (NEMA), CDC intends to implement the “polluter pays principle” which will establish incentives for minimising solid, liquid and gaseous waste generation. 1.9.2 Is there any air pollution data available Apart from the information provided in the Air from other aluminium smelters and will Quality and Materials Handling and Waste this data be made available for public Management Specialist Studies, which makes scrutiny? reference to emissions from other smelters, it is not within the scope of the EIA to evaluate emissions from other smelters. It must also be pointed out that when comparing data from other smelters it is important to understand their different smelting technologies, receiving environments and industrial contexts. Regarding availability of information, the specialist studies will be made available for public scrutiny. 1.9.3 Will the information from the Coega Air The 2001 Report of the ambient air quality Pollution Monitoring Stations be made monitoring is available to the public and can be available to the public? requested from the CDC. 1.9.4 Will the plant have chimneys as none Yes, the smelter would have stacks (chimneys). appear in visualisation diagrams There would be two stacks for the Gas Treatment presented? Centres (GTC), one for the Fume Treatment Centre (FTC) and five stacks for the casthouse (refer to section 3.4). 1.9.5 If there is a reduction in the air quality in The air quality specialist study will show the Bluewater Bay, this project will drive effects, if any, of emissions from the smelter on people away from this area? air quality in the surrounding area, including Bluewater Bay. Environmental management of the IDZ aims to ensure that surrounding communities are not negatively affected and would not, therefore, need to be moved.
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6.2.2 Water resource and liquid waste management issues
Water resources The water usage for the plant is approximately 600,000 m3/year, which includes both industrial and domestic water requirements. Key issues related to water utilization are the availability of water and the optimization of on-site water recycling.
Liquid waste management The three main liquid discharges from the site are sewage, process wastewater and stormwater. A key issue related to water discharges from the smelter site is the risk of pollutants exceeding the receiving water quality objectives of surface and groundwater and the possible impact on the marine environment. This risk arises mainly from the discharge of stormwater offsite, in particular, after the “first flush” rainfall event (i.e. first rain run-off after a dry period) as this contains a higher concentration of potential pollutants which have accumulated during the dry period. For example, the atmospheric deposition of fluoride over an extended dry period may result in elevated levels of fluoride in the stormwater.
During construction, stormwater pollution may mainly occur as a result of erosion from construction areas leading to increased turbidity in the stormwater and downstream sedimentation. Once the site is operational, erosion, should be minimal and the management of spills and general contamination more important in order to reduce pollution levels in the stormwater.
ISSUE RESPONSE 2.1 Water Utilisation and Services 2.1.1 Will the plant require potable or recycled The plant will initially be supplied with potable water? water.
2.1.2 What will be the quantities of water The aluminium smelter would require used? Does the Metro have the approximately 600,000 m3/year of water. The required capacity to meet the demands Metro has sufficient capacity to meet the water of the plant? demands of Aluminium Pechiney. Further details will be provided in the water resource and liquid waste management specialist study. 2.1.3 Where will the NMMM be getting the Water will be supplied to the CDC (and the water from to supply the site and how smelter) from the Nooitgedacht Water will this impact on the water availability Treatment Works that originates from Gariep for the rest of the Port Elizabeth Dam on the Orange River. The works has a metropole? capacity of 70 Megalitres (Ml) per day. The current output is an average of 42 Ml per day. The water resource and liquid waste management specialist study will address this issue in more detail. 2.1.4 How much water does the entire At present the Metro consumes 75 000 metropole use and will the increased Megalitres of water per year. The water requirements result in an increase in the consumed by the smelter will have no impact general rates within the metropole? on rates and negligible impact on the water tariff.
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ISSUE RESPONSE 2.1.5 How will this water be delivered to the A large diameter pipeline has been installed to site. Such associated developments, in Coegakop and a delivery pipeline installed from terms of pipeline infrastructure etc. Coegakop to the edge of the Coega IDZ and should also be assessed at this stage. N2 road. A 2 Ml break pressure tank has been constructed on Coegakop. When the demand requires it, a 17 Ml capacity storage reservoir will be constructed. Water is therefore ready to be supplied to the smelter or any other development. It is beyond the scope of this EIA to assess the impacts associated with the construction of the reservoir. 2.2 Water Quality & Monitoring 2.2.1 How will the potential impacts on the Groundwater monitoring has been initiated by Coega Aquifer be monitored to restrict CDC prior to construction activities in the IDZ, contamination? to provide baseline data. Further monitoring recommendations for the Aluminium Pechiney proposal will be provided in the water resource and liquid waste management specialist study. 2.2.2 Will there be water pollution and will this The water resource and liquid waste impact on under ground water? management specialist study will identify and investigate the potential sources of water pollution from the smelter, and assess the potential impacts on groundwater. 2.2.3 Will the EIA be assessing the rate at The water resource and liquid waste which atmospheric fallout will enter the management specialist study, will assess the groundwater and what levels of significance of potential impacts on groundwater contamination could result? groundwater and, where necessary, provide recommendations for further research and monitoring.
6.2.3 Materials handling and solid waste management issues
Materials handling The handling of raw materials has the potential to cause dust impacts or pollution from spillage (refer to section 3.4.1 describing the import and storage of raw materials).
Waste management Solid wastes produced by the aluminium smelter include spent potlinings, miscellaneous industrial waste (wood, metals, etc), laboratory wastes and domestic waste. Waste minimization, re-use, recycling and disposal is a key issue.
A particular environmental concern is the disposal of the spent potlinings. Potlinings consist of the refractory bricks that are used to insulate the steel shell of the pot (to contain the heat and prevent damage to the steel shell) and the carbon blocks that form the cathode. The potlinings have a useful life of about 5 to 6 years, after which they have to be disposed off. Spent potlinings are impregnated with aluminium and silicon oxides, fluorides, sodium and cyanide compounds. Specific care must be taken during handling, storage, disposal or recycling. Potential opportunities exist for spent potlinings to be recycled by the cement industry through being added to raw materials to manufacture cement.
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ISSUE RESPONSE 3.1 Materials Handling 3.1.1 Suction unloading can create dust and Management of dust generation and spillages will material losses at transfer points and be addressed in the materials handling and waste spillages on belts. How will losses and management specialist study. spillages be dealt with? 3.1.2 Will the impacts of spillage of imported Impacts of potential spillage of raw materials at raw materials be assessed? the Port of Ngqura and during transport from the port to the smelter will be investigated in the materials handling and waste management specialist study. 3.1.3 The storage site for aluminium and the Aluminium Pechiney will lease port facilities from pitch tanks requires substantial removal National Port Authority (NPA). NPA are of a portion of the sloping hillside. Does responsible for the environmental assessment of this have a material effect on the impacts associated with constructing the sensitive area? necessary storage areas and facilities. The loss and fragmentation of sensitive habitats is addressed in Section 5.2.2 of the Subsequent EIR for the Port of Ngqura (CES, 2001). 3.1.4 All potentially significant risks associated This will be addressed by the materials handling with the operation and materials handling and waste management specialist study. must be assessed. 3.1.5 What precautions are provided to ensure safe working of the liquid pitch operation? 3.1.6 Are raw materials completely enclosed or stored in containers or warehouses? 3.2 Waste Generation and Disposal 3.2.1 How much waste will be generated by The materials handling and solid waste the development and how will it be management specialist study will identify the disposed of? different types and volumes of waste produced. A 3.2.2 A breakdown of the waste is required, key focus of this study will be to identify additional indicating what is recyclable, what is opportunities for waste minimisation and hazardous, and how much waste is recycling. Appropriate means of disposing of produced for each ton of aluminium to be waste, in accordance with national regulations, produced. will be proposed. Calculations of the mass of waste produced per tonne of product will be provided. 3.2.3 Incineration in cement kilns, as a method The materials handling and waste management of disposing some of the smelter’s waste, specialist study will provide a comprehensive in particular, spent potlinings, is review of options for waste minimisation, re-use, considered to be an inefficient, recycling and, where necessary, disposal. destructive and dirty method of waste disposal. The EIA should exploreproactive means of waste disposal including greater recycling of waste. 3.2.4 The use of the CSIRO’s (Australia) new It is assumed that the comment refers to the technology for treatment of spent AUSMELT process developed in Australia. The potlinings should be compared to potential of this disposal option will be considered disposal via a cement kiln. in the materials handling and solid waste management specialist study. 3.2.5 The disposal of hazardous waste is of The need for an H:H waste site to accommodate concern as the region is currently without hazardous waste from the smelter, current site an operational class H:H landfill. The re- availability and future plans for a new H:H site will
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ISSUE RESPONSE commissioning of the Aloes II site is not be discussed in the materials handling and waste definite, and is a short-term solution to management specialist study. the problem. It is undesirable that the current transportation of hazardous waste to Cape Town by road continues. It is important that the new hazardous waste site is operational before the aluminium smelter becomes operational. 3.2.6 How will the development impact on the The CDC is being consulted as part of the Integrated Waste Management Plan development of the NMMM’s Integrated Waste being developed by the Metro? Management Plan. 3.2.7 Should waste not be disposed of on site, The materials handling and solid waste and off-site site disposal is required, this management specialist will characterise the waste needs to be included in the EIA streams and identify the class of waste site assessment. required for disposal of solid waste. Waste is to be disposed of at appropriately designated and licensed waste disposal sites. The water resources and liquid waste management specialist study will assess the impacts associated with the discharge of liquid waste. 3.2.8 Should the development require The need for different classes of waste disposal dedicated waste disposal sites then sites, local availability and future planning for the impact assessments for these waste disposal sites for the NMMM will be sites needs to be assessed together discussed in the materials handling and waste with the current development as they management specialist study. are inextricably linked. 3.2.9 Cyanide must be encapsulated and The safe treatment of wastes containing cyanide stored in a toxic waste site. compounds of cyanide will be addressed in the materials handling and solid waste management specialist study.
6.2.4 Issues related to water discharges to the marine environment
Stormwater from the smelter site would ultimately reach the marine environment. Key issues related to the effect of discharges on the marine environment are the rate of dispersal of pollutants, sedimentation, accumulation of toxic compounds in sediments in close proximity to the discharge points, and risks of pollutants reaching sensitive receptors (such as mariculture activities).
ISSUE RESPONSE 4.1 Marine Discharges 4.1.1 What will be the impact on the marine This will be assessed in the specialist study on environment from water discharges? water discharges to the marine environment. 4.1.2 Discharges to the marine environment The specialist study on water discharges to the would negatively impact on the abalone marine environment will include modelling farm, Marine Growers. This potential stormwater discharges and dispersion of potential impact, with regards to stormwater run- off pollutants, modelling the fate of pollutants and and discharges to the marine environment, identifying potential risks to other marine users, needs to be assessed. including the Marine Growers abalone farm and
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ISSUE RESPONSE 4.1.3 Discharges to the marine environment need marine life forms. to model dispersion in the water column; impacts on marine life forms need to be anticipated, particularly the breeding birds on the nearby islands. 4.1.4 An issue of concern for the marine This issue will be addressed in the specialist discharge is the bioaccumulation of toxic study on water discharges to the marine materials. environment which includes guidelines for sediment quality and recommendations for monitoring. 4.1.5 The discharge of effluents to the marine This will be covered in the specialist study on environment needs to be assessed and water discharges to the marine environment. compared with national and international standards. It should further include mitigation measures and recommendations to minimise impacts. 4.1.6 The Coega Development Corporation has The provision of infrastructure (such as sewage stated that they will utilise the spare treatment services) is a shared responsibility capacity of the Fish Water Flats sewage between the Metro and the CDC. Initially the treatment works for the discharge of CDC’s effluents will be sent to the Fish Water sewage. Fish Water Flats discharges to the Flats treatment works which has the spare marine environment. Will the impact of this capacity to treat this effluent. Later, as CDC’s additional capacity on the marine volumes increase a new treatment works will be environment be assessed? built within the CDC. The impacts associated with sewage treatment were identified in the Rezoning EIA (CES, 2000). An EIA will be required for the new CDC treatment works.
With regard to the Aluminium Pechiney EIA, the volumes of sewage which would be produced by the smelter will be quantified in the materials handling and solid waste management specialist study.
6.2.5 Socio-economic issues
Socio-economic considerations take into account the implications of the project on people’s livelihoods and quality of life. The employment opportunities created during construction and operation would have a range of implications for the local community. The perception of increased job opportunities could lead to in-migration of people to the Port Elizabeth area with attendant social problems, for example, a lack of housing or unaffordable housing settlements, leading to the development of squatter settlements, increased spread of diseases, and increased pressure on social services (especially welfare services such as clinics). On the other hand, the project creates opportunities for sustainable job creation and local skills development, for example, through training programmes and the promotion of side- and downstream industries, both large-scale as well as Small, Medium and Micro Enterprises (SMMEs).
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ISSUE RESPONSE 5.1 Social Impacts 5.1.1 What will be the social impacts The socio-economic specialist study will assess both associated with the project positive and negative social impacts of the project. 5.1.2 The benefits of this project for the This comment has been noted. The socio-economic Motherwell community should be specialist study will include recommendations for how maximised. benefits of the project could be maximised. 5.2 Employment Process 5.2.1 How will the recruitment process The CDC is currently compiling a register of jobseekers. work and who will be responsible A comprehensive strategy for recruitment and placement it? of personnel within the zone is being developed by the 5.2.2 The employment process needs to CDC to manage the requirements and expectations of ensure that the citizens of the Metro both investors and job-seekers. These policies will be maximise the employment benefits based on agreements with organised labour, and will created by this development. take account of existing South African labour legislation Preference should be given for as well as industry-specific agreements. The CDC will employment to local people before facilitate and provide a service for itself and investors but national and international skills are it will not actually recruit labour for any third parties. All sourced. contractors will hire their own labour, within the 5.2.3 How accessible will the recruitment guidelines given by the CDC. process be, especially to the unemployed in the Metro? The socio-economic specialist study will describe the recruitment process and consider the accessibility of the recruitment process to disadvantaged communities. 5.2.4 The use of employment agencies is This comment is noted and brought to the attention of not supported as employment the CDC. agencies and labour brokers charge a percentage on salaries or wages. People must derive the full benefits from this development. 5.3 Employment Equity 5.3.1 It does not appear that enough The recruitment process for the Aluminium Pechiney effort is made to involve the so- smelter has not yet started, as a decision has not yet called Coloured people in been made whether or not the project will proceed. If the recruitment. go-ahead is given for the project, recruitment will be jointly managed by the CDC and Aluminium Pechiney. 5.3.2 There should be equitable A comprehensive strategy for recruitment and placement distribution of job opportunities of personnel within the zone is being developed by the across areas and colour lines. The CDC to manage the requirements and expectations of project will need to ensure that it both investors and job-seekers. These policies will be reflects local demographics in its based on agreements with organised labour, and will employment. take account of existing South African labour legislation 5.3.3 How will Uitenhage benefit from the as well as industry-specific agreements. project and how would you ensure that not only Motherwell residents There is no general restriction on the employment of benefited from job opportunities. woman in an aluminium smelter. The smelter would 5.3.4 Will the project employ woman, and employ all ages of people eligible, legally, to work. The what will be the targets for gender project would strictly comply with national and equity? international regulations with regards to child labour. 5.3.5 The employment of historically disadvantaged individuals is supported. 5.3.6 What will be the age limit for employment? There is a concern about the number of multinational companies that have been caught practicing child labour in the country.
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ISSUE RESPONSE 5.3.7 A number of organisations in the disadvantaged community have emphasised that the following sectors should not be excluded from the employment process, woman, the youth, disabled and the elderly. They should be provided the opportunity to be trained and gain employment. 5.4 Training 5.4.1 Should the jobs be high-tech in The socio-economic specialist study will describe the nature, what training opportunities training plan which is being developed by the CDC in will there be for local historically conjunction with the Department of Labour and local disadvantaged individuals and does training institutions and boards. Pechiney have a programme geared towards empowerment and Specific training programme would be implemented by training of historically Aluminium Pechiney for all categories of employee to disadvantaged individuals? meet both the technical and managerial skills required.
5.4.2 Are there enough training facilities The CDC is currently establishing exactly which skills in the Metro to meet the technical are required for the various investments (including the training expertise requirements of proposed aluminium smelter), and determining the the development? How will the available skills base in the Eastern Cape. A training plan shortage of skills in the region be is being developed by CDC, in conjunction with the addressed? Department of Labour and local training institutions and 5.4.3 When training is provided it should boards, in order to ensure the right skills are available to reflect a bias towards institutions investors in the zone and port. that have been historically disadvantaged. 5.4.4 Training should target the disadvantaged community. The Department of labour and CDC need to develop a training plan based on the skills required for the development. 5.4.5 There is a need to educate taxi The CDC is responsible for coordinating the overall drivers on the government's transport services for the IDZ. This comment will recapitalisation programme for therefore be brought to the attention of the CDC. them to enhance their opportunities at Coega. 5.4.6 There is a need to train emerging CDC is responsible for compiling a register of eligible contractors on the employment service providers for the IDZ, including emerging process. contractors. This comment will therefore be brought to the attention of the CDC.
5.4.7 Planning is required to ensure that This comment has been noted. the Metro is ready and that it benefits from the project and from the expansion of the skills base. 5.5 Potential for SMME Development 5.5.1 Efforts should be made to involve These comments have been noted. Opportunities for SMME's in the project, as this will supporting SMMEs will be assessed in the socio- bolster the local economy. To what economic specialist study and recommendations extent is this planned for in the provided. project?
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ISSUE RESPONSE 5.5.2 SMMEs need to be empowered SMMEs have the opportunity to register as service and be made aware of providers with the CDC. opportunities. They are often not aware of the opportunities that are there to assist them. 5.5.3 Motherwell Community Development Forum has small businesses affiliated to it; these have to be looked after. 5.5.4 Will there be an opportunity of truck The socio-economic specialist study will describe and bakkie (small pickup vehicle) opportunities for promotion of SMMEs as a result of the owners to offer their services to smelter project, including outsourcing of transport Pechiney? services.
5.6 Social Investment Programme 5.6.1 Aluminium Pechiney's social This comment has been noted. Aluminium Pechiney is investment programme will have to committed to developing a corporate social be needs driven and responsive. It responsibility/ investment programme. Aluminium will have to be visible and one that Pechiney’s social responsibility programme would cover the recipients of the programme matters such as: partnerships in education programmes; can relate to. Its primary objectives SMME development; community foundation projects; should be to eradicate poverty and charitable health & welfare projects; & biodiversity address unemployment. conservation. 5.6.2 Aluminium Pechiney should have a Aluminium Pechiney is committed to developing a social responsibility to promote corporate social responsibility/investment programme recycling, particularly of aluminium, linked to the smelter project. The level of community in the Nelson Mandela Metropolitan support for promotion of recycling aluminium products Municipality if the proposal were can be assessed in development of this programme. approved. However, it must be noted that aluminium recycling is a completely different business from primary smelting, with few synergies between these activities. 5.7 Impact on Tourism 5.7.1 The Motherwell community has a The socio-economic specialist study will assess the lot of tourism potential and there potential impacts of the project on the tourism potential are a number of projects that are of the Motherwell community. being planned for this area, will this project not impact negatively on these initiatives? 5.8 In-migration 5.8.1 In-migration to the Metro is The issue of in-migration related to the establishment of expected. What plans are there in the Coega IDZ was assessed in the Coega Rezoning place to manage this? EIA. In so far as it relates to Aluminium Pechiney, the issue of in-migration will be assessed in the socio- economic specialist study. 5.9 Construction Village 5.9.1 Will there be a construction village As far as possible local labour will be used. A at Coega or will workers have to construction village for the Aluminium Pechiney smelter commute? How will the project is, however, planned for Well’s Estate to house construction village impact on that component of the workforce that cannot be sourced Motherwell and Wells Estate? Will locally. More detail on issues related to the construction people at the construction village village will be supplied in the socio-economic specialist be allowed visitors? study.
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6.2.6 Traffic and transportation issues
The smelter would be operating 24 hours per day and 365 days per year. Consequently, frequent trucking of finished product (ingots) and some trucking of raw materials (pitch and aluminium fluoride) would take place between the smelter and the port. Other transport- related issues during both construction and operation include the transport of personnel to and from the workplace, effects of increased traffic load on road safety and pedestrians, increased noise levels associated with trucking activities, and impacts of heavy vehicles on the road surface.
ISSUE RESPONSE 6.1 Transportation of Goods 6.1.1 How will Aluminium Pechiney haul The majority of raw materials would be material between the smelter and the transported by conveyor from the port to the Harbour? Has rail been considered? smelter; and finished products (ingots) There is a definite over utilization of transported by truck from the smelter to the port roads and under utilization of rail in (see section 3.4.1). Alternative transport modes South Africa and the maximum use of will be considered in the traffic and transportation rail will be preferable to roads. study. 6.2 Integrated Transport Planning 6.2.1 The siting of the Aluminium Pechiney This comment has been noted and brought to the plant needs to take into account the attention of the CDC. Within the IDZ, rail traffic proposed future commuter rail network has been investigated. This option is being kept planned for the IDZ. Cognisance open and may be implemented once the number needs to be taken of the existing and of potential commuters and their actual location planned future rail lines for the IDZ. In has been determined. The potential for rail particular a proposed future commuter transport associated with the smelter will be rail link is planned to link future lines considered in the traffic and transportation from Uitenhage to Motherwell through specialist study. the metallurgical cluster to the existing lines at the Aloes and Coega stations. 6.2.2 Who is responsible for transportation CDC is responsible for transportation planning planning within the Coega within the IDZ and keeping all options open, Development Corporation? The including rail transportation. development needs to look at transportation planning with the IDZ and ensure that these developments are co-ordinated specifically with future rail access. Rail corridors are extremely more difficult to amend than road corridors. 6.2.3 How will workers access the site? It is anticipated that workers will access the site There is presently no transportation to by means of private vehicles, buses and minibus Coega. taxis. Transportation planning will be coordinated by the CDC, with busses to be provided to collect workers from the construction village and some other key areas.
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6.2.7 Macro-economic issues
Macro-economics issues are those related to the broader economic costs and benefits of the project (e.g. jobs, income, taxes, investment) at a local, provincial and national scale. The proposed project would entail an investment of US $1.7 billion which would have economic implications for both the local, provincial and national economy. One of the immediate effects would be the creation of direct employment during both construction and operation (refer to section 3.6 for details), as well as upstream and downstream opportunities associated with the proposed project. Aluminium Pechiney would be an anchor tenant for the Coega IDZ. Anchor tenants acts as catalysts for further investment (including improvements in local infrastructure and services) and as a magnet for other economic activities. They usually involve large-scale projects and in the construction and operational phases, present major employment and other economic opportunities for local enterprises (CES, 2000, EIR, pp xix). The project would therefore have implications for the South African economy, for example, contributions to tax revenues, the national Gross Domestic Product (GDP) and the national balance of payments.
ISSUE RESPONSE 7.1 Employment Opportunities 7.1.1 What will be the total number of jobs On average, construction would provide 2000 created by the project, what types of jobs. Employment opportunities would peak at jobs and during what phases of the 6 000 workers for approximately 12 months during project? How many technical jobs will construction. The operation of the smelter would be required by the project and how provide long-term employment for 550 semi- many of these will be for the Nelson skilled (Grade 10 or 11) and skilled employees Mandela Metropolitan people? (Grade 12) and 200 highly skilled employees. A strategy for recruitment and placement of personnel within the zone is being developed by the CDC to manage the requirements and expectations of both investors and job-seekers. 7.1.2 What will be the skills levels required The 550 operating positions would require skilled for the various jobs? (grade 12) and semi skilled (grade 10 or 11) employees. Specific technical training would be given with regards to aluminium smelting process activities. The 200 managing positions would require skilled people with supervisory experience or highly skilled employees. Specific technical training would be given including practical training in other AP smelters for key positions. 7.1.3 There are 550 lower level jobs. Why The number of operational positions required is this number and is the opportunity for defined by the technology basis of the project. promoting labour-intensive practices The 550 positions would compose the team which being optimised? would have to control the normal operation of the equipments and to correct deviations. The aluminium smelting process is mainly computer controlled from distant control rooms and most of the operations are done using multi-purpose specialized overhead cranes with cabins. Non- core operational requirements would be sub- contracted.
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ISSUE RESPONSE 7.1.4 What will be the ratio of foreign After start-up of operations the foreign work force technical expertise to local expertise will make up approximately 5% of the total. when the project is up and running?
7.1.5 There is a concern that foreign skills This concern has been noted. Foreign expertise will be imported and large numbers of would be brought in for commissioning and early people outside of the Metro will benefit operation of the smelter in order to give the from the project. unexperienced workforce time to develop the specific skills required for the aluminium smelting process. The project provides significant opportunities for skills transfers to local people. 7.2 Economic Impacts 7.2.1 Besides employment and training what The macro-economic specialist study will describe other benefits will the Metro derive and assess the positive and negative impacts of from the project? the proposed project on the local, provincial and 7.2.2 What will be the upstream and national economy. downstream economic impacts and forward and backward links into the country, especially in the rural areas? 7.2.3 How will SA benefit if all the raw materials are imported and the finished product is exported? 7.2.4 A percentage of the finished product Local market demand will determine the level of should be used locally to boost and finished product used locally. Developing sustain local markets as opposed to downstream aluminium activities is an exporting 100% of the finished product. independent strategy that could be undertaken irrespective of the presence or absence of a 7.2.5 A condition of approval for the smelter smelter. should be that South African industries are given the opportunity to add value to a portion of the product being produced, before it is exported. In other words, instead of exporting aluminium ingots, South African industries make use of the aluminium to produce value-added products, for example, aluminium engine blocks, for the local motor industry, or for export. 7.3 Economic Sustainability 7.3.1 The development needs to be The development has a nominal lifespan of 30 to economically sustainable, for example, 40 years. A final decision on investment in the it should not be retrenching people project will be made on the basis of it being within a few years but provide considered economically sustainable for the long sustainable employment. term. 7.3.2 Will companies be given a tax holiday Issues related to taxation and revenue generation at Coega? will be addressed in the macro-economic specialist study. 7.4 Impact on Businesses 7.4.1 The 8CR property was acquired with This issue was included in the Subsequent Port the specific intent and use for EIR (issue no. 1.6 of the Issues Trail), which development of five (5) abalone farms. identified that construction of the port would The property has very limited pre create a risk of pollution for mariculture activities existing land use as abalone farms and in the area. was successfully marketed as that. This has been stated in early studies With regard to the Aluminium Pechiney EIA, the
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ISSUE RESPONSE on the Coega project. Due to the water discharges to the marine environment Harbour and IDZ development, specialist study will consider the potential impacts proposed transactions have lapsed of stormwater discharges originating from the and the best land use option for the Pechiney smelter on the marine environment and area has been affected. mariculture. 7.4.2 Will the development at Coega This will be an individual company’s decision. encourage companies to close down and relocate to Coega?
6.2.8 Noise issues
Experience from EIAs for aluminium smelters in southern Africa show that the main sources of noise relate to: · Construction activities · Transport of raw materials and finished products to and from the port · Operational noise from the smelter (eg. from the electrical sub-station).
During operation of the smelter, the significance of noise impacts on the surrounding communities is reduced by the location of the proposed smelter within the Industrial Development Zone. No residential development is planned for within the IDZ, and the nearest residential areas (Motherwell) are located some 3 km from the Pechiney site. Therefore, the impact of noise from the smelter relates mainly to the effect on other future tenants in the IDZ and whether noise levels at the boundary of the smelter site meet relevant national and international standards.
ISSUE RESPONSE 8.1 Noise Impacts 8.1.1 What are the anticipated noise impacts Noise impacts and mitigation measures are during construction and operation of addressed by the noise specialist study. the smelter and how will these be managed.
6.2.9 Issues related to visual impacts
The smelter would occupy a site of approximately 80 hectares (approximately the extent of 160 soccer fields) with the potrooms being 1200m long and 22.8m to the top of the roof. Consequently, due to its size, the smelter would result in changes to the current landscape and “sense of place”. Additional infrastructure directly associated with the smelter that would also be particularly visible includes the dedicated materials handling facilities at the port and the conveyer belt between the port and the smelter. Issues related to the visual impact of the smelter include the effect of the smelter on the development of tourism in the area and its visibility from key tourism routes or view sites.
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ISSUE RESPONSE 9.1 Impacts on Addo National Park 9.1.1 What will be the impacts of this These issues will be addressed in the visual development on the greater Addo impact specialist study. Visual guidelines are National Elephant Park? being developed by CDC in conjunction with South African National Parks for the IDZ, which 9.1.2 As the plant will be operating 24 hours, will also be integrated into the EIA when what will be the visual impact on Addo, available. especially at night with regards to lighting? 9.1.3 What will be the visual impact of the plant from the rest camps and camp sites in the Park? 9.1.4 Buildings will have to blend in with the environment and take colour into account. 9.1.5 Will there be building height restrictions to limit the visual impact on Addo? 9.1.6 With new park developments in the Visual impacts of the smelter, the conveyer belt Colchester area potential tourists would and the port infrastructure will be addressed by be using the N2 as an access route to the the visual impact specialist studies. The visual park. As a result these visitors would impact of powerlines to supply the IDZ are need to travel through the IDZ to reach addressed in two EIAs being undertaken by the park. The visual impacts are therefore Eskom. not only restricted to the area within the park boundary and this needs to be taken into consideration. 9.1.7 The total visual impact of the development needs to be assessed: powerlines, conveyer belt, plants etc. 9.1.8 How will lighting at night time impact on The visual impact specialist study will consider the the St Croix Islands and the breeding of significance of lighting impacts on the St Croix birds. Islands. If considered significant this may necessitate further investigations into the impacts on birds breeding on St Croix Islands. 9.1.9 Although it is assumed that the The visual impact specialist study will assess the significance from shore-based lighting and significance of lighting associated with the the subsequent impacts will be low, it Aluminium Pechiney activities and will provide should still be incorporated into the EIA, recommendations to mitigate negative impacts, with recommendations and mitigation where necessary. measures to limit this possible disturbance. 9.1.10 What will be the impact of emissions on Under normal operating conditions, no visible the Addo National Park expansion project, plumes would occur. The potential for visible especially with regards to visible plumes? plumes to occur during upset conditions will be assessed in the air quality specialist study. 9.2 Design alternatives 9.2.1 The visual assessment should compare At present, the dome design for storage of the impact of silos versus domes for the materials has been incorporated into the plans for storage of materials, domes are the the smelter by Aluminium Pechiney. The visual preferred option for storage by CDC. impacts of the domes will be assessed in the visual impact specialist study as part of the overall impact of the smelter.
9.3 Visual guidelines for the IDZ 9.3.1 The visual assessment needs to take into The visual impact study will include reference to account guidelines being developed by the guidelines being developed by the CDC. The CDC. consultant preparing the visual guidelines for the IDZ will be involved in the review of the visual study for the Aluminium Pechiney EIA.
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6.2.10 Additional environmental issues
The proposed aluminium smelter would require 860 MW of electricity. This is approximately the consumption of the cities of Port Elizabeth and East London combined. The amount of electricity required to operate the smelter raises the issue of the impacts associated with electricity generation elsewhere in South Africa. Although South Africa currently has spare capacity to meet the energy demands of the project, approximately 90% of this electricity is currently generated through burning low-grade coal. Impacts related to this form of electricity generation include problems associated with coal mining (such as acid mine drainage and increased risk of respiratory diseases and cancer amongst humans), as well as with the electricity generation itself as this releases large volumes of SO2 and CO2 into the atmosphere. The impacts of these gases have been described in section 6.2.1. A detailed assessment of the impacts associated with electricity generation is, however, beyond the scope of this EIA. Issues associated with South Africa’s energy supplies are more appropriately addressed at a strategic, policy level by the Department of Minerals and Energy and, for example, as part of Eskom’s Integrated Strategic Energy Planning.
Energy Planning and the Environment
The Department of Minerals and Energy’s responsibility on energy and the environment follows a two- tier approach, namely:
· evaluation of the effect of energy activities on the environment, and · evaluation of the effect of environmental legislation and standards on the supply and cost of energy.
These evaluations are currently performed on three levels, namely the local, regional and global levels. The local level includes aspects such as smoky coal and cheap paraffin stoves, the regional level aspects such as the impact of power stations and chemical plants and the global level aspects of global climate change.
Source: Department of Minerals and Energy
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ISSUE RESPONSE 10.1 Impacts of electricity generation 10.1.1 The large amount of energy required The air quality specialist study will provide a for the primary smelting process may summary of the raw materials consumed and be particularly problematic in South emissions released in order to generate the Africa, where most energy is electricity required for the smelter. This will be generated from coal-fired power done assuming coal-based power generation, stations that burn low-grade coal. using information from Eskom. A full assessment Although it is recognised that this of the impacts associated with electricity issue is generally out of Aluminium generation is, however, beyond the scope of the Pechiney’s control, the EIA should Aluminium Pechiney. register that the increased energy requirement could have impacts on the Highveld, where most of South Africa’s energy is generated. 10.1.2 In order to know the full impact of the smelter on the SA environment, the tonnage of coal used, gases produced, water used etc. per year to generate the electricity should be stated. 10.1.3 The global impacts of greenhouse The air quality specialist study will identify the gases emitted by a primary aluminium additional contribution that the smelter will make smelter need to be considered. to South Africa’s total greenhouse gas emissions. 10.1.4 The economic costs of pollution to the An assessment of the economic cost of pollution SA environment, from the increase in from electricity generation is beyond the scope of electricity consumption, should be this EIA and is best addressed by the activities of assessed. the Dept of Minerals and Energy, as quoted above. 10.1.5 Major reductions in greenhouse gas This comment is noted. emissions may be possible by converting from coal based electricity to other forms. 10.2 Construction of additional power lines 10.2.1 The erection of an electrical supply Eskom is currently undertaking an EIA for line from Grassridge to the smelter provision of new powerlines from the Grassridge needs to be assessed. sub-station to the IDZ (including the Aluminium Pechiney site) and Port Elizabeth. 10.2.2 It is critical that future power The expansion of the powerlines and corridors requirements are anticipated, taking from Poseidon to Grassridge and Grassridge to into account future expansions, in Coega are designed to meet the electricity order to assess these impacts at this demand of the IDZ and the proposed smelter. stage of the development. Eskom has indicated that the supply capacity being planned for is sufficient for a possible second potline, if necessary. The environmental impacts associated with the expansion of electricity supply capacity is being addressed in EIAs commissioned by Eskom. 10.2.3 SANParks would oppose any further Noted. This comment has been forwarded to the additions to the power grid over and Eskom public participation process for the EIAs of above those already planned to meet the construction of new powerlines from Poseidon the requirements of the IDZ, to Grassridge and from Grassridge to Coega. particularly if they impact on the expanding park.
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ISSUE RESPONSE 10.3 Impacts on Electricity Supply Capacity 10.3.1 What electricity capacity does the The electricity requirements for the smelter will Metro have and what are the not draw on existing electricity allocations to the requirements of this project? In the Metro, as power will be supplied directly by event of a power failure will Eskom via dedicated powerlines. The annual preference be given to the smelter to power consumption of the smelter is 860 MW. the disadvantage of the NMMM ratepayers and communities? 10.3.2 How will the consumption of electricity CDC has indicated that the charges for electricity impact on service charges payable by the CDC to their tenants will be in-line with the within the metro? charges levied by the metro and so will have no effect on metro prices.
6.2.11 Issues related to the EIA and public participation process
ISSUE RESPONSE 11.1 Responsibilities of Roleplayers in this EIA 11.1.1 Is the CSIR an independent Yes, the CSIR is an independent consultant. The consultant? What does “not having CSIR is not a shareholder in Pechiney and has no vested interests in the project” mean vested interest in the smelter project going ahead. and will the CSIR not receive further In accordance with the EIA Regulations, the CSIR work from Pechiney meaning that they has completed a “declaration of independence” have vested interests? for this EIA, which has been submitted to the provincial environmental authorities.
11.1.2 The CSIR is a parastatal and as Coega The CSIR is committed to provide an independent is a government project, the CSIR assessment of the potential impacts of the project, should not be involved in the project. in accordance with international best practice and the professional ethics applying to environmental practitioners. The public participation process also provides numerous opportunities for stakeholders to review the quality, integrity and independence of the EIA. Independent reviews of the specialist studies are also included in this EIA as an additional quality control measure.
11.1.3 How is the CSIR structured, is it a The CSIR is a parastatal Science Council, Public or Private Sector Institution and established by an Act of Parliament. Its only who are its shareholders? Is the CSIR shareholder is Parliament, which provides core Profit or Non-Profit driven? funding in the form of a Parliamentary Grant for research through the "Science Vote" of the Department of Arts, Culture, Science and Technology. Current income is derived both from normal business operations (60%) and the Parliamentary Grant (40%). Surplus income (profit) is managed in accordance with the mandate under which the CSIR operates. This mandate is to serve the nation and the private sector through directed research and technological innovation, and to contribute to improving the quality of life of the people of South Africa.
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ISSUE RESPONSE 11.1.4 Why is the National Department of The national Department of Environmental Affairs Environmental Affairs not included in and Tourism (DEAT) has agreed that the the decision making process for this provincial Department of Economic Affairs, EIA? Environment and Tourism (DEAE&T) is the relevant decision-making authority for this EIA process. Nonetheless National DEAT are involved in reviewing and commenting on the EIA. Furthermore, national DEAT is responsible for issuing permits related to atmospheric emissions. 11.2 The EIA Process 11.2.1 Government has given the final go While the ROD for the Rezoning EIA gives ahead for Coega, why are we still conditional go ahead for the IDZ as a whole, the consulting if the final ROD has been EIA Regulations require that a separate EIA is granted? done for individual projects in the IDZ, such as the proposed aluminium smelter. 11.2.2 Why is the EIA process spread out The EIA is being undertaken over a ten month over a year, this seems like a long period, from March to December 2002. The time? process is very comprehensive, and this length of time is required in order to include extensive public consultation, detailed technical studies, and authority review and approval stages. 11.2.3 The assessment should include input Agreed. Relevant agencies and organisations for all relevant governmental and non- have been identified, pro-actively consulted with governmental agencies and and provided with information on the EIA. organisations. 11.3 Scope of this EIA 11.3.1 The environmental impacts of this Agreed. The overall aim of the EIA is to provide a development need to be balanced and balanced assessment of the impacts, as well as managed. clear recommendations for enhancing benefits and mitigating negative impacts. 11.3.2 It is critical to assess the impact of This EIA is assessing the impacts associated with future expansions to the smelter at this the proposed project. If an expansion is proposed stage of the EIA process, in order to in the future, then this will be subject to a obtain a comprehensive consolidated separate EIA process, in accordance with the picture at maximum operation. For regulations and future development of the IDZ. example, consider impacts of additional electricity supply, air emissions and waste generation. 11.3.3 The Pechiney Factory and Port cannot Cumulative effects for the IDZ have been taken be seen in isolation. Cumulative into account by in IDZ planning by, for example, affects of the development to date setting maximum limits on air pollution. These have not been assessed and no public concerns of the 8CR Property Trust were Scoping report has been done for the addressed in the recently completed Rezoning IDZ. In none of the reports to date and Port EIAs. have the concerns of the 8CR Property Trust been addressed. 11.3.4 No specialist study has been done to The water discharges to the marine environment assess the cumulative affects of a specialist study will consider the potential impacts large industrial area and port of stormwater discharges originating from the surrounding an abalone farm. This Aluminium Pechiney smelter on the marine should be assessed with a focus on a environment and the abalone farm. mariculture and abalone. The study should include the effect on abalone It is beyond the scope of the smelter EIA to
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ISSUE RESPONSE farming and breeding of abalone address the wider cumulative impacts of the IDZ unless there is an agreement reached and the proposed port on abalone farming. on buyout or relocation before construction starts. 11.3.5 The specialist studies need to assess This issue is covered by the Rezoning EIA and the affects the IDZ and Port had or will Subsequent Port EIA. have on existing land uses within or adjoining the area. All factors need to be taken into account and satisfactory mitigatory measures proposed. 11.3.6 Infrastructure to support the smelter Agreed. Infrastructure provision to the IDZ will may have a bigger impact than the have both positive and negative impacts. smelter alone. 11.3.7 The EIA needs to assess impacts Where information is uncertain a precautionary under a worst case scenario i.e. during approach is being adopted in the specialist upset or abnormal conditions. studies and the worst case scenario has been included in the assessment. The potential for upset conditions will be described. 11.3.8 The EIA needs to include an An assessment of the impacts associated with the assessment of the impacts of the operation of the conveyer belt is included in the proposed conveyor route from the EIA. harbour to the plant. 11.3.9 The conveyer belt run intends to run Provision of the conveyor corridor from the port up along the bottom of the side of the hill to the east side of the N2 is the responsibility of but cuts into the slope at Butterfly NPA, as part of the Aluminium Pechiney/NPA Valley before it crosses the N2, which Agreement. Aluminium Pechiney will work closely will require substantial cut and with NPA to establish mitigation measures when excavation. How will this be mitigated constructing the corridor and conveyor. The EIA to limit visual impacts and maximise for the smelter can also propose some basic ecological functioning. mitigation measures. 11.3.10 Has attention been given to the 1:50 The 1:100 year flood level has been taken into and 1:100 flood plain? consideration in the overall planning for the IDZ. The Pechiney site is located well above the 1:100 year flood level.
11.3.11 What will be the electromagnetic Potential electromagnetic field impacts are impacts associated with the accounted for in specification of the smelter site to development? ensure no impacts are experienced offsite. 11.3.12 The process options should include the Aluminium Pechiney acknowledges this point. Best Practised Environmental Option Proposed process options will be assessed (BPEO) to be assessed, if it is not the against international best practice guidelines in current proposal. Technology should the specialist reports. minimise air emissions, liquid effluent (should be zero process water effluents) and solid waste. Page 12 of the Scoping report implies SO2 could be reduced by using alternative technologies. Sulphur content in heavy fuel oil (HFO) must be low. 11.3.13 The EIA should evaluate possible The Environmental Impact Report will include energy conservation measures that information on energy conservation measures to would be implemented in the operation be implemented by Aluminium Pechiney at the of the smelter in order to reduce smelter during operation. greenhouse gas emissions.
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ISSUE RESPONSE 11.3.14 The feasibility of establishing a Secondary aluminium production is a different secondary smelter for aluminium business to that of primary aluminium production recycling, or of mixing primary and and requires very different processes. The secondary aluminium production, casthouse equipment in a primary aluminium should be explored as alternatives in smelter is not capable to meet secondary smelting the EIA. needs. 11.3.15 Who is undertaking the various A table with the list of specialists is included in the specialist studies? Draft Scoping Report (Table 2, in chapter 5) and similarly in the Final Scoping Report. 11.4 Management & Monitoring of Impacts 11.4.1 Although SA has comparable Aluminium Pechiney has full intentions to comply legislation it is often not enforced or with all SA legislation. It is also against Pechiney’s imposed, does this make SA a more internal policy to consider the degree to which attraction option for siting the smelter? legislation is enforced as a factor in site selection. 11.4.2 Will the mitigatory measures proposed In general, the mitigatory actions will be designed be as stringent as those required by to ensure that the smelter meets national European countries? standards, international best practice, and international protocols or conventions that South Africa has ascribed to.
11.4.3 CDC intend aligning all sustainability Noted. indicators throughout the zone and linking them the Global Reporting Initiative (GRI). 11.4.4 Who will be responsible for enforcing Through the permitting/licensing process, the the mitigation measures proposed for relevant government departments issuing permits the Pechiney development? will be responsible for monitoring and enforcement. CDC will provide over-arching monitoring for the IDZ. Furthermore, as part of their company commitment to ISO 14001, Aluminium Pechiney will monitor environmental and performance indicators. 11.4.5 Are the existing government agencies Regarding point (i), the identification of adequately funded and resourced to: environmental problems/issues is being done (i) identify and assess environmental through a scoping process that includes inputs problems, particularly the long-term from I&APs. The assessment of these issues is effects; and (ii) ensure monitoring and the objective of the EIA, which is funded by compliance with environmental Aluminium Pechiney and undertaken by the CSIR. standards for construction and operation and deal with environmental Regarding point (ii), compliance and monitoring problems which may nevertheless will be a shared responsibility between Aluminium occur? It is the experience of the Pechiney, CDC, NMMM and regional and national Zwartkops Trust that the Metro, DWAF government. Levies and “pollution charges” will be and DEAET are not adequately funded applied by CDC to tenants in the IDZ to cover and resourced to deal with the monitoring costs. numerous pollution and environmental matters in the area under their jurisdiction. 11.5 Record of Decisions of other EIAs 11.5.1 The ROD's for the Port and the IDZ Noted. have been issued subject to buyout or relocation of the abalone farm, Marine Growers. Any future EIA's should be
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ISSUE RESPONSE issued subject to this condition. 11.6 Other EIA process issues 11.6.1 The exact position of the smelter on At the time of producing the Draft Scoping Report the ground is unclear in the scoping this was the most detailed map available. A more report. detailed map will be provided in the EIR. 11.6.2 The process diagrams should show the Noted. The diagram has been updated. role of the CDC, this should be included as Authorities, CDC, others. 11.6.3 The social and economic section of the The summary description of the affected Draft Scoping Report needs to be environment in the Draft Scoping Report was updated as things have changed since based on the final reports of the Rezoning EIA the CES Rezoning EIA final report (CES, 2000) and the Subsequent Port EIA (CES, (2000). 2001). This contextual description will be updated with the findings of the specialist studies from the Pechiney EIA. 11.6.4 The final EIR should include all The final EIR will include all mitigation and benefit mitigatory measures that Pechiney are enhancement actions recommended by the CSIR; committed to implementing. as well as the commitment from Aluminium Pechiney to these recommendations.
11.7 Public Participation 11.7.1 Public involvement and participation is Agreed. For this reason the CSIR has appointed critical in these types of developments. Sandy and Mazizi Consultants to undertake the public participation process. 11.7.2 Does registration on the public No, but it means you are better informed about participation attendance register the project and the potential opportunities. secure one employment or favour one in any way? 11.7.3 There is a need to ensure that as many Noted. The public has been informed of the people as possible are informed about proposed smelter project and EIA through this development. newspaper adverts. 11.7.4 How different is this consultation This consultation process is for the Environmental process to the other consultations that Impact Assessment (EIA) process being have been held for Coega? conducted for the proposed Pechiney Aluminium Smelter. The previous consultations processes were for the EIAs for the Port of Ngqura and the Rezoning of the Core Development Area from Agriculture to Special Purposes as well as the EMPR for the mining of Coega Kop. In line with national government legislation, EIAs will be conducted for all listed activities at Coega and will include public participation.
11.7.5 To what extent are I&APs involved in At the Scoping Phase the input of I&APs in the decision making and can they reverse identification of issues and concerns for further decisions that are made? investigation compliments the knowledge and expertise of the scientific research process. During the EIR phase, I&APs play a further role in reviewing the EIA thereby ensuring that the issues raised have been addressed. This information forms part of the final EIR, which is submitted to the relevant government department that makes their decisions and/or recommendations based on the scientific research conducted and the public input into the EIA process. I&APs are also
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ISSUE RESPONSE provided the opportunity to appeal Records of Decision that are issued by the Department.
11.7.6 What other opportunities will we have I&APs have the opportunity to comment on the to engage with the process? When the Draft Environmental Impact Report (EIR), to be report is available will community released in September 2002. structures have the opportunity to debate the report? 11.7.7 The Northern Areas of the Nelson Noted. The Northern Areas form an integral part Mandela Metropole should be more of the public participation process for this EIA. involved in this project. 11.7.8 It should be noted that there are two Noted and conveyed to the public participation primary I&APS with respect to rail consultants for the EIA, Sandy and Mazizi matters, i.e. the South African Rail Consulting. Commuter Corporation (SARCC) for commuter related facilities, and Spoornet for freight related activities.
6.2.12 Issues related to Aluminium Pechiney project proposal
ISSUE RESPONSE 12.1 General 12.1.1 Who is the initiator of this project, Aluminium Pechiney has initiated this project to the Coega Development meet anticipated increasing demand for aluminium Corporation or Government? metal. 12.1.2 Are there other aluminium The only two primary aluminium smelters are smelters in South Africa, how located in Richards Bay (the Bayside and Hillside many and where are they located? smelters), which are operated by BHP Billiton. The only other primary aluminium smelter in southern Africa is the Mozal smelter, located outside Maputo. 12.2 Site Selection Criteria 12.2.1 If political instability was a Nobody can predict the impact with any degree of selection criterion for a site, how certainty. Interest rates, currency, inflation and will the depreciation of the Rand depreciation rates have combined effects on the impact on SA's position in the economics of the project. race/bid for the project? 12.2.2 When will a decision be made on a Coega has already been selected as a preferred preferred site? site by Pechiney. This triggered the EIA process. The final decision on whether to construct and operate a smelter within the Coega IDZ is subject to contractual, legal and financial frameworks being confirmed. The timeframe to have all agreements in place and financial closing will be early 2003. 12.2.3 How was SA selected as one of Coega satisfies many of the required site selection the preferred sites and was criteria. In particular, South Africa and Eskom have Canada considered as a potential power generation capacities which are available in site as it has hydroelectric power a time frame which is difficult to meet in other and produces one of the cleanest countries at this stage. energies? Why has it not been short-listed? 12.2.4 What is meant when talking about Argentina, Australia and South Africa were Argentina and Australia? identified as preferred sites for the location of the smelter. Due to recent economic instability in Argentina, the more detailed feasibility studies for
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ISSUE RESPONSE this site were stopped. At present engineering, planning and environmental studies are underway at the South African and Australian sites, with the intention of reaching a decision on the preferred site as soon as strategic agreements are reached. South Africa is currently the most promising location, but business development is actively pursued elsewhere. 12.2.5 What is the status of the studies Engineering, planning, and preliminary being conducted in Australia and environmental studies have been initiated for an how far are they? Australian site. A notice of intent has been logged with the relevant authority to initiate the scoping phase of the EIA process. 12.2.6 Is it possible to have a report from Providing such a report, if it exists, is beyond the ratepayers in Australia outlining scope of this EIA process. For information, there how they feel about the smelter in are six smelters in Australia, several of which have their country? gone through (or are going through) formal approval processes for expansion activities in recent times. Public consultation processes have been a requirement of project approvals, indicating a level of public agreement with existing operations. 12.2.7 Is the project dependent on the The Coega harbour (Port of Ngqura), as well as the Coega Harbour being built or can IDZ, contribute to securing and accelerating the Pechiney use the existing Port project development. One could say that without the Elizabeth Harbour? port or the IDZ, Aluminium Pechiney will not have a 12.2.8 If the area for the smelter were not smelter in operation at Coega by 2005. an IDZ, would Pechiney still be interested in the area? 12.2.9 Why not site the smelter close to Proximity of raw materials is only one of the criteria the raw materials it requires? considered when siting an aluminium smelter. Many other criteria such as port facilities, power availability, site availability, infrastructure and market proximity are also factors considered. 12.2.10 Why has Pechiney identified SA as Refer to section 3.2 of the Final Scoping Report for a location for their smelter? Is this site selection criteria and process. A major factor in related to the source of raw identifying South Africa as a preferred location for materials and market or is related siting the smelter was the agreement with Eskom to the fact that legislation on for the supply of electricity, as well as the pollution in SA is not as strict as in development of the port and infrastructure within the France and Europe. IDZ.
12.2.11 Is the land available where the CDC has indicated that a suitable site within the proposed plant will be built and metallurgical cluster is available to Pechiney and how do you know if it is available? details of tenure are currently under discussion When will Pechiney acquire the between CDC and Pechiney. land, and will they purchase the land or lease it? 12.2.12 What are the chances of Coega Coega has been selected as the preferred site. being selected as the preferred However, a final decision will only be made after site? completion of studies, establishment of financial and commercial agreements and obtaining of approvals.
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ISSUE RESPONSE 12.3 Skill requirements 12.3.1 Pechiney needs to state the skills Aluminium Pechiney will work with the CDC and that will be required within the local training organisations/authorities to define skill plant so that people can begin the requirements as the project proceeds towards process of equipping themselves formal approval. with the necessary skills to take advantage of future opportunities. 12.4 Project Construction Process 12.4.1 When will the project commence Aluminium Pechiney plans to have the EIA and how long will construction completed and to reach a decision on the preferred last? What are the total project site by end of 2002 following the issue of the Record timeframes? of Decision for the EIA. If the Coega site is selected, construction would then commence early 2003, with operation starting in early 2005, reaching full operational capacity by the end of 2005 (refer to section 3.8). 12.4.2 Once the smelter is constructed Planning for the construction workforce will be what will happen to the undertaken jointly between Aluminium Pechiney and construction workers who were the CDC, and will include planning for the end of the employed during this phase of the construction phase. work. 12.4.3 From where will the building Building materials would be sourced by the materials be sourced? engineering firm that would undertake the construction of the plant. This would be undertaken according to normal procurement practices and economic criteria. Experience suggests that most of civil works and structural steel materials would be sourced from southern Africa. 12.4.4 Will production during operations Yes. be on a 24-hour basis? 12.5 Materials required during operations 12.5.1 From where will the raw material Raw materials such as alumina, coke and pitch be sourced? Will it be local or will would be imported from South America, Northern they be imported? America, Asia, Europe or Australia. These materials are not available locally. 12.5.2 Are the raw materials available in Aluminium Pechiney has indicated that alumina, SA? aluminium fluoride, liquid pitch and petroleum coke will be imported. The smelter will use agreed raw materials for its operation. Any new source of raw material should go through an agreement process once the operation has begun.
12.5.3 What agreement has been A preliminary agreement has been reached reached with Eskom? between Eskom and Aluminium Pechiney for multi- year electricity supply to the smelter.
12.6 Operational targets 12.6.1 What will be the production targets Approximately 443 tonnes of aluminium ingots per shift and how long will each would be produced per 8-hour shift to meet annual shift be? production targets of 485,000 tonnes. The production process would run continuously, 24 hours a day. The plant would operate three 8-hour shifts per day.
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ISSUE RESPONSE 12.6.2 How sure is Pechiney that the jobs Aluminium Pechiney has long-standing experience they are proposing to create will be in the construction and operation of aluminium the number of jobs that will be smelters. The estimated workforce for construction required by the development. is based on similar projects completed both within and outside of South Africa. The personnel requirements for the operational phase are well defined. 12.6.3 To which countries will the ingots Aluminium ingots are a world-traded commodity and be transported? the export destination depends on market demand. 12.6.4 What is the expected life span of The currently anticipated life of the plant is 30-40 the project? What will happen to years. Thereafter, based on Aluminium Pechiney’s the smelter plant once it has international experience, options include: reached its anticipated 40 year life 1. Extension of the lifespan of the smelter span? through technology upgrade 2. Alternative use of the buildings and facilities by other industries 3. Removing structures and full site rehabilitation The financial provision for decommissioning is made from the outset. 12.7 Communication with Stakeholders 12.7.1 How will Aluminium Pechiney This is a good point which will be considered in the communicate project progress to overall communication programme. With assistance the surrounding community, from the CDC, Aluminium Pechiney would seek especially with regard to opportunities to inform and educate the local opportunities that arise? As community on progress of the project. statutory ward representative structures, the Ward Committees should be involved in this process. 12.7.2 There is a need to constantly give Agreed. This could be achieved, for example, feedback to affected communities. through the Environment Monitoring Committee that A mechanism should be CDC is required to establish in terms of the ROD for developed to ensure that this the Rezoning EIA. This Committee is to include occurs once the EIA process is representatives from I&APs, relevant authorities, complete. CDC and the National Ports Authority.
12.8 Environmental, Health and Safety Management 12.8.1 Environmental Management Pechiney has made a company commitment to systems must be used to implementing ISO 14001, and intend to implement minimised negative impacts on the an Environmental Management System based on environment and ensure the this standard at the PAS2005 smelter. development is not harmful to the environment. 12.8.2 Does Pechiney have a Health and Pechiney’s 2001 EHS annual report identifies Safety policy and will workers be Environmental protection, Health and Safety as key provided with protective clothing? priorities in the Company’s strategy and the Pechiney Continuous Improvement System. The PAS2005 smelter will have a health and safety policy that requires that workers are provided with protective clothing according to the job they have to perform. The safety management system will require workers to use protective clothing provided, together with a range of other personal protective equipment for specific work activities.
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ISSUE RESPONSE 12.8.3 Safety and security must be Noted. provided on site for workers. 12.8.4 Fire fighting equipment must be provided on site. 12.8.5 Clean drinking water and toilets must be provided. 12.9 Labour Relations 12.9.1 What benefits can workers expect The development of a labour relations policy for the to derive if they are employed at operating smelter will be undertaken at a later stage the development e.g. medical aids, by the PAS 2005 smelter management. pensions and housing subsidies 12.9.2 Will companies at Coega be Labour relations will be undertake in accordance to unionised and will workers be general South African labour regulations. allowed to join unions? 12.9.3 The project must comply with SA This comment is noted and agreed upon. labour legislation, this is non- Aluminium Pechiney would comply with SA labour negotiable to the labour legislation. movement. Attention must be given to the Labour Relations Act and the Basic Conditions of Employment Act. 12.10 Tender and Procurement Policy 12.10.1 Will tenders be awarded through a With regard to tenders for the operation of the public tender process? smelter, details would be found in the tender and procurement policy that has not been finalized yet for the operation of the smelter. 12.10.2 Does Pechiney have a Pechiney has a company procurement policy, which procurement policy and if so will a does not specifically address this point. The representative from the development of a Procurement Policy for the disadvantaged community operating smelter will be undertaken at a later stage participate in any decision by the PAS 2005 smelter management. making? What is Pechiney's procurement policy? 12.10.3 There is a need for Pechiney to Noted. implement affirmative action in its approach to employment. 12.10.4 Does Pechiney's plan include the The development of a social equity policy for the promotion of historically operating smelter will be undertaken at a later stage disadvantaged individuals? by the PAS 2005 smelter management. 12.11 Trade-offs 12.11.1 The broad habitat unit upon which The CDC is undertaking a planning exercise for the the proposed Pechiney Aluminium management and use of all open spaces within the smelter is to be built, has been IDZ. The STEP and the metro’s MOSS information classified by the Subtropical will form part of this exercise. WESSA participated Thicket Environmental Plan in the review of the terms of reference for this work (STEP) and Nelson Mandela and the selection of consultants. They will also be Metropolitan Open Space System involved in the development of the Open Space (MOSS) Projects as Sundays Management Plan for the IDZ. This grassy bontveld. This broad recommendation will therefore form part of the habitat unit has been highly deliberations for the Open Space Management transformed by urbanisation and Plans. grazing, with only small fragments now remaining intact. WESSA EP does not have any objection to the proposed siting of the Pechiney
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ISSUE RESPONSE Aluminium smelter, particularly in light of the high degree of this patch’s transformation. However, It is requested that an alternative portion of Sundays grassy Bontveld, within the Coega IDZ, be set aside for conservation purposes as part of a trade-off for the use of the proposed site.
6.2.13 Issues related to the management of the Coega IDZ and the proposed Port of Ngqura
ISSUE RESPONSE 13.1 Registration of Service The responses below were provided by CDC: Providers by CDC 13.1.1 How is the registration process CDC is currently registering service providers for proceeding? What will be the duration the provision of infrastructure and services for the of this process? IDZ. 13.1.2 If you are not registered with the No. Receiver of Revenue will this impact on your registration? 13.1.3 What are the requirements for There are no minimum requirements. businesses to register with Coega? 13.1.4 When did this process start and when It started during June 2002 and is ongoing. will it end? 13.1.5 There is a need to encourage the Definitely. historically disadvantaged to participate and benefit from the Coega project. Is this being done? 13.1.6 What kind of businesses is the Coega Any organisation that wishes to register, believing Development Corporation registering? that it may be able to provide a service to the CDC or its tenants. 13.2 Registration of Job Seekers by The responses below were provided by CDC: CDC 13.2.1 It has been recommended by a Noted. number of organisations that the following people are considered and given attention in the employment process, woman, youth, the elderly and the disabled. 13.2.2 Making information on employment Noted. opportunities accessible to people is critical. The Ward Councillor’s offices should be considered as distribution points when information is required to go to the public. 13.2.3 Are there satellite offices in Addo for The Ward Councillor’s office acts as a satellite people seeking employment? There office at Addo and Patensie. is a need to provided satellite centres for people to access to information 13.2.4 How does this process work? How will Lists of the captured names will be available in people know if their name has been Ward Councillor’s offices and later be printed in captured. the newspaper (in a similar way in which the
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ISSUE RESPONSE matric exam results are published). 13.2.5 Competency and not only Noted. qualifications must be considered when employing people. 13.2.6 How is the registration process linked There will be checks between the demand for to training and skills development if at certain skills and the number of people registered all? with those skills. Where there are shortages, training may take place. 13.2.7 How will it be ensured that corruption The system has been set up to prevent this and and nepotism do not occur? external audits of the system will be undertaken. 13.3 Issues related to the Rezoning The responses below were provided by CDC: 13.3.1 Does the Record of Decision for the The whole Pechiney site is covered by the Rezoning EIA cover all the property Rezoning EIA, however only those sites owned by portions that will be included in the the CDC at the time of the Record of Decision Pechiney site? (ROD) were covered by the ROD. Once the outstanding properties are owned by the CDC, then they too will be rezoned, using the same EIA and having the same final ROD conditions applied to them. CDC plan to have control of all properties for the Pechiney site before the Pechiney EIA has been completed. 13.3.2 What will happen with people This issue was addressed in the Port EIA and is presently employed at the Salt Works? beyond the scope of the smelter EIA. A condition Many of the people employed there attached to the ROD of the Port EIA is that, in the come from Motherwell, will they lose event that closure of the salt works is a necessary their jobs? Should this occur the option, NPA must ensure that workers of the salt impact would be very high. works must be retrained and receive preference during recruitment for both the IDZ and the port development. 13.3.3 The rezoning EIA for Coega IDZ and These issues were addressed in the rezoning and the rezoning EIA for the Port of Port EIRs and were considered by the authority Ngqura state that there will be severe before a final decision was taken. It is beyond the impacts on the 8CR Trusts land. The scope of this EIA to address this issue. impacts and recommendations in both the EIA's have still not been resolved or implemented. Any further development such as the Pechiney aluminium smelter would only compound the affects on the Trusts lands. Any Scoping Report or EIA should offer satisfactory mitigation factors for the loss of land use and any development should be made subject to mitigating factors being adhered to. 13.4 Issues related to ROD's Issued The responses below were provided by CDC: 13.4.1 What happened to the appeals lodged The Minister considered these and issued a Final against the previous ROD's? ROD. The ROD for the CDC is available on their web site www.coega.com 13.4.2 When can we expect to hear about the Final Records of Decision (RODs) for the Final ROD's. Rezoning EIA and the Subsequent Port of Ngqura EIA have been issued by DEAT in May 2002. 13.4.3 Does the issuing of the RODs mean Yes, subject to the conditions contained in the the Coega project can proceed? Final ROD.
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ISSUE RESPONSE 13.5 CDC Monitoring Stations The responses below were provided by CDC: 13.5.1 What is being monitored by CDC and Ambient air conditions are being monitored at when will this be made available to the three stations. The report for 2001 is available public? from CDC to interested parties. 13.5.2 Who is CDC reporting and accounting The CDC has been gathering this information for to for the data they are collecting? their own use in order to establish the baseline ambient conditions and track changes. The information is available to interested parties. 13.6 Port Management 13.6.1 How many ships will be docking per As an average for a year: annum and have Portnet developed a · 16 to 24 shipment of alumina plan to deal with oil spills? · 8 to 12 shipments of coke · 7 to 10 shipments of pitch · 15 to 22 shipments of aluminium ingots.
The Final ROD issued for the Port of Ngqura EIA requires that an oil spill contingency plan is implemented before port operations commence.
13.7 Other issues 13.7.1 Would these multinational companies CDC will ensure that all companies operating at Coega ignore local legislation? within the IDZ do so in accordance with South Africa’s environmental legislation. 13.7.2 It is proposed that an independent It is not the objective of the public participation report assess the perception of process to identify and reflect the opinions and surrounding communities towards the perceptions of surrounding communities and a development. wider group of stakeholders towards a proposed project. The public participation aims to identify key environmental issues and concerns which require further assessment in the EIA. This is undertaken by an independent consultancy, Sandy & Mazizi Consulting. 13.7.3 There has been a lot of negative One of the key aims of the EIA is to provide reporting about Coega which needs to stakeholders and the public with objective, easily be countered. understandable information on the proposed project. In this way we hope to provide balanced reporting. 13.7.4 There needs to be a core group The final ROD for the Rezoning EIA (May 2002) monitoring the Coega Project? requires the establishment of an Environmental Monitoring Committee (EMC). The committee shall consist of representatives from interested and affected parties, the relevant authorities, the CDC and the National Ports Authority of South Africa (NPA).
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6.3 Linkages between key environmental issues
It is clear from the above discussion that many of the key issues (and hence the respective specialist studies) are closely related in terms of impacts, mitigation measures, benefit enhancement measures and information requirements.
A workshop for all specialists was held at the end of April 2002 to identify information requirements and linkages between the various specialist studies. One of the main objectives of the workshop was to ensure that information would be exchanged timeously between specialists as required for their respective studies and, where there was an overlap between studies, to minimise the potential for the duplication of efforts.
The linkages between the key issues and specialist studies has been summarised in Figure 9.
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Two-way linkages may exist either in terms of Negative/positive impacts of one issue on another Opportunities for mitigation + benefit enhancement AIR QUALITY ons H issi Q u m d u m E u a a le n n ic st t eh a if h V n ic ea d a l t th e io , m n p is a la s n n io d ts n a s cl n Increased spending on infrastructure a d TRAFFIC & ri a MACRO-ECONOMICS fi gr ca ic t u TRANSPORTATION io lt n ur Socio-economic SMME Development Sa o e fety f issues context Oppo M rtuni Job creation potential Increased at Nee ties fo eria d for S r supp Economic growth
vehicle ls tr MME orting
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O NOISE 2 SOCIO-ECONOMICS
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noise mitigation potent l rism F risks on tou measures Impacts development Smelter & Conveyer belt VISUAL MATERIALS HANDLING s ser & SOLID WASTE r u on rs ate MANAGEMENT ts se w ac r u of p s ate on im er r w ati n us the ific tio r o ent s Design of liquid waste management system lu te to Id rial ol wa sks ate P er Ri f m th ge o ing o illa load Storage of raw materials and solid waste Sp off ring WATER MARINE du RESOURCES & DISCHARGE LIQUID WASTE MARINE MANAGEMENT BIODIVERSITY
Figure 9: Linkages between key environmental issues associated with the proposed aluminium smelter
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7. REVISED TERMS OF REFERENCE FOR THE SPECIALIST STUDIES
An initial identification of key environmental issues was done through the technical Scoping process. This enabled the initiation of nine specialist studies. The preliminary terms of reference for these studies were included in the Draft Scoping Report. Based on comments received through the public Scoping process, the terms of reference for these specialist studies have been revised, and are presented in this section.
7.1 Generic Terms of Reference for all specialist studies
The following methodology for assessing impacts and assigning significance to the key issues identified through the Scoping process is to be applied in all of the specialist studies.
Assessment of impacts
The significance of potential impact should be described as follows:
Low: Where the impact would not have an influence on the decision or require to be significantly accommodated in the project design; Medium: Where it could have an influence on the environment which would require modification of the project design or alternative mitigation; High: Where it could have a ‘no-go’ implication for the project regardless of any possible mitigation.
The assessment of impact significance should be based on the following convention:
Nature of impact - this reviews the type of effect that a proposed activity would have on the environment and should include “what would be affected and how?” Extent - this should indicate whether the impact would be local and limited to the immediate area of development (the site or the servitude corridor); limited to within 5km of the development; or whether the impact may be realised regionally, nationally or even internationally. Duration - this should review the lifetime of the impact, as being short term (0 - 5 years), medium (5 - 15 years), long term (>15 years but where the impacts would cease after the operation of the site), or permanent. Intensity - here it should be established whether the impact is destructive or innocuous and should be described as either low (where no environmental functions and processes are affected), medium (where the environment continues to function but in a modified manner) or high (where environmental functions and processes are altered such that they temporarily or permanently cease).
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Probability - this considers the likelihood of the impact occurring and should be described as improbable (low likelihood), probable (distinct possibility), highly probable (most likely) or definite (impact would occur regardless of prevention measures).
The status of the impacts and degree of confidence with respect to the assessment of the significance, must be stated as follows:
Status of the impact - A description as to whether the impact would be positive (a benefit), negative (a cost), or neutral. Degree of confidence in predictions - The degree of confidence in the predictions, based on the availability of information and specialist knowledge.
Other aspects to take into consideration in the specialist studies are:
· Impacts should be described both before and after the proposed mitigation and management measures have been implemented. · All impacts should be evaluated for the full-lifecycle of the proposed development, including construction, operation and decommissioning. · The impact evaluation should take into consideration the cumulative effects associated with this and other facilities which are either developed or in the process of being developed in the region. · The specialist studies must attempt to quantify the magnitude of potential impacts (direct and cumulative effects) and outline the rationale used. Where appropriate, national standards are to be used as a measure of the level of impact.
Mitigation and monitoring
· Where negative impacts are identified, specialists should set mitigation objectives (i.e. ways of reducing negative impacts), and recommend attainable mitigation actions. Where no mitigation is feasible, this should be stated and the reasons given. Where positive impacts are identified, actions to enhance the benefit must also be recommended. · The specialists should set quantifiable standards for measuring the effectiveness of mitigation and enhancement. In addition, specialists should recommended monitoring and review programmes to assess the effectiveness of mitigation.
7.2 Specific Terms of Reference for the specialist studies
7.2.1 Air quality study
The specialists should address the generation and subsequent dispersion of air pollution arising from the proposed AP smelter. The changes in air pollution predicted for the project should be evaluated in the context of existing air pollution from projects planned for the
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Coega IDZ, the air pollution load in the Coega area, relevant legislation and international guidelines.
The study should specifically:
· Describe the aluminium production process with respect to the pollutants released into the atmosphere. · Discuss the human health and general environmental implications of the pollutants released (with a particular focus on hydrogen fluoride, sulphur dioxide, carbon dioxide, poly-aromatic hydrocarbons, perfluorocarbons and the deposition of particulates). · Prepare an emissions inventory for normal operation of the AP Smelter quantifying the existing and projected future emissions, together with all data needed for dispersion modelling, such as, gas flows, temperatures, heights of release etc. · Discuss the meteorology of the Coega area and identify possible abnormal or upset atmospheric conditions, their effect on emissions, and their likely frequency. This will require the collection of appropriate meteorological data for air quality modelling from all available and relevant sites. This should include wind speed and direction, temperature, cloud cover, sea surface temperature, and land use. The Specialist should also prepare topographical input for the model that includes large buildings and features such as piles of wood chips. · Dispersion modelling for the AP smelter, both alone and as part of the Coega IDZ suite of industries (so far as this is possible). Modelling should use one year’s worth of data and should predict the annual average as well as 24-hour and 1- hour episodes. Where possible, measured pollution concentrations will be compared with the model predictions for the current suite of industries. · Present the modelled predictions as maps showing isopleths on a base map of the Coega IDZ. · The model results will provide estimations of deposition rates for particulate fluoride and estimations of ambient level of fluoride and sulphur dioxide within the zone of impact. · Discuss the predictions in terms of existing South African air pollution guidelines, as well as international standards (in particular those of the World Health Organisation). · Evaluate the risk to human health of atmospheric emissions. · Evaluate the effects of atmospheric emissions on plants and agriculture, in particular agricultural activities in the area (e.g. citrus farming in the Sundays River valley). · Evaluate the potential for significant odours being emitted from the smelter (e.g.
from the emission of SO2). · Model possible “upset” scenarios over appropriate time periods, probably 24- hours or 1-hour. Present and discuss “upset” scenarios and their implications on human health. · All model inputs should be recorded in the Specialist Report.
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· Evaluate the impacts associated with dust that might result from the construction process. · Consider the impacts of “greenhouse gas” emissions in relation to South Africa’s contribution to the overall load and the country’s international commitments. · Identify and discuss any needs for pollution abatement and mitigation that are apparent from the study. This should be linked with recommendations for a long- term monitoring programme of either in-stack or ambient concentrations. As far as possible, mitigation measures for minimising emissions should include process and technology related measures, as well as “good practice” guidelines for employees and for equipment maintenance. · The Atmospherics Study should assess whether the proposed project could impact on flora and fauna in the surrounding areas through increased atmospheric deposition. Deposition on land use characteristics should be considered.
7.2.2 Water resource management and liquid waste management study
The water resource and liquid waste management specialist study will address a range of factors associated with water use and the handling of liquid waste generated on-site. The study will therefore include confirmation and assessment of water sources, pre-treatment requirements, liquid wastewater characterization (in terms of both volumes and quality) and the management of all liquid wastes generated on-site for discharge from the smelter site. Consideration of water recycling and re-use within the system will be included in the study. The study will include the following:
Water use
· Confirmation of water sources · Confirmation of quantities of water required · Recycle/re-use options · Waste management quantification, qualification and management considerations.
Liquid waste
· Effluent discharge water quality requirements in terms of local/national regulations including National Water Act (Act 36 of 1998) and other legislation identified as pertinent. · Qualification and quantification of effluent including: o Location, identification and confirmation of sources of impact on water quality [on-site wastewater production and effect of discharge on receiving water quality (surface and groundwater); atmospheric fallout; effects of non-point sources (run-off); and seepage from stormwater retention dam] o Identification of constituents of concern in effluent
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o Effect of effluent water quality on future water uses and the natural aquatic environment, in particular the Coega River. o Identification of effluent water treatment/remediation requirements or opportunities.
The Water Study will be collated as a Water Management Plan that includes consideration of:
· The potential for water recycling and re-use. · Water quality monitoring and performance management. · Any infrastructural requirements to reduce the risk of water contamination (e.g. seepage into groundwater aquifers).
7.2.3 Materials handling and solid waste management study
The study will consider the environmental impacts associated with the handling of raw materials and products onto and off the site, as well as the waste products that could be generated through the aluminium smelting and associated process. In particular, the study will: · Provide a detailed examination of the chemical process used to smelt aluminium in terms of the potential risk to the environment under normal conditions, start-up and shut-down, maintenance operations, and upset plant conditions. · Provide a comprehensive mass-balance to ensure that all waste streams have been identified and characterised in terms of quantities generated, composition and disposal options. · Provide a clear summary of the amount of waste (solid, liquid or gas) produced for each tonne of aluminium. If possible, compare this with international averages (eg. from the World Bank Pollution Prevention and Abatement Handbook) and results from the aluminium industry. · Review the technology to be used (e.g. unit operations) in terms of the “best practicable environmental option” principle. · Evaluate the environmental risks associated with the movement of materials associated with the manufacturing process, including inter alia: o Transport of raw materials from the PE harbour to the site. o Transport of raw materials from the proposed Coega harbour to the site. o The handling of materials at the ports and at the smelter site. · Evaluate the environmental risks associated with the storage of materials on-site. · Provide a detailed account of waste management opportunities and threats with particular emphasis on any hazardous waste that is identified. This should provide an overview of waste management within the Nelson Mandela Metropolitan Municipality and include an evaluation of the various waste management options which may be available, in order to identify the best practicable environmental option. · Provide a detailed review of national legislative requirements pertaining mainly to waste and effluents of the proposed smelter (e.g. Minimum Requirements for
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Waste Disposal, Hazardous Installations Act, National Water Act, etc.) · The specialist study will identify all permits required for waste management and materials handling on and off the Aluminium Pechiney site. Subsequently, the necessary permit application will be prepared, working together with the EIA Project Manager, Aluminium Pechiney and the relevant authority. · Identify international conventions and protocols to which South Africa is signatory and which are of relevance to this study and to the proposed development. · Identify and discuss any remedial and mitigation measures that could be employed to reduce any of the impacts identified through the above studies. This should include an evaluation of the potential for recycling and reuse of materials both by other industries and by SMMEs. · As far as possible, mitigation measures for minimising waste and for reducing the risk of spillages should include process and technology related measures, as well as “good practice” guidelines for employees and for equipment maintenance. · Provide and discuss potential monitoring and measuring plans that would be needed by Aluminium Pechiney to assist in managing the environmental impacts identified in the specialist study. · Provide and discuss “sustainability indicators” for the Aluminium Pechiney smelter. This includes indicators such as solid waste produced per ton of product. These sustainability indicators will be compared to similar local and international operations where information is available.
7.2.4 Study of water discharges to the marine environment
The study should consider the impacts associated with the discharge of contaminated process water and stormwater originating from the Pechiney smelter site into the marine environment as well as the impacts of materials spilled at the port. In particular, the study should:
· Provide an examination of the fate of discharges from alternative sites to the marine environment, in terms of the potential risk to the environment under normal conditions, start-up and shut-down, and maintenance operations. · Perform transport and fate modelling to address the fluoride, suspended solids and Poly-Aromatic Hydrocarbon (PAH) constituents in both stormwater and waste water discharges. · Based on the results of the surface water study, model the dispersion rates in the selected discharge areas, and compare predicted levels with national or relevant international standards. · Evaluate the environmental risks associated with the discharge of the liquid waste to the marine environment. · Provide recommendations on site selection, which optimise cost and water quality compliance considerations. · Provide recommendations on the long term monitoring programme, which will ensure that predictions and assumptions remain valid.
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· Provide a detailed review of the permit/licence requirements in terms of the marine legislation. · Identify and discuss any remedial measures that could be employed to reduce any of the impacts identified through the above studies.
7.2.5 Socio-economics study
The specialist study shall address all key issues of social and socio-economic concern which fall within the scope of the Aluminium Pechiney EIA. The terms of reference are as follows:
· Identify the nature and number of new employment opportunities, including upstream and downstream opportunities (for example the additional jobs associated with increased harbour usage and other industrial potential) – this will be based on calculations from the macro-economics study. · Evaluate the infrastructure requirements necessary to meet the demands of an increased labour force. This should include inter alia: o Housing. o Clinics and hospitals. o Domestic waste management facilities. o Water demand and competition for resources. o Transport. · Consider employment opportunities related to the development and further downstream industrial development potential (including the potential for SMME development). · Consider the implications of outsiders arriving in the Coega area in search of employment opportunities. Specific reference to the potential for increased crime in the areas should be evaluated. · Identify benefits that might broadly accrue to the Port Elizabeth-Despatch- Uitenhage-Coega community both directly and indirectly through the proposed construction. Specific reference to current and potential social investment opportunities and projects should be considered. · Evaluate the impact that the proposed construction may have on current and future tourism opportunities in the area. · Identify and discuss any opportunities to maximise or reduce the positive or negative impacts identified through the above studies. · Bear in mind and make reference to possible cumulative impacts. It can be assumed that the development of the aluminium smelter within the IDZ would not happen in isolation. Therefore, there may be one, or a number of other developments taking place simultaneously, which increases the intensity of the potential impacts.
7.2.6 Traffic and transportation study
The transportation specialist study should consider the following aspects:
· Provide a context to the study with respect to the current and planned traffic and
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transportation situation in the Nelson Mandela metro. · Perform a basic analysis on the effect of materials and personnel transport on the road traffic patterns in the PE-Uitenhage-Coega sub-region. · Evaluate the risks associated with the transportation of materials associated with the manufacturing process, including inter alia: o Transport of raw materials from the PE harbour to the site. o Transport of raw materials from the proposed Coega harbour to the site. o Possible long distance transport of raw materials by rail to the site. o The movement of materials on-site. · Assess the possible modes of transport (shipping, road, rail and conveyer) and discuss the advantages and disadvantages of each. · Identify any fatal flaws along the major road and rail routes for the transport of AP’s raw materials, products and personnel (for the different transport scenarios). This should include an assessment of the effect of the various modes of transport on the safety of other users. · Perform a basic assessment on the effect of road transportation on infrastructure and propose remedial measures that may be required. This should include the potential increase in vibrations associated with transport. · Identify measures which will enhance the positive aspects of the smelter in terms of traffic and transport related impacts, for example, opportunities for SMME development in road-based transportation. This will be picked up on by the socio-economic study.
7.2.7 Macro-economics study
This specialist study will address the following macro-economic aspects:
· Provide a brief overview of the respective roles of investments and exports in the South African economy. · Quantify the macro-economic impact of the smelter project both locally, regionally (in the province) and nationally. This will be done in terms of generic macro- economic variables, including employment, and its contributions to the gross domestic product (GDP), for example in terms of profits, remuneration, tax revenues) and the balance of payments (foreign exchange reserves). · The evaluation will consider both the proposed development and upstream and downstream opportunities associated with the proposed project.
7.2.8 Noise study
The specialist study on noise impacts will address:
· The impact of the proposed PAS 2005 project on noise levels, both at the proposed site in the Coega IDZ, at the proposed Coega Harbour, at the PE harbour (during construction only) and for the proposed transport routes from the Coega harbour to the smelter.
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· For noise levels at the IDZ site, place the predicted noise levels from the AP smelter within the context of current and potential future ambient noise levels. · Provide comparisons of predicted noise levels to relevant national and international standards (e.g. World Bank). · The study should propose remedial measures to reduce the potential noise impacts.
7.2.9 Visual impact study
The specialist study on visual impacts will address the following: · The visual impact of the proposed aluminium smelter both at the proposed site in the Coega IDZ, at the proposed Port of Ngqura and the conveyer belt system (during the day and at night). · The visibility and visual impact of the smelter from important tourist routes (taking into consideration new initiatives such as the creation of the Greater Addo Elephant National Park). · Evaluate the predicted magnitude of lighting impacts at St Croix islands which stem from Aluminium Pechiney’s night-time lighting requirements. · For visual impacts at the IDZ site, place the predicted impacts from the smelter within the context of current and potential future developments. · The study should propose remedial measures to reduce the potential visual impacts. These should take into account the visual impact management guidelines currently being prepared for the Coega IDZ. · Potential permit applications must be identified and guidelines provided for satisfying these requirements (e.g. for aviation lights on tall structures).
8. REFERENCES
Barnes K.N. 1998. The Eskom Red Data Book of Birds of South Africa, Lesotho and Swaziland. BirdLife South Africa, Johannesburg. Barnes K.N. 1998. The Important Bird Areas of Southern Africa. BirdLife South Africa, Johannesburg. Branch W.R. 1999. Save our species: Threatened small adders. Africa Environment and Wildlife 7(4): 36-37. CES 2000. Coega Rezoning EIA. Environmental Impact Assessment for the Rezoning of the Core Development Area from Agriculture to Special Purposes –Environmental Impact Report. Coastal & Environmental Services, Grahamstown. CES 2001. Subsequent Environmental Impact Report for the Proposed Port of Ngqura, Coega River, Port Elizabeth. Coastal & Environmental Services. Grahamstown. Coega Implementing Authority 1999. Coega Development Zone: Detailed Planning and Engineering Studies. Framework Plan Report. Port Elizabeth. Coetzee, P.S., Kerley G.I.H., Campbell E.E., de Ruyck A., Woodridge T., Boshoff A. and Bate G. 1996. Zinc Smelter Environmental Impact Assessment: Flora and Fauna Baseline Study for the Coega Precinct. SAB Institute for Coastal Research, Port Elizabeth.
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