SAPPI SOUTHERN AFRICA LIMITED SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE FINAL STAKEHOLDER ENGAGEMENT REPORT
24 JULY 2018 PUBLIC SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE FINAL STAKEHOLDER ENGAGEMENT REPORT
SAPPI SOUTHERN AFRICA LIMITED
TYPE OF DOCUMENT (VERSION) PUBLIC
PROJECT NO.: 41100417 DATE: JULY 2018
WSP BLOCK A, 1 ON LANGFORD LANGFORD ROAD WESTVILLE, DURBAN, 3629 SOUTH AFRICA
T: +27 31 240 8800 F: +086 606 7121 WSP.COM
WSP Environmental (Pty) Ltd. QUALITY MANAGEMENT
ISSUE/REVISION FIRST ISSUE REVISION 1 REVISION 2 REVISION 3
Remarks Final SER
Date 24 July 2018
Prepared by Mpendulo Dlamini
Signature
Checked by Hilary Konigkramer
Signature
Authorised by Hilary Konigkramer
Signature
Project number 41100417
Report number 01
File reference G:\000 NEW Projects\41100417 - Saiccor Project Stone Expansion\42 ES\2-REPORTS SIGNATURES
PREPARED BY
Mpendulo Dlamini, Consultant
REVIEWED BY
Hilary Konigkramer, Director
Purpose and basis of preparation of this Report This Final Stakeholder Engagement Report (Report) has been prepared by WSP Environmental Proprietary Limited (WSP) on behalf and at the request of Sappi Southern Africa Limited, to provide the Client an understanding of the Relevant Documents. Unless otherwise agreed by us in writing, we do not accept responsibility or legal liability to any person other than the Client for the contents of, or any omissions from, this Report. To prepare this Report, we have reviewed only the documents and information provided to us by the Client or any third parties directed to provide information and documents to us by the Client. We have not reviewed any other documents in relation to this Report and except where otherwise indicated in the Report. PRODUCTION TEAM
CLIENT
Saiccor Mill General Manager Krish Naidu
Saiccor Mill SHEQ Manager Craig Daniel
WSP
Project Assistant Mpendulo Dlamini
Environmental Assessment Practitioner Hilary Konigkramer TABLE OF 1 INTRODUCTION ...... 1 1.1 Purpose of this Report ...... 1
CONTENTS 1.2 Objectives of the Stakeholder Engagement Process ...... 1
2 AUTHORITY PRE-CONSULTATION ...... 2
3 STAKEHOLDER NOTIFICATION ...... 2 3.1 Advertisements ...... 2 3.2 Public Notices ...... 3 3.3 Written Notification ...... 5 3.4 Background Information Document...... 6 3.5 Traditional Authority Notification ...... 6
4 STAKEHOLDER DATABASE...... 6
5 DRAFT BASIC ASSESSMENT REPORT .. 6 5.1 Stakeholder Notification of Draft Report Availability ...... 7
6 COMMENT AND RESPONSE REPORT ... 7 6.1 Comments on the Background Information Document ...... 8 6.2 Comments on the Draft Basic Assessment Report ...... 8
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED TABLES TABLE 1: AUTHORITY PRE-APPLICATION CONSULTATIONS ...... 2 TABLE 2: ADVERTISEMENTS: INITIAL STAKEHOLDER NOTIFICATION . 3 TABLE 3: WRITTEN NOTIFICATION REQUIREMENTS ...... 5 TABLE 4: COMMENT AND RESPONSES – WRITTEN NOTIFICATION AND BACKGROUND INFORMATION DOCUMENT ...... 9
FIGURES FIGURE 1: LAYOUT ILLUSTRATING THE POSITION OF THE PROJECT NOTIFICATION POSTERS ...... 4
APPENDICES A AUTHORITY PRE-APPLICATION CONSULTATIONS A-1 Letter from DWS A-2 EDTEA Meeting Minutes A-3 eThekwini Municipality Meeting Minutes B STAKEHOLDER NOTIFICATIONS B-1 Initial Advertisements B-2 Posters B-3 Written Notification B-4 Background Information Document B-5 Traditional Leaders Meetings – Attendance Registers C STAKEHOLDER DATABASE D COMMENTS RECEIVED D-1 Comments in response to the BID
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED 1 INTRODUCTION
1.1 PURPOSE OF THIS REPORT
Sappi Southern Africa Limited (Sappi) is proposing to increase production at the Saiccor Mill. The proposed expansion requires the following: — Environmental Authorisation in terms of the National Environmental Management Act (Act 107 of 1998), as amended (NEMA) and associated Environmental Impact Assessment (EIA) Regulations, 2014 as amended in April 2017; and — Amendment of the Atmospheric Emission Licence (AEL) in terms of the National Environmental Management: Air Quality Act (Act 39 of 2004) (NEM:AQA). WSP has been appointed by Sappi to undertake the function of independent Environmental Assessment Practitioner (EAP) to facilitate the Basic Assessment (BA) process in accordance with the EIA Regulations. The stakeholder engagement process is being undertaken in accordance with the EIA Regulations in order to meet the EA and AEL application requirements. The process aims to ensure that the widest range of potential stakeholders are identified and provided with an opportunity to review the details of the proposed project and submit any issues and concerns. This stakeholder engagement report (SER) describes the stakeholder engagement process that has been undertaken as part of the BA process for the proposed Sappi Saiccor expansion. It forms an appendix to the Basic Assessment Report (BAR) and will be considered by the competent authority, the Department of Economic Development, Tourism, and Environmental Affairs (EDTEA) in its decision on whether to grant the EA for the proposed activity.
1.2 OBJECTIVES OF THE STAKEHOLDER ENGAGEMENT PROCESS
In order to ensure compliance with the applicable national legislation, WSP undertook the stakeholder consultation process in a diligent manner at the outset of the BA process. The NEMA requires an inclusive, transparent process of stakeholder engagement. The objectives of the stakeholder engagement process were as follows: — Ensure an open and transparent BA and consultation process; — Identify and inform stakeholders of the proposed project and associated environmental authorisation process; — Provide an opportunity for stakeholders to raise all issues, concerns and questions and ensure that these are considered in the BA process; — Ensure that stakeholders have an opportunity to make a meaningful contribution towards decision making by EDTEA, and — Compile issues, concerns and questions raised by stakeholders and responses (from the EAP and the applicant) in the form of a comments and responses table.
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 1 2 AUTHORITY PRE-CONSULTATION
Pre-application consultation meetings were held with the relevant authorities, namely the eThekwini Municipality, Department of Water and Sanitation (DWS), the EDTEA and the Tribal Authorities of the surrounding tribal areas. These meeting were held in February and April 2018 (Table 1). Table 1: Authority Pre-Application Consultations
Authority Meeting date
Department of Water and Sanitation 02 February 2018 and 05 February 2018
Department of Economic Development, Tourism 09 February 2018 and Environmental Affairs. eThekwini Municipality 28 February 2018
A summary of each of the authority meetings held is provided below. — DWS meeting: an overview of the proposed project was given and a discussion held on whether the project requires a Water Use Licence in terms of the National Water Act (Act 36 of 1998). DWS advised that the proposed expansion project does not trigger any WUL requirements as it is proposed to occur within the existing Mill footprint on existing hardstanding areas. This was confirmed in writing by DWS on 09 February 2018 (Appendix A).
— EDTEA meeting: an overview of the proposed project was given, the approach to the environmental authorisation process was presented and initial comments and guidance received from EDTEA. EDTEA confirmed acceptance of the legal framework and approach to the EIA. The minutes of the meeting, including attendance register, are attached in Appendix A.
— eThekwini Municipality meeting: an overview of the proposed project was given, and the approach to the proposed Air Quality Impact Assessment discussed. The minutes of the meeting, including attendance register, are attached in Appendix A.
3 STAKEHOLDER NOTIFICATION
WSP elected to notify stakeholders of Sappi’s intention to submit an Application for Environmental Authorisation and an Application for Amendment of an AEL in respect of the proposed expansion of the Saiccor Mill. The purpose of this early notification was to: — Ensure that those who have an interest in participating in the EIA process had an opportunity to register as Interested and Affected Parties (I&APs); and — Provide some information on the project in advance of the provision of the Draft Basic Assessment Report (BAR) for public comment (in the form of a Background Information Document (BID); and — Provide the opportunity for stakeholders to submit any initial comments or questions they may have in respect of the project.
3.1 ADVERTISEMENTS
Newspaper advertisements were placed, in accordance with the NEMA EIA Regulations, formally announcing the intention to submit an Application for EA and an Application for Amendment of an Atmospheric Emission Licence (AEL) for the proposed expansion project.
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 2 English advertisements were placed in numerous publications (the Mercury, Mid-South Coast Rising Sun and the Mid-South Coast Mail), and an isiZulu advertisement was placed in the Isolezwe (Table 2). Advertisement wording and proof of publication is provided in Appendix B. Table 2: Advertisements: Initial Stakeholder Notification
Publication Date of Placement The Mercury 12 March 2018 Isolezwe 12 March 2018 Mid-South Coast Rising Sun 13 – 19 March 2018 Mid-South Coast Mail 13 – 19 March 2018
3.2 PUBLIC NOTICES
The EIA Regulations require site notices to be fixed at places conspicuous to the public at the boundary or on the fence of the site where the activity (to which the application relates) is to be undertaken, as well as at any alternative sites. Posters, conforming to the size specifications of the EIA Regulations (A2: 420 X 594 mm), were placed in English and isiZulu at the following locations on 13 March 2018 (Figure 1): — alongside the road that leads to the Sappi Saiccor Mill off the N2, — Sappi Saiccor entrance, — alongside the Lignotech SA boundary, and — Umkomaas SuperSpar notice board. The poster format and proof of placement is included in Appendix B.
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 3 Figure 1: Layout illustrating the position of the project notification posters
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 4 3.3 WRITTEN NOTIFICATION
Section 41 of the 2014 EIA Regulations states that written notification must be given to the stakeholders outlined in Table 3. Table 3: Written Notification Requirements
Stakeholder EAP Comment (i) the owner or person in control of that land if the Not applicable as Sappi is the owner of the land on which applicant is not the owner or person in control of the activity will take place. the land (ii) the occupiers of the site where the activity is or The site of the activity is the existing Sappi Saiccor Mill. is to be undertaken or to any alternative site There are no occupiers of the site where the activity is to where the activity is to be undertaken be undertaken. (iii) Owners and occupiers of land adjacent to the LignoTech South Africa (a 50:50 joint venture between site where the activity is or is to be undertaken Sappi S.A. and Borregaard AS of Norway) is located or to any alternative site where the activity is to adjacent to the Saiccor Mill on land owned by Sappi. be undertaken LignoTech SA, as the partial occupiers of the land adjacent to the site, have been notified by email. There are a number of small business tenants which occupy premises located on Sappi owned land adjacent to the Mill. The tenants were included in the stakeholder database and were provided with written notification via email. (iv) the municipal councillor of the ward in which The Municipal Councillor for Ward 99, Mrs Buyisiwe the site or alternative site is situated and any Gumede, was notified by email. organisation of ratepayers that represent the community in the area (v) the municipality which has jurisdiction in the Written notification was issued to the EThekwini area Municipality (various departments) by email. (vi) any organ of state having jurisdiction in respect The organs of state that have jurisdiction over the activity of any aspect of the activity are the KwaZulu Natal Department of Economic Development, Tourism and Environmental Affairs and the eThekwini Municipality. These two organs of state were notified by email, as well as a range of other government organs which are included in Sappi’s stakeholder database. These include; the Department of Environmental Affairs, Department of Water and Sanitation and the Department of Transport. (vii) any other party as required by the competent The competent authority has not specified any other authority. parties which need to be notified. Other general stakeholders and interested and affected parties included in the stakeholder database were notified by email. These include general citizens, traditional authorities as well as Non-Governmental-, and Community Based Organisations.
Notification was undertaken via email on 19 March 2018. A second email was sent to newly added stakeholders on 20 April 2018. In addition to the stakeholders listed in Table 3, all stakeholder included in the initial stakeholder database were provided with written notification. The written notification and proof of distribution is provided in Appendix B.
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 5 3.4 BACKGROUND INFORMATION DOCUMENT
A Background Information Document (BID) was developed at the outset of the project (Appendix B). The purpose of the BID was to; - Provide a brief introduction to the proposed project; - Provide an outline of the process being followed; - Advise stakeholders of the manner in which they can be involved in the process - Inform members of the public of their rights and responsibilities regarding participation in the process; - Encourage stakeholders to comment on the project, ask questions and raise issues that should be included in the Basic Assessment process. The BID was sent by email with the written notification. These documents were sent to all personnel listed in the stakeholder database. Traditional Authorities received hardcopies of the BID.
3.5 TRADITIONAL AUTHORITY NOTIFICATION
The traditional authorities of the surrounding areas were notified through a series of two meetings that were held at the Illovo Karridene Protea Hotel on 06 and 13 April 2018. At the meetings the proposed project was explained and the written notification and BID documents were distributed. The meeting’s attendance registers are included in Appendix B.
4 STAKEHOLDER DATABASE
Stakeholders with a potential interest in the project were identified at the project outset, and continue to be identified throughout the application process. The stakeholder database has been developed and will be maintained throughout the BA process (Appendix C). The database contains the details of known stakeholders, and those who registered with an interest in the project as a result of the notification process.
5 DRAFT BASIC ASSESSMENT REPORT
The Draft BAR was be made available for to all stakeholders for a 30 day comment period from 20 June 2018 to 20 July 2018. Hard copies of the report were be provided to the relevant regulatory and local authorities for comment. The report was be made available to stakeholders as follows: — Umkomaas Public Library — From WSP on request — Online on the WSP website: http://www.wspgroup.com/en/WSP-Africa/What-we-do/Services/All- Services-A-Z/Technical-Reports/
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 6 5.1 STAKEHOLDER NOTIFICATION OF DRAFT REPORT AVAILABILITY
Section 40(1) of the EIA Regulations requires that all potential or registered stakeholders be provided a period of 30 days to submit comments on the BAR. Advertisements will be placed and a written notification circulated to all stakeholders on the database to advise all potential stakeholders of the availability of the BAR for review and comment.
5.1.1 ADVERTISEMENTS Newspaper advertisements were placed, in accordance with the NEMA EIA Regulations, formally announcing the availability of the Draft BAR for comment. The notices will encourage members of the public to register as stakeholders in order to participate in the BA process. English and isiZulu advertisements were placed in the same media as the initial notifications published (Section 3.1). English advertisements were placed in numerous publications (the Mercury, Mid-South Coast Rising Sun and the Mid-South Coast Mail), and an isiZulu advertisement was placed in the Isolezwe (Table 4). Advertisement wording and proof of publication is provided in Appendix B. Table 4: Advertisements: Initial Stakeholder Notification
Publication Date of Placement The Mercury 22 June 2018 Isolezwe 22 June 2018 Mid-South Coast Rising Sun 26 June 2018 Mid-South Coast Mail 29 June 2018
5.1.2 NOTIFICATION All stakeholders listed within the stakeholder database were notified of the availability of the Draft BAR for comment. A written notification that formally announced the availability of the Draft BAR for comment was circulated by email. All those stakeholders that do not have access to email were sent a SMS notification. The written notification letter and proof of email and SMS distribution is included in Appendix B.
6 COMMENT AND RESPONSE REPORT
Written comments received from the stakeholders have been captured on this section of the report. All comments have been captured and responses have been provided by the applicant and EAP for consideration by the lead authority, the EDTEA.
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 7 6.1 COMMENTS ON THE BACKGROUND INFORMATION DOCUMENT
To date, comments have been received from the distribution of the written notifications and the BID. The comments received and associated responses are presented in Table 5. Copies of the original comments are included in Appendix D.
6.2 COMMENTS ON THE DRAFT BASIC ASSESSMENT REPORT
All comments received on the Draft Basic Assessment Report have been responded to in Table 6. Copies of the original comments are included in Appendix D.
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 8 Table 5: Comment and Responses – Written Notification and Background Information Document
NO. COMMENT RESPONSE
1. Diane Van Rensburg, eThekwini Municipality – 19 March 2018 (via email)
1.1 Please will you register eThekwini Municipality as an Interested and Affected Party. Would WSP responded to eThekwini Municipality and advised that the BID was prepared largely to you like me to provide consolidated comments on the BID application, bearing in mind that provide an overview of the proposed expansion project, and did not contain sufficient detail to it will take at least three weeks to process? form the basis of detailed comments. It was suggested that the BID be reviewed as background information and formal comments be facilitated on the Draft BAR.
2. Rosemary Owen, Phelamanga – 19 March 2018
2.1 We currently provide the facilitation for the Sappi Saiccor CAF (community Forum) where Phelamanga’s contact details have been added to the stakeholder database to ensure they are kept Sappi provide regular reporting on their current emissions, and this provides an opportunity informed during the BA process. A presentation of the Draft Basic Assessment Report can be for the community, the authorities and Sappi to proactively address any concerns or issues as provided at an appropriate time. they occur. We would like to be kept informed, and are able to also share any information with our existing database, we would also welcome a presentation or feedback regarding the outcomes of the basic assessment when they are available.
3. Judy Bell , Coast Watch – 19 March 2018 (via email)
3.1 Please register me as an IAP for this project – I am a member of Coastwatch KZN and Contact details have been added to the stakeholder database. would like to receive updates by email. My concerns relate to:
3.2 — Use of water from a seriously oversubscribed river, impacts from discharges to The proposed expansion of the Mill will not result in additional water requirements from the estuary and sea Umkomaas River. It is proposed that with the implementation of Project Vulindlela and Project Stone that the water consumption of the Mill will reduce. Currently spent calcium cooking liquor is supplied to LignoTech SA and the remainder is disposed of via the marine outfall. The project proposes a reduction in the Mill’s calcium cooking process, thereby reducing the amount of effluent generated and ultimately disposed of. Further information will be provided in the Draft BAR.
3.3 — Need to reuse and recycle water internally as well as to take water from the The Mill currently reuses and recycles water within its production process, most notably during the eThekwini regional WWTW for treatment and reuse. washing, screening and bleaching process. The treatment and reuse of water from the eThekwini regional WWTW is outside of the scope of the proposed Mill expansion. Discussions in this regard have been held, and will continue to be
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 9 held, between the relevant parties. This is a complex issue, and the Mill’s requirements with regard to water quality require specific consideration.
3.4 — Best practice implementation, not merely legal compliance. Sappi Saiccor is committed to best practice implementation. The proposed expansion provides the opportunity for the Mill to address some of the operational challenges and implement significant environmental improvements. The design engineers, AF Consult, have proposed process changes that are in line with international best practice.
4. Andrew Cobb – WESSA – Coast Watch, 21 March 2018
4.1 The new Sappi Mill Expansion not clear on: Currently spent calcium cooking liquor is supplied to LignoTech SA and the remainder is disposed of via the marine outfall. The project proposes a reduction in the Mill’s calcium cooking process — Handling additional lignosulphate disposal thereby reducing the amount of effluent generated and ultimately disposed of. A reduced number of calcium digesters will remain to ensure supply of spent liquor to maintain the LignoTech SA’s operations.
4.2 — Boiler scrubber capacity and sulphur fume eradication The expansion project proposes significant environmental improvements including improved emissions, in particular reduced sulphur dioxide emissions. An Air Quality Impact Assessment has been undertaken in support of the proposed expansion project. The findings of this assessment will be presented in the Draft BAR.
5. Mike Bentley, Empisini in Scottburgh - 23 March 2018 (via email)
5.1 Please continue to send me information to this e-mail address. I am a Sappi pensioner living Contact details have been added to the stakeholder database. in the area.
6. Henry Reddy (Technical Services Manager), LignoTech South Africa – 30 April 2018 (via email)
6.1 I would like to register as a stakeholder. My contact details are as follows. Please send all Contact details have been added to the stakeholder database correspondences via email.
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 10 Table 6: Comment and Responses – Draft Basic Assessment Report
WSP COMMENT RESPONSE REF.
7. Department of Water and Sanitation – 05 July 2018
Reference is made to the above-mentioned document received by this Office on 20 June 2018. This Department has the following comments with regard to the proposed development:
1.1 1. The content of the letter sent by this Department to Sappi Saiccor is noted. This Noted. In the event that water pollution issues arise during or post construction, this Office requests that water pollution issues during and post construction must be will be reported to Department of Water and Sanitation as required. reported to this Department as required in terms of Section 20 of the National Water Act, 1998 (Act No. 36 of 1998) (NWA).
1.2 2. Stormwater Management Plan on site must be upgraded to accommodate the A Stormwater Management Plan is in place for the existing Mill operations. This plan proposed expansion and must be submitted to eThekwini Metropolitan will be updated to accommodate the proposed expansion, and included in the plans Municipality for approval. approval submission to eThekwini Municipality.
1.3 3. General and hazardous waste accumulated during the construction phase must The EMPr (Appendix H of the BAR) includes the necessary management actions for be disposed at a permitted / licensed landfill site. Disposal certificates must be general and hazardous waste. The EMPr includes the requirement that all waste kept on record. generated must be disposed of at a licenced landfill site and disposal certificate must be retained as proof of this disposal.
1.4 4. There must be no unacceptable impact on the quality of both surface and Noted. The DWS will be notified in the event of pollution of surface or groundwater groundwater in the area. If pollution of any surface or groundwater occurs, it resources, and appropriate measures will be employed. must be immediately reported to this Department and the appropriate mitigation Sappi conducts annual groundwater monitoring on an ongoing basis. measures must be employed. In addition, should the proposed development impact on any groundwater and/or surface water users, then water of equal quality and quantity must be provided to the affected users.
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 11 1.5 5. It is important that any significant spillage of chemicals, fuels, etc. during the In the event of a significant spill or incident, this will be reported to DWS and the construction phase and/or operational phase is reported to this Office and other relevant authorities. The EMPr (Appendix H of the BAR) contains spill control relevant authorities. In the event of a spill, the following steps can be taken: measures. Stop the source of the spill; Contain the skill; All significant spills must be reported to this Department and other relevant authorities; Remove the spilled product for treatment or authorised disposal; Determine if there is any soil, groundwater or other environmental impact; If necessary, remedial action must be taken in consultation with this Department and the Department of Economic Development, Tourism and Environmental Affairs; Incident must be documented.
1.6 Notwithstanding the above, the responsibility rests with the Applicant to identify any Noted. source or potential source of pollution from his undertaking and to take appropriate measures to prevent any pollution of the environment. Failure to comply with the requirements of the National Water Act (Act 36 of 1998) could lead to legal action being instituted against the Applicant. This reply does not grant any exemption from the requirements of any applicable Act, Ordinance, Regulation or Bylaw.
8. Anti-Pollution Watch Dog, Mr MA Naicker – 17 July 2018
2.1 We take a closer look at prominent environmental challenges in Umkomaas the The need and desirability of the expansion project is presented in Section 4.1 of the factors that drive them and their impact on our natural environment and livelihoods. BAR. It is emphasised that the proposed project has a strong focus on environmental Climate change is one of the most compounding challenges that the people of South improvement. The proposed expansion will result in a number of improvements Africa are facing, irrespective of where or how they live. including:
Taking your 6.5 billion rand expansion into consideration, we very well know that (1) Significant decrease in SO2 emissions the bigger the plant gets, the more toxic waste and SO2 will be released. (2) Reduction in waste volumes generated by the Mill
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 12 (3) Reduction in fossil fuels (4) Improvement in effluent quality due to reduced calcium cooking
2.2 1. Sappi should utilize 1 billion to lower their emissions. Do not release chemicals The project involves a significant investment (more than R1 billion) in environmental and SO2 at night or early hours of the morning when people are asleep. improvement, with the focus being on a reduction in emissions. One of the positive
outcomes of this proposed project is a reduction in SO2 emitted from the Mill and an
associated significant decrease in ambient SO2 at community receptors surrounding the Mill. The Mill operates 24 hours a day and operations are consistent during day and night.
2.3 2. Our poor locals that live along side the fence line and also surrounding areas of Under the current emission scenario, concentrations of emitted gases stay within health Sappi are victims of pollution in early hours of the morning. You can get bad standards (the National Ambient Air Quality Standards, NAAQS) beyond the fenceline smells from across the devils corridor that’s emmiting from the plant. during normal operations of the plant. However, under upset conditions, exceedences
of the hourly SO2 NAAQS can be experienced at community receptors. As presented in the Atmospheric Impact Report (AIR) (Section 7, page 55), Sappi propose
improvements to the Mill to ensure that these SO2 emission events are limited and
normal operating conditions are maintained. As such, ambient concentrations of SO2 are predicted to be maintained below the NAAQS. The term “devils corridor” is not understood. However, from an odour perspective – Sappi has an existing Odour Management Plan and a well-established complaints procedure for logging and addressing community concerns.
2.4 3. It would be very good to have Sappi and the expansion consider the plight of our The proposed project does have the potential to generate employment opportunities for people and also meet with their demands. Create jobs for our locals and local people. The BAR contains the anticipated employment requirements associated consider those that are suffering with asthma, lukima and cancer. with the projects which are summarised below: Construction phase: 2080 skilled individuals 1120 unskilled individuals Operational phase:
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 13 114 skilled individuals 11 unskilled individuals Given the high unemployment rate, the proposed positive socio-economic benefits of the project are considered to be significant. The continued security of employment and potential to increase employment associated with the construction and operational supply chains are considered indirect benefits of the project. Sappi Saiccor is committed to local community upliftment. Contractors employed will be required to source employment locally. In addition, community members will be trained at the Mill’s skills centre in order to ensure they have the skills to be employed during the project implementation. The Mill’s commitment extends beyond the project scope and includes further commitment to community upliftment and employment, as previously presented to SDCEA.
2.5 4. NB 40% of our locals are asthmatic due to Sappi’s emissions. Sappi should be Sappi is committed to ensure that their facility does not impact negatively on the heath held responsible for the locals health and well being and it would be only fair if of the local community. Community health care is, however, the responsibility of Sappi builds a fully fledged asthmatic clinic. government.
9. eThekwini Municipality – 18 July 2018 (DRAFT)
With reference to the abovementioned Draft Basic Assessment Report, please be advised that various Municipal Departments have had sight of the proposal and the following comments are submitted for your attention:
3.1 1. eThekwini Electricity Department The H.V. Department has no objection however please note: No objection to the project is noted.
3.1.1 1.1. The applicant must consult eThekwini Electricity’s main records (held in the Noted. The proposed expansion will take place within the Mill boundary, as such the drawing office at eThekwini Electricity Headquarters, 1 Jelf Taylor Crescent, presence of underground services is well understood as all electrical services have been for the presence of underground electrical services. In addition should any
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 14 overhead line and/or servitude be affected, the specific permission of the installed by Sappi. Notwithstanding, Sappi will confirm the presence of underground Head: Electricity must be sought regarding the proposed development. electrical services prior to any construction commencing. In the event that any overhead lines and/or servitude may be affected, permission will be sought from the relevant authorities.
3.1.2 1.2. The relocation of MV/LV electrical services, if required in order to Noted. accommodate the proposed development, will be carried out at the expense of the applicant.
3.2 2. Environmental Planning and Climate Protection Department The Draft Basic Assessment for the Sappi Saicor Mill Expansion (Project Vulindlela and Project Stone) refers.
3.2.1 This Department has no biodiversity objection to the project being granted No objection to the project is noted. environmental authorisation if the mitigation and management measures contained in the Environmental Management Programme (EMPr) are implemented as recommended to ensure minimisation of the potential impacts.
3.3 3. Land Use Management Branch
3.3.1 No objections provided that the proposed expansion takes place within the existing No objection to the project is noted. boundary of the Saiccor Mill on existing hard-standing areas, as stated in the Draft The National Building Regulations will be adhered to. Basic Assessment Report. In addition, any new buildings will require the submission of building plans in terms of the National Building Regulations.
3.4 4. Strategic Spatial Planning Branch
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 15 3.4.1 The Strategic Spatial Planning Branch supports the proposed Vulindlela and Project Support for the project is noted. Stone within the existing mill boundary in Umkomaas to increase the production of elemental chlorine free dissolving wood pulp in order to remain globally competitive.
3.4.2 The Strategic Spatial Planning Branch’s comments for the abovementioned Noted. application are subject to the following: 4.1. This Branch’s support is subject to the applicant meeting all sector requirements. 4.2. This support should not be deemed to be an approval of the eThekwini Municipality. 4.3. This Branch reserves the right to comment further should the need arise.
3.5 5. Coastal, Stormwater and Catchment Management No objection to the project is noted. This Department has no objections.
3.6 6. Parks, Leisure and Cemeteries No objection to the project is noted. This Department has no objections.
3.7 7. Pavement and Geotechnical Engineering No objection to the project is noted. No geotechnical objection.
3.8 8. eThekwini Transport Authority
3.8.1 Please note that the Traffic Engineering Branch has no objections to the Draft Basic No objection to the project is noted. Assessment Report for the proposed Expansion to Sappi Saiccor Mill, located on The necessary approvals will be obtained prior to submission of building plans. Portion 656 of Umkomanzi Drift – 1357 as the road network utilised for assessing the site is predominantly provincial. However approval is required from KZN
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 16 Department of Transport (KZNDoT) and South African National Roads Agency (SANRAL) prior to submission of building plans. The following documents were considered in this application: Draft Basic Assessment Report compiled by WSP Environmental for Sappi South Africa Limited, dated 18 June 2018. Traffic Impact Assessment complied by WSP, dated 29 March 2018
3.9 9. Environmental Health Department This Department has the following comments regarding the Draft Basic Assessment Report.
3.9.1 9.1 Chemicals must be contained and stored correctly to avoid water or river The EMPr (Appendix H) contains management measures that will ensure that all of the contamination. recommendations listed are addressed. 9.2 Ensure management of waste water and safe disposal of solid waste. 9.3 All precautionary measures to minimize noise to the acceptable standards are maintained in terms of Noise Control Regulations. 9.4 Ablution facilities must be provided for workers at the construction site. 9.5 All waste generated during the construction phase should be disposed of at an approved landfill site and records thereof should be kept. 9.6 Air quality impacts during the construction phase must be suitably monitored.
3.9.2 The mitigation measures outlined on the EIA document appear to be suitable. In this Support for the project is noted. The recommendations above are included in the regard the Health Department is in support subject to all the above recommendations EMPr being implemented.
3.10 10. eThekwini Water and Sanitation Department No objection to the project is noted. Wastewater Design Branch. No objection to the proposed expansion.
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 17 3.11 11. Durban Solid Waste At the time of submission, comments had not yet been provided by Durban Solid Waste.
3.12 12. Disaster Management Noted. The Mill’s on-site emergency response plan will be reviewed and updated if necessary. Sappi Saiccor is proposing to expand the mill in Umkomaas. This will include increasing the above ground storage of various chemicals at the chemical plant. A preliminary risk assessment has been undertaken and the conclusions are that the expansion will not cause the major hazard risks to become unacceptable. Sappi must however review and where necessary update the on-site emergency response plan taking into account the increase in hazardous material inventories.
3.13 13. Fire Safety At the time of submission, comments had not yet been provided by Fire Safety
10. eThekwini Municipality Health Unit – 19 July 2018
The Health Unit does not support the draft Basic Assessment report however would be Various meetings were held with Ethekwini Health during the course of the project. A prepared to reconsider should the below-mentioned be suitably addressed. meeting was scheduled for 17 July 2018 to present the Draft BAR but unfortunately, eThekwini Health were unable to attend. WSP is of the opinion that most, if not all, of the comments raised, could have been addressed at this meeting.
4.1 A full mass and energy balance is required of the system in order to apportion the Mass balances (we cannot determine the relevance of energy here) for PM, SO2 and contribution of fugitive emissions, stack emissions and area sources to the overall NO2 from point sources are provided on pages 31-33 of the AIR. emission inventory. This would better focus efforts towards the most significant Whilst the mass balance diagrams can be amended to represent emissions from the area sources onsite. The mass and energy balances should be submitted in a PDF format sources (stockpiles), this is unconventional since these emissions lie outside of the to show stream properties using proper process engineering software. The mass process flow and is unlikely to add much value. balance must account for the following priority pollutants (PM, SO , NO ) generated 2 2 The specification for ‘pdf format’ is confusing as the entire document was submitted in onsite. pdf format. The use of ‘proper’ process engineering software is contested since this is not an engineering report and the process flow is represented clearly in the current format.
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 18 This request lies outside the requirements of the Regulations Regarding Air Dispersion Modelling, Government Notice 533 of 2014 and Regulations Prescribing the Format of the Atmospheric Impact Report, Government Notice 747 of 2013. It is WSP position that the mass balances provided contain sufficient information to support the application.
4.2 The predicted Particulate matter results appear to be an underestimation. Therefore No ‘actual’ data is available because these are proposed scenarios. If the project is actual particulate matter data is required to supplement the modelling. approved, isokinetic monitoring data will meet this requirement and modelling scenarios can be rerun in line with the reality. Engineering calculations offer current predictions for these proposed scenarios. There is no basis supplied for the contention that current engineering calculations are an ‘underestimate’. Data was provided by the client-appointed international engineering design consultants, AF and is as per BAT. The contention that this is an underestimate questions the integrity of the client in supply of this data.
4.3 The actual ambient sulphur dioxide one-hour standard data from the Sappi Under the current emission scenario, concentrations of emitted gases stay within health monitoring stations does not correlate with the predicated baseline. All sulphur standards (the National Ambient Air Quality Standards, NAAQS) during normal dioxide ambient data must be within NAAQS. operations of the plant. However, under upset conditions, exceedences of the hourly SO2 NAAQS can be experienced at community receptors. As presented in the AIR
(Section 7, page 55), Sappi propose improvements to the Mill to ensure that these SO2 emission events are limited and normal operating conditions are maintained. As such,
ambient concentrations of SO2 are predicted to be maintained below the NAAQS.
4.4 The predicted nitrogen dioxide results appear to be an underestimation. Therefore No ‘actual’ data is available because these are proposed scenarios. If the project is actual nitrogen dioxide data is required to supplement the modelling. approved, continuous stack monitoring data will meet this requirement and modelling scenarios can be rerun in line with the reality. Engineering calculations offer current predictions for these proposed scenarios.
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 19 There is no basis supplied for the contention that current engineering calculations are an ‘underestimate’. Data was provided by the client-appointed international engineering design consultants, AF and is as per BAT. The contention that this is an underestimate questions the integrity of the client in supply of this data.
The physical parameters of the MgO3 emission point are provided in Table 5-1 on 4.5 Provide specification for MgO3 boiler including emissions, streams, inputs and page 34 of the AIR. abatement control technology. Emissions from MgO3 are provided in Table 5-2 on page 35 of the AIR. Streams/inputs are provided in Figures 5-10 and 5-11 on pages 32 and 33 respectively of the AIR. Abatement technology on MgO3 (a Venturi scrubber plant, 5 stage as per MgO2) is provided in Table 3-3 on page 12 of the AIR. Ethekwni Health are familiar with the current technology utilised at the Mill, including MgO2 recovery boiler. The proposed MgO3 recovery boiler is effectively a duplicate of MgO2 (both of which will include an additional scrubbing stage that will result in improved emissions).
4.6 The projects proposed to reduce sulphur dioxide is vague and does not provide The explanations for the decreases in SO2 emissions is adequately detailed in the AIR adequate detail. Additional information is required in terms of the expected as summarised below: reductions. CFBS: Reduced coal usage (pages 9, 11, 30 of the AIR); MgO2: Additional stage on MgO2 scrubber (pages 12 and 55 of the AIR). Although not included in the scope of the expansion project there is a proposed
upgrade to the efficiency of the washpit scrubber that will further limit SO2 emissions (as per Section 7 on page 55 of the AIR). Since this decrease could not be quantified at the time of modelling, emissions at the washpit scrubber were conservatively assumed to run as at present (Table 5-2 on page 35 of the AIR).
4.7 Project plans are required for all projects highlighting net reductions of priority Noted. pollutants. Actual monitoring will also be required of priority pollutants including
PM, NO2 and SO2 at the completion of each project to confirm predicted results.
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 20 This monitoring to be completed prior to commencement of any subsequent project phases.
4.8 There is no mention of odour and VOC’s emanating from the facility nor mitigation The existing Odour Management Plan was provided as Appendix C to the AIR. This measures to address odour and VOC’s. The previous assessment conducted by WSP Odour Management Plan refers explicitly to management of total reduced sulphur does not suffice. compounds (including hydrogen sulphide, dimethylsulphide, dimethyldisulphide and methyl mercaptan) and volatile organic compounds (including methanol, acetic acid, formic acid, formaldehyde, methyl glyoxal, furfural and cymene) from the facility. Results of emission testing of these compounds at emission points with potential for odour (washpit scrubber, MgO1 outlet and LTSA evaporator vents) are provided in the Odour Management Plan. The Odour Management Plan (Appendix C) describes a low concentration gas collection system that transfers odorous gas streams to the recovery boilers for destruction. The two recovery boilers are monitored continuously for TRS and excess oxygen by online instrumentation. Further, as mentioned on page 30 of the AIR, VOC profiles along the process streams are highly variable and, as such, snapshot values on a static profile diagram are misleading and thus excluded from the profile diagrams and further modelling. A previous assessment (WSP Report 20222: Saiccor Post Expansion AQIA, 2013) showed that ambient VOC impacts resulting from measured stack concentrations are negligible.
4.9 It is of concern that a new increase in PM and NO2 is predicted. Any increase in EThekwini Health’s statement regarding lack of support on the basis of the proposed these priority pollutants cannot be supported. PM and NO2 increase is disappointing. Predicted increases are well within the NAAQS, which is the legal framework limiting ambient health impacts. The overall improvement in emissions from the Mill is focused on the current pollutant of concern,
namely SO2.
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 21 The increases in PM10 and NO2 are due to environmentally conservative emission assumptions associated with increased use of the diesel train and increase in size of the woodchip stockpile.
Increases in NO2 emissions environmentally conservatively assume that proposed SO2
abatement will not decrease NO2 emissions. In reality, the SO2 abatement will result in
a decrease in NO2. Despite environmentally conservative estimates of increases in these emissions, ambient concentrations at all receptor points are well within NAAQS:
3 Peak receptor long-term average concentrations of PM10 increase to 1.62 µg/m at Craigieburn (NAAQS is 40 µg/m3). 3 Peak receptor P99 24-hour concentrations of PM10 increase to 8.54 µg/m at Drift (NAAQS is 75 µg/m3). 3 Peak receptor long-term average concentrations of NO2 increase to 7.26 µg/m at Dlambula (NAAQS is 40 µg/m3). 3 Peak receptor P99 hourly concentrations of NO2 increase to 110.38 µg/m at Drift (NAAQS is 200 µg/m3).
4.10 An account of GHG’s and its impact must be disclosed. It is anticipated that the proposed project will result in a 10% reduction in GHG emissions from the facility due to significant reductions in fossil fuel usage. Sappi submits the required annual GHG disclosures to the relevant authority.
4.11 The Department of Environmental Affairs must be informed about the proposed The Department of Environmental Affairs: Oceans and Coasts was notified of the expansion to ensure the changes in effluent quality do not impact on the marine proposed expansion and of the availability of the Draft BAR for comment. As reported environment. A more recent study must be done to determine the status of the in Section 7.10 of the draft BAR, the effluent quality is proposed to improve as a result impact from the Sappi Saiccor effluent line as all studies mentioned in the draft BAR of the expansion project and will remain well within the limits specified in the Coastal are out dated. Waters Discharge Permit. Section 6.13 of the draft BAR refers to studies done by the CSIR which confirmed that the marine outfall does not have a negative impact on marine flora and fauna. This section also notes that ongoing annual marine surveys are conducted and that no negative impacts have been reported.
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 22 The most recent annual survey was conducted in 2017, and the 2018 survey is currently underway.
11. CoastWatch – 20 July 2018
5.1 Thank you following up and reminding us of the comment deadline. Unfortunately Noted. Coastwatch has not been able to review the report and will not be submitting comment.
12. AMAFA – 20 July 2018
6.1 We acknowledge receipt of your invitation for comment with regards to the proposed No objection noted. development. The object of Amafa is to administer, conserve and protect heritage resources of the Province within the terms of KZN Heritage Act no. 4 (2008) and the National Heritage Resources Act No 25 of 1999. The proposed development footprint was surveyed by eThembeni in 2005 and no heritage resources were recorded on this site. The Environmental Practitioner has indicated that the structures that require expansion are not older than 60 years. Amafa therefore has no objection to the development.
6.1 You are also required to adhere to the below-mentioned standard conditions: The EMPr has been updated to include the conditions listed by Amafa. Conditions: 1. Amafa should be contacted if any heritage objects are identified during earthmoving activities and all development should cease until further notice. 2. No structures older than sixty years or parts thereof are allowed to be demolished altered or extended without a permit from Amafa. 3. Under no circumstances may any heritage material be destroyed or removed from site unless under direction of Amafa and a heritage specialist.
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 23 4. Should any remains be found on site that is potentially human remains, the South African Police Service (SAPS) should also be contacted. No SAPS official may disturb or exhume such remains, whether of recent origin or not, without the necessary permission from Amafa. 5. No activities are allowed within 50m of a site, which contains rock art. 6. Sources of all natural materials (including topsoil, sands, natural gravels, crushed stone, asphalt, etc.) must be obtained in a sustainable manner and in compliance with the heritage legislation.
6.3 Failure to comply with the requirements of the National Heritage Resources Act and The relevant legislation pertaining to heritage resources will be adhered to. the KwaZulu Natal Heritage Resources Act could lead to legal action being instituted against the applicant. This decision is valid for a period of two years.
13. South Durban Community Environmental Alliance – 20 July 2018
7.1 Terms of Reference WSP is required by the NEMA EIA Regulations to be impartial and independent in their role as Environmental Assessment Practitioner (EAP). To this affect, WSP has We need you to provide the contract of appointment as we want to assess whether signed a declaration of independence confirming their independence and that they have WSP will act impartial and without bias. no vested interest in the outcome of the decision on the proposed project.
7.2 Project Overview Sappi considered a number of alternatives in respect of the proposed expansion of their global business. Section 4.1 of the BAR provides a description of the need and Why have you not investigated other sites? Why Sappi Saiccor was chosen to expand desirability of the project, and Section 5 outlines the various alternatives associated – we need valid reasons for this. Why is your current production levels on both phase with the expansion at the Saiccor Mill site. one and phase two? What are your project margins and projected profit as well as your projected turnover? Phase 1 (Project Vulindlela) proposes a production increase to 890 000 tons/annum, and Phase 2 (Project Stone) proposed a further increase to 1 050 000 tons/annum.
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 24 Project margins, profits and turnover is commercially sensitive information and has no bearing of the application for environmental authorisation.
7.3 Benefits:
7.3.1 Please tell us what are your current permanent staff, and casual staff? The Section 6.14 of the BAR states that the Saiccor Mill currently employs 1 160 people on demographics of where your staffs are from? We need accurate and proper informed a permanent basis. More than 60% of permanent staff reside in the communities information supported by the departed labour and detailed addresses to ascertain the adjacent to the Mill. There are no casual staff employed at the Mill. benefits to Umkomaas and Magabeni community members.
7.3.2 How many will be employed through the contractual phase and where will the labor Section 7.9 of the BAR provides the anticipated employment opportunities during the force come from? What percentage of equipment will be made locally by local construction and operational phase, which are summarised below: workforce? Additionally what percentage will labor of local contractor’s be given Construction phase: contracting opportunities? 2080 skilled individuals 1120 unskilled individuals Operational phase: 114 skilled individuals 11 unskilled individuals Given the high unemployment rate, the proposed positive socio-economic benefits of the project are considered to be significant. The continued security of employment and potential to increase employment associated with the construction and operational supply chains are considered indirect benefits of the project. Sappi Saiccor is committed to local community upliftment. Contractors employed will be required to source employment locally. In addition, community members will be trained at the Mill’s skills centre in order to ensure they have the skills to be employed during the project implementation.
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 25 7.3.3 Please provide us with evidence and information of your current operation including All information relevant to the proposed expansion project has been provided. Any expert reports done by CSIR / other independent unbiased experts as well as the information requested that does not pertain to the application for environmental information that informs your air emission licenses and all schedule permits. authorisation is outside of the scope of this project.
7.4 Technology: The technology utilised for the production of chemical cellulose from hardwoods is not unique to South Africa, is it used throughout the world. We request you provide where this technology is used in first world countries. What legislative regime that’s used to hold this technology in compliance. Please explain The Mill is governed by the laws of South Africa, as such operational compliance is to us how an increase in production can fund the environmental improvements? Why required in terms of the relevant South African laws. have you not budgeted for environmental improvements as per your licenses and Sappi is committed to continual environmental improvement and legal compliance. permits as required under law to fulfil obligations as a company complying with There is a programme of continuous improvement; however the proposed expansion NEMA, section 24 of the South African Constitution Bill of Rights, Air quality act, project provides the opportunity for significant improvement through the installation of Waste act and the King 2 and 3 Commission, labor act, department of labor and new equipment. The Mill has to grow to remain globally competitive. occupational health and safety.
Please explain what you mean by significant expansion in detailed information. A The scope of the expansion is outlined in the BAR. As the project is an expansion of full EIA and all risk and concerns must be analysed by screening and quantified by an existing facility, the legal requirements is for the project to be subjected to a Basic environmental experts. Assessment process in terms of the NEMA EIA Regulations. WSP is suitably qualified to undertake the assessment.
We want full participation with regards to your atmospheric emission licenses as this The public participation process requirements for the AEL amendment and Basic must be known through a credited and evaluated process. Information must be honest Assessment process have been met. Information relevant to this application has been and truthful reviewed and peer reviewed paid for by Sappi and chosen by the made available for review. community. A peer review of all documentation is not deemed necessary. No specific issues have been raised with the findings of any of the specialist studies, which would warrant a peer review of any of these studies.
7.5 Project team:
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 26 7.5.1 Is in house and appointed and paid for by Sappi Saiccor therefore all information put WSP is required by the NEMA EIA Regulations to be impartial and independent in through a peer review process. Appointed by the affected communities and I&APs their role as Environmental Assessment Practitioner (EAP). To this affect, WSP has paid for by Sappi Saiccor. signed a declaration of independence confirming their independence and that they have no vested interest in the outcome of the decision on the proposed project. All specialists have signed declarations of independence which are included in the BAR (Appendix A). A peer review of all documentation is not deemed necessary. No specific issues have been raised with the findings of any of the specialist studies, which would warrant a peer review of any of these studies.
7.5.2 As this project proposes a significant expansion at the mill and may have a The proposed project includes significant environmental improvements that will significant impact and create more environmental problems that presently improve the overall impact of the Mill on the environment. With the implementation experienced. of the EMPr, no adverse or unacceptable impacts are anticipated.
7.5.3 This process must be put through a full scoping EIA and external review of the As the project is an expansion of an existing facility, the legal requirements is for the concerns and impacts that we have identified to ensure that alternative sites are project to be subjected to a Basic Assessment process in terms of the NEMA EIA investigated. Particularly as issues of water, land, flora and fauna, agriculture, marine Regulations. As documented in the BAR, the process has included consideration of life, health, food, energy is fully examined in this expansion. alternatives and consideration of a broad range of environmental aspects.
7.6 Procedural framework:
7.6.1 A full EIA process needs to be followed from a basic assessment until a full EIA As the project is an expansion of an existing facility, the legal requirements is for the process is fulfilled and completed. project to be subjected to a Basic Assessment process in terms of the NEMA EIA Regulations.
7.6.2 The questions we raise regarding this section is why have you not looked at other In their decision to expand their global operations, Sappi considered a number of other sites such as Sappi Ngodwana or Sappi Stanger? We don’t want desk top studies but sites both here in South Africa and in other countries. The decision was taken on the proper sight inspections based on physical information and research and evidence to basis of the current and predicted market demand for chemical cellulose (a product not produced at all Sappi Mills). Research undertaken is commercially sensitive.
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 27 back the information presented in this document. We want site visits, focus group Information has been made available for reviewing, including a Background meetings and all information available to us for viewing. Information Documents and the Draft BAR. SDCEA is welcome to contact the Saiccor Mill to arrange a site visit.
7.7 Methodology: Section 7 of the BAR provides a description of the anticipated construction and operational phase impacts associated with the proposed expansion of the Mill. The WSP have not considered the impacts and has not been adequately shown. significance of the impact identified were assessed using a recognised impact Communities are aware of Sappi’s incidents regarding the gas pipeline leak that assessment methodology. The results of the impact assessment are presented in affected Sappi staff, Umkomaas Drift Primary school which had to be relocated and Section 8 of the BAR, and the detailed assessment appended in Appendix G of the multiple nearby community residents of Magabeni and Craige Burn were BAR. hospitalized due to this gas leak in 2006. Regrettably, references to incidents and dates are inaccurate and difficult to respond to. Here is a link to the above mentioned Sappi Incident: There is no gas pipeline to the facility; the article referenced described an incident https://midsouthcoastrisingsun.co.za/5282/watchdogs-attack-pollution-by-sappi- where detergent was released accidentally into the estuary in 2016. Numerous studies saiccor/ were undertaken to confirm that there was no long term impact on the estuarine and Furthermore, the effluent pipeline into the Umkomaas River affected the marine life marine environment. and the livelihoods of subsistence fishermen of Umkomaas. Section 6.13 of the draft BAR refers to studies done by the CSIR which confirmed that There is no risk assessment and this site is in close proximity to communities, the the marine outfall does not have a significant negative impact on marine flora and risk must be done and why isn’t this featured in this basic assessment report due to fauna. This section also notes that ongoing annual marine surveys are conducted and the reputation of Sappi and its incidents? that no negative impacts have been reported. The most recent annual survey was conducted in 2017, and the 2018 survey is currently underway. A preliminary risk assessment has been undertaken by an Approved Inspectorate Authority, Ishecon, which considered the major risk to employees and communities surrounding the Mill. The assessment confirmed that the proposed project represents an insignificant change to the risk profile of the mill and that no unacceptable risk will be posed to the public. A detailed MHI Risk Assessment is currently underway in order to meet the necessary legal requirements.
7.8 Public participation: Appendix B contains all the relevant documentation associated with the stakeholder engagement process followed to date. Meetings that were held are documented and proof of newspaper advertisements placed. All comments submitted by stakeholders
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 28 Appendix B there is nothing captured or provided under this section which is meant have been responded to. WSP have not received any requests for further engagement to indicate your Stakeholder Engagement and why is this not captured here? Where by community leaders or community members. The public participation activities did WSP host meetings and what was the outcome of your meetings held? Where are undertaken meet and exceed the legal requirements specified in the EIA Regulations; the minutes of your meeting/s? and are considered adequate for this application. Also where are the registers of this meeting and who attended? WSP have not captured the advertisements put into local newspapers and we want to see evidence of these advertisements, including English, isiZulu and Afrikaans and provide pamphlets as communities have stated that WSP have not held any public participation meetings in their communities. WSP needs to explain and give proper responses that can be verified within the stakeholder engagement. Public participation meetings were held by Sappi Saiccor only. Why is this case when this should have been held by WSP the appointed consultants? Many residents have come forward and stated WSP have not hosted any public participation meetings and why is this?
7.9 Location of the site: Project Vulindlela and Project Stone are proposed to occur within the existing boundary of the Sappi Saiccor Mill site. The proposed additional infrastructure, WSP doesn’t mention in project context any alternative sites and how did you get to equipment and processes are inextricably linked to the existing facility; therefore there this decision? And why did you choose this site? are no feasible or reasonable site alternatives.
7.10 Health Impacts of chemicals: Manganese is not used at the Saiccor Mill. Manganese which is a chemical used on the Sappi Saiccor Site – has a chronic health The cooking process is described in the BAR. No additional production processes are benchmark value of 50ng/m³ (RfC, US EPA IRIS, 2004) was derived from human proposed, the expansion involves the reduction in the calcium cooking process and an data from occupational exposure with the critical endpoints of impairment of increase in the magnesium cooking process. All chemical reactions take place in neurobehavioral function, especially speed and coordination of motor function. contained vessels under controlled and monitored conditions. This project will increase power generation from renewable energy. In the event of the cooking process that WSP makes mention of this is actually a reaction process where chemicals react with one another and WSP uses a play on words where they downplay the impacts of such reactions.
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 29 Also you make mention of reducing coal and in its place you make no mention of what would be taking its place? What are you replacing other gases with? What about renewable energy? And there is no mention of the hidden costs that will arise out of this project.
7.11 Surrounding land use: Section 4.2 of the BAR provides the project context. Section 4.2.2 describes the surrounding land uses associated with the Mill in detail including residential Why Sappi hasn’t done proper measurements according to the distances from the communities, schools, shops, agricultural activities, and water features. The figures mill to the residential areas, schools, agricultural land, shops and water features? This presented are considered sufficiently accurate. is not adequate and not accurate. Why did they not get accurate figures of closeness of site?
7.12 Upgrade of bleach plant: Pictures provided depict a Section 30 incident reported to the relevant authorities. This incident occurred when detergent was released accidentally into the estuary in 2016. Numerous studies were undertaken to confirm that there was no long term impact on the estuarine and marine environment. Sappi has put additional controls in place to prevent the reoccurrence of such an incident.
Pictures Above and Right: Sappi Saiccor leaking detergent straight out to sea outfall
7.13 Calcium and magnesium: Section 4 of the BAR provides a description of the mill production process and the proposed expansion. The increase in chemical storage is outlined in Section 7.5. What are the total inputs? What are the range of chemicals and what chemicals are in this range?
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 30 7.14 Water treatment plant: The proposed project does not include changes to the water treatment plant. What are the chemicals used? Is it chlorine? How will WSP evaluate the effluent and Sappi undertake continuous monitoring of their effluent prior to disposal via the sea its treatment before being disposed of? Why are they persisting in use of coal and ash outfall. which are high in Sulphur dioxide and cancer causing agents? The proposed project will result in a reduction in coal usage and associated ash generation and sulphur dioxide emissions due to an increase in renewable energy.
7.15 Coal lime slurry: All stacks are monitored on a continuous basis and this information is reported to the authorities on a monthly basis. Sulphur dioxide that emitted comes out as white smoke and in this case do you have in stack monitoring? Why hasn’t Sappi provided monitoring results? Explain to us The explanations for the decreases in SO2 emissions is adequately detailed in the AIR the SO2 recovery plant will reduce emissions from the stacks. Additionally we need as summarised below: to know figures and what will be the increased amounts. CFBS: Reduced coal usage (pages 9, 11, 30 of the AIR); MgO2: Additional stage on MgO2 scrubber (pages 12 and 55 of the AIR). Although not included in the scope of the expansion project there is a proposed
upgrade to the efficiency of the washpit scrubber that will further limit SO2 emissions (as per Section 7 on page 55 of the AIR). Since this decrease could not be quantified at the time of modelling, emissions at the washpit scrubber were conservatively assumed to run as at present (Table 5-2 on page 35 of the AIR).
7.16 Calcium digesters: The project involves the reduction in calcium cooking process at the Mill. Effluent from the remaining calcium cooking process will continue to be sent to LignoTech SA You do not mention the size in your proposal? Will this cooking liquid be sent for the recovery of calcium lignosulphonate. There will be a reduction of Ca effluent through the pipeline? Where is all the waste going to be dumped? This is not produced from the calcium cooking process. mentioned in this basic assessment report and why? Black liquor refers to the spent magnesium liquor from the cooking process which is You make mention of a black liquor evaporators and we want to know more about thickened by evaporation to a suitable consistency to allow for combustion in the this liquid and what its used for and more details to be provided about this. recovery boiler. Refer to Section 4 of BAR that described the Mill production process.
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 31 With proposed new equipment and added loads to the existing capacity there is no The AIR includes an overview of current and proposed electricity generation mention of the increase in electricity. What are your current outputs? associated with the Mill.
7.18 Timeframe: The expansion of the Saiccor Mill is proposed to take place within the existing footprint of the site. The project triggers a requirement for a Basic Assessment in Sappi has a huge footprint currently and with this proposed expansion added to this terms of the NEMA EIA Regulations. The anticipated impacts associated with the current load there will be significant impacts. This is why we want a full EIA project have been identified and adequately assessed. conducted as this expansion will have a huge impact than what’s stated by WSP.
7.19 Decommissioning: There is no decommissioning proposed as part of this project. The proposed expansion will take place on the existing Mill footprint. Of materials are not explained? Soil contamination on the Sappi site as well as the bleach plant leaks have contributed to this – how is this going to be tested, is this Sappi undertakes annual groundwater monitoring. going to be taken to hazardous dumpsites to be disposed of?
7.20 Working hours: The Saiccor Mill operates 365 days per year, 24 hours a day. The operational process must remain continuous due to the nature of the production process. Sappi exists in and surrounds residential homes and communities and currently exploit working hours and persist throughout the night causing significant noise impacts currently.
7.21 Magnesium oxide:
7.22 Have had compound effects on marine life especially at Aliwal Shoal which is the Section 6.13 of the draft BAR refers to studies done by the CSIR which confirmed that remains of an ancient sand dune – a world heritage site and this has not been the marine outfall does not have a significant negative impact on marine flora and investigated. fauna. This section also notes that ongoing annual marine surveys are conducted and that no significant negative impacts have been reported. The most recent annual survey was conducted in 2017, and the 2018 survey is currently underway.
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 32 7.23 There needs to be alternatives and an investigation on the recovery boiler. As well as Refer Section 5 of BAR which covers the alternatives associated with the proposed there is no information on the turbine capacity and there is no explanation as to why project adequately; and provides the anticipated turbine capacity. chosen.
7.24 What is the current storage capacity on site? This has not been disclosed or reasons Section 7.5 of the BAR includes a summary of the current and proposed chemical for this nondisclosure? storage requirements.
7.25 No Project Alternative: Section 5.4 of the BAR described the anticipated implications of the no-project alternative. As the proposed project will result in significant environmental WSP cannot hold communities around Sappi to ransom if Sappi’s operation already improvement, these benefits would not be realised should the project not proceed. contributes significantly to environmental issues that have not been addressed. They must be fined and Sappi has a history of its pollution. Sappi Saiccor have an Emergency Response Plan in place and communicate regularly with the relevant local government emergency response personnel. “The no project alternative would mean that the inherent efficiencies obtained from upgrading production capacity at the same time as reducing atmospheric emissions would be lost. Therefore, the no project alternative is not considered to be reasonably viable.” With regards to this statement WSP has a history of doing this for their clients and this should not be accepted. There is no emergency plan should something go wrong such as previous gas leak incidents and community residents were hospitalized.
7.26 Local meteorology: The AIR contains wind roses and receptor diagrams which provides sufficient information in respect of local meteorology. Please explain wind speed and direction to the nearest house, nearest school, nearest farm. Do you do continuous monitoring? Why is there data from 2014-2016 only? Continuous emission and ambient monitoring is undertaken. We live in the south and most of our winds come up in the night winds are often Regulations Regarding Air Dispersion Modelling, Government Notice 533 of 2014 strong but also calm – we request why we do not have wind speeds for 2017 and require 3 full years of recent of local meteorological data. At the commencement of 2018 and before 2014. How can this plant be expanded when all the monitoring the project, the most recent 3 years of data were 2014 – 2016. stations are non-compliant? They don’t predict future emissions that will have Under the current emission scenario, concentrations of emitted gases stay within health detrimental effects on people’s health and wellbeing? standards (the National Ambient Air Quality Standards, NAAQS) beyond the fenceline
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 33 during normal operations of the plant. However, under upset conditions, exceedences
of the hourly SO2 NAAQS can be experienced at community receptors. As presented in the Atmospheric Impact Report (AIR) (Section 7, page 55), Sappi propose
improvements to the Mill to ensure that these SO2 emission events are limited and
normal operating conditions are maintained. As such, ambient concentrations of SO2 are predicted to be maintained below the NAAQS. Proposed emission scenarios for Project Vulindlela and Project Stone are provided in Table 5-2 on Page 35 of the AIR.
7.27 Geology: The proposed project will take place within the existing Mill boundary. The geology of the site is described in Section 6.3 of the BAR. Sappi conduct ongoing groundwater What passed activities disturbed the soil? Oil, chemicals please explain in detailed monitoring annually. information.
7.28 Flora and fauna: Section 6.5 of the BAR provides a description of the Flora and Fauna in the vicinity of the Saiccor Mill. The proposed expansion will take place within the existing Indigenous vegetation has not been provided. There is a diverse rich species of operational areas within the boundary of the Mill. The operational areas within the animals but this has not been recorded, but WSP state there is none. How have they Mill boundary are devoid of vegetation. The site does not provide suitable habitat for done their research when there are a range of bird species prominent in the area? the majority of the fauna that occurs in the broader area. Given that this is an existing industrial site, the level of information provided in the report is considered adequate.
7.29 Hydrology: Section 6.8 of the BAR states that annual groundwater monitoring is carried out on the site. As the proposed project will take place within the Mil boundary and on existing What chemicals are present in the bore holes and what’s in the water? Have they hard standing areas, the project is not envisaged to have an impact on groundwater. tested the water especially in the tribal farming areas? There is mention of annual ground water carried on site, what have you found onsite and offsite?
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 34 7.30 Noise levels: Regulations Regarding Air Dispersion Modelling, Government Notice 533 of 2014 require 3 full years of recent of local meteorological data. At the commencement of You’ve provided us with noise levels for April 2018, why haven’t you provided us the project, the most recent 3 years of data were 2014 – 2016. with air quality data for 2018? Why is this and also why is noise not provided for 2014? There have been many noise levels and no toll number to complain and record Recent noise data was utilised for the Environmental Acoustic Impact Assessment. complaints. The road is used by trucks, buses, and not just cars. Data is available for 2014 but was not included in the study as the more recent data was deemed adequate for the assessment. The Mill has a well-established complaints procedure for logging and addressing community concerns.
7.31 Distances: Section 4.2.2 (Page 16) provides a general description of the land uses surrounding the Mill including distances to community areas. This information was sourced from the Distances differ from those on page 16 to those on page 43 huge differences in Mill’s AEL and was included to provide a broad overview of the context in which the distance and something is wrong in the surrounding land use. Noise levels acceding Mill operates. now what will the noise be when the site expansion is ten times the size now? How can you allow this plant to go ahead? Section 6.9 (Page 43) provides the distance from community receptors selected for inclusion in the Environmental Acoustic Impact Assessment. These distances were measured by the acoustic specialist as part of their study. The Environmental Acoustic Impact Assessment (Appendix D) concluded that the noise increases proposed are slight and likely to go unnoticed.
7.32 Traffic: A Traffic Impact Assessment is appended to the BAR (Appendix E). The additional truck movements are assessed. How many more trucks are going to be added to the 600? Noise levels and increase not mentioned and why?
7.33 Water abstraction: There will be no increase in abstraction of water from the Umkomaas River. No mention of using water from the river and the site is going to expand drastically? why is this not featured here when the current usage Sappi has been licensed to use is 53 million m³ from the Umkomaas River?
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 35 7.34 Effluent management: Section 6.13 of the draft BAR refers to studies done by the CSIR which confirmed that the marine outfall does not have a significant negative impact on marine flora and How are you going to manage manganese oxide as this poses a serious risk to marine fauna. This section also notes that ongoing annual marine surveys are conducted and life and the Aliwal Shoal heritage site? Studies done 2005 on sea outfall why aren’t that no negative impacts have been reported. studies done after 2005? The most recent annual survey was conducted in 2017, and the 2018 survey is Why is there no worst case scenario assessment of nearest household impact? With currently underway. chlorine and manganese being released into the air? The Mill does not use manganese. Emissions from the Mill have been assessed in the AIR (Appendix C).
7.35 Expropriation of land: The proposed project will take place within the existing Mill boundary. There will be no expansion of the Mills footprint and no expropriation of land. Are they going to be using more land?
7.36 Socio-economic: The socio-economic implications of the proposed expansion project have been described in Section 7.9 of the BAR. The information provided is considered relevant Provide us with an organogram of your current workforce and where jobs are located to the scope of the application. as this is not featured here. How much have you exported in 2018? Gross domestic product- what benefit is this to South Africans? Why 2003 statistics and not the last five years statistics? What are your levels of unemployed plantation staff? As once in ten years you will provide jobs on the plantations and thereafter this workforce is unemployed for the next ten years?
7.37 Last water user: The proposed expansion will not impact on resorts, guesthouses or other industries. The quality of the effluent is anticipate to improve as such no adverse impact is Are the resorts, guesthouses, small industries dependent on marine and beach anticipated on marine environment. environment for business use contaminated water.
7.38 Vehicle emissions: Vehicles emissions are considered in the AIR (Appendix C).
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 36 Not discussed and why is there no monitoring on this? The use of the diesel train but A social enhancement study is not deemed necessary for this project. the socio- no mention of the noise caused? This is an indication of predicted noise levels and economic impacts of the project have been identified and assessed in Section 7.9 of the not actual noise levels. BAR No social enhancement study of current situation and no mention of it done.
7.39 Waste removal: A preliminary risk assessment has been undertaken by an Approved Inspectorate Authority, Ishecon, which considered the major risk to employees and communities How are we going to measure hazardous chemicals? How are we going to know this? surrounding the Mill. The assessment confirmed that the proposed project represents The risk assessment is supposed to be conducted now and not later. an insignificant change to the risk profile of the mill and that no unacceptable risk will There needs to be an indication of how many workers have been affected on site over be posed to the public. A detailed MHI Risk Assessment is currently underway in the years. order to meet the necessary legal requirements. We also have not seen the negative noise levels. All waste streams have been classified. All workers are subjected to annual surveillance medicals. An Environmental Acoustic Impact Assessment (Appendix D) has been undertaken to assess the anticipated impact of the proposed expansion.
7.40 Way forward: The list provided on the way forward is a summary of the issues raised, which have been addressed in the line items above; in summary: We need independent experts. WSP’s independence has been confirmed; We need all of these questions answered and not overlooked All questions raised have been responded to Safe disposal certificates will be retained as per the EMPr requirements We need cradle to the grave certificates The impacts of the proposed expansion have been adequately assessed and We need a health study to be done in Umkomaas to assess the impacts on health included in the BAR. from the polluter Sappi A full Scoping and EIA is not required for this project. In terms of the legal framework (NEMA EIA Regulations), a Basic Assessment process is A full EIA needs to be conducted required.
14. KZN Department of Economic Development, Tourism and Environmental Affairs: Oceans and Coasts – 20 July 2018
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 37 8.1 May you kindly confirm if the above mentioned project will affect the current Sappi The proposed effluent quality will remain well within the Mill’s CWDP limits as saiccor's Coastal Waters Discharge Permit conditions. If it will, please stipulate the described in Section 7.8 of the BAR. The conditions stipulated in the CWDP remain sections and mitigation measures. valid.
SAPPI SAICCOR EXPANSION: PROJECT VULINDLELA AND PROJECT STONE WSP Project No. 41100417 July 2018 SAPPI SOUTHERN AFRICA LIMITED Page 38 APPENDIX
A AUTHORITY PRE- APPLICATION CONSULTATIONS APPENDIX
A-1 LETTER FROM DWS
APPENDIX
A-2 EDTEA MEETING MINUTES MEETING NOTES
JOB TITLE Sappi Saiccor Expansion: Project Vulindlela and Project Stone
PROJECT NUMBER 41100417
DATE 09 February 2018
TIME 10:00am
VENUE EDTEA offices, 17th Floor, Commercial City Building, 40 AB Zuma Street, Durban.
SUBJECT Pre-Consultation Meeting
CLIENT Sappi Southern Africa Limited: Saiccor Mill
PRESENT EDTEA - Vanessa Maclou (MC) - Yugeshni Naicker (YG) Sappi - Craig Daniel (CD) WSP - Hilary Konigkramer (HK)
APOLOGIES None
DISTRIBUTION As above
ATTACHMENTS Attendance Register and PowerPoint Presentation
MATTERS ARISING ACTION
HK opened the meeting by thanking the Department of Economic Development, Tourism and Environmental Affairs (EDTEA) for making the time to meet to discuss the future development plans at the Sappi Saiccor Mill. HK confirmed that the objectives of the meeting were to: (1) Introduce the proposed expansion project (2) Present the approach to the Environmental Authorisation (EA) process (3) Receive initial comments / guidance from the EDTEA HK and CD provided a powerpoint presentation which covered the following: (i) a project overview; (ii) a summary of the legal framework associated with the project; (iii) an overview of the approach to the EA process and the anticipated timeframes. A summary of the key discussion points from the meeting is provided below: KEY DISCUSSION POINTS (1) EDTEA confirmed acceptance of the broad legal framework (Basic Assessment and AEL amendment). The applicable Listing Activities were discussed and agreed. (2) Specialist studies: — EDTEA support the proposed Traffic and Air Quality Impact Assessment (AQIA) specialist studies. — EDTEA recommended that odour be considered in the AQIA. WSP is to ensure that there is a correlation between AQIA and Traffic studies (i.e. traffic emissions to be included in AQIA).
Block A, 1 on Langford Langford Road Westville, Durban, 3629 South Africa
T: +27 31 240 8800 F: +27 31 240 8801 www.wsp.com MEETING NOTES
— EDTEA recommended that Noise be adequately considered, as this is likely to be an issue raised by stakeholders. Whilst it is acceptable to address noise within the Basic Assessment Report, it was recommended that a standalone, high level, Noise Impact Assessment be undertaken. — EDTEA agreed that the timeframes presented for the Basic Assessment process were acceptable. EDTEA requested a meeting be held once the Draft Basic Assessment Report (BAR) is circulated whereby WSP will present the content of the BAR to EDTEA and EThekwini Health. — EDTEA suggested the BAR include background to the mill i.e. projects that are ongoing that do not require EA (Project Morris etc.) for context. — EDTEA support WSP’s approach in respect of circulating a Background Information Document (BID) as it provides information for review and comment prior to the BAR being made available. This will allow WSP to address comments/issues in the Draft BAR, reducing the extent of comments/changes in the Final BAR. EDTEA recommended that WSP include sufficient technical detail in the BID.
INFORMAL DISCUSSION ON PILING ACTIVITIES: (1) WSP motivated for commencement of piling activities (associated with the new recovery boiler) on the basis that (i) these activities are currently ongoing at the Mill and don’t require an EA, and (ii) the intention of the trigger for the boiler is to govern the operational phase impacts (i.e. AEL requirement is for emissions). (2) EDTEA advised that piling for the boiler would constitute commencement of the listed activity associated with the boiler which refers to “expansion of existing facilities and infrastructure….need for a permit or licence…” and that the term “expansion” inherently implies construction related activities. EDTEA confirmed that there is no legal mechanism for commencement of a listed activity prior to receipt of the EA. (3) EDTEA was sympathetic to the challenge Sappi faces in respect of construction related timeframes and made the following suggestions in terms of expediting commencement of the project: (i) EDTEA are willing to start the review of the application on receipt of the Draft Basic Assessment Report (~ end May) in order to improve the decision making timeframes. Based on the dates provided by WSP (Draft BAR by ~end May 2018 and Final BAR submitted in July 2018) it would be possible for EDTEA to provide a decision in September 2018 (a month earlier than the forecasted October 2018 timeframe). (ii) Modifications to the mill that do not trigger the need for an EA and that can be constructed and operated in isolation of the broader project can commence. The critical aspect of this is that modifications made must be entirely independent of the expansion project scope i.e. can operate without the associated infrastructure proposed as part of the EA application.
Page 2
21/02/2018
09 February 2018
Sappi Saiccor Expansion Project Vulindlela and Project Stone
Authority Pre-Consultation: EDTEA
Meeting Agenda
— Introduction — Project Overview — Legal Framework
2 — Approach and timeframes — Discussion
1 21/02/2018
Meeting Objectives
— Introduce the project — Present the approach to the Environmental Authorisation process and associated permits / licences 3 — Receive initial comments / guidance from relevant authorities
09 February 2018
Project Overview
2 21/02/2018
Project Vulindlela/Stone delivering on strategy 2017
Vision 2020
next phase growth
intentional evolution
Craig Daniel Risk Manager – Saiccor Mill Sappi Southern Africa
5
Introduction
• To remain globally competitive Saiccor needs to expand • Competitive base is not only defined by production but environmental performance (community and customer) • Therefore expansion has been separated into two phases • 1. Vulindlela or the Environmental Phase (Priority) – 890 000 tpa • 2. Stone – Significant capacity increase – 1 050 000 tpa • Expected Projected Expenditure R5.5 Billion • Expansion within existing footprint
6
3 21/02/2018
Environmental Improvement
Tons 783 000 tpa 1050 000 tpa D% Employment (direct) 1 312 1 437 9% Water 6 022 m3/h 5 585 m3/h 7% Effluent 5 237 m3/h 5 080 m3/h 5%
SO2 1,66 t/d 1,44 t/d 13% COD 1 536 t/d 877 t/d 43%
CO2(fossil) 2 176 t/d 902 t/d 59% Waste 195 t/d 120 t/d 39%
7
Project Summary
Project Vulindlela (Phase 1): — Increased woodyard input — Reduced production from Ca digesters — New MgO line – additional MgO digesters (~8)
8 — New recovery boiler & SRP — New evaporator — New washing and screening plant — Upgrade bleach plant — Upgrade pulp machines
4 21/02/2018
Project Summary
Project Stone (Phase 2): — Increased chip screening — Additional MgO digesters (~5) — New washing and screening plant
9 — New evaporator — New bleach plant — New pulp machine — New turbine to produce power and steam
09 February 2018
Legal Framework
5 21/02/2018
Legal Framework
Legal Review: — National Environmental Management Act — National Environmental Management: Air Quality Act
11 — National Environmental Management: Waste Act — National Water Act — National Heritage Resources Act
Legal Framework: NEMA EIA Regulations
Listing Notice 1 (GNR 327) – Requirement for Basic Assessment
Activity Description Applicability
34 The expansion of existing facilities or The proposed expansion will 12 infrastructure for any process or activity require an amendment of the where such expansion will result in the Mill’s Atmospheric Emission need for a permit or licence or an Licence (AEL). The primary amended permit or licence in terms of activity, which triggers Activity national or provincial legislation 34, is the proposed new governing the release of emissions, recovery boiler (Phase 1). effluent or pollution, excluding—
6 21/02/2018
Legal Framework: NEMA EIA Regulations
Listing Notice 1 (GNR 327) – Requirement for Basic Assessment
Activity Description Applicability
37 The expansion and related operation of Sappi will add a new turbine 13 facilities for the generation of electricity (TG8) that will produce power from a non-renewable resource where – (45MW ) and low-pressure (i) The electricity output will be increased steam (Phase 2). The power to by 10 megawatts or more, excluding be produced will be for Sappi’s where such expansion takes place on own consumption, as such, there the original development footprint; or will be no export of power to the (ii) Regardless of the increased output of national grid the facility, the development footprint will be expanded by 1 hectare of more
Legal Framework: NEMA EIA Regulations
Listing Notice 1 (GNR 327) – Requirement for Basic Assessment Activity Description Applicability
51 The expansion and related operation Sappi propose to expand their of facilities for the storage, or storage storage of chemicals, in above 14 and handling, of a dangerous good, ground storage tanks (Phase 2), where the capacity of such storage in excess of 80m3, at the facility will be expanded by more than Chemical Plant. 80 cubic metres.
7 21/02/2018
Legal Framework: NEMA EIA Regulations
Listing Notice 1: — Activity 31 (decommissioning): not applicable — Activity 45; 46 (expansion of bulk infrastructure): not applicable — Activity 48 (infrastructure in/32m of watercourse): not applicable — Activity 56 (roads): not applicable
15 Listing Notice 2: — No activities applicable – expansion project
Listing Notice 3: — None of the biodiversity, conservation or ecological parameters listed in Listing Notice 3 apply to the Saiccor Mill site
09 February 2018
Approach and Timeframes
8 21/02/2018
Approach
— Application for Environmental Authorisation: Basic Assessment — AEL Amendment Application 17 — Specialist studies —Traffic Impact Assessment —Air Quality Impact Assessment
Approach
Public Participation: — Public Announcement: Feb 2018 —Adverts,
18 —Site Posters, —Written Notification —Background Information Document (comment period) — Draft BAR and EMPr: 30 day comment period
9 21/02/2018
Anticipated Timeframes
— Authority pre-consultation: Early February 2018 — Public announcement: February 2018 — Draft Basic Assessment Report: ~ May 2018
19 — Public comment period: ~ June 2018 — Final Basic Assessment Report: ~ July 2018 — Decision: ….
Discussion
wsp.com
10 APPENDIX
A-3 ETHEKWINI MUNICIPALITY MEETING MINUTES MEETING NOTES
JOB TITLE Sappi Saiccor Expansion: Project Vulindlela and Project Stone
PROJECT NUMBER 41100417
DATE 28 February 2018
TIME 12:30pm
VENUE Ethekwini Health Office, Archie Gumede Place, Central Durban, Durban, 4000
SUBJECT Pre-Consultation Meeting
CLIENT Sappi Southern Africa Limited: Saiccor Mill
PRESENT EThekwini Health - Bruce Dale (BD) - Modise Molefe (MM) - Nazmeera Ismail (NI) - Sam Sewlall (SS) - Neil Larratt (NL) - Prenthan Chetty (PC) - Phumulani Ngema (PN) Sappi - Craig Daniel (CD) WSP - Hilary Konigkramer (HK) Lisa Ramsay (LR)
APOLOGIES None
DISTRIBUTION As above
ATTACHMENTS Attendance Register and PowerPoint Presentation
MATTERS ARISING ACTION
HK opened the meeting by thanking the EThekwini Health Department for making the time to meet to discuss the future development plans at the Sappi Saiccor Mill. HK confirmed that the objectives of the meeting were to: (1) Introduce the proposed expansion project (2) Present the approach to the Environmental Authorisation (EA) and Atmospheric Emission License (AEL) Amendment process (3) Receive initial comments / guidance from the EThekwini Health HK and CD provided a powerpoint presentation which covered the following: (i) a project overview; (ii) a summary of the legal framework associated with the project; (iii) an overview of the approach to the EA process and the anticipated timeframes.
Block A, 1 on Langford Langford Road Westville, Durban, 3629 South Africa
T: +27 31 240 8800 F: +27 31 240 8801 www.wsp.com MEETING NOTES
LR provided an overview of the methodology that will be followed for the Air Quality Impact Assessment (AQIA) study to be conducted. A summary of the key discussion points from the meeting is provided below: KEY DISCUSSION POINTS (1) NL stated that the city is likely to support the project on the basis of job creation and economic growth. However, the most important consideration for the EThekwini Health Unit is the degrees to which ground level SO2 levels will be reduced. WSP and Sappi provided NL with a brief overview of the Project Morris project and that challenges that were initially experienced with discrepancies between model outputs and the monitoring data. The recent work by WSP has resulted in a better understanding of the Mill’s emissions, specifically ground level SO2 levels. (2) NL asked whether the expansion project would result in a stop in current emissions exceedences. This needs to be the basis of the project approval. The Mill must operate in compliance with legal requirements. CD responded by stating that the expansion project will result in a significant improvement in the ambient environment. NL stated that the issues is not whether the improvement is significant, but rather whether it is acceptable or not – to EThekwini Health and the local communities. (3) WSP confirmed that there will be no additional AEL Listed Activities triggered by the expansion project, over and above what is currently included in the Mill’s license. (4) NL asked what the current situation was in respect of encroachment of communities on the Mill. CD responded by saying that Sappi communicates regularly with community leadership with regard to settlement encroachment. Sappi continues to appeal to community leaders to manage this issue, however this is an ongoing challenge. (5) BD was interested to know what issues or comments had been raised by EDTEA at the meeting held with them earlier in the month. HK provided a brief overview of the meeting held with EDTEA on 09 February 2018. HK noted that EDTEA was in agreement with the proposed approach to the Basic Assessment Process and the key comments made by EDTEA were as follows: (i) EDTEA recommended that a standalone Noise Impact Assessment study be undertaken (rather than addressing noise as a section within the Basic Assessment Report); and (ii) EDTEA requested a meeting be held with EThekwini Health where the Draft Basic Assessment Report is presented. This will allow EDTEA and EThekwini Health to engage collectively in respect of comments and aspects relating to the project. (6) NL supported the recommendation that a standalone Noise Impact Assessment be undertaken. NL asked whether baseline noise monitoring would be done in the community areas around the Mill. WSP confirmed that this was the case. (7) BD confirmed his support for an integrated engagement with EDTEA on the findings of the EIA and AQIA studies. (8) EThekwini Health confirmed that they are happy with the approach and methodology proposed for the AQIA study. LR advised that WSP would submit a Plan of Study in a letter to EThekwini Health which would confirm the proposed methodology, to which EThekwini could respond.
Page 2
19/06/2018
28 February 2018
Sappi Saiccor Expansion Project Vulindlela and Project Stone Authority Pre-Consultation: Ethekwini Health
Meeting Agenda
— Introduction — Project Overview — Legal Framework
2 — Approach and timeframes — Discussion
1 19/06/2018
Meeting Objectives
— Introduce the project — Present the approach to the Environmental Authorisation process and associated permits / licences 3 — Receive initial comments / guidance from relevant authorities
28 February 2018
Project Overview
2 19/06/2018
Introduction
• To remain globally competitive Saiccor needs to expand • Competitive base is not only defined by production but environmental performance (community and customer) • Therefore expansion has been separated into two phases • 1. Vulindlela or the Environmental Phase (Priority) – 890 000 tpa • 2. Stone – Significant capacity increase – 1 050 000 tpa • Expected Projected Expenditure - Vulindlela: R5.5 Billion • Expansion within existing footprint
5
Environmental Improvement (estimated)
Tons 783 000 tpa 1050 000 tpa D% Employment (direct) 1 312 1 437 9% Water 6 022 m3/h 5 585 m3/h 7% Effluent 5 237 m3/h 5 080 m3/h 5%
SO2 1,66 t/d 1,44 t/d 13% COD 1 536 t/d 877 t/d 43%
CO2(fossil) 2 176 t/d 902 t/d 59% Waste 195 t/d 120 t/d 39%
6
3 19/06/2018
Project Summary
Project Vulindlela (Phase 1): — Increased woodyard input — Reduced production from Ca digesters — New MgO line – additional MgO digesters (~8)
7 — New recovery boiler & SRP — New evaporator — New washing and screening plant — Upgrade bleach plant — Upgrade pulp machines
Project Summary
Project Stone (Phase 2): — Increased chip screening — Additional MgO digesters (~5) — New washing and screening plant
8 — New evaporator — New bleach plant — New pulp machine — New turbine to produce power and steam
4 19/06/2018
28 February 2018
Legal Framework
Legal Framework
Legal Review: — National Environmental Management Act — National Environmental Management: Air Quality Act
10 — National Environmental Management: Waste Act — National Water Act — National Heritage Resources Act
5 19/06/2018
Legal Framework: NEMA EIA Regulations
Listing Notice 1 (GNR 327) – Requirement for Basic Assessment
Activity Description Applicability
34 The expansion of existing facilities or The proposed expansion will 11 infrastructure for any process or activity require an amendment of the where such expansion will result in the Mill’s Atmospheric Emission need for a permit or licence or an Licence (AEL). The primary amended permit or licence in terms of activity, which triggers Activity national or provincial legislation 34, is the proposed new governing the release of emissions, recovery boiler (Phase 1). effluent or pollution, excluding—
Legal Framework: NEMA EIA Regulations
Listing Notice 1 (GNR 327) – Requirement for Basic Assessment
Activity Description Applicability
37 The expansion and related operation of Sappi will add a new turbine 12 facilities for the generation of electricity (TG8) that will produce power from a non-renewable resource where – (45MW ) and low-pressure (i) The electricity output will be increased steam (Phase 2). The power to by 10 megawatts or more, excluding be produced will be for Sappi’s where such expansion takes place on own consumption, as such, there the original development footprint; or will be no export of power to the (ii) Regardless of the increased output of national grid the facility, the development footprint will be expanded by 1 hectare of more
6 19/06/2018
Legal Framework: NEMA EIA Regulations
Listing Notice 1 (GNR 327) – Requirement for Basic Assessment Activity Description Applicability
51 The expansion and related operation Sappi propose to expand their of facilities for the storage, or storage storage of chemicals, in above 13 and handling, of a dangerous good, ground storage tanks (Phase 2), where the capacity of such storage in excess of 80m3, at the facility will be expanded by more than Chemical Plant. 80 cubic metres.
28 February 2018
Approach and Timeframes
7 19/06/2018
Approach
— Application for Environmental Authorisation: Basic Assessment — AEL Amendment Application 15 — Specialist studies —Traffic Impact Assessment —Air Quality Impact Assessment —Environmental Acoustic Impact Assessment
Approach
Public Participation: — Public Announcement: Feb 2018 —Adverts,
16 —Site Posters, —Written Notification —Background Information Document (comment period) — Draft BAR and EMPr: 30 day comment period
8 19/06/2018
Anticipated Timeframes
— Authority pre-consultation: Early February 2018 — Public announcement: February 2018 — Draft Basic Assessment Report: ~ May 2018
17 — Public comment period: ~ June 2018 — Final Basic Assessment Report: ~ July 2018 — Decision: ….
28 February 2018
AQIA Methodology
9 19/06/2018
AQIA:
— Baseline Assessment — Emissions Inventory Compilation — Dispersion Modelling
19 — Air Quality Impact Assessment Reporting — AEL application preparation and submission
Discussion
wsp.com
10 APPENDIX
B STAKEHOLDER NOTIFICATIONS APPENDIX
B-1 INITIAL ADVERTISEMENTS
Figure B1: The newspaper advert and site poster APPENDIX
Figure B2: Notification placed in the Isolezwe APPENDIX
Figure B3: Notification placed in the Mercury APPENDIX
Figure B4: Notification placed in the Mid South Coast Rising Sun APPENDIX
Figure B5: Notification placed in the Mid-South Coast Mail APPENDIX
B-2 POSTERS
Figure B6: Posters notifying the public about the project Figure B7: Posters notifying the public about the project at Sappi Saiccor Mill entrance LignoTech SA’s entrance
Figure B8: Posters notifying the public about the project Figure B9: Posters notifying the public about the project at the turn off to Saiccor Mill just beyond the N2 off ramp at the Umkomaas Spar APPENDIX
B-3 WRITTEN NOTIFICATION
Figure B10: Email of trail of the written notification and the BID distribution on 19 March 2018
Figure B11: Email of trail of the written notification and the BID distribution on 20 April 2018 APPENDIX
B-4 BACKGROUND INFORMATION DOCUMENT Background SAPPI SAICCOR EXPANSION: Information PROJECT VULINDLELA AND PROJECT STONE Document BASIC ASSESSMENT PROCESS Date: March 2018
Introduction
Sappi Southern Africa Limited (Sappi) is proposing the phased expansion of the Saiccor Mill, located near Umkomaas. WSP, Environment and Energy (WSP) has been appointed as the independent Environmental Assessment Practitioner (EAP) to undertake the necessary environmental authorisation and licencing processes. This process includes the consultation with parties that may be affected by, or have an interest in the proposed project, referred to as interested and affected parties.
Purpose of this Document
The purpose of this document is to: — Provide a brief introduction to the proposed project; — Provide an outline of the process being followed; — Advise stakeholders of the manner in which they can be involved in the process — Inform members of the public of their rights and responsibilities regarding participation in the process; — Encourage stakeholders to comment on the project, ask questions and raise issues that should be included in the Basic Assessment process.
Overview of the Saiccor Mill
The Sappi Saiccor Mill is the largest manufacturer of elemental chlorine free dissolving wood pulp (speciality cellulose), primarily for the export market. This product is used as a raw material in textiles, cellophane wrap, pharmaceuticals and household products. The Sappi Saiccor Mill is located on the southern bank of the Umkomaas River, approximately 3,5 km from the coastal town of Umkomaas, approximately 50km south of Durban (Figure 1). The Sappi Saiccor Mill is located on Portion 656 of Erf 1357, Umkomaas. The co- ordinates of the approximate centre point of the Mill are latitude 30°10'57.39"S and longitude 30°46'27.53"E. The mill falls within the southern boundary of the eThekwini Metropolitan Municipality. The Mill can be seen from the N2 as one crosses the bridge over the Umkomaas River. The surrounding land uses include small-scale (predominately subsistence) farming, residential areas and natural vegetation. The main residential areas within a 5km radius of the Mill include Craigieburn, Dlambula, Drift, Ilfracombe, Magabeni, Naidooville, Saiccor Village and Umkomaas (Figure 2). Beyond the Mill and surrounds are agricultural activities well as formal and informal housing.
Page 1 Figure 1: Location of Sappi Saiccor Mill
Figure 2: Proximity of Residential Receptors to the Sappi Saiccor Mill Page 2 Existing Saiccor Mill Operations
The overall production process at Sappi Saiccor Mill involves a number of sequential phases (Figure 3 and Table 1).
Figure 3: Simplistic Production Process Diagram
Table 1: Overview of Production Processes at Saiccor Mill
PROCESS PHASE OVERVIEW
Wood handling and Debarked logs arrive at the Mill by road or rail. Logs are unloaded onto stockpiles in the woodyard or chipping directly to conveyors to be transported to chippers. Logs are chipped to the required sizes. Chips are blown onto chip piles where they are stored until required.
Cooking liquor production Calcium bisulphite and magnesium bisulphite cooking liquors are produced on site for their respective cooking processes.
Cooking, washing and Cooking takes place in batch digesters. Wood chips are fed and packed in the digesters, following which screening cooking liquor is added from the base of the digester. The digester is then pressurised and steam added to bring the digester to the correct temperature for cooking. The produced calcium and magnesium pulps are washed and screened before proceeding to the bleaching stage.
Bleaching A five stage bleaching process is carried out to ensure complete delignification of the pulp and that the pulp meets customer specifications and requirements. This process is elemental chlorine free.
Cleaning and drying The last stage in the production process is final cleaning and drying of the pulp in the pulp machines or ‘continuas’. These form the pulp into a continuous sheet, which is dried. The sheet is then cut and baled or reeled into sizes suitable for transportation. All product is transported from the Mill on road trucks.
The Mill was expanded in 2008 through the implementation of Project Amakhulu. The Mill received the necessary environmental approval for an increase of the mill production to 810 000 tons per annum.
Page 3 Brief Project Description: Project PHASE OVERVIEW Vulindlela and Project Stone Project Stone — Increased woodyard input and chip In order to remain globally competitive Sappi needs to (Phase 2): screening expand. After consideration of a number of options, Sappi — Additional magnesium digesters Increased are proposing to increase production at the Sappi Saiccor — New turbine to produce power and production to 1 050 steam Mill. The project will take place within the existing Mill 000 tons per annum boundary. The expansion is proposed to take place in two — New evaporator phases as follows: — New washing and screening plant — New bleach plant — Phase 1 – Project Vulindlela — New pulp machine — Phase 2 – Project Stone — Sulphur dioxide recovery Due to the fact that environmental performance is critical to Sappi’s global clients and to the communities in the area in which they operate, it is essential that the future Legal Framework expansion has a strong focus on environmental WSP have identified the following legal requirements improvement. For this reason, the first phase of the associated with the proposed project: expansion, Project Vulindlela (which means to “open the way”) proposes significant improvements in the Mill’s (1) Basic Assessment process to obtain environmental performance in numerous areas, in Environmental Authorisation (EA) in particular improved emissions; reduced water use and compliance with the National Environmental effluent generation, and reduced reliance on coal. The Mill Management Act (Act 107 of 1998), as amended operates two different cooking processes, one is a calcium (NEMA) and the associated 2014 Environmental based and the other is a magnesium based process. The Impact Assessment (EIA) Regulations (amended Mill intends to reduce the calcium cooking process and April 2017); and increase the magnesium based cooking process. (2) Amendment of the Atmospheric Emission Magnesium oxide cooking is considered Best Available Licence (AEL) in terms of the National Technology (BAT) as it is a closed loop process which does Environmental Management: Air Quality Act not generate a significant amount of effluent as most of the (2008) (NEM:AQA). effluent is recovered. There is an increase in production proposed as part of Project Vulindlela, which is necessary to assist in funding Environmental Authorisation the numerous environmental improvements. Project Vulindlela, as the name suggests, opens the way for the The NEMA provides the environmental legal framework second phase of the expansion, namely Project Stone. in South Africa, and requires that activities be Project Stone proposes a significant expansion in the mills investigated that may have a potential impact on the production. environmental, socio-economic conditions, and cultural A summary of the key features of each of the proposed heritage. The 2014 EIA Regulations as amended, expansion phases are presented in Table 2 below. promulgated under NEMA, contain listed activities (Listing Notice 1, 2 and 3) which are subject to either a Basic Assessment or Scoping and EIA process in order to Table 2: Overview of Sappi Saiccor Expansion obtain Environmental Authorisation. Phases
PHASE OVERVIEW Table 3 contains the listed activities that are triggered by Project Vulindlela — Increased woodyard input (timber) the proposed expansion of the Saiccor Mill. Based on the (Phase 1): — Reduced production from calcium activities identified as applicable to the project, a Basic digesters Increased Assessment process will be undertaken in order to obtain — Additional magnesium digesters production to 890 the necessary Environmental Authorisation. The — New recovery boiler 000 tons per annum competent authority responsible for assessing the — New evaporator application for Environmental Authorisation is the — New washing and screening plant KwaZulu-Natal Department of Economic Development, — Upgrade of bleach plant — Upgrade of pulp machines Tourism and Environmental Affairs (EDTEA). — Secondary recovery plant — Sulphur dioxide recovery
Page 4 Table 3: Listing Activities Requiring Environmental Authorisation
LISTED ACTIVITY APPLICABILITY TO THE PROJECT
Listing Notice 1 (GNR 327)
Activity 34: The proposed expansion will require an amendment of the Mill’s The expansion of existing facilities or infrastructure for any existing AEL. process or activity where such expansion will result in the need for a permit or licence or an amended permit or licence in terms of national or provincial legislation governing the release of emissions, effluent or pollution, excluding— (i) where the facility, infrastructure, process or activity is included in the list of waste management activities published in terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in which case the National Environmental Management: Waste Act, 2008 applies; (ii) the expansion of existing facilities or infrastructure for the treatment of effluent, wastewater, polluted water or sewage where the capacity will be increased by less than 15 000 cubic metres per day; or (iii) the expansion is directly related to aquaculture facilities or infrastructure where the wastewater discharge capacity will be increased by 50 cubic meters or less per day. Activity 37: Sappi is proposing a new turbine that will produce power (45MW) and low-pressure steam. The power produced by the turbine will The expansion and related operation of facilities for the be more than 10 megawatts. generation of electricity from a non-renewable resource where – (i) The electricity output will be increased by 10 megawatts or The power to be produced will be for Sappi’s own consumption, more, excluding where such expansion takes place on the as such, there will be no export of power to the national grid. original development footprint; or Regardless of the increased output of the facility, the development footprint will be expanded by 1 hectare of more
Activity 51: Sappi proposes to expand its storage of chemicals in above ground storage tanks, in excess of 80m3, at the existing chemical The expansion and related operation of facilities for the storage, plant. or storage and handling, of a dangerous good, where the capacity of such storage facility will be expanded by more than 80 cubic metres.
Atmospheric Emissions Licence (Amendment)
The NEM:AQA seeks to protect the environment and improved air quality through the minimisation of air pollution. Regulations promulgated under NEM:AQA provide a list of activities that require licencing, due to their potential for negative impact on the environment. Any activity identified as a listed activity is required to apply for an Atmospheric Emissions Licence (AEL).
Sappi Saiccor Mill currently holds an Atmospheric Emission License (AEL), which was issued by the eThekwini Municipality on 01 July 2017. Whilst the proposed expansion does not trigger any new listed activities in terms of NEM:AQA, the proposed project requires an application for AEL amendment. The competent authority for the consideration of this application is the eThekwini Municipality.
Page 5 Basic Assessment Process The first step in the Stakeholder Engagement process is to notify the public and identified stakeholders of the As defined in Appendix 1 of the EIA Regulations, the proposed project through the following mediums: objective of the impact assessment process is to, through a - Newspaper advertisements and site notices in and consultative process: around the project area; - Determine the policy and legislative context within - Written notification letters to adjacent land owners which the proposed activity is located and how the and occupiers, municipal councillor of the ward, activity complies with and responds to the policy and ratepayers association in the area, municipality, any legislative context; organ of state having jurisdiction in respect of the - Identify the alternatives considered, including the activity, and any other party required by the activity, location, and technology alternatives; competent authority; and - Describe the need and desirability of the proposed - Distribution of this BID to surrounding landowners alternatives; and registered stakeholders. - Through the undertaking of an impact and risk assessment process, inclusive of cumulative impacts How can you get involved? which focused on determining the geographical, physical, biological, social, economic, heritage, and - Register as a stakeholder (by phone, fax or email) to cultural sensitivity of the sites and locations within ensure you are kept informed and are able to sites and the risk of impact of the proposed activity participate in the process; and technology alternatives on these aspects to - Complete the attached comments form and return by determine— email, fax or post to WSP (contact details provided on - The nature, significance, consequence, extent, the form); duration, and probability of the impacts occurring - Attend the stakeholder meeting that will be held to; and during the course of the project; and - The degree to which these impacts— - Review and comment on the Draft Basic Assessment - Can be reversed; Report when it becomes available. - May cause irreplaceable loss of resources; and - Can be avoided, managed or mitigated; and Roles and Responsibilities of Stakeholders - Through a ranking of the site sensitivities and possible impacts the activity and technology Stakeholders have the right to bring to the attention of the alternatives will impose on the sites and location competent authority any issues that they believe may be of significance to the consideration of the application. The identified through the life of the activity to— rights of stakeholders are qualified by certain obligations, - Identify and motivate a preferred site, activity namely: and technology alternative; - Identify suitable measures to avoid, manage or - Stakeholders must ensure that their comments are mitigate identified impacts; and submitted within the timeframes that have been - Identify residual risks that need to be managed approved by the competent authority, or within any and monitored. reasonable extension of a timeframe agreed by the Proponent or EAP; - Specialist Studies Anticipated A copy of comments submitted directly to the competent authority must be served on the Proponent or EAP; and The following specialist studies will be undertaken to - Any direct business, financial, personal or other interest support the application processes: that a stakeholder might have in the approval or refusal 1. Traffic Impact Assessment of the application must be disclosed. 2. Air Quality Impact Assessment 3. Environmental Acoustic Impact Assessment The roles of stakeholders in a stakeholder engagement process usually include one or more of the following:
Stakeholder Engagement - Assisting in the identification and prioritisation of issues that need to be investigated; The purpose of stakeholder engagement is to consult with - Making suggestions on alternatives and means of stakeholders and interested and affected parties during the preventing, minimising and managing negative impacts assessment and decision-making process, on projects that and enhancing project benefits; may affect them. Stakeholders will be provided with the - Assisting in, or commenting on, the development of opportunity to express their view and concerns regarding mutually acceptable criteria for the evaluation of the project through project correspondence. The EAP will decision options; document stakeholder views and concerns and ensure the - Contributing information on public needs, values and project team and relevant authorities are aware of issues expectations; associated with the project. - Contributing to local and traditional knowledge; and - Verifying that their issues have been considered. Page 6 Registration and PROPOSED SAPPI SAICCOR MILL EXPANSION PROJECT Comment Form To register as a stakeholder and to ensure all comments and queries regarding this project are accurately documented and addressed, please provide your contact details and comments below to Mpendulo Dlamini at WSP.
Email: [email protected] | Fax: 086 606 7121 Postal Address: 1 On Langford Road, Westville, 3629
PLEASE PROVIDE YOUR PERSONAL DETAILS BELOW: Name:
Organisation & Designation:
Address:
Tel:
Fax:
Email:
I would like to receive my Email Fax SMS Letter (mail) notification by: ☐ ☐ ☐ ☐ (please tick the appropriate box) As required in terms of the EIA Regulations, please disclose below any direct business, financial, personal or other interest you may have in the granting or rejection of the application for environmental authorisation:
Please list your project-related comments below:
Stakeholder Signature: Date:
Page 7 APPENDIX
B-5 TRADITIONAL LEADERS MEETINGS – ATTENDANCE REGISTERS APPENDIX APPENDIX APPENDIX
B-6 DRAFT BAR ADVERTISEMENTS APPENDIX
Figure B12: The Draft Basic Assessment newspaper advert APPENDIX
Figure B13: The Mercury advert proof APPENDIX
Figure B14: The Isolezwe advert proof APPENDIX
Figure B15: The Mid South Coast Rising Sun advert proof APPENDIX
Figure B16: The Mid-South Coast Mail advert proof APPENDIX
B-7 DRAFT BAR STAKEHOLDER NOTIFICATION 20 June 2018 Our ref: 41100417 EDTEA ref: DM/0012/2018
Dear Stakeholder
Subject: Sappi Saiccor Expansion: Project Vulindlela and Project Stone – Draft Basic Assessment Report
Sappi Southern Africa Limited (Sappi) are proposing the expansion of their Saiccor Mill. The Mill is located at the Umkomaas Drift, R197 approximately 50 km south of Durban, in the eThekwini Municipality, KwaZulu-Natal. The expansion is proposed to take place in two phases. Phase 1, known as Project Vulindlela, is the ‘environmental phase’ of the expansion project which will result in some significant environmental improvements at the mill as well as a production increase to 890 000 tons per annum. Phase 2, known as Project Stone, will result in a further increase in production at the Mill to 1 050 000 tons per annum. Both Phase 1 and 2 of the Mill expansion includes the upgrade of associated infrastructure to support the project. The proposed mill expansion is subject to an Environmental Authorisation (Ref: DM/0012/2018) by the Department of Economic Development, Tourism and Environmental Affairs (EDTEA) in terms of the 2014 Environmental Impact Assessment (EIA) Regulations (amended 2017), promulgated in terms of the National Environmental Management Act (No. 107 of 1998) (NEMA).
The draft Basic Assessment report (BAR) is available for comment for a period of 30 days, from the 20 June 2018 to 20 July 2018 in accordance with Section 19 the National Environmental Management Act (Act No.107 of 1998) Impact Assessment Regulations, 2014 as amended.
The report will be available at the following locations: - Umkomaas Public Library (41 Barrow Street, Umkomaas) - Online on the WSP website: http://www.wspgroup.com/en/WSP-Africa/What-we- do/Services/All-Services-A-Z/Technical-Reports/ - From WSP– on request (details below)
Comments can be submitted by email, post or fax to Mpendulo Dlamini (details overleaf). All comments received will be incorporated into the final BAR for submission to the EDTEA. To ensure that your comments are incorporated into the final BAR, please ensure that they are received on or before 17h00 on 20 July 2018.
Block A, 1 on Langford Langford Road Westville, Durban, 3629 South Africa
T: +27 31 240 8800 F: +086 606 7121 wsp.com
WSP Environmental (Pty) Ltd. Thank you in advance for your participation.
Yours sincerely,
Mpendulo Dlamini Environmental Consultant WSP Environmental (Pty) Ltd Tel: (031) 240 8860 Fax: (031) 240 8861 Email: [email protected]
Page 2
Login Name Sent Date/Time Mobile Status Status Date/Time Cost Message [email protected] 2018/06/20 15:22 27748884730 DELIVERED 2018/06/20 15:22 2 Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. For further information contact Mpendulo on 031 240 8860 [email protected]. [email protected] 2018/06/20 15:22 27827226195 DELIVERED 2018/06/20 15:22 2 Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. For further information contact Mpendulo on 031 240 8860 [email protected]. [email protected] 2018/06/20 15:22 27737341680 DELIVERED 2018/06/20 15:22 2 Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. For further information contact Mpendulo on 031 240 8860 [email protected]. [email protected] 2018/06/20 15:22 27735413562 DELIVERED 2018/06/20 15:22 2 Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. For further information contact Mpendulo on 031 240 8860 [email protected]. [email protected] 2018/06/20 15:22 27834671386 DELIVERED 2018/06/20 15:23 2 Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. For further information contact Mpendulo on 031 240 8860 [email protected]. [email protected] 2018/06/20 15:22 27836843888 DELIVERED 2018/06/20 15:22 2 Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. For further information contact Mpendulo on 031 240 8860 [email protected]. [email protected] 2018/06/20 15:22 27729373028 DELIVERED 2018/06/20 15:22 2 Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. For further information contact Mpendulo on 031 240 8860 [email protected]. [email protected] 2018/06/20 15:22 27731936837 DELIVERED 2018/06/20 15:22 2 Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. For further information contact Mpendulo on 031 240 8860 [email protected]. [email protected] 2018/06/20 15:22 27786319706 DELIVERED 2018/06/20 15:23 2 Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. For further information contact Mpendulo on 031 240 8860 [email protected]. [email protected] 2018/06/20 15:22 27834416663 DELIVERED 2018/06/20 15:22 2 Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. For further information contact Mpendulo on 031 240 8860 [email protected]. [email protected] 2018/06/20 15:22 27835384672 DELIVERED 2018/06/20 15:22 2 Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. For further information contact Mpendulo on 031 240 8860 [email protected]. [email protected] 2018/06/20 15:22 27825592843 DELIVERED 2018/06/20 15:22 2 Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. For further information contact Mpendulo on 031 240 8860 [email protected]. [email protected] 2018/06/20 15:22 27824069891 DELIVERED 2018/06/20 15:22 2 Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. For further information contact Mpendulo on 031 240 8860 [email protected]. [email protected] 2018/06/20 15:22 27827193999 DELIVERED 2018/06/20 15:22 2 Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. For further information contact Mpendulo on 031 240 8860 [email protected]. [email protected] 2018/06/20 15:22 27721274841 DELIVERED 2018/06/20 15:22 2 Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. For further information contact Mpendulo on 031 240 8860 [email protected]. [email protected] 2018/06/20 15:22 27735766666 DELIVERED 2018/06/20 15:22 2 Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. For further information contact Mpendulo on 031 240 8860 [email protected]. [email protected] 2018/06/20 15:22 27828660173 DELIVERED 2018/06/20 15:22 2 Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. For further information contact Mpendulo on 031 240 8860 [email protected]. [email protected] 2018/06/20 15:22 27829083748 DELIVERED 2018/06/20 15:22 2 Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. For further information contact Mpendulo on 031 240 8860 [email protected]. [email protected] 2018/06/20 15:22 27814215452 FAIL - UNDELIV 2018/06/20 15:53 2 Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. For further information contact Mpendulo on 031 240 8860 [email protected]. [email protected] 2018/06/20 15:22 27824551539 FAIL - UNDELIV 2018/06/20 15:53 2 Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. For further information contact Mpendulo on 031 240 8860 [email protected]. [email protected] 2018/06/20 15:22 27784328257 SENT 2018/06/20 15:22 2 Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. For further information contact Mpendulo on 031 240 8860 [email protected]. [email protected] 2018/06/20 15:22 27797171919 SENT 2018/06/20 15:22 2 Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. For further information contact Mpendulo on 031 240 8860 [email protected]. Login Name Sent Date/Time Mobile Status Status Date/Time Cost Message Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. [email protected] 2018/06/27 09:40 27737341680 DELIVERED 2018/06/27 09:40 2 For further information contact Mpendulo on 031 240 8860 [email protected]. Sappi are proposing the expansion of their Saiccor Mill. Please note that a draft basic assessment report is available for comment from 20 June 2018 to 20 July 2018. [email protected] 2018/06/27 09:40 27832528219 DELIVERED 2018/06/27 09:40 2 For further information contact Mpendulo on 031 240 8860 [email protected]. APPENDIX
C STAKEHOLDER DATABASE APPENDIX APPENDIX APPENDIX APPENDIX APPENDIX APPENDIX
D COMMENTS RECEIVED APPENDIX
D-1 COMMENTS IN RESPONSE TO THE BID Konigkramer, Hilary
From: Diane VanRensburg
Dear Mpendulo,
Please will you register eThekwini Municipality as an Interested and Affected Party. Would you like me to provide consolidated comments on the BID application, bearing in mind that it will take at least three weeks to process?
Kind Regards Diane. EIA HUB (Private Applications) eThekwini Municipality 031-3117136
From: Dlamini, Mpendulo [mailto:[email protected]] Sent: Monday, March 19, 2018 12:28 PM Subject: Proposed Sappi Saiccor Mill Expansion: Written Notification
Dear Stakeholder
Please find attached Written Notification in respect of the PROPOSED EXPANSION OF THE SAPPI SAICCOR MILL IN UMKOMAAS, KWAZULU-NATAL.
Notification is being given of the intention to: (1) Submit an application for Environmental Authorisation and, (2) Submit an application for Amendment of the facility’s existing Atmospheric Emission Licence
WSP has prepared a Background Information Document (attached) which contains an overview of the project and the proposed application processes to be followed.
Please confirm your interest in this project by registering as a stakeholder. You can register by completing the registration and comment form (last page of the Background Information Document) or by return email providing your full contact details.
Many thanks
Mpendulo Dlamini Cand. Sci. Nat. Environmental Consultant WSP, Environment & Energy, Africa
T +27 31 2408814 F +27 31 240 8801 M +27 74 7111143
Block A, 1 on Langford Langford Road Westville Durban 3629 South Africa
1 Konigkramer, Hilary
From: Rose Owen
Good day Mpendula
Thank you, for your email, and your time on the phone today.
Please find attached my I&AP form as completed. I will send out the documents to our forum for their information and for their registration.
Regards Rose
Rose Owen (MSoc Sci)
T: 031 765 8236; C: 082 506 0093 E: [email protected] Web: http://www.phelamanga.co.za
From: Dlamini, Mpendulo
Dear Stakeholder
Please find attached Written Notification in respect of the PROPOSED EXPANSION OF THE SAPPI SAICCOR MILL IN UMKOMAAS, KWAZULU-NATAL.
Notification is being given of the intention to: (1) Submit an application for Environmental Authorisation and, (2) Submit an application for Amendment of the facility’s existing Atmospheric Emission Licence
WSP has prepared a Background Information Document (attached) which contains an overview of the project and the proposed application processes to be followed.
Please confirm your interest in this project by registering as a stakeholder. You can register by completing the registration and comment form (last page of the Background Information Document) or by return email providing your full contact details.
Many thanks
Mpendulo Dlamini Cand. Sci. Nat. Environmental Consultant WSP, Environment & Energy, Africa
1 Konigkramer, Hilary
From: Judy Bell
Hi Mpendulo
Please register me as an IAP for this project – I am a member of Coastwatch KZN and would like to receive updates by email.
My concerns relate to:
· Use of water from a seriously oversubscribed river, impacts from discharges to estuary and sea · Need to reuse and recycle water internally as well as to take water from the eThekwini regional WWTW for treatment and reuse. · Best practice implementation, not merely legal compliance.
Thanks Judy
From: Dlamini, Mpendulo [mailto:[email protected]] Sent: Monday, March 19, 2018 12:28 PM Subject: Proposed Sappi Saiccor Mill Expansion: Written Notification
Dear Stakeholder
Please find attached Written Notification in respect of the PROPOSED EXPANSION OF THE SAPPI SAICCOR MILL IN UMKOMAAS, KWAZULU-NATAL.
Notification is being given of the intention to: (1) Submit an application for Environmental Authorisation and, (2) Submit an application for Amendment of the facility’s existing Atmospheric Emission Licence
WSP has prepared a Background Information Document (attached) which contains an overview of the project and the proposed application processes to be followed.
Please confirm your interest in this project by registering as a stakeholder. You can register by completing the registration and comment form (last page of the Background Information Document) or by return email providing your full contact details.
Many thanks
Mpendulo Dlamini Cand. Sci. Nat. Environmental Consultant WSP, Environment & Energy, Africa
T +27 31 2408814 F +27 31 240 8801 M +27 74 7111143
Block A, 1 on Langford
1
Konigkramer, Hilary
From: Empisini
Thanks Mpendulo - please continue to send me information to this e-mail address. I am a Sappi pensioner living in the area. Address : 1 Axbridge Place, Widenham 4170
Regards Mike Bentley
On 2018/03/19 12:28 PM, Dlamini, Mpendulo wrote: Dear Stakeholder
Please find attached Written Notification in respect of the PROPOSED EXPANSION OF THE SAPPI SAICCOR MILL IN UMKOMAAS, KWAZULU-NATAL.
Notification is being given of the intention to: (1) Submit an application for Environmental Authorisation and, (2) Submit an application for Amendment of the facility’s existing Atmospheric Emission Licence
WSP has prepared a Background Information Document (attached) which contains an overview of the project and the proposed application processes to be followed.
Please confirm your interest in this project by registering as a stakeholder. You can register by completing the registration and comment form (last page of the Background Information Document) or by return email providing your full contact details.
Many thanks
Mpendulo Dlamini Cand. Sci. Nat. Environmental Consultant WSP, Environment & Energy, Africa
T +27 31 2408814 F +27 31 240 8801 M +27 74 7111143
Block A, 1 on Langford Langford Road Westville Durban 3629 South Africa
wsp.com
Confidential This message, including any document or file attached, is intended only for the addressee and may contain privileged and/or confidential information. Any other person is strictly prohibited from reading, using, disclosing or copying this message. If you have received this message in error, please notify the sender and delete the message. Thank you.
WSP Environmental (Pty) Ltd, Registered Office: Building C, Knightsbridge, 33 Sloane Street, Bryanston, 2191, South Africa Registered Number: 1995/008790/07 South Africa
1 APPENDIX
D-2 COMMENT IN RESPONSE TO THE DRAFT BAR
A.P.W.D
51 SWALLOW ROAD NEWHAVEN UMKOMAAS 4170 17 JULY 2018
WE TAKE A CLOSER LOOK AT PROMINENT ENVIROMENTAL CHALLENGES IN UMKOMAAS THE FACTORS THAT DRIVE THEM AND THEIR IMPACT ON OUR NATURAL ENVIROMENT AND LIVELIHOODS. CLIMATE CHANGE IS ONE OF THE MOST COMPOUNDING CHALLENGES THAT THE PEOPLE OF SOUTH AFRICA ARE FACING, IRESPECTIVE OF WHERE OR HOW THEY LIVE.
TAKING YOUR 6.5 BILLION RAND EXPANSION INTO CONSIDERATION, WE VERY WELL KNOW THAT THE BIGGER THE PLANT GETS, THE MORE TOXIC WASTE AND S.O.2 WILL BE RELEASED.
1…SAPPI SHOULD UTILIZE 1 BILLION TO LOWER THEIR EMISSIONS. DO NOT RELEASE CHEMICALS AND S.O.2 AT NIGHT OR EARLY HOURS OF THE MORNING WHEN PEOPLE ARE ASLEEP. 2…OUR POOR LOCALS THAT LIVE ALONG SIDE THE FENCE LINE AND ALSO SURROUNDING AREAS OF SAPPI ARE VICTIMS OF POLLUTION IN EARLY HOURS OF THE MORNING. YOU CAN GET BAD SMELLS FROM ACROSS THE DEVILS CORRIDOR THAT’S EMMITING FROM THE PLANT. 3…IT WOULD BE VERY GOOD TO HAVE SAPPI AND THE EXPANSION CONSIDER THE PLIGHT OF OUR PEOPLE AND ALSO MEET WITH THEIR DEMANDS. CREATE JOBS FOR OUR LOCALS AND CONSIDER THOSE THAT ARE SUFFERING WITH ASTHMA, LUKIMA AND CANCER.
N.B.40% OF OUR LOCALS ARE ASTHMETIC DUE TO SAPPI`S EMISSIONS. SAPPI SHOULD BE HELD RESPONSIBLE FOR THE LOCALS HEALTH AND WELL BEING AND IT WOULD BE ONLY FAIR IF SAPPI BUILDS A FULLY FLEDGED ASTHMETIC CLINIC.
YOURS SINCERELY MA NAICKER
083 467 1386 Our Ref.: (21/11) DPM/EIA 813(S) DEDTEA: DM/0012/2018 Enquiries: Mrs D. van Rensburg Telephone: 031 – 3117136 18 July 2018
WSP Environmental Block A, 1 on Langford Road Westville Durban 3629 Att: Mpendulo Dlamini
Dear Sir/Madam,
RE: DRAFT BASIC ASSESSMENT REPORT FOR THE PROPOSED SAPPI SAICCOR MILL EXPANSION: PROJECT VULINDLELA AND PROJECT STONE, UMKOMAAS AREA.
With reference to the abovementioned Draft Basic Assessment Report, please be advised that various Municipal Departments have had sight of the proposal and the following comments are submitted for your attention:-
1. eThekwini Electricity Department.
The H.V. Department has no objection however please note:
1.1. The applicant must consult eThekwini Electricity’s mains records (held in the drawing office at eThekwini Electricity Headquarters, 1 Jelf Taylor Crescent, for the presence of underground electrical services. In addition should any overhead line and/or servitude be affected, the specific permission of the Head: Electricity must be sought regarding the proposed development.
1.2. The relocation of MV/LV electrical services, if required in order to accommodate the proposed development, will be carried out at the expense of the applicant.
1 2. Environmental Planning and Climate Protection Department.
The Draft Basic Assessment Report for the Sappi Saiccor Mill Expansion (Project Vulindlela and Project Stone) refers.
This Department has no biodiversity objection to the project being granted environmental authorisation if the mitigation and management measures contained in the Environmental Management Programme (EMPr) are implemented as recommended to ensure minimisation of the potential impacts.
3. Land Use Management Branch.
No objections provided that the proposed expansion takes place within the existing boundary of the Saiccor Mill on existing hard-standing areas, as stated in the Draft Basic Assessment Report. In addition, any new buildings will require the submission of building plans in terms of the National Building Regulations.
4. Strategic Spatial Planning Branch.
The Strategic Spatial Planning Branch supports the proposed Vulindlela and Project Stone within the existing mill boundary in Umkomaas to increase the production of elemental chlorine free dissolving wood pulp in order to remain globally competitive.
The Strategic Spatial Planning Branch’s comments for the abovementioned application are subject to the following:
4.1. This Branch’s support is subject to the applicant meeting all sector requirements. 4.2. This support should not be deemed to be an approval of the eThekwini Municipality. 4.3. This Branch reserves the right to comment further should the need arise.
5. Coastal, Stormwater and Catchment Management.
This Department has no objections.
6. Parks, Leisure and Cemeteries.
7. Pavement and Geotechnical Engineering.
No geotechnical objection.
2 8. eThekwini Transport Authority.
Please note that the Traffic Engineering Branch has no objections to the Draft Basic Assessment Report for the proposed Expansion to Sappi Saiccor Mill, located on Portion 656 of Umkomanzi Drift – 1357 as the road network utilised for assessing the site is predominantly provincial. However approval is required from KZN Department of Transport (KZNDoT) and South African National Roads Agency (SANRAL) prior to submission of building plans. The following documents were considered in this application:
Draft Basic Assessment Report compiled by WSP Environmental for Sappi South Africa Limited, dated 18 June 2018. Traffic Impact Assessment complied by WSP, dated 29 March 2018
9. Environmental Health Department.
This Department has the following comments regarding the Draft Basic Assessment Report.
9.1. Chemicals must be contained and stored correctly to avoid water or river contamination. 9.2. Ensure management of waste water and safe disposal of solid waste. 9.3. All precautionary measures to minimize noise to the acceptable standards are maintained in terms of Noise Control Regulations. 9.4. Ablution facilities must be provided for workers at the construction site. 9.5. All waste generated during the construction phase should be disposed of at an approved landfill site and records thereof should be kept. 9.6. Air quality impacts during the construction phase must be suitably monitored.
The mitigation measures outlined on the EIA document appear to be suitable. In this regard the Health Department is in support subject to all the above recommendations being implemented.
10. eThekwini Water and Sanitation Department.
Wastewater Design Branch. No objection to the proposed expansion.
11. Durban Solid Waste.
12. Disaster Management.
3 Sappi Saiccor is proposing to expand the mill in Umkomaas. This will include increasing the above ground storage of various chemicals at the chemical plant.
A preliminary risk assessment has been undertaken and the conclusions are that the expansion will not cause the major hazard risks to become unacceptable.
Sappi must however review and where necessary update the on-site emergency response plan taking into account the increase in hazardous material inventories.
13. Fire Safety.
Should you seek clarification on any of the above issues, please contact the writer on telephone: 031 - 3117136 or via e-mail: [email protected] In addition, the Department requests that a copy of the Environmental Authorisation be emailed to the same address.
Yours faithfully
MANAGER: LAND USE MANAGEMENT CB NORTON (Claire Norton: Professional Planner A/746/1993)
DATE:
HEAD: DEVELOPMENT PLANNING, ENVIRONMENT AND MANAGEMENT TB MBHELE
DATE:
Copy To: Department of Economic Development, Tourism and Environmental Affairs Private Bag X 54321 Durban 4000
4
Konigkramer, Hilary
From: Dlamini, Mpendulo Sent: 20 July 2018 02:05 PM To: Konigkramer, Hilary Subject: FW: DM/0012/2018- AVAILABILITY OF DRAFT BASIC ASSESSMENT REPORT
Follow Up Flag: Follow up Flag Status: Flagged
Hi Hilary,
FYI
Mpendulo Dlamini Consultant WSP, Environment & Energy, Africa
T +27 31 2408814 F +27 31 240 8801 M +27 74 7111143 From: Carolyn [mailto:[email protected]] Sent: 20 July 2018 01:56 PM To: Dlamini, Mpendulo
Hi Mpendulo Thank you following up and reminding us of the comment deadline. Unfortunately Coastwatch has not been able to review the report and will not be submitting comment. Regards Carolyn
From: Dlamini, Mpendulo Sent: Tuesday, July 17, 2018 4:19 PM To: undisclosed-recipients: Subject: RE: DM/0012/2018- AVAILABILITY OF DRAFT BASIC ASSESSMENT REPORT
Dear stakeholder,
You are hereby reminded that the comment period is ending this Friday, 20 July 2018 at 17:00. If you will be submitting comments, kindly ensure that these are submitted on time.
Regards
Mpendulo Dlamini Consultant WSP, Environment & Energy, Africa
T +27 31 2408814 F +27 31 240 8801 M +27 74 7111143 From: Msomi, Bathabile Sent: 20 June 2018 12:36 PM Subject: DM/0012/2018- AVAILABILITY OF DRAFT BASIC ASSESSMENT REPORT
Dear Stakeholder
1 Sappi Southern Africa Limited (Sappi) are proposing the expansion of their Saiccor Mill. The Mill is located at the Umkomaas Drift, R197 approximately 50 km south of Durban, in the eThekwini Municipality, KwaZulu-Natal. The proposed mill expansion is subject to an Environmental Authorisation (Ref: DM/0012/2018) by the Department of Economic Development, Tourism and Environmental Affairs in terms of the 2014 Environmental Impact Assessment (EIA) Regulations (amended 2017), promulgated in terms of the National Environmental Management Act (No.107 of 1998) (NEMA).
Please find attached notification of the availibity of the draft basic assessment report (BAR). The draft BAR is available for comment for a period of 30 days, from 20 June 2018 to 20 July 2018 in accordance with Section 19 the NEMA EIA Regulations, as amended in 2017.
Should you require any further assistance, do not hesitate to contact Mpendulo Dlamini on the contact details below.
Tel: (031) 240 8860 Fax: (031) 240 8861 Email: [email protected]
Kind Regards
Bathabile Msomi Environmental Consultant WSP, Environment & Energy, Africa
F +27 31 240 8801
Block A, 1 on Langford Langford Road Westville Durban 3629 South Africa wsp.com
Confidential This message, including any document or file attached, is intended only for the addressee and may contain privileged and/or confidential information. Any other person is strictly prohibited from reading, using, disclosing or copying this message. If you have received this message in error, please notify the sender and delete the message. Thank you.
WSP Environmental (Pty) Ltd, Registered Office: Building C, Knightsbridge, 33 Sloane Street, Bryanston, 2191, South Africa Registered Number: 1995/008790/07 South Africa
NOTICE: This communication and any attachments ("this message") may contain information which is privileged, confidential, proprietary or otherwise subject to restricted disclosure under applicable law. This message is for the sole use of the intended recipient(s). Any unauthorized use, disclosure, viewing, copying, alteration, dissemination or distribution of, or reliance on, this message is strictly prohibited. If you have received this message in error, or you are not an authorized or intended recipient, please notify the sender immediately by replying to this message, delete this message and all copies from your e- mail system and destroy any printed copies.
-LAEmHhHzdJzBlTWfa4Hgs7pbKl
2 PROPOSED EXPANSION OF THE SAPPI SAICCOR MILL
Our Ref: SAH18/12614
Enquiries: Bernadet Pawandiwa Date: Tuesday July 17, 2018 Tel: 033 394 6543 Email: [email protected] Page No: 1 CaseID: 12614
Final Comment In terms of Section 38 of the National Heritage Resources Act (Act 25 of 1999) and the KwaZulu-Natal Heritage Act (Act 4 of 2008) Attention: Sappi Southern Africa Limited Sappi Southern Africa Limited (Sappi) are proposing the expansion of their Saiccor Mill. The Mill is located at the Umkomaas Drift, R197 approximately 50 km south of Durban, in the eThekwini
Municipality, KwaZulu-Natal. The expansion is proposed to take place in two phases. Phase 1, known as Project Vulindlela, is the ‘environmental phase’ of the expansion project which will result in some significant environmental improvements at the mill as well as a production increase to 890 000 tons per annum. Phase 2, known as Project Stone, will result in a further increase in production at the Mill to 1 050 000 tons per annum. Both Phase 1 and 2 of the Mill expansion includes the upgrade of associated infrastructure to support the project. We acknowledge receipt of your invitation for comment with regards to the proposed development. The object of Amafa is to administer, conserve and protect heritage resources of the Province within the terms of KZN Heritage Act no. 4 (2008) and the National Heritage Resources Act No 25 of 1999.The proposed development footprint was surveyed by eThembeni in 2005 and no heritage resources were recorded on this site. The Environmental Practitioner has indicated that the structures that require expansion are not older than 60 years. Amafa therefore has no objection to the development.You are also required to adhere to the below-mentioned standard conditions:
Conditions:
1. Amafa should be contacted if any heritage objects are identified during earthmoving activities and all development should cease until further notice. 2. No structures older than sixty years or parts thereof are allowed to be demolished altered or extended without a permit from Amafa. 3. Under no circumstances may any heritage material be destroyed or removed from site unless under direction of Amafa and a heritage specialist. 4. Should any remains be found on site that is potentially human remains, the South African Police Service (SAPS) should also be contacted. No SAPS official may disturb or exhume such remains, whether of recent origin or not, without the necessary permission from Amafa. 5. No activities are allowed within 50m of a site, which contains rock art. 6. Sources of all natural materials (including topsoil, sands, natural gravels, crushed stone, asphalt, etc.) must be obtained in a sustainable manner and in compliance with the heritage legislation.
Failure to comply with the requirements of the National Heritage Resources Act and the KwaZulu Natal Heritage Resources Act could lead to legal action being instituted against the applicant.
This decision is valid for a period of two years.
PROPOSED EXPANSION OF THE SAPPI SAICCOR MILL
Our Ref: SAH18/12614
Enquiries: Bernadet Pawandiwa Date: Tuesday July 17, 2018 Tel: 033 394 6543 Email: [email protected] Page No: 2 CaseID: 12614 Should you have any further queries, please contact the designated official using the case number quoted above in the case header.
Yours faithfully
______Bernadet Pawandiwa Senior Heritage Officer Amafa/Heritage KwaZulu Natal
______James van Vuuren Deputy Director: Support Services, Technical Amafa/Heritage KwaZulu Natal
ADMIN: Direct URL to case: http://www.sahra.org.za/node/507637 (EDTEA, Ref: DM/0012/2018)
Terms & Conditions:
1. This approval does not exonerate the applicant from obtaining local authority approval or any other necessary approval for proposed work. 2. If any heritage resources, including graves or human remains, are encountered they must be reported to Amafa immediately. 3. Amafa reserves the right to request additional information as required.
Powered by TCPDF (www.tcpdf.org) No 2 John Dunn House South Durban 224 Gouritz Crescent Community Austerville, Durban 4052 +27 31-461-1991 Environmental www.sdcea.co.za Alliance
20 July 2018
Bathabile Msomi Environmental Consultant WSP, Environment & Energy, Africa E: [email protected]
Mpendulo Dlamini Consultant WSP, Environment & Energy, Africa E: [email protected]
DM/0012/2018- AVAILABILITY OF DRAFT BASIC ASSESSMENT REPORT
Sappi Southern Africa Limited (Sappi) are proposing the expansion of their Saiccor Mill.
Terms of reference: We need you to provide the contract of appointment as we want to assess whether WSP will act impartial and without bias.
Project Overview: Why have you not investigated other sites? Why Sappi Saiccor was chosen to expand – we need valid reasons for this. Why is your current production levels on both phase one and phase two? What are your project margins and projected profit as well as your projected turnover?
Benefits: Please tell us what are your current permanent staff, and casual staff? The demographics of where your staffs are from? We need accurate and proper informed information supported by the departed labour and detailed addresses to ascertain the benefits to Umkomaas and Magabeni community members. How many will be employed through the contractual phase and where will the labor force come from? What percentage of equipment will be made locally by local workforce? Additionally what percentage will labor of local contractor’s be given contracting opportunities? Please provide us with evidence and information of your current operation
The Right to Know | The Duty to Inquire | The Obligation to Act
SDCEA Members P.O. Box 211150 SDCEA Members Earthlife Africa- Durban Isipingo Ratepayers Association Clairwood Ratepayers Association Bluff, 4036 Silverglen Civic Association Umkomaas Anti-Pollution Watchdogs Kwazulu-Natal, South Africa Wentworth Development Forum Isipingo Environmental Committee [email protected] Treasure Beach Environmental Forum Umlazi Unemployed peoples movement Christ the King Church Airport Farmers Association 028-964-NPO Ubunye Bama Hostela KZN Subsistence Fishermen Forum Bluff Ridge Conservancy
including expert reports done by CSIR / other independent unbiased experts as well as the information that informs your air emission licenses and all schedule permits.
Technology: We request you provide where this technology is used in first world countries. What legislative regime that’s used to hold this technology in compliance. Please explain to us how an increase in production can fund the environmental improvements? Why have you not budgeted for environmental improvements as per your licenses and permits as required under law to fulfil obligations as a company complying with NEMA, section 24 of the South African Constitution Bill of Rights, Air quality act, Waste act and the King 2 and 3 Commission, labor act, department of labor and occupational health and safety. Please explain what you mean by significant expansion in detailed information. A full EIA and all risk and concerns must be analysed by screening and quantified by environmental experts.
We want full participation with regards to your atmospheric emission licenses as this must be known through a credited and evaluated process. Information must be honest and truthful reviewed and peer reviewed paid for by Sappi and chosen by the community.
Project team: Is in house and appointed and paid for by Sappi Saiccor therefore all information put through a peer review process. Appointed by the affected communities and I&APs paid for by Sappi Saiccor. As this project proposes a significant expansion at the mill and may have a significant impact and create more environmental problems that presently experienced. This process must be put through a full scoping EIA and external review of the concerns and impacts that we have identified to ensure that alternative sites are investigated. Particularly as issues of water, land, flora and fauna, agriculture, marine life, health, food, energy is fully examined in this expansion.
Procedural framework: A full EIA process needs to be followed from a basic assessment until a full EIA process is fulfilled and completed. The questions we raise regarding this section is why have you not looked at other sites such as Sappi Ngodwana or Sappi Stanger? We don’t want desk top studies but proper sight inspections based on physical information and research and evidence to back the information presented in this document. We want site visits, focus group meetings and all information available to us for viewing.
Methodology: WSP have not considered the impacts and has not been adequately shown. Communities are aware of Sappi’s incidents regarding the gas pipeline leak that affected Sappi staff, Umkomaas Drift Primary school which had to be relocated and multiple nearby community residents of Magabeni and Craige Burn were hospitalized due to this gas leak in 2006.
Here is a link to the above mentioned Sappi Incident: https://midsouthcoastrisingsun.co.za/5282/watchdogs-attack-pollution-by-sappi-saiccor/
The Right to Know | The Duty to Inquire | The Obligation to Act
SDCEA Members P.O. Box 211150 SDCEA Members Earthlife Africa- Durban Isipingo Ratepayers Association Clairwood Ratepayers Association Bluff, 4036 Silverglen Civic Association Umkomaas Anti-Pollution Watchdogs Kwazulu-Natal, South Africa Wentworth Development Forum Isipingo Environmental Committee [email protected] Treasure Beach Environmental Forum Umlazi Unemployed peoples movement Christ the King Church Airport Farmers Association 028-964-NPO Ubunye Bama Hostela KZN Subsistence Fishermen Forum Bluff Ridge Conservancy
Furthermore, the effluent pipeline into the Umkomaas River affected the marine life and the livelihoods of subsistence fishermen of Umkomaas.
There is no risk assessment and this site is in close proximity to communities, the risk must be done and why isn’t this featured in this basic assessment report due to the reputation of Sappi and its incidents?
Public Participation: Appendix B there is nothing captured or provided under this section which is meant to indicate your Stakeholder Engagement and why is this not captured here? Where did WSP host meetings and what was the outcome of your meetings held? Where are the minutes of your meeting/s? Also where are the registers of this meeting and who attended? WSP have not captured the advertisements put into local newspapers and we want to see evidence of these advertisements, including English, isiZulu and Afrikaans and provide pamphlets as communities have stated that WSP have not held any public participation meetings in their communities. WSP needs to explain and give proper responses that can be verified within the stakeholder engagement. Public participation meetings were held by Sappi Saiccor only. Why is this case when this should have been held by WSP the appointed consultants? Many residents have come forward and stated WSP have not hosted any public participation meetings and why is this?
Location of site: WSP doesn’t mention in project context any alternative sites and how did you get to this decision? And why did you choose this site?
Health Impacts of chemicals: Manganese which is a chemical used on the Sappi Saiccor Site – has a chronic health benchmark value of 50ng/m³ (RfC, US EPA IRIS, 2004) was derived from human data from occupational exposure with the critical endpoints of impairment of neurobehavioral function, especially speed and coordination of motor function.
In the event of the cooking process that WSP makes mention of this is actually a reaction process where chemicals react with one another and WSP uses a play on words where they downplay the impacts of such reactions. Also you make mention of reducing coal and in its place you make no mention of what would be taking its place? What are you replacing other gases with? What about renewable energy? And there is no mention of the hidden costs that will arise out of this project.
Surrounding land use: Why Sappi hasn’t done proper measurements according to the distances from the mill to the residential areas, schools, agricultural land, shops and water features? This is not adequate and not accurate. Why did they not get accurate figures of closeness of site?
Upgrade of bleach plant:
The Right to Know | The Duty to Inquire | The Obligation to Act
SDCEA Members P.O. Box 211150 SDCEA Members Earthlife Africa- Durban Isipingo Ratepayers Association Clairwood Ratepayers Association Bluff, 4036 Silverglen Civic Association Umkomaas Anti-Pollution Watchdogs Kwazulu-Natal, South Africa Wentworth Development Forum Isipingo Environmental Committee [email protected] Treasure Beach Environmental Forum Umlazi Unemployed peoples movement Christ the King Church Airport Farmers Association 028-964-NPO Ubunye Bama Hostela KZN Subsistence Fishermen Forum Bluff Ridge Conservancy
Pictures Above and Right: Sappi Saiccor leaking detergent straight out to sea outfall
Calcium and magnesium: What are the total inputs? What are the range of chemicals and what chemicals are in this range?
Water treatment plant: What are the chemicals used? Is it chlorine? How will WSP evaluate the effluent and its treatment before being disposed of? Why are they persisting in use of coal and ash which are high in Sulphur dioxide and cancer causing agents?
Coal lime slurry: Sulphur dioxide that emitted comes out as white smoke and in this case do you have in stack monitoring? Why hasn’t Sappi provided monitoring results? Explain to us the SO2 recovery plant will reduce emissions from the stacks. Additionally we need to know figures and what will be the increased amounts.
Calcium digesters: You do not mention the size in your proposal? Will this cooking liquid be sent through the pipeline? Where is all the waste going to be dumped? This is not mentioned in this basic assessment report and why?
You make mention of a black liquor evaporators and we want to know more about this liquid and what its used for and more details to be provided about this.
With proposed new equipment and added loads to the existing capacity there is no mention of the increase in electricity. What are your current outputs?
Time frame: Sappi has a huge footprint currently and with this proposed expansion added to this current load there will be significant impacts. This is why we want a full EIA conducted as this expansion will have a huge impact than what’s stated by WSP.
The Right to Know | The Duty to Inquire | The Obligation to Act
SDCEA Members P.O. Box 211150 SDCEA Members Earthlife Africa- Durban Isipingo Ratepayers Association Clairwood Ratepayers Association Bluff, 4036 Silverglen Civic Association Umkomaas Anti-Pollution Watchdogs Kwazulu-Natal, South Africa Wentworth Development Forum Isipingo Environmental Committee [email protected] Treasure Beach Environmental Forum Umlazi Unemployed peoples movement Christ the King Church Airport Farmers Association 028-964-NPO Ubunye Bama Hostela KZN Subsistence Fishermen Forum Bluff Ridge Conservancy
Why haven’t you looked at things that are made in South Africa?
Decommissioning: Of materials are not explained? Soil contamination on the Sappi site as well as the bleach plant leaks have contributed to this – how is this going to be tested, is this going to be taken to hazardous dumpsites to be disposed of?
Working hours: Sappi exists in and surrounds residential homes and communities and currently exploit working hours and persist throughout the night causing significant noise impacts currently.
Magnesium oxide: Have had compound effects on marine life especially at Aliwal Shoal which is the remains of an ancient sand dune – a world heritage site and this has not been investigated.
There needs to be alternatives and an investigation on the recovery boiler. As well as there is no information on the turbine capacity and there is no explanation as to why chosen. What is the current storage capacity on site? This has not been disclosed or reasons for this nondisclosure?
No Project Alternative: WSP cannot hold communities around Sappi to ransom if Sappi’s operation already contributes significantly to environmental issues that have not been addressed. They must be fined and Sappi has a history of its pollution.
“The no project alternative would mean that the inherent efficiencies obtained from upgrading production capacity at the same time as reducing atmospheric emissions would be lost. Therefore, the no project alternative is not considered to be reasonably viable.”
With regards to this statement WSP has a history of doing this for their clients and this should not be accepted.
There is no emergency plan should something go wrong such as previous gas leak incidents and community residents were hospitalized.
Local meteorology: Please explain wind speed and direction to the nearest house, nearest school, nearest farm. Do you do continuous monitoring? Why is there data from 2014-2016 only? We live in the south and most of our winds come up in the night winds are often strong but also calm – we request why we do not have wind speeds for 2017 and 2018 and before 2014. How can this plant be expanded when all the monitoring stations are non-compliant? They don’t predict future emissions that will have detrimental effects on people’s health and wellbeing?
Geology: What passed activities disturbed the soil? Oil, chemicals ple4ase explain in detailed information.
The Right to Know | The Duty to Inquire | The Obligation to Act
SDCEA Members P.O. Box 211150 SDCEA Members Earthlife Africa- Durban Isipingo Ratepayers Association Clairwood Ratepayers Association Bluff, 4036 Silverglen Civic Association Umkomaas Anti-Pollution Watchdogs Kwazulu-Natal, South Africa Wentworth Development Forum Isipingo Environmental Committee [email protected] Treasure Beach Environmental Forum Umlazi Unemployed peoples movement Christ the King Church Airport Farmers Association 028-964-NPO Ubunye Bama Hostela KZN Subsistence Fishermen Forum Bluff Ridge Conservancy
Flora and fauna: Indigenous vegetation has not been provided. There is a diverse rich species of animals but this has not been recorded, but WSP state there is none. How have they done their research when there are a range of bird species prominent in the area?
Hydrology: What chemicals are present in the bore holes and what’s in the water? Have they tested the water especially in the tribal farming areas? There is mention of annual ground water carried on site, what have you found onsite and offsite?
Noise levels: You’ve provided us with noise levels for April 2018, why haven’t you provided us with air quality data for 2018? Why is this and also why is noise not provided for 2014? There have been many noise levels and no toll number to complain and record complaints. The road is used by trucks, buses, and not just cars.
Distance: Distances differ from those on page 16 to those on page 43 huge differences in distance and something is wrong in the surrounding land use. Noise levels acceding now what will the noise be when the site expansion is ten times the size now? How can you allow this plant to go ahead?
Traffic: How many more trucks are going to be added to the 600? Noise levels and increase not mentioned and why?
Water abstraction: No mention of using water from the river and the site is going to expand drastically? why is this not featured here when the current usage Sappi has been licensed to use is 53 million m³ from the Umkomaas River?
Effluent management: How are you going to manage manganese oxide as this poses a serious risk to marine life and the Aliwal Shoal heritage site? Studies done 2005 on sea outfall why aren’t studies done after 2005?
Why is there no worst case scenario assessment of nearest household impact? With chlorine and manganese being released into the air?
Expropriation of land: Are they going to be using more land?
The Right to Know | The Duty to Inquire | The Obligation to Act
SDCEA Members P.O. Box 211150 SDCEA Members Earthlife Africa- Durban Isipingo Ratepayers Association Clairwood Ratepayers Association Bluff, 4036 Silverglen Civic Association Umkomaas Anti-Pollution Watchdogs Kwazulu-Natal, South Africa Wentworth Development Forum Isipingo Environmental Committee [email protected] Treasure Beach Environmental Forum Umlazi Unemployed peoples movement Christ the King Church Airport Farmers Association 028-964-NPO Ubunye Bama Hostela KZN Subsistence Fishermen Forum Bluff Ridge Conservancy
Socio-economic: Provide us with an organogram of your current workforce and where jobs are located as this is not featured here. How much have you exported in 2018? Gross domestic product- what benefit is this to South Africans? Why 2003 statistics and not the last five years statistics? What are your levels of unemployed plantation staff? As once in ten years you will provide jobs on the plantations and thereafter this workforce is unemployed for the next ten years?
Last water user: Are the resorts, guesthouses, small industries dependent on marine and beach environment for business use contaminated water.
Vehicle emissions: Not discussed and why is there no monitoring on this? The use of the diesel train but no mention of the noise caused? This is an indication of predicted noise levels and not actual noise levels.
No social enhancement study of current situation and no mention of it done.
Waste removal: How are we going to measure hazardous chemicals? How are we going to know this? The risk assessment is supposed to be conducted now and not later.
There needs to be an indication of how many workers have been affected on site over the years. We also have not seen the negative noise levels.
Way forward: We need independent experts. We need all of these questions answered and not overlooked We need cradle to the grave certificates We need a health study to be done in Umkomaas to assess the impacts on health from the polluter Sappi A full EIA needs to be conducted
Regards
______Desmond Mathew D'Sa Goldman Prize Recipient 2014 (Africa) SDCEA Co-ordinator Tel: 031-4611991 Fax: 031-4681257 Cell: 0839826939
The Right to Know | The Duty to Inquire | The Obligation to Act
SDCEA Members P.O. Box 211150 SDCEA Members Earthlife Africa- Durban Isipingo Ratepayers Association Clairwood Ratepayers Association Bluff, 4036 Silverglen Civic Association Umkomaas Anti-Pollution Watchdogs Kwazulu-Natal, South Africa Wentworth Development Forum Isipingo Environmental Committee [email protected] Treasure Beach Environmental Forum Umlazi Unemployed peoples movement Christ the King Church Airport Farmers Association 028-964-NPO Ubunye Bama Hostela KZN Subsistence Fishermen Forum Bluff Ridge Conservancy
Konigkramer, Hilary
From: Bonisiwe Sithole
Dear Mpendulo,
May you kindly confirm if the above mentioned project will affect the current sappi saiccor's Coastal Waters Discharge Permit conditions. If it will, please stipulate the sections and mitigation measures.
Kind regards, Boni ______From: Dlamini, Mpendulo [[email protected]] Sent: 19 July 2018 03:35 PM To: Bonisiwe Sithole Cc: Mvelo Zulu Subject: RE: DM/0012/2018- AVAILABILITY OF DRAFT BASIC ASSESSMENT REPORT
Mimecast Attachment Protection has deemed this file to be safe, but always exercise caution when opening files. ______
Mpendulo Dlamini Consultant WSP, Environment & Energy, Africa
T +27 31 2408814 F +27 31 240 8801 M +27 74 7111143 From: Bonisiwe Sithole [mailto:[email protected]] Sent: 19 July 2018 10:06 AM To: Dlamini, Mpendulo
Dear Mpendulo,
May I please have reports regarding the project mentioned bellow.
Kind regards,
Miss Bonisiwe Sithole Control Environmental Officer: Marine Pollution and Special Area Management Sub-directorate: Coastal and Biodiversity Management KZN Department of Economic Development Tourism and Environmental Affairs 4th floor Bramhill building 140 Langalibalele street
1