PROPOSED REGIONAL GENERAL AND HAZARDOUS WASTE MANAGEMENT FACILITY IN THE EASTERN CAPE

APPENDICES

June 2010

Bohlweki-SSI Environmental i January 2009

APPENDIX A: DWEA approval of the Plan of Study for EIA

APPENDIX B: I&AP Database

Mr/Ms Intitials/Name Last Name Company/Organisation/Entity Nelson Mandela Bay Metro, Ward Cllr CM Adams 12 Mr. Aubrey Adshade Zwartkops Trust Mrs Susan Alcock EnviroServ Dispose-tech Ms Phumla Alifezwa ANC BEC Ms Sindiswa Apleni ANC BEC Mr./Mrs Zamkele Apolisi ANC Mr A April Community Member Mr Zalisile Armstrong Community Member Mr Vaughan Attwell KirkwoodFarmers Association Nelson Mandela Metropole Cllr HM August Municipality Mr/Mrs TN Ayo African National Congress South African National Civic Mr Daniel Baartman Organisation PE Nelson Mandela Bay Metro, Ward Cllr KT Baatjes 35 Mr Hugo Badenhorst PPC Ms Sigi Bailes Strathmore Farm/SRVCF Mr F Bain Geddes Bain Consulting Engs Premier Nosimo Balindlela Office of the Premier Mr/Mrs Private Bag X 613 Bambeni Ward 53 Nonzuzo & Mr/Ms Melikhaya Bangani African National Congress Mr TW Bantom African National Congress Mr/Mrs A. Barkhuizen Dept of Agriculture Ms Belinda Barlow Cape Truss Manufacturing Ms J Bashe Ward Committee Member Mr. Conrad Basson Arcus Gibb Ms GF Baushana Community Mr V Befile Mrs. Nomvuyo Bekwayo Ms XG Bele Community Environment Network Mr Sekiwe Belu ANC Ms Siphokazi Belu Ward Committee Mr/Mrs LC Bena Youth Member Sundays River Valley Tourism Mr/Mrs JR Beyl Forum Mr Mzwanele Bisa Addo Youth Forum Ms Cikizwa Blaaw CDW Mr John Blackbeard PPC Bluewater Bay Ratepayers Mr. Alex Blacklaws Association Mr M Bless Ward District Ms VC Blignaut Ms Mavis Bloro ANC Cllr NV Blouw Cacadu District Municipality Cllr M Bobani UDM Mr/Mrs PS Bobbie Mr/Mrs BJ Bokwana Mr Gcobani Bolo Ms Nombeko Bolyina African National Congress

Cllr Mandla Bomvana Ward Councillor NMBM, Ward 43 Mr. Jadson Bona SRVM Mr Mike Bonya SANCO Mr Mawonga Booi Ms Nokuthula Booi Ms. Yiliwe Gladys Booi Mr Hymie Booysen KSCDIF Ms Sylvia Booysen SANCO African National Congress Youth Mr Kevin Boqwana League Ms Annie & Cecil Borens African National Congress Dr Andre Boshoff Terrestrial Ecology Research Unit Mr. Danie Botha PPC Cement South African National Roads Mr Izak Botha Agency Ms. Jenny Botha Black Management Forum Ms Nosimo Botha Community Member Ms N Boyce ANC South African National Civic Mr Poyo James Bozo Organisation PE Ms M Bradfield SANParks Addo National Park Mr Boy Branden ANC Mr Sheldon Branford Cape Comm. Props Ms B Brenda PE Drums Mr/Mrs AJ Briggs Good Hope Farm Ms Jacky Broadhurst Arlington Monitoring Committee Mr Eric Brown Ityatyambo Mrs N Budaza African National Congress Mr/Mrs JR Buel SRV Tourism Forum Mr Howard Bulkin Boundry Paper & Plastics Nelson Mandela Bay Metro, Ward Cllr ML Bungane 48 Mr Douglas Bungu Mr PH Bunton Mr/Mrs NB & WB Burger PHD Slucteul Ms Barbara Buster SRV Tourism Ms Portia Cacela ANC BEC Mr Mkuseli Calata SA National Civic Organisation PE Mr Thanduxolo Caluza Community Member Congress of South African Trade Mr Mnikelo Camagu Union Mr Andile Canda Mr NG Carter Arcus Gibb African Renaissance Sport Mr Moki Cekisane Foundation Mr Monwabisi Cekiso African National Congress Mr Siyabonga Cengani Ward Committee Member Dr. Chabula Cacadu District Council African National Congress Women's Madam Chairperson League Mr/Mrs Chairperson PE Afrikaanse Sakekamer Mr Len Chandler National Ingredient Suppliers Ms Mary Chettle Mary Chettle & Associates Mr Lulama Cikolo

Mr Mzuhleli Citwa African National Congress Mr. D Civico Fume Engineering Ms. Ronel Claasen Poltech EC Mr H Clark Eveready Pty Ltd Mr Mkhuseli Class African National Congress Mr JA Coetzee Geluk Farm Mr. Pieter Coetzee Cacadu District Council Mr. Mike Cohen Community Environment Network Mr. Coleske Ms Theresa Condes Comparex Africa Nelson Mandela Metropolitan Mr. Neil Contell Council Mrs Gloria Cousins Mr Lukhanyo Crab African National Congress Mr Phatheka Ctana ANC Miss JB Damane Community Member Ms Anita Damons Mr Anthony Dancey Mr. C Daniels African National Congress Youth Mr Wonga Daniels League Mr. Mabhuti Dano African National Congress Mr/Mrs ZC Danster Mr/Mrs ZL Danster Mr Danster Mr Thobani Dashe Mrs NL Dastile Community Member Mr Charles Davids Mr Rick Davies River BendCitrus/ Lodge Mr MP Dayimani Mr Connie De Klerk JA (Junior and KilliamWilliam Strydom Deon Mr Senior) De Klerk Scheepers Mr de Klerk Coega Kammas Kloof Mr de Klerk Coega Kammas Kloof Mr Francious De Kock Algoa Engineering Bluewater Bay Ratepayers Mr Mike De Souza Association Mr Dudley De Vaux Zwartkops Trust Cllr DWS de Vos Cacadu District Municipality Ms Florence F De Vos SANCO Mr P Deetlefs Cosmos Cuisine Ms Jochelle Dekker Eveready Mr Stef Delport Kirkwood Farmers Association Nelson Mandela Bay Metro, Ward Cllr Fikile Desi 49 Mr MT Desi Nelson Mandela Bay Metro Mr. Philippe Devailly Onyx Miss ME Deyzel Winterhoek Bosveld Landbouvening Mrs NP Didiza Ms Joyce Didiza-Batye African National Congress Ms Bulelwa Diko Mr Lubabalo Dimbaza GRADIMA

Ms Monica Diniso Mr. J Dirker Dirker family Trust Mr MC Dlabathi Mrs Nomvulazana Dladla Ward Committee Member Mr Sbusiso Dlamini NMMM Land Planning Ms Mabel Boniswa Dlepu Motherwell Clean and Green Project Nombulelo, Nontuthuzelo & Ms Thembela Dodo African National Congress Ms Xoliswa Dodo Ms Nocawa Dokwana Ward Committee Mr H Dolley Willard Batteries Mr. James Dondashe Worker Ms Nobangela Dondashe African National Congress Mr Benny Dorfling Community Member Mr Zamekile John Douw Mr. Du Piesanie Mr JHH Du Plessis SR Water Users Association Ms Khangelwa Dubula ANC BEC Winnie & Ms Nothulamile Duma Ms Alice Dwakaza Ward Committee Member Mr Spiwo Dwane Mr. Welile Dwani Ms. Funeka & Bonile Dyakala Mr Mpati Dyantyi Ms Joyce Dyasi Motherwell Clean and Green Project Mr Kiki Dyimi Mr/Mrs Fleur Dyordin Eveready Ms Esther Dzedze Ms Wendy Edge-Hiscock Betzdearborn Pty Ltd Godfields Biotechnology Group, Mr. Clark Ehlers Rhodes University Mr Robert Einkamerer SRVM Mr Leon Els Dept of Environmental Affairs Nelson Mandela Metropole Mr WKN Emslie Municipality Ms Carina & Jakkie Erasmus Mr Erasmus Art Engineering Ms Thandiwe Faku Ward Committee Member Mr Thando Faku African National Congress Miss X Faku Community Member Mr Sipho Faltein Community Member Urban Services Group / PE NGO Mr. Clive Felix Coalition Mr. MG Ferreira Mr Keith Finnemore SRVCF Mr Fischer Gubb & Inggs Mr AT Fitzpatrick Sunland Farms (Pty) Ltd Nelson Mandela Metropole Mr FE Flatela Municipality Ms. Saskia Fourie Mr Nigel Fox Gemtec Ms O Frank

Ms Julia Frost St. George's Hospital Mr Peter Frost Delta Straundale Plant Kirkwood Agricultural Union Mr Phillip J Frost (Chairperson) African National Congress Youth Ms Kholeka Gadu League Mr Keith Gafney Winterhoek Bosveld Landbouvening Mr ME Galela African National Congress Regina & Ms Nompumelelo Gampu Mr Thembisile Gana Ward Committee Member Mr Zola Justice Gangca Ward Committee Mr Monwabisi Gans SANCO Mr Kevin Garner Lafarge SA Ms LC Gashe Mr Thando Gaveni ANCYL Mr/Mrs Gcaba Ms Joyce Geja Mr/Mrs SD Genu South African Communist Party Ms Maureen George Mr/Mrs TB George Mrs M Gerber Atsun General Engineering Ms. Nozizwe Geza ANC. Wessa Conservation Comm. Mr. Matt Gibbs Member Mr. Winton Gibbs Mrs. Nancy Goddard Redhouse WA Mr Fumanekile Gojela SANCO Branch Mr Ncedo Gola African National Congress Nelson Mandela Bay Metro, Ward Cllr ML Gomomo 21 African National Congress Youth Ms Nontsikelelo Gongqa League Ms Nontuthuzelo Gongqa Ms NM Gongxeka African National Congress Nelson Mandela Bay Metro, Ward Cllr Andre Goosen 21 Mr/Mrs D Goosen Coetye Dorstrye Ms Ester Goosen Transnet Mr. Bevan Goqwana Health Deputy Director: Environmental Mr Dayalan Govender Affairs Mr Thandikhaya Gqabi SA National Civic Organisation Nelson Mandela Bay Metro, Ward Cllr AA Gqalane 29 Mr. Wiseman Gqamana SANP Addo Elephant Park Ms Phumeza Gqazengele African National Congress Mr/Mrs NH Gqogqo Community Member Mr Thando Gqomo Ms Fikiswa Gquma ANC Ms Betty Sharon Greef Ward Councillor NMBM Mr/Mrs P& R Greville Mr. PB Grewar Mr Brian Grey Bridgestone Firestone

Mr Emile Greyvenstein Erf 190/3 Grassridge Mr Morgan Griffiths WESSA- Eastern Cape Ms Wendy Griffiths St. George's Hospital Ms Ann Grine Pico (Pty) Ltd Grobbelaar/ Mr Leon / Neville Heckrath Intensive Waste (Pty) Ltd Envirofill Mr Thulani Grootboom ANC Mr Kerneels Grundling PPC Ms Nomzi Gume Community Member Ms Pumza Gunya African National Congress Mr Z Gxekani Ward 47 Committee Mr. Piet Gxewa Mr Thozamile Gxowa African National Congress Mr Trevern Haasbroek Mr Malusi Hadi African National Congress South African Rail Commuter Mr. CRP Hahn Corporation Ltd Mr Royal James Hamman Mr. Ian Hammond Waste Resources Pty Ltd Mr RJ Hammond RJH Renovator Mr/Mrs MS Hanabe African National Congress Mr Mpumelelo Hani Mr T Hanise Community Mr James Hannah Sun Orange Farm Mr/Mrs PD Hans African National Congress Mr. Paul Hansen SRV Community Forum Mr Ludwig Harris Uitenhage Waste Collectors Mr. S Hayes Mr Eugene Heeger Coega Development Corporation Mr/Mrs Aubrey Helmey Community Member Mr Xolani Henda Ms Maggie Hendricks CUP Soup Kitchen Mrs. Willem Hendriks Cllr TM Herbst Nelson Mandela Bay Metro, Ward 5 Mr R Herhold Sunday's River Valley Municipality Mr Rudolph Herholdt Sunday's River Valley Municipality Ms Florence Hermans ANCWL National Education Health & Allied Mr Maria Hermans Workers Union Ms Gloria Heshu African National Congress Ms Carol Hiles Voting District African National Congress Youth Ms Mandisa Hini League Mr/Mrs M Hitge Hitgehesm Mr Ayanda Hlathi Mr David Hoffman Goodyear SA Pty Ltda Mr Paul Hoffman ADV RP Hoffman SC Mr. Jörg and Sue Hoffmann East Cape Conservancy Ass Ms. Judy Hoggons Northern Areas Development Trust Mr/ Mrs Eric & Liz Holmden Armadale Farm Dr. Stephen Holness South African National Parks Mr. Simo Hopa Disaster Management, CDM Mr Megan Hope ECCA

Cllr F Hote Nelson Mandela Bay Metro, Ward 5 Mr. Peter Howard Farmer Mr Andri Hugo Amandla Environmental Ms Nosango Hulushe African National Congress Ms Nomfundo Humata Mrs. Valerie Hunt Wildlife Society Mr. C Hurn Mr JH Husselmann Sundays River Citrus Co-operative Mr Werner Illenberger East Cape Clean Air Initiative Mr Peter Inman Coega Development Corporation Mr/Mrs X Inu African National Congress Mr M Jack MP Jack Mr/Mrs Lulama Jackson African National Congress Ms N Jacobs Ms Nokuthula Jacobs African National Congress Ms Lindiwe Jafta ANCYL Ms Bukelwa Jama Ward Comm. Mr. Fannie James Black Management Forum Mr Nicholas James Dept of Records and Admission South African Municipal Workers Mr C Jamta Union Mr/Mrs H Janlut Habuta Ms Nonkoliseko Jantjie African National Congress Nelson Mandela Metropole Cllr T Jantjie Municipality Mr Monde Jebe Mr. A Jeeva East Cape General MNF PE Regional Chamber of Ms Wendy Jefferson Commerce & Industry Mr. Chris Jeffrey Wildlife and Enviroment Society Mr ZL Jekwa COSATU PE Local Mr VC Jensen Birchmore Mr/Mrs L Jibiliza Community Member African National Congress Youth Mr Fezile Jijana League Mr Vuyani Jim African National Congress Ms Nomvuyiselelo Jo Ward Committee Member Mr Welcome Jobela Afrox Mr Daliwonga Jobo Community Member Mr/Mrs M Jonas African National Congress Mr Gregory Jones SRVCF SA National Civic Organisation Mr Thembikile Jonga (Secretary) Ms Mary Jooman Precision Exhaust Systems Mr Chris Jordaan Colchester Community Mr Claud Jordaan Community Member Mr Melvin Jordaan Community Member Mr Deon Joubert Unifrutti Mr SJ Joubert Hababa Ms N Joxo-Matenjwa Mr Marius Jurgens Kirkwood Farmers Association Mr Eric Kakana Ward Committee Member

Ms Mandisa Kaleni Ms Pumza Kaleni Dept of Water and Forest Nelson Mandela Metropole Ms Abigail Kamineth Municipality Mr/Mrs MC Kapayi African National Congress Mr/Mrs SH Kasibe Community Member Ms JN Kaspiri Ward Committee Member Cllr PM Kate Cacadu District Municipality Mr. Joseph Kato Ms Phumeza Keke African National Congress Nelson Mandela Metropole Mr Ken Kendall Municipality Ms. Nomalungelo Kete Ms Nondumiso Ketye Mrs. ME Keyter Mr Sabona Kgasi DWAF Urban Monitoring & Awareness Mr. Len Khalane Cmt. Mr Solomon Khunou PE Tourism Mr/Mrs SN & Ndondomzi Kibi African National Congres Mr Dale King African Hide Trainer Mr Les Kingma Community Mr Kobus Klaas Community Member Ms LV Klaas Mr M Klaas Community Youth Mr Sithembele Klaas ANC Mr. Mike Knight South African National Parks Nelson Mandela Metropolitan Mr RA Knipe Council EnviroServ Waste Management Mr/Mrs Thea Koch (Pty) Ltd Nelson Mandela Metropole Mr Sipho Kohlakala Municipality Ms Noluthando Kolele African National Congress Ms Mandisa Kolisa Mr Lungile P Kolisi District N Komsana Mr Ntsikelelo Konaha ANC Cllr LP Kondile-Mlonzi Mr Sipho Konzani Mr Sipho Konzani Ms Lungelwa Kosani Ms NJ Kose Mr Mzukisi Kotela ANC Metro Region Ms Nomzamo Kotsele PE Regional Chamber of Mrs Marinda Kotze Commerce & Industry Mnr T. Kotze Olifantskop Citrus Farms Mr Themba Koza Coega Development Corporation Ms Nicolette Krause Airshed Planning Professionals Kirkwood Agricultural Union Mr R Krause (Secretary) Mr Percy Kriedemann Lazy Dryg Farm Dr. RJ (Cobus) Kriek Mintek

Mr/Mrs LJ Kula SRVM Ms Zoliswa Kula African National Congress Mr. BM Kulati Mr Fungile Kume African National Congress Ms Nozipho Kundayi Nelson Mandela Bay Metro, Ward Cllr Martin Kuscus 14 Ms Vuyokazi Kuse GRADIMA Mr Derrick Kwanele African National Congress Ms Thembisa Kwanini Cllr MM Kwenaite Nelson Mandela Bay Metro Ms Somikazi Lagenge ANC Mr Gordon Lake LW Lake & Sons Tankara Mr Mazwi Lama African National Congress Mr Thembinkosi Lambani Community Member Mr Mlungisi Lande Ward Committee Member Ms Joyce Landu African National Congress Ms LB Langbooi African National Congress Ms DN Langman NMBM Environmental Services Mr/Mrs Linda Lasmisi Community Member Mr Marius Latter Farmer Ms/Mr Hugh Laue Zwartkops Trust Nelson Mandela Metropole Cllr TW Lawu Municipality Mr. Jokl Le Roux East Cape Game Management Ass Mr Riaan Le Roux Nelson Mandela Bay Metro Mr Paul Leese Coega Development Corporation Mr Mark Lentin ABSA IDZ Mr Llewellyn Leonard GroundWork South African National Civic Mr Toni Lepela Organisation PE SAHRA, Archaeology, Ms Mary Leslie Palaeontology & Metorite Unit Ms Wendy Ann Lester PERCCI Mr Tom Lindolf Zwartkops Trust Mr Paul Lochner CSIR Mr. John Lockhead Ms Boniswa Lolwana Prof SS Long PE Technikon Mr/Mrs M Loonat Health & Welfare Mr/Mrs PW Loro African National Congress Cllr J Lose Sunday's River Valley Municipality Mr T Lotz Nelson Mandela Metropole Cllr Annette Lovemore Municipality Cllr ML Lowe Nelson Mandela Bay Metro, Ward 2 Dept of Water and Forestry Water Mr. Andrew Lucas Quality Management Mr Johanes Lucas Mr ME & Z Lucas African National Congress Ms Nqabakazi Lufuta Coega Development Corporation Mr Nkundla & PB Luguxa

Mr Raymond Lund SAPPI Mr Mzolisi Luphondo SANCO Mr AM Lupondwana Community Ms Xolisa Lupuwana Arcus Gibb Mr George Luse FABCOS Ms Nozizwe Mabizela Mr Mzwandile Mabuya Mr Malcolm Mackenzie Hella SA (Pty) Ltd Ms Nozengazi Maclean Mr Gordon Maclear SRK Consulting Ms Primrose Madikizela Safety & Quality Manager, Transnet African National Congress Youth Mr Simphiwe Madlavu League Ms Bongiwe Madlokazi South African Municipal Workers Mr N Madubedube Union Mr Lunga Madubela African National Congress Mr Joe Madwara Ward Committee Member Mr/Mrs Unathi Madyo Ms Zanele Madyosi Mr Luthando Mafana ANC Mr Mzwabantu Mafana African National Congress Ward 60 Cllr Thembinkosi Mafana Councillor Nelson Mandela Metropolitan Mr. SVP Mafongosi Municipality SG Mafu Mr/Mrs Mafu Mr/Mrs Vuyokazi Magasane African National Congress Mrs Magida Community Member Ms Thembisile Magqangeni African National Congress Mr Viwe Magula African National Congress Ms Ntomboxolo Magwa African National Congress Mr/Mrs Magwada Mr Thembelani Magwebu African National Congress Ms Nombulelo Magxaki African National Congress Mr Mzimkhulu Mahe Mr Mvuleni Mahola Ward Committee Member Ms Gladys Majalamba African National Congress Mr Buyile Majali SRCC Agri BEE South African National Civic Mr Z Maji Organisation PE Ms Thobile Majiki Mr Andile Majola Mr Luyanda Majola African National Congress Ms Nokutu Makalima Mr Frans J Makapie Community Member Mr Cheeky Makasi African National Congress Mr Bonisile Makedlana Community Member Mr Tsepiso Makgato Community Member Mr Andile Lungisa Makhanda South African National Civic Mr/Mrs LK Makinana Organisation PE Mr/Mrs MW Makuleni African National Congress

Mr. JS Maledu African National Congress Chemical Energy Paper,Printing Mr MKG Maleki Wood & Allied Workers Union Mr Thabo Malgas Mr/Mrs M Malherbe River Bend Nelson Mandela Metropole Cllr J Mali Municipality Mr/Mrs MR Mali African National Congress Mr Tamsanqa Mali African National Congress Khanya Local Business Service Miss Nandi Maliza Centre Mr Martin Mandla Community Environment Network Ms Bulelwa Maneli ANC Mr David Maneli Nelson Mandela Metropole Cllr MM Manentsa Municipality Ms Akhona Mangali Ms Nomthandazo Mangaliso SANCO Mr. M Mangena Fire & Emergency Services Mr Thembisile Mangqangeni Mr A Mangqase Community Mr Rodney Manicom Wasteman Group Ms. Nombulelo Manjezi Ward Comm. Mr. Stanford Mankayi Ms Marcia Mankeya Ward Committee Member Mr Siphiwo Mantile Addo Youth Forum Ms Jill Manuel NMBM: Environmental Management Ms. Violet Manya Mr/Mrs WD Mapeli Community Member Mr Wezile Mapempeni Motherwell Clean and Green Project Nelson Mandela Metropole Cllr JN Mapu Municipality Mr Luvuyo Maqakaza Community Environment Network Mr Vuyisile Maqalo Ms Malibuseng Maqanda Community Ms Fundiswa Maqhetseba Ms Sweetness Maqizana Ms S Maqula Community Mr Charles Marais Hugenot Farm Mr. JD Marais Mr P Marais Allandale Farm Mr. Paul Marais SRWI Mr Simphiwe Marangula Mr. P Maré Pretoria Portland Cement Ms Enelen & Milton Marela Mr Fred Marshall Atlas Plastics Mr/Mrs A.S. Martin SANCO Mr Paul Martin Cape Chemical Industries Dr Paul Martin Coega IDZ / Port of Ngqura Mr M Marwana Mr. Masebe Mr. Roger Mason Sappi Waste Paper MEC. Phumulo Masualle Public Works and Transport

Mr Elijah Matabese African National Congress Mr. Thembikhaya Matanzima Ms Thembisa Matebe Motherwell Clean and Green Project Nelson Mandela Bay Metro, Ward Cllr LEW Matebese 54 Ms Mirriam Matebese SANCO Ms Pumla Matebese Mr BH Mathenjwa Project Committee Ms Sharlene Mathews Agri Eastern Cape Mr Ndiphelele Mathuthu SANCO Ms Nontuthuzelo Mati African National Congress Ms Nomba Matikinca African National Congress Nelson Mandela Metropolitan Mr AG Matisi Council Mr M Matomela Community Mr Alfred Matroos Ward 7 Mr Mxolisi Matsamko Community Member Mr Boyce Matshisi African National Congress Mr. Bonisile Matshotyana African National Congress PE Regional Chamber of Mr/Mrs BW Matthews Commerce & Industry Mr Solomzi Mavi Private Ms Hazel Maweni Planned Parenthood Association Mr CJ Maxambela Mr. Maxhegwana African National Congress Mr Elliot Mayisela Z Mayo Ms Fundiswa Mbane Youth Sector Mr/Mrs T & Gift Mbaxa Ms NS Mbena African National Congress Dept Economic Affairs Environment Ms. Mbengashe & Tourism Z Mbona Ms N Mbotshelwa V Mboxela Mr Siyabulela Mboyi Mrs Dawn Mc Carthy Nelson Mandela Bay Metro Mr Buck McFarlane Aberdare Telecommunications EnviroServ Waste Management Mr. Stuart McMullan (Pty) Ltd Mr/Mrs Blue McQuade M.J.M. McQuade & Associates Mr. Rob McWilliams Zwartkops Trust Mr/Mrs TJ Mdaniswana African National Congress Mr. Nosipho Mde Ms Nandi Mdingi Community Member Ms XE Mdingi Nelson Mandela Metropole Mr Reiner Meintjies Municipality Mr Peter Meiring Kirkwood Farmers Association Ms. Sindiswa Meke Mr George Meko Ms Nomonde Meleni Mr/Mrs N & Wilson Melese African National Congress Mr/Mrs Fay Meltz Nelson Mandela Metropolitan

Municipality Ms Neziwe Memani African National Congress Ms NG Memani Mr Sipho Memani Food & Allied Workers Union Ms N Mesani Ward Committee Mr Hannes Meyer PPC Cement Ms Petra Meyer SA Breweries Ms Nonceba Mfengu African National Congress Mr Fikile Mfukeli African National Congress M Mfuko Nelson Mandela Bay Metro, Ward Cllr ACG Mfunda 30 Ms L Mgaga Community Ms Gwen Mgayi SAWIMA Ms Zoleka Mgojo Ward Committee Member Ms Tabisa Mgoqi Mr S Mgoqozi Community Mr X Mguca Community Nelson Mandela Bay Metro, Ward Cllr ET Mgwanza 26 Mr Nkosinathi Mhlana African National Congress Ms Mawethu Mhlauli Ms Nomahlubi Mhletywa African National Congress Mr Ndumiso Mila Mr/Mrs D Mille Woodal Ms Muffy Miller SRV Tourism Forum Mr/Mrs NC Mini Community Member Mr QL Mini Community Member Ms MM Mintoor Community Member Mr. CM Mitchell Mitchell Trust Lulama, Nomathamsanqa Ms &Thozama Mithiyo Mr M Miyo Ms Mabel Mjoli African National Congress Ms Nandipha Mjuza SANCO African National Congress Youth Mr Buyisile Mkavu League Mrs Jane Mkhontwana Community Member Mr Mzolisi Mkiva African National Congress Ms Tenjiwe Mkobeni Motherwell Clean and Green Project Ms Ntombizodwa Mkokeli Ward Committee Member Ms Nombeko Mkonjeni ANC NMBM - Environmental Mr Joram Mkosana Management Mr Tembile Mkosi ANC. Mr Mnyamezeli Mkoto Masakhane Voting District Mr Nelson F Mkoto Nelson Mandela Metropole Mr Tsediso Mkumatela Municipality Eastern Cape African Chamber of Mr Mthobeli Mlahleki Commerce Ms Pumza Mlalandle Ms Tandiswa Mlambo SANCO

Ms Noluthando Mlele African National Congress Mr Jackson Mlinda Sports Forum Mr Eric Mngaza Ms Nosipho Mntanase Community Mr Billy Mnyaluza Mr/Mrs N Mnyanda Ward Committee Mr Themba Mnyateli ANC Mr Mziwakhe Mnyubusi African National Congress Nelson Mandela Bay Metro, Ward Cllr LM Mohapi 28 Mr Wynand Moller DELTA Motor Corporation Mr Linda Mona Mziwoxolo & Mr Vusikhaya Mona Ms Ntombizodidi Mona Ms Mandisa Mondi National Ports Authority of SA Mr Archie Mongo Addo Youth Forum Ms Pamela Moodley Delta Motor Co-operation Mr Soldier Mooiman Ms. M Moore Fundile & Themba Mr Solani More Community Member Mr Mkokeli Moyake Mr Lesley Mpanzi Coega Aluminium Smelter (CAL) Mrs P Mpati African National Congress African National Congress Women's Ms LG Mpohla League Mr Mpupa African National Congress Mr Mnombo Mpushe African National Congress Ms PT Mpushe African National Congress Mr Siphelo Mqhoma Mr/Mrs Z Mshweshwe African National Congress Ms Lindelwa Msinekelwa African National Congress Mr MM Msizi Mr Mpumelelo Msizi Ward Comm. Mr Simphiwe Msizi Ward Committee Nelson Mandela Metropole Cllr LR Mtana Municipality Nelson Mandela Metropole Cllr MC Mtanga Municipality African National Congress Youth Mr Tembinkosi Mtanga League Mr Mbulelo Mtati PE Regional Chamber of Mr. Odwa Mtati Commerce & Industry Nelson Mandela Metropole Cllr PP Mtati Municipality Ms Phumeza Mthimkhulu African National Congress Ms Leona Mtimkulu Ms Nonyaniso Mtshawulana Ward Committee Member Mr Luvuyo Mtshiselwa Sports & Culture South African Natinal Civic Mr/Mrs Scrummy Mtwa Organisation PE Nelson Mandela Metropole Cllr TC Mtyapa Municipality

Ms Ntombi Mtyhobile African National Congress Ms Laurence Muburgh SANTA Mr Fleur Mulder Eveready Pty Ltd Mr Mxolisi Muleka Mr Lowrens Mulle Kirkwood Farmers Association ERM Southern Africa (Pty) Ltd - Ms Frauke Munster JHB Office Mr Mxolisi Muradzi African National Congress Mr Stephen Murray Amanzi Country Estate Mayor MG Mvoko Cacadu District Municipality NJ Mvulane Mr Thembinkosi Mwahla Ward Committee Member Mr Lulamile Mxaku Ms Ndileka Mxaku African National Congress Ms Zoleka Mxoli Sports Forum Mr. Norman Myers Mr Goodman Mzimasi African National Congress Mr Peter Mzimkhulu Mr Mthuthuzeli Mzini Ward Committee Member Mr Mkhuseli Mzinyathi Mr/Mrs Nabo Ms Julia Namba African National Congress Ms Bukeka Nants PE Complex Health Livingstone Mr/Mrs L Ncaca Hospital Mr Mzukisi Ncamani African National Congress Mr Vuyani Ncana South African Communist Party Ms Martha & Ncediwe Ncedwe & Moss African National Congress Ms Sekiwe N Ncisana Ward Committee 51 Mr/Mrs M Ncwana Mr Ndakhele Mr Fezile Ndema Coega Development Corporation Mr Sandile Ndema Ward Committee Member Ms Yolisa Ndema Ms Pumla Ndingaye African National Congress Ms P Ndlovu Ms. Celiwe Ndoni Worker Mr Mzwandile Ndoni African National Congress Ms Nomalizo Ndoni African National Congress Nelson Mandela Metropole Cllr PS Ndoni Municipality Ms Tozama Ndoni African National Congress Mr Mtiwabo Ndube ANC Metro Region Ms Nelisa Ndulama PPC Ms Thobeka Ndunyane African National Congress Ms Nobelungu Ndzelisa Ward Committee Member Mr. Ndaba Ndzombane Metroplan Mr. Deon Nel Ms Nonkoliseko Nel Ms N Neliswa Mr Renaldo Nell DWAF Mr. Nell Mr. N Netu

Mr. Clive Newman Impala Group Ms Virginia Ngandi Debbies Contruction Ms. Nomhlobo Ngange African National Congress Mr. Luthando Ngcangca ANC. Mr Xola Ngcangca Youth Sector Ms Nombulelo Ngciphe Community Member Nelson Mandela Metropole Cllr TH Ngcolomba Municipality Jongile Ngele Ms Princess Ngesimani African National Congress Ms Agnes Ngindo Mr Samuel Ngona SANCO Ms Bukelwa Ngono ANCWL Mr/Mrs AR Ngoqo SA National Civic Organisation Mr N Ngoqo Mr Vuyisile Ngqandu Ms Veliswa Ngqonga Mr/Mrs N Ngwantashe Community Member Ms Nomfundo Ngxale Mr Gladman Ngxokwana Ms Nomthandazo Ngxonono Mr Nkosinathi Nicholas African National Congress Mr Amien Nieftagodien Mr Lungelo Ningi Mr Clive Niven Amanzi Packhouse Mr/Mrs JDF & SA Niven Mfuleni Farm Mr Vuyo Niwa Mrs Njanjala Community Member Ms Belinda Njoloza Coega Development Corporation Ms NM Njongi African National Congress Eastern Cape African Chamber of Mr Loyiso Nkantsu Commerce Nelson Mandela Bay Metro, Ward Cllr MM Nkewu 26 Cllr MS Nkohli Nelson Mandela Bay Metro, Ward 3 Ms Pumla Nkohli African National Congress Mr Thando Nkombisa Land Claims Mr Zolile Nkombisa Community Member Mr Xolani Nkonjane Addo Youth Forum Mr Lonwabo Nkosana African National Congress Mr Thembile Nkosiyapantsi Ward Committee Mr Sidima Nkumanda African National Congress MEC. Gugile Nkwinti Housing and Local Government L Nobebe Zimisele Nocanda Mrs Beauty Noda Community Member Mr. Phumzile Nodongwe COSATU Mr Nodwele Health Dept Mr Mziyanda Nojoko African National Congress Ms Carolina Nolingo Nelson Mandela Bay Metro, Ward Cllr CM Nombiba 14 Ms Zukiswa Nomeva

Mrs. Selani Nongeniselo Nono Mr David Nontshinga Mr Tim Norris DELTA Motor Corporation Ms NB Nosilela Community Institute for Waste Management Mr Peter Novella Association SA Ms Lydia Nqokwe Ms Thandiwe Nqontsha Community Member Mr Nqowana Mr M Nqwata Ms Nosimo Ntakana African National Congress Ms Nomvuyo Ntambuleni Ms Busisiwe Ntamo African National Congress Ms Thando & Mandisa Ntamo African National Congress African National Congress Youth Mr/Mrs ZE Ntamo League Ms Boniswa Ntanjana African National Congress South African National Civic Ms Thembisa Ntantiso Organisation PE Ms Ntombentsha Ntinga Mr Tobile Ntola South African Communist Party Ms Stella Ntongana Ward Committee 51 Mr Zolile Ntoyanto Ward Committee Member Ms Nomakaya Ntozini ANCYL Ms N Ntsele Community Mr/Mrs G Ntshede Community Member Ms N Ntshobodi Ward Committee Member Nelson Mandela Metropole Cllr Beza Ntshona Municipality Mr Sipho Ntswahlana African National Congress Ms Nolubabalo Ntunzi Coega Development Corporation Mr Tuney Nubayiwa Ward Committee Member Ms NE Nxele African National Congress Mr/Mrs V. Nyanda Ward Comm. Ms Phumla Nyathi African National Congress Mr Alex Nyati EACP arts and craft Ms Tiny Nzeku Mr Hennie Oelofse Siesta Mr Eric Offerman Coega Brick(PTY) Ltd Mr Warwick Ofsowitz Phoenix Hotel Ms N Oliphant African National Congress BEC Mr. Marius Olivier Setplan Mr William Oosthuizen Algorax Dr. BLR Otto Ms Pindiwe C Oyise African National Congress Ms Bukiwe Pamba Ward Committee Member Mr Tabiso Pamba SANCO Mr/Mrs E Pana Community Member HC Pango Mr Greg Parker Greyvensteins Mr./Mrs N.G. Pase SANCO Glenda Patterson Zuurberg Mountain Inn

Mr S Payi Colibri Towels Mr./Mrs R. Peni Emlungisi Disabled Ms Andiswa Pepese Mr John Perold Sundays River Citrus Co-operative Mr Lizo & BC Peta Mr Thando Peta South African National Civic Mr Aaron Peter Organisation PE Mr. T.G. Peter Ms Tanise Peter African National Congress Mr Dennis Petersen Ford Motor Company Mr Esley Phalo Ms Xoliswa Phama Mr/Mrs D Phillip Community Member Mr. TJ Phipps Community Service Environmental Mr Zingisa Phohlo Health Practioner Mr/Mrs L Pickels Sundays River Primary Mr Desmond Pienaar Mr PA Pienaar Cempro Brick Mr Cornelius Pieterse Agri Eastern Cape Mr Hendrik Pieterse Mr DM Pillay Cacadu Municipality Ms Phindiswa Pita Community Member Mr. Dubrien Pitoyi ANC. Mr Frank Plaatjies Mr/Mrs M Plaatjies Community Member Ms Mavis Plaatjies Mr/Mrs DA Plakkor SRCC NC Polo Ms Jennifer B Pompy Community Member Mr Mawethu Poni South African Communist Party Mr Frikkie & Ronnie Potgieter Mr/Mrs Potgieter Suttonvale / Grassridge Farm Ms Fiona Pralten Stellenhof Farm Ms Eunice Pretorius Community Member Mr John Pretorius Algoa Roller Mills (Pty) Ltd Sicela Community Development Mr Goodman Prince Forum Ms Amanda Pruissen Arcus Gibb Ms Siphokazi Puwana African National Congress Mr Max Qandana Community Police Forum Ms Gciniswa Qatshana Nelson Mandela Bay Metro, Ward Cllr SJ Qona 17 Mr/Mrs R Quin Huview Farm Mr Siyabulela Qwazi Mr Bongani Rala Mr Mangele Ralo Sunday's River Valley Municipality Mr Mark Ralph Rocklands Poultry Mr. Mark Ralph Ms. Ina Randall Algoa Sun Mr. T Ranger Prentice Kraal

Mr AK Rathbone Anti Waste Drum Reconditioner Mr Siyabulela Rawula Ward Committee Member Mr Pieter Retief Dept of Water and Forest Mr. TF Rintoul Roberts Mr N Robertsen Cape of G Hope Wool Combers Mr CJ Robertson Fedwin Farm Ms Merlene Robinson Cadbury Mr M.N. Rodwell ANC Mr. Guy Rogers TML Mr Siphiwo Rolo African National Congress Mr. Brad Rosser Mr Francoius Roux R & L Bordery, Coega Kammas Mr L & Petronella Roux Kloof Mrs M Roux Mr W Roux Swartkoppen (Farm North of Coega) Mr Nick Rudd Aardvark Guest House Ms NN Rudlin Mr Authur & CC Rudman Uitenhage Farmers Association Mr/Mrs Barbara Rudman Mr Henry Ruiters Community Member Mr/Mrs Ruiters Mr/Mrs Ruiters Ms Tobeka Rulumeni Mr Simphiwe Rume SACP. Mr Arthur Rump Zwartkops Trust Mrs. M Saayman Mr Manamela Sadimo DWAF Ms Ali Said Nelson Mandela Bay Municipality Mr/Mrs SS Saki South African Communist Party Mr Michael Salawa African National Congress Ms S Sam Mr Evans Samuels Eberspacher SA Pty Ltd Ms S Sarah S.A.F.I.C. Mr/Mrs D Sauer Die Burger African National Congress Branch Mr/ Ms L & G Sayster 43 Mr Andy B Sceales FCA (SA) Mr J Schamrel Mr Deon Scheepers Mr Jacques Scherman Municipal Voters Association Ms Hester Schoeman Community Member Mr/Mrs Manie Schoeman Community Member Nelson Mandela Bay Metro, Ward Cllr A Scholtz 34 Mr Strelza Schumann Kings Beach Mr. Schwartz Friends of the Beachfront Mr Mnoneleli Scritch ANC Mr Pindile Sebezela African National Congress Mr/Mrs JB Seeland African National Congress Ms Mandisa Septemba Mr/Mrs Sivuyile & September Community Member

Nontozanele Ms Z.E. September ANCYL Mrs September Community Member Nelson Mandela Bay Metro, Ward Cllr MD Seti 27 Ms B Shinga ACER (Africa Ms Feziwe Sibela African National Congress Mr Xolisa Sidandala Goodyear SA Pty Ltd Ms Noyise Sigenu Ward Committee Member Ms Nombulelo Sigwanda African National Congress Ms Vuyiswa Siko African National Congress Nelson Mandela Bay Metro, Ward Cllr ZW Sikosanna 25 Ms Buyiswa Simakuhle Religious Sector Mr Dawn & Fundile Singaphi Mr Sibongile Singaphi Ward Committee Member Mr Zwelinzima Singata SANCO Branch Ms T Sinkwana Ward Committee Mr Andile Sipika Mr Mlungisi Sipika Ms Zoleka Sithela ANCWL Mr Ibhahim & V Sitoto African National Congress Mr/Ms MG Siwa Sports & Culture Nelson Mandela Metropole Cllr TC Siwa Municipality Ms Beauty Siwoni African National Congress Mr Mzimkhulu Skaye Mr N Skeates Forecourt Express Ms Buyelwa Skepu Ward Committee Member Mr Crossby Slatsha Mr Zoleka Smandla Ms Anita Smith Dr. Michael Smout Chair, Planning Advisory Board JR Snyman Mr/Mrs P Snyman Cacadu District Municipality Mr Linda Sofute Nelson Mandela Metropole Mr SA Sogobile Municipality P Solani Mr Johannes Solanie Community Member Mr AR Soldaat Mr Harry Solomon African National Congress Mr/Mrs Thami Solomon African National Congress Ms M Sonanze Mr. Richard Sonders Talbot & Talbot Mr Mbulelo Sonjica Community Member Mr Mzwandile Sonjica Mr Andile Sota Ms Xoliswa Sotisa Dept Economic Affairs, Environment Mr. Alan Southwood and Tourism Mr. Andile Sowazi ANCYL. Mr Mike Spearpoint Zwartkops Trust

Mr Zandisile Speelman Ward 47 Committee Ms Alison Spence Continental Tyres Mr/Mrs N Spogter Community Member Ms Eunice Springbok Community Member African National Congress Youth Ms Pumla Stamper League Mr Thobile Statu Community Member Mr Warren Steele Onyx Interwaste Ms Nompumelelo Stemela Mr Loyiso B Stemele African National Congress Congress of South African Trade Mr Thembile Eric Stemele Union(COSATU) Mr Mathews Stememla African National Congress Mr/Mrs Allan & Gail Stephen Allandale Farm Ms Pumeza Stephen Mr Boby Stephenson Democratic Party Mr Richard Stephenson Zwartkops Trust Mr NA Steven Mr Ntsikie Steven Community Member Nelson Mandela Metropole Mr D Steyn Municipality ( Env Health) Mr. I Steynberg Mr Sydney Stiemmie Kirkwood Farmers Association Mr SJ Stoffel South African Communist Party Ms Doris Stofile ANC BEC Nelson Mandela Metropole Mr Pumzile Stofile Municipality Mr/Mrs S Stokwe African National Congress Dept Economic Affairs, Environment Mr. Andries Struwig and Tourism Mr. A Strydom Mr Johan Stumpf Sundays River Citrus Co-operative Department of Housing & Local Mr/Mrs D Stupart Government Mr Lawrence Stuurman Mr/Mrs B Stwayi Community Member Mr George Summers Zwartkops Trust Mr/Mrs B Swanepoel Sundays River Citrus Co-operative Mr G Swanepoel Atlas Plastics Mr. Jacobus Swanepoel Transnet Chemical Services Mr Piet Swanepoel Sundays River Citrus Co-operative Mr Johan Swart Kirkwood Farmers Association Mr Martin Swartz Kirkwood Agricultural Union Ms Nomsa Swartz REC Ms Nondumiso Tafane African National Congress Mr Mlamli Tambo Cllr Vuyo Tambo Sundays River Valley Municipality Mr Siyabulela Tana ANC Ms Tozama Tanda Motherwell Clean and Green Project Mr/Mrs M Tarr Belmont Vuyolwethu & Ms Tembisa Tatu Community Member Mr. Norton Tennille South Africa Environment Project Mr/Mrs The Chairperson African National Congress Youth

League The Manager Bosal Africa (Pty) Ltd The Manager C & M Hydraulic Services Environmental Justice Networking Mr/Mrs The Manager Forum The Manager SKF Bearing Manufacturers Mr Patrick Thole Ward Committee 23 Mr Mbulelo Thompson Mr Anele Tima Mr Grey Tini Nelson Mandela Metropolitan Mr/Mrs T Titima Municipality Ms. Cikizwa Tobi ANC. Nelson Mandela Metropole Cllr MB Tokota Municipality Ms T Tokota Community South African Municipal Workers Mr A Tolom Union Mr Andile Tom ANC Mr Zalisile Tom Ms Rachel Toring Community Member Ms. Thembeka Toto Mr Vuyo Toto African National Congress Mr Patrick Tshaka African National Congress Mr. Daluxolo Tshazi Ms Linda Tshokela African National Congress Ms Nombulelo Tshongweni Winfre & Mr/Mrs Nomakhaya Tsili Community Member Ms Phindiwe Tuku Community Member African National Congress Mr Mthetho Tusheni Community Structure Nelson Mandela Metropole Cllr VJ Tutu Municipality Mr Abner & Boniswa Twalo African National Congress Tyali Tyesi Mr Makaya Tyolweni ANC Ms Ntombizanele Tywini Ward Committee Member Mr Bart Uljee Barloworld Automotive Coatings Ms Nicky Unwin GMSA Mr/Mrs J Vakaza African National Congress Mr/Mrs M Van Breda Eendracht Farm Mr Johannes Van Der Merwe Kirkwood Farmers Association Mr. Hennie van der Walt FFS Refiners Pty Ltd Ms. Louise van Greunen PE Afrikaanse Sakekamer Mr Jo Van Heerden PPC Nelson Mandela Metropole Cllr AMJ Van Jaarsveld Municipality Mr Van Louw Mrs. A Van Niekerk Mr B van Niekerk Rhino Plastics Pty Ltd Mr Derrick Van Staden Killians Precision Engineering Mr JK van Wyk Van Niekerk Huisamen & Van Wyk

Mr. Hendrik van Zyl Roshcon Mr S van Zyl Volkswagen SA Ms Sonia van Zyl Johnson Controls Automotive Mr Simphiwe Vayo ANC Mr Roger Vazi SANCO Ms Nomute Vena African National Congress Nonzuzo, Tandiswa Ms & Ntombizanele Vena Mr Denzil Vencencie Eveready Mr/Mrs M Viannie SRVM Ms Nomakhosazana Vinqi Ms Andrea Von Holdt Coega Development Corporation Ms Tembisa Voorslag Khanya Local Business Service Ms. Michelle Vosloo Centre Mr Werner Vosloo Cadbury Ms Cleopatra Vumazonke Mr/Mrs ET & Mrs Vusani African National Congress Ms Joan Wainwright Prentice Kraal Mrs Margaret Wallon Farmer's Wife Mr./Mrs Neil & Priscilla Walton Farmer Bluewater Bay Ratepayers Mr Grant Watkins Association Congress of South African Trade Mr Zanoxolo Wayile Union Mr/Mrs A Welkom Community Member Ms P Whitebooi Cacadu District Municipality Mr Kevin Whittington Jones CES Mrs Catherine & Ivan Whittle Nelson Mandela Metropole Mrs T Wiegand Municipality Mr Alan Willcocks Interwaste Mr Andrew Williams SRCC Agri BEE Ms Grace Williams African National Congress Cllr OM Williams Cacadu District Municipality Mr Phindiwe Williams ANC Ms Thembisa Williams Mr. Victor Williams ANC. Mr FM Williamson Uitenhage District Agricultural Union Ms N Witbooi African National Congress Cllr MW Wogane Cacadu District Municipality Mr Gary Wood Salvation Army Mr & Mrs KU & RM Woolley CHFWOOLLEY Trust Mr./Mrs Z. Woshani Emlungisi Disabled Mr Mxolisi Xakaxa Mr Simphiwe Xalaba Mr/Mrs M & Veliswa Xangati Community Member Ms Thobeka Xola African National Congress Mr/Mrs Yali Mr. Edward Yeko Ms NA Yisaka Mr Elvin Yola Sports Forum Cllr VG Yona Nelson Mandela Bay Metro, Ward

53 Ms Ntombomzi Yose Ward Committee Member Mr ML Yoyo Gqebera Development Trust Mr Thembisa Zalabe Nelson Mandela Metropole Ms Nozuko Zamxaka Municipality Mrs & Ms N & NP Zembe Community Environment Network Mrs Gladys Zenani African National Congress Ms Eunice Zingela ANC Mr Eddie Zinto African National Congress Mr Nkululeko Zondani Mr Mike Zono SANCO Ms. Thozama Zono Masizame Community Project Mr Mxolisi Zozi SANCO Ms Sharlene & Bolligello Aims Group of Companies Dove South Africa Kronenhof(Guest House) Nelson Mandela Bay Metro, Ward Cllr F Frans 58 Mr Litho Suka ANC Mandela Metro Region Nelson Mandela Bay Metro, Ward Cllr T Vusani 53 Mr Simphiwe Hlihli ANC Ms Nombulelo Ncambele Ward Committee Ms Maureen Dayimani Ward Committee Mr Kelello Makgoka SRVM Mr Tembile Dlamini SRVM Mr Mthetheleli Nkohla SRVM Mr CV Mata SRVM Mr Zukile Jodwana SACP District Secretary Veolia Environmental Services(Pty) Ms Nelize Fourie Ltd Mr D Jacobs Mr Ivan Cornelius Ms Vanessa Lessing PPC Mr Bernerd Venter PPC Veolia Environmental Services(Pty) Ms Tamia Bouwer Ltd Mr ME Galela Mr Sandi Hobson Zwartkops Trust Mr David Hayes Zwartkops Trust Ms Linda Redfern Zwartkops Trust Ms Nadia Wessels Zwartkops Trust Mr Retha Tailor Mr Danie Brink Jones & Wagener Mr Nicola Schwim Environmental Consultant Mr John Adendortt Sanparks Mr CR Reas Elephant House Veolia Environmental Services(Pty) Mr Greg Patterson Ltd

Mr Peter Corkland SANCO Mr Colin Jones PPC

APPENDIX C: Draft EIR availability advertisements

Advertisements Placed

Weekend Post, 17 January 2009

Herald, 20 January 2009

Die Burger, 20 January 2009

Daily Dispatch, 20 January 2009

APPENDIX D: Issues and Responses Register (including minutes of public meetings and written correspondence received from I&APs)

ISSUES AND RESPONSES TRAIL – DRAFT EIR

PROPOSED REGIONAL GENERAL AND HAZARDOUS WASTE PROCESSING FACILITY

1. Biophysical Issues of Concern (Fauna and Flora)

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1.1 A search and rescue effort for the Albany Adder 19Feb09, Mike Spearpoint, This is included in the EMP as an action to be must be made prior to construction Net Mtg Swartkops Trust undertaken prior to the commencement of any commencing. construction related activities on site. 1.2 There should be a vegetation barrier to screen 19Feb09, Mike Spearpoint, Due to the proposed height of the landfill body this the site off visually. Net Mtg Swartkops Trust mitigation measure is in all likelihood not feasible. It must be reiterated that as per the findings of the Visual Impact Assessment (VIA) that the facility will hardly be visible from the R335 to Addo, with the proposed facility only visible once inside the boundary of the existing PPC land and mining operations. The effect of existing vegetation cover, as a potential to absorb the visual exposure, was not considered, as the facility exceeds 30m in height and the average vegetation cover (thicket and bushland) is 2 to 3m high. 1.3 Are there measures to manage and monitor 24Feb09, Kelello Makgoka, The measures to control of scavengers on the site animals that scavenge on the site such as Net Mtg Sundays River will need to be developed prior to the facility birds? Valley Municipality becoming operational. Certain faunal species such as birds and rodents are, however, extremely difficult to manage and best practice measures as utilised by existing landfills (if available) will be considered for implementation. These measures will be further developed prior to the facility becoming operational. 1.4 Are there any endangered species on the site? 9Mar09, L Suka, ANC The presence of any Red Data List or Endangered Net Mtg Region species has not been confirmed on site by the relevant specialists during their field surveys, however, it has been indicated that these species may occur on site as it is within the historical habitat range of certain rare and endangered species. A search and rescue exercise will be conducted prior to the commencement of

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construction activities on site in order to identify any possible endangered species present. 1.5 In what condition is the site now and how will it 3Feb09, Ivan Cornelius The site is disturbed and in places highly degraded be rehabilitated in future? Pub Mtg due to historical agricultural land use practices. PE Currently, the area surrounding the site is owned by PPC who has mining rights for the area in which Footprint F falls, and is earmarked for mining due to the relatively high quality calcrete and limestone deposits found there.

Rehabilitation of the landfill will be in accordance with the Closure and Rehabilitation sections have been included in Section 13 of the Design Report and Section 22 of the Operating Manual (contained in the Permit Application Report – PAR - by Jones & Wagener Consulting Engineers) for the proposed regional hazardous waste disposal site. The site will be capped with the required synthetic membrane and soil layers - and gradually revegetated.

The Design Report by Jones & Wagener (Report number JW80/08/B494 dated July 2008, included in the PAR) outlines the conceptual rehabilitation process as per the following sub-sections:

• Rehabilitation and Closure • Proposed Final Landform • Phased Capping • Capping Design • Stormwater Management Post-Closure • Maintenance and Monitoring

The Operating Manual developed by Jones & Wagener (Report number JW50/08/B494 dated June 2008, included in the PAR) includes the following sub-sections:

• Site Life

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• Proposed Rehabilitation and Closure Design

Monitoring and maintenance procedures post closure are also included in the relevant sections in the Operating Manual.

As the proposed site is classed as hazardous no public access can be permitted onto the closed hazardous landfill in terms of the Minimum Requirements for Waste Disposal by Landfill. The site will remain fenced off and access to it restricted. No future development or alternative land uses can therefore be considered for the site. 1.6 Biodiversity impacts – a plant and animal 22Feb09, Morgan Griffiths, This is included in the EMP as an action to be rescue & relocation exercise is required before letter WESSA EP undertaken prior to the commencement of any construction activities begin, especially for construction related activities on site. This is highly species of special concern, such as the Albany likely to be a condition of authorisation should the Dwarf Adder. proposed landfill be granted a positive decision. 1.7 Biodiversity impacts – During construction and 22Feb09, Morgan Griffiths, As outlined in the Draft EIR (January 2009) the operation, the areas to be impacted need to be letter WESSA EP facility footprint will be clearly demarcated and carefully delineated, to limit destruction outside construction activity will be contained within it. of the construction footprint. Unnecessary access to the adjacent areas (remaining sensitive portion of Bontveld to the north and east of the proposed facility footprint – refer to Chapter 5 of the Revised Draft EIR) will be restricted, and construction related activities prohibited in this area. 1.8 Biodiversity impacts – The GHWMF will need to 22Feb09, Morgan Griffiths, Noted. The control of scavengers on the site will be properly managed to avoid attracting birds, letter WESSA EP need to be carefully managed; however, monkeys and other scavengers – the daily mechanisms to ensure this will still need to be covering of deposited wastes is essential in developed prior to the facility becoming operational. combating this problem. As noted in 1.3 above, the control of certain scavenger species is likely to remain a challenge throughout the operational phase of the facility.

2. Issues related to roads and transportation of hazardous waste

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2.1 A traffic impact assessment must be done for 19Feb09, Nadia Wessels, A TIA for the entire transport route has been the entire route. Net Mtg Swartkops Trust conducted for the preceding phases of the study. It has concluded that the Addo Road (R335) will have to be upgraded to an appropriate standard if it is to accommodate the additional heavy vehicle traffic volumes associated with the operational facility. A revised Transport Study (Chapter 13 of the Revised Draft EIR) indicating the extent and significance of the anticipated traffic impacts resulting from increased heavy vehicle traffic, as well as the implications of the current deteriorated state of the R335 for construction and operation of the facility has been included in the Revised Draft EIR. 2.2 Does the upgrading of the Addo Road and its 19Feb09, Mike Spearpoint, At this time the EAP has no knowledge as to what associated stormwater infrastructure Net Mtg Swartkops Trust the road upgrade designs will incorporate. It is incorporate into its design an accident and however highly unlikely that any preliminary design hazardous spill on this road? It is detail that may have been produced to date will be recommended that the design of the road reflective of this. This recommendation will be include catch pits which capture the spill, carried through to the EMP, and put forward by the especially where there are culverts. EAP to be considered in any forthcoming road upgrade designs for the R335. 2.3 It is recommended that trucks travelling to the 19Feb09, Mike Spearpoint, The trucks will have to use the R335 from Coega, facility are confined to a specific route and Net Mtg Swartkops Trust as well as other regional roads servicing outlying that transport of hazardous waste through towns and districts in the Port Elizabeth area. residential areas is avoided. Hazardous waste from the IDZ will pass through Motherwell along this route, but residential areas are not affected once past Motherwell for waste coming from Coega. The recommendation that trucks from various locations use a specific route only for waste transport from these locations in order to avoid residential areas as far as possible will be included in the EMP. 2.4 Is it possible that spills from vehicles 20Feb09, Thulani Grootboom, Yes, it is highly probable that this will eventuate transporting waste could be experienced? Net Mtg Addo Alliance during the lifespan of the facility. 2.5 The R335 needs to be upgraded to meet the 20 Feb09, Thulani Grootboom, Noted. It has been concluded that the road in its demand for this project. Net Mtg Addo Alliance current condition cannot accommodate operational

NO. ISSUES RAISED DATE COMMENTATOR RESPONSE

phase vehicle traffic until it is refurbished. This will be a recommendation for a condition of environmental authorisation that the R335 is upgraded taking into account the waste transport volumes and requirements prior to the facility becoming operational.

The Eastern Cape Department of Roads and Transport notified the public of an open meeting to discuss the proposed upgrade and special maintenance works to be undertaken on the Main Road MR0450 (R335) between Motherwell and Addo during the course of August 2009. It appears that this will not be an extensive upgrade to the standards likely to be required to accommodate the increased vehicular traffic associated with the operational facility, but more of a temporary improvement measure. 2.6 Will the trucks transporting waste be sealed to 24Feb09, Kelello Makgoka, The transport of waste to the site is the avoid spillages? What type of trucks will be Net Mtg Sundays River responsibility of the person or company who used to transport waste? Valley Municipality generated that waste, and is not controlled by the waste site Permit Holder or the landfill operator. That said, transport of waste in South Africa in governed by the National Road Traffic Act (Act No 93 of 1996) as well as a host of SANS standards relating to the transport of dangerous goods. Waste generators will have to ensure that transport of their waste complies with these. The waste generators (along with third party transporters, if applicable) will therefore decide what type of trucks will be used, and how spillages can be avoided. Waste transporters should also be registered to transport waste. 2.7 Is the R335 road in a condition to 24Feb09, Kelello Makgoka, Not at present. The road is in an extremely accommodate trucks for such a facility? Net Mtg Sundays River deteriorated condition and will have to be upgraded Valley Municipality prior to the commencement of the facility’s operational activities. 2.8 Is there a plan to upgrade the Addo road? 9Mar09, L Suka, ANC Region There have been proposals to this effect in the

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Net Mtg past; however, this has not been realized to date. It is noted that the upgrade will have to have to be upgraded prior to the commencement of the facility’s operational activities. 2.9 The report indicates 6000 tons per month of 4Feb09, Chris Morley For the purposes of the Transport Study (Chapter waste will be transported to the facility, how Pub Mtg 13 of the Revised Draft EIR), and using the many vehicles per day does this equate to? Sunlands maximum rate of deposition scenario (as per 2004 waste stream projections from the Coega IDZ) it has been determined that a total of 25 loaded trips per hour (251 loaded trips per day) will be required by full ramp up in year 11 to transport 301 823 tons per annum. This is the maximum number of trips likely to be required (maximum volume of waste) and will continue for the remainder of the 20 year design period.

During the course of 2008 the potential waste stream estimates from the IDZ were revised to reflect the current low rates of occupancy and generally static rate of hazardous waste production. The revised estimates indicate that the expected initial and full ramp up volumes is less than the volumes utilised for the Transport Study calculations. 2.10 How will the facility NOT be visible from the 4Feb09, Chris Morley The extent of its visibility is contained, to a large Addo Road? Pub Mtg degree, to scattered sighting down the valley within Sunlands which it is situated. It does not extend above the Sundays/Coega River watershed boundary, and is therefore not visible from the north. Visibility from the R335 is theoretically possible at a distance of approximately 6 km, though it is highly unlikely due to the relatively small visual porthole afforded by the ridges flanking the footprint's valley. The visibility would further be highly interrupted, because no considerable length of road is ever exposed to the facility. 2.11 The report indicates on a map the extent of 4Feb09, Keith Finnemore The assessment of the road conditions and the facility. Our experience has shown that Pub Mtg transport corridors has been addressed in the

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with the transportation of waste, there can be Sunlands Transport Study (Chapter 13 of the Draft EIR). The all kinds of spills and/or accidents. Thus the maps of the various transport route options to the extent of the facility and the impacts it will facility are also depicted the in the Draft EIR. It is have are not just confined to the facility but noted and accepted that the impacts of the extend for the entire transportation corridor. transport corridors cannot be separated form the Thus the map for the facility should be impact of the facility itself, and this has been amended to reflect that the facility includes its assessed as such in the Draft EIR in the air, visual, transportation corridors. This should be carried heritage, fauna and flora as well as the SIA through the report; monitoring and specialist studies. management of the facility as well as the assessment of impacts should include the The impacts resulting from, the utilisation of the access roads to the facility. existing transport corridors and access routes to the facility will be significant if not appropriately managed or prevented as far as possible. As recommended by Mr. Finnemore the monitoring and management of these transport corridors to reduce the significance of potential spill, road safety and increased traffic volumes, air quality and litter impacts that are likely to occur is crucial. 2.12 The assessment of impacts should include the 4Feb09, Keith Finnemore As per 2.11 above access roads to the facility, this is an Pub Mtg international trend yet the Draft EIA does not Sunlands look at the impacts of the transport corridors, the management or monitoring of such impacts. All access roads leading to and that will be used by the facility should be included in the assessment process. 2.13 What happens on these roads affects Tourism 4Feb09, Keith Finnemore The implications of this scenario are noted. It is the and the citrus industry. This road is used by Pub Mtg opinion of the EAP that quantifying the risks and trucks transporting fruit to the PE harbour for Sunlands likelihood of this scenario occurring will be difficult exports, all you need is one accidental spill of to accurately and credibly assess. It should waste on the road accompanied by rain, which therefore be assumed that a spill event followed by, could result in contaminated rain water or during, a rainfall event is likely to eventuate landing up on fruit for international export. If during the lifespan of the facility. It Is therefore this contaminated fruit landed up in the imperative that and appropriate emergency international market/stores it would be a response measures are developed for, and disaster for the local citrus industry. The implemented during, the operational phase of the assessment process must therefore assess facility for this scenario.

NO. ISSUES RAISED DATE COMMENTATOR RESPONSE

and identify impacts on the transport routes as well as include management and In the instance of an accident/spill event it would monitoring mechanisms for these routes. have to be communicated quickly and effectively to affected road users, traffic halted and an alternative transport route (N10 road) utilised until such time as the spill is cleared up. Trucks transporting fruit should therefore ideally be covered to a degree that will prevent ingress of water that could potentially be contaminated by wet road surfaces from a spill event when transporting fruit to PE harbour once the facility is operational. 2.14 The R335 has collapsed, Province has 4Feb09, Keith Finnemore Noted. In light of the poor state of the R335 it is committed to building it in 5 years, the design Pub Mtg imperative that all stakeholders and authorities and construction plan is for the road is Sunlands responsible for the required upgrade begin finished and will entail closing the road for 2 engaging on this and allowing for appropriate years. This directly impacts on your budgetary allocations and the commencement of timeframe for construction of the facility. The the required tender process for this refurbishment. R335 is fundamental to the facility and must This will be a recommendation for condition of be built before construction on the facility authorisation. takes place, what can be done about this? 2.15 The R335 is a lifeline for the people of Addo, 4Feb09, Muffy Miller A transport study for all transport routes under this road is used by the people of Addo to Pub Mtg consideration has been conducted in the preceding access facilities available in the Metro which Sunlands phases of the study. A revised chapter indicating are not available in Addo for example, the extent and significance of the anticipated traffic hospitals and schools. The impact of the impacts, and impact of the proposed facility on facility on this road must form part of the transport corridors, has been included in the assessment process. Revised Draft EIR. 2.16 Will the waste be transported in open or 4Feb09, Dieter van der Please see item 2.6 above. closed bins to the site? Pub Mtg Merwe Waste needs to be transported in a suitable vehicle Sunlands and / or container. This would be decided by the waste transporter and the waste generator prior to transport. 2.17 Windscatter – The GHWMF will also need to 22Feb09, Morgan Griffiths, Noted. This recommendation will be carried through take responsibility, along with the NMBM, for letter WESSA EP to the EMP, as well as included as a recommended extra litter clean-ups along the approach condition of authorisation. roads, especially as the R335 is such an important tourism corridor. 2.18 Traffic impacts – the issue of dust generation, 22Feb09, Morgan Griffiths, Noted. These recommendations will be carried

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spill and congestion are of concern to us. We letter WESSA EP through to the EMP, as well as included as a hold that the approach road/s to the site from recommended condition of authorisation. the R335 and/or R75 impacts need to be tarred to minimise dust generation. The Aloes H:H waste site has shown that without this ‘mitigation’, considerable management is needed to suppress dust by trucks approaching the site; recognising that tipping, spreading and covering activities also produce much dust. Considering the lifespan of the GHWMF and impacts (biological, social and visual-dust clouds), we believe the expense of hard-surfacing the road up to the site is justified. The incoming and outing lanes of the R335 from Port Elizabeth should be double-carriage or at least have hard shoulders to facilitate overtaking on this important tourist route. 2.19 Traffic impacts – We remain concerned that 22Feb09, Morgan Griffiths, Noted. This recommendation will be carried through the timing and delivery of the Eastern Cape letter WESSA EP to the EMP, as well as included as a recommended Provincial promise to upgrade this road condition of authorisation that the road be remains outside the ambit of this assessment. upgraded to a suitable standard prior to the facility WESSA-EP believes that the road needs to be becoming operational. upgraded before construction activities begin on site, not started when the site is ready to accept its first waste delivery. 2.20 Traffic impacts – A major concern to us is the 22Feb09, Morgan Griffiths, A detailed emergency response plan will be event of a vehicle accident resulting in a letter WESSA EP developed prior to the facility becoming operational. hazardous spill on the R335, R75 or approach This would in part be contingent on who the roads. What will the emergency response plan preferred bidder/operator of the facility will be and be, what might be the worst-case scenario be will have to be informed by all stakeholder and IAP and what impact might such a spill have on issues, concerns and requirements. The content and the transport of people and the citrus industry. development of this emergency response plan This issue has not been adequately dealt with should ideally be approved by the as yet to be in these reports. established Environmental Monitoring Committee (EMC) that will be constituted by, and representative of, all these parties and stakeholders. The onus will be on the company

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transporting the waste as well as the eventual operator of the facility to implement. Mobile spill response teams will have to be available and permanently on call, ideally at the proposed facility as well as closer to PE. 2.21 One of the conditions of the smelter ROD was 4Feb09, Paul Hansen Illegal dumping is a reality. However, the disposal that they must have access to a waste facility, Pub Mtg of wastes of this nature, especially those generated yet it is the Addo community that will have the Sunlands in the IDZ, will be strictly controlled through a safe facility on their door step. The site is far from disposal permitting system that is required by the where the waste will be generated which will relevant statutes and regulations. Of key make it costly to dispose of the waste at the importance here is enforcement that prevents site; people may just dispose of their waste illegal disposal, and appropriate monitoring of the on-route to reduce their costs. transport corridors and auditing of waste generators to ensure compliance to the safe disposal criteria. 2.22 The R335 is currently in a very poor state of 19Feb09, Colin Jones, PPC Noted. It is reiterated that the required upgrade will repair and will not cope with this extra traffic. letter be recommended as being necessary prior to the The proposed upgrade to the R335 has been commencement of the facility’s operational postponed due to budget constraints. activities. The Eastern Cape Department of Roads and Transport notified the public in August 2009 of an open meeting to discuss the proposed upgrade and special maintenance works to be undertaken on the Main Road MR0450 (R335) between Motherwell and Addo during the course of August 2009. it appears that this will not be an extensive upgrade to the standards likely to be required to accommodate the increased vehicular traffic, but more of a temporary improvement measure. 2.23 The R335 will become more popular with 19Feb09, Colin Jones, PPC Noted. Should the road be upgraded to a double tourists as an access to the Addo region. letter lane standard, or make allowances for climbing These tourist vehicles will find difficulty in lanes on uphill sections this should to a large travelling this route with such a large volume degree help mitigate the potentially longer traveling of potentially slow moving waste vehicles and times that could be experienced by tour buses and probable litter that such traffic is likely to tourist traffic in general. The use of the N10 road cause. route to Addo should also be promoted 2.24 The P1954 is a small secondary gravel road 19Feb09, Colin Jones, PPC Noted. Subsequent engagement with PPC on this that has not been used by the public for the letter issue has highlighted the need to use an alternate last 10 years. The P1954 runs directly through access route to the north of the proposed facility. the PPC mining area and there are currently 2 Accordingly, it has been put forward that the R335

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crossings that are continually used by off-road – P1958 – P1954 access route be utilised in order mining vehicles travelling between the PPC to reduce the disruption to PPC vehicle movements. crushing plant and the working faces of the mine. The safety of these vehicles, when there are up to 502 waste vehicles travelling through the mining area in a 10 hour period (50 trips per hour) on a daily basis, is a definite concern to PPC. 2.25 The intersection between the R335 and the 19Feb09, Colin Jones, PPC Noted. The utilisation of the R335 – P1958 – P1954 P1954 is a significant concern as it is on a letter access route will negate these concerns. blind rise. The speed limit on this part of the road is 100kph and the likely hood of accidents as the 502 waste vehicles try to turn off the R335 onto the P1954 and then later re- enter the R335 is a major safety hazard to both the Waste vehicles and the general public using the R335. 2.26 An alternative route using the P1958 as 19Feb09, Colin Jones, PPC Noted. However, the use of the R75 for vehicles considered in the documentation would be letter would significantly increase the average trip more acceptable as it would not impact on distance for waste vehicles servicing the Coega IDZ PPC’s mining operation as much as the and the PE area in general. At this time it is recommended route and would use an existing anticipated that only vehicles from the secondary road that is currently in use. This Uitenhage/Despatch area will utilise the R75 access alternative would still have the problem of route. significantly increased traffic on the R335 and this would impact on the PPC haulage contract that moves limestone from the mine on the left side of the R335 to a Transnet Freight Rail siding on the right of the R335. We have an authorized crossing on the R335 which would be subject to significantly increased traffic volumes. An alternative using the R75 and the P1958 would eliminate any impact of the traffic to the waste site on the PPC operation. 2.27 From the outset of the discussions about the Feb09, Sundays River These concerns are noted, however, it is beyond waste site, it was always understood that this letter Valley Community the ambit of this EIA process to make a credible would be a world class hazardous waste site, Forum assessment, or draw conclusions, about the manner with minimal impact on the local community. in which the site will be operated in the future by

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It is pleasing to note in the PAR, Waste the NMBM or the private operator who successfully Management Philosophy Report, page 21, ‘The secures the rights to manage the facility. proposed Grassridge waste disposal facility should be operated to the highest national and While the illegal dumping issues highlighted here international waste management standards. are valid and often the case in the Port Elizabeth The objective for the operation for the area, as well as countrywide, appropriate Grassridge waste disposal facility will be to enforcement of the relevant statutes and by-laws is ensure that the waste is managed in an required to prevent this. It is conceded that this is environmentally and socially acceptable very difficult to prevent, however, as it is only manner.’ The reality of waste site registered waste removal service providers, or management, especially in the NMBMM area, municipal waste vehicles, utilizing the proposed leaves a lot to be desired. Access roads are facility it is not anticipated that illegal dumping littered with waste, trucks carry loads without from these vehicles will be a concern. covers, fallen waste is never picked up. Trucks simply dump their loads on the side of the Similarly, monitoring and enforcement of best road or in a nearby side road if they cannot practice waste management and disposal enter a waste site. Monitoring and punitive procedures will have to be the standard for the measures against transgressing operators are proposed facility and binding on all parties involved obviously not carried out. The entire waste in the management, operation and servicing management sector, including engineers, site thereof. operators and owners are in a state of collective denial about the waste process. It is As previously noted, the transport corridors to the as if waste is produced at a factory, and then facility are a fundamental aspect under assessment magically appears at the waste disposal site, Where relevant it has been factored into specialist without any impact or potential impact on the studies conducted for the EIA process. entire transport corridor. This denial runs like a fault line throughout the study – the PAR, SIA, EMP and EIR all ignore it, in spite of our highlighting the problem in our previous submission, and in spite of the engineers and operators own experience of the state of access roads around waste sites countrywide. 2.28 The first step in the addressing of this problem Feb09, Sundays River In terms of the EIA regulations and reporting is to redefine the site footprint to include all letter Valley Community processes the footprint of the facility is defined as access roads leading to the Grassridge site. Forum being the total developable area of a proposed This would include the R335 from Motherwell activity. According to this definition the transport to the site, as well as the R75 from Uitenhage corridors are not part of the facility footprint per se, to the site. Thereafter all the above reports but an integral part of the overall impact

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(PAR, SIA, EMP and EIR), plans and assessment for the project. The reports mentioned assessments (eg SIA risk assessment) will have taken the transport corridors into need to be re-evaluated in terms of the actual consideration as they relate to the various specialist (extended) footprints. This will impact on study components under question – notably the air, visual aspects, tourism and many other facets visual, heritage, fauna and flora as well as the SIA of the studies and reports already submitted specialist studies. and approved. 2.29 In addition, a Transport Risk Assessment Feb09, Sundays River In the opinion of Bohlweki-SSI Environmental – as (TRA) for all products that may be transported letter Valley Community informed by transport engineer specialist study along the transport corridors to this facility Forum findings - the upgrading the R335 has to take place needs to be undertaken. This TRA will need to prior to the commencement of construction activity consider a) the elevated risk to export fruit for the facility. Ideally this should be to double lane and other food travelling through the same standard – or at least making allowances for slow corridor to the harbour and local consumers lanes on essential sections of the route – to at least and b) the effects on tourists and tourism. the entrance of the proposed facility. These two aspects need to be evaluated in terms of both upgrading the R335 as well as As stated in 2.13 above, it is the opinion of the EAP not upgrading the road. that quantifying the risks and likelihood of this scenario occurring will be difficult to accurately and credibly assess. It should therefore be assumed that a spill event followed by, or during, a rainfall event is likely to eventuate during the lifespan of the facility. It is therefore imperative that and appropriate emergency response measures are developed prior to, and implemented during, the operational phase of the facility for this scenario.

It has also noted that increased vehicular traffic resulting from waste truck movements would have a significant impact on the integrity of the existing R335 road that is in poor condition. An increased traffic volume on the R335 that is utilised by tourist vehicles to access the Addo area is highly likely to be significant if the road is not upgraded prior to the commencement of operational activities, possibly resulting in longer traveling times to their destinations, and an associated increased risk of accidents as the road becomes more heavily used.

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Accordingly, as per the findings of the Tourism Study (Chapter 8 of the Draft EIR) an increase in traffic on the R335 would negatively affect the experience of tourists to the area if their journey is delayed by trucks and if the road deteriorates due to increased usage by heavy vehicles should it not be refurbished. The use of the N10 route to Addo should also be promoted.

Bohlweki-SSI is of the opinion that should the road be upgraded to double lane standard (from Motherwell to the facility at least) prior to the commencement of construction activity at the facility, this would be more beneficial for tourism and tourists traveling along the R335 in the long term despite the increase in operational phase traffic volumes. As it stands it is unlikely that future trips along an upgraded, double lane standard road would be significantly longer, if at all, in comparison to an average trip length along the road in its existing condition.

In the opinion of Bohlweki-SSI the actual road upgrading construction period and activities are more likely to detract from the tourist experience during this period, than that of tourists traveling along a suitably upgraded double lane road once the facility is fully operational. 2.30 Upgrading of the R335 - There is a crisis Feb09, Sundays River It is reiterated that the required upgrade of R335 looming in terms of commissioning the site letter Valley Community must be undertaken prior to the have to be before the Aloes site is full. The key elements Forum upgraded prior to the commencement of the shaping this crisis are: facility’s operational activities. 1. The R335 road to Addo is collapsing, and in the opinion of the Consulting Engineers, It is not sure what is implied by bullet point 2 and will not be able to handle any extra traffic there is no response to this. brought on by the waste site 2. Aloes II is almost full. An extension is The urgency of the required upgrade and the need being applied for, which could or might for the pre-emptive allocation of funds therefore are

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extend its life to 2014. Coincidentally the noted. It will require appropriate engagement same time as Grassridge is to be amongst all stakeholders, and a commitment from commissioned, coincidence or not since the Province to secure funding and expedite the Aloes II site extension is yet to be refurbishment process. As mentioned by the SRVCF approved. the timing of this is crucial in order to avoid a 3. It will take 2 years to complete the design situation whereby Aloes II (even with a granting of of the facility and screen a suitable an extension) runs out of capacity prior to the potential operator for this waste site, and a proposed facility becoming operational. minimum of another 2 years to build, and get ready for accepting waste. (Danie Brink quoted from meeting on 4th Feb. 2009) 4. Coega is coming on stream, and businesses there are beginning to generate waste. 5. Money for the upgrading of the R335 has been diverted to 2010 projects, and construction, which should have started in June 2008, has now been put off ‘for 5 years’ 6. The rebuilding of the road, which has been designed, will take 2 years. 7. During road-building, the R335 will be closed completely between Motherwell and Addo. This is the main access road for waste from Coega/PE to the Grassridge site. Clearly, there is an urgent need for strategic intervention in this matter by CDC and NMBMM, to access funds for the project from Province. In order for a crisis to be averted, the road reconstruction needs to start by 2010 at the latest.

3. Potential Impacts on Addo Elephant National Park

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3.1 The site is 20km’s from Addo’s main gate, but 4Feb09, Chris Morley The nearest boundary to Addo is approximately 14 it is closer to the actual boundary of the park, Pub Mtg km away from Footprint F. The Colchester section how has this been taken into account in the Sunlands of the park is the closest boundary that is apparent assessment process? as per the existing and proclaimed boundary of the park. As such it is not deemed likely that the facility will result in direct impacts on the Park. The proximity to the Park has been taken into account in the Transport, Tourism, Air Quality and SIA components of the study. 3.2 All references in the Draft EIA Report to the 4Feb09, Paul Hansen As above. distance between the facility and the Addo Pub Mtg Park must be checked as they are incorrect; Sunlands the boundary of the park is closer to the facility than indicated in the report.

4. Potential Impacts on Air Quality

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4.1 How will you monitor the impact on air quality, 20 Feb09, Thulani Standard monitoring processes and protocols for especially odours? Net Mtg Grootboom, Addo air quality impacts will be an operational and Alliance procedural requirement as outlined in Section 17.5 of the Operations Manual included in the PAR. 4.2 I have identified a fatal flaw in this process. 3Feb09, Sue Hoffman The EAP is of the opinion that the air quality The Draft EIA Report states that air quality Pub Mtg studies conducted for the project are impacts will be of minimal significance and that PE comprehensive and technically correct. it is probably unlikely it will have a negative impact on the citrus industry in Addo. The data Hydrogen sulphide gas is generated in the I have indicates that hydrogen sulphide can be anaerobic phase of landfill decomposition, and can detected up to 142km away from the facility. be odorous and toxic above certain concentrations. It can also be generated by chemical reactions between wastes, which are typically avoided by controlling co-disposal of incompatible waste types. Monitoring of a number of hazardous waste sites in South Africa indicates that hydrogen sulphide gas

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is not detected at a considerable distance from hazardous waste landfills. Hydrogen sulphide is generated by other sources, such as tanneries, sewage works, petroleum refineries, coke ovens, pulp mills and diesel engines. Odour and health impact zones were modeled for the proposed Grassridge site. No exceedances of the health or odour criteria were predicted to occur off-site.

The delineation and enforcement of the proposed 500m buffer zone around the site would negate these air quality impact concerns. Accordingly, the EAP cannot agree with the statement that this constitutes a fatal flaw. 4.3 Air pollution should never happen, however to 3Feb09, Cllr Andre Goosen Noted. It will ultimately be the responsibility of the achieve this appropriate technology will have to Pub Mtg mandated national and provincial authorities, used and the facility will have to be managed PE successful bidder/operator, CDC and the NMBMM to by specialists. The facility will have to be run ensure that this is the case. by experts in hazardous waste management. 4.4 Air Quality Monitoring – this will need to be of 22Feb09, Morgan Griffiths, Noted. the highest standard, including the use of letter WESSA EP independent monitoring and auditing. 4.5 Dust measures must be effectively studied. Comment Templeton Titima, Monitoring stations and their associated procedures Form NMBM Air & Noise and protocols will be put in place to monitor Control ambient air quality, and specifically that of suspended particulate matter that results from construction and operational phase activities. Standard dust suppression measures are detailed in the EMP. Should all access roads to the facility be upgraded to bitumen standard, the largest source of dust will be from the excavation and covering operations at the working face of the landfill. 4.6 Odour control measures must be thoroughly Comment Templeton Titima, Noted. Due to the relatively large distances to the done. Form NMBM Air & Noise nearest residential settlements it is not predicted Control that odour impacts resulting from the operational facility will be of significance. 4.7 Fence monitoring for offensive and carcinogenic Comment Templeton Titima, This recommendation will be carried forward into

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gases to be in place. Form NMBM Air & Noise the EMP. Control 4.8 A suitable weather station which will indicate Comment Templeton Titima, This recommendation will be carried forward into suitable wind activity must also be in place. Form NMBM Air & Noise the EMP. Control

5. Potential Impacts on ground and surface water

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5.1 There is need for a strict monitoring strategy of 24Feb09, Mthetheleli Nkohla, Noted. This has been addressed in the the site to ensure that underground water is Net Mtg Sundays River Operational Manual contained in the PAR. As protected. Valley Municipality per the Geohydrological specialist findings it is highly unlikely that the site will impact on groundwater resources due to the significant thickness of the underlying geology (Kirkwood and Sundays River formations), which will protect the deeper Table Mountain Group artesian aquifer. 5.2 It is important that the new facility is properly 3Feb09, Ivan Cornelius Noted. These concerns are addressed in the designed so that storm water does not Pub Mtg PAR. Contaminated and uncontaminated overflow. PE stormwater management systems are incorporated in to the preliminary design of the facility. 5.3 Stormwater on site must be carefully managed 3Feb09, John Sayster As above. and planned to avoid health risks. Pub Mtg PE 5.4 Treatment of H:H wastes – We also hold that 22Feb09, Morgan Griffiths, Noted. This has been addressed in the the treatment facility also needs to be lined or letter WESSA EP Operational Manual contained in the PAR. bunded, to facilitate clean-up and prevent ground contamination in the event of spills.

6. Socio Economic Impacts of Concern

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6.1 There is a need to encourage recycling 10Mar09, Cllr Vusani, Ward Noted. There are no communities on site. opportunities for the community. Are there any Net Mtg 53 NMBM communities on site? 6.2 How will you monitor scavenging on the site? 20 Feb09, Cllr Tambo, Addo The site will have to be fenced of with strict Net Mtg Alliance access control measures put in place and maintained. 6.3 Opportunities for recycling should be 10mar09, Cllr Frans, Noted. encouraged. Net Mtg Motherwell Councillors Forum 6.4 What are the economic benefits of this project 24Feb09, Mthetheleli Nkohla, It is not anticipated that there will be a to the Sundays River Valley Municipality? Will Net Mtg Sundays River negative impact on the local economy. The the project impact negatively on the economy Valley Municipality facility will lead to the provision of limited of the Sundays River Valley Municipality in employment opportunities for residents of the future? area. These issues are addressed in the Social Impact Assessment (SIA) report – Chapter 14 of the Draft EIR. 6.5 As the site is in close proximity to the Sundays 24Feb09, Mthetheleli Nkohla, As noted above there will be opportunities for River Valley Municipality how will it benefit in Net Mtg Sundays River employment, most likely on a limited scale. It terms of jobs and preference given to local Valley Municipality will be a condition of the EMP that where communities? possible local labour must be given preference. 6.6 There is a need to train locals as this project 24Feb09, CV Mtata, Sundays Noted. However, it is not known at this time will require skilled people to operate the Net Mtg River Valley how many locally resident persons will be facility. Municipality employed during the operational phase of the facility. It is anticipated that the construction phase of the project will result in more employment opportunities for local residents. 6.7 Are there any communities that live on this 9Mar09, L Suka, ANC No. the site is currently totally within the site? Net Mtg Region confines of the PPC mining area which excludes residential settlement. 6.8 How will you keep people off the site, people 3Feb09, Ivan Cornelius Strict access control will have to be enforced. are attracted to these sites as they come Pub Mtg looking for food and valuables? PE 6.9 How do you implement the buffer surrounding 3Feb09, Primrose The proposed 500m buffer around the site will the site? I understand the site has been Pub Mtg Madikizela, Portnet have to be strictly enforced, as will access to identified as it is far away from people but how PE the site in general. The buffer in effect will you stop people coming to the site and prohibits any other development within this

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settling around the site? This quite often zone. The restrictions imposed on development happens when people are looking for by the buffer zone around the facility must be employment and construction commences. noted and incorporated into local Spatial Development Frameworks that will dictate future land uses for the area in question. By virtue of the existing mining land uses occurring on site this 500m buffer zone is already in de facto enforcement. 6.10 Recycling should take place at the landfill and 3Feb09, Goodman Prince There will be allowances for recycling activities the community should be able to benefit from Pub Mtg in the design and operation of the facility. It is this. PE not clear at this time how the community will benefit form this, but this suggestion will be carried over to the EMP. 6.11 The metro has historically placed residential 3Feb09, Goodman Prince Once the facility is decommissioned it will be development on old dump sites. This could Pub Mtg subject to strict access control. Due to the constitute a health risk. PE nature of the facility it will never be an option to develop residential units on the site as an end use once the site is rehabilitated. The site will be not be developed at all on closure and rehabilitation. It should also be noted that Footprint F is far removed from any residential areas. 6.12 What are the long term plans for community 3Feb09, Goodman Prince It is recommended in the EMP that as part of engagement to ensure appropriate waste Pub Mtg the Environmental Management Committee management and sustainable development? PE (EMC) functions (which must be partly constituted by I&APs and stakeholders) Community Liaison Forums should also be established that will allow for ongoing engagement with the surrounding communities for the lifespan of the facility. All issues pertaining to the facilities operation and performance will be addressed through these structures. 6.13 Buffer zone – We caution the NMBMM to 22Feb09, Morgan Griffiths, Noted. The enforcement of this buffer zone and vigorously enforce the proposed buffer zone, letter WESSA EP prohibiting free access to the site in general not allowing new activities to start in these will have to be enforced. As noted above the zones, where inhabitants or workers could fact that it is currently owned PPC mining land become exposed to elevated health risks. has already sterilized the buffer zone area for

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potential development. Should the potential land transfer go ahead it is recommended that this be inclusive of the proposed buffer zone area in the transfer agreement. 6.14 Access Control at the Waste site - The Waste 19Feb09, Colin Jones, PPC This concern is noted. As discussed above site will be surrounded by PPC property. The letter access to the site will have to be strictly unauthorized access to the waste site by enforced. people trying to find items of value or items to re-cycle is a concern to PPC especially as they will probably try to cross PPC land to try to gain access to the site. 6.15 Access Control at the Waste site - The Waste 19Feb09, Colin Jones, PPC As above. site will be surrounded by PPC property. The letter potential for squatters to establish an informal settlement on PPC land is a serious concern as people will be drawn to the site by the potential to earn money from recycling or by servicing the drivers of the Waste vehicles with refreshments while they wait to gain entrance to the waste site. 6.16 The project must be managed in such a way 30Jan09, Thanduyolo Noted. that all aspects of life are considered and fax Caluza, community respected. It is good that the site is far away from residential areas. The site must be properly fenced and secured to prevent scavenging by people and animals. 6.17 Education on waste management is very 30Jan09, Thanduyolo Noted important. fax Caluza, community

7. Impact on PPC Operations

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7.1 Impact on PPC’s Mining operation - The Waste 19Feb09, Colin Jones, PPC Noted. site footprint including the proposed buffer is letter sited entirely on PPC land over which we currently hold a valid mining licence. 7.2 Impact on PPC’s Mining operation - The site 19Feb09, Colin Jones, PPC Noted. However, it is preferable that the area including buffer would impact on up to 1 000 letter in question is not mined as the existing 000 tons of PPC limestone reserves. Pre-mining soil/limestone cover will be utilised in the this reserve is possible but at significantly construction band eventual capping of the increased costs. landfill. 7.3 Impact on PPC’s Mining operation - Although 19Feb09, Colin Jones, PPC According to Mr. Erasmus of PPC, blasting most of the limestone reserves are soft enough letter using 3 m deep drill holes is occasionally used for free digging with an excavator, some areas (approximately once every two years) to mine may need to be blasted. How would the these layers. These hard calcrete deposits proximity of the waste facility impact on sometimes have to be mined to ensure the possible blasting activities? availability of a continuous supply of ore to the crushing plant at times when mechanical failure of excavating equipment is encountered. The mining techniques applied in this mining operation, are totally different to deep level underground and some open cast mining operations, and therefore mining induced seismicity and earth tremors as a risk to the stability of the waste disposal cells, can be ruled out. (As per Reinhard Meyer’s – geohydrology specialist - findings in Chapter 7 of the Revised Draft EIR). 7.4 Consideration of Alternatives - Surely the EIA 19Feb09, Colin Jones, PPC Due to the length of time involved in for the Aloes facility should be completed and letter identifying suitable landfill sites and the an ROD obtained before a new site is associated authorisation and reporting considered? If the Aloes extension is successful processes involved it was not feasible to wait the construction of a new facility could be for the Aloes extension ROD prior to embarking delayed by a number of years. This would allow on a new process for the proposed facility. It PPC sufficient time to mine those areas that must be reiterated that the Aloes extension will could be impacted by the proposed site and only extend its lifespan for a few years and the

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move the operation out of the way. region requires the additional capacity that the proposed facility will provide regardless of the capacity and anticipated lifespan of existing facilities in the region. It is hoped that the likely delays that will be experienced by the recommendation that the R335 be upgraded in its entirety prior to the commencement of construction activity will allow for a 2-3 year lead time for PPC to priotitise its mining operations.

It must be reiterated however that it is preferable that the Footprint F area is not pre- mined in order to allow for as much in situ cover material as possible to be made available for construction of the facility, as well as the operational and decommissioning (capping and rehabilitation) phase requirements.

8. Project Monitoring and Detailed Implementation

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8.1 All breakdowns or incidents to be recorded and Comment Templeton Titima, Noted. This recommendation will be included in reported to the respective authorities within 24 Form NMBM Air & Noise the EMP. hrs. Control 8.2 Will there be incineration on site; the 10 Feb09, Morgan Griffiths, There are currently no plans for incineration incinerator in East London became inoperable? Net Mtg Wildlife and capacity and infrastructure at the facility that Environment Bohlweki-SSI is aware of. The Draft EIR Society mentioned typical components and infrastructure often associated with hazardous waste sites of which incineration technologies are one of them. It was further noted that should incineration, or any of the other optional components of the proposed facility that are not

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under consideration or under application at this time, these will be subject to a separate EIA process. As such, the related specialist studies do not consider the potential impacts associated with incineration at the facility as this has never been in their scope of work.

The SRVCF has indicated that they will never accept incineration on site – assurances to this effect have previously been made by the project team to the SRVCF during preceding rounds of engagement and consultation for the project - and will vehemently oppose it should this ever be considered. Accordingly, it will be a recommendation for a condition of authorisation that no waste incineration be allowed at the proposed facility during its lifespan. 8.3 Will there be concrete encapsulation as a 10 Feb09, Morgan Griffiths, At this time, no encapsulation area has been component of the facility, if so, where will this Net Mtg Wildlife and included in the design. However, given that be? You need to avoid lateral movement Environment encapsulation of high hazard wastes does take which could impact on the lining of the facility. Society place in the region, the construction of an encapsulation area could be required. Prior to the development of an encapsulation area, however, alternative treatment or destruction methods for high hazard wastes should be considered. The development of an encapsulation silo is preferable to mass encapsulation, as better quality control is achievable for the concrete encasement. This could be sited adjacent to the landfill footprint, with its own lining and drainage systems. Lateral movement would typically be taken into account in design. 8.4 You cannot rely on management alone to get 10 Feb09, Morgan Griffiths, Noted. things right once they have gone wrong, so it Net Mtg Wildlife and is really important that this site is constructed Environment

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correctly from the outset. Society 8.5 Will the facility be closed to the public? If it is 19Feb09, Linda Redfurn, Yes. Access will be strictly controlled to only this will assist with conservation in the general Net Mtg Swartkops Trust allow facility personnel and waste removal area. vehicles and personnel on site. 8.6 Who is responsible for monitoring the facility? 19Feb09, Nadia Wessels, A range of entities and institutions will be Net Mtg Swartkops Trust responsible. The operator themselves, NMBM, the yet to be established EMC, independent third party auditors as well as mandated regulatory authorities (DEA, DWA etc) will fulfill these compliance monitoring functions and oversight functions. It will be a condition of authorisation that appropriate monitoring and corrective action processes be developed and implemented for the duration of the facilities lifespan; including end use monitoring once the facility is decommissioned. 8.7 How is the liner fixed if there is a break in the 19Feb09, Dave Hayes, Firstly, strict quality control and quality liner? Net Mtg Swartkops Trust assurance procedures are typically carried out during the construction period to avoid/detect and repair liner damage. For geomembrane (plastic) liners, a patch of the same material can be welded over the break. For compacted clay liners, reconstruction of a section may be necessary. For hazardous waste sites, two composite liners (each comprising a geomembrane liner and a compacted clay liner) are installed, with a leakage detection layer in between them. Any leakage can therefore be drained out of the leakage detection layer before entering the environment, if the liners are no longer accessible. 8.8 Who will be responsible for a clean up if there 19Feb09, Mike Spearpoint, Ultimate responsibility for clean up of an is an accident or spill along the transportation Net Mtg Swartkops Trust accident or spillage along the route lies with the route? waste generator. If a waste generator has contracted transport of his/her waste to a third party transporter, then the transporter would

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usually organise clean up operations. There are a number of waste transporters that contract to Hazmat Spill Teams that would then be responsible for the correct and safe clean-up and disposal of the product. 8.9 How long will construction of the site take and 18Feb09, 18 February 2009 The construction of the site would take between what is the life span of the site? Net Mtg Cllr Mafana, Ward 12 and 18 months. The necessary approvals for 60 NMBM the site will need to be in place prior to this, and detailed design and tender phases would also be required. The life span of the site as designed is currently 20 years, but it could be shorter or longer depending on how much waste is actually accepted on site. Additional space is available in the valley for developing further landfill cells, which would extend the site life. 8.10 Will the site accommodate domestic waste? 20Feb09, Cllr Tambo, Addo Yes. Net Mtg Alliance 8.11 Will the site have incinerators? 20Feb09, Thulani Grootboom, No. Incineration capacity has never been part Net Mtg Addo Alliance of this assessment process’s scope of works. At this point in time the EAP has no knowledge of this being a future option or requirement. As noted above, it will be a recommendation for a condition of authorisation that no incineration whatsoever be allowed at the proposed facility during its lifespan. 8.12 Who will operate the facility and when is the 10Mar09, Cllr Frans, The operation of the facility will go out to facility expected to commence operation? Net Mtg Motherwell tender. It is anticipated that one of the Councillors Forum established waste management companies would be the successful bidder. The approvals process, detailed design, tender, construction and commissioning phases could take 5 to 6 years. Development would also depend on when the required road refurbishment is completed. 8.13 Will there be any dangerous chemicals on site 20 Feb09, Thulani Grootboom, By definition these hazardous wastes are

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that could impact on communities? Net Mtg Addo Alliance dangerous hence the need for appropriate management and disposal of these wastes. There are no communities or residential areas in close proximity to the proposed site that could potentially be impacted on. 8.14 The monitoring on this facility must be strictly 20 Feb09, Thulani Grootboom, Noted. controlled. Net Mtg Addo Alliance 8.15 How long will the process take from this 20 Feb09, Thulani Grootboom, The approvals process, detailed design, tender, phase? Net Mtg Addo Alliance construction and commissioning phases could take 5 to 6 years. Development would also depend on when the required road refurbishment is completed. 8.16 Is the land owner willing to sell the property? 10Mar09, Cllr Vusani, Ward PPC have indicated there willingness to engage Net Mtg 53 NMBM on this matter, and are in principle not opposed to it at this time. 8.17 Is the land owner prepared to sell the land that 19Feb09, Zukile Jodwana, As above. has been identified? Net Mtg SACP 8.18 There is a need to develop an environmental 19Feb09, Zukile Jodwana, Noted. Community engagement and training awareness programme on the use of the Net Mtg SACP initiatives should be conducted simultaneously facility. and through the community liaison forums that will be required to ensure ongoing engagement with the nearest or most relevant communities. 8.19 An awareness campaign for residents in close 9Feb09, Mike Bonya, SANCO Noted. proximity to the facility must be developed and Net Mtg Regional implemented. 8.20 Will the transportation of general waste to the 9Feb09, Mike Bonya, SANCO Rate payers will not be liable for waste facility in future result in rate payers paying Net Mtg Regional transport costs as these are generally borne by more? the producers of that waste, or by levies imposed on domestic waste producers by the local authority for waste removal services. The upgrade of the R335 will be funded from the public purse however. 8.21 Is there a mechanism to double check the type 9Feb09, Mike Bonya, SANCO Yes. The Operating Manual for the site includes of waste transported to and received at the Net Mtg Regional waste acceptance procedures, which include site for disposal? This will help in identifying sampling and testing a waste stream while still medical waste and ensuring that it is not at the generator’s premises, and then re-

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accepted at the facility? sampling the waste stream and testing indicators in the site laboratory to confirm the waste type before disposal, for hazardous waste. Medical waste would not be accepted on site, and where it is detected (such as mixed in with general waste streams), appropriate procedures will be in place to alert authorities and remove and dispose of the waste in the correct manner and at the correct facility. 8.22 How will SANCO get involved on the 9Feb09, Mike Bonya, SANCO There will be an EMC and Community Liaison monitoring of the facility and will there be a Net Mtg Regional Forums established to include I&APs and civil monitoring office? society organisations in these ongoing consultation forums. The monitoring of the facilities performance will be an integral function of these forums and committees. 8.23 Where is the exact location of the site? 24Feb09, Kelello Makgoka, On the Farm Grassridge, on PPC owned land. Net Mtg Sundays River Valley Municipality 8.24 What type of hazardous waste will the site 24Feb09, Kelello Makgoka, A wide range of wastes will be accommodated accommodate and will medical waste be Net Mtg Sundays River (refer to the PAR) for more detail. Medical accepted at the site? Is there a limit on the Valley Municipality waste will be accepted. The facility will only be amount of waste that will be accepted? able to accept and manage as much waste as the design and operating capacity allows for. 8.25 A community awareness programme around 24Feb09, Kelello Makgoka, Noted. this facility must be implemented. Net Mtg Sundays River Valley Municipality 8.26 The use of a Waste Management Plan to 24Feb09, Rudi Herholdt Noted. This requirement is evident in the Waste reduce the amount of waste produced must be Net Mtg Sundays River Management Philosophy Report contained in encouraged as well as recycling of waste to Valley Municipality the PAR which advocates waste minimization, create more jobs, this will also result in less recycling and re-use as essential to minimizing waste being transported and reduced transport the waste volumes having to be interred at the costs. landfill. 8.27 Rehabilitation and monitoring of the site is 24Feb09, Mthetheleli Nkohla, This will be in accordance standard operating encouraged. Net Mtg Sundays River and decommissioning practice as outlined in the Valley Municipality PAR. 8.28 Is there an emergency plan to manage any 24Feb09, CV Mtata, Sundays It is not understood as to what these

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unexpected activity that was never envisaged Net Mtg River Valley unexpected activities might entail or imply for or identified in the studies? Municipality operational phase activities. Accordingly, the EAP has no response other than to refer the individual to the PAR. 8.29 Who will be responsible for emergency plans 24Feb09, CV Mtata, Sundays A range of entities and institutions will be and monitoring of the facility? Net Mtg River Valley responsible. The operator themselves, NMBM, Municipality the yet to be established EMC, independent third party auditors as well as mandated regulatory authorities (DEA, DWA etc) will fulfill these compliance monitoring functions and oversight functions. It will be a condition of authorisation that appropriate monitoring and corrective action processes be developed and implemented for the duration of the facilities lifespan; including end use monitoring once the facility is decommissioned. 8.30 Regular audits of the facility are important as 3Feb09, Sue Hoffman Noted. This will be standard operating practice people at Motherwell are directly affected by Pub Mtg and is almost certainly likely to be a condition the current facility at Aloes. PE of environmental authorisation. 8.31 What has happened about the rezoning of the 3Feb09, John Sayster The land is at this time not rezoned for use as a land and what is the timeframe for the Pub Mtg landfill. This process will take place once the proposed rezoning? PE required authorisations and permits for the facility have been secured. On average these rezoning applications take in the order of 3-6 months. 8.32 If the perceptions of tourists are affected by 3Feb09, Primrose This recommendation will be carried over to the the location of the facility then the monitoring Pub Mtg Madikizela, Portnet EMP. programme should include the monitoring of PE the perceptions of tourists. 8.33 What disposal options are envisaged for waste 3Feb09, Primrose It is likely that some slags and ash waste streams that will be excluded from the site e.g. Pub Mtg Madikizela, Portnet streams will be accepted, to provide daily cover slags. PE and co-disposal media for the site. For large slag waste streams, it is unlikely that transport of the slag to the site would prove economical, and the development of dedicated slag disposal facilities at or closer to the generator’s premises

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is likely to be considered by the generators. 8.34 What are the rehabilitation options for the site? 3Feb09, Goodman Prince The site will be capped, revegetated and not Pub Mtg used for any other purpose post rehabilitation. PE 8.35 Where will the clay for the liner for the facility 3Feb09, Andrea Von Holdt, No, there is not enough clay material on site. come from, is there enough on site to be used Pub Mtg CDC The liner will be constructed from a variety of as a cover material as well? PE imported natural and synthetic materials. The co-disposal of wastes (i.e. using inert wastes as cover material) will ensure that adequate cover material is available. It is anticipated that there is enough cover material available on site for this purpose, as well as the final capping of the rehabilitated landform on final decommissioning of the landfill. 8.36 What is the long term plan to ensure that this 3Feb09, Andrea Von Holdt, The operation and management of the facility is a sustainable project? Pub Mtg CDC will ideally be in accordance with national and PE international waste management best practice. By definition it can be interpreted or postulated that facilities of this type probably cannot be classified as sustainable. The waste management and operational practices are intended to be in line with the prescriptions of the National Waste Management Strategy (NWMS) which aims to integrate sustainability objectives in waste management activities and processes. 8.37 The project is proposed to operate in four 4Feb09, Chris Morley The liners of each phase will be connected, so phases, how is each phase integrated so that it Pub Mtg that leakage does not occur between phases. A does not result in leaks in the liner for the Sunlands strip of additional liner is constructed for the facility when you move between phases? earlier phases, to facilitate tying in future phase liners during construction. Planning would be integrated, so that a bed of solid waste is placed above the liner of new phases before co- disposal and significant activity takes place on that phase, to protect the liners. 8.38 We object to the inclusion of any types of 4Feb09, Chris Morley Noted. This will be carried forward as a

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incineration at the facility. Pub Mtg recommendation as a condition of Sunlands authorisation. 8.39 Will there be any incineration at the facility? 4Feb09, Eric Holmden No. Pub Mtg Sunlands 8.40 If the site is going to impact on Rooidam as we 4Feb09, Keith Finnemore The air quality impacts on the immediately don’t want a disaster situation because Pub Mtg surrounding areas in general, are predicted to monitoring and auditing does not extend to Sunlands be of minimal significance. It will be a this area. recommendation for condition of authorisation that communities and sensitive areas in close proximity to the facility be actively monitored and audited for compliance to best practice, or the required minimum standards for a given environmental aspect as and if these are applicable 8.41 The monitoring of the facility does not include 4Feb09, Sigi Bailles Noted. This will be carried forward as a the transportation network but only the site, Pub Mtg recommendation as a condition of the monitoring needs to be extended to include Sunlands authorisation. the transportation network. 8.42 The report states that there will be no “people” 4Feb09, Andrea von Holdt, Once the site is rehabilitated, capped and access to the site after rehabilitation; this Pub Mtg CDC access restricted it will not present a direct implies that the site presents a hazard after Sunlands hazard. Ongoing landfill integrity monitoring, closure? Will it present such a hazard? air, groundwater and leachate management monitoring processes will be put in place to identify any situations or events that may lead to the rehabilitated landfill becoming a hazard. Similarly all aspects required to be monitored shall be done so in accordance with the Operating Manual contained in the PAR. 8.43 Fire Risks – a recent spontaneous combustion 22Feb09, Morgan Griffiths, Noted. This recommendation will be carried episode at the Aloes (II) waste site has letter WESSA EP over to the EMP. highlighted the need to have adequate fire- fighting equipment, staff training, emergency plans and municipal fire-fighting support. This site is far removed from the nearest fire- station and hence will need to have adequate

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resources of its own. This area is generally dry, and predicted to get drier due to Global warming, so the provision and maintenance of fire-breaks around the site will need careful attention. 8.44 Windscatter – Adequate numbers of mobile 22Feb09, Morgan Griffiths, Noted. This recommendation will be carried windscatter screens and litter control is letter WESSA EP over to the EMP. required. 8.45 Air Quality Monitoring – We are delighted that 22Feb09, Morgan Griffiths, Noted. the GHWMF plans to include gas extraction letter WESSA EP pipes, which may allow for the future trapping and utilisation of gas for energy generation. 8.46 Treatment of H:H wastes – It is not clear to us 22Feb09, Morgan Griffiths, Given that the exact wastes expected to be whether from the onset of the site, whether letter WESSA EP generated by future Coega IDZ industries is not H:H wastes will be treated and then disposed yet know, detailed planning of treatment and of in encapsulation cells, such as the concrete disposal methods for the site has not been encapsulation blocks seen at other H:H waste carried out as yet. It is noted that it would be sites. If they are to be, the encapsulation area preferable to treat and dispose of high hazard needs the highest standard of linings and to be wastes by methods other than encapsulation, constructed to the latest designs that prevent and that the construction of an encapsulation pressure leaks, as per knowledge gained from silo would be preferable to encapsulation in the Aloes H:H waste site and others. mass concrete blocks. If required, design would take into account current containment standards and lessons learnt from other facilities. 8.47 Appointment of GHWMF operator – WESSA’s 22Feb09, Morgan Griffiths, Noted. It is anticipated that the tender process experiences from being a member of the letter WESSA EP will be judging potential operators on their Roundhill H:h waste site (East London) EMC, technical ability and past track record. The have convinced us that only a company or recommendation that the authorities are entity with a track-record of expertly managing involved in the scrutiny of potential operators a H:H waste site should be appointed to will be recommended as a condition of operate the site. The tender for such authorisation. appointment needs to be restricted from any ‘wannabe’ operators! The management of Roundhill had been fraught with serious problems because of the appointment of

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inappropriate managers/operators. We hold that DEAT and DWAF need to vet the tendering and selection process to ensure that an experienced operator is appointed. 8.48 Monitoring mechanism – WESSA requires that 22Feb09, Morgan Griffiths, Noted. The establishment of the EMC and CLF’s an independent monitoring body is letter WESSA EP will be recommended as a condition of appointment for this GHWMF, namely an EMC, authorisation. Third party review of the with independent auditors reporting to it (as management and monitoring processes will be per the Aloes H:H waste site situation). The a requirement by the regulating authority and proposed EMP and EMS, with its appropriate will almost certainly be a condition of ISO internal monitoring regime, are not authorisation. adequate without independent oversight and checking. We urge DEAT to require the formation of an EMC with appropriate public representation on it, as part of any authorisation Record of Decision. 8.49 Heat treatment facility – WESSA does not 22Feb09, Morgan Griffiths, Noted. It will be a recommendation for object to any proposed autoclave facility at the letter WESSA EP condition of authorisation that no incineration GHWMF in the future, but would be opposed to be allowed at the facility. any incinerator that would burn any wastes that gave off toxic compounds such as dioxins and furans. While the organic components of abattoir or veterinary wastes could safely be burned, were theses wastes mixed with other wastes, particularly plastics, then unacceptable amounts of dioxins and furans would be released. 8.50 Illegal dumping and wind scatter - As with any 19Feb09, Colin Jones, PPC While the illegal dumping issues highlighted other Waste disposal site (a visit to Aloes will letter here are valid and often the case in the Port confirm this) evidence of illegal dumping of Elizabeth area, as well as countrywide, waste on the access road to the Waste site is appropriate enforcement of the relevant clear to see. How would this be statutes is required to prevent this. It is controlled/eliminated? conceded that this is very difficult to prevent, however, as it is most likely that only registered waste removal service providers servicing IDZ industries, or municipal waste vehicles, utilizing

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the proposed facility it is not anticipated that illegal dumping from these vehicles will be a concern.

Similarly, monitoring and enforcement of best practice waste management and disposal procedures will have to be the standard for the proposed facility and binding on all parties involved in the management, operation and servicing thereof. 8.51 Illegal dumping and wind scatter - A significant 19Feb09, Colin Jones, PPC Regular clearing/cleaning operations along haul problem will arise with wind blown litter from letter routes will have to be implemented as standard the site contaminating the surrounding area. procedure. This will be a recommendation for At Aloes certain control measures are used but condition of authorisation. the surrounding area up to several kilometers from the site is significantly polluted with wind blown litter. How would this be controlled/eliminated? 8.52 Adherence to conditions of the ROD - Should a 19Feb09, Colin Jones, PPC PPC would have to be permanently represented positive ROD be obtained with significant letter o the EMC in order to ensure that issues can be mitigation measures listed, what control appropriately and timeously addressed. measures would be in place for neighbours (i.e. PPC) to monitor compliance and ensure rectification of non-compliance? 8.53 Studies were done on the community 16Feb09, Sue Hoffman The EAP has no knowledge of the studies surrounding the existing Aloes site and they fax referred to. The air quality studies conducted identified that the site had no effect on this for this assessment have indicated that due to community but medical records of the nearby the relatively large distance from any community reveal they die of terrible cancers. communities around Footprint F these cancer Regular monitoring and checks should be risks are considered minimal and within the done. An annual external audit should be done maximum acceptable range proposed by the and corrective measures put in place. A authorities. An EMC will be established to monitoring committee should be set up to ensure that the monitoring of the facility is as include I&APS from near and far. transparent and inclusive as possible.

9. EIA and Public Participation

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9.1 WESSA is comfortable with the process that 10 Feb09, Morgan Griffiths, Noted. has been followed; it is a good example of how Net Mtg Wildlife and the process and public participation should Environment work. Society 9.2 We appreciate this process and the thorough 24Feb09, Kelello Makgoka, Noted. consultation and studies that have been Net Mtg Sundays River conducted in identifying a suitable site. We are Valley Municipality happy with the extensive studies that have been done and support the project. 9.3 Were there any other issues, other than 24Feb09, Mthetheleli Nkohla, The screening and footprint ranking exercises biodiversity that were used to identify this site? Net Mtg Sundays River undertaken in the site selection took a variety Valley Municipality of biophysical and social considerations into account. The site selection process is extensively described in the Footprint Ranking Report. 9.4 The ANC executive will look at the report and 9Mar09, L Suka, ANC Noted. make further comments. Net Mtg Region 9.5 I have identified a fatal flaw in this process, in 3Feb09, Sue Hoffman Bohlweki-SSI Environmental is of the opinion 2007 at the Public Meeting I requested Pub Mtg that the air quality studies conducted for the specialists to contact me with regards to PE and fax EIA process is of the required standard and historical data on air quality and health impacts of appropriately reflects the site specific context related to the Aloes Facility and no specialists 16Feb09 of the proposed facility. have contacted me to date. I am still available to provide this information and request that a With regard to the perceived fatal flaws the specialist on this project come and talk to me following responses are put forward: and view the documentation available. 1. All potential pollution sources from deposited wastes associated with the (additional issues added from fax received proposed facility are designed to be 16Feb2009) contained within Footprint F. Appropriate stormwater, groundwater and air quality I also said there were fatal flaws based on management and monitoring systems have statements made at this meeting (Public been incorporated in the Operating Manual Meeting 3 Feb2009). included in the PAR.

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1. Pollution deemed to be of minimal 2. It is not anticipated that the operational significant problem facility will have a direct impact on the 2. It was unlikely that the facility would adjacent citrus farming industry due to the impact negatively on the surrounding citrus distance of the facility from these citrus farms growing areas that will ensure that gaseous 3. Odor impacts, cancer risks and risks of emissions from the site have very little carcinogenics exposure would affect 1:3 chance of contaminating these crops. million 3. The air quality studies have indicated that 4. No buffer zones were necessary total maximum incremental cancer risk levels were predicted to be less than ~ 1 in These assessments have been established 3.5 million for the proposed landfill through desk top studies. operations. The maximum cancer risk at the sensitive receptors as a result of Pollution will affect nearby communities if the emissions from the proposed landfill site bar is not raised. Odours from the chemical was predicted to occur at Rooidam (~ 1 in composition do impact the surrounding areas. 45 million). No odour threshold Buffer zones are required by law. exceedances were predicted to occur due to on-site concentrations of odoriferous I have since met with the consultant Marc gasses. Off-site odour impacts were Hardy. Waste sites are unfortunately a predicted to far below the acceptable odour requisite with industries today. The very real unit level at all the sensitive receptors. problem of complaints from communities must 4. A 500m buffer zone around the facility has be clearly taken into consideration as all lives been recommended by the air quality are important and standards must be First specialist. World. These air quality assessments are by definition desk top exercises that use well established computer modelling processes, and take the area’s climatological data and topographical aspects into account in the assessment process.

The yet to be established EMC (if appropriately constituted) will serve as the appropriate forum, along with the Community Liaison Forum initiatives, to ensure that public issues

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and concerns regarding the facility are given due attention and action. 9.6 We have a few concerns regarding the EIA 3Feb09, Bernard Venter Noted. These additional comments have not which we will forward through to the Pub Mtg been received to date. consultants. We are having a general meeting PE on the 12th following which we will provide input. 9.7 One of the sites proposed was near Amanzi, is 3Feb09, Margaret Galela No. this option still a consideration? Pub Mtg PE 9.8 The image on page 43 of the report is incorrect 4Feb09, Paul Hansen The image has been amended to reflect the and should be removed from the report; this Pub Mtg distance to the nearest boundary of the was raised at the last meeting but has still not Sunlands proclaimed reserve extent of Addo, namely the been affected in the report. Colchester section. 9.9 The weather data on page 38 of the Draft EIA 4Feb09, Paul Hansen These inaccuracies have been amended to report is incorrect. There are a number of Pub Mtg accurately represent climatological data additional inaccuracies in the Draft EIA report, Sunlands available for the area. which casts a shadow on what is contained in the rest of the report. We have raised these Due to the highly technical nature of the matters before, but nothing has been done, the specialist studies it is difficult to relate these same inaccuracies appear in the report. The findings without referring to the assessment errors we are picking up are related to things processes and technical jargon utilised in these we can understand, what about the more assessments. The EAP is of the opinion that specialist reports where we don’t have the these specialists reports or of an appropriate knowledge to pick up any inaccuracies. This technical standard. information is being used to make judgements but the information is incorrect and false. It is requested that what is deemed to be incorrect or false is brought to the attention of the EAP. The respondent must bear in mind that these studies will most likely be subject to peer review during the authority review phase 9.10 The report states that there is the potential for 4Feb09, Paul Hansen No incineration capacity is planned for the thermal treatment at the facility in future, this Pub Mtg facility to the knowledge of Bohlweki-SSI is incineration. We have been previously Sunlands Environmental at this time. It will be a reassured and it has previously been stated recommendation for condition of authorisation that there will be no incineration. If that no incineration of waste be permitted at

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incineration does take place we will oppose the the facility during its lifespan. project, we have stated this from the beginning of the process. The project will not proceed if It must be noted that thermal treatment can be it includes thermal treatment at any stage. in the way of an autoclaving technology as well Once the facility is there you may be forced to (medical wastes) that does not incinerate accept a thermal treatment/incineration wastes as such but uses heat treatment to component at a later stage if it is applied for. render these wastes inert. It has been the view of the Sundays River Valley Community Form from the beginning that incineration will not be acceptable. 9.11 This is supposed to be the forum where we 4Feb09, Keith Finnemore This is an ongoing process and significant raise issues and they are addressed but this is Pub Mtg efforts are being made to address all concerns. not happening. Sunlands It is anticipated that the revised draft EIR will to a large degree address these outstanding issues and concerns. 9.12 We are satisfied with the process taken to 22Feb09, Morgan Griffiths, Noted. investigate and prepare a final Environmental letter WESSA EP Impact Report that meets the DWAF Minimum Requirements for Hazardous waste sites and the regulations of the National Environmental Management Act (Act 107 of 1998). We are currently satisfied with the public participation and community engagement processes for this GHWMF. 9.13 WESSA-EP concurs with the findings of the 22Feb09, Morgan Griffiths, Noted. Draft EIR that Footprint F would appear most letter WESSA EP appropriate for siting the GHWMF. We base our decision on the fact that the proposed site: • The study to elucidate the most appropriate site has been thoroughly undertaken, with the input of I&APs making a substantial contribution to the process; • is on partially mined land, the land use being compatible for this area; • is closer to the centre of Port Elizabeth,

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having lower travel costs and fuel use (CO2 emissions) over the lifespan of the GHWMF than the other sites • is underlain by thick Kirkwood and Sundays River formations, which will protect the deeper Table Mountain Group artesian aquifer; • will only require the relocation of 20 people; • has a very low human population in the area and hence will not unduly impact on a larger community; • is well screened from the R335 provincial road; • has an overall low conservation worth, and that the small patch of threatened Bontveld is largely outside the site area and it can be reasonably protected and appropriately managed; • is far enough away from the citrus growing areas that gas emissions from the site have very little chance of contaminating these crops; and it • is located outside of Sundays River catchment.

We raise concerns and issues on the following, based on the contents of the reports and from WESSA EP’s experience of being long-standing members of the Aloes H:H waste site Environmental Monitoring Committee (EMC): (The detailed concerns raised are captured in the relevant sections of the issues and responses trail and a copy of this input is included as an Appendix to this report.) 9.14 Future planning – WESSA reiterates the 22Feb09, Morgan Griffiths, Noted. This will be carried through to the EMP

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suggestion that the NMBM consider acquiring or letter WESSA EP as a recommendation otherwise setting in place land use restrictions in this area, so that Footprint C can be held in reserve as a future waste site. Considering the time and resources that have already gone into studying this site, acquiring it for future use could well be cost and time effective. 9.15 Consideration of Alternatives - The current 19Feb09, Colin Jones, PPC The fact remains that additional H:H landfill waste site at Aloes near Port Elizabeth has letter capacity will have to be acquired in the short approximately 7 years of life left at current term future to cater for the Coega IDZ, as well volumes according to the manager on site. as the region in general. Owing to the original There is currently an EIA in progress for an projections of Aloes running out of capacity extension to the life of this waste site by sooner than what is now anticipated the EIA infilling between the two current cells. This will process for the proposed new facility was extend the life by a further 10 years according initiated prior to the decision being made to to the manager on site. Surely this EIA should apply for an extension to the Aloes facility. Due be completed and an ROD obtained before a to the length of time to date (approximately 7 new site is considered? If the Aloes extension is years) that the current site selection, ranking successful the construction of a new facility and EIA reporting process has required it would could be delayed by a number of years. not have been sensible to what for authorisation of the Aloes extension. 9.16 Inaccuracies in the Reports - The investigation Feb09, Sundays River The errors referred to have been corrected as of the waste site are costing the South African letter Valley Community follows: taxpayer a huge amount of money. It is Forum 1. The weather data has been corrected to expected that the quality of the reports would accurately reflect the ambient temperature reflect the considerable amounts of money and precipitation data for the areas in being paid to the Engineering Consultants. And question. yet, we find that basic errors are still being 2. The references to he proposed pipeline are made, which effectively casts a shadow on the as result of utilizing an existing EMP format entire volume, rendering it suspect from an (pipeline EIA application) for this project accuracy point of view. For example, that was not edited correctly by the EAP. 1. The weather data in the draft EIA, Table 4.1 The EMP itself is context and project page 38, is obviously wrong. It implies that specific as it relates to the proposed Port Elizabeth’s summer temperatures are GHWMF phasing and operations. It must be higher than Addo, and that winter reiterated that is a Draft EMP that will have temperatures are lower. (Jones & Wagener to be further refined and submitted for

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PAR page 14 table 2 is correct) authority approval once detailed design 2. The draft EMP, glossary, page iii, states information is made available, the preferred Contractor: Persons / organizations operator and construction contractor contracted by the Developer to carry out appointed. parts of the work for the proposed 3. The map referred to on page 43 of the Draft pipeline. This clearly indicates that the EIR has been amended to reflect the closest EMP has been largely lifted from another distance to a currently proclaimed park study. Hardly encouraging for any I & AP’s, boundary as opposed to the distance to the never mind the due diligence required. Addo main gate. In this instance it is 14 km 3. On page 43 of the draft EIR, there is a map as the crow flies from Footprint F to the showing the distance from the site F to the boundary in the Colchester section of the Addo Elephant National Park. This is stated park. The initial distance of 30 km depicted as approximately 30km. Why the distance on the original map was reflective of the to the park main camp is important, and distance from the facility to the main not the distance to the nearest conservation visitor’s gate at Addo. area, (about 14km) is a mystery to us. In 4. The map on page 6 has been revised to our last submission, we raised precisely this reflect the correct locations of Footprints E issue, but no correction was made. Was this and F. in order to mislead anyone not familiar with 5. The technical reports produced by the the area who might review this report? (30 relevant specialists are reflective of the kilometers Sounds a lot better than 14.) technical assessment methodologies and 4. The Map (fig. 1.1) on Page 6 of the scientific terminology and jargon that are introduction has sites E and F reversed. associated with these fields of expertise. This too was pointed out in the previous Bohlweki-SSI is of the opinion that these feedback to I & AP’s and has also gone reports are of an appropriate standard, and uncorrected. adequately assess the given specialist 5. In the brief period allocated to I & AP’s to aspects under consideration. Accordingly, it review these extensive documents, we were is difficult to “dumb down” – in the most able to identify a number of misleading respectful sense of the word - these inaccuracies. It is highly probable that technical reports in a manner that does not these extensive and technical documents detract from the assessment methodology, contain many more such errors and guidelines and requirements of these inaccuracies which need to be corrected by specialized assessments. It must be noted qualified people. Many of these studies are that a project and application of this nature very complex and require specialist is highly likely to be subject to peer review knowledge to understand their implications by the authorities once the application is

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within a development of this nature before submitted to them for decision making. being able to determine the veracity of such information. For example the benchmark values for carcinogens in an air pollution study, or what is considered adequate substrate in a geo-hydrological or engineering interpretation. It would be absolute Greek to most lay people, yet it has been expected to date that we the public and the I&AP’s must review and correct these documents. We talk about due diligence often, but this is now bordering on undue negligence. 9.17 Disregarding the inputs of the I&APs - Our Feb09, Sundays River Noted. It is hoped that these recommendations previous submission, dated 5th November letter Valley Community have been incorporated and addressed in the 2007, as reflected in the final feasibility report Forum Revised Draft EIR. as well as other comments and suggestions from other I&AP’s, listed a number of suggestions which we believed were critical to the further development of the project. We were astonished to find that NOT ONE of these recommendations had been considered. We were even more astonished to hear that, at the meeting of the 4th February, 2009, when we raised the issues again, there seemed to be acknowledgement from the assembled engineers and consultants that these suggestions seemed to have due merit, and we were asked to resubmit them. 9.18 Why are the Engineers and Consultants deaf to Feb09, Sundays River Bohlweki-SSI is of the opinion that a rigorous the suggestions of the SRVCF and other I & letter Valley Community and comprehensive public participation process AP’s when we have engaged in constructive Forum has been conducted to date and has complied dialogue and have made valuable contributions with, and probably exceeded regulatory to this project in the past, as acknowledged by requirements in this regard to date. It is the consultants in these reports. Why then is it unfortunate that the SRVCF’s concerns have necessary to threaten, and take these issues to not been fully addressed to date and it is this

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other channels on a higher level before additional round of public engagement and cognizance is taken of them? Why are they so Revised Draft EIR review that the EAP hopes disrespectful of Government legislation, which will address these outstanding issues and places high priority on the public process? The concerns. two main issues are discussed in more detail in sections 4 and 5 of this letter. (Captured under the relevant sections of this Issues and Responses Trail and a copy of the correspondence is included with this Report). 9.19 Incinerator (Thermal treatment) - The Feb09, Sundays River Noted. The SRVCF’s opposition to incineration community has always been vehemently letter Valley Community on sight will be included in the final opposed to the establishment of an incinerator Forum submissions to the authorities. It will be a on this site. This is on record and recommendation for condition of authorisation acknowledged as such by Dr Angus Patterson that no incineration is to be allowed on site when he assured this community that an ever. incinerator will not be established.

On page 3 of the draft EIR, it states that the landfill …”could, in future, include a combination of the following, A thermal treatment facility for high hazard organic waste, and possibly difficult wastes such as abattoir waste….. It is important to note that the current design does not include certain of the above mentioned future options.” It was with the assurance of the project consultants that there would never be an incinerator at this facility, that we as a community accepted the possibility of a waste site within our region. All subsequent agreements and understandings between this community and the successful undertaking and implementation of this project are subject to this condition being complied with, now and in the future.

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9.20 This community will strongly oppose any Feb09, Sundays River Noted. With regard to the issues outlined the development on this site until such time as the letter Valley Community following responses are put forward: following issues have been dealt with Forum satisfactorily: 1. As indicated previously in this document it 1. The possibility of a thermal processing will be a recommendation for a condition of treatment plant/incinerator is removed authorisation that no incineration of any permanently from the proposal. sort whatsoever be permitted at the facility 2. Road reconstruction has been completed to during its entire lifespan. a point where it can accommodate the 2. This will also be a recommendation for additional traffic. condition of authorisation. 3. The footprint is extended to include the 3. The management and maintenance of these access roads that feed the site, and roads will be integral to ensuring that spill, management/operational plans have been litter, and traffic disruption events are kept comprehensively revised to include the to a minimum. The footprint of the facility is monitoring and cleaning of these roads. defined as, and limited to, the actual 4. The PAR, SIA, EMP and the EIR reports be physical site boundaries of the total area to rejected until they have been amended to be developed. The access roads to the include the increased footprint. facility are therefore not included in this 5. A Transport Risk Assessment is undertaken footprint. to study the risk to tourists, export and 4. The EAP does not agree with this statement local food by transporting waste under as we are of the opinion that transport and conditions of a) no road improvement and existing road quality considerations have b) rebuilt roads. been adequately addressed. 5. The Transport Risk Assessment will not be conducted as previously stated.

10. General

COMMENTAT NO. ISSUES RAISED DATE RESPONSE OR 10.1 A municipal site would level out the playing 3Feb09, Greg Paterson Yes, the operating licence will go out to tender to field, will this project go out to tender? Pub Mtg select the preferred bidder. PE 10.2 The original date for the closure of Aloes 3Feb09, Greg Paterson The EIA process under way for the extension of the Facility was 2010, this has now increased by a Pub Mtg Aloes facility is to extend the lifespan thereof. Aloes year and potentially an additional 5 years PE was initially scheduled for closure in 2010 but this according to the EIA that is currently has since been extended due to lower than underway, why has this timeframe shifted? anticipated waste streams being received by the facility. The extension of Aloes would add an additional 5 years to the facility lifespan. 10.3 Hazardous waste is a purified chemical, often 3Feb09, Cllr Andre Ideally hazardous waste should go back to source variable, depending on where it is generated in Pub Mtg Goosen for recycling or re-use, unfortunately it is not always the city. Hazardous waste should ideally go PE possible to find an alternative use or to re-use such back to the source for recycling. wastes. Hazardous waste is not necessary a purified chemical and waste composition can vary depending on the process or facility generating it. Therefore, as part of the initial sampling and testing that is carried out on a waste stream (while it is still at the generators premises), a understanding of the process, products entering the process and the expected by-products / waste products are investigated to understand the nature and composition of the waste produced. If the waste is suitable for re-use or for an alternative process, this can be investigated at the time. 10.4 I support this project as I am in need of Comment Nontozanele Noted. employment. Form September 10.5 What can be done to assist the local authority 3Feb09, John Sayster This is essentially the mandate of the local, to improve waste management in the Metro? Pub Mtg metropolitan and provincial authorities

COMMENTAT NO. ISSUES RAISED DATE RESPONSE OR PE 10.6 I am happy that this project will create 30Jan09, Thanduyolo Noted employment, employment agencies should be fax Caluza, avoided and government should be in full community control of this project to avoid the exploitation of workers. 10.7 We support this project as it will create 28Jan09, Annie Borens, Noted. employment for woman. It is important the fax ANCWL Addo recycling and cleaning of areas in Addo is undertaken. 10.8 Will the site affect Eskom powerlines planned 9Feb09, F Williamson, It is unlikely that it will affect provisional or planned for the area? fax Winterhoek powerline servitudes for the area as these would Farmers have to traverse PPC land that is earmarked for Association mining operations. As such, it is highly unlikely that PPC would provide consent to Eskom for powerline servitudes in light of these servitudes potentially sterilizing areas to be mined. 10.9 We support this project as it will create Comment Thando Noted. employment. form Gqomo, Uitenhage

ISSUES AND RESPONSES TRAIL – REVISED DRAFT EIR APRIL TO MAY 2010

1. Biophysical Issues of Concern (Fauna and Flora)

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1.1 What will be the impact on birds that fly in 26/04/2010, Kelello Makqoka, It is unlikely that there will be any direct and out of the facility? Net Mtg SRVM, impacts on avifauna such as increased Environmental mortality of individual species as the security Health Practitioner fences are to be 1.8m in height and it is unlikely that this poses a significant collision risk for birds. 1.2 Will the facility be safe for the wild animals, 03/04/2010, Ndumiso Peter, It is not anticipated that any wild animals will will it impact on them? Net Mtg SANCO NMBM be significantly impacted on as per the specialist study findings in this regard.

2. Potential Impacts on Groundwater

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2.1 Strict monitoring measures should be 26/04/2010, Kelello Makqoka, Noted, however, as indicated in the implemented to prevent leaks that would Net Mtg SRVM, Geotechnical and Geohydrological specialist destroy underground water. Environmental report (Ch 7 Draft EIR) the depth of the Health Practitioner underlying and impermeable geology will effectively prevent the ingress or percolation of water into the deeper lying aquifers below the study area. 2.2 When the Leachate Treatment Plant is built, 18/05/2010 Morgan Griffiths, Noted. This recommendation is included in the it will also need to be bunded. We note that email WESSA EP Permit Application Report produced by Jones the Leachate dam appears to have an and Wagener. adequately designed liner system; though the climate change trends for this region

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suggest that this site will need to cater for lower annual rainfall, but for increasing incidents of greater magnitude downpours/flashfloods. The overflow designs of the dams will need to address this, to prevent overtopping and wall collapse

3. Impacts on Air Quality

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3.1 In the event of an incident of spontaneous 20/04/2010, Charles Marais, Noted. As all disposed material will be subject combustion, is this addressed in the report? Pub Mtg SRVCF to a separation process to ensure that The prevailing winds are from the south unsuitable compounds cannot be co-disposed towards Addo which is our major concern; together that may result bin chemical reaction we are not as concerned about spill from and/or an exothermic fire event. The potential runoff from the site as it will not impact on for a spontaneous combustion event of this the Sundays River Valley. type is deemed to be insignificant.

4. Traffic Impacts

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4.1 Will the existing Addo road be able to carry 26/04/2010, Kelello Makqoka, Only construction phase vehicle traffic can heavy duty trucks? Net Mtg SRVM, currently be accommodated due to the poor Environmental state of the road. It has been recommended Health Practitioner as a condition of authorization that the road be upgraded to an appropriate design standard prior to the facility becoming

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operational. 4.2 We will appreciate the upgrading of the 26/04/2010 Cllr. Tambo, SRVM Noted. An environmental application and Addo road so that it will be able to carry authorisation process for the required road heavy trucks. upgrade is currently underway. 4.3 It has been noted that the current 20/04/2010, Paul Hansen, Noted, however, the EAP cannot comment on upgrading of the R335 is for a period of Pub Mtg SRVCF how long these road upgrades may last. about 3 years, discussions with the District Roads Agency indicate that the upgrade may only last for 2 years.

It is important to note that fruit from the Noted. Sundays River Valley is no longer transported via train to Port Elizabeth, the primary mode of transport is therefore the Addo road. Noted, however, it appears that the upgrade According to Provincial Roads the plans and project is intended to be initiated in the 2010 designs for the upgrade of the Addo road calendar year. are complete and have been complete for some time, what is lacking is funding for the upgrade. 4.4 The upgrading of the R335 must be 20/04/2010, Paul Hansen, Noted, it has been included as such. included as a condition of the environmental Pub Mtg SRVCF authorisation and indicate that the waste site cannot commence operation until the R335 is upgraded. 4.5 Page 27 of the report states that access 20/04/2010, Keith Finnemore, Noted. This will be incorporated in the final roads to the site are not included as part of Pub Mtg SRVCF construction and operational EMP’s. the site. Access roads to the facility should be included in the environmental management plan for the facility, this

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should include monitoring of the route by the operator, regular clean ups, corrective action and penalties for illegal disposal. 4.6 We confirm our call that the site does not 18/05/2010 Morgan Griffiths, Noted. These suggestions are included as become operational until such time as the email WESSA EP recommendations for conditions of R335 has been upgraded and the relevant authorisation. sections of the P1954 – P1958 – MR00470 roads have been tarred to minimise dust generation. 4.7 A major concern to us is the event of a 18/05/2010 Morgan Griffiths, Noted. This will be incorporated in the final vehicle accident resulting in a hazardous email WESSA EP construction and operational EMP’s. spill on the R335, R75 or approach roads. The site operator must have an emergency response plan and containment/clean-up facilities to deal with any spill within a certain reasonable distance of the site (though we recognise that the transporting company is ultimately responsible for the clean-up). The critical issue remains getting the clean-up started as quickly as possible, to limit contamination of the environment. 4.8 With regards to the potential for illegal 18/05/2010 Morgan Griffiths, Noted. dumping along the approach roads, we email WESSA EP suggest that the strategic placement of CCTV cameras that feed to the waste site’s security office could curtail this potential problem.

5. Socio Economic Impacts of Concern

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5.1 How many permanent jobs will be created 21/04/2010, Cllr. Vusani, Ward It is not known at this time. by the development? net mtg 53 5.2 Will there be opportunities to train people 21/04/2010, Cllr. Vusani, Ward There will most likely be opportunities for skills on the running of the facility as it requires net mtg 53 training for persons employed at the site. trained personnel to operate the facility. However, due to the highly technical nature of these facility operations appropriate qualifications and expertise of potential personnel will be prioritised. 5.3 What are the economic benefits for the 26/04/2010, Kelello Makqoka, The EAP cannot respond to this question as it Sunday’s River Valley Municipality from this Net Mtg SRVM, has not been quantified. development? Environmental Health Practitioner 5.4 There is a need to provide education and 26/04/2010, Kelello Makqoka, Noted. This will be incorporated into the final awareness to local communities, especially Net Mtg SRVM, EMP’s on the impact of the facility and why Environmental scavengers will not be allowed at the Health Practitioner facility. 5.5 We encourage job creation. 07/05/2010 Cllr. Mafana, Noted. Motherwell

6. Heritage related impacts of concern

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6.1 SAHRA does not have any further 11/05/2010, Mariagrazia Noted. This will be incorporated into the final comments for the revised draft EIA report SAHRA Galimberti, SAHRA EMP’s. and EMP. Please note that the recommendations given in our

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Archaeological Review Comment on the 21st November 2007 are still valid and therefore: • If any evidence of archaeological sites or artefacts, unmarked human burials or other heritage resources are found during construction activities, SAHRA APM Unit must be alerted immediately and an accredited professional archaeologist must be contacted as soon as possible to inspect the findings. If the newly discovered heritage resources provide to be of archaeological significance, a Phase 2 rescue3 operation might be necessary at the cost of the developer. • Where bedrock or river gravels are to be affected by mining, it is the responsibility of the developer to ensure that a Palaeontological desktop study is undertaken to assess whether or not the development will impact upon palaeontological resources. A letter motivating for an exemption from an accredited palaeontologist will be accepted if such a desktop study is deemed necessary. If the area is deemed sensitive, a full Phase 1 Palaeontological Impact Assessment will be required and if necessary a Phase 2 rescue operation might be necessary.

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• The Archaeological Review Comment from 2007 does not exempt the applicant from further HIA’s if roads need to be built on land outside the footprints C, E and F to serve the purpose of the Hazardous Waste Disposal Facility. • Decisions in terms of section 34 of the NHRA on the Built Environment must be made by the Provincial Heritage Resources Authority of the Eastern Cape.

7. Concerns and Recommendations for operational Management and Monitoring

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7.1 There is a need for firm monitoring to 21/04/2010, Nosipho Mtili, Noted. prevent scavengers entering the site Net Mtg ANCYL illegally. 7.2 There needs to be an assurance that there 21/04/2010, Nosipho Mtili, Noted. will be no disease outbreaks in future which Net Mtg ANCYL comes from the facility. 7.3 There needs to be an assurance that the 03/04/2010, Carol Mkhithi, Noted. facility is operated by specialized and Net Mtg SANCO NMBM experienced personnel in order to minimize any future impacts on communities. 7.4 Who will be monitoring the facility as this 26/04/2010, Kelello Makqoka, The EMC, eventual operator, NMBMM and local requires a strict monitoring and compliance Net Mtg SRVM, authorities, the CDC and various organs of strategy? All laws must be enforced with Environmental state (Water and Environmental Affairs) will be

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regards to the running of the facility. We Health Practitioner responsible for monitoring of the facility as encourage the use of modern technology to part of ongoing compliance monitoring minimize any risks associated with the activities and programmes for the operational facility. Any spillages will present a risk to facility more comprehensive monitoring communities as well as road users. programmes will be developed on appointment of the preferred bidder and the initiation of construction. 7.5 Strict monitoring during operation is 26/04/2010 Cllr. Tambo, SRVM Refer to 7.5 above. encouraged. How will this facility be monitored? 7.6 Will there be an independent monitoring 29/04/2010, Zukile Jodwana, Yes. As part of the ongoing monitoring process team to monitor the facility in accordance Net Mtg SACP NMBM periodic independent 3rd party review audits with the conditions of the permit? will take place. Community based structures should be trained on the ways and means to evaluate and assess acceptable standards for the running of the facility. 7.7 Any spillages on roads must be monitored 29/04/2010, Zukile Jodwana, Noted. and the law enforced for non compliance by Net Mtg SACP NMBM companies and the operator. 7.8 There is a need for constant monitoring and 07/05/2010 Cllr. Mafana, Noted. feedback to communities during the Motherwell operational phase of the facility 7.9 The monitoring of access roads to the site 20/04/2010, Paul Hansen, Noted. must also form part of the environmental Pub Mtg SRVCF monitoring and management of the site, not just the site itself. Our concern is not only around a spill scenario but illegal and indiscriminate disposal of waste on the route to the waste facility. 7.10 The illegal disposal of waste is important to 20/04/2010, Charles Marais, Noted.

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manage and monitor from a tourism point Pub Mtg SRVCF of view, especially with estimates of a truck every minute on the road, this increases the possibility for a spill or illegal disposal of waste. This area is currently one of the major national tourism destinations in SA which currently enjoys approximately 95% occupancy, the area is currently clean and free of waste. 7.11 Will anyone be allowed access to the facility 20/04/2010, Keith Finnemore, No. Access to the facility will be strictly or will it only be for authorised companies? Pub Mtg SRVCF controlled with only registered waste service It must be noted that the facility in principle providers or local authorities refuse vehicles will be open to the Sundays River Valley but allowed to access the site. as far as we are aware there are no authorised companies in the valley that can collect and dispose of waste. The situation that could result is that waste would be collected and transported to the facility only to be turned away, and this is where the illegal disposal of waste will come from. It will be easier to dispose of the waste on the road side, than transport it all the way back to the valley. 7.12 The Sundays River Valley authorities would 20/04/2010, Paul Hanson, Noted. The facility will be subject to become a legal operator and transport Pub Mtg SRVCF independent audit processes. waste to the facility. The NMBM is also responsible for the facility as well as monitoring of the facility and in essence will then be monitoring itself, which could be a conflict of interests. 7.13 The community needs to have legal 20/04/2010, Paul Hanson, Noted. This will most likely form part of the

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assurance that the facility and access to the Pub Mtg SRVCF conditions of authorisation stipulated by the facility will be monitored. relevant authorities. 7.14 I think the consultants are doing a very 22/03/2010 Thanduxolo Caluza, Noted. good job. The project itself is a good idea fax ANC especially when you look at the situation at Arlington, where there is no control. Arlington is very close to the Walmer Community. I believe the facility will be managed professionally. The planting of tree around this facility will be very important, big and high trees will be ideal. Animal rights groups should have agents to monitor and capture stray animals in and around this facility 7.15 A recent spontaneous combustion episode 18/05/2010 Morgan Griffiths, Noted. at the Aloes (II) waste site has highlighted email WESSA EP the need to have adequate on-site fire- fighting equipment, staff training, emergency plans and municipal fire-fighting support. 7.16 The proposed 1.8m high fence is 18/05/2010 Morgan Griffiths, Noted. These considerations will have to be inadequate, as proved by the on-going email WESSA EP addressed in the final EMP’s and facility detail incidents of scrap-metal scavengers design phase. breaking onto the Aloes II H:H waste site. Additional height and other security measures will be needed.

8. Project detail

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8.1 Who will be operating the facility? 15/04/2010, Mlamli Tsotsi, COPE The preferred bidder/operator has not been net mtg Metro Region appointed at this time as this will only occur once the required environmental authorisation and land purchase agreements have been secured. 8.2 What is the lifespan of the proposed site? 20/04/2010 Greg Paterson, 25-30 years. Pub Mtg Veolia 8.3 PPC have sent a letter as part of this 20/04/2010 Bernard Venter, At this time no formal correspondence has process, will you reply to us in writing? Pub Mtg PPC been received from PPC for the Revised Draft EIR. A previous correspondence submitted by Colin Jones of PPC during March 2009 for the Draft EIR has been responded to and all issues raised therein dealt with (refer to Draft EIR Issues and Responses Trail)

9. EIA and Public Participation

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9.1 We appreciate and welcome the 15/04/2010, Mlamli Tsotsi, COPE This comment is noted, no further comments presentation. Cope will discuss the report net mtg Metro Region were received from COPE. and make a submission. This information has empowered us to understand the type of facility that will be developed. 9.2 The information will be presented to the 06/05/2010 Stephanie No further comments were received from the ANC Regional secretary. The project Cemrette, ANC ANC. information is welcomed and appreciated. NMBM 9.3 What we have is a plan for a process that 20/04/2010 Paul Hansen, Noted. It has been recommended that the

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will take place in the future, once there is a SRVCF SRVCF be included on the yet to be more detailed plan in place we would want constituted EMC for the facility whereby they access to that plan. will have access to these developments 9.4 We need to understand the way forward 20/04/2010, Paul Hanson, Where relevant the various issues and the from here. Will all the issues raised form Pub Mtg SRVCF mitigation thereof have been included as a part of the environmental authorisation? recommendation for environmental authorisation. 9.5 The GPS points on page 10 and 11 of the 20/04/2010, Keith Finnemore, These are correct. report, at the bottom of the page are Pub Mtg SRVCF possibly incorrect. 9.6 We support the following statements made 09/05/2010, Sundays River Noted. It has been included as such. in the reports, and expect to see them in letter Valley Community the Record of Decision: Form a. There will be no incinerator for the life of the facility. b. The R335 will be rebuilt to the agreed standards BEFORE the site becomes operational 9.7 As mentioned in the meeting, we are 09/05/2010, Sundays River Noted. The EAP reiterates that the compliance extremely concerned that our highlighting letter Valley Community monitoring and enforcement measures will of the errant waste issue has not been Form have to be determined and detailed once the adequately addressed. preferred operator has been appointed and Final construction and operational EMP’s We have pointed out that the generation of approved by the EMC and the relevant errant waste from uncovered trucks, or authorities. As such, it impossible for the EAP illegal dumping by members of the public to ensure that this will in fact be appropriately happens to a great extent near all waste enforced at this stage of the process as it is sites. Municipalities, and in particular the ultimately the responsibility of various tiers of NMBM are extremely inefficient in local government to ensure that appropriate preventing or cleaning up this errant waste. enforcement measures are put in place to ensure that illegal dumping and “fly litter” are

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As a community we cannot accept that the minimised or prevented. R335, which is the main tourist road in the Eastern Cape, will end up being littered, and threatening the tourist and farming industries in the area.

In order for us to have some comfort in this matter, we would like the following to be addressed in the Record of Decision: • The R335 will be recognised as an important tourist and export food produce route. An errant waste monitoring and collection system will be established to mitigate this problem. • The responsibility for implementing such system shall be the operator of the hazardous waste site (i.e. not the Municipality). As the SRVCF, we would like to thank all those who participated in the process. It was a long and often hard road, but in the end, we believe, the correct decisions were made. 9.8 As “the National Environmental 08/04/2010, Lemercier Pierre- Noted. It is the understanding of the EAP the Management Act No. 107 of 1998 (NEMA) email Louis, point sources of waste generation are where builds on the Environment Conservation Act Renewable Energy recycling and reuse initiatives and and provides a link between new Centre programmes need to be implemented. As developments and environmental such, the proposed facility is for the disposal protection. One of the main principles of hazardous wastes that cannot be recycled, proposed in NEMA is that of Integrated reused or minimised. It is by definition the last Waste Management (IWM) which promotes line of the overall national waste management

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the avoidance, minimisation, recycling and strategy. It is unavoidable that certain types treatment of waste in preference to its of these hazardous wastes will have to be disposal to landfill,” it is quite clear that a disposed – in an appropriate and regulated priority, before working on a land field is to manner. The facility itself cannot therefore be set a comprehensive recycling system. responsible for the waste minimisation strategies employed (or not) throughout the Where is the latter? How can we then region that the facility will serve. assess the remaining quantities and types of wastes which are still to be disposed in a dumpsite?

Investing in a waste dump and related EIA before working on a recycling system could therefore be construed as unlawful.

Moreover, one could also question Coega’s understanding of recycling necessities, advantages and its interest thereof.

This is also surprising for a corporate which claims that it complies with the ISO14,000 guidelines in all its endeavours.

It is worrying that a well known company such as Bohlweki-SSI which works on Environmental issues and has reported on the above piece of legislation has even not mentioned this problem in its report.

What is the opinion of our waste management authorities, which are

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responsible for enforcing the law, on the matter? 9.9 As far as the venue is concerned it is going 03/04/2010, Kiki Dyini, SANCO In order to overcome the challenges to be very difficult for me to reach the fax PE associated with transport to Public Meetings, venue because of transport problems meetings have been held with local community and/or unemployment. structures in their areas, thereby not disadvantaging anyone from receiving As an interested person, the facility is of information on the project. A meeting was most importance for the benefit of the held with SANCO and they were provided with region and all the communities, because a a presentation on the project, the comments healthy environment must be our top made at this meeting have been captured in priority. this Issues Trail. It was agreed at the last public meeting that as the main issue of concern emanated from the Sundays River Valley Community. 9.10 No additional issues, but I want to see the Letter, no Mike Spearpoint, project properly managed from cradle to date Zwartkops Trust grave. 9.11 The report is long overdue yet the project Letter, no Mpumelelo Galela, The EIA and public participation process for does not show good progress so that we are date ANC the regional general and hazardous waste site actually able to participate, due to the fact has taken place over a period of more than 10 of Sandy and Mazizi Consulting. However years. Consultation with communities during the report notes that a health risk each stage of the EIA forms an important assessment will be undertaken and component of the decision making process. recommendations regarding health risks will The legislated process for the EIA and the be included in the EIA and EMP. I need Permit Application Report must be followed, clarification on when we are going to start construction on the facility may only performing on the proposed project? commence once this process has been followed and environmental authorization for the project has been received. 9.12 Please register groundWork as an I&AP for 12/04/2010E Rico Euripidou, This I&AP was registered on the project

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this process and email us a copy of all the mail groundWork- database, and provided with the link to relevant documents for this process. Friends of the Earth download project documentation. The notes SA from the Public Meeting as well as the Also please indicate exactly where in the Presentation from the Public Meeting were EIA stage this proposal is. emailed to this I&AP.

It would also be very difficult for us (logistically) to attend the public meeting and I would thus be very grateful if you emailed the presentations along with a copy of the narrative and we will then also provide comments and feedback in this regard. 9.13 We are satisfied with the process taken to 18/05/2010 Morgan Griffiths, Noted. investigate and prepare these reports, that email WESSA EP meets the 1994 Minimum Requirements for Waste Disposal by Landfill and the regulations of the, Environment Conservation Act (Act 73 of 1989), the National Environmental Management Act (Act 107 of 1998) and the NEM: Waste Management Act (Act 59 of 2008). We are currently satisfied with the public participation and community engagement processes for this GHWMF. 9.14 WESSA EP concurs with the findings of the 18/05/2010 Morgan Griffiths, Noted. EIR that Footprint F would appear most email WESSA EP appropriate for siting the GHWMF. We confirm this decision based on our reasons highlighted in our letter to you dated 22 February 2009. We raised a number of

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concerns in this letter, which appear to have been addressed in the rdEIR. We submit a few comments and offer some suggestions below: Note: the additional issues raised by WESSA have been captured in the relevant sections of this issues trail) 9.15 We are relieved that incineration is not part 18/05/2010 Morgan Griffiths, Noted. of this application and we fully support the email WESSA EP EAP’s recommendation that any positive ROD exclude incineration, as a condition of approval. 9.16 WESSA reiterates our suggestion that the 18/05/2010 Morgan Griffiths, Noted. This will be communicated to the NMBM consider acquiring or otherwise email WESSA EP relevant NMBMM line function departments. setting in place land use restrictions in this area, so that the buffer zone is enforced and that Footprint C can be held in reserve as a future waste site. Considering the time and resources that have already gone into studying this site, acquiring it for future use could well be cost and time effective. 9.17 We support the suggested conditions for 18/05/2010 Morgan Griffiths, Noted. inclusion into any positive ROD. email WESSA EP

10. General

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10.1 Education and awareness in schools is 29/04/2010, Zukile Jodwana, Noted, this will however be the ultimate encouraged as part of a programme to Net Mtg SACP NMBM responsibility of the various local authorities

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separate waste at source as it will ensure that domestic waste is recycled. 10.2 The Draft EIA refers to a lifespan beyond 20/04/2010 Paul Hansen, At present all indications point to the 2016 for the Aloes facility. What does this Pub Mtg SRVCF possibility of the Aloes facility being in mean? operation till at least 2020. 10.3 Are you aware of any interaction between 20/04/2010 Greg Paterson, No. It is beyond the ambit of this EIA process the CDC, NMBM and the EL municipality Pub Mtg Veolia to determine or assess this. regarding the development of mechanisms to reduce the amount of waste coming into PE? There is currently a H:h waste site that is being haphazardly managed. 10.4 What is the timeline for the proposed Aloes 20/04/2010 Bernard Venter, Until 2020 at least. The closure date of the facility? For how much longer will it be Pub Mtg PPC facility is entirely contingent on the volumes operating? deposited in the medium term future. 10.5 I am glad to say I do not have any issues to 09/04/2010, Maggie Hendricks, Noted. declare and congratulate your hard work. fax Cup Soup Kitchen 10.6 We refer to the Nelson Mandela Bay 18/05/2010 Morgan Griffiths, Noted. Municipality’s Integrated Waste email WESSA EP Management Plan, and encourage the NMBM enforce its waste strategies by requiring residential, commercial, industrial and agricultural waste producers to re-use, reduce and recycle their wastes, and thereby limit wastes to landfill and conserve energy and resources.

11. PPC Operations

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11.1 Fauna: We disagree with the assertion the 09/06/2010 Urishanie Govender With regard to the Albany Adder issue the EAP Albany Adder may be present on Site C only email PPC remains in agreement with Doctor Bill Branch as PPC is currently mining at Site E and is that none were identified on site (Footprint F) finding the Albany Adders. This which during numerous inspections thereof during implies that the likelihood of the occurrence the process to date. He states in the relevant of the Albany Adder at Site F is high due to chapter that that it has been positively the close proximity. PPC requires a identified on neighboring land portions (as has scientific motivation for Site F having a been the PPC experience to date for Footprint lower likelihood for the occurrence of the E). This does raise the very strong possibility Albany Adder than Site C. that it will be present on Footprint F as well, however, a complete search and rescue operation for fauna and flora, where relevant, will be conducted prior to the commencement of construction activity as per the environmental specification and recommendations stemming from the specialist studies and incorporated in the Draft EMP. Once again the EAP can only refer you to Bill Branch’s (who is probably SA’s leading herpetologist, most definitely one of them) findings who is based in PE and has extensive knowledge of the region.

11.2 Transport: PPC understands that R335 – 09/06/2010 Urishanie Govender The required roads upgrade costs that were P1958 – P1954 access route will be utilised email PPC used in the Justification table were premised and that this will be a condition of the on the assumption that the existing haul road environmental authorisation. The cost on site would be utilized for waste facility differential for Site C for road establishment vehicles in which case the upgrade of the must be explained as it cannot be “double” R335 – P1958 – P1954 would be

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that of site F if the proposed route as shown approximately twice the cost of upgrading the in Figure 13.4 (Annexure 1) is utilised. The existing haul road. Safety issues around the safety risks of additional vehicles on future use of the existing haul road raised by Colin haul roads (North West of the landfill site) Jones in PPC’s previous submission led to the are higher than that at Site C due to the recommendation that the R335 – P1958 – increased volumes on the roads. Further P1954 access route be utilized instead. As additional haulage distances (and cost) such the costs would now be similar as would be incurred by PPC due to the need Footprint C would also have to use this access to circumvent the proposed hazardous route, however, Footprint C remains more waste site. These important factors are not expensive (albeit marginally) due to the extra discussed in the site selection section of the couple of kilometers of bitumen standard road report. required. I must reiterate that the R335 – P1958 – P1954 access route is a public (provincial) road and will not therefore impinge on additional vehicle movements in this area. The same applies to the short length of road immediately north of the existing haul road (just south of the R335 marker on the image below) that as the EAP understands is a provincial road as well. It further understood that this gate/access to this road portion has been secured and access thereto controlled by PPC with provincial road authority permission.

11.3 Seismic testing: No seismic testing has 09/06/2010 Urishanie Govender As requested we have considered the issue of been undertaken to establish the potential email PPC seismicity and the affect that blasting in close risks to the proposed landfill site. The proximity to the facility could have. Our reserves to the east of site F at a distance comments are as follows: of ± 900m and the reserve to the west of the proposed site of <50m will require 1. According to PPC they have minable blasting due to the hard nature of the calcrete reserves within 50m and to the

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calcrete. Seismic tests will have to be done west of the proposed facility. to establish any risks to the integrity of the 2. The calcrete occurs as a surface or near- proposed landfill on site F site prior to the surface deposit of limited depth, confirmation of site selection. Please note overlying weathered sedimentary rocks. that Mr Erasmus is a land owner in the area The calcrete is hard and would require and does not represent PPC. He is a blasting to be able to excavate contractor on site with no knowledge of our economically. future activities. His assessment on the 3. A portion of the proposed site layout is mining induced seismicity is therefore his located on a remnant of the calcrete personal view with no scientific basis and deposit as it pinches out in the valley not that of PPC. within which the site will be developed. The facility will be developed in a phased PPC understands that the process for site manner and the initial cells, which are establishment is in the region of 10 years. estimated to have a 10 year life, are not Please note that PPC has existing reserves underlain by calcrete. in close proximity (< 50 m) to Site F and a 4. The potential for blasting to cause date sooner than 12 years will impact damage to existing infrastructure, such negatively on the PPC operations. as dams or plastic lined facilities or cause instability of a waste pile is dependent on a number of factors; including the following: • Geology; in this instance it can be expected that seismic shocks will be transmitted laterally through the hard calcrete layer • Blasting methodology; The magnitude of seismic shock that can be transmitted through the calcrete will depend on the blast charge per delay; this is something that can be controlled to reduce the risk of damage to

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adjacent facilities. In addition the blasting methodology can be designed in such a way that an initial void is created through controlled blasting and excavation; subsequent blasts then displaces material into the voided area with limited seismic shock being transmitted. • Proximity; obviously the closer the blasting to existing facilities the greater the potential for damage. • The nature of the facility under threat; the more flexible the nature of the facility the less the risk of damage. Waste facilities which incorporate plastic liners and clay liners are designed to be relatively flexible and, in our opinion the risk of loss of integrity due to seismic activity is low. The stability of the waste pile however needs to be considered. Should the waste pile have a relatively steep outer slope and a high phreatic surface (ie. elevated liquid level in the waste), the stability of the waste pile could be of concern during a seismic event.

5. The overall risk of blasting to the facility can be quantified through a technical study and appropriate measures designed to prevent damage or

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instability. However in our opinion this is not required at this point for the following reasons. • As part of the design, storm water cut- off trenches have been included to divert storm water past the western and eastern part of the landfill. If required, these trenches can be excavated through the relatively thin calcrete, thereby creating an effective “void” that will prevent the transmission of seismic shocks into the landfill • Due to their flexible nature, landfill linings are not sensitive to seismicity • The stability of the landfill can be improved in a potentially affected area by simply flattening the outer slope from (say) 1 in 3 to 1 in 4. • The timing is such that the part of the landfill that could potentially be affected by blasting will only be in use in 20 years or more. By that time mining activities in the area may have been concluded, in which case it is no longer an issue.

6. If blasting is carried out close to the site there is a danger of damage to infrastructure or people due to fly rock. Coordination and planning will be

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required to manage this aspect.

In conclusion, it is our opinion that although blasting close to the waste facility could pose a risk, we believe that the risk can be adequately addressed by the construction of cut-off trenches and localized flattening of slopes. The issue of fly rock can be managed through coordination and proper management of the blasting operation.

As the site may only be developed once mining operations have been concluded, we believe that no additional study work should be carried out at this stage. It would be premature to design detail control measures (if required) at this stage.

WRITTEN COMMNENTS RECIEVED ON THE PROJECT (EMAILS, LETTERS AND COMMENT FORMS RECEIVED)

From: Morgan Griffiths [[email protected]] Sent: 20 December 2007 01:47 PM To: Sandy Wren Subject: Brian Reeves & WESSA

Follow Up Flag: Follow up Flag Status: Flagged

Hi Sandy

Please not that Brian Reeves no longer works for WESSA, but instead SRK; and can be removed from your mailing lists, such the Regional H:H wastesite .

Regards

Morgan Griffiths Conservation Officer

Wildlife & Environment Society of South Africa Eastern Province Region 2 b Lawrence Street, Central Hill, 6001 PO Box 12444, Centrahil, 6006 Port Elizabeth, South Africa Tel: +27 (0)41 585 9606/1157 Fax: +27 (0)86 614 9701 E-mail: [email protected]

From: Morgan Griffiths [[email protected]] Sent: 22 February 2009 11:20 AM To: [email protected] Subject: Comments on draft EIReport for the proposed regional GHWMF Attachments: 090222 WESSA Comments on draft EIR.doc

The Managing Directors Sandy & Mazizi Consulting cc PO Box 27688 Greenacres 6057 Tel: 041 374-8426 Fax: 041 373-2002 Email: [email protected]

Dear Mrs Sandy Wren

RE: COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT AND PERMIT APPLICATION REPORTS FOR THE PROPOSED REGIONAL GENERAL AND HAZARDOUS WASTE MANAGEMENT FACILITY Please find attached a letter of comments from WESSA EP Region (the Wildlife and Environment Society of South Africa) on the draft Environmental Impact (dEIR) and Permit Application (PAR) Reports for the proposed Regional General and Hazardous Waste Management Facility.

Thank you for the additional time allowed for submission.

Regards

Morgan Griffiths Conservation Officer

WESSA Wildlife & Environment Society of South Africa Eastern Province Region 2 b Lawrence Street, Central Hill, 6001 PO Box 12444, Centrahil, 6006 Port Elizabeth, South Africa Tel: 041 5859606 Fax: 086 6149701 Cel: 072 4175793 Email: [email protected] **************************************

SUNDAYS RIVER VALLEY COMMUNITY FORUM PO BOX 117 ADDO 6105 COMMENT FORM: DRAFT EIA AND PRELIMINARY PERMIT APPLICATION REPORT: PROPOSED REGIONAL AND HAZARDOUS WASTE DISPOSAL FACILITY – EASTERN CAPE. SENT TO: [email protected]

Thank you for the opportunity of responding to the Draft EIA and preliminary PAR, which were discussed at public meeting held at Sunland on Wednesday 4th February 2009. Herewith are our comments/suggestions. Note that we have no problems with the site itself, and we believe the main issues at this stage relate to operational/management issues of the site, which would be relevant irrespective of which site was chosen.

1. INACCURACIES IN THE REPORTS

The investigation of the waste site is costing the South African taxpayer a huge amount of money. It is expected that the quality of the reports would reflect the considerable amounts of money being paid to the Engineering Consultants. And yet, we find that basic errors are still being made, which effectively casts a shadow on the entire volume, rendering it suspect from an accuracy point of view. For example, • The weather data in the draft EIA, Table 4.1 page 38, is obviously wrong. It implies that Port Elizabeth’s summer temperatures are higher than Addo, and that winter temperatures are lower. (Jones & Wagener PAR page 14 table 2 is correct) • The draft EMP, glossary, page iii, states Contractor: Persons/organizations contracted by the Developer to carry out parts of the work for the proposed pipeline. This clearly

indicates that the EMP has been largely lifted from another study. Hardly encouraging for any I & AP’s, never mind the due diligence required. • On page 43 of the draft EIR, there is a map showing the distance from the site F to the Addo Elephant National Park. This is stated as approximately 30km. Why the distance to the park main camp is important, and not the distance to the nearest conservation area, (about 14km) is a mystery to us. In our last submission, we raised precisely this issue, but no correction was made. Was this in order to mislead anyone not familiar with the area who might review this report? (30 kilometers Sounds a lot better than 14.) • The Map (fig. 1.1) on Page 6 of the introduction has sites E and F reversed. This too was pointed out in the previous feedback to I & AP’s and has also gone uncorrected. • In the brief period allocated to I & AP’s to review these extensive documents, we were able to identify a number of misleading inaccuracies. It is highly probable that these extensive and technical documents contain many more such errors and inaccuracies which need to be corrected by qualified people. Many of these studies are very complex and require specialist knowledge to understand their implications within a development of this nature before being able to determine the veracity of such information. For example the benchmark values for carcinogens in an air pollution study, or what is considered adequate substrate in a geo-hydrological or engineering interpretation. It would be absolute Greek to most lay people, yet it has been expected to date that we the public and the I & AP’s must review and correct these documents. We talk about due diligence often, but this is now bordering on undue negligence.

2. DISREGARDING THE INPUTS OF THE I AND AP’S

Our previous submission, dated 5th November 2007, as reflected in the final feasibility report as well as other comments and suggestions from other I and AP’s, listed a number of suggestions which we believed were critical to the further development of the project. We were astonished to find that NOT ONE of these recommendations had been considered. We were even more astonished to hear that, at the meeting of the 4th February, 2009, when we raised the issues again, there seemed to be acknowledgement from the assembled engineers and consultants that these suggestions seemed to have due merit, and we were asked to resubmit them .

What is happening here…..?

Why are the Engineers and Consultants deaf to the suggestions of the SRVCF and other I & AP’s when we have engaged in constructive dialogue and have made valuable contributions to this project in the past, as acknowledged by the consultants in these reports. Why then is it necessary to threaten, and take these issues to other channels on a higher level before cognizance is taken of them? Why are they so disrespectful of Government legislation, which places high priority on the public process? The two main issues are discussed in more detail in sections 4 and 5 of this letter.

3. INCINERATOR (Thermal treatment)

The community has always been vehemently opposed to the establishment of an incinerator on this site. This is on record and acknowledged as such by Dr Angus Patterson when he assured this community that an incinerator will not be established. On page 3 of the draft EIR, it states that the landfill …”could, in future, include a combination of the following, A thermal treatment facility for high hazard organic waste, and possibly difficult wastes such as abattoir waste….. It is important to note that the current design does not include certain of the above mentioned future options.” It was with the assurance of the project consultants that there would never be an incinerator at this facility, that we as a community accepted the possibility of a waste site within our region. All subsequent agreements and understandings between this community and the successful

undertaking and implementation of this project are subject to this condition being complied with, now and in the future.

4. FOOTPRINT OF THE SITE

From the outset of the discussions about the waste site, it was always understood that this would be a world class hazardous waste site, with minimal impact on the local community. It is pleasing to note in the PAR, Waste Management Philosophy Report, page 21, ‘The proposed Grassridge waste disposal facility should be operated to the highest national and international waste management standards. The objective for the operation for the Grassridge waste disposal facility will be to ensure that the waste is managed in an environmentally and socially acceptable manner.’ The reality of waste site management, especially in the NMMM area, leaves a lot to be desired. Access roads are littered with waste, trucks carry loads without covers, fallen waste is never picked up. Trucks simply dump their loads on the side of the road or in a nearby side road if they cannot enter a waste site. Monitoring and punitive measures against transgressing operators are obviously not carried out. The entire waste management sector, including engineers, site operators and owners are in a state of collective denial about the waste process. It is as if waste is produced at a factory, and then magically appears at the waste disposal site, without any impact or potential impact on the entire transport corridor. This denial runs like a fault line throughout the study – the PAR, SIA, EMP and EIR all ignore it, in spite of our highlighting the problem in our previous submission, and in spite of the engineers and operators own experience of the state of access roads around waste sites countrywide. The first step in the addressing of this problem is to redefine the site footprint to include all access roads leading to the Grassridge site. This would include the R335 from Motherwell to the site, as well as the R75 from Uitenhage to the site. Thereafter all the above reports, plans and assessments (eg SIA risk assessment) will need to be reevaluated in terms of the actual (extended) footprints. This will impact on visual aspects, tourism and many other facets of the studies and reports already submitted and approved. In addition, a Transport Risk Assessment (TRA) for all products that may be transported along the transport corridors to this facility needs to be undertaken. This T RA will need to consider a) the elevated risk to export fruit and other food travelling through the same corridor to the harbor and local consumers and b) the effects on tourists and tourism. These two aspects need to be evaluated in terms of both upgrading theR335 as well as not upgrading the road.

5. UPGRADING OF THE R335

There is a crisis looming in terms of commissioning the site before the Aloes site is full. The key elements shaping this crisis are: - The R335 road to Addo is collapsing, and in the opinion of the Consulting Engineers, will not be able to handle any extra traffic brought on by the Waste site - Aloes 2 is almost full. An extension is being applied for, which could or might extend its life to 2014. Coincidentally the same time as Grassridge is to be commissioned….coincidence or not since the Aloes II site extension is yet to be approved. - It will take 2 years to complete the design of the facility and screen a suitable potential operator for this waste site, and a minimum of another 2 years to build, and get ready for accepting waste. (Danie Brink quoted from meeting on 4th Feb. 2009) - Coega is coming on stream, and businesses there are beginning to generate waste. - Money for the upgrading of the R335 has been diverted to 2010 projects, and construction, which should have started in June 2008, has now been put off ‘for 5 years’ - The rebuilding of the road, which has been designed, will take 2 years. - During road-building, the R335 will be closed completely between Motherwell and Addo. This is the main access road for waste from Coega/PE to the Grassridge site.

Clearly, there is an urgent need for strategic intervention in this matter by CDC and NMMM, to access funds for the project from Province. In order for a crisis to be averted, the road reconstruction needs to start by 2010 at the latest. 6. CONCLUSION

This community will strongly oppose any development on this site until such time as the following issues have been dealt with satisfactorily: • The possibility of a thermal processing treatment plant/incinerator is removed permanently from the proposal.

• Road reconstruction has been completed to a point where it can accommodate the additional traffic.

• The footprint is extended to include the access roads that feed the site, and management/operational plans have been comprehensively revised to include the monitoring and cleaning of these roads.

• The PAR, SIA, EMP and the EIR reports be rejected until they have been amended to include the increased footprint.

• A Transport Risk Assessment be undertaken to study the risk to tourists, export and local food by transporting waste under conditions of a) no road improvement and b) rebuilt roads.

As we have stated before, we once again offer our time and effort to resolve these issues in the interests of the Sundays River Community. Yours sincerely,

SRVCF Executive Committee

NOTES FROM PUBLIC MEETINGS

3 February 2009, Edward Hotel

Greg Paterson The original date for the closure of Aloes Facility was 2010, this has now increased by a year and potentially an additional 5 years according to the EIA that is currently underway, why has this timeframe shifted? A municipal site would level out the playing field, will this project go out to tender?

Sue Hoffman I have identified a fatal flaw in this process, in 2007 at the Public Meeting I requested specialists to contact me with regards to historical data on air quality and health impacts related to the Aloes Facility and no specialists have contacted me to date. I am still available to provide this information and request that a specialist on this project come and talk to me and view the documentation available. The Draft EIA Report states that air quality impacts will be of minimal significance and that it is probably unlikely it will have a negative impact on the citrus industry in Addo. The data I have indicates that hydrogen sulphide can be detected up to 142km away from the facility. Regular audits of the facility are important as people at Motherwell are directly affected by the current facility at Aloes.

Ivan Cornelius I live in Schauderville where there is a crèche and a municipal swimming pool, a nearby board clearly states that there is no “dumping” of refuse allowed but people continue to dispose of their refuse at these sites. The current bins are abused or stolen, and large Wastetech Type bins would be more suitable in this area. Further there is a storm water system drain nearby which overflows after heavy rains, it is important that the new facility is properly designed so that storm water does not overflow. In what condition is the site now and how will it be rehabilitated in future? How will you keep people off the site, people are attracted to these sites as they come looking for food and valuables?

Andre Goosen Hazardous waste is a purified chemical, often variable, depending on where it is generated in the city. Hazardous waste should ideally go back to the source for recycling. Air pollution should never happen, however to achieve this appropriate technology will have to used and the facility will have to be managed by specialists. The facility will have to be run by experts in hazardous waste management.

John Sayster What has happened about the rezoning of the land and what is the timeframe for the proposed rezoning? Stormwater on site must be carefully managed and planned to avoid health risks. What can be done to assist the local authority to improve waste management in the Metro?

Primrose Madikizela If the perceptions of tourists are affected by the location of the facility then the monitoring programme should include the monitoring of the perceptions of tourists.

How do you implement the buffer surrounding the site? I understand the site has been identified as it is far away from people but how will you stop people coming to the site and settling around the site? This quite often happens when people are looking for employment and construction commences. What disposal options are envisaged for waste streams that will be excluded from the site e.g. slags.

Bernard Venter We have a few concerns regarding the EIA which we will forward through to the consultants. We are having a general meeting on the 12th following which we will provide input.

Goodman Prince Recycling should take place at the landfill and the community should be able to benefit from this. What are the rehabilitation options for the site? The metro has historically placed residential development on old dump sites. This could constitute a health risk. What are the long term plans for community engagement to ensure appropriate waste management and sustainable development?

Andrea Von Holdt Where will the clay for the liner for the facility come from, is there enough on site to be used as a cover material as well? What is the long term plan to ensure that this is a sustainable project?

Margaret Galela One of the sites proposed was near Amanzi, is this option still a consideration?

Public Meeting Notes

4 February 2009, Sunlands

Chris Morley The report indicates 6000 tons per month of waste will be transported to the facility, how many vehicles per day does this equate to? The site is 20km’s from Addo’s main gate, but it is closer to the actual boundary of the park, how has this been taken into account in the assessment process? The project is proposed to operate in four phases, how is each phase integrated so that it does not result in leaks in the liner for the facility when you move between phases? How will the facility NOT be visible from the Addo Road? We object to the inclusion of any types of incineration at the facility.

Paul Hansen The image on page 43 of the report is incorrect and should be removed from the report, this was raised at the last meeting but has still not been affected in the report. All references in the Draft EIA Report to the distance between the facility and the Addo Park must be checked as they are incorrect; the boundary of the park is closer to the facility than indicated in the report. The report states that there is the potential for thermal treatment at the facility in future, this is incineration. We have been previously reassured and it has previously been stated that there will be no incineration. If incineration does take place we will oppose the project, we have stated this from the beginning of the

process. The project will not proceed if it includes thermal treatment at any stage. Once the facility is there you may be forced to accept a thermal treatment/incineration component at a later stage if it is applied for. It has been the view of the Sundays River Valley Community Form from the beginning that incineration will not be acceptable. One of the conditions of the smelter ROD was that they must have access to a waste facility, yet it is the Addo community that will have the facility on their door step. The site is far from where the waste will be generated which will make it costly to dispose of the waste at the site, people may just dispose of their waste on-route to reduce their costs. The weather data on page 38 of the Draft EIA report is incorrect. There are a number of additional inaccuracies in the Draft EIA report, which casts a shadow on what is contained in the rest of the report. We have raised these matters before, but nothing has been done, the same inaccuracies appear in the report. The errors we are picking up are related to things we can understand, what about the more specialist reports where we don’t have the knowledge to pick up any inaccuracies. This information is being used to make judgements but the information is incorrect and false.

Eric Holmden Will there be any incineration at the facility?

Keith Finnemore The report indicates on a map the extent of the facility. Our experience has shown that with the transportation of waste, there can be all kinds of spills and/or accidents. Thus the extent of the facility and the impacts it will have are not just confined to the facility but extend for the entire transportation corridor. Thus the map for the facility should be amended to reflect that the facility includes its transportation corridors. This should be carried through the report; monitoring and management of the facility as well as the assessment of impacts should include the access roads to the facility. This is an international trend yet the Draft EIA does not look at the impacts of the transport corridors, the management or monitoring of such impacts. All access roads leading to and that will be used by the facility should be included in the assessment process. What happens on these roads affects Tourism and the citrus industry. This road is used by trucks transporting fruit to the PE harbour for exports, all you need is one accidental spill of waste on the road accompanied by rain, which could result in contaminated rain water landing up on fruit for international export. If this contaminated fruit landed up in the international market/stores it would be a disaster for the local citrus industry. The assessment process must therefore assess and identify impacts on the transport routes as well as include management and monitoring mechanisms for these routes. The R335 has collapsed, Province has committed to building it in 5 years, the design and construction plan is for the road is finished and will entail closing the road for 2 years. This directly impacts on your timeframe for construction of the facility. The R335 is fundamental to the facility and must be built before construction on the facility takes place, what can be done about this? This is supposed to be the forum where we raise issues and they are addressed by this is not happening. If the site is going to impact on Rooidam we don’t want a disaster situation because monitoring and auditing does not extend to this area.

Muffy Miller The R335 is a lifeline for the people of Addo, this road is used by the people of Addo to access facilities available in the Metro which are not available in Addo for example, hospitals and schools. The impact of the facility on this road must form part of the assessment process.

Sigi Bailles The monitoring of the facility does not include the transportation network but only the site, the monitoring needs to be extended to include the transportation network.

Dieter van der Merwe Will the waste be transported in open or closed bins to the site?

Andrea von Holdt The report states that there will be no “people” access to the site after rehabilitation; this implies that the site presents a hazard after closure, will it present such a hazard?

NETWORKING MEETING CONSULTATION NOTES

REGIONAL WASTE SITE

JANUARY TO FEBRUARY 2009

Morgan Griffiths, Wildlife and Environment Society 10 February 2009

• Will there be incineration on site, the incinerator in East London became inoperable. • Will there be concrete encapsulation as a component of the facility, if so, where will this be? You need to avoid lateral movement which could impact on the lining of the facility. • WESSA is comfortable with the process that has been followed, it is a good example of how the process and public participation should work. • You cannot rely on management alone to get things right once they have gone wrong, so it is really important that this site is constructed correctly from the outset.

Swartkops Trust, 19 February 2009

Linda Redfurn • Will the facility be closed to the public? If it is this will assist with conservation in the general area.

Mike Spearpoint • A search and rescue effort for the Albany Adder must be made prior to construction commencing. • There should be a vegetation barrier to screen the site off visually.

Nadia Wessels • Who is responsible for monitoring the facility? • A traffic impact assessment must be done for the entire route.

Dave Hayes • How is the liner fixed if there is a break in the liner?

Mike Spearpoint • Does the upgrading of the Addo Road and its associated stormwater infrastructure incorporate into its design an accident and hazardous spill on this road? It is recommended that the design of the road include catchpits which capture the spill, especially where there are culverts. • Who will be responsible for a clean up if there is an accident or spill? • It is recommended that trucks travelling to the facility are confined to a specific route and that transport of hazardous waste through residential areas is avoided.

18 February 2009 Cllr Mafana, Ward 60 NMBM

• How long will construction of the site take? • What is the life span of the site?

20 February 2009 Nomathamsanqua, Addo Alliance Structures

Cllr Tambo • Will the site accommodate domestic waste? • How will you monitor scavenging on the site?

Thulani Grootboom • Will the site have incinerators? • How will you monitor the impact on air quality, especially odours. • Will there be any dangerous chemicals on site that could impact on communities? • Is it possible to spills from vehicles transporting was could be experienced? • The monitoring on this facility must be strictly controlled. • How long will the process take from this phase? • The R335 needs to be upgraded to meet the demand for this project.

10 March 2009 Cllr Vusani, Ward 53 NMBM

• There is a need to encourage recycling opportunities for the community. Are there any communities on site? • Is the land owner willing to sell the property?

10 March 2009 Cllr Frans, Motherwell Councillors Forum

• Opportunities for recycling should be encouraged. • Who will operate the facility and when is the facility expected to commence operation?

19 February 2009 Zukile Jodwana, SACP

Is the land owner prepared to sell the land that has been identified? There is a need to develop an environmental awareness programmes on the use of the facility.

09 February 2009 Mike Bonya

An awareness campaign for residents in close proximity to the facility must be developed and implemented. Will the transportation of general waste to the facility in future result in rate payers paying more? Is there a mechanism to double check the type of waste transported to and received at the site for disposal? This will help in identifying medical waste and ensuring that it is not accepted at the facility? How will SANCO get involved on the monitoring of the facility and will there be a monitoring office?

Sundays River Valley Municipality 24 February 2009

Kelello Makgoka We appreciate this process and the thorough consultation and studies that have been conducted in identifying a suitable site. We are happy with the extensive studies that have been done and support the project. Where is the exact location of the site? What type of hazardous waste will the site accommodate and will medical waste be accepted at the site? Is there a limit on the amount of waste that will be accepted? Are there measures to manage and monitor animals that scavenge on the site such as birds? Will the trucks transporting waste be sealed to avoid spillages? What type of trucks will be used to transport waste? Is the R335 road in a condition to accommodate trucks for such a facility? A community awareness programme around this facility must be implemented.

Rudi Herholdt The use of a Waste Management Plan to reduce the amount of waste produced must be encouraged as well as recycling of waste to create more jobs, this will also result in less waste being transported and reduced transport costs.

Mthetheleli Nkohla

Were there any other issues, other than biodiversity that were used to identify this site? What are the economic benefits of this project to the Sundays River Valley Municipality? Will the project impact negatively on the economy of the Sundays River Valley Municipality in future? As the site is in close proximity to the Sundays River Valley Municipality how will it benefit in terms of jobs and preference given to local communities? There is need for a strict monitoring strategy of the site to ensure that underground water is protected. Rehabilitation and monitoring of the site is encouraged.

CV Mata There is a need to train locals as this project will require skilled people to operate the facility. Is there an emergency plan to manage any unexpected activity that was never envisaged or identified in the studies? Who will be responsible for emergency plans and monitoring of the facility?

09 March 2009 L Suka

Are there any communities that live on this site? Is there a plan to upgrade the Addo road? Are there any endangered species on the site? The ANC executive will look at the report and make further comments.

Copies of Registration Forms from Meetings held

Letter 13: Notification of the comment period and public meeting

Comment form

Copies of Registration Forms from Meetings held

Notes from Meetings held during the Review of the Revised Draft EIA

Notes from Strategically Targeted Consultations

15 April 2010 COPE Metro Region

Mlamli Tsotsi

We appreciate and welcome the presentation. Cope will discuss the report and make a submission. This information has empowered us to have an understanding of the type of facility that will be developed. Who will be operating the facility?

21 April 2010 Motherwell Councillor’s Forum Member and Community Based Structures

Cllr. Vusani, Ward 53

How many permanent jobs will be created by the development? Will there be opportunities to train people on the running of the facility as it requires trained personnel to operate the facility.

Nosipho Mtili, ANCYL Motherwell There is a need for firm monitoring to prevent scavengers entering the site illegally. Ensure that there will be no outbreak of diseases in future as a result of this facility.

26 April 2010 Sunday’s River Valley Municipality

Kelello Makqoka, Environmental Health Practitioner Strict monitoring measures to protect and prevent leaks that would destroy underground water. Will the road be able to carry the heavy duty trucks? What are the economic benefits for the Sunday’s River Valley Municipality from this development? Who will be monitoring the facility as this requires a strict monitoring and compliance strategy? There must be the enforcement of law in the running of the facility. We encourage the use of modern technology to minimize risks associated with the facility. Spillages will present a risk to communities and road users. There is a need to provide education and awareness to local communities, on the impact of the facility and why scavengers will not be allowed at the facility. What will be the impact on birds who will be flying in and out of the facility?

Cllr. Tambo We appreciate the upgrading of the road to be able to carry heavy trucks. Strict monitoring during operation is encouraged. How will this facility be monitored?

29 April 2010 SACP Nelson Mandela Region

Zukile Jodwana Will there be an independent monitoring team to monitor the facility in accordance with the conditions of the permit? Community based structures should be trained on the ways and means to evaluate and assess acceptable standards for the running of the facility. Spillages on roads must be monitored and the law enforced for non compliance by companies and the operator. Education and awareness in schools is encouraged as part of a programme to separate waste at source as it will ensure that domestic waste is recycled.

03 May 2010 SANCO Nelson Mandela Region

Ndumiso Peter Will this facility be safe for the wild animals, will it impact on them?

Carol Mkhithi Ensure that the facility is operated by specialized and experienced personnel and minimize future impact on communities.

06 May 2010 ANC Nelson Mandela Region

Stephanie Cemrette The information will be presented to the ANC Regional secretary. The project information is welcomed and appreciated.

07 May 2010 Motherwell Councillor’s Forum Chairperson

Cllr. Mafana

We encourage job creation. There is a need for constant monitoring and feedback to communities during operation.

PUBLIC MEETING NOTES 20 APRIL 2010

Paul Hansen The Draft EIA refers to a lifespan beyond 2016 for the Aloes facility, what does this mean?

Paul Hansen It has been noted that the current upgrading of the R335 is for a period of about 3 years, discussions with the District Roads Agency indicate that the upgrade my only last for 2 years.

It is important to note that fruit from the Sundays River Valley is no longer transported via train to Port Elizabeth, the primary mode of transport is therefore the Addo road. According to Provincial Roads the plans and designs for the upgrade of the Addo road are complete and have been complete for some time, what is lacking is funding for the upgrade. The upgrading of the R335 must be included as a condition of the environmental authorisation and indicate that the waste site cannot commence operation until the R335 is upgraded. The monitoring of access roads to the site must also form part of the environmental monitoring and management of the site, not just the site itself. Our concern is not only around a spill scenario but illegal and indiscriminate disposal of waste on the route to the waste facility.

Charles Marias The illegal disposal of waste is important to manage and monitor from a tourism point of view, especially with estimates of a truck every minute on the road, this increases the possibility for a spill or illegal disposal of waste. This area is currently one of the major national tourism destinations in SA which currently enjoys approximately 95% occupancy, the area is currently clean and free of waste.

Keith Finnemore Page 27 of the report states that access roads to the site are not included as part of the site. Access roads to the facility should be included in the environmental management plan for the facility, this should include monitoring of the route by the operator, regular clean ups, corrective action and penalties for illegal disposal.

Charles Marais In the event of an incident of spontaneous combustion, is this addressed in the report? The prevailing winds are south towards Addo which is our major concern, we are not as concerned about spill from runoff from the site as it will not impact on the Sundays River Valley.

Paul Hansen What we have is a plan for a process that will take place in the future, once there is a more detailed plan in place we would want access to that plan.

Keith Finnemore Will anyone be allowed access to the facility or will it only be for authorised companies? It must be noted that the facility in principle will be open to the Sundays River Valley but as far as we are aware there are no authorised companies in the valley that can collect and dispose of waste. The situation that could result is that waste would be collected and transported to the facility only to be turned away, and this is where the illegal disposal of waste will come from. It will be easier to dispose of the waste on the road side, than transport it all the way back to the valley.

Paul Hanson The Sundays River Valley would become a legal operator and transport waste to the facility. The NMBM is also responsible for the facility as well as monitoring of the facility and in essence will then be monitoring itself, which could be a conflict of interests. The community needs to have legal assurance that the facility and access to the facility will be monitored. We need to understand the way forward from here, will all the issues raised form part of the environmental authorisation.

Greg Paterson Are you aware on any interaction between the CDC, NMBM and the EL municipality regarding the development of mechanisms to reduce the amount of waste coming into PE? There is currently a H:h waste site that is being haphazardly managed.

Greg Paterson What is the lifespan of the proposed site?

Bernard Venter What is the timeline for the proposed Aloes facility, for how much longer will it be operating? PPC have sent a letter as part of this process, will you reply to us in writing?

Keith Finnemore The GPS points on page 10 and 11 of the report, at the bottom of the page are possibly incorrect.

Copies of Comments Received during the review of the Revised Draft EIA and PAR

18 May 2010 Public Process Consultants PO Box 27688 Greenacres 6057 Tel: 041 374-8426 Fax: 041 373-2002 Email: [email protected]

Dear Mrs Sandy Wren

COMMENTS ON THE REVISED DRAFT ENVIRONMENTAL IMPACT AND DRAFT ENVIRONMENTAL MANAGEMENT PLAN EASTERN PROVINCE FOR THE PROPOSED REGIONAL GENERAL AND HAZARDOUS REGION 2(b) Lawrence Street WASTE MANAGEMENT FACILITY IN THE EASTERN CAPE Central Hill Many thanks for providing the WESSA Eastern Province Region with Port Elizabeth, 6001 a hardcopy of the revised draft Environmental Impact (rdEIR), draft PO Box 12444 Environmental Management Plan (dEMP) and draft Permit Centrahil, 6006 Application (dPAR) Reports for the proposed Regional General and www.wessa.org.za Hazardous Waste Management Facility (the GHWMF). We remain Tel: (041) 585- highly interested in this proposed GHWMF. 9606/1157 Fax: (041) 586-3228 We are satisfied with the process taken to investigate and prepare these reports, that meets the 1994 Minimum Requirements for Regional Manager: [email protected] Waste Disposal by Landfill and the regulations of the, Environment a Conservation Act (Act 73 of 1989), the National Environmental Management Act (Act 107 of 1998) and the NEM: Waste Conservation: Management Act (Act 59 of 2008). We are currently satisfied with [email protected] the public participation and community engagement processes for Environmental Education: this GHWMF. [email protected]

WESSA EP concurs with the findings of the rdEIR that Footprint F Administration: [email protected] would appear most appropriate for siting the GHWMF. We confirm this decision based on our reasons highlighted in our letter to you dated 22 February 2009. We raised a number of concerns in this letter, which appear to have been addressed in the rdEIR. We submit a few comments and offer some suggestions below:

Fire Risks – a recent spontaneous combustion episode at the Aloes (II) wastesite has highlighted the need to have adequate on-site fire-fighting equipment, staff training, emergency plans and municipal fire-fighting support. Fencing – the proposed 1.8m high fence is inadequate, as proved by the on-going incidents of scrap-metal scavengers breaking onto the Aloes II H:H wastesite. Additional height and other security measures will be needed.

Traffic impacts – we confirm our call that the site does not become operational until such time as the R335 has been upgraded and the relevant sections of the P1954 – P1958 – MR00470 roads have been tarred to minimise dust generation. Reg No. 1933/004658/08 (Incorporated Association not for gain) A major concern to us is the event of a vehicle accident resulting in Registration Number in Terms of the a hazardous spill on the R335, R75 or approach roads. The site Non Profit Organisation Act 1997: operator must have a emergency response plan and 000-716NPO containment/clean-up facilities to deal with any spill within a certain Tax Exemption Number: 18/11/13/1903

DIRECTORS Messrs: P Burger, BE Havemann, Prof M Kidd, Dr RG Lewis (Chairman), J Pinnell (National Treasurer), Dr RJ Taylor

reasonable distance of the site (though we recognise that the transporting company is ultimately responsible for the clean-up). The critical issue remains getting the clean-up started as quickly as possible, to limit contamination of the environment.

With regards the potential for illegal dumping along the approach roads, we suggest that the strategic placement of CCTV cameras that feed to the wastesite’s security office could curtail this potential problem. Treatment of H:H wastes – we are relieved that incineration is not part of this application and we fully support the EAP’s recommendation that any positive ROD exclude incineration, as a condition of approval. When the Leachate Treatment Plant is built, it will also need to be bunded. We note that the Leachate dam appears to have an adequately designed liner system; though the climate change trends for this region suggest that this site will need to cater for lower annual rainfall, but for increasing incidents of greater magnitude downpours/flashfloods. The overflow designs of the dams will need to address this, to prevent overtopping and wall collapse Future planning – WESSA reiterates our suggestion that the NMBM consider acquiring or otherwise setting in place landuse restrictions in this area, so that the buffer zone is enforced and that Footprint C can be held in reserve as a future wastesite. Considering the time and resources that have already gone into studying this site, acquiring it for future use could well be cost and time effective. Waste Management – we refer to the Nelson Mandela Bay Municipality’s Integrated Waste Management Plan, and encourage the NMBM enforce its waste strategies by requiring residential, commercial, industrial and agricultural waste producers to re-use, reduce and recycle their wastes, and thereby limit wastes to landfill and conserve energy and resources. Recommendations for Conditions of Approval – we support the suggested conditions for inclusion into any positive ROD.

WESSA-EP remains committed to contributing positively to this EIA process and trusts that our comments will be seen as constructive in ensuring the most appropriate site selection and long-term environmental management of this proposed Wastesite.

Yours faithfully

Morgan Griffiths Senior Conservation Officer Cellphone: 072 417-5793

From: Ken & Jen Munro [[email protected]] Sent: 22 April 2010 08:44 PM To: [email protected] Subject: Change of address

Hello Sandy,

I have changed my address and would like you to amend your records.

Ken Munro, BirdLife Eastern Cape. 117 Cassia gardens, Cassia Drive, Sunridge Park 6045.

Many thanks for your regular communications.

Kind regards

Ken Munro

From: Kobus Buys [[email protected]] Sent: 19 April 2010 02:18 PM To: 'Sandy Wren' Subject: RE: REgional Waste Site Report

Thanks Sandy Best regards Kobus

From: Sandy Wren [mailto:[email protected]] Sent: 19 April 2010 12:44 PM To: [email protected] Subject: REgional Waste Site Report

All reports are available on the following website www.bohlweki.co.za

Sandy Wren Public Process Consultants PO Box 27688, Greenacres, 6057 120 Diaz Road, Adcockvale, PE, 6001 Phone: 041 374 8426 Fax: 041 373 2002 Cell: 082 4909 828 www.publicprocess.co.za

Coega Development Corporation Comments Form for Issues COMMENT FORM: REVISED DRAFT EIA AND EMP, INCLUDING THE PERMIT APPLICATION REPORT Applicant: Coega Development Corporation Project: Proposed Regional General and Hazardous Waste Disposal Facility, Eastern Cape Province Please fill in your contact details:

Your name: Lemercier Pierre-Louis Your organisation (if applicable): Renewable Energy Centre Full Postal address: Po box 6205 1200 Walmer Tel. No.: 041 3671149 Cell. No.: 076 190 6384

Please complete the form and return by post or fax, or email your comments to: RETURN BY 9 MAY 2010 TO: PO Box 27688, Greenacres 6057 Phone: 041 – 374 8426 or Fax 041-373 2002 or Email [email protected]

Do you have any issues or comments that you would like to raise in connection with this project? Please outline the nature of your comment clearly. (Use the back of this form if necessary)

As “the National Environmental Management Act No. 107 of 1998 (NEMA) builds on the Environment Conservation Act and provides a link between new developments and environmental protection. One of the main principles proposed in NEMA is that of Integrated Waste Management (IWM) which promotes the avoidance, minimisation, recycling and treatment of waste in preference to its disposal to landfill,” it is quite clear that a priority, before working on a land field is to set a comprehencive recycling system.

Where is the latter ? How can we then assess the remaining quantities and types of wastes which are still to be disposed in a dumpsite ?

Investing in a waste dump and related IEA before working on a recycling system could therefore be construed as unlawful .

Moreover, one could also question COEGA understanding of recycling necessities, advantages and its interest thereof.

This is also surprising for a corporate which claims that it complies with the ISO14,000 guidelines in all its endeaviours

It is worrying that a well known company such as Bohlweki-SSI which works on Environmental issues and has reported on the above piece of legislation has even not mentioned this problem in its report.

What is the opinion of our waste management authorities, which are responsible of enforcing the law, on the matter ?

Regards

PL

From: Sandy Wren [[email protected]] Sent: 12 April 2010 04:24 PM To: '[email protected]' Cc: '[email protected]'; '[email protected]'; '[email protected]' Subject: RE: Proposed regional general & hazardous waste disposal facility, EC Province, revised draft EIA report & EMP, including permit application report for public comment

Rico

The documents are quite large to email but all the reports can be downloaded from the project website www.bohlweki.co.za

This EIA process was initiated approximately 10 years ago, in 2000, and has thus come a long way. The first section of the Revised Draft EIA Report includes an executive summary which will provide you with an overview of the various stages that have been followed in the process.

I will make an inquiry with the project applicants regarding emailing the presentation, as this is public information and summarises the process I doubt

there will be a problem with this. However, please note that there is not a narrative that accompanies the presentation, there will however be notes taken at the meeting regarding comments received and these will be included in the Final EIA.

Please don’t hesitate to contact me should you require any additional information.

Regards

Sandy Wren Public Process Consultants PO Box 27688, Greenacres, 6057 120 Diaz Road, Adcockvale, PE, 6001 Phone: 041 374 8426 Fax: 041 373 2002 Cell: 082 4909 828 www.publicprocess.co.za

From: Rico Euripidou [mailto:[email protected]] Sent: 12 April 2010 04:16 PM To: [email protected] Cc: [email protected]; [email protected]; [email protected] Subject: Proposed regional general & hazardous waste disposal facility, EC Province, revised draft EIA report & EMP, including permit application report for public comment Importance: High

Dear Sandy Wren & Mazizi Msutu,

RE: Proposed regional general & hazardous waste disposal facility, EC Province, revised draft EIA report & EMP, including permit application report for public comment

Please register groundWork as an I&AP for this process and email us a copy of all the relevant documents for this process.

Also please indicate exactly where in the EIA stage this proposal is.

It would also be very difficult for us (logistically) to attend the public meeting and I would tyhus be very grateful if you emailed the presentations along with a copy of the narrative and we will then also provide comments and feedback in this regard.

Rico Euripidou groundWork- Friends of the Earth SA Tel: +27 (0) 33 3425662 Fax: +27 (0) 33 3425665 PO BOX 2375,Pietermaritzburg, 3200 www.groundwork.org.za

Sundays River Valley Community Forum Addo 9th May 2010

COMMENTS ON THE PROPOSED REGIONAL GENERAL AND HAZARDOUS WASTE DISPOSAL FACILITY - REVISED DRAFT EIA, EMP AND PERMIT APPLICATION REPORT

Thank you for the opportunity to attend the public meeting held at Sunland on the 20th April 2010. Our comments are as follows: 1. We support the following statements made in the reports, and expect to see them in the Record of Decision: a. There will be no incinerator for the life of the facility. b. The R335 will be rebuilt to the agreed standards BEFORE the site becomes operational 2. As mentioned in the meeting, we are extremely concerned that our highlighting of the errant waste issue has not been adequately addressed. We have pointed out that the generation of errant waste from uncovered trucks, or illegal dumping by members of the public happens to a great extent near all waste sites. Municipalities, and in particular the NMBM are extremely inefficient in preventing or cleaning up this errant waste. As a community we cannot accept that the R335, which is the main tourist road in the Eastern Cape, will end up being littered, and threatening the tourist and farming industries in the area. In order for us to have some comfort in this matter, we would like the following to be addressed in the Record of Decision: • The R335 will be recognised as an important tourist and export food produce route. An errant waste monitoring and collection system will be established to mitigate this problem. • The responsibility for implementing such system shall be the operator of the hazardous waste site (ie not the Municipality).

As the SRVCF, we would like to thank all those who participated in the process. It was a long and often hard road, but in the end, we believe, the correct decisions were made.

Sundays River Valley Community Forum.

APPENDIX E: Geological and Geohydrological Assessment

APPENDIX F: Letter from Grant Thornton

APPENDIX G: Air Quality Assessment

APPENDIX H: Comments from the South Africa Heritage Resources Agency (SAHRA)

APPENDIX I: Social Impact Assessment

APPENDIX L: Draft Environmental Management Plan

Draft Environmental Impact Report for the Proposed Regional General and Hazardous Waste Management Facility in the Eastern Cape

DRAFT ENVIRONMENTAL MANAGEMENT PLAN FOR THE PROPOSED REGIONAL GENERAL AND HAZARDOUS WASTE MANAGEMENT FACILITY IN THE EASTERN CAPE

DWEA REFERENCE NO: 12/12/20/445

June 2010

Bohlweki-SSI Environmental clxvii January 2009 Draft Environmental Management Plan for the Proposed Regional General and Hazardous Waste Management Facility in the Eastern Cape

TABLE OF CONTENTS

Introduction ...... 6 Overview of Proposed Project ...... 6 Expertise of the EAP ...... 8 Applicable documentation ...... 9 Project Responsibilities ...... 10 Project Manager ...... 10 Environmental Control Officer ...... 10 Contractor ...... 11 Environmental Liaison Officer ...... 12 Independent Auditor ...... 15 Objectives of an EMP ...... 16 The EMP seeks to highlight the following: ...... 16 Environmental monitoring ...... 17 Compliance with the EMP and associated documentation ...... 17 Penalties for non-compliance ...... 18 Layout of the EMP ...... 18 Training and Awareness ...... 19 Legislation, Development Strategies and Guidelines ...... 19 Legislation ...... 19 Guidelines and Policy ...... 20 ISO 14000 (EMS System) ...... 20 Environmental Management Plan: Construction Phase ...... 24 Site Clearing ...... 24 Site establishment ...... 24 Environmental Management Plan: Operational Phase ...... 90 Environmental Management Plan: Decommissioning Phase ...... 108

Bohlweki-SSI Environmental i June 2010 Draft Environmental Management Plan for the Proposed Regional General and Hazardous Waste Management Facility in the Eastern Cape

LIST OF TABLES

Table 0-1: Environmental consultants ...... 8 Table 2-1: Responsible Parties and Auditing Process ...... 12 Table 2-2: Environmental Management Responsibilities ...... 13 Table 5-1: Pre-construction Phase ...... 22 Table 6-1: Construction Traffic and Access ...... 25 Table 6-2: Construction Camp ...... 28 Table 6-3: Environmental Education and Training ...... 32 Table 6-4: Borrow Pits ...... 34 Table 6-5: General Construction ...... 36 Table 6-6: Soils and Geology ...... 37 Table 6-7: Erosion Control ...... 42 Table 6-8: Ground and Surface Water Pollution ...... 44 Table 6-9: Hydrology and stormwater ...... 48 Table 6-10: Air Quality ...... 50 Table 6-11: Noise ...... 54 Table 6-12: Flora ...... 57 Table 6-13: Fauna ...... 64 Table 6-14: Employment ...... 66 Table 6-15: Waste Management ...... 67 Table 6-16: Health and Safety ...... 71 Table 6-17: Security ...... 76 Table 6-18: Social Environment ...... 78 Table 6-19: Visual Impact ...... 87 Table 6-20: Cultural and Heritage Artefacts ...... 89 Table 7-1: Construction Site Decommissioning ...... 90 Table 7-2: Surface and Groundwater ...... 93 Table 7-3: Air Quality ...... 96 Table 7-4: Noise ...... 100 Table 7-5: Biodiversity ...... 101 Table 7-6: Waste Management ...... 105 Table 7-7: Health and Safety ...... 106 Table 8-1: Decommissioning mitigation measures ...... 108

APPENDICES

Appendix 1: ISO 14001 Approach to EMP development

Bohlweki-SSI Environmental ii June 2010 Draft Environmental Management Plan for the Proposed Regional General and Hazardous Waste Management Facility in the Eastern Cape

GLOSSARY

Construction Phase: The activities pertaining to the preparation for and the physical construction of the proposed development

Contractor: Persons/organisations contracted by the Developer to carry out parts of the work for the proposed pipeline.

Developer: The Developer is the COEGA DEVELOPMENT CORPORATION/NELSON MANDELA BAY MUNICIPALITY.

Engineer (E) / Project Manager (PM): Person/organisation appointed by the Developer to oversee the work of all consultants, sub-developers, contractors, residents and visitors.

Environment: The environment is defined in terms of the National Environmental Management Act, No 107 of 1998, as the surroundings within which humans exist and that are made up of – the land, water and atmosphere of the earth; micro-organisms, plant and animal life; any part or combination of (i) and (ii) and the interrelationships among and between them; and the physical, chemical, aesthetic and cultural properties and conditions of the foregoing that influence human health and well-being.

Environmental Control Officer (ECO): Person/organisation appointed by the Developer who will provide direction to the Principal Agent concerning the activities within the Construction Zone. The ECO will also be responsible to liaise with the independent auditor who will conduct an environmental audit during the construction phase of the project according to the provisions of the Environmental Management Plan.

Environmental Liaison Officer (ELO): The Environmental Liaison Officer (ELO) will be appointed by the contractor to monitor activities on site on a daily basis. The ELO will be the ECO’s representative on the site and will report back on all audit trips. The ELO must report any major incidents immediately to the ECO

Bohlweki-SSI Environmental iii June 2010 Draft Environmental Management Plan for the Proposed Regional General and Hazardous Waste Management Facility in the Eastern Cape

Independent Auditor: The person or entity who will conduct an environmental audit during the construction phase of the project according to the provisions of the Environmental Management Plan

Environmental Management Plan (EMP): The EMP is a detailed plan for the implementation of the mitigation measures to minimise negative environmental impacts during the life-cycle of a project. The EMP contributes to the preparation of the contract documentation by developing clauses to which the contractor must adhere for the protection of the environment. The EMP specifies how the construction of the project is to be carried out and includes the actions required for the Post-Construction Phase to ensure that all the environmental impacts are managed for the duration of the project’s life-cycle. Therefore the EMP will be a working document, which will be reviewed when necessary, or if required by the authorities. A revision will be done once the detailed design of the proposed GHWMF project has been completed.

Operational Phase (Post Construction): The period following the Construction Phase, during which the proposed development will be operational.

Pre-Construction Phase: The period prior to commencement of the Construction Phase, during which various activities associated with the preparation for the Construction Phase will be undertaken.

Rehabilitation: Rehabilitation is defined as the return of a disturbed area to a state which approximates the state (where possible) which it was before disruption. Rehabilitation for the purposes of this specification is aimed at post-reinstatement re-vegetation of a disturbed area and the insurance of a stable land surface. Re- vegetation should aim to accelerate the natural succession processes so that the plant community develops in the desired way, i.e. promote rapid vegetation establishment.

Site Manager: The person, representing the Contractor, responsible for all the Contractor’s activities on the site including supervision of the construction staff and activities associated with the Construction Phase. The Site Manager will liaise with the Principal Agent in order to ensure that the project is conducted in accordance with the Environmental Management Plan.

Bohlweki-SSI Environmental iv June 2010 Draft Environmental Management Plan for the Proposed Regional General and Hazardous Waste Management Facility in the Eastern Cape

ACRONYMS

DEV Developer DWEA Department of Water and Environmental Affairs ECO Environmental Control Officer EIA Environmental Impact Assessment ELO Environmental Liaison Officer ESS Environmental Scoping Study I&AP’s Interested and Affected Parties MC Main Contractor OHSA Occupational Health and Safety Act, Act 85 of 1993 PM Project Manager SM Site Manager

Bohlweki-SSI Environmental v June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

Introduction

The Coega Development Corporation (CDC) and the Nelson Mandela Bay Municipality (NMBM) have identified the need for the establishment and operation of a new Regional General and Hazardous Waste Management Facility (GHWMF) in the Eastern Cape to serve the Municipality and surrounding areas. General waste generated in the NMBM is presently disposed of at Arlington (G:L: B-) and other general waste disposal sites, while hazardous waste is disposed of at the privately owned Aloes II high hazard (H:H) waste facility or municipally owned Koedoeskloof low hazard (H:h) waste facility. Reliance on EnviroServ’s Aloes II H:H landfill site, whose currently available airspace is expected to be used by mid-2011 (an environmental impact assessment is underway for an extension to the Aloes site and a lease extension from the NMBM has recently been granted). The Koedoeskloof (H:h) waste facility is also limited in the types and volumes of hazardous waste that may be disposed of there.

It is further anticipated that the development of the Coega Industrial Development Zone (IDZ) and associated industries will significantly add to the demand for hazardous waste disposal facilities within the proximity of the NMBM area. Therefore, the proposed Grassridge GHWMF will be a co-disposal site (i.e. it will accept both hazardous and general waste) and is required in order to serve the region, NMBM and the Coega IDZ.

Overview of Proposed Project

The GHWMF site under investigation is situated of the R355 road, approximately halfway between Port Elizabeth and Addo. The site (Grassridge 190 Remainder) is situated on a plateau at an elevation of 170 to 250 mamsl. This plateau forms the watershed between the Sundays River and Coega River catchments and both footprints are within the Coega River catchment. The proposed GHWMF site is located within a fairly flat and wide gulley head which drains in a southerly direction towards a tributary of the Coega River. The site is located within a broad, low slope valley draining in a southerly direction. No perennial rivers or streams drain the area.

A detailed process has been followed throughout the EIA which included thorough consultation with landowners as well as key stakeholders. A number of alternatives were identified during the Scoping Phase of the project which was refined to the preferred site during the EIR Phase of the assessment process. Detailed mitigation measures have been developed for the preferred site based on the various specialist studies that have been conducted for the project. This EMP has been

Bohlweki-SSI Environmental 6 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape compiled to ensure good environmental compliance during the construction of the GHWMF. The EMP will be strictly implemented during the construction phase of the project and will be consulted regularly during the lifespan of the project until decommissioning. The EMP specifies mitigation measures for the following environmental aspects:

Pre-construction Phase • Environmental Management Plan (EMP):

Construction Phase • Site clearing • Site establishment • Construction traffic and access • Construction camps • Erosion control • Groundwater and Surface Water Pollution • Hydrology and Stormwater • Air Pollution • Noise • Flora • Fauna • Employment • Waste Management • Health and Safety • Security • Social Environment • Visual Impact • Cultural and Heritage Artefacts

Operational Phase • Surface and Groundwater • Biodiversity • Air Quality • Noise • Waste Management • Health and Safety • Visual Impact

Decommissioning Phase • Generic Decommissioning mitigation measures

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Expertise of the EAP

Bohlweki SSI–Environmental prepared the Environmental Management Plan together with the EIR Reports. The staff who have worked on this project and contributed to the compilation of this report are included below.

Table 0-1: Environmental consultants

Consultant Field of expertise Mark Freeman Environmental Management Marc Hardy Environmental Management Specialist input into the EMP was received from the following Specialist Sub consultants Airshed Planning Professionals Air quality assessment

Dr William Branch (Bayworld) Assessment of potential impacts on fauna.

Reinhard Meyer (Geotechnical Assessment of geological, hydrological consultant) and geohydrological impacts

Joggie van Staden of Bohlweki – SSI Assessment of potential impacts on Environmental flora

Dr Angus Paterson and Dr Kevin Assessment of all issues related to land Whittington-Jones of Coastal and such as resettlement, land availability Environmental Services. and rezoning, land use and aviation and third party review of project reports Lourens du Plessis of MetroGIS Assessment of all potential visual impacts and compilation of all environmental GIS maps

Danie Brink and Riva Nortje of Jones Assessment of potential geotechnical and Wagener impacts and responsible for preliminary design of the waste facility

Stewart Scott International (SSI) Responsible for the transport study

J. Kaplan of the Agency for Cultural Assessment of potential impacts on Resource Management palaeontological sites and heritage

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impact assessment

Martin Jansen van Vuuren of Grant Assessment of potential impacts on Thornton. tourism

Anita Bron of Master Q Research Responsible for the EIA phase SIA

CV’s of above-mentioned consultants are available on request.

Applicable documentation

The following documents should be read in conjunction with this EMP:

• Draft Environmental Impact Assessment Report for the Proposed Grassridge Regional General and Hazardous Waste Management Facility in the Eastern Cape (Bohlweki-SSI Environmental, 2009) • Draft Permit Application Report by for the Proposed Regional General and Hazardous Waste Management Facility in the Eastern Cape (Jones and Wagener Consulting Engineers, 2009) • Draft Design Report by for the Proposed Regional General and Hazardous Waste Management Facility in the Eastern Cape (Jones and Wagener Consulting Engineers, 2009) • Draft Operating Manual for the Proposed Regional General and Hazardous Waste Management Facility in the Eastern Cape (Jones and Wagener Consulting Engineers, 2009) • Draft Emergency Preparedness Manual and Response Action Plan for the Proposed Regional General and Hazardous Waste Management Facility in the Eastern Cape (Jones and Wagener Consulting Engineers, 2009) • Draft Waste Management Philosophy for the Proposed Regional General and Hazardous Waste Management Facility in the Eastern Cape (Jones and Wagener Consulting Engineers, 2009)

Once/if a Record of Decision (RoD) has been issued by the authorities, the conditions included within the RoD must be included within the EMP.

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Project Responsibilities

Several professionals will form part of the construction team. The most important from an environmental perspective are the Project Manager, the Environmental Control Officer (ECO), the contractor and the developer.

The Project Manager is responsible for the implementation of the EMP on the site during the pre-construction and construction phases of the project.

The ECO is responsible for monitoring the implementation of the EMP during the design, pre-construction and construction phases of the project.

The contractor is responsible for abiding by the mitigation measures of the EMP which are implemented by the Project Manager during the construction phase.

The developer is responsible for the implementation of the EMP during the operational and decommissioning phases of the project. Decommissioning will however entail the appointment of a new professional team and responsibilities will be similar to those during the design, pre-construction and construction phases. It is unlikely that the pipeline will be decommissioned for several years. The existing pipeline has been in use for more than 40 years.

Project Manager

The Project Manager is responsible for overall management of project and EMP implementation. The following tasks will fall within his / her responsibilities:

• Be aware of the findings and conclusions of the Environmental Impact Assessment and the conditions stated within the Record of Decision. • Be familiar with the recommendations and mitigation measures of this EMP, and implement these measures. • Monitor site activities on a daily basis for compliance. • Conduct internal audits of the construction site against the EMP. • Confine the construction site to the demarcated area. • Rectify transgressions through the implementation of corrective action.

Environmental Control Officer

The Environmental Control Officer is responsible for the implementation of the EMP during the construction phase as well as liaison and reporting to the developer,

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Contractor, Landowners and Authorities. The following tasks will fall within his / her responsibilities:

• Be aware of the findings and conclusions of the Environmental Impact Assessment and the conditions stated within the Record of Decision. • Be familiar with the recommendations and mitigation measures of this EMP. • Conduct weekly / monthly audits of the construction site according to the EMP and ROD. • Educate the construction team about the management measures of the EMP and ROD. • Regular liaison with the construction team and the project leader. • Recommend corrective action for any environmental non-compliance incidents on the construction site. • Compile a regular report highlighting any non-compliance issues as well as good compliance with the EMP. • All negotiations for any reason shall be between the ECO, the developer, affected parties (landowners) and the Contractor. No verbal agreements shall be made. All agreements shall be recorded in writing and all parties shall co-sign the documentation. • The affected parties shall always be kept informed about any changes to the construction programme should they be involved. If the ECO is not on site the Contractor should keep the affected parties informed. The contact numbers of the Contractor and the ECO shall be made available to the affected parties. This will ensure open channels of communication and prompt response to queries and claims.

Contractor

The contractor is responsible for the implementation and compliance with recommendations and conditions of the EMP inter alia:

• Ensure compliance with the EMP at all times during construction • Maintain an environmental register which keeps a record of all incidents which occur on the site during construction. These incidents include:

o Public involvement / complaints o Health and safety incidents o Incidents involving Hazardous materials stored on site o Non compliance incidents

Adjacent landowners could see the construction period as interference with their daily activities. There will be a negative attitude towards the whole construction

Bohlweki-SSI Environmental 11 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape process. The Contractor shall under no circumstances interfere with the property of Landowners or nearby Communities.

Environmental Liaison Officer

The Environmental Liaison Officer (ELO) will be appointed by the contractor to monitor activities on site on a daily basis. The ELO will be the ECO’s representative on the site and will report back on all audit trips. The ELO must report any major incidents immediately to the ECO.

Table 2-1: Responsible Parties and Auditing Process

TITLE PARTY ROLE DURING ROLE ABBREVIATION CONSTRUCTION DURING OPERATION Developer Coega Assume ultimate Assume DEV Development responsibility ultimate Corporation responsibility (CDC) Project TBA Project Project PM Management management management Landscape TBA Monitoring of Possibly LA Architect vegetation Maintenance translocation and of landscaping planting Main TBA Main Contractor N/A MC Contractor Environmental To be appointed Day to day N/A ELO Liaison Officer by Main environmental Contractor responsibility, point of contact for ECO Environmental To be appointed Two weekly to Annual audits ECO Control Officer by CDC monthly audits

The following are the environmental management responsibilities of the various parties during construction and operational phases. Unless otherwise stated the EMP will be adhered to as follows:

• The ELO will be the responsible party for all compliance of this EMP during the construction phase.

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• The monitoring party will be the ECO. • Method of record keeping will be weekly to two weekly audits depending on the stage of the project. • Audit Technique will be the review of records that will be kept on site by the ELO and/ or site inspections. • The Client will bear ultimate responsibility.

Table 2-2: Environmental Management Responsibilities

ITEM PROJECT RESPONSIBLE MONITORING AUDIT COMPONENT AND PARTY PARTY TECHNIQUE ACTIVITY 1 PRE CONSTRUCTION ACTIVITY 1.1 Appoint construction DEV, PM ELO, ECO team and suitable qualified manager 1.2 Training of site staff MC, ELO, SM, DEV, ECO PM 1.3 Confirm suitable sites MC, ELO, SM, DEV, ECO for Construction PM Camp & Storage 2.1 CONSTRUCTION ACTIVITY 2.1.1 Construction Zone MC, SM, ELO ECO Daily monitoring

2.1.2 Construction Camp MC, SM, ELO ECO Daily monitoring

2.1.3 Storage Areas MC, SM, ELO ECO Daily monitoring

2.1.4 Stock Pile Areas MC, SM, ELO ECO Daily monitoring

2.1.5 Geotechnical Issues DEV, MC, PM ECO Daily monitoring for Consideration 2.1.6 Surface run-off MC, SM, ELO ECO Daily monitoring

2.1.7 Disruption of DEV, MC, SM, ECO Daily monitoring Infrastructure & ELO, PM Services

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ITEM PROJECT RESPONSIBLE MONITORING AUDIT COMPONENT AND PARTY PARTY TECHNIQUE ACTIVITY 2.1.8 Supervision MC, ELO, SM, ECO Daily monitoring PM

2.2 PHYSICAL ENVIRONMENT 2.2.1 Construction Traffic MC, SM, ELO ECO Daily monitoring and Access 2.2.2 Noise MC, SM, ELO ECO Records Review

2.2.3 Soils and Geology MC ECO Daily monitoring

2.2.4 Groundwater and MC ECO Records Review surface water pollution 2.2.5 Hydrology and Storm MC ENGINEER Daily monitoring water 2.2.6 Air pollution MC ECO Records Review

2.2.7 Flora MC ECO, Ecologist Daily monitoring (when necessary) 2.2.8 Fauna MC ECO, Ecologist Records Review (when and Daily necessary) monitoring 2.3 SOCIO-ECONOMIC ENVIRONMENT 2.3.1 Employment DEV, MC, PM ECO Records Review

2.3.2 Injury to Workers MC, ELO, SM, Safety Officer Daily monitoring and Public PM 2.3.4 Security MC, ELO, SM, ECO Daily monitoring PM 2.4 VISUAL ENVIRONMENT 2.4.1 Upkeep of visual ELO, LA ECO Daily monitoring environment 2.5 CULTURAL ENVIRONMENT

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ITEM PROJECT RESPONSIBLE MONITORING AUDIT COMPONENT AND PARTY PARTY TECHNIQUE ACTIVITY 2.5.1 Archaeology ELO ECO Records Review

3 POST CONSTRUCTION OPERATIONAL ACTIVITIES 3.1 Land Use LA, ELO DEV Daily monitoring Rehabilitation 3.2 Replacement of DEV, ELO DEV Daily monitoring Topsoil 3.3 Re-vegetation LA, ELO DEV Daily monitoring

3.4 Surface Water DEV, ELO DEV Daily monitoring

3.5 Site and Public DEV, ELO DEV Daily monitoring Safety 3.6 Pollution Control DEV ELO DEV Daily monitoring

Independent Auditor

The independent auditor will conduct quarterly environmental audits during the construction phase of the project (i.e. on a construction period of 6 months, only 2 external audits are needed, one a month after construction commenced and another towards the end of the construction phase) according to the provisions of the Environmental Management Plan. The independent auditor will:

• Conduct audits; • Submit audit reports to ECO and relevant authority; and • Engage specialist sub-consultants when required.

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The Environmental Management Plan

This EMP seeks to manage and keep to a minimum the negative impacts of a development and at the same time, enhance the positive and beneficial impacts.

Objectives of an EMP

The objectives of the EMP are to:

• Identify a range of mitigation measures which could reduce and mitigate the potential impacts to minimal or insignificant levels. • To identify measures that could optimize beneficial impacts. • To create management structures that addresses the concerns and complaints of I&APs with regards to the development. • To establish a method of monitoring and auditing environmental management practices during all phases of development. • Ensure that the construction and operational phases of the project continues within the principles of Integrated Environmental Management. • Detail specific actions deemed necessary to assist in mitigating the environmental impact of the project. • Ensure that the safety recommendations are complied with. • Propose mechanisms for monitoring compliance with the EMP and reporting thereon. • Specify time periods within which the measures contemplated in the final environmental management plan must be implemented, where appropriate.

The EMP seeks to highlight the following:

• Avoiding impacts by not performing certain actions. • Minimising impacts by limiting aspects of an action. • Rectifying impacts through rehabilitation, restoration, etc of the affected environment. • Compensating for impacts by providing substitute resources or environments • Minimising impacts by optimising processes, structural elements and other design features. • Provide ongoing monitoring and management of environmental impacts of a development and documenting of any digressions /good performances. • The EMP is a legally binding document that all parties involved in the project must be aware of.

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Environmental monitoring

A monitoring programme will be implemented for the duration of the construction phase of the project. This programme will include:

• Bi-weekly audits during first month where after monthly audits will be conducted by the Environmental Control Officer, which are according to the EMP and RoD’s conditions. These audits can be conducted randomly and do not require prior arrangement with the project manager. • Compilation of an audit report with a rating of the compliance with the EMP. This report will be submitted to the relevant authorities.

The ECO shall keep a photographic record of any damage to areas outside the demarcated site area. The date, time of damage, type of damage and reason for the damage shall be recorded in full to ensure the responsible party is held liable. All claims for compensation emanating from damage should be directed to the ECO for appraisal. The Contractor shall be held liable for all unnecessary damage to the environment. A register shall be kept of all complaints from adjacent landowners or communities. All complaints / claims shall be handled immediately to ensure timeous rectification / payment by the responsible party.

A formal monitoring protocol will be included within the revised EMP once all (if any) outstanding studies and detailed design have been completed, and once recommendations and conditions from the reviewing and permitting authorities have been received. In addition the requirements of the Department of Water Affairs and Forestry in terms of landfill permitting process will be incorporated. These requirements in terms of a monitoring protocol will only be able to be incorporated into the revised EMP once, and should authorisation for the proposed facility and/or permit/s have be received from the aforementioned Departments.

Compliance with the EMP and associated documentation

A Copy of the EMP must be kept on site during the construction period at all times. The EMP will be made binding on all contractors operating on the site and must be included within the Contractual Clauses. It should be noted that in terms of the Environment Conservation Act, and the National Environmental Management Act No 107 of 1998 (Section 28) those responsible for environmental damage must pay the repair costs both to the environment and human health and the preventative measures to reduce or prevent further pollution and/or environmental damage (The polluter pays principle). The Contractor is deemed not to have complied with the EMP if:

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• Within the boundaries of the site, site extensions and haul/ access roads there is evidence of contravention of clauses; • If environmental damage ensues due to negligence; • The contractor fails to comply with corrective or other instructions issued by the ECO or Authorities within a specified time; and • The Contractor fails to respond adequately to complaints from the public.

The Developer is deemed not to have complied with the EMP if:

• Within the boundaries of the site there is evidence of contravention of clauses; • If environmental damage ensues due to negligence; and • They fail to respond adequately to complaints from the public.

Penalties for non-compliance

Application of a penalty clause to the contractor will apply for incidents of non- compliance. The penalty imposed will be per incident and will be deducted from the contractor’s monthly payment certificate. Unless stated otherwise in the project specification, the penalties imposed per incident or violation will be determined in consultation with DWEA/DWEA in the revised EMP. The level of non- compliance will be determined through the use of an audit checklist. This checklist will be drawn up according to the revised EMP.

Layout of the EMP

The EMP is separated into four phases. Each phase has specific issues unique to that period of the development and operation of the proposed pipeline and associated infrastructure. The impact is identified and given a brief description. The four phases of the development are then identified as below:

• Pre-Construction Phase; • Construction Phase and associated rehabilitation of affected environment; • Operational Phase (Post-Construction); and • Closure and Decommissioning.

After analysing the criteria such as extent, duration, intensity, etc under each phase, a discussion is presented where appropriate. The Environmental Management Plan is then shown and the mitigation measures in each development phase identified. Thereafter, a brief section indicating significance after mitigation is presented. Where necessary referral will be made to the Draft Operating Manual

Bohlweki-SSI Environmental 18 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape and Draft Emergency Preparedness Manual and Response Action Plan (Jones and Wagener Consulting Engineers, 2008) where management and mitigation actions for various aspects are mutually relevant for all these documents.

Training and Awareness

Training of Construction Workers

The Construction Workers must receive basic training in environmental awareness, including the storage and handling of hazardous substances, minimisation of disturbance to sensitive areas, management of waste, and prevention of water pollution etc. They must also be subjected to an appraisal of their knowledge of the EMP’s requirements.

Contractor Performance

The Contractor must ensure that the conditions of the Environmental Management Plan are adhered to. Should the Contractor require clarity on any aspect of the EMP the Contractor must contact the Environmental Control Officer for advice.

Legislation, Development Strategies and Guidelines

The following environmental legislation is applicable to the proposed project.

Legislation

• Constitution of South Africa (Act No. 108 of 1996) • National Environmental Management Act (Act No 107 of 1998) – NEMA • Environment Conservation Act (Act No 73 of 1989) • National Heritage Resources Act (Act No 25 of 1999) • National Water Act (Act No 36 of 1998) • Hazardous Substances Act (Act No. 15 of 1973) • Protected species – provincial ordinances • National Forests Act (Act No 84 of 1998) • Conservation of Agricultural Resources Act (Act No 43 of 1983) • National Environmental Management: Biodiversity Act (Act No. 10 of 2004) • National Veld and Forest Fire Act (Act No 101 of 1998) • Occupational Health and Safety Act (Act No 85 of 1993) • National Environmental Management: Air Quality Act (Act No. 39 of 2004) • Atmospheric Pollution Prevention Act (Act No. 45 of 1965)

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Guidelines and Policy

Several regulations will be applicable to the construction phase of the project. These guidelines are mentioned in the EMP tables in section 6.

ISO 14000 (EMS System)

The EMP will follow the ISO 14000 Environmental Management System (EMS) guidelines and a specific EMS will be developed for the construction of the proposed GHWMF. This EMS system is described in Appendix 1.

However, the onus will rest with the developer to initiate and attain ISO 14000 EMS status.

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EMP: Pre – Construction Phase

Requirements for the pre-construction phase:

• Continuous liaison between the Developer, Contractor and relevant Landowners to ensure all parties are appropriately informed at all times. • The Landowners must be informed of the starting date of construction as well as the phases in which the construction shall take place. • The Contractor must adhere to all conditions of contract including the EMP Plan and landowner special conditions. • Adequate planning of the construction programme to allow for disruptions due to rain and very wet conditions. • All manmade as well as natural (vegetation) structures outside the boundary of the site shall be protected against damage at all times and any damage shall be rectified immediately. • Proper documentation and record keeping of all complaints and actions taken. • Regular site inspections by the ECO and good control over the construction process throughout the construction period. • Appointment of an ECO on behalf of the Developer to implement this EMP as well as deal with all Landowner related matters. • Appointment of an Environmental Liaison Officer on behalf of the Developer to implement this EMP as well as deal with all Landowner related matters. • Independent Environmental Audits to be carried out during and upon completion of construction. The frequency of these audits will be determined in the revised EMP. • A formal communications protocol should be set up during this phase. The aim of the protocol should be to ensure that effective communication on key issues that may arise during construction be maintained between key parties such as the ECO, project manager and contractor. The protocol should also ensure that concerns / issues raised by I&APs are formally recorded and considered and where necessary acted upon. If necessary, a forum for communicating with key stakeholders on a regular basis may need to be set up. This could be done through an Environmental Monitoring Committee that would meet on a regular basis. The communications protocol should be maintained throughout the construction phase.

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Table 5-1: Pre-construction Phase

IMPACT PRE-CONSTRUCTION PHASE RESPONSIBILITY FREQUENCY / (This section deals with the preparation of the site and actions MONITORING that need to be implemented before construction commences) REQUIREMENTS PHASE PRE – CONSTRUCTION Developer, ECO Weekly

ENVIRONMENTAL MANAGEMENT PLAN

MITIGATION 1. Appoint an Environmental Control Officer (ECO) and Environmental Liaison Officer (ELO). 2. Before construction commence, all areas to be developed must be clearly demarcated with fencing. 3. The contractor must ensure compliance with conditions described in the Record of Decision. 4. Records of compliance / non-compliance with the conditions of the authorisation must be kept and be available to DWEA on request. 5. Records of all environmental incidents must be maintained and a copy of these records be made available to DWEA/DWEA on request throughout the project execution. 6. Confirm, with ECO, suitable sites for the construction camps (equipment and batching etc) and storage areas for materials. 7. All construction equipment must be stored within this construction camp and all associated oil changes etc (no servicing) must take place on a sealed surface such as concrete slab within this camp. 8. Unskilled labourers should be drawn from the local market. 9. Training of site staff: * Environmental awareness training for construction staff,

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IMPACT PRE-CONSTRUCTION PHASE RESPONSIBILITY FREQUENCY / (This section deals with the preparation of the site and actions MONITORING that need to be implemented before construction commences) REQUIREMENTS concerning the prevention of accidental spillage of hazardous chemicals and oil; pollution of water resources (both surface and groundwater), air pollution and litter control and identification of archaeological artefacts. * Project Manager shall ensure that the training and capabilities of the Contractor’s site staff are adequate to carry out the designated tasks. * Staff operating equipment (such as excavators, loaders, etc.) shall be adequately trained and sensitised to any potential hazards associated with their tasks. * No operator shall be permitted to operate critical items of mechanical equipment without having been trained by the Contractor and certified competent by the Project Manager. * Staff should be educated as to the need to refrain from indiscriminate waste disposal and/or pollution of local soil and water resources and receive the necessary safety training.

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Environmental Management Plan: Construction Phase

Site Clearing

Site clearing must take place in a phased manner, as and when required. Areas which are not to be constructed on within a two week period must not be cleared to reduce erosion risks. The area to be cleared must be clearly demarcated and this footprint strictly maintained. If any spoil is removed from the site must be moved to an approved spoil site or DWEA registered landfill site. The necessary silt fences and erosion control measures must be implemented in areas where these risks are more prevalent.

Site establishment

Site establishment shall take place in an orderly manner and all required amenities shall be installed at Camp sites before the main workforce move onto site. The Construction camp shall have the necessary ablution facilities with chemical toilets at commencement of construction. The Contractor shall inform all site staff to make use of supplied ablution facilities and under no circumstances shall indiscriminate sanitary activities be allowed.

The Contractor shall supply waste collection bins where such is not available and all solid waste collected shall be disposed of at a DWEA registered landfill. A certificate of disposal shall be obtained by the Contractor and kept on file. Where a registered waste site is not available close to the construction site, the Contractor shall develop and incorporate a method statement with regard to waste management on site during the construction phase. The disposal of waste shall be in accordance with all relevant legislation. Under no circumstances may solid waste be burnt on site.

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Table 6-1: Construction Traffic and Access

IMPACT CONSTRUCTION TRAFFIC AND ACCESS RESPONSIBILITY FREQUENCY / (This section deals with the impact that construction traffic and MONITORING access has on the site and surrounds) REQUIREMENTS PHASE CONSTRUCTION Main Contractor, Weekly SM, ECO ENVIRONMENTAL MANAGEMENT PLAN MITIGATION Construction traffic 1. Construction routes and required access roads must be clearly defined. 2. Delivery of equipment must be undertaken with the minimum amount of trips. 3. Access of all construction and material delivery vehicles should be strictly controlled, especially during wet weather to avoid compaction and damage to the topsoil structure. 4. Planning of site delivery hours must be scheduled to avoid peak hour traffic, weekends and evenings. 5. Wheel washing and damping down of un-surfaced roads must be implemented to reduce dust and nuisance. 6. Vehicles and equipment shall be serviced regularly to avoid the contamination of soil from oil and hydraulic fluid leaks etc. 7. Servicing must be done off-site. 8. Oil changes must take place on a concrete platform or over a drip tray. 9. Soils compacted by construction shall be ripped to loosen compacted layers and re-graded to even running levels.

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IMPACT CONSTRUCTION TRAFFIC AND ACCESS RESPONSIBILITY FREQUENCY / (This section deals with the impact that construction traffic and MONITORING access has on the site and surrounds) REQUIREMENTS Access 10. Temporary access roads must be rehabilitated prior to the contractor leaving the site. 11. Strategic positioning of entry and exit points to ensure as little effect as possible on the traffic. 12. The main routes to the site must be clearly signposted and printed delivery maps must be issued to all suppliers and Sub-Contractors. 13. Planning of access routes to the site for construction purposes shall be done in conjunction between the Contractor, Developer and the Landowner. All agreements reached should be documented and no verbal agreements should be made. The Contractor shall clearly mark all access roads. Roads not to be used shall be marked with a "NO ENTRY" sign. 14. Where new access roads are constructed, this must be done according to design and contract specifications. Drainage channels shall be suitably designed to ensure erosion does not occur, especially at the outflow points. The new access road shall be designed to allow for the natural flow of water where required. Crossing of dongas and eroded areas on access routes to new sites shall be thoroughly planned and installed according to design and contract specifications. All areas susceptible to erosion shall be protected with suitable erosion control measures from the onset of the project. Prevention is the ultimate aim, as restoration is normally very difficult and costly.

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IMPACT CONSTRUCTION TRAFFIC AND ACCESS RESPONSIBILITY FREQUENCY / (This section deals with the impact that construction traffic and MONITORING access has on the site and surrounds) REQUIREMENTS Road maintenance 15. Where necessary suitable measures shall be taken to rehabilitate damaged areas. In the event of rehabilitation work being required on private roads, such work will be done to the original specifications of the private road. 16. Contractors should ensure that access roads are maintained in good condition by attending to potholes, corrugations and stormwater damage as soon as these develop. 17. If necessary, staff must be employed to clean surfaced roads adjacent to construction sites where materials have spilt.

General 18. The Contractor shall meet safety requirements under all circumstances. All equipment transported shall be clearly labelled as to their potential hazards according to specifications. All the required safety labelling on the containers and trucks used shall be in place. 19. The Contractor shall ensure that all the necessary precautions against damage to the environment and injury to persons are taken.

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Table 6-2: Construction Camp

IMPACT CONSTRUCTION CAMP RESPONSIBILITY FREQUENCY / (This section deals with the impacts relating to the construction MONITORING camp - equipment and batching camp) REQUIREMENTS PHASE CONSTRUCTION Main Contractor, Weekly SM, ELO, ECO ENVIRONMENTAL MANAGEMENT PLAN MITIGATION Siting of construction camp 1. Choice of site for the Contractor’s camp requires the Engineer and ECOs permission and must take into account location of local residents and / or ecologically sensitive areas, including flood zones and slip / unstable zones. A site plan must be submitted to the Engineer for approval. 2. The construction camp may not be situated within a 1:100 year floodline or on slopes greater that 1:3. 3. If the Contractor chooses to locate the camp site on private land, he must get prior permission from both the Engineer and the landowner. 4. The size of the construction camp should be minimized (especially where natural vegetation or grassland has had to be cleared for its construction). 5. Adequate parking must be provided for site staff and visitors. This should not inconvenience or serve as a nuisance for neighbours. 6. The Contractor must attend to drainage of the camp site to avoid standing water and / or sheet erosion. 7. Suitable control measures over the Contractor’s yard, plant and material storage to mitigate any visual impact of the construction activity must be implemented. 8. No development, or activity of any sort, is allowed below the

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IMPACT CONSTRUCTION CAMP RESPONSIBILITY FREQUENCY / (This section deals with the impacts relating to the construction MONITORING camp - equipment and batching camp) REQUIREMENTS 1:100 year flood line of any water system. Only designated areas must be used for storage of construction materials, soil stockpiles, machinery and other equipment. 9. Specific areas must be designated for cement batching plants. Sufficient drainage for these plants must be in place to ensure that soils do not become contaminated. 10. The construction camp must be kept clear of litter at all times. 11. No open fires are allowed within the construction camp and no surrounding vegetation may be used to create a fire.

Storage of materials (including hazardous materials) 12. Choice of location for storage areas must take into account prevailing winds, distances to water bodies, general onsite topography and water erosion potential of the soil. Impervious surfaces must be provided where necessary. 13. Storage areas must be designated, demarcated and fenced. 14. Storage areas should be secure so as to minimize the risk of crime. They should also be safe from access by unauthorised persons. 15. Fire prevention facilities must be present at all storage facilities. 16. Proper storage facilities for the storage of oils, paints, grease, fuels, chemicals and any hazardous materials to be used must be provided to prevent the migration of spillage into the ground and groundwater regime around the temporary storage area(s). These pollution prevention measures for

Bohlweki-SSI Environmental 29 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT CONSTRUCTION CAMP RESPONSIBILITY FREQUENCY / (This section deals with the impacts relating to the construction MONITORING camp - equipment and batching camp) REQUIREMENTS storage should include a bund wall high enough to contain at least 110% of any stored volume, and this should be sited away from drainage lines in a site with the approval of the Engineer. 17. These storage facilities (including any tanks) must be on an impermeable surface that is protected from the ingress of storm water from surrounding areas in order to ensure that accidental spillage does not pollute local soil or water resources. Spillages within the construction camp need to be cleaned up immediately and disposed of in the hazardous skip bin for correct disposal. 18. Any spillage, which may occur, shall be investigated and immediate action must be taken. This must also be reported to the ECO and DWEA, as well as local authorities if so required. 19. Material Safety Data Sheets (MSDSs) shall be readily available on site for all chemicals and hazardous substances to be used on site. Where possible the available, MSDSs should additionally include information on ecological impacts and measures to minimise negative environmental impacts during accidental releases or escapes. 20. Clear signage must be placed at all storage areas containing hazardous substances / materials. 21. Staff dealing with these materials / substances must be aware of their potential impacts and follow the appropriate safety measures. 22. A Waste Disposal Contractor must be employed to remove

Bohlweki-SSI Environmental 30 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT CONSTRUCTION CAMP RESPONSIBILITY FREQUENCY / (This section deals with the impacts relating to the construction MONITORING camp - equipment and batching camp) REQUIREMENTS waste oil. These wastes should only be disposed of at DWEA licensed landfill sites designed to handle hazardous wastes. A disposal certificate must be obtained from the Waste Disposal Contractor. 23. The contractor must ensure that its staff is made aware of the health risks associated with any hazardous substances used and has been provided with the appropriate protective clothing/equipment in case of spillages or accidents and have received the necessary training. 24. All excess cement and concrete mixes are to be contained on the construction site prior to disposal off site.

Drainage of construction camp 25. Run-off from the camp site must not discharge into neighbours’ properties or into adjacent hydrological features.

Bohlweki-SSI Environmental 31 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

Table 6-3: Environmental Education and Training

IMPACT ENVIRONMENTAL EDUCATION AND TRAINING RESPONSIBILITY FREQUENCY / (This section deals with the environmental training of construction MONITORING employees who will work on the facility) REQUIREMENTS PHASE CONSTRUCTION Main Contractor, Monthly SM, ECO ENVIRONMENTAL MANAGEMENT PLAN MITIGATION Environmental training 1. Ensure that all site personnel have a basic level of environmental awareness training. The Contractor must submit a proposal for this training to the ECO for approval. Topics covered should include: * What is meant by “Environment” * Why the environment needs to be protected and conserved * How construction activities can impact on the environment * What can be done to mitigate against such impacts * Awareness of emergency and spills response provisions * Social responsibility during construction e.g. being considerate to local residents 2. It is the Contractor’s responsibility to provide the site foreman with no less that 2 hour’s environmental training and to ensure that the foreman has sufficient understanding to pass this information onto the construction staff. 3. Training should be provided to the staff members in the use of the appropriate fire-fighting equipment. Translators are to be used where necessary. 4. Use should be made of environmental awareness posters on site. 5. The need for a “clean site” policy also needs to be explained to

Bohlweki-SSI Environmental 32 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

the workers. 6. Staff operating equipment (such as excavators, loaders, etc.) shall be adequately trained and sensitised to any potential hazards associated with their tasks.

Monitoring of environmental training 7. The Contractor must monitor the performance of construction workers to ensure that the points relayed during their introduction have been properly understood and are being followed. If necessary, the ECO and / or a translator should be called to the site to further explain aspects of environmental or social behaviour that are unclear.

Bohlweki-SSI Environmental 33 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

Table 6-4: Borrow Pits

IMPACT BORROW PITS RESPONSIBILITY FREQUENCY / (This section deals with the impact that construction traffic and MONITORING access has on the site and surrounds) REQUIREMENTS PHASE CONSTRUCTION Main Contractor, Monthly SM, ELO, ECO ENVIRONMENTAL MANAGEMENT PLAN MITIGATION Location of borrow pits (if required) 1. Borrow pit localities that may be situated outside the footprint of the proposed GHWMF must be negotiated with the relevant municipality to ensure consensus of their location. 2. The Contractor is required to comply with the requirements of the Minerals Act (Act 50 of 1991). In terms of the Act, mining authorisation from the Department of Minerals and Energy (DME) is a legal requirement. This application must include the Environmental Management Plan and is duly submitted to the Provincial Director of Mineral Development.

Management of borrow pits 3. The contractor must also compile an information document which states the methods which will be utilised when creating borrow pits. This document must include, but not be limited to the following: * Plans which detail the expected quantity of excavation that will be required * temporary and permanent stormwater control * the final contouring of the borrow pit and the proposed method of rehabilitation * The current status and land use of the borrow pit * Topsoil management strategy (preservation of topsoil for

Bohlweki-SSI Environmental 34 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT BORROW PITS RESPONSIBILITY FREQUENCY / (This section deals with the impact that construction traffic and MONITORING access has on the site and surrounds) REQUIREMENTS reinstatement) * Proposed management of dangerous conditions (eg steep slopes, loose and unstable material, holes).

Bohlweki-SSI Environmental 35 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

Table 6-5: General Construction

IMPACT GENERAL CONSTRUCTION RESPONSIBILITY FREQUENCY / MONITORING REQUIREMENTS PHASE CONSTRUCTION Main Contractor, Bi-weekly Developer, SM, ECO, Engineer ENVIRONMENTAL MANAGEMENT PLAN MITIGATION General construction 1. Construction should be limited to daylight hours (06h00 – 18h00) in sensitive areas such as residential areas. Where construction is required after hours in order to avoid traffic interruptions, notification is to be sent out to all potentially affected land owners. 2. Notification must also be ensured when essential services such as water or electricity are to be affected by the construction process. 3. Blasting (if required) must be done in accordance with the relevant by laws and SANS standards. Explosives must be used according to the relevant by-laws, SANS standards and to the relevant guidelines, including the Occupational Health and Safety Act (Act 15 of 1973) and the Explosives Act (Act 26 of 1956)].

Bohlweki-SSI Environmental 36 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

Table 6-6: Soils and Geology

IMPACT SOILS AND GEOLOGY RESPONSIBILITY FREQUENCY / (This section deals with the impact that the proposed MONITORING development will have on soils and geology) REQUIREMENTS PHASE CONSTRUCTION ECO, Main Monthly Contractor ENVIRONMENTAL MANAGEMENT PLAN

MITIGATION Topsoil / METHOD 1. The contractor should, prior to the commencement of STATEMENT earthworks determine the average depth of topsoil, and agree on this with the ECO. The full depth of topsoil should be stripped from areas affected by construction and related activities prior to the commencement of major earthworks. This should include the building footprints, working areas and storage areas. Topsoil must be reused where possible to rehabilitate disturbed areas. 2. Care must be taken not to mix topsoil and subsoil during stripping. 3. Should any topsoil become polluted the contractor must remove the polluted soil to the full depth of pollution and replace it at his own expense with approved topsoil which should be at least equal to Department of Agriculture approved topsoil specifications. 4. Removed polluted topsoil should be transported to a licensed landfill site.

Soil Stripping 5. No soil stripping must take place on areas within the site that the contractor does not require for construction works or areas of retained vegetation.

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IMPACT SOILS AND GEOLOGY RESPONSIBILITY FREQUENCY / (This section deals with the impact that the proposed MONITORING development will have on soils and geology) REQUIREMENTS 6. Subsoil and overburden should, in all construction and lay down areas, be stockpiled separately to be returned for backfilling in the correct soil horizon order. 7. Construction vehicles must only be allowed to utilise existing tracks or pre-planned access routes.

Stockpiles 8. Stockpiles should not be situated such that they obstruct natural water pathways. 9. Stockpiles should not exceed 2m in height unless otherwise permitted by the Engineer. 10. If stockpiles are exposed to windy conditions or heavy rain, they should be covered either by vegetation or cloth, depending on the duration of the project. Stockpiles may further be protected by the construction of berms or low brick walls around their bases. 11. Stockpiles should be kept clear of weeds and alien vegetation growth by regular weeding. 12. Where contamination of soil is expected, analysis must be done prior to disposal of excess soil to determine the appropriate disposal route. Proof from an applicable waste disposal site where contaminated soils are dumped if and when a spillage / leakage occur should be forwarded to the DWEA/DWEA.

Fuel storage 13. Topsoil and subsoil to be protected from contamination.

Bohlweki-SSI Environmental 38 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT SOILS AND GEOLOGY RESPONSIBILITY FREQUENCY / (This section deals with the impact that the proposed MONITORING development will have on soils and geology) REQUIREMENTS 14. Fuel and material storage must be away from stockpiles. 15. Cement, concrete and chemicals must be mixed on an impermeable surface and provisions should be made to contain spillages or overflows into the soil. 16. Any storage tanks containing hazardous materials must be placed in bunded containment areas with sealed surfaces. The bund walls must be high enough to contain 110% of the total volume of the stored hazardous material. 17. Contaminated soil must be contained and disposed of off site at an approved landfill site.

Concrete mixing 18. Concrete mixing and the concrete batching plant must be contained within a bunded area. 19. Concrete mixing must only take place within designated areas. 20. No vehicles transporting concrete to the site may be washed on site. 21. If a batching plant is necessary, run-off should be managed effectively to avoid contamination of other areas of the site. Untreated run-off from the batch plant must not be allowed to get into the storm water system or any rivers, streams, wetlands or existing erosion channels / dongas (if present on site).

Earthworks 22. All earthworks and borrowpits must be adequately controlled

Bohlweki-SSI Environmental 39 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT SOILS AND GEOLOGY RESPONSIBILITY FREQUENCY / (This section deals with the impact that the proposed MONITORING development will have on soils and geology) REQUIREMENTS and managed. 23. Soils compacted during construction should be deeply ripped to loosed compacted layers and re-graded to even running levels. Topsoil should be re-spread over landscaped areas. 24. The area should be re-vegetated upon completion of phased construction activities as per to specifications by the developer’s landscape architect. 25. It is very important that the foundation excavations for the proposed structures be inspected by an engineering geologist or geotechnical engineer prior to the placing of steel reinforcement or concrete in order to determine that the structure is being founded upon the correct material, and also to detect whether any active layers have been exposed by the foundation excavation.

Herbicides / pesticides 26. Fertilisers should not be used excessively and slow release fertilizers and organic products should be used in preference to highly soluble and inorganic fertilizers. 27. The use of herbicides and pesticides and other horticultural chemicals should be carefully controlled wherever these are used. Where feasible, ‘environmentally friendly’ products should be utilised.

Blasting 28. Sufficient mitigation, for example blast mats must be placed over blasting areas to minimise fly rock and noise.

Bohlweki-SSI Environmental 40 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT SOILS AND GEOLOGY RESPONSIBILITY FREQUENCY / (This section deals with the impact that the proposed MONITORING development will have on soils and geology) REQUIREMENTS 29. Rupture / Failure surveys in local area to check for existing structural failures / ruptures of storage infrastructure so as to exclude risk of insurance claims to contractor / client from other parties. 30. Clear safe zone around blast point to prevent potential injury to personnel and damage to equipment on site. May include in certain situations halting traffic temporarily. 31. Inform local inhabitants / traffic of blast times.

Bohlweki-SSI Environmental 41 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

Table 6-7: Erosion Control IMPACT EROSION CONTROL RESPONSIBILITY FREQUENCY / (This section deals with the impact that the proposed MONITORING development will have with regards to potential erosion) REQUIREMENTS PHASE CONSTRUCTION ECO, Main Bi-Monthly Contractor ENVIRONMENTAL MANAGEMENT PLAN

MITIGATION 1. Wind screening and stormwater control should be undertaken to prevent soil loss from the site. 2. The use of silt fences and sand bags must be implemented in areas that are susceptible to erosion. 3. Other erosion control measures that can be implemented are as follows: * Brush packing with cleared vegetation * Mulch or chip packing * Planting of vegetation * Hydroseeding / hand sowing 4. Sensitive areas need to be identified prior to construction so that the necessary precautions can be implemented. 5. All erosion control mechanisms need to be regularly maintained. 6. Seeding of topsoil and subsoil stockpiles to prevent wind and water erosion of soil surfaces. 7. Retention of vegetation where possible to avoid soil erosion 8. Vegetation clearance should be phased to ensure that the minimum area of soil is exposed to potential erosion at any one time. 9. Re-vegetation of disturbed surfaces should occur immediately after construction activities are completed. 10. No impediment to the natural water flow other than approved

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IMPACT EROSION CONTROL RESPONSIBILITY FREQUENCY / (This section deals with the impact that the proposed MONITORING development will have with regards to potential erosion) REQUIREMENTS erosion control works is permitted. 11. To prevent stormwater damage, the increase in stormwater run-off resulting from construction activities must be estimated and the drainage system assessed accordingly. A drainage plan must be submitted to the Engineer for approval and must include the location and design criteria of any temporary drainage line crossings. 12. Stockpiles not used in three (3) months after stripping must be seeded to prevent dust and erosion

Bohlweki-SSI Environmental 43 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

Table 6-8: Ground and Surface Water Pollution

IMPACT GROUNDWATER AND SURFACE WATER POLLUTION RESPONSIBILITY FREQUENCY / (This section deals with the impact that the construction and MONITORING operation of the development could have on Ground and surface REQUIREMENTS water pollution) PHASE CONSTRUCTION - REFER TO SECTIONS 13.5-13.6, 17.2- Main Contractor, Weekly 17.3 AND 17.11-17.12 OF DRAFT OPERATIONS MANUAL ECO ENVIRONMENTAL MANAGEMENT PLAN

MITIGATION Sanitation / METHOD 1. Adequate sanitary facilities and ablutions must be provided STATEMENT for construction workers (1 toilet per every 15 workers). 2. The facilities must be regularly serviced and emptied to reduce the risk of surface or groundwater pollution.

Hazardous materials 3. Use and or storage of materials, fuels and chemicals which could potentially leak into the ground must be controlled 4. All storage tanks containing hazardous materials must be placed in bunded containment areas with sealed surfaces. The bund wall must be high enough to contain 110% of the total volume of the stored hazardous material with an additional allocation for potential stormwater events. 5. Any hazardous substances must be stored at least 20m from any of the water bodies on site. 6. The ECO should be responsible for ensuring that potentially harmful materials are properly stored in a dry, secure, ventilated environment, with concrete or sealed flooring and a means of preventing unauthorised entry. 7. Contaminated wastewater must be managed by the Contractor to ensure existing water resources on the site are

Bohlweki-SSI Environmental 44 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT GROUNDWATER AND SURFACE WATER POLLUTION RESPONSIBILITY FREQUENCY / (This section deals with the impact that the construction and MONITORING operation of the development could have on Ground and surface REQUIREMENTS water pollution) not contaminated. All wastewater from general activities in the camp shall be collected and removed from the site for appropriate disposal at a licensed commercial facility.

Cement mixing 8. Cement contaminated water must not enter the water system as this disturbs the natural acidity of the soil and affects plant growth

Public areas 9. Food preparation areas should be provided with adequate washing facilities and food refuse should be stored in sealed refuse bins which should be removed from site on a regular basis. 10. The contractor should take steps to ensure that littering by construction workers does not occur and persons should be employed on site to collect litter from the site and immediate surroundings, including litter accumulating at fence lines. 11. No washing or servicing of vehicles on site.

Water resources 12. Site staff shall not be permitted to use any other open water body or natural water source adjacent to or within the designated site for the purposes of bathing, washing of clothing or for any construction or related activities. 13. Municipal water (or another source approved by the ECO)

Bohlweki-SSI Environmental 45 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT GROUNDWATER AND SURFACE WATER POLLUTION RESPONSIBILITY FREQUENCY / (This section deals with the impact that the construction and MONITORING operation of the development could have on Ground and surface REQUIREMENTS water pollution) should instead be used for all activities such as washing of equipment or disposal of any type of waste, dust suppression, concrete mixing, compacting, etc. SITE SPECIFIC MITIGATION MEASURES

14. Approval of groundwater quality monitoring systems must be obtained from the relevant government authorities ie the Departments of Water Affairs and Forestry (DWEA) and Environment and Tourism (DWEA). 15. Sealing of all existing boreholes on site not to be utilised for monitoring purposes (to be covered by the facility footprint) with cement and final bentonite at the top. Sanitary seal consisting of a bentonite and sand mixture around the upper 4 m of the borehole. 16. Proper storm water control measures must to be implemented to minimize storm water collection within the excavated areas and to reduce erosion. 17. Selection of good quality natural clay for landfill cell liner construction must be the standard, alternatively addition of bentonite to liner material to attain the prescribed permeability for liners. Regular inspection of construction and testing of liner permeability and compaction characteristics during construction. Proper control and supervision during the placement of synthetic liners, and testing after completion. 18. Proper management of all construction material storage areas and bunding of facilities where required. 19. Ensure that surface/storm water is diverted away from

Bohlweki-SSI Environmental 46 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT GROUNDWATER AND SURFACE WATER POLLUTION RESPONSIBILITY FREQUENCY / (This section deals with the impact that the construction and MONITORING operation of the development could have on Ground and surface REQUIREMENTS water pollution) excavation trenches. 20. If necessary ensure that stream flow bypasses the construction area within drainage lines. 21. Shape backfilling of trench in such a way that water ponding and erosion of backfilled trench are avoided. 22. Ensure that contaminants are safely stored and away from construction site. 23. In terms of hydrotesting, abstraction from identified water sources, agreed with DWEA, will be used for hydrotesting 24. Any water discharge will have to comply with the water quality standards as agreed with DWEA. 25. Regular water quality monitoring according to permit conditions and in compliance to Minimum Requirement documents of DWEA. Reporting of results to the authorities on a six monthly basis.

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Table 6-9: Hydrology and stormwater

IMPACT HYDROLOGY AND STORMWATER RESPONSIBILITY FREQUENCY / (This section deals with the impact that the construction and MONITORING operation of the development could have on hydrology and REQUIREMENTS stormwater) PHASE CONSTRUCTION – REFER TO SECTION 13.5 OF THE DRAFT ECO, ELO, Main Weekly OPERATIONS MANUAL Contractor ENVIRONMENTAL MANAGEMENT PLAN

MITIGATION 1. The site must be managed in order to prevent pollution of / METHOD drains, downstream watercourses or groundwater, due to STATEMENT suspended solids, silt or chemical pollutants. 2. Silt fences should be used to prevent any soil entering the stormwater drains. 3. Temporary cut of drains and berms may be required to capture stormwater and promote infiltration. 4. Promote a water saving mind set with construction workers in order to ensure less water wastage. 5. New stormwater construction must be developed strictly according to specifications from engineers in order to ensure efficiency. 6. Hazardous substances must be stored at least 20m away from the buffer area surrounding any water bodies on site to avoid pollution. 7. The installation of the stormwater system must take place as soon as possible after commencement of construction, to attenuate stormwater from the construction phase as well as the operation phase. 8. Earth, stone and rubble is to be properly disposed of so as not to obstruct natural water path ways over the site. i.e. these materials must not be placed in stormwater channels,

Bohlweki-SSI Environmental 48 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT HYDROLOGY AND STORMWATER RESPONSIBILITY FREQUENCY / (This section deals with the impact that the construction and MONITORING operation of the development could have on hydrology and REQUIREMENTS stormwater) drainage lines or rivers. 9. There should be a periodic checking of the site’s drainage system to ensure that the water flow is unobstructed. 10. If a batching plant is necessary, run-off should be managed effectively to avoid contamination of other areas of the site. Run-off from the batch plant must not be allowed to get into the stormwater system or nearby steams, rivers or erosion channels or dongas.

Bohlweki-SSI Environmental 49 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

Table 6-10: Air Quality

IMPACT AIR QUALITY RESPONSIBILITY FREQUENCY / (This section deals with the impact from air pollution) MONITORING REQUIREMENTS PHASE CONSTRUCTION – REFER TO SECTIONS 13.7-13.9, 17.5 OF Main Contractor, Daily THE DRAFT OPERATIONS MANUAL ELO ENVIRONMENTAL MANAGEMENT PLAN

MITIGATION Dust control 1. The proposed GHWMF operator should control on-site fugitive dust emissions by effective management and mitigation. At least 75% dust control efficiency is required on unpaved roads to ensure dustfall rates are reduced to the levels predicted. 2. The haul roads going to and from the site as well as on-site were identified as a significant source of dust emissions. Three types of measures may be taken to reduce emissions from unpaved roads: * measures aimed at reducing the extent of unpaved roads, e.g. paving, * traffic control measures aimed at reducing the entrainment of material by restricting traffic volumes and reducing vehicle speeds, and * measures aimed at binding the surface material or enhancing moisture retention, such as wet suppression and chemical stabilization 3. It is recommended that gravimetric sampling for PM10 be done using portable mini high-volume samplers. These are battery-driven and take a composite sample over 24 h. If sampling is carried out every third day (including week- ends) a sample series without systematic error, yet not too

Bohlweki-SSI Environmental 50 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT AIR QUALITY RESPONSIBILITY FREQUENCY / (This section deals with the impact from air pollution) MONITORING REQUIREMENTS labour-intensive is built up. 4. It is recommended that at least four deposition gauges be placed on the landfill site perimeter. The recorded wind field suggests that the dustfall gauges should be situated to the north-eastern, south-eastern, south-western and north- western boundaries of the site. 5. It is also recommended that PM10 and dustfall levels be monitored in order to: * confirm the predicted air quality impacts associated with activities from the landfill site; * assess compliance of landfill emissions and associated impacts with current air quality standards; * determine source contributions to ambient air quality in order to prioritise mitigation measures; * assess the efficiency of mitigation measures 6. Control measures that can be applied to reduce fugitive dust emissions from exposed surfaces include the use of vegetation cover. Vegetal cover retards erosion by binding the residue with a root network, by sheltering the residue surface and by trapping material already eroded. Vegetation is also considered the most effective control measure in terms of its ability to also control water erosion. In investigating the feasibility of vegetation types the following properties are normally taken into account: indigenous plants; ability to establish and regenerate quickly; proven effective for reclamation elsewhere; tolerant to the climatic conditions of the area; high rate of root production; easily

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IMPACT AIR QUALITY RESPONSIBILITY FREQUENCY / (This section deals with the impact from air pollution) MONITORING REQUIREMENTS propagated by seed or cuttings; and nitrogen-fixing ability. 7. Wheel washing and damping down of un-surfaced and un- vegetated areas 8. Retention of vegetation where possible will reduce dust travel 9. Excavations and other clearing activities must only be done during agreed working times and permitting weather conditions to avoid drifting of sand and dust into neighbouring areas. 10. Damping down of all exposed soil surfaces with a water bowser or sprinklers when necessary to reduce dust. 11. Blasting must be carried out in accordance with legislation using optimal and not excessive quantities of explosives. Blasting should only occur on calm days in order to reduce dust carry. The geotechnical report indicated that the probability of blasting is low. 12. The Contractor shall be responsible for dust control on site to ensure no nuisance is caused to the Landowner or neighbouring Communities. 13. A speed limit of 30km/h must not be exceeded. 14. Any complaints or claims emanating from the lack of dust control shall be attended to immediately by the Contractor.

Odour control 15. Regular servicing of vehicles in order to limit gaseous emissions (to be done off-site). 16. Regular servicing of on site toilets to avoid potential odours.

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IMPACT AIR QUALITY RESPONSIBILITY FREQUENCY / (This section deals with the impact from air pollution) MONITORING REQUIREMENTS 17. Allocated cooking areas must be provided. 18. The contractor must make alternative arrangements (other than fires) for cooking and / or heating requirements. LP gas cookers may be used provided that all safety regulations are followed.

Rehabilitation 19. The contractor should commence rehabilitation of exposed soil surfaces as soon as practical after completion of earthworks.

Fire prevention 20. The contractor must ensure that any grass left in a natural state during construction should be cut in order to prevent veld fires, especially during the dry months. 21. No open fires shall be allowed on site under any circumstance (The Forest Act, No 122 of 1984). All cooking shall be done in demarcated areas that are safe and cannot cause runaway fires. 22. The Contractor shall have operational fire-fighting equipment available on site at all times. The level of fire fighting equipment must be assessed and evaluated thorough a typical risk assessment process. It may be required to increase the level of protection, especially during the winter months.

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Table 6-11: Noise

IMPACT NOISE RESPONSIBILITY FREQUENCY / (This section deals with the impact that increased noise will MONITORING have on surrounding areas) REQUIREMENTS PHASE CONSTRUCTION Main Contractor, Daily ELO ENVIRONMENTAL MANAGEMENT PLAN MITIGATION 1. Although the proposed GHWMF is sited far from any residential settlement the following generic noise mitigation measures must be adhered to. 2. The construction phase must aim to adhere to the relevant noise regulations and limit noise to within standard working hours in order to reduce disturbance. 3. Construction site yards, workshops, concrete batching plants, and other noisy fixed facilities should be located well away from noise sensitive areas. Once the proposed final layouts are made available by the contractor(s), the sites must be evaluated in detail and specific measures designed into the system. 4. Truck traffic should be routed away from noise sensitive areas, where possible. 5. Noise levels must be kept within acceptable limits. All noise and sounds generated must adhere to SABS 0103 specifications for maximum allowable noise levels for residential areas. No pure tone sirens or hooters may be utilised except where required in terms of SABS standards or in emergencies. 6. Noisy operations should be combined so that they occur where possible at the same time. 7. Blasting operations (if required) are to be strictly

Bohlweki-SSI Environmental 54 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT NOISE RESPONSIBILITY FREQUENCY / (This section deals with the impact that increased noise will MONITORING have on surrounding areas) REQUIREMENTS controlled with regard to the size of explosive charge in order to minimise noise and air blast, and timings of explosions. The number of blasts per day should be limited, blasting should be undertaken at the same times each day and no blasting should be allowed at night. 8. Construction activities are to be contained to reasonable hours during the day and early evening. Night-time activities near noise sensitive areas should not be allowed. 9. With regard to unavoidable very noisy construction activities in the vicinity of noise sensitive areas, the contractor and ECO should liaise with local residents on how best to minimise impact, and the local population should be kept informed of the nature and duration of intended activities. 10. As construction workers operate in a very noisy environment, it must be ensured that their working conditions comply with the requirements of the Occupational Health and Safety Act (Act No 85 of 1993). Where necessary ear protection gear should be worn. 11. Noisy activities to take place during allocated construction hours only as per section 25 of the Noise Control Regulations of the Environment Conservation Act, 1989 (Act No. 73 of 1989) 12. Noise from labourers must be controlled. 13. Noise suppression measures must be applied to all construction equipment. Construction equipment must be

Bohlweki-SSI Environmental 55 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT NOISE RESPONSIBILITY FREQUENCY / (This section deals with the impact that increased noise will MONITORING have on surrounding areas) REQUIREMENTS kept in good working order and where appropriate fitted with silencers which are kept in good working order. Should the vehicles or equipment not be in good working order, the contractor may be instructed to remove the offending vehicle or machinery from site. 14. The contractor must take measures to discourage labourers from loitering in the area and causing noise disturbance. Where possible labour shall be transported to and from the site by the contractor or his Sub- Contractors by the contractors own transport.

Bohlweki-SSI Environmental 56 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

Table 6-12: Flora

IMPACT FLORA RESPONSIBILITY FREQUENCY / (This section deals with the impact that the development will MONITORING have on flora on site and in the surrounding areas) REQUIREMENTS PHASE CONSTRUCTION ECO, ELO Weekly ENVIRONMENTAL MANAGEMENT PLAN MITIGATION Existing vegetation / METHOD 1. Existing indigenous vegetation must be retained where STATEMENT possible. 2. Development on the Bontveld area along the northern boundary of the site should not be allowed at all. Due to the available space on the proposed site, a change in layout in order to exclude this Bontveld from all construction and operational activity is regarded as feasible and necessary. 3. The actual lay-out of the site to be developed, along with the access routes and associated structures should be marked clearly with hazard tape before commencement of construction. This would allow a proper search and rescue effort to be executed. The indigenous plants within these areas should be removed to an established nursery (or one set out on the site) for use in the rehabilitation of disturbed areas after construction. The plant search and rescue operation can be done with the help of the local botanical society, NMMU (University) and Eastern Cape Nature Conservation. 4. Construction activities should be restricted to the minimum area needed. 5. A follow up vegetation survey should be conducted before site clearing to demarcate vegetation that should remain and remove and relocate any plants of botanical or ecological

Bohlweki-SSI Environmental 57 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT FLORA RESPONSIBILITY FREQUENCY / (This section deals with the impact that the development will MONITORING have on flora on site and in the surrounding areas) REQUIREMENTS significance. 6. Vegetation to be removed as it becomes necessary. 7. Materials should not be delivered to the site prematurely which could result in additional areas being cleared or affected. 8. No vegetation to be used for firewood. 9. Stormwater from within the developed site should be properly contained and should not be allowed drain off-site at all. Stormwater flow patterns after construction should be carefully controlled to prevent alteration of natural water flow patterns of the receiving vegetation downslope from the site as far as possible. 10. An alien plant control and monitoring programme must be developed starting during the construction phase and to be carried over into the operational phase. The following elements should be included in such a programme: * The active control of all alien invasive species by means of manual removal, ring-barking, chemical control or a combination of these methods. * The bigger trunks and branches should be removed while the smaller branches can be used as a soil stabiliser against wind erosion in exposed areas, while providing micro-habitat for seedling establishment. * Rehabilitation of the cleared areas, starting with the establishment of a grass cover and phasing in the re- establishment of shrub species by sowing in of appropriate seed mixes.

Bohlweki-SSI Environmental 58 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT FLORA RESPONSIBILITY FREQUENCY / (This section deals with the impact that the development will MONITORING have on flora on site and in the surrounding areas) REQUIREMENTS 11. All emergent alien plant seedlings must be removed by hand and re-sprouting from existing rootstock must be chemically treated in a continual monitoring and follow-up programme. 12. Pollution of the surface and or ground water with petrol, diesel, oil, cement, paint, litter etc., secondarily affecting the vegetation of the receiving environment must be prevented. * Construction activities should be limited to the Hazardous Waste site and servitude areas. * Movement by construction personnel outside of the demarcated development areas should be strictly prohibited. * Adequate numbers and placement of portable chemical toilet facilities at construction sites is crucial to prevent unnecessary pollution of the surrounding vegetation. A ratio of one toilet per fifteen persons is proposed. * During construction, littering, specifically of the natural areas, should be prevented. Adequate containers for litter removal should be supplied on site. These containers should be emptied on a regular basis and the contents removed to an appropriate and licensed waste disposal site. 13. During operation specific care should be taken to prevent the spread of air-blown and other litter from the site. Screening of the site with diamond mesh fences of appropriate height may help to contain most of the air-blown litter. Regular cover with soil and compaction of the waste layer should also be implemented.

Bohlweki-SSI Environmental 59 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT FLORA RESPONSIBILITY FREQUENCY / (This section deals with the impact that the development will MONITORING have on flora on site and in the surrounding areas) REQUIREMENTS 14. The risk of accidental fires to occur during the construction phase is considered to be high, especially during the dry summer months and windy periods. Fires could spread to vegetation on properties adjacent to the site, especially to the private Grassridge nature reserve which could lead loss of biodiversity. The following measures must be implemented: * Accidental fires should be prevented through proper sensitisation of the contractors and their workers towards the associated risks, dangers and damage of property. * An emergency preparedness plan should be in place to fight accidental veld fires, should they occur. The adjacent land owners/users/managers should also be informed and involved in the establishment of a Fire Protection Agency according to the Veld and Forest Fire Act. * Enclosed areas for food preparation must be provided. The use of open fires for cooking of food etc. by construction personnel should be strictly prohibited. 15. Use of branches of trees and shrubs for fire making purposes must be strictly prohibited.

Rehabilitation 16. All damaged areas shall be rehabilitated upon completion of phased construction activities in accordance with design and construction programme specifications. In accordance with the Conservation of Agricultural Resources Act, Act No 43 of 1983, slopes in excess of 2% must be contoured and slopes in excess of 12% must be terraced. Extra seed shall be sown on

Bohlweki-SSI Environmental 60 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT FLORA RESPONSIBILITY FREQUENCY / (This section deals with the impact that the development will MONITORING have on flora on site and in the surrounding areas) REQUIREMENTS disturbed areas as directed by the ECO (see below for specifications). Other methods of rehabilitating disturbed sites may also be used at the discretion of the Project Manager to comply with the conditions of the ROD and EMP, e.g. stone pitching, logging, etc. Contour banks shall be spaced according to the slopes. The type of soil shall also be taken into consideration. 17. It is recommended that any Mesic Succulent Thicket vegetation that can be stored after initial site clearance be utilised in the rehabilitation of the site. 18. To get the best results in a specific area, it is a good idea to consult with a vegetation specialist or the local Extension Officer of the Department of Agriculture. Seed distributors can also give valuable advice as to the mixtures and amount of seed necessary to seed a certain area.

Permits 19. Permits for removal of any protected species must be obtained from Provincial Nature Conservation should such species be affected.

Demarcation of construction footprint 20. All plants not interfering with the operational phases of the facility shall be left undisturbed, clearly marked and indicated on the site plan. 21. The construction footprint must be well demarcated and no construction activities must be allowed outside of this

Bohlweki-SSI Environmental 61 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT FLORA RESPONSIBILITY FREQUENCY / (This section deals with the impact that the development will MONITORING have on flora on site and in the surrounding areas) REQUIREMENTS demarcated footprint. 22. Areas which are identified by the Engineer or the ECO as being ecologically sensitive and which are adjacent to any construction work are to be suitably demarcated to prevent damage by labour and equipment. 23. Only vegetation within the servitude must be removed. 24. Vegetation removal must be phased in order to reduce impact of construction. 25. Construction site office and laydown areas must be clearly demarcated and no encroachment must occur beyond demarcated areas. 26. Strict and regular auditing of facility construction process to ensure containment of the construction servitude. 27. Where the route passes intact vegetation (but does not impact on it), a buffer zone should be established to ensure that construction activities do not extend into these areas. 28. Construction areas must be well demarcated and these areas strictly adhered to. 29. Soils must be kept free of petrochemical solutions that may be kept on site during construction. Spillage can result in a loss of soil functionality thus limiting the re-establishment of flora.

Utilisation of resources 30. Gathering of firewood, fruit, muthi plants, or any other natural material onsite or in areas adjacent to the site is prohibited unless with prior approval of the ECO.

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IMPACT FLORA RESPONSIBILITY FREQUENCY / (This section deals with the impact that the development will MONITORING have on flora on site and in the surrounding areas) REQUIREMENTS Exotic vegetation 31. All exotic vegetation must be removed from site. 32. Alien vegetation on the site will need to be controlled in terms of Government Notice R1048. 33. The contractor should be responsible for implementing a programme of weed control (particularly in areas where soil has been disturbed); and grassing of any remaining stockpiles to prevent weed invasion. 34. The spread of exotic species occurring throughout the site should be controlled.

Herbicides 35. Herbicide use shall only be allowed with the approval of Transnet and according to contract specifications. The application shall be according to set specifications and under supervision of a qualified technician. The possibility of leaching into the surrounding environment shall be properly investigated and only environmentally friendly herbicides shall be used. 36. The use of pesticides and herbicides within the servitude must be discouraged as this will impact on important pollinator species of indigenous vegetation.

Construction schedule 37. Where possible, construction should take place during winter i.e. the dormant stage to minimise impacts on vegetation during the growing season.

Bohlweki-SSI Environmental 63 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

Table 6-13: Fauna

IMPACT FAUNA RESPONSIBILITY FREQUENCY / (This section deals with the impact that the development will MONITORING have on fauna in the area) REQUIREMENTS PHASE CONSTRUCTION ECO, ELO Weekly

ENVIRONMENTAL MANAGEMENT PLAN

MITIGATION 1. The Environmental Officer (EO) for the proposed GHWMF / METHOD should be familiar with the other threatened and endemic STATEMENT fauna detailed in this report. The EO should record the presence in the area of any breeding populations or large congregations of such species, and bring these to the attention of local conservation authorities. 2. The quality of sensitive habitats, particularly Bontveld, should be monitored. Any indications of degradation, pollution or contamination of this habitat should be recorded and the causative agents identified for correction/mitigation. 3. All project actions during construction and subsequent operation of the proposed GHWMF should avoid MST and Bontveld habitat where possible. 4. GHWMF staff should be informed of the need for environmental protection, and the diverse impacts that the GHWMF activities may have on the environment. 5. Due to known presence of threatened fauna in Bontveld habitat in areas adjacent to Footprint F, and the presence of similar habitats in the northern section of Footprint F and alongside transport linkages to the proposed GHWMF, a detailed and committed conservation plan for the critically endangered Albany Adder must be implemented. The plan

Bohlweki-SSI Environmental 64 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT FAUNA RESPONSIBILITY FREQUENCY / (This section deals with the impact that the development will MONITORING have on fauna in the area) REQUIREMENTS must incorporate a similar plan for the adjacent PPC lands, on which the only known population of the Albany Adder is situated. 6. Containment of construction servitude through identified sensitive areas 7. The quality of sensitive habitats, particularly Bontveld, should be monitored. Any indications of degradation, pollution or contamination of this habitat should be recorded and the causative agents identified for correction/mitigation. 8. Demarcation of sensitive areas prior to construction activities starting. 9. Intensive environmental auditing in these areas (daily audits recommended) 10. Rehabilitation to be undertaken as soon as possible after phased construction activities in or adjacent to any sensitive area has been completed.

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Table 6-14: Employment

IMPACT EMPLOYMENT RESPONSIBILITY FREQUENCY / (This section deals with the impact that increased employment MONITORING from the development will have on the area) REQUIREMENTS PHASE CONSTRUCTION Developer, Main Weekly Contactor, ECO, ELO ENVIRONMENTAL MANAGEMENT PLAN

MITIGATION 1. The use of labour intensive construction measures should be used where appropriate. 2. Training of labour to benefit individuals beyond completion of the project 3. Labour to be sourced from the local community where possible 4. Local suppliers to be used where possible 5. The Project Manager must ensure that all staff working on the proposed project must be in possession of a South African Identity Document or a relevant work permit.

Bohlweki-SSI Environmental 66 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

Table 6-15: Waste Management

IMPACT WASTE MANAGEMENT RESPONSIBILITY FREQUENCY / (This section deals with the impact from waste produced by the MONITORING development) REQUIREMENTS PHASE CONSTRUCTION Main Contractor, Weekly ECO, ELO ENVIRONMENTAL MANAGEMENT PLAN

MITIGATION Construction rubble 1. All rubble from demolition activities must either be used on site as part of the existing development, or must be taken off the reserve and disposed off at an approved site. 2. Rubble must not be dumped on site but must be placed within a skip bin for regular removal. 3. Construction rubble shall be disposed of in pre – agreed, demarcated spoil dumps that have been approved by the relevant Municipality.

Litter management 4. Refuse bins must be placed at strategic positions to ensure that litter does not accumulate within the construction site. 5. A housekeeping team should be appointed to regularly maintain the litter and rubble situation on the construction site. 6. Waste disposal will need to take place in terms of Section 20 if the Environmental Conservation Act (Act No. 73 of 1989). 7. If possible and feasible, all waste generated on site must be separated into glass, plastic, paper, metal and wood and recycled. An independent contractor can be appointed to conduct this recycling. 8. Littering by the employees of the Contractor shall not be

Bohlweki-SSI Environmental 67 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT WASTE MANAGEMENT RESPONSIBILITY FREQUENCY / (This section deals with the impact from waste produced by the MONITORING development) REQUIREMENTS allowed under any circumstances. The ECO shall monitor the neatness of the work sites as well as the Contractor campsite. 9. Skip waste containers should be maintained on site. These should be kept covered and arrangements made for them to be collected regularly form the site by the local council. 10. All waste must be removed from the site and transported to a landfill site as approved by the relevant Municipality. 11. Waybills providing disposal at each site shall be provided to the Engineer’s inspection.

Hazardous waste 12. All waste hazardous materials must be carefully stored as advised by the ECO, and then disposed of off site at a licensed landfill site. 13. Contaminants to be stored safely to avoid spillage 14. Machinery must be properly maintained to keep oil leaks in check

Sanitation 15. The Contractor shall install mobile chemical toilets on the site. 16. Staff shall be sensitised to the fact that they should use these facilities at all times. No indiscriminate sanitary activities on site shall be allowed. 17. Ablution facilities shall be within 100m from workplaces but not closer than 50m from any natural water bodies or boreholes. There should be enough toilets available to accommodate the workforce (minimum requirement 1: 15

Bohlweki-SSI Environmental 68 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT WASTE MANAGEMENT RESPONSIBILITY FREQUENCY / (This section deals with the impact from waste produced by the MONITORING development) REQUIREMENTS workers). Male and females must be accommodated separately where possible. 18. Toilets shall be serviced regularly and the ECO shall inspect toilets regularly. 19. Toilets should be no closer than 100m or above the 1:100 year flood line from any natural or manmade water bodies or drainage lines or alternatively located in a place approved of by the Engineer. 20. Under no circumstances may open areas, neighbours fences or the surrounding bush be used as a toilet facility. 21. The construction of “Long Drop” toilets are not allowed. 22. Potable water must be provided for all construction staff.

Remedial actions 23. Depending on the nature and extent of the spill, contaminated soil must be either excavated or treated on-site. 24. Excavation of contaminated soil must involve careful removal of soil using appropriate tools/machinery to storage containers until treated or disposed of at a licensed hazardous landfill site. 25. The Environmental Managers must determine the precise method of treatment of polluted soil. This could involve the application of soil absorbent materials as well as oil-digestive powders to the contaminated soil. 26. If a spill occurs on an impermeable surface such as cement or concrete, the surface spill must be contained using oil absorbent materials.

Bohlweki-SSI Environmental 69 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT WASTE MANAGEMENT RESPONSIBILITY FREQUENCY / (This section deals with the impact from waste produced by the MONITORING development) REQUIREMENTS 27. If necessary, oil absorbent sheets or pads must be attached to leaky machinery or infrastructure. 28. Materials used for the remediation of petrochemical spills must be used according to product specifications and guidance for use. 29. Contaminated remediation materials must be carefully removed from the area of the spill so as to prevent further release of petrochemicals to the environment, and stored in adequate containers until appropriate disposal

Bohlweki-SSI Environmental 70 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

Table 6-16: Health and Safety

IMPACT HEALTH AND SAFETY RESPONSIBILITY FREQUENCY / (This section deals with the safety of workers and the public MONITORING exposed to construction hazards) REQUIREMENTS PHASE CONSTRUCTION - REFER TO SECTION S 7 AND 8 DRAFT Developer, Main Daily OPERATIONS MANUAL, AND DRAFT EMERGENCY Contractor, ECO, PREPAREDNESS MANUAL AND RESPONSE ACTION PLAN ELO ENVIRONMENTAL MANAGEMENT PLAN

MITIGATION Worker safety 1. Implementation of safety measures, work procedures and first aid must be implemented on site. 2. A health and safety plan in terms of the Occupational Health and Safety Act (Act No. 85 of 1993) must be drawn up to ensure worker safety. 3. Workers should be thoroughly trained in using potentially dangerous equipment 4. Contractors must ensure that all equipment is maintained in a safe operating condition. 5. A safety officer must be appointed. 6. A record of health and safety incidents must be kept on site. 7. Any health and safety incidents must be reported to the project manager immediately. 8. First aid facilities must be available on site at all times. 9. Workers have the right to refuse work in unsafe conditions. 10. A record shall be kept of drugs administered or precautions taken and the time and dates when this was done. This can then be used as evidence in court should any claims be instituted against the Contractor. 11. The contractor must ensure that all construction workers are well educated about HIV/ AIDS and the risks surrounding this

Bohlweki-SSI Environmental 71 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT HEALTH AND SAFETY RESPONSIBILITY FREQUENCY / (This section deals with the safety of workers and the public MONITORING exposed to construction hazards) REQUIREMENTS disease. The location of the local clinic where more information and counselling is offered must be indicated to workers. 12. Material stockpiles or stacks must be stable and well secured to avoid collapse and possible injury to site workers / local residents.

Worker facilities 13. Eating areas should be regularly serviced and cleaned to ensure the highest possible standards of hygiene and cleanliness 14. Fires are not to be allowed.

Protective gear 15. Personal Protective Equipment (PPE) must be made available to all construction staff and must be compulsory. Hard hats and safety shoes must be worn at all times and other PPE worn were necessary i.e. dust masks, ear plugs etc. 16. No person is to enter the site without the necessary PPE. 17. SABS Standards and specifications governing dangerous processes such as welding must be strictly applied, with a view to proper protection of the public and workers.

Site safety 18. The construction camp must remain fenced for the entire construction period. 19. Potentially hazardous areas such as trenches are to be

Bohlweki-SSI Environmental 72 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT HEALTH AND SAFETY RESPONSIBILITY FREQUENCY / (This section deals with the safety of workers and the public MONITORING exposed to construction hazards) REQUIREMENTS demarcated and clearly marked 20. Adequate warning signs of hazardous working areas. 21. Uncovered manholes and excavations must be clearly demarcated 22. Emergency numbers for local police and fire department etc must be placed in a prominent area. 23. Fire fighting equipment must be placed in prominent positions across the site where it is easily accessible. This includes fire extinguishers, a fire blanket as well as a water tank. 24. Suitable conspicuous warning signs in English and all other applicable languages must be placed at all entrances to the site. 25. All speed limits must be adhered to.

Construction equipment safety 26. All equipment used for construction must be in good working order with up to date maintenance records.

Hazardous Material Storage 27. Staff that will be handling hazardous materials must be trained to do so. 28. Any hazardous materials (apart from fuel) must be stored within a lockable store with a sealed floor. 29. All storage tanks containing hazardous materials must be placed in bunded containment areas with sealed surfaces. The bund walls must be high enough to contain 110% of the total volume of the stored hazardous material.

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IMPACT HEALTH AND SAFETY RESPONSIBILITY FREQUENCY / (This section deals with the safety of workers and the public MONITORING exposed to construction hazards) REQUIREMENTS 30. Material Safety Data Sheets (MSDS) which contain the necessary information pertaining to a specific hazardous substance must be present for all hazardous materials stored on the site. 31. The bund walls for the transformer oil containers must be in place before the installation of these containers. 32. The provisions of the Hazardous Chemical Substances Regulations promulgated in terms of the Occupational Health and Safety Act 85 of 1993 and the SABS Code of Practise must be adhered to. This applies to solvents and other chemicals possibly used in the construction time.

Procedure in the event of a petrochemical spill 33. The individual responsible for or who discovers the petrochemical spill must report the incident to the Project Manager, ECO or Contractor. 34. The problem must be assessed and the necessary actions required will be undertaken. 35. The immediate response must be to contain the spill. 36. The source of the spill must be identified, controlled, treated or removed.

Fire management 37. Fire fighting equipment should be present on site at all times as per OHSA. 38. All construction staff must be trained in fire hazard control and fire fighting techniques.

Bohlweki-SSI Environmental 74 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT HEALTH AND SAFETY RESPONSIBILITY FREQUENCY / (This section deals with the safety of workers and the public MONITORING exposed to construction hazards) REQUIREMENTS 39. All flammable substances must be stored in dry areas which do not pose an ignition risk to the said substances. 40. No open fires will be allowed on site. 41. Smoking may only be conducted in demarcated areas.

Safety of surrounding residents 42. All I & AP’s should be notified in advance of any known potential risks associated with the construction site and the activities on it. Examples of these are: * Blasting * Earthworks / earthmoving machinery on steep slopes above infrastructure * Risk to residence along haulage roads / access routes

Bohlweki-SSI Environmental 75 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

Table 6-17: Security

IMPACT SECURITY RESPONSIBILITY FREQUENCY / (This section deals with issues of security during construction for MONITORING workers and surrounding land users) REQUIREMENTS PHASE CONSTRUCTION - REFER TO SECTION 11 DRAFT Main Contractor, Weekly OPERATIONS MANUAL ELO ENVIRONMENTAL MANAGEMENT PLAN

MITIGATION 1. Access to the construction site should be strictly controlled by a security company. 2. 24 hour security on-site. 3. Labour should be transported to and from the site to discourage loitering in adjacent areas and possible increase in crime or disturbance. 4. Unsocial activities such as consumption or illegal selling of alcohol, drug utilisation or selling and prostitution on site should be prohibited. Any persons found to be engaged in such activities shall receive disciplinary or criminal action taken against them. 5. Other than pre-approved security staff, no workers shall be permitted to live on the construction site. 6. The site shall be fenced (where necessary) to prevent any loss or injury to persons, game or livestock during the construction phase. 7. If any fencing interferes with the construction process, such fencing shall be deviated until construction is completed. The deviation of fences shall be negotiated and agreed with the landowner in writing. 8. No alcohol / drugs to be present on site. 9. No firearms allowed on site or in vehicles transporting staff to / from site (unless used by security personnel).

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IMPACT SECURITY RESPONSIBILITY FREQUENCY / (This section deals with issues of security during construction for MONITORING workers and surrounding land users) REQUIREMENTS 10. No harvesting of firewood from the site or from the residential and business properties adjacent to it. 11. Construction staff is to make use of the facilities provided for them, as opposed to ad-hoc alternatives (e.g. fires for cooking, the use of surrounding bush as a toilet facility are forbidden). 12. Trespassing on private / commercial properties adjoining the site is forbidden. 13. Driving under the influence of alcohol is prohibited. 14. All employees must undergo the necessary safety training and wear the necessary protective clothing. 15. Secure the site in order to reduce the opportunity for criminal activity in the locality of the construction site

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Table 6-18: Social Environment

IMPACT SOCIAL ENVIRONMENT RESPONSIBILITY FREQUENCY / (This section deals with the social impacts that the new MONITORING development will have on the site and surrounds) REQUIREMENTS PHASE CONSTRUCTION Developer, Main Bi-Monthly Contractor, SM, ECO ENVIRONMENTAL MANAGEMENT PLAN

MITIGATION 1. All contact with the affected parties shall be courteous at all times. The rights of the affected parties shall be respected at all times. 2. A complaints register should be kept on site. Details of complaints should be incorporated into the audits as part of the monitoring process. This should be in carbon copy format, with numbered pages. Any missing pages must be accounted for by the Contractor. This register is to be tabled during monthly site meetings. 3. During the setup phase of the project the Contractor needs to make contact with those people that are Interested in or Affected by the development (I & AP’s). The contractor will notify adjacent neighbours and inform them of the intended development. He will also inform neighbours that a complaints register will be available on site. 4. No interruptions other than those negotiated shall be allowed to any essential services. Damage to infrastructure shall not be tolerated and any damage shall be rectified immediately by the Contractor. A record of all damage and remedial actions shall be kept on site. 5. All existing private access roads used for construction purposes,

Bohlweki-SSI Environmental 78 June 2010 Draft Environmental Management Plan (EMP) for the Regional General and Hazardous Waste Management Facility in the Eastern Cape

IMPACT SOCIAL ENVIRONMENT RESPONSIBILITY FREQUENCY / (This section deals with the social impacts that the new MONITORING development will have on the site and surrounds) REQUIREMENTS shall be maintained at all times to ensure that the local people have free access to and from their properties. Speed limits shall be enforced in such areas and all drivers shall be sensitised to this effect. 6. Any possible disruptions to essential services must be kept to a minimum and should be well advertised and communicated to the Landowners and surrounding Communities. Care must be taken not to damage irrigation equipment, lines, channels and crops, as this could lead to major claims being instituted against the Developer and the Contractor. The position of all facilitys and irrigation lines in the vicinity of a site must be obtained from the Landowners or local Community and clearly marked. Where required such lines shall be deviated. SITE SPECIFIC MITIGATION

Resettlement 7. Residents on site must be assisted with the relocation process. 8. The land valuator should be experienced in valuating the land in question. 9. Both parties should have the option to have contracts reviewed by an independent body. A formal grievance procedure should be implemented and communicated to these residents to ensure a fair and transparent process. Roads 10. Road rehabilitation should take place during and once construction is completed where required. 11. Construction traffic should only make use of an approved route. 12. The number of trucks that pass through communities should

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IMPACT SOCIAL ENVIRONMENT RESPONSIBILITY FREQUENCY / (This section deals with the social impacts that the new MONITORING development will have on the site and surrounds) REQUIREMENTS be kept to a minimum and should be restricted to certain times of the day, i.e. avoid peak hours when community members are on their way to or from school and work. 13. Traffic signs should warn construction vehicles of the presence of pedestrians and school children along the road. 14. General road rules must be enforced. 15. Implement traffic flow controls where road closure or partial road closure is unavoidable. This can either be in the form of providing alternative access routes via detours and/or the use of 1-way traffic flow control. 16. In the event of 1-way traffic flow control, trained personnel should be used to regulate the traffic to prevent severe delays at waiting points. Influx of 17. Raise awareness amongst construction workers about local construction traditions and practices. workers 18. Depending on the size and origin of construction workers, inform local businesses to the fact that construction workers will move into the area to enable local businesses to plan for the extra demand. 19. Ensure that the local community communicate their expectations of construction workers’ behaviour with them. Influx of job 20. Ensure that employment procedures / policy are seekers communicated to local stakeholders, especially community representative organisations and ward councillors. 21. Have clear rules and regulations for access to the camp / site office to control loitering. Consult with the local SAPS to establish standard operating procedures for the control and/or

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IMPACT SOCIAL ENVIRONMENT RESPONSIBILITY FREQUENCY / (This section deals with the social impacts that the new MONITORING development will have on the site and surrounds) REQUIREMENTS removal of loiterers at the construction site. 22. Construction workers should be clearly identifiable by wearing proper construction uniforms displaying the logo of the construction company. Construction workers could also be issued with identification tags. Outflow of 23. Implement methods (posters, talks, etc.) to create HIV and labourers STI awareness amongst construction workers. 24. Develop skills transfer plans (e.g. portable skills training) that would enable a worker to move from one project to another project within the same area. 25. Payment should comply with applicable Labour Law legislation in terms of minimum wages. 26. Where local labourers are employed on a more permanent basis, cognisance should be taken of the Labour Law in terms of registering the worker with the Unemployment Insurance Fund (UIF), Pay as you earn (PAYE), workman’s compensation and all other official bodies as required by law. This would enable the worker to claim UIF as a means of continuous financial support when the worker’s position on the construction team has either become redundant or once the construction phase comes to an end. Direct formal 27. Unskilled job opportunities should be afforded to local employment community members. Local trade unions could assist with the opportunities recruitment process to counteract the potential for social for local mobilisation. individuals 28. Equal opportunities for employment should be created to ensure that the local female population also have access to

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IMPACT SOCIAL ENVIRONMENT RESPONSIBILITY FREQUENCY / (This section deals with the social impacts that the new MONITORING development will have on the site and surrounds) REQUIREMENTS these opportunities. Females should be encouraged to apply for positions. 29. Individuals with the potential to develop their skills should be afforded training opportunities. Transnet Facilitys should be involved in this process. 30. Mechanisms should be developed to provide alternative solutions for creating job security upon completion of the project. This could include formal and/or informal training on how to look for alternative employment, information on career progression, etc. to ensure that people are equipped to seek other jobs with the skills that they have gained. 31. Payment should comply with applicable Labour Law legislation in terms of minimum wages. 32. Where local labourers are employed on a more permanent basis, cognisance should be taken of the Labour Law in terms of registering the worker with the Unemployment Insurance Fund (UIF), Pay as you earn (PAYE), workman’s compensation and all other official bodies as required by law. This would enable the worker to claim UIF as a means of continuous financial support when the worker’s position on the construction team has either become redundant or once the construction phase comes to an end. Indirect formal 33. Develop a procurement policy that is easy to understand and and/or ensure that local subcontractors also comply with the informal procurement policy and any other applicable policies. employment 34. Ensure that local subcontractors receive the necessary support opportunities in terms of resources.

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IMPACT SOCIAL ENVIRONMENT RESPONSIBILITY FREQUENCY / (This section deals with the social impacts that the new MONITORING development will have on the site and surrounds) REQUIREMENTS for local 35. Agree on specific performance criteria prior to appointment. individuals 36. Identify the segment that might benefit from informal indirect opportunities, and assist them with skills development and subsidise initiatives that are sustainable. 37. Encourage construction workers to use local services. 38. Consider housing construction workers in local communities. Attitude 39. Transparent information should be supplied to the community formation from the outset of the project. against the 40. The local community should play an active participatory role in project the planning process, especially landowners of neighbouring properties. This could be achieved by means of establishing a community forum that meet quarterly or once a month to discuss issues and progress surrounding the project. 41. Employment opportunities should first be offered to the local community if the skills are available within the community. 42. CDC/NMBM should deliver on their undertakings with the community in terms of employment creation, etc. (tangible benefits to the community). 43. The undertakings in the EMP should also be implemented effectively and with due diligence. Additional 44. Construction workers should be made aware of the limited demand on capacity of the municipal services network. municipal 45. Negotiations with the affected local municipalities must be services conducted and a “demand-side management” should be implemented. 46. Construction camps should be located away from areas of concern.

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IMPACT SOCIAL ENVIRONMENT RESPONSIBILITY FREQUENCY / (This section deals with the social impacts that the new MONITORING development will have on the site and surrounds) REQUIREMENTS Disaster 47. Integrate risk management programmes with the IDP. Management 48. Establish disaster prevention programmes that focus on the Plan most vulnerable communities – and, at the same time, support sustainable livelihoods. 49. Establish and maintain fire protection on the facility fringe. 50. Establish a culture of scientific risk analysis by investigating possible risk scenarios and developing standard operating procedures for such scenarios. 51. Establish and maintain multi-disciplinary co-operation and cooperative partnerships. 52. Establish pro-active media liaison. 53. Educate and inform surrounding communities and/or households on the standard operating procedures to follow during accidents. Ensure that these communities and/or households know who to contact in case of an emergency and are able to implement a step-by-step disaster management procedure. 54. The way in which the disaster management plan is communicated to the surrounding communities and/or households should be jargon-free and outline an easy to follow step-by-step procedure. Cognisance should be taken of the fact that some members of the surrounding communities and/or households are illiterate – make use of alternative communication methods (e.g. picture posters) to educate and inform these individuals. Pollution and 55. Sufficient portable chemical toilets on site and at the fire risk construction village.

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IMPACT SOCIAL ENVIRONMENT RESPONSIBILITY FREQUENCY / (This section deals with the social impacts that the new MONITORING development will have on the site and surrounds) REQUIREMENTS 56. Refuse on site should be discarded in sealed bins and/or covered skips. Refuse should be removed from the site on regular intervals (at least once a week) and disposed of at an approved waste disposal site. 57. Contractors are liable for the costs involved with connecting to the electricity network and the water services network. 58. Construction workers should only be allowed to make fire in designated areas. Construction workers who do not keep within designated areas should be fined. Sanitation 59. Construction workers should receive medical advise regarding correct sanitation and receive correct medical attention where required. 60. Adequate water facilities should be provided. 61. Sufficient portable chemical toilets on site and at the construction village. 62. Adequate sanitation services (e.g. showers) at the construction camp with effective drainage facilities to ensure that used water is carried away from the site. Sense of place 63. Sufficient and transparent information should be supplied to local residents within the area to enhance their sense of safety and thereby reducing the negative impact on sense of place. 64. An information session with the construction workers and representatives from the local areas (farmers, Motherwell/Uitenhage residents associations) should be held prior to the start of construction. Local traditions, mitigation measures, and expectations should be discussed. The ECO will be responsible for organising this meeting. If need be, these

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IMPACT SOCIAL ENVIRONMENT RESPONSIBILITY FREQUENCY / (This section deals with the social impacts that the new MONITORING development will have on the site and surrounds) REQUIREMENTS meetings should be held throughout the construction period. 65. The undertakings in the EMP should also be implemented effectively and with due diligence. The ECO should ensure that social mitigation measures are implemented, and give monthly feedback to the representative residents associations. 66. Establish a formal grievances procedure: * Start addressing these grievances within 24 hours. * Keep record of complaints and how they were dealt with. * Keep record of feedback to the complainant. * Minimise complaints received / litigation. * No conflict between the project team and construction workers and the local inhabitants. Integration 67. An aggressive STI and HIV/AIDS awareness campaign should with local be launched, which is not only directed at construction community workers but also at the community as a whole. 68. Condoms should be distributed by placing them at centrally located points and by ensuring that construction workers and community members are aware of the availability and location of condoms. The distribution of condoms should be approached with the necessary cultural sensitivity. 69. Access at the construction site should be controlled to prevent sex workers from either visiting and/or loitering at the construction village. 70. Local women should be empowered. This could be achieved by employing them to work on the project, which in turn would decrease their (financial) vulnerability.

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Table 6-19: Visual Impact

IMPACT VISUAL IMPACT RESPONSIBILITY FREQUENCY / (This section deals with the visual impact that the new MONITORING development will have on the site and surrounds) REQUIREMENTS PHASE CONSTRUCTION Main Contractor, Monthly ELO, ECO ENVIRONMENTAL MANAGEMENT PLAN

MITIGATION 1. The potential screening of the facility, through the strategic placement of vegetation at the areas of highest impact,

should be investigated and implemented. The placement of site infrastructure and associated buildings must be carefully planned to further reduce unnecessary visual clutter. Soften impact by use of landscaping, planting trees 2. Fencing of the site will also aid in reducing the visual impact of construction. 3. Cluster construction activities on site where possible. 4. Storage facilities, elevated tanks and other temporary structures on site should be located such that they have as little visual impact on local residents as possible. 5. Material chosen to blend in with the surrounding environment 6. Unwanted material and litter should be removed on a frequent basis 7. Lighting of the facility should be designed to contain, rather than spread the light, and avoid potential visual impacts at night. This would apply to security lighting and operational lighting, should the facility function at night. Lighting must be subtle and not disturb passing motorists and surrounding residents. Lighting should be inward and downward facing. 8. The site shall be kept visually and aesthetically pleasing, especially in and around the Contractor camp. The ECO shall

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IMPACT VISUAL IMPACT RESPONSIBILITY FREQUENCY / (This section deals with the visual impact that the new MONITORING development will have on the site and surrounds) REQUIREMENTS regularly inspect the site to ensure that it is neat and clean. 9. Where required the campsite shall be screened by the Contractor to ensure that there is no unacceptable visual intrusion in the area of the site. Screening can be done by use of shade-cloth. 10. Reduce the construction period through careful planning and productive implementation of resources. 11. Restrict the activities and movement of construction workers and vehicles to the immediate construction site. 12. Ensure that the general appearance of construction activities, construction camps (if required) and lay-down areas are maintained by means of the timely removal of rubble and disused construction materials. 13. Restrict construction activities to daylight hours (where possible) in order to negate or reduce the visual impacts associated with lighting.

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Table 6-20: Cultural and Heritage Artefacts

IMPACT CULTURAL AND HERITAGE ARTEFACTS RESPONSIBILITY FREQUENCY / (This section deals with the impact that the new development has MONITORING on potential archaeological artefacts of the site) REQUIREMENTS PHASE CONSTRUCTION Main Contractor, Monthly ECO, ELO ENVIRONMENTAL MANAGEMENT PLAN

MITIGATION 1. Any finds must be reported to the nearest National Monuments office to comply with the National Heritage Resources Act (Act No 25 of 1999) and to DWEA. 2. Local museums as well as the South African Heritage Resource Agency (SAHRA) should be informed if any artefacts are uncovered in the affected area. 3. The contractor must ensure that his workforce is aware of the necessity of reporting any possible historical or archaeological finds to the ECO so that appropriate action can be taken. 4. Any discovered artefacts shall not be removed under any circumstances. Any destruction of a site can only be allowed once a permit is obtained and the site has been mapped and noted. Permits shall be obtained from the South African Heritage Resources Association (SAHRA) should the proposed site affect any world heritage sites or if any heritage sites are to be destroyed or altered. 5. Should any archaeological sites and/or graves be uncovered during construction, their existence shall be reported to the Developer immediately.

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Environmental Management Plan: Operational Phase

Table 7-1: Construction Site Decommissioning

IMPACT CONSTRUCTION SITE DECOMMISSIONING RESPONSIBILITY FREQUENCY / MONITORING REQUIREMENTS PHASE OPERATION Main Contractor, Weekly Developer, ECO, ELO ENVIRONMENTAL MANAGEMENT PLAN

MITIGATION Construction Camp 1. All structures comprising the construction camp are to be removed from site. 2. The area that previously housed the construction camp is to be checked for spills of substances such as oil, paint, etc, and these shall be cleaned up. 3. Once construction has been completed on site and all excess material has been removed, the storage area shall be rehabilitated. All hardened surfaces within the construction camp area should be ripped, all imported materials removed, and the area shall be top soiled and regressed using the guidelines as set out in the section on Flora and Fauna that forms part of this document. If the area was badly damaged, re-seeding shall be done and fencing in of the area shall be considered if there is likely to be free access to such an area.

Temporary services 4. The Contractor must arrange the cancellation of all temporary

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IMPACT CONSTRUCTION SITE DECOMMISSIONING RESPONSIBILITY FREQUENCY / MONITORING REQUIREMENTS services. 5. Copies of all weigh bridge certificates from waste disposed are to be presented to the ECO. 6. Temporary roads must be closed and access across these, blocked. 7. All areas where temporary services were installed are to be rehabilitated to the satisfaction of the ECO.

Associated infrastructure 8. Surfaces are to be checked for waste products from activities such as concreting or asphalting and cleared in a manner approved by the Engineer. 9. All surfaces hardened due to construction activities are to be ripped and imported material thereon removed. 10. All rubble is to be removed from the site to an approved disposal site as approved by the Engineer. Burying of rubble on site is prohibited. 11. The site is to be cleared of all litter. 12. The Contractor is to check that all watercourses/drainage lines are free from building rubble, spoil materials and waste materials. 13. Fences, barriers and demarcations associated with the construction phase are to be removed from the site unless stipulated otherwise by the Engineer. 14. All residual stockpiles must be removed to spoil or spread on site as directed by the Engineer. 15. All leftover building materials must be returned to the depot

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IMPACT CONSTRUCTION SITE DECOMMISSIONING RESPONSIBILITY FREQUENCY / MONITORING REQUIREMENTS or removed from the site. 16. The Contractor must repair any damage that the construction works has caused to neighbouring properties, specifically, but not limited to, damage caused by poor storm water management.

Borrow pits 17. Borrow pits are to be closed and rehabilitated in accordance with the DME approved mining permits/rights.

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Table 7-2: Surface and Groundwater

IMPACT SURFACE AND GROUNDWATER RESPONSIBILITY FREQUENCY / MONITORING REQUIREMENTS PHASE OPERATION - REFER TO SECTIONS 13.5-13.6, 17.2-17.4 Developer Bi-Annually AND 17.11-17.12 OF DRAFT OPERATIONS MANUAL ENVIRONMENTAL MANAGEMENT PLAN

MITIGATION Surface water / METHOD 1. Correct drainage of the site should ensure that contaminants STATEMENT and contaminated stormwater flow do impact upon surface water. All contaminated storm water flows are to be channelled and impounded in the proposed stormwater dams. No sensitive surface water features are however present on the site. 2. The stormwater system on the proposed site needs to be regularly maintained to ensure effective working.

Waste management 3. Management must ensure that solid waste collection and sanitation is managed effectively in order to avoid any chances of ground and surface water pollution.

Borehole monitoring 4. Monitoring boreholes and protocols must be implemented as agreed to by DWEA as part of the licensing process to detect any possible contamination as early as possible.

Leachate Generation 5. Leachate generation must be minimised through proper landfill management and control of ratio between liquid and solid

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IMPACT SURFACE AND GROUNDWATER RESPONSIBILITY FREQUENCY / MONITORING REQUIREMENTS waste disposed in each cell. Proper control of leachate seepage and collection thereof and diverting to properly designed holding dam and/or treatment facility to the south of the site.

Leachate-Stormwater Dams / Impoundments 6. The confluence of the system is in the south eastern corner of the site where the diversion trenches meet in a drop inlet formed from manhole rings. The drop inlet leads to a pipe that connects the drainage system to the contaminated storm water dam south of the site. Regular inspection and maintenance is necessary for this system. 7. The monitoring of leachate quality and quantity will take place during the first year of operation, treatability tests, design and pilot treatment studies will take place in the second year, and the leachate treatment plant will be constructed and commissioned by the middle of the third year of operation. It would be an advantage to design a modular system that can easily be expanded as the need arises, given current uncertainties in the expected waste stream composition. The leachate dam would then continue to provide sufficient buffer capacity to accommodate seasonal peaks in order to match the rate of treatment.

Cell Capping 8. Proper capping of each cell and regular maintenance of these capped cells according to permit conditions to avoid infiltration of rainwater and thus leachate generation within the waste

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IMPACT SURFACE AND GROUNDWATER RESPONSIBILITY FREQUENCY / MONITORING REQUIREMENTS pile. Installation of a leachate level monitoring facility for each cell monitoring point is required.

Monitoring and Reporting 9. A formal monitoring and reporting strategy/protocol should be developed for monitoring the integrity of the different water resources potentially affected by the GHWMF. This should include any ongoing rehabilitation measures initiated in the construction phase. 10. Specific activities that should be monitored include: * Erosion potential (specifically in and around roads and storm-water discharge points). * Stormwater management and design * Groundwater borehole monitoring * Identified problem areas 11. Resource-directed measures and any other monitoring requirements as stipulated by DWEA should be included in the monitoring programme.

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Table 7-3: Air Quality

IMPACT AIR QUALITY RESPONSIBILITY FREQUENCY / MONITORING REQUIREMENTS PHASE OPERATION Developer Annually ENVIRONMENTAL MANAGEMENT PLAN

MITIGATION Dust management 1. Any dirt roads that are utilised by the Developer to access the pipe line must be regularly maintained to ensure that dust levels are controlled. 2. The proposed GHWMF operator should control on-site fugitive dust emissions by effective management and mitigation. At least 75% dust control efficiency is required on unpaved roads to ensure dustfall rates are reduced to the levels predicted. 3. The haul roads going to and from the site as well as on-site were identified as a significant source of dust emissions. Three types of measures may be taken to reduce emissions from unpaved roads: * measures aimed at reducing the extent of unpaved roads, e.g. paving, * traffic control measures aimed at reducing the entrainment of material by restricting traffic volumes and reducing vehicle speeds, and * measures aimed at binding the surface material or enhancing moisture retention, such as wet suppression and chemical stabilization 4. It is recommended that gravimetric sampling for PM10 be done using portable mini high-volume samplers. These are

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battery-driven and take a composite sample over 24 h. If sampling is carried out every third day (including week- ends) a sample series without systematic error, yet not too labour-intensive is built up. 5. It is recommended that at least four deposition gauges be placed on the landfill site perimeter. The recorded wind field suggests that the dustfall gauges should be situated to the north-eastern, south-eastern, south-western and north- western boundaries of the site. 6. It is also recommended that PM10 and dustfall levels be monitored in order to: * confirm the predicted air quality impacts associated with activities from the landfill site; * assess compliance of landfill emissions and associated impacts with current air quality standards; * determine source contributions to ambient air quality in order to prioritise mitigation measures; * assess the efficiency of mitigation measures 7. Control measures that can be applied to reduce fugitive dust emissions from exposed surfaces include the use of vegetation cover. Vegetal cover retards erosion by binding the residue with a root network, by sheltering the residue surface and by trapping material already eroded. Vegetation is also considered the most effective control measure in terms of its ability to also control water erosion. In investigating the feasibility of vegetation types the following properties are normally taken into account: indigenous plants; ability to establish and regenerate quickly; proven effective for reclamation elsewhere; tolerant to the climatic conditions of the area; high rate of root production; easily

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propagated by seed or cuttings; and nitrogen-fixing ability. 8. Wheel washing and damping down of un-surfaced and un- vegetated areas 9. Retention of vegetation where possible will reduce dust travel 10. Excavations and other clearing activities must only be done during agreed working times and permitting weather conditions to avoid drifting of sand and dust into neighbouring areas. 11. Damping down of all exposed soil surfaces with a water bowser or sprinklers when necessary to reduce dust. 12. Blasting must be carried out in accordance with legislation using optimal and not excessive quantities of explosives. Blasting should only occur on calm days in order to reduce dust carry. The geotechnical report indicated that the probability of blasting is low. 13. The Contractor shall be responsible for dust control on site to ensure no nuisance is caused to the Landowner or neighbouring Communities. 14. A speed limit of 30km/h must not be exceeded. 15. Any complaints or claims emanating from the lack of dust control shall be attended to immediately by the Contractor.

Odour control 16. Regular servicing of vehicles in order to limit gaseous emissions (to be done off-site). 17. Regular servicing of on site toilets to avoid potential odours. 18. Allocated cooking areas must be provided. 19. The contractor must make alternative arrangements (other than fires) for cooking and / or heating requirements. LP

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gas cookers may be used provided that all safety regulations are followed.

Rehabilitation 20. The contractor should commence rehabilitation of exposed soil surfaces as soon as practical after completion of earthworks.

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Table 7-4: Noise

IMPACT NOISE RESPONSIBILITY FREQUENCY / MONITORING REQUIREMENTS PHASE OPERATION Developer Annually

ENVIRONMENTAL MANAGEMENT PLAN

MITIGATION 1. Although the proposed GHWMF is sited far from any residential settlement the following generic noise mitigation measures must be adhered to. 2. The operational phase must aim to adhere to the relevant noise regulations and limit noise to within standard working hours in order to reduce disturbance. 3. Noisy operations should be combined so that they occur where possible at the same time. 4. No pure tone sirens or hooters may be utilised except where required in terms of SABS standards or in emergencies. 5. It must be ensured that their working conditions comply with the requirements of the Occupational Health and Safety Act (Act No 85 of 1993). Where necessary ear protection gear should be worn. 6. Noise suppression measures must be applied to all operational equipment. Equipment must be kept in good working order and where appropriate fitted with silencers which are kept in good working order. Should the vehicles or equipment not be in good working order, the contractor may be instructed to remove the offending vehicle or machinery from site.

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Table 7-5: Biodiversity

IMPACT BIODIVERSITY (FAUNA AND FLORA) RESPONSIBILITY FREQUENCY / MONITORING REQUIREMENTS PHASE OPERATION Developer Monthly in rehabilitation phase, quarterly thereafter ENVIRONMENTAL MANAGEMENT PLAN

MITIGATION Flora / METHOD 1. Indigenous vegetation must be maintained and all exotics STATEMENT removed as they appear and disposed off appropriately. 2. Re-vegetation of the disturbed site is aimed at approximating as near as possible the natural vegetative conditions prevailing prior to construction. 3. All natural areas impacted during construction must be rehabilitated with locally indigenous grasses typical of the representative botanical unit. 4. Rehabilitation must take place as soon as construction is complete to avoid the edge effect, the infiltration of alien species and soil erosion within the servitude. 5. Rehabilitation process must make use of species indigenous to the area. Seeds from surrounding seed banks can be used for re-seeding. Vegetative re-establishment shall, as far as possible, make use of indigenous or locally occurring plant varieties within a 20-metre radius of the site. 6. After completion of construction, all access roads that will not be used during the operational phase, should be

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IMPACT BIODIVERSITY (FAUNA AND FLORA) RESPONSIBILITY FREQUENCY / MONITORING REQUIREMENTS rehabilitated and re-vegetated if necessary to blend in with the surrounding vegetation. 7. Rehabilitation must be executed in such a manner that surface run-off will not cause erosion of disturbed areas during and following rehabilitation. 8. There has been little research done with regard to how successfully MST can be fully rehabilitated. However, there is also a degree of confusion over habitat from a faunal and floristic perspective. The continued presence of so many faunal groups in degraded MST habitat shows that ‘functional rehabilitation’ is possible, even if recovery of full floristic diversity may be very difficult or take a long time. Accordingly, the impact can be partially mitigated by avoiding direct loss of intact MST and Bontveld habitat. All project actions during construction and subsequent operation of the proposed GHWMF should avoid MST and Bontveld habitat where possible. After closure of the facility all habitats, where possible, should be rehabilitated to the existing vegetation type. This is probably attainable for MST, at least in terms of functional rehabilitation for faunal groups, but Bontveld is a growth form dependent upon the underlying limestone pavement, and once this has been removed it cannot be re-habilitated. 9. Accidental fires should be prevented through proper sensitisation of the contractors and their workers towards the associated risks, dangers and damage of property.

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IMPACT BIODIVERSITY (FAUNA AND FLORA) RESPONSIBILITY FREQUENCY / MONITORING REQUIREMENTS 10. An emergency preparedness plan should be in place to fight accidental veld fires, should they occur. The adjacent land owners/users/managers should also be informed and involved in the establishment of a Fire Protection Agency according to the Veld and Forest Fire Act.

Fauna 11. No faunal species must harmed by maintenance staff during any routine operations at the GHWMF. Rehabilitation of faunal diversity on closure of the proposed GHWMF will require habitat corridors along which fauna can migrate from refugia retaining original fauna. The license holder or operator of the proposed RGHWMF should therefore integrate their EMP, particularly for threatened species (e.g. the Albany Adder) with neighbouring properties to ensure successful faunal rehabilitation on closure. 12. Due to known presence of threatened fauna in Bontveld habitat in areas adjacent to Footprint F, and the presence of similar habitats in the northern section of Footprint F and alongside transport linkages to the proposed RGHWMF, a detailed and committed conservation plan for the critically endangered Albany Adder must be implemented. The plan must incorporate a similar plan for the adjacent PPC lands, on which the only known population of the Albany Adder is situated. 13. The Environmental Officer (EO) for the proposed GHWMF

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IMPACT BIODIVERSITY (FAUNA AND FLORA) RESPONSIBILITY FREQUENCY / MONITORING REQUIREMENTS should be familiar with the other threatened and endemic fauna detailed in this report. The EO should record the presence in the area of any breeding populations or large congregations of such species, and bring these to the attention of local conservation authorities. 14. The quality of sensitive habitats, particularly Bontveld, should be monitored. Any indications of degradation, pollution or contamination of this habitat should be recorded and the causative agents identified for correction/mitigation. The RGHWMF operation will be limited to the site. However, off-site impacts will occur on the proposed access roads. These secondary impacts must be monitored to assess whether potential cumulative effects may need to be addressed.

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Table 7-6: Waste Management

IMPACT WASTE MANAGEMENT RESPONSIBILITY FREQUENCY / MONITORING REQUIREMENTS PHASE OPERATION Developer Monthly when conduction / and or maintenance is required ENVIRONMENTAL MANAGEMENT PLAN

MITIGATION Waste management (if this is required on the site) 1. Solid waste separation and recycling should take place for the duration of the operational phase for the development. 2. All waste must be removed promptly to ensure that it does not attract vermin or produce odours.

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Table 7-7: Health and Safety

IMPACT HEALTH AND SAFETY RESPONSIBILITY FREQUENCY / MONITORING REQUIREMENTS PHASE OPERATION- REFER TO SECTION S 7 AND 8 OF THE DRAFT Developer Daily OPERATIONS MANUAL AND THE DRAFT EMERGENCY PREPAREDNESS MANUAL AND RESPONSE ACTION PLAN ENVIRONMENTAL MANAGEMENT PLAN

MITIGATION Emergency evacuation plan 1. Upon completion of the construction phase, an emergency evacuation plan must be drawn up to ensure the safety of the staff and surrounding land users in the case of an emergency. An emergency evacuation plan should be drafted together with the NMBM. 2. All permanent staff must undergo safety training.

Maintenance 3. The facility is to be regularly maintained. A maintenance schedule must be drawn up and records of all maintenance kept.

Fire safety 4. Fire fighting equipment in the form of fire hydrants or fire extinguishers must be available on the site. These must be regularly maintained by an appropriate company.

Transport, Storage and handling of hazardous waste 5. Educate local communities on the safety risks of the hazardous

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IMPACT HEALTH AND SAFETY RESPONSIBILITY FREQUENCY / MONITORING REQUIREMENTS waste spillage and how to minimise the risk. This should be included in the emergency and prevention plans that should be communicated to the community and can be done by distributing pamphlets, having open days for the public, etc. 6. Trucks should be clearly marked as carrying hazardous waste. Part of this marking should include where the waste originated from together with a contact number that community members can contact in the case of an emergency. Transport of all hazardous substances must be in accordance with the relevant legislation. 7. Oil containers must be regularly maintained to ensure that leaks do not occur. A spill kit needs to be kept on site to address any unforeseen spillages. 8. The bund wall surrounding transformer oil containers (if present) must be regularly maintained to ensure that any spills are completely contained.

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Environmental Management Plan: Decommissioning Phase

At this stage the date of decommissioning of the GHWMF is not known and is unlikely to occur within the next 20 years. The mitigation measures will be refined once the decommissioning process is initiated. The outcomes of the required EIA process for the decommissioning of the GHWMF will further inform the mitigation and management measures to be incorporated into the EMP. The mitigation measures presented below are those identified during the current EIA process for the GHWMF.

Table 8-1: Decommissioning mitigation measures

IMPACT GENERIC DECOMMISSIONING MITIGATION MEASURES RESPONSIBILITY FREQUENCY / MONITORING REQUIREMENTS PHASE DECOMMISSIONING Developer, Main Weekly for the contractor duration of decommissioning ENVIRONMENTAL MANAGEMENT PLAN

MITIGATION 1. The relevant EIA process will need be followed to obtain the necessary approval for the decommissioning of the GHWMF where all possible impacts associated with this phase will be further assessed.

Flora and Fauna 2. According to current environmental legislation, the GHWMF has to be rehabilitated to resemble the surrounding and historical vegetation. The establishment of a waste site provide an opportunity to recreate the previous landscape to a large extent. This is possible by using landscaped cells to conform to the general landscape of the area instead of the

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traditional square cells with flat tops used at waste facilities. 3. The continued presence of so many faunal groups in degraded MST habitat shows that ‘functional rehabilitation’ is possible, even if recovery of full floristic diversity may be very difficult or take a long time. Accordingly, the impact can be partially mitigated by avoiding direct loss of intact MST and Bontveld habitat. All project actions during construction and subsequent operation of the proposed GHWMF should avoid MST and Bontveld habitat where possible. After closure of the facility all habitats, where possible, should be rehabilitated to the existing vegetation type. This is probably attainable for MST, at least in terms of functional rehabilitation for faunal groups, but Bontveld is a growth form dependent upon the underlying limestone pavement, and once this has been removed it cannot be re-habilitated. 4. Rehabilitation of faunal diversity on closure of the proposed GHWMF will require habitat corridors along which fauna can migrate from refugia retaining original fauna. The license holder or operator of the proposed RGHWMF should therefore integrate their EMP, particularly for threatened species (e.g. the Albany Adder) with neighbouring properties to ensure successful faunal rehabilitation on closure.

Geohydrology 5. Proper capping of each cell and regular maintenance of capping according to permit conditions to avoid infiltration of rainwater and thus leachate generation within the waste pile. Installation of leachate level monitoring facility for each cell monitoring point

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6. Treatment and/or proper disposal of final leachate volumes and draining of holding dams 7. Development and implementation of a storm water management plan as well as the proper maintenance of storm water control systems on site after closure according to permits and regulations issued from time to time by relevant authorities. Regular inspections by authorities 8. Regular water quality monitoring according to permit conditions and in compliance to Minimum Requirement documents of DWEA. Reporting of results to the authorities on a six monthly basis

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APPENDIX 1

ISO 14001 approach to ongoing EMP development

ISO 14001 approach to ongoing EMP development

1) Environmental Management Framework

The effective management of the environmental aspects and potential impacts associated with the GHWMF during the construction and operational phases are essential to successfully implement the EMP. Accordingly, is recommended that the project proponent implement an Environmental Management System (EMS) that is, or comparable to, the ISO 14001 standard. A core component of an EMS such as the ISO 14001 standard is that environmental performance can be continuously monitored and audited, thereby identifying areas that require improvement as reflected in Figure 1 below:

Figure 1: EMS Components

The ISO 14001 (2004) standard requires “the adoption and implementation of a range of environmental management techniques in a systematic manner can contribute to optimal outcomes for all interested parties”. The standard is based

on the methodology known as Plan-Do-Check-Act (PDCA). PDCA can be briefly described as follows:

• Plan: establish the objectives and processes necessary to deliver results in accordance with the organization's environmental policy. • Do: implement the processes. • Check: monitor and measure processes against environmental policy, objectives, targets, legal and other requirements, and report the results. • Act: take actions to continually improve performance of the environmental management system.

The effective implementation of the project EMP will require the continuous monitoring of its environmental performance, and where necessary initiate appropriate planning and implement corrective actions to rectify any shortfalls in performance that may occur as per the process represented in Figure 2 below.

Figure 2: EMS process

The draft final EMP that is currently under review will be the basis for identifying the salient environmental aspects of the project that can interact with the environment, and can be developed to be reflective of the ISO 14001 standard requirements that will be a substantial component of the overall EMS for the project. The final iteration of the EMP (subject to periodic review as determined by operational environmental performance) must incorporate all aspects of detail

design and will have to be reflective of the ISO 14001 (2004) elements that require: a) Environmental policy

The environmental policy is determined and articulated by the project proponent, and this in effect defines how it will manage its environmental objectives and monitor its performance. The policy is a statement of intent on how the environmental management function will be effected as part of the organisation’s activities. b) Planning

Planning involves identifying and defining the various environmental aspects and related potential impacts that can result from the organisation’s activities as these aspects interact with the environment. It requires that objectives and targets be defined so as to provide a benchmark against which environmental management performance can be appraised. c) Implementation and Operation

Appropriate control and operational systems must be implemented that ensure that the targets and objectives defined by the organization are articulated in a fashion that ensures that all persons responsible for achieving these standards are in fact capacitated to do so. d) Checking and corrective action

Checking and corrective is aimed at ensuring that both the necessary environmental management activities are being implemented and that the desired outcomes are being achieved. This continuous monitoring and auditing cycle throughout the project lifespan is the core component in ensuring adherence to, and the continuous improvement of environmental performance. e) Management review

Periodic strategic level management review is required to ensure that the feedback loop of the PCDA methodology is complete. Areas designated for improvement will require committed planning strategy and appropriate action by management to ensure continuous improvement.

2) Environmental Policy

The developer must develop an environmental policy. The revised EMP must make provision for this policy, and should be seen as the vehicle for implementation of the guiding principles to be specified in the policy.

3) Environmental Management Planning

Detail with regards to the planning component as illustrated in Figure 2 above is provided in sections 3.1 - 3.9 below

3.1 Activities

The implementation of the GHWMF project would involve a range of activities within the three principal components of design, construction as well as operation & maintenance.

3.2 Design

The design component of the GHWMF project should entail the environmental standards according to which the different facilities will be designed as well as the specific and detailed design measures / criteria (method statements) that will be implemented to meet the specified standards. These design measures / criteria must be linked back to project facilities. Design is not an environmental management activity in its own right, but rather a means to achieving environmental management requirements.

3.3 Construction

3.3.1 GHWMF Components & Construction Activities

The full range of GHWMF components and construction activities must be summarized respectively and the link between project facilities and activities be established. Facilities will for example entail Construction sites (i.e. Offices, Storage tanks, Topsoil stockpiles, Work shops and Wash bays), Spoil dump sites, Parking facilities (if any), Borrow pits, etc.

Activities on the other hand may involve blasting activities, building activities, cleaning and grubbing and bulldozing activities, concrete work, construction and use of temporary access roads, construction employment (appoint contractors and labourers, etc), control of exotic weeds and invasive species, cut and cover activities, spoil material generation and management, lighting activities, painting etc

3.3.2 GHWMF activity implementation schedule

A schedule for the implementation of method statements must be developed. The method statements can be implemented as a function at the onset of the individual activities for which the method statements are relevant.

3.4 Aspects

Various environmental aspects of the activities assessed in the EIA must be listed. Aspects normally associated with construction activities are for example waste water discharge, gaseous emissions, noise, vibration, labour force, construction solid waste (hazardous & non-hazardous), disturbed areas to be rehabilitated, domestic solid waste, dust, electricity supply, flammable materials inclusive of fuels and oils, odours, groundwater, materials sourcing etc. The link between the project activities and aspects must be established in an Activity/Aspect Matrix.

3.5 Impacts

Various impacts of the construction activities assessed in the EIA must be listed. Impacts normally associated with the construction activities are for example road safety impacts, disturbance and influence on well-being of fauna, flora and avifauna, disturbance and loss of indigenous tree species, disturbance and loss of individual rare and endangered plants and animals, disturbance and loss of vegetation and subsequently faunal habitat, impact on surface water quality, disturbance of topsoil, possible change to topsoil structure and characteristics, vehicle emissions, social impact and disruption, visual impacts, ecological impact, etc. The link between project aspects and impacts must be established in an Aspect/Impact and Standard Matrix.

3.6 Standards

Standards are performance benchmarks that are prescribed externally to the project, mostly through the legislative and regulatory framework. The standards that apply to the various environmental aspects and potential impacts must be listed and included in the revised EMP. Because standards are mostly based within the legislative and regulatory framework, it is important to explain the workings of the South African legislation system in the revised EMP before applying any standard. The link between project aspects, impacts and relevant standards must also be established in an Aspect/Impact and Standard Matrix. Applicable impacts can be marked with “X” and relevant standards should be listed alongside.

3.7 Mitigation

The purpose of mitigation is to define what can be done to minimise or prevent the identified aspects and impacts during the construction, operation and maintenance stages of the project. The mitigation must take the form of broad- based management and mitigation plans that are developed for each of the potential impacts.

3.7.1 Construction phase management and mitigation plans

The various management and mitigation plans (MMPs) that are needed to address the potential impacts of the GHWMF construction activities must be provided, with respective numbers and components thereof listed for each. The link between project impacts and management and mitigation plans must be established in an Impact/Management and Mitigation Plan Matrix. On the matrix, the different relevant MMPs can be marked with “X” as well as applicable components.

3.8 Method Statements

Method statements must provide the detail of the management and mitigation plans. Method statements must be presented with each of the management and mitigation plans as applicable. As these MMPs and method statements are updated throughout the PCDA process these iterative revisions are to be incorporated in the subsequently updated EMP and Operations manual for the GHWMF where pertinent.

3.9 Objectives and Targets

In order to ensure that environmental management performance follows from the environmental policy and planning, objectives and targets must be specified which provide the basis for monitoring of that performance. It is important to recognize that objectives and targets can (and should) be specified for both environmental aspects as well as the implementation of the revised EMP and associated procedures and practices. In other words, objectives and targets can be specified for both the activities and the performance of those activities, as well as the outcomes or results of those activities. The objectives and targets for environmental management on the construction activities can be captured as sections in the management and mitigation plans.