enviroserv waste management ltd - sahra

Synergistics is a SLR Group company

Project Applicant: EnviroServ Waste Management Ltd

Project:

Report Name:

Report Status:

Revision No: 00

Report Date: 4 November 2014

Report Number: 752.05018.00022/Holfontein Extension: IWMF/SR00

Prepared by: Samantha Scott and Matthew Hemming

Reviewed by: Matthew Hemming and Kerry Fairley

For submission to: 1. Department of Environmental Affairs (DEA): Application for a Waste Management Licence in terms of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008). 2. Gauteng Department of Agriculture and Rural Development (GDARD): Environmental Authorisation in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998).

Reference No: DEA Ref No.: 12/9/11/L1406/3 GDARD Ref No.: Gaut 002/13-14/E0241

Johannesburg: Tel: +27 11 467 0945 Fax: +27 11 467 0978 PO Box 1596 Cramerview, 2060

Unit 7 and 9 Fourways Manor Office Park Cnr Roos and Macbeth Streets, Fourways

KwaZulu-Natal:

Tel/Fax: +27 33 343 5826

2 Wattle Grove, Hilton, 3201

REPORT DISTRIBUTION

Name Designation Affiliation

Client Review

1 Neil Brink National Compliance Manager EnviroServ Waste Management Limited

2 Nico Vermeulen General Manager: TDS EnviroServ Waste Management Limited

3 Terence Malan National Technical Manager: TDS

EnviroServ Waste Management Limited

4

Draft for Public and Authority Review

1 Britz Reinders Site Manager: HHWDS For public review

2 Reference Librarian Delmas Public Library For public review

3 Commenting authorities See list in Table 3.1 For information and commenting purposes.

4 Ms Malepo Phoshoko Directorate: Chemicals and Waste Management

Department of Environmental Affairs

5 Ms Boniswa Belot Branch: Sustainable Use of the Environment

Gauteng Department of Agriculture and Rural Development

Synergistics website: www.synergistics.co.za/reports For public review

PROJECT INFORMATION SHEET

PROJECT:

Holfontein Extension: Integrated Waste Management Facility

COMPETENT AUTHORITIES:

Waste Management Licensing

Department of Environmental Affairs

Directorate: Chemicals and Waste Management

DEA Ref No.: 12/9/11/L1406/3

Environmental Authorisation

Gauteng Department of Agriculture and Rural Development

Sustainable Use of the Environment

GDARD Ref No.: Gaut 002/13-14/E0241

REPORT DETAILS:

Report Name: Scoping Report

Report Number: 752.05018.00022/Holfontein Extension: IWMF/SR00

Report Status: DRAFT for public review

Revision No: 00

Date: November 2014

PROJECT APPLICANT:


Contact Person: Neil Brink

Designation: National Compliance Manager

Tel: 011 456 5400

Fax: 011 456 5607

Email: [email protected]

Postal Address: PO Box 9385, Edenglen, 1613

INDEPENDENT ENVIRONMENTAL CONSULTANT:

Synergistics Environmental Services (Pty) Ltd

Contact Person: Matthew Hemming

Designation: Environmental Assessment Practitioner

Tel: 011 467 0945/082 940 8274

Fax: 011 467 0978

Email: [email protected]/ [email protected]

Postal Address: PO Box 1596, Cramerview, 2060

EAP: Matthew Hemming

EAP Expertise: MSc (Conservation Biology), UCTP, 2001.Member of IAIA and IWMSA

8.5+ years’ environmental management and assessment experience, specifically in the mining and waste management sectors.

November 2014 752.05018.00022/HIWMF/SR01


Draft Scoping Report i

ENVIROSERV WASTE MANAGEMENT LIMITED

SCOPING REPORT (Draft)

EXECUTIVE SUMMARY

Introduction to the Project

EnviroServ Waste Management Limited (EnviroServ) has proposed the development of the Holfontein

Extension: Integrated Waste Management Facility (Holfontein Extension: IWMF). The project will be in

addition to, and an extension of, the waste management operations at EnviroServ’s current Holfontein

Hazardous Waste Disposal Site (HHWDS).

The Holfontein Extension: IWMF will be located immediately adjacent to the HHWDS on portions 15,

16, 28, 31, 32, 33, 34, 38, 39, 48, 72 and 74 of the farm Holfontein 71-IR (Figure 1-1), which are owned

by EnviroServ.

The project will include infrastructure, plants and facilities for an integrated, full-service waste

management facility that can receive, store, re-use, recycle, recover and treat all waste types, as well

as provide for the final disposal of both general and hazardous wastes. Wastes will be managed in

accordance with procedures advocated by the waste management hierarchy.

The proposed development of the Holfontein Extension: IWMF is subject to various authorisation/

licensing requirements under legislation administered by different competent authorities. This includes a

waste management licence in terms of the National Environmental Management Waste Act, 59 of 2008,

as amended; an environmental authorisation in terms of the National Environmental Management Act,

107 of 1998, as amended; an atmospheric emissions licence in terms of the National Environmental

Management Air Quality Act, 39 of 2004, as amended and a water use licence in terms of the National

Water Act, 1998, as amended. A scoping and Environmental Impact Assessment process is required in

support of the applications for authorisation/licensing.

The purpose of this scoping report is to identify the potential environmental impacts associated with the

development of the project and to present the ‘plan of study’ for the EIA for the project.

Environmental Legal Requirements and Responsible Authorities

Synergistics Environmental Services (Pty) Ltd was appointed by EnviroServ as independent

environmental assessment practitioner (EAP) to undertake the necessary environmental work to meet



Draft Scoping Report ii

the requirements of informing the following authorisations:

Legislation Listed Activities Competent Authority

National Environmental

Management: Waste Act,

2008

Category A and B waste

management activities listed in

GN R 921 of November 2013

National Department of Environmental Affairs:

Chemicals & Waste Management.


Management Act, 1998

Activities in listing Notice 1, 2

and 3, GN R 544, 545 and 546

of June 2010.

Gauteng Department of Agriculture and Rural

Development: Sustainable Use of the Environment.


Management: Air Quality

Act, 2004

Listed atmospheric emission

activities, GN R 893 of

November 2013.

Ekurhuleni Metropolitan Municipality: Environmental

Development Department: Air Quality Management

National Water Act, 1998 Section 21 of the Act. Department of Water & Sanitation

In order to inform the authorisations required for the Holfontein Extension: IWMF, a scoping and EIA

process, as stipulated in the EIA Regulations (GN R 543 – 547 of July 2010) made under section 24(5)

of the NEMA must be conducted.

The scoping report is structured in accordance with GNR 543 (June 2010) and includes the

consolidated results of the public participation and authority consultation processes conducted to date.

In accordance with regulation 28(1f) of GN R 543, all legislation and guidelines that have been

considered in the preparation of the Scoping Report are documented. All of the specific activities for

which authorisation/licences have been applied are detailed in the main report.

Approach and Methodology

Study Objectives

The specific objectives for the scoping phase of the EIA process are to:

• Collate project and baseline environmental information.

• Identify landowners, adjacent landowners, local authorities, environmental authorities, as well

as other stakeholders which may be affected by, or that may have an interest in the

environmental impacts of the project.

• Inform interested and affected parties (IAPs) about the proposed project.

• Document key IAP issues and concerns for consideration in the EIA phase.

• Engage with environmental authorities and confirm legal and administrative requirements.

• Identify and describe potential environmental issues.

• Introduce and evaluate the alternative options at desktop level.

• Identify the nature and extent of further investigations and specialist input required in the EIA

phase.

The study area is defined as the EnviroServ owned properties adjacent to the existing Holfontein

Hazardous Waste Disposal Site and the area of land within 100 m of the subject property boundaries.



Draft Scoping Report iii

Baseline information

Baseline information for this scoping report was gathered through visual inspections of the project area

and surroundings, desktop studies and review of existing reports and monitoring data. Such information

will aid in identifying and assessing the potential current and future impacts of operations at the site,

specifically with regards to sensitive receptors in the area.

Public Participation and Authority Consultation Process

The scoping report provides details of the public and authority participation process followed to date,

which included:

• Press advertisements and site notices;

• Identification of interested and affected parties;

• Notification and information document to interested and affected parties;

• Notifications to relevant authorities;

• Registration of interested and affected parties;

• Announcement of public meeting and open day;

• Public meeting on 15 April 2014;

• Receipt of issues and responses from IAPs;

• Focussed authority meetings with DEA, EMM and COJ; AND

• Public and authority review of the draft scoping report.

Numerous organs of state and commenting authorities have been notified of the project and the EIA process.

Review of the Draft Scoping Report

The draft scoping report is available for public and authority review for a 40 calendar day period from 5

November to 15 December 2014. Comments submitted by IAPs and commenting authorities will be

incorporated into the final scoping report.

Project Description

The Holfontein: IWMF will provide an integrated, full-service waste management facility that can

receive, store, re-use, recycle, recover and treat all waste types, as well as provide for the final disposal

of both general and hazardous wastes in disposal sites. The facility is proposed to include some or all

of the following:

• Mechano Chemical Destruction facility;

• Bioremediation facility;

• Micro-encapsulation plant;

• Oil Separation plant;

• Health Care Risk Waste Treatment

plant ;

• Solvents Recovery plant;

• Treatment and blending pad;

• Pilot Plant test area;

• Waste to Energy plant;

• Gasifier;

• Anaerobic digester;

• Pyrolysis/ Devolatilisation plant;

• Solid fuel plant;

• Minerals upsizing/ downsizing plant;

• Mineral recycling plant;

• General Waste Materials Recovery

facility;



Draft Scoping Report iv

• Tyre Recycling plant;

• Plastic beneficiation plant;

• Board manufacturing;

• Panel manufacturing;

• WEEE and battery recycling plant;

• General (Class B) Disposal Site

• Landfill gas extraction and utilisation;

and

• Hazardous (Class A) Disposal Site.

Preliminary information on each facility/plant is detailed in Section 4.3 of the scoping report. More

details on the facilities, their capacity and operational parameters will be provided in the EIA report. It is

possible that not all of these facilities/plants will be developed.

The Class A and Class B disposal facilities will be designed and operated in terms of the current

National Norms and Standards for Disposal of Waste to Landfill (GN R 636). Conceptual engineering

designs will be provided for the facilities that require design approval from the Department.

All of the facilities/plants will be located on the properties owned by EnviroServ. A preliminary layout of

the Holfontein Extension: IWMF is presented in the report. This layout is conceptual, being informed

largely by the cadastral boundaries of the included properties. The final layout will be informed and

refined through on-going feasibility work and inputs derived from the EIA process. Updated layouts will

be included in the EIA report.

Various development alternatives have been considered during the feasibility studies undertaken to

define the project. EnviroServ is heavily in the Holfontein area with infrastructure, monitoring networks

and knowledge of the environmental conditions and receptors around the site. A locality alternative will

not be considered in the EIA as the project would not be reasonable or feasible for EnviroServ at any

other location. Alternative activity type, layout and design, technologies and operational aspects that

provide reasonable and feasible means of meeting the general objectives of the project will be

assessed in the EIA. The no-go alternative will be considered in the EIA.

Description of the Affected Environment

The baseline environment described in the scoping report represents the current environmental

conditions of the area where the Holfontein Extension: IWMF will be constructed. It is indicative of

pollution and degradation due to current waste management operations, human, agricultural, mining

and industrial activities in the area and naturally occurring phenomena. Baseline information was

sourced from desktop studies, site inspections and from on-going monitoring completed at the site. The

baseline information serves as a reference point to scientifically measure or professionally judge future

changes to the environment that may occur with the development of the Holfontein Extension: IWMF.

Information on each environmental aspect is presented in the main report.

Issues Raised During Consultation with Interested and Affected Parties

Responses were received from neighbouring commercial farmers, residents of nearby communities,



Draft Scoping Report v

members of the HMC and Interwaste (Pty) Ltd as the proponents of the proposed Amadwala

Integrated Waste Management Facility. All of the questions and issues raised by IAPs during the

scoping phase are detailed in Section 7 of the main report.

Environmental Impacts and EIA Tasks

The report provides a scoping-level identification of potential environmental impacts (physical,

biological, social and economic) associated with the proposed Holfontein Extension: IWMF as well as a

framework of how these impacts will be assessed further in the EIA phase. The key impacts of the

project may include:

IMPACT IMPACT SOURCE FRAMEWORK FOR TASKS IN THE EIA

PHASE

VISUAL + LANDSCAPE CHARACTER

Addition of visual elements resulting in change to landscape character

• Development of waste bodies.

• Dispersal of waste in wind

• Odours from the facility.

• Operation of landfill site, dust emissions

and heavy vehicle traffic.

• Industrial infrastructure including buildings and stacks.

• Sensitive receptors to be identified.

• Visual Impact Assessment to predict

changes to the viewshed from key sensitive receptors.

• Design of waste body profile and final cover to consider need for a final shape that is the least visually intrusive.

• Consider the visual intrusiveness and alteration in landscape at day and night

ZONING + LAND USE

Conversion of land with agricultural potential to built facilities and waste bodies.

• Removal of vegetation.

• Stripping of soil.

• Establishment of buildings, facilities and

landfills

• Assessment of agricultural potential to

determine potential loss.

• Soil stripping plan to ensure maximal soil recovery.

Restriction on zoning and use of land within buffer zone required for facility.

• Undertaking of waste management activities/emissions that pose a health risk and require a buffer zone for the protection of human health.

• Interaction of buffer zones of various facilities influencing larger area.

• Air Quality Impact Assessment to assess health risks and determine extent of required buffer zone and permissible land uses.

• Comparative assessment of current land use and zoning with buffer zone requirements.

• End-use planning to be considered in the

context of regional development.

AIR QUALITY

Increase in odours at receptors

• Decomposition of waste resulting in the

emission of landfill gas – in particular the odourous components

• Storage, handling, treatment and disposal of wastes and leachate with strong chemical odours.

• Operation of plants, particularly those with

thermal or biological processes resulting in the emissions of odorous gases.


• Air Quality Impact Assessment to assess potential for odour generating activities and to consider dispersion of such gases to receptors.

• Operations methods and emissions

controls to ensure emissions comply with standards or better.

Increase in ambient levels of criteria air pollutants at receptors

• All processes and plants that result in

gaseous emissions of criteria air pollutants.

• Air Quality Impact Assessment to assess

emissions of criteria air pollutants against legislated limits.



Draft Scoping Report vi


PHASE

• Plant design and emissions controls to

ensure emissions comply with standards or better.

Health risks to nearby receptors from inhalable particulates and or

pollutants

• Direct and cumulative risk to health

(carcinogenic and non-carcinogenic) to nearby receptors from site emissions.


• Air Quality Impact Assessment to compare modelling and dispersion results against legislated and best practice limits to assess health risks to key receptors.

HYDROLOGY

Reduction in surface water quality in the watercourse/resource

• Sediments dispersed from site

• Pollutants from construction machinery as

well as materials, fuels and chemicals used and stored on site.

• Release of contaminants that may be in the soils across the site during the

disturbance or use of these soils.

• Management of materials, fuels and chemicals to minimise risks of contamination.

• Management of storm water during

construction.

• Assessment of soil quality and restriction

on use of contaminated soils.

• Rainwater coming into contact with waste.

• Rainwater coming into contact with

materials, fuels and chemicals.

• Spillage of dirty storm water or leachate from site.

• Sediments from exposed surfaces.

• Sediments on vehicle wheels.

• Dirty water from plant processes.

• Discharge of treated effluents

• Hydrological assessment to consider potential risks during operations.

• Calculation of hydrological parameters of

affected catchments and floodlines of affected watercourses

• Design of facilities dealing with wastes,

materials, fuels and chemicals to minimise risks of contamination.

• Designs of storm water facilities to ensure diversion, containment of volumes from maximum expected precipitation in 1: 50

year event.

Alteration of flow to and in the watercourse

• Additional hard surfaces increasing runoff over infiltration.

• Diversion of clean storm water and its

reintroduction at points different from natural.

• Return of storm water to be done with minimum disturbance to natural flow patterns.

SOILS + GEOLOGY

Loss of topsoil from the site


• Stripping and backfilling for levelling

• Erosion and sedimentation by surface

water flows.

• Establishment of buildings, facilities and landfills over soils.

• Soils assessment to determine type and

depths of soils across site.

• Assessment of agricultural potential.

• Salvaging of all useable topsoil.

Loss of clay mineral

resource from the site • Establishment of buildings, facilities and

landfills over mineral resources – particularly clay.

• Soils assessment to identify clay

resources that could be used for specific purpose.

• Salvaging of all useable clay.

GROUNDWATER:

Reduction in groundwater quality

• Contaminated surface water infiltrating to groundwater

• Leachate from waste cells infiltrating to

groundwater.

• Seepage from leachate and storm water

dams infiltrating to groundwater.

• Specialist hydrogeological impact assessment to determine the contaminant sources, model the dispersion plume and

assess impacts on groundwater quality.

• Conceptual design of landfill and dam liners and protective measures in terms of Norms and Standards.



Draft Scoping Report vii


PHASE

Alteration in groundwater

flow and change in seepage contribution to site wetlands

• Surface water infrastructure, waste bodies

altering flow of shallow groundwater

• Specialist hydrogeological impact

assessment to determine the contribution of groundwater seepage top the wetlands and to determine the likely impacts on wetlands hydrological regime.

BIODIVERSITY: TERRESTRIAL

Loss of natural habitat of conservation importance from the site



• Establishment of buildings, facilities and landfills.

• Ecological study to confirm status of site and validity of conservation importance of the habitat.

• Site layout designed to avoid areas of

high conservation importance.

BIODIVERSITY: FRESHWATER ECOSYSTEMS

Loss of wetland habitat from the site

• Removal of vegetation and establishment

of buildings, facilities and landfills over wetlands.

• Reduction in inflows to wetland habitat.

• Wetland assessment to delineate

wetlands on and within 100m of the site.

• Site layout designed to avoid wetlands where possible.

• Project to consider commitments to

wetland rehabilitation.

Decline in PES or EIS of remaining wetlands

• Sediments in surface water flows.

• Contaminants (waste/ fuels and

chemicals/ leachate) in surface water flows.


• Discharge of treated effluents.

• Alteration of volume of surface and ground

water in flows to wetlands.

• Wetland assessment to assess wetland status on and within 100m of the site.

Also to consider the likely impacts on the wetland in light of the proposed development plan.

CULTURE + HERITAGE

Destruction of heritage resources on the site


• Establishment of buildings, facilities and

landfills.

• Heritage assessment to determine presence of any resources.

Conflict with cultural beliefs

• Receipt, treatment and disposal of HCRW

may conflict with cultural beliefs of indigent communities.


• Social assessment to consider the implications of the social concerns over anatomical wastes.

TRAFFIC Reduction in road safety • Increased volume of heavy vehicles on

the access roads.

• High risk nature of the loads of hazardous

waste on the vehicles.

• Traffic Impact Assessment to assess the

potential change in vehicle volumes and the likely impacts on congestion and road safety.

SOCIAL & ECONOMIC ENVIRONMENT

Employment creation, Skills development and training & Economic opportunities in supply, fabrication, construction(positive)

• Construction, fabrication and installation of plants and facilities.

• Delivery of construction materials and

wastes to the site.

• Operation of the plants and facilities.

• Social plan for the facility to ensure maximum benefit to local communities and business.

Nuisance impacts to

neighbours which affect quality of life

• Cumulative impacts on quality of life from

noise, visual, odour, dust and air quality impacts.

• All specialist assessments to identify and

consider impacts to sensitive receptors.

• Assessment to consider cumulative

effects of the various aspects on key receptors.

• Identify measures to safeguard neighbours and landowners from project



Draft Scoping Report viii


PHASE

risks

Health risks to neighbouring communities.

• Dispersion of health risk substances beyond the site boundaries to public receptors in quantities that result in health risks.


• Specialist assessments, in particular air

quality, to identify and assess health risks to sensitive receptors.

• Design of facilities to minimise risks of contamination and public health risks.

• Buffer zone to be based on the maximum,

cumulative health risk.

Real/perceived impacts on property values

• Establishment of waste management

facilities altering perception of area and influencing property values.

• Buffer zone restrictions influencing future land use with resultant influence on values.

• Socio Economic assessment to assess

current property values and consider influences on future values.

WASTE MANAGEMENT

Implementation of the waste management hierarchy to obtain the most sustainable result from waste streams (positive)

• Multiple facilities at a single site allow for waste streams to be managed at the plant (s) where the maximum benefit can be obtained from the waste such that the

smallest fraction becomes residual waste requiring disposal.

• Having the various plants located at a single site reduces transport costs and risks.

• Ensure an integrated facility that can derive the maximum sustainable benefit from target waste streams

Plan of Study for Environmental Impact Assessment

This plan of study for EIA, Section 9 of the main report, includes a description of the EIA process and

tasks, specialist studies and consultation to be undertaken during the EIA phase of Holfontein

Extension: IWMF as well as a proposed impact assessment methodology and impact assessment

rating criteria.

EIA Process

The EIA process has been developed to ensure that it complies with GNR 543 Section 26 to 33 and the

associated guidelines. The proposed EIA process and public consultation activities are illustrated

below, with specific reference to the opportunities for consultation.

EIA Phase Opportunities for Consultation and Participation

Schedule Competent Authorities IAPs, State Departments and Organs of State

Project

Announcement and

Application Phase

Review

Baseline Data

DEA & GDARD

Nov 2013 to Feb 2014

Advertisements and project notifications to potential

IAPs and commenting authorities. Public information meeting

March 2014

April 2014

Sco

ping

Pha

se DSR to authorities. Review of DSR (40 days, ±6 weeks).

November -December 2014



Draft Scoping Report ix



Focused consultation with authorities if required.

Focused consultation with IAPs or commenting authorities if required.

Final scoping report to authorities Review and acceptance of final scoping

report (30 days).

Review of final scoping report (21 days, ±3 weeks). January 2015

EIA Phase

Specialist Input and

Assessments

Submit draft EIA report to authorities.

Review of draft EIA report (40 days, ±6 weeks).

May - June 2015 Meetings with authorities during EIA if required. Public Feedback Meeting.


Authority review and

Authorisation Phase

Final EIA report to DEA & GDARD. Review of final EIA report (21 days, ±3 weeks).

July – September 2015

Authorities Acceptance of EIA report (60 days).

Application Accepted / Refused (45 days). Waste Management Licence &

Environmental Authorisation Granted / Refused (45 days).

November 2015

Notifications to IAPs regarding environmental

authorisation (granted or refused).

Appeal Phase Consultation during processing of appeal if

relevant. Consultants to provide guidance regarding the

appeal process as and when required. variable

Alternatives

The EIA will provide an assessment of alternatives that are both feasible and reasonable and which

provide a different means of achieving the same general purpose and requirements of the Holfontein

Extension: IWMF.

Methodology

The identification and assessment of environmental impacts is a multi-faceted process, using a

combination of quantitative and qualitative descriptions and evaluations. It involves applying scientific

measurements and professional judgement to determine the significance of environmental impacts

associated with the proposed project. The EIA will consider current impacts, incremental impacts of the

project and the cumulative impacts. The significance of impacts will be evaluated through a rating

system that considers the intensity, duration, frequency, extent and probability of each impact. Impacts

will be considered across the project phases where there is likely to be significantly different impact

between the phases. This could include construction, operations, decommissioning and closure.

Specialist Studies

Specialist input and studies will be conducted for the following environmental components:

• Visual Impacts

• Soils (including type and quality)

• Traffic

• Air Quality

• Surface water

• Ecology



Draft Scoping Report x

• Wetlands

• Hydrogeology

• Heritage

• Socio-economic

The scopes of work for these studies are outlined in the main report. Specialist reports will be structured

in terms of Section 32of GNR 543.

Study Team

Synergistics has been appointed by EnviroServ as the independent EAP to undertake the EIA for the

Holfontein Extension: IWMF. Suitably qualified and experienced scientists will be appointed to complete

the various specialist assessments.

EIA and EMPr Report

The EIA Report will be structured in terms of Section 31 of GNR 543. A draft Environmental

Management Programme (EMPr), structured in terms of Section 33 of GNR 543, will be submitted as a

supporting part of the EIA Report. The aim of the EMP will be to ensure that the project facilities are

managed to reduce potential negative environmental impacts and enhance potential positive

environmental impacts. The EMP will detail the actions required, the responsibility for implementation

and the schedule and timeframe.

Consultation Process

The following opportunities will be provided to IAPs, relevant Organs of State and commenting

authorities for input into the EIA process:

• On-going submission of questions and comment;

• Public Feedback Meeting during EIA, including presentation of specialist results;

• Consultation with Competent Authority, Organs of State and commenting authorities;

• Public Review of the draft and final EIA reports.

Atmospheric Emissions Licence

The atmospheric emissions licence forms will be submitted to the Air Quality Officer at the Ekurhuleni

Metropolitan Municipality once final design details and information from the Air Quality Impact

Assessment are available and the environmental authorisation has been obtained.

In the interim there will be on-going consultation with the EMM so that the officials remain informed and

the investigations and reporting are appropriate to meet the requirements of the atmospheric emissions

licence application process.

Water Use Licence

The water use licence application will be submitted to the Department of Water and Sanitation once the



Draft Scoping Report xi

final design details and information from the Hydrological and Geohydrological Impact Assessment are

available. The water use licence application will need to be informed by the environmental authorisation

and waste management licence.

In the interim there will be on-going consultation with the Department of Water and Sanitation so that

the officials remain informed and the investigations and reporting are appropriate to meet the

requirements of the water use licence application process.

Conclusions and Key Findings

This report concludes the scoping phase of the environmental assessment for the Holfontein Extension:

IWMF. It outlines the results of the public participation and authority consultation processes to date,

identifies the potential impacts that may result and defines the plan of study for the Environmental

Impact Assessment phase.

Facilities proposed for the Holfontein Extension: IWMF include means to re-use, recycle, recover and

treat target waste streams as well as to provide for the disposal of general and hazardous waste to

landfill. The project is located on properties owned by EnviroServ and adjacent to the HHWDS in

Ekurhuleni, Gauteng . The proposed facilities will variously complement and/or extend the services of

the HHWDS. EnviroServ’s investment in infrastructure and baseline monitoring provide motivation for

the project’s location.

Operations at the existing HHWDS pose environmental and health risks from the hazardous wastes

handled, treated and disposed there, mostly notably to the surface and groundwater resource and air

quality. Various impacts have been documented and are regularly discussed at the Holfontein

Monitoring Committee forum. There are concerns that the facilities proposed for the Holfontein

Extension: IWMF could: extend the time period over which such risks will occur; add cumulatively to the

existing impacts thereby worsening the current situation; and/or add risks and impacts additional to

those currently experienced.

Re-use and recycling of waste streams is promoted in the waste management hierarchy and are

generally beneficial if undertaken appropriately. When handling general wastes there can be risks

related to surface water quality, odour and litter dispersion, dust generation and proliferation of vermin.

With appropriate facility design and management the risks are anticipated to be low. The recycling of

hazardous wastes can present more significant risks than for general wastes and thus requires more

rigorous design and management. The potential impacts of the various recycling plants to

environmental aspects will be assessed and measures proposed to ensure that the layout, design and

operations are appropriate.

The recovery of materials and energy from wastes are also proposed. These processes are also

generally beneficial and promoted in the waste management hierarchy. However, if improperly

implemented, the various facilities can result in environmental risks similar to and of greater impact than

recycling. Recovery from hazardous wastes is likely to include risks to surface and groundwater and



Draft Scoping Report xii

possibly, air quality. The various thermal treatment plants proposed, as well as the anaerobic digestion

plant, all have the benefit of recovering embodied energy from the waste and reducing the volume of

residual waste. However, the processes can consume wastes that are better suited to recycling;

concentrate the contaminants in the residual waste and result in the release of pollutants to air. An air

quality impact assessment will be necessary to investigate the potential impacts on air quality and any

related health risks. Emitting facilities will need to achieve the emissions limits set by the National

Environmental Management Air Quality Act to ensure that air quality impacts are within the acceptable

range.

Treatment of certain waste streams is necessary to reduce the environmental risk prior to further use or

disposal. Such treatment can remove or alter the contaminants in the waste stream or change the

properties of the waste so that the risks to the environment are reduced. Although the treatment

process may have inherent risks, these are generally far outweighed by the benefits of the treatment.

The treatment of HCRW, and anatomical wastes in particular, is of concern to some IAPs. The concern

is partly related to possible health risks but also due to conflicting cultural beliefs. The potential impacts

of the various treatment plants to environmental aspects will be assessed and measures proposed to

ensure that the layout, design and operations are appropriate.

The disposal of waste to landfill is the least preferred method in the waste management hierarchy, but

is a key tool for waste managers. The disposal of residual waste to appropriately designed and

managed landfills remains an environmentally responsible option. Disposal of waste to land is

associated with many risks, but particularly to the surface and groundwater resource, air quality and

human health. The generation of landfill gas is concern when disposing of general waste. Landfills

disposing hazardous waste potentially pose greater risks to each of the environmental aspects and

particularly to human health. The potential impacts of the Class A and Class B landfills will be assessed

in detail and measures proposed to ensure that the layout, design and operations are appropriate. This

will include hydrogeological and hydrological assessments as well as an air quality impact assessment

to determine risks to human health. Buffer zones to protect receptors will be defined. The disposal

facilities will be designed by experienced professional engineers with due consideration of the

geotechnical conditions, hydrogeological setting, waste classification and other environmental aspects.

The proposed location of Holfontein Extension: IWMF is adjacent to the HHWDS as this has numerous

benefits and synergies for the operator. However, the properties could have various environmental

aspects that render the site as a whole, or the layout of facilities, inappropriate for development.

Potential aspects of concern include soils of high agricultural potential; heritage resources; a

watercourse and associated wetlands; critical biodiversity areas that are necessary to achieve

conservation targets in the province, host species of conservation concern or provide vital ecological

services; and nuisance and health risks to sensitive receptors. Site assessments by appropriately

qualified specialists will be necessary to determine the status of these aspects. The presence of waste

management facilities may have influences on social and economic aspects of the area as well as on

the zoning and permissible use of the adjacent properties. The value of adjacent land may be

influenced. A socio-economic study as well a traffic impact assessment and visual assessment are



Draft Scoping Report xiii

advocated to assess these issues.

The development of the Holfontein Extension: IWMF adjacent to the existing HHWDS could result in

cumulative changes to environmental aspects that are above acceptable limits. The potential,

concurrent development of the Amadwala Integrated Waste Facility by Interwaste

(DEA:12/9/11/L1257/3 ,GDARD: Gaut 002/13-14/E0073) on adjacent properties may add further weight

to the impact concerns. The cumulative impact of the Holfontein Extension: IWMF and the neighbouring

facilities will need to be considered by the specialists and throughout the impact assessment, as far as

this is possible.

The Holfontein Extension: IWMF will have benefits in enabling integrated waste management at a

single location in terms of the principles of the waste management hierarchy. This is in line with the

approach advocated by government through legislation and policy and in terms of the goals of the

National Waste Management Strategy. The various plants and facilities proposed will aim to derive the

maximal sustainable benefit from each waste stream through recycling, recovery and treatment before

disposing of the residual waste to landfill. EnviroServ has invested significantly in the infrastructure of

the existing HHWDS and has good knowledge of the environmental parameters and receptors in the

area from decades of monitoring. This data will enable informed design, management and impact

monitoring that could not be easily achieved at any alternate site. EnviroServ maintains that, given

these reasons, the site is the only reasonable and feasible location for the project.

There have been no fatal flaws identified during the scoping phase and the project will proceed to the

EIA phase. The next step will be to conduct the specialist studies and further consultation processes

that will inform the EIA and authority decision-making process. Additional impacts/issues identified

during the EIA phase will be addressed. The EIA reports will incorporate a draft environmental

management programme that will set out the management and mitigation measures required at each

facility to ensure that potential impacts are managed to an acceptable level.



Draft Scoping Report 1


SCOPING REPORT (Draft)

TABLE OF CONTENTS

1. INTRODUCTION ...................................................................... 1

1.1 The Project and its Location ..................................................................... 1

1.2 Project Motivation .......................................................................................... 3

1.3 Project Need and Desirability ................................................................... 5

1.4 Terms of Reference ....................................................................................... 7

EAP details ............................................................................................................. 7 1.4.1

Applicant Details ..................................................................................................... 7 1.4.2

1.5 Environmental Assessment and Authorisation

Process............................................................................................................... 8

1.6 Competent Authorities ............................................................................... 10

WML ..................................................................................................................... 10 1.6.1

EA ......................................................................................................................... 10 1.6.2

AEL ....................................................................................................................... 11 1.6.3

WUL...................................................................................................................... 11 1.6.4

1.7 Structure of the Scoping Report ............................................................ 11

2. Environmental Legal Requirements and

Guidelines ................................................................................ 13

2.1 National Environmental Management Act, 1998 ............................. 13

EIA Guidelines ...................................................................................................... 16 2.1.1




2.2 National Environmental Management: Waste Act,

2008 .................................................................................................................... 17

National Waste Management Strategy .................................................................. 21 2.2.1

Waste Management Hierarchy .............................................................................. 21 2.2.2

National Policy on Thermal Treatment of General and Hazardous Waste .............. 22 2.2.3

Environment Conservation Act, 1989 .................................................................... 23 2.2.4

2.3 National Environmental Management: Air Quality

Act, 2004 .......................................................................................................... 23

Applicable Air Quality Guidelines and Standards ................................................... 23 2.3.1

2.3.1.1 National Minimum Emission Standards ........................................................ 24

2.3.1.2 National Ambient Air Quality Standards for Criteria Pollutants ........... 24

2.3.1.3 Air Quality Management Plan for the HPA.................................................... 26

2.3.1.4 Air Quality Management Plan for Ekurhuleni .............................................. 26

2.3.1.5 National Dust Control Regulations.................................................................. 27

European Union Emissions Standards .................................................................. 27 2.3.2

2.4 National Water Act, 1998 ........................................................................... 28

2.5 Other Applicable Legislation ................................................................... 29

National Heritage Resources Act, 1999 ................................................................. 29 2.5.1

National Environmental Management: Biodiversity Act, 2004 ................................ 29 2.5.2

Conservation of Agricultural Resources Act, 1983 ................................................. 30 2.5.3

Ekurhuleni Metropolitan Municipality By-laws ........................................................ 30 2.5.4

2.5.4.1 Waste Water By-Laws (6 March 2002) ............................................................ 30

2.5.4.2 Solid Waste By-Laws (6 March 2002) ............................................................. 30

2.5.4.3 EMM Environmental Policy (2006) ................................................................... 30

Regional and Local Land Use Policies and Plans .................................................. 31 2.5.5

2.5.5.1 Ekurhuleni Integrated Development Plan........................................................... 31

2.5.5.2 Ekurhuleni Spatial Development Framework .................................................... 31

2.5.5.3 Regional Spatial Development Framework (Eastern Service Delivery

Region) ....................................................................................................................... 31

2.5.5.4 Victor Khanye Local Municipality.......................................................................... 31




3. Study Approach and Methodology.............................. 32

3.1 Study Objectives .......................................................................................... 32

3.2 Definition of Study Area ............................................................................ 32

3.3 Identification of Alternatives ................................................................... 32

3.4 Baseline Environmental Description ................................................... 33

3.5 Existing Reports and Monitoring Data ................................................ 33

3.6 Public Participation Process ................................................................... 34

Identification of Potential Interested and Affected Parties ...................................... 35 3.6.1

Notifications to IAPs .............................................................................................. 35 3.6.2

3.6.2.1 Press Advertisements ............................................................................................. 35

3.6.2.2 Site Notices................................................................................................................ 35

Background Information Document ....................................................................... 35 3.6.3

Public and Stakeholder Meetings .......................................................................... 36 3.6.4

Registered IAPs .................................................................................................... 36 3.6.5

Comments and Responses ................................................................................... 36 3.6.6

3.7 Authority Consultation .............................................................................. 36

Competent Authorities ........................................................................................... 36 3.7.1

Commenting Authorities ........................................................................................ 37 3.7.2

Authority Meetings ................................................................................................ 38 3.7.3

3.8 Review of the Scoping Report ................................................................ 38

3.9 Scoping Report Finalisation .................................................................... 38

4. Project Description.............................................................. 39

4.1 Background .................................................................................................... 39

4.2 Introduction .................................................................................................... 39

Project Location .................................................................................................... 40 4.2.1

4.3 Conceptual Activity Description ............................................................ 42

Project Design Criteria .......................................................................................... 42 4.3.1




Mechano-Chemical Destruction (MCD) ................................................................. 42 4.3.2

Bioremediation Facility .......................................................................................... 42 4.3.3

Micro-encapsulation .............................................................................................. 43 4.3.4

Oil Separation ....................................................................................................... 43 4.3.5

Health Care Risk Waste Facility ............................................................................ 43 4.3.6

Solvents Recovery Facility .................................................................................... 43 4.3.7

Treatment and Blending Pad ................................................................................. 44 4.3.8

Pilot Plant Area ..................................................................................................... 44 4.3.9

Waste to Energy Facility ........................................................................................ 44 4.3.10

Gasifier Facility ..................................................................................................... 45 4.3.11

Anaerobic Digester................................................................................................ 45 4.3.12

Pyrolysis / devolatisation Facility ........................................................................... 45 4.3.13

Solid Fuel Plant ..................................................................................................... 45 4.3.14

Minerals upsizing/downsizing facility ..................................................................... 45 4.3.15

Minerals Recycling Facility .................................................................................... 46 4.3.16

Materials Recycling Facility ................................................................................... 46 4.3.17

Tyre Recycling Facility .......................................................................................... 46 4.3.18

Plastic Beneficiation Facility .................................................................................. 46 4.3.19

Board Manufacturing Facility ................................................................................. 47 4.3.20

Panel Manufacturing Facility ................................................................................. 47 4.3.21

WEEE and battery recycling Facility ...................................................................... 47 4.3.22

Class B Disposal Site ............................................................................................ 48 4.3.23

Landfill gas extraction and utilisation ..................................................................... 48 4.3.24

Class A Disposal Site ............................................................................................ 48 4.3.25

Storm water and Leachate Management ............................................................... 51 4.3.26

Monitoring Networks.............................................................................................. 51 4.3.27

4.4 Project Phases .............................................................................................. 52

Planning Phase ..................................................................................................... 52 4.4.1

Construction and Commissioning Phase ............................................................... 52 4.4.2

4.4.2.1 Disposal Sites ........................................................................................................... 53




Operations ............................................................................................................ 53 4.4.3

4.4.3.1 Waste Receipt........................................................................................................... 53

4.4.3.2 Waste Management and Disposal ....................................................................... 53

Decommissioning and Closure Activities ............................................................... 54 4.4.4

4.5 Development Alternatives ........................................................................ 54

Location ................................................................................................................ 54 4.5.1

Activity Type.......................................................................................................... 55 4.5.2

Layout and Design ................................................................................................ 55 4.5.3

Technologies and Operational Aspects ................................................................. 55 4.5.4

No-go Development Alternative ............................................................................. 56 4.5.5

5. Description of the Affected Physical

Environment ........................................................................... 57

5.1 Topography .................................................................................................... 57

5.2 Visual Landscape Character ................................................................... 57

5.3 Land Ownership and Zoning ................................................................... 57

5.4 Land Use .......................................................................................................... 58

Current Land Use of the Holfontein Extension: IWMF ............................................ 58 5.4.1

Surrounding Land Uses......................................................................................... 59 5.4.2

5.4.2.1 Proposed Developments ........................................................................................ 59

5.5 Soils and Geology........................................................................................ 61

Soil........................................................................................................................ 61 5.5.1

5.5.1.1 Soil Contamination ................................................................................................... 61

Regional Geology.................................................................................................. 62 5.5.2

Local Geology ....................................................................................................... 62 5.5.3

Dolomite Stability .................................................................................................. 62 5.5.4

5.6 Climate .............................................................................................................. 64

Regional Climate ................................................................................................... 64 5.6.1

Temperatures........................................................................................................ 64 5.6.2




5.6.2.1 Precipitation ............................................................................................................... 64

5.6.2.2 Wind Patterns............................................................................................................ 65

5.7 Air Quality........................................................................................................ 67

Regional Air Quality .............................................................................................. 67 5.7.1

Local Air Quality .................................................................................................... 67 5.7.2

5.8 Noise.................................................................................................................. 67

5.9 Hydrology ........................................................................................................ 68

Catchments and River Systems ............................................................................ 68 5.9.1

Surface water resources ....................................................................................... 68 5.9.2

Present Ecological Status and Sensitivity .............................................................. 73 5.9.3

Surface Water Quality ........................................................................................... 75 5.9.4

5.9.4.1 Regional ..................................................................................................................... 75

5.9.4.2 Local ............................................................................................................................ 75

Surface Water Use ................................................................................................ 78 5.9.5

5.10 Groundwater .................................................................................................. 78

Characterisation of the Aquifers ............................................................................ 78 5.10.1

Groundwater Gradient and Levels ......................................................................... 79 5.10.2

Groundwater Quality ............................................................................................. 80 5.10.3

Groundwater Use .................................................................................................. 83 5.10.4

5.11 Ecology and Biodiversity.......................................................................... 83

Flora ..................................................................................................................... 84 5.11.1

5.11.1.1 Protected and Red Data Plant Species .............................................................. 84

Fauna ................................................................................................................... 87 5.11.2

5.11.2.1 SABAP2...................................................................................................................... 87

5.11.2.2 SARCA Project ......................................................................................................... 87

5.11.2.3 Frog Atlas ................................................................................................................... 88

5.11.2.4 Mammal Map............................................................................................................. 88

Biodiversity and Conservation Importance............................................................. 88 5.11.3

5.11.3.1 Protected and Conservation Areas ...................................................................... 88




5.11.3.2 Threatened Ecosystems ......................................................................................... 88

5.11.3.3 GDARD Conservation Plan ................................................................................... 89

5.12 Cultural and Heritage Resources .......................................................... 89

5.13 Traffic ................................................................................................................ 89

5.14 Socio-Economic Environment ................................................................ 89

Population Information .......................................................................................... 90 5.14.1

Economic Activity .................................................................................................. 90 5.14.2

Employment trends ............................................................................................... 91 5.14.3

Planning and Proposed Local Development .......................................................... 91 5.14.4

7. Results of Public Consultation...................................... 93

7.1 Collation of Issues and Concerns ......................................................... 93

7.2 Summary of Issues raised by Interested and

Affected Parties ............................................................................................ 93

8. Anticipated Environmental Impacts.......................... 100

9. Plan of Study for Environmental Impact

Assessment .......................................................................... 108

9.1 EIA Process .................................................................................................. 108

9.2 Development Alternatives to be Investigated in the

EIA Phase ...................................................................................................... 109

Locality................................................................................................................ 109 9.2.1

Activity Type........................................................................................................ 109 9.2.2

Layout and Design .............................................................................................. 109 9.2.3

Technology ......................................................................................................... 109 9.2.4

No-go Development Alternative ........................................................................... 110 9.2.5

9.3 Environmental Impact Assessment Methodology ....................... 110

Identification and Description of Impacts ............................................................. 110 9.3.1




9.3.1.1 Current Impacts (Impacts of Existing Developments) ................................... 110

9.3.1.2 Incremental Impacts (Direct project impacts) .................................................. 111

9.3.1.3 Cumulative Impacts (Total Impacts) .................................................................. 111

Evaluation of Impacts and Mitigation Measures ................................................... 111 9.3.2

Project Phases .................................................................................................... 114 9.3.3

9.4 Specialist Studies ...................................................................................... 115

Visual assessment .............................................................................................. 115 9.4.1

Soils and agricultural potential assessment ......................................................... 115 9.4.2

Air Quality Impact Assessment ............................................................................ 116 9.4.3

Noise assessment ............................................................................................... 117 9.4.4

Surface water study ............................................................................................ 117 9.4.5

Geotechnical study.............................................................................................. 118 9.4.6

Hydrogeological Study ........................................................................................ 118 9.4.7

Ecological study .................................................................................................. 119 9.4.8

Wetland study ..................................................................................................... 119 9.4.9

Culture and Heritage assessment ....................................................................... 120 9.4.10

Traffic Impact Assessment .................................................................................. 120 9.4.11

Socio-economic Impact Assessment ................................................................... 121 9.4.12

Conceptual design of Disposal Sites ................................................................... 121 9.4.13

9.5 Study Team ................................................................................................... 122

9.6 Consultation Process for EIA ............................................................... 123

Public Participation Process ................................................................................ 123 9.6.1

9.6.1.1 IAP Responses ....................................................................................................... 123

9.6.1.2 Public Feedback Meeting during EIA ................................................................ 123

9.6.1.3 Public Review of the EIA Report ........................................................................ 123

9.6.1.4 Notification of authorisation ................................................................................. 123

Consultation with Competent Authority, State Departments and Organs 9.6.2

of State ............................................................................................................... 123

9.6.2.1 Authority Meetings ................................................................................................. 123

9.6.2.2 Review of the Scoping and EIA Report ............................................................ 124




9.7 EIA Report ..................................................................................................... 124

9.8 Draft Environmental Management Programme

(EMPr) ............................................................................................................. 124

9.9 Atmospheric Emissions Licence ......................................................... 124

9.10 Water Use Licence ..................................................................................... 125

10. Conclusions and Key Findings ................................... 126

11. Consultant Declaration.................................................... 129

References ....................................................................................... 130

List of Appendices ....................................................................... 131

LIST OF TABLES

Table 1-1: Detail of applications for authorisation of the H:IWMF ....................................................... 10

Table 1-2: Structuring of the Scoping Report in terms of GNR 543 Requirements.............................. 11

Table 2-1: Listed EIA Activities applicable to the Holfontein Extension: IWMF ................................... 13

Table 2-2: Waste management activities applicable to the Holfontein Extension: IWMF .................... 18

Table 2-3: Atmospheric emission activities applicable to the Holfontein Extension: IWMF.................. 23

Table 2-4: Minimum emission standards for Sub Category 8.1 .......................................................... 24

Table 2-5: National Ambient Air Quality Standards ............................................................................ 25

Table 2-6: Preliminary water use activities applicable to the Holfontein Extension: IWMF .................. 28

Table 3-1: Relevant Commenting Authorities Notified of the Project ................................................. 37

Table 5-1: Affected and Adjacent Properties and Land Ownership..................................................... 57

Table 5-2: Annual Rainfall and Evaporation at the HHWDS (source: Jones & Wagener,

2013) ............................................................................................................................................ 64

Table 5-3: Dams and Quarries on the proposed Holfontein Extension: IWMF............................. 69

Table 5-4: Boreholes located on proposed Holfontein Extension: IWMF.................................... 80

Table 7-1: Issues and Concerns ........................................................................................................ 94




Table 8-1: Preliminary identification of potential environmental impacts for the Holfontein

Extension: IWMF ........................................................................................................................ 100

Table 9-1: Simplified EIA Process with Explanation of Opportunities for Consultation

and Participation in the EIA Process ........................................................................................... 108

Table 9-2: Impact Rating Criteria and Assessment Process ............................................................. 111

Table 9-3: EIA Study Team.............................................................................................................. 122

LIST OF FIGURES

Figure 1-1: Locality of the Holfontein Extension: Integrated Waste Management Facility ..................... 2

Figure 1-2: Simplified Scoping and EIA Process .................................................................................. 9

Figure 2-1: The Waste Management Hierarchy .............................................................................. 22

Figure 4-1: Conceptual layout of the Holfontein Extension: IWMF ...................................................... 41

Figure 4-2: Containment Barrier Designs for Different Class Landfills ................................................ 50

Figure 5-1: Current Land Use at the proposed Holfontein Extension: IWMF...................................... 60

Figure 5-2: General Geology at the Proposed Holfontein Extension: IWMF ...................................... 63

Figure 5-3: Annual average and day/night time wind roses ............................................................... 66

Figure 5-4: Seasonal average wind roses .......................................................................................... 66

Figure 5-5: Surface Water Resources in the Proposed Holfontein Extension: IWMF

Area .............................................................................................................................................. 71

Figure 5-6: Structure of the Wetland Bodies located at the Holfontein Extension: IWMF

(Ecotone Report, 2013). ................................................................................................................ 72

Figure 5-7: Ecological Sensitivity of the Proposed Holfontein Extension: IWMF Area ........................ 74

Figure 5-8: Surface water quality results for electrical conductivity (July 2014)................................... 77

Figure 5-9: Groundwater Quality (electrical conductivity) in weathered Karoo boreholes

(July 2014) .................................................................................................................................... 82

Figure 5-10: Vegetation at the Proposed Holfontein Extension: IWMF .............................................. 86

LIST OF APPENDICES

Appendix A: Application Information

Appendix B: Public Participation Information

Appendix C: Heritage Information




ACRONYMS AND ABBREVIATIONS

± or ~ Approximately

BID Background Information Document

HMC Holfontein Monitoring Committee

DEA Department of Environmental Affairs

DSR Draft Scoping Report

DWS (formerly

DWS and DWSF)

EA

Department of Water & Sanitation (formerly Department of Water Affairs which

was formerly Department of Water Affairs and Forestry)

Environmental Authorisation

EAP Environmental Assessment Practitioner

EIA Environmental Impact Assessment

EIS Ecological Importance and Sensitivity

EMM Ekurhuleni Metropolitan Municipality

EMP(r) Environmental Management Programme (report)

EnviroServ EnviroServ Waste Management Limited

GDARD Gauteng Department of Agriculture and Rural Development

GN R Government Notice Regulation

IAP Interested and Affected Party

IWMF Integrated Waste Management Facility

JAWS Jones & Wagener Consulting Civil Engineers

km Kilometre

m Metre

m3 cubic metre

mamsl Meters above mean sea level

NEMA National Environment Management Act, 1998 (Act No. 107 of 1998)

NEM:AQA National Environmental Management: Air Quality Act, 2004 (Act No. 39 of

2004)

NEM:BA National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of

2004)

NEM:WA National Environment Management: Waste Act, 2008 (Act No. 59 of 2008)

NWA National Water Act, 1998 (Act No. 36 of 1998)

PM2.5 PM10 are inhalable particulates with an aerodynamic diameter < 2.5 µm

PM10 PM10 are inhalable particulates with an aerodynamic diameter < 10 µm

PES Present Ecological Status

PPP Public Participation Process

Synergistics Synergistics Environmental Services (Pty) Ltd

WMH Waste Management Hierarchy

WML Waste Management Licence





SCOPING REPORT (DRAFT)

1. INTRODUCTION

1.1 The Project and its Location

EnviroServ Waste Management Limited (EnviroServ) has proposed the development of the Holfontein

Extension: Integrated Waste Management Facility (Holfontein Extension: IWMF/the project). The

Holfontein Extension: IWMF will include infrastructure, plants and facilities for an integrated, full-service

waste management facility that can receive, store, re-use, recycle, recover and treat Type 0 to Type 4

wastes, as well as provide for the final disposal of both general and hazardous wastes. Waste will be

managed in accordance with procedures advocated by the waste management hierarchy, which

promotes the minimisation, recycling, recovery and treatment of waste prior to disposal. The project will

be in addition to, and an extension of, the waste management operations at EnviroServ’s current

Holfontein Hazardous Waste Disposal Site (HHWDS).

The Holfontein Extension: IWMF will be located immediately adjacent to the HHWDS on portions 15,

16, 28, 31, 32, 33, 34, 38, 39, 48, 72 and 74 of the farm Holfontein 71-IR (Figure 1-1). All of these

properties are owned by EnviroServ. The site is located in Ekurhuleni, Gauteng.

The proposed development of the Holfontein Extension: IWMF is subject to various authorisation/

licensing requirements under legislation administered by different competent authorities. This includes a

waste management licence (WML) in terms of the National Environmental Management Waste Act, 59

of 2008, as amended; an environmental authorisation (EA) in terms of the National Environmental

Management Act, 107 of 1998, as amended; an atmospheric emissions licence (AEL) in terms of the

National Environmental Management Air Quality Act, 39 of 2004, as amended, and a water use licence

(WUL) in terms of the National Water Act, 1998, as amended. A scoping and Environmental Impact

Assessment (EIA) process is required in support of the applications for authorisation/licensing.

The purpose of this scoping report is to identify the potential environmental impacts associated with the

development of the Holfontein Extension: IWMF and to present the ‘plan of study’ for the EIA for the

project.




See separate Electronic Figure

Figure 1-1: Locality of the Holfontein Extension: Integrated Waste Management Facility




1.2 Project Motivation

South Africa produces more than 108 million tons of waste per year of which more than 90% is being

disposed to landfill (Department of Environmental Affairs, 2012). Waste legislation, strategy, principles

and regulations adopted in South Africa aim to improve waste management by moving away from

disposal to more sustainable practices as advocated in the waste management hierarchy (WMH). The

South African government has set a target that 25% of recyclables should be diverted from landfill sites

for re-use, recycling or recovery by 2016 (Department of Environmental Affairs, 2011). The backdrop to

this is acknowledged increases in waste generation; an increasing complexity, coupled with lack of

knowledge of many waste streams and out-dated or a complete lack of waste management

infrastructure. It is evident that new facilities and practices will be required, mostly from the private

sector, if these targets and the other goals set out in the National Waste Management Strategy

document (DEA, 2011) are to be achieved.

According to EnviroServ Waste Management Limited, the company has been providing responsible and

innovative African waste management solutions for more than 33 years. EnviroServ operates through

specialist divisions - each focusing on waste management solutions for particular customer needs.

Through these divisions, EnviroServ is able to offer services and products to cover the hazardous and

non-hazardous waste management requirements of clients from most industries across southern Africa.

Services range from waste minimisation and beneficiation to collection, on-site waste management and

recycling, industrial cleaning, treatment as well as the development and management of state of the art

landfill operations. See www.enviroserv.co.za

EnviroServ state that they aim to be at the forefront of waste management in South Africa and are

continuously researching and developing new methods and technologies for the management,

treatment and disposal of both general and hazardous waste. Through these investigations, EnviroServ

has determined the requirements for an integrated waste management facility that is equipped to

manage multiple waste streams in terms of the requirements of waste legislation, regulations and as

per the principles of the waste management hierarchy. The proposed Holfontein Extension: IWMF will

provide:

• an integrated, full-service waste management facility that can receive, store, re-use, recycle,

recover and treat Type 0 to 4 wastes under GN 636 of the National Environmental

Management: Waste Act, 2008 (Act No. 59 of 2008) (NEM:WA).

• for the final disposal of both general and hazardous wastes in landfill disposal sites.




The various plants comprising the Holfontein Extension: IWMF have been proposed as their

combination will result in a facility equipped to undertake the recycling, recovery and treatment of the

great majority of the waste streams that are expected for the region in the foreseeable future. The

restrictions on waste disposal set out in the National Norms and Standards for Disposal of Waste to

Landfill (GN R 636) have also provided motivation for proposing many of the plants. The Holfontein

Extension: IWMF is in line with the goals of the NWMS and will make significant contribution toward

Goal 1: “Promote waste minimisation, reuse, recycling and recovery of waste”, and Goal 3: “Grow the

contribution of the waste sector to the green economy” of the NWMS.

Landfill sites are also included at the Holfontein Extension: IWMF as the residual wastes that are not

suited to recycling, recovery and treatment will require disposal. It is advantageous to have disposal

capacity immediately adjacent to the waste management plants as this limits costs and risks for both

the waste generator, waste transporter and the waste manager.

The proposed Holfontein Extension: IWMF will continue and expand on operations at the HHWDS. The

HHWDS is a hazardous waste treatment and H:H waste disposal facility operated in terms of waste

management licence(s) (WML) issued by the Department of Environmental Affairs: Chemicals and

Waste Management. The HHWDS is located on portions 23 and 24 of the farm Holfontein 71-IR within

the Ekurhuleni Metropolitan Municipality (EMM) near Springs (Figure 1-1). Due to space limitations and

restrictions, the recycling, recovery and treatment facilities proposed for the Holfontein Extension:

IWMF project cannot take place within the HHWDS. Thus the Holfontein Extension: IWMF has been

proposed on land adjacent to the HHWDS. The proximity of the Holfontein Extension: IWMF to the

HHWDS is both strategically and commercially appropriate, as EnviroServ has invested significantly in

the site in terms of physical infrastructure and has a detailed knowledge of the site and environmental

conditions from the established monitoring networks.

Although the HHWDS has remaining airspace for the disposal of hazardous waste, further disposal

sites have been proposed for the Holfontein Extension: IWMF. Capacity at the HHWDS is fixed and the

consumption of this airspace is determined by disposal rates. Additional disposal capacity for

hazardous wastes is required to match the life of the recycling, recovery and treatment facilities, thus

the Class A disposal facility is proposed. The HHWDS has no appropriate disposal capacity for residual

general wastes and it is required to develop such airspace for waste that will arise from the recycling,

recovery and treatment facilities, but which does not require disposal to a H:H/Class A site. Thus the

Class B disposal facility is proposed.




1.3 Project Need and Desirability

The generation of waste from human activities is a fait accompli. With their high population density and

intensive mining, production and manufacturing industries, Gauteng and Mpumalanga produce large

quantities of waste. Even with significant policy initiatives such as cleaner production, resource

efficiency and waste minimisation these sectors in the Gauteng and Mpumalanga areas will continue to

produce waste. The other main centres in South Africa also produce wastes for which there are not

always appropriate, local waste management facilities. The management and disposal of such waste

requires appropriately designed and operated facilities in order to protect health, well-being and the

environment. EnviroServ maintains that the proposed Holfontein Extension: IWMF facilities will meet

these needs and the objects of the NEMWA and the NWMS.

The waste management philosophy adopted in South Africa advocates the minimisation, recycling,

recovery and treatment of waste prior to disposal. The Holfontein Extension: IWMF project will support

the diversion of waste from landfill, towards more recycling, energy recovery and treatment from waste.

The provision of a variety of waste management facilities at a single location means that EnviroServ will

be able to provide an integrated service that can efficiently and effectively meet a variety of waste

management needs. Waste streams arriving at the site can be directed to the plant or facility most

suited to derive the maximum benefit from the waste and in so doing enable the implementation of the

waste management hierarchy. This will result in the maximum contribution to sustainable development

from waste management. This is directly in line with Goals 1 and 2 of the NWMS.

The waste hierarchy advocates the minimisation, recycling, recovery and treatment of waste prior to

disposal. In terms of the hierarchy the re-use and recycling should be undertaken prior to recovery and

treatment. Many of the plants proposed at the Holfontein Extension: IWMF will enable the re-use and

recycling of waste streams or components of the waste stream. This will generate materials and

products that are available for further use, contribute to reductions in natural resource consumption and

reduce the volume of material requiring disposal.

In terms of the hierarchy the recovery of waste should be undertaken prior to disposal. Energy

generation from waste is a key form of recovery and thermal waste treatment is therefore preferred over

waste disposal. The National Policy on Thermal Treatment of General and Hazardous Waste (2009)

indicates that the national government intends to accept and advance the implementation of thermal

waste treatment technologies as a key aspect of integrated waste management in South Africa.

Thermal waste treatment for the recovery of energy, as proposed at the Holfontein Extension: IWMF is

thus a preferred technology supported by government policy. The recovery of energy from waste also

prevents the total loss of the energy embodied in the waste. Thermal treatment, as provided by the

various plants at the Holfontein Extension: IWMF can provide a 95% reduction of waste by volume,

significantly reducing the volume of material requiring disposal.

The significant reduction in waste requiring disposal after processing at the various plants at the

Holfontein Extension: IWMF will reduce the amount of airspace required and extend the life of all landfill

sites where this material was being disposed.




The operation of an integrated waste management facility with recycling, recovery and treatment

facilities as well as disposal capacity will ultimately minimise the cost of waste management for the

waste generator, particularly through reduced transport and disposal volumes. This will benefit the

economy as these savings should be passed back into the supply chain. Additionally, the operation of

an integrated waste management facility enables waste to be managed at a single site rather than

being moved between facilities. This reduces the risks associated with the transport of waste and

benefits human health and the environment.

The recycling, recovery and treatment facilities at the Holfontein Extension: IWMF will significantly

reduce the volume of solid and liquid waste disposed to landfill at the HHWDS, as well as to the future

disposal sites located at the Holfontein Extension: IWMF. This will improve the overall sustainability of

the facilities and the contribution to sustainable development. The integrated approach will also enable

the disposal site to comply with the waste disposal restrictions that are set out in the Norms and

Standards for Disposal of Waste to Landfill (GN R 636).

Development of the Holfontein Extension: IWMF will result in the creation of sustainable jobs in the

waste management sector. The great majority of these jobs will be available to historically

disadvantaged individuals and local persons. In addition to direct employment, there will be many

downstream jobs in waste collection and transport, as well as upstream jobs in transport,

manufacturing, beneficiation and use of the materials and products. This is directly in line with Goal 3 of

the NWMS.

The Holfontein location is well placed to service ‘Africa’s Workshop’ in Ekurhuleni, businesses and

industries in Gauteng and mines and industries in Mpumalanga as well as other major centres in central

South Africa. The continued growth in the population and manufacturing output of these regions results

in the production of large volumes of waste that requires management. The Holfontein site is well

located to service these areas, with good accessibility from the N12 highway. Although the region has

urbanised significantly in the past two decades, there are no residential areas within 1.6 kilometres of

the site. The nearest significant residential populations are further than 3 km from the site and thus the

site is relatively isolated from potentially sensitive receptors and therefore appropriate for use in the

management of waste.




EnviroServ maintains that while the Holfontein Extension: IWMF may increase overall environmental

impacts in the Holfontein area, this is significantly preferable to the alternative of EnviroServ

establishing a second facility at a different site. The incremental impacts at the Holfontein area are likely

to be much less than direct impacts at any new greenfield site. The benefit of containing the impacts to

a single area is supported by the fact that the HHWDS already has a buffer zone that includes

restrictions on land use (and will likely to continue to do so for many years beyond closure). The

Holfontein Extension: IWMF will be located within the HHWDS buffer zone and thus have relatively little

influence on land use patterns, although the buffer zone may need to be extended. EnviroServ has

significant amounts of baseline data on the conditions at the site; well established monitoring networks;

and is aware of the resources and key sensitive receptors around the site. This will enable potential

impacts to be accurately identified, mitigated for in the design and planning and managed during

operations. It would require many years to establish the same level of knowledge of an alternative site

and thus the proposed site is preferable to another site.

1.4 Terms of Reference

Synergistics Environmental Services (Pty) Ltd (Synergistics) was appointed by EnviroServ as the

independent Environmental Assessment Practitioner (EAP) to undertake the necessary environmental

work to meet the requirements of informing the process for a waste management licence,

environmental authorisation, atmospheric emissions licence and water use licence for the Holfontein

Extension: IWMF.

Synergistics has no vested interest in the proposed project and has declared its independence as

required by the EIA Regulations.

EAP details 1.4.1

Synergistics Environmental Services (Pty) Ltd (an SLR Group Company)

Contact Person: Matthew Hemming

Designation: Environmental Assessment Practitioner

Tel: 011 467 0945

Fax: 011 467 0978

Email: [email protected]/ [email protected]

Postal Address: PO Box 1596, Cramerview, 2060

EAP: Matthew Hemming

EAP Expertise: MSc (Conservation Biology), UCT, 2001. Member of IAIA and IWMSA

8.5+ years’ environmental management and assessment experience, specifically in the mining and waste management sectors.

Applicant Details 1.4.2

For the purposes of the EIA, the following person is the nominated applicant at EnviroServ.


Contact Person: Neil Brink

Designation: National Compliance Manager




Tel: 011 456 5400

Fax: 011 456 5607

Email: [email protected]

Postal Address: PO Box 9385, Edenglen, 1613

1.5 Environmental Assessment and Authorisation Process

In order to inform the authorisations required for the Holfontein Extension: IWMF, a scoping and EIA

process, as stipulated in the EIA Regulations (GN R 543 – 547 of July 2010) made under section 24(5)

of the NEMA must be conducted. See Figure 1-2 for the phases of the scoping and EIA process.

The undertaking of a scoping and EIA process in support of applications for a WML, EA and AEL for the

Holfontein Extension: IWMF commenced in November 2013. The respective departments accepted the

application forms and provided reference numbers. The application for the AEL will be submitted to

EMM following the completion of the air quality study.

This draft Scoping Report (DSR) forms the first phase of the EIA process and documents the initial

identification of the environmental issues associated with the proposed development of the Holfontein

Extension: IWMF. The DSR also presents the ‘plan of study’ for the EIA that sets out the scope and

method of the investigations required to assess the potential impacts of the project. The DSR and plan

of study for EIA have been compiled in accordance with the EIA Regulations (GNR 543, June 2010)

and will be submitted to DEA for acceptance in terms of the NEM:WA, NEMA and EIA Regulations.




Figure 1-2: Simplified Scoping and EIA Process

SCOPING, PUBLIC &

AUTHORITY CONSULTATION

TO IDENTIFY ISSUES & CONCERNS

UNDERTAKE SPECIALIST STUDIES:

Visual, Soils, Traffic, Air Quality, Surface

water, Ecology, Wetlands, Hydrogeology,

ENVIRONMENTAL IMPACT ASSESSMENT &

MANAGEMENT PROGRAMME

SUBMIT FINAL EIA/EMP REPORT TO AUTHORITY

SUBMIT APPLICATIONS TO AUTHORITIES

NEMA EIA PROCESS

SUBMIT SCOPING TO AUTHORITY

PUBLIC REVIEW OF SCOPING

PUBLIC REVIEW OF EIA/EMP

AUTHORISATION

ACCEPTANCE OF SCOPING

APPEAL PROCESS




1.6 Competent Authorities

Four (4) different applications to the competent authorities are required in order to authorise the

Holfontein Extension: IWMF under the National Environmental Management Act, 1998, as amended

(NEMA), National Environmental Management: Waste Act, 2008, as amended (NEM:WA), National

Environmental Management: Air Quality Act, 2004 (NEM:AQA) and National Water Act, 1998 (NWA).

These are detailed in the table below.

Table 1-1: Detail of applications for authorisation of the H:IWMF

Legislation Listed Activities Process

required

Competent Authority


Management: Waste Act,

2008

Category A and B

waste management

activities listed in GN R

921 of November 2013

Scoping and EIA National Department of Environmental

Affairs: Chemicals & Waste

Management.


Management Act, 1998

Activities in listing

Notice 1, 2 and 3, GN

R 544, 545 and 546 of

June 2010.

Scoping and EIA Gauteng Department of Agriculture and

Rural Development: Sustainable Use of

the Environment.


Management: Air Quality

Act, 2004

Listed atmospheric

emission activities, GN

R 893 of November

2013.

Approved EA and

application forms

Ekurhuleni Metropolitan Municipality:

Environmental Development

Department: Air Quality Management

National Water Act, 1998 Section 21 of the Act. Integrated Water

Use Licence

Application

Department of Water & Sanitation

WML 1.6.1

The waste management licence form was submitted to the Department of Environmental Affairs (DEA):

Chemicals and Waste Management Directorate who acknowledged receipt and provided a reference

number on 6 December 2013. Reference: 12/9/11/L1406/3.

EA 1.6.2

The environmental authorisation form was submitted to the Gauteng Department of Agriculture and

Rural Development (GDARD) which acknowledged receipt and provided a reference number on

February 2014. Reference: Gaut: 002/13-14/E0241.




AEL 1.6.3

The authority for the issuing of atmospheric emissions licences in terms of the NEMAQA has been

delegated to the municipal level. Holfontein falls within the Ekurhuleni Metropolitan Municipal(EMM)

and this Municipality is the competent authority. The EMM has been informed of the Holfontein

Extension: IWMF and an application for the AEL will be completed once the relevant project details and

the air quality impact assessment study have been finalised.

WUL 1.6.4

The application for the IWULA will be submitted to Department of Water and Sanitation (DWS) following

the completion of the facility designs and geohydrological studies. The DWS has been informed of the

Holfontein Extension: IWMF project and is involved as a commenting authority for the scoping and EIA.

1.7 Structure of the Scoping Report

The DSR is structured in accordance with GNR 543 and includes the consolidated results of the public

participation and authority consultation processes conducted to date. Table 1-2 provides a summary of

the requirements of GNR 543, with cross references to the report sections where these requirements

have been addressed.

Table 1-2: Structuring of the Scoping Report in terms of GNR 543 Requirements

Legal and Regulatory Requirement Cross Reference to Report Section

GNR 543 Section 27

After having submitted an application, the EAP managing the application must:

(f) Prepare a scoping report in accordance with regulation 28 This Report.

GNR 543 Section 28(1)

A scoping report must contain all information that is necessary for a proper understanding of the nature of the issues identified during scoping and must include:

a) Details of:

(i) the EAP who prepared the report; and

(ii) the expertise of the EAP to carry out scoping procedures;

See Project Information Sheet

b) A description of the proposed activity; See Section 4,

c) A description of any feasible and reasonable alternatives that have

been identified;

See sections within Section 4.5

d) A description of the property on which the activity is to be undertaken and the location of the activity on the property, or if it is:

(i) a linear activity, a description of the route of the activity; or

(ii) an ocean-based activity, the coordinates where the activity is to be undertaken;

See Section 5.3,

Table 5-1 for list of affected properties

e) A description of the environment that may be affected by the activity and the manner in which activity may be affected by the environment;

See Section 5 (entire chapter) - Description of the Affected Environment

f) An identification of all legislation and guidelines that have been considered in the preparation of the scoping report;

See Section 2

g) A description of environmental issues and potential impacts, including cumulative impacts, that have been identified;

See Section 8 and Table 8-1




Legal and Regulatory Requirement Cross Reference to Report Section

h) Details of the public participation process conducted in terms of regulation 27(a), including:

(i) The steps that were taken to notify potentially interested and affected parties of the application;

(ii) Proof that notice boards, advertisements and notices notifying potentially interested and affected parties of the application have been displayed, placed or given;

(iii) A list of all persons or organisations that were identified and registered in terms of regulation 55 as interested and affected parties in relation to the application; and

(iv) A summary of the issues raised by interested and affected parties, the date of receipt of and the response of the EAP to those

issues;

See Section 3.6 (steps taken and process followed), and

Section 7 (results of public consultation followed with summary of issues raised), as well as Appendix B (copies of all

relevant documentation and correspondence).

i) A description of the need and desirability of the proposed activity; See Section 1.2

j) A description of identified potential alternatives to the proposed activity, including advantages and disadvantages that the proposed activity or alternatives may have on the environment and the community that may be affected by the activity;

See sections within Section 9.2

k) Copies of any representations, and comments received in connection with the application or the scoping report from interested and affected parties;

See Appendix B.

l) Copies of the minutes of any meetings held by the EAP with interested

and affected parties and other role players which record the views of the participants; and

See Appendix B.

m) Any responses by the EAP to those representations and comments and views;

See Section 7 and Appendix B.

n) A plan of study for environmental impact assessment which sets out the proposed approach to the environmental impact assessment of the application, which must include:

See Section 9.

(i) A description of the tasks that will be undertaken as part of the environmental impact assessment process, and the manner in which such tasks will be undertaken;

See Section 9




2. Environmental Legal Requirements and Guidelines

In accordance with EIA sub regulation 28(1f) of GN R 543, all legislation and guidelines that have been

considered in the preparation of the Scoping Report are documented. This section lists environmental

legislation that has been identified as being pertinent to the proposed Holfontein Extension: IWMF.

The activities that will be undertaken at the proposed Holfontein Extension: IWMF are regulated by

various legislation and multiple authorisation/licences are required from the competent authorities prior

to the commencement of the project. This section also lists the specific activities for which

authorisation/licences have been applied (as set out in the application forms).

2.1 National Environmental Management Act, 1998

The National Environmental Management Act, 1998, as amended, prohibits the commencement of

certain controlled (or ‘listed’) activities. In terms of Section 24 (1) of NEMA the potential environmental

impact associated with these listed activities must be considered, investigated, assessed and reported

on to the competent authority for the granting of an environmental authorisation.

The Environmental Impact Assessment Regulations define the requirements for the submission,

processing, consideration and decision of applications for environmental authorisation of listed

activities. Any activity that is captured in the listing notices requires environmental authorisation from

the competent authority. The EIA Regulations have been revised twice in the last 10 years and the

current Regulations are of June 2010 (GNR 543). The activities require either a Basic Assessment or

an Environmental Impact Assessment process in order to inform a decision from the competent

authority. Activities set out in Listing Notices 1, 2 and 3 of the 2010 EIA Regulations (GN R 544, 545

and 546 of June 2010) with relevance to the Holfontein Extension: IWMF are detailed in Table 2-1.

Environmental authorisation is required and a scoping and environmental impact assessment process

must be undertaken in support of the application.

Table 2-1: Listed EIA Activities applicable to the Holfontein Extension: IWMF

NOTICE ACTIVITY

NO.

DESCRIBE EACH LISTED ACTIVITY

APPLICABILITY OF ACTIVITY

GNR 544, 18 June 2010

1 The construction of facilities or infrastructure for the generation of electricity where:

(i) the electricity output is more than 10 megawatts but less than 20 megawatts; or

(ii) the output is 10 megawatts or less but the total extent of the facility covers an area in excess of 1 hectare.

The construction of the Waste to Energy plants, Gasifier and Anaerobic Digester, which may produce electricity in excess of the thresholds.

GNR 544, 18 June 2010

9 The construction of facilities or infrastructure exceeding 1 000 meters in length for the bulk transportation of water, sewage or storm water –

(i) with an internal diameter of 0.36 meters or more; or

(ii) with a peak throughput of 120 litres per second or more, excluding where:

Storm water drains and canals close to watercourse.




a. such facilities or infrastructure are for bulk transportation of water, sewage or storm water or storm water drainage inside a road reserve; or

b. where such construction will occur within urban areas but further than 32 meters from a watercourse, measured from the edge of the watercourse.

GNR 544, 18 June 2010

10 The construction of facilities or infrastructure for the transmission and distribution of electricity –

(i) outside urban areas or industrial complexes with a capacity of more than 33 but less than 275 kilovolts; or

(ii) inside urban areas or industrial complexes with a capacity of 275 kilovolts or more.

Power line connection to the grid from electrical generation plants.

GNR 544, 18 June 2010

11 The construction of: (i) canals; (ii) channels; (iii) bridges; (iv) dams; (v) weirs; (vi) bulk storm water outlet structures; (vii) marinas; (viii) jetties exceeding 50 square meters in size; (ix) slipways exceeding 50 square meters in

size; (x) buildings exceeding 50 square meters in

size; or (xi) infrastructure or structures covering 50

square meters or more.

where such construction occurs within a watercourse or within 32 meters of a watercourse, measured from the edge of a watercourse, excluding where such construction will occur behind the development setback line.

Storm water drains, canals and other infrastructure in excess of 50 square metres, in or close to watercourse.

GNR 544, 18 June 2010

13 The construction of facilities or infrastructure for the storage, or for the storage and handling, of a dangerous good, where such storage occurs in containers with a combined capacity of 80 but not exceeding 500 cubic meters.

Chemical and fuel storage may exceed 80 cubic metres.

GNR 544, 18 June 2010

18 The infilling or deposit ing of any material of more than 5 cubic meters into, or the dredging, excavation, or removal or moving of soil, sand, shells, shell grit, pebbles or rock of more than 5 cubic metres from:

(i) a watercourse; (ii) the sea; (iii) the seashore; (iv) the littoral active zone, an estuary or a

distance of 100 meters inland of the high-water mark of the sea or an estuary, whichever distance is the greater-

but excluding where such inf illing, depositing, dredging, excavation, removal or moving

(i) is for maintenance purposes undertaken in accordance with a management plan agreed to by the relevant environmental authority; or

(ii) occurs behind the development setback line.

Possible removal and infilling of material into watercourse in order to complete construction.

GNR 545, 18 June 2010

1 The construction of facilities or infrastructure for the generation of electricity where the electricity output is 20 megawatts or more.

The Waste to Energy Incinerator may have the capacity to produce more than 20 MW.




GNR 545, 18 June 2010

15 Physical alteration of undeveloped, vacant or derelict land for residential retail, commercial, recreational, industrial or institutional use where the total area to be transformed is 20 hectares or more:

Except where such physical alteration takes place for: (i) linear development activities; or (ii) agriculture or afforestation where activity 16

in this Schedule will apply.

Development footprint of the Holfontein Extension: IWMF is bigger than 20 ha.

GNR 545, 18 June 2010

26 Commencing of an activity, which requires an atmospheric emission license in terms of section 21 of the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004), except where such commencement requires basic assessment in terms of Notice of No. R544 of 2010.

The Waste to Energy plant and other plants require an atmospheric emission license.

GNR 545, 18 June 2010

(previously GN 921 of 29 Nov

2013: B(7))

27 The treatment construction of facilities for the treatment of effluent, wastewater or sewage with an annual daily throughput capacity of 15 000 cubic metres or more.

The Effluent Treatment Plant may have the capacity to process more than 15 000 cubic metres of effluent per day.

GNR 546, 18 June 2010

4 The construction of a road wider than 4 meters with a reserve less than 13,5 meters.

(b) In Gauteng: (i) A protected area identified in terms of

NEMPAA, excluding conservancies; (ii) National Protected Area Expansion Strategy

Focus areas; (iii) Sensitive areas as identified in an

environmental management framework as contemplated in chapter 5 of the Act and as adopted by the competent authority.

(iv) Sites identified in terms of the Ramsar Convention;

(v) Sites identified as irreplaceable or important in the Gauteng Conservation plan;

(vi) Areas larger than 2 hectares zoned for use as public open space;

(vii) Areas zoned for a conservation purpose. (viii) Any declared protected area including

Municipal or Provincial Nature Reserves as contemplated by the Environment Conservation Ordinance (Ordinance 12 of 1983);

(ix) Any site identified as land with high agricultural potential located within the Agricultural Hubs or Important Agricultural Sites identified in terms of the Gauteng Agricultural Potential Atlas, 2006.

Internal roads within the facility will cross sensitive areas.

GNR 546, 18 June 2010

10 The construction of facilities or infrastructure for the storage, or storage and handling of a dangerous good, where such storage occurs in containers with a combined capacity of 30 but not exceeding 80 cubic meters.

(c) In Gauteng:

(i) A protected area identified in terms of NEMPAA, excluding conservancies;

(ii) National Protected Area Expansion Strategy Focus areas;

Chemical storage may exceed 30 cubic metres and be within sensitive areas.




(iii) Sensitive areas as identified in an environmental management framework as contemplated in chapter 5 of the Act and as adopted by the competent authority;

(iv) Sites or areas identif ied in terms of an International Convention;

(v) Sites identified as irreplaceable or important in the Gauteng Conservation Plan;

(vi) Within 100 meters of a watercourse or within 100 meters of wetland that is not linked to a watercourse;

(vii) Any declared protected area including Municipal or Provincial Nature Reserves as contemplated by the Environment conservation Act, 1989 (Act No. 73 of 1989), the Nature Conservation Ordinance (Ordinance 12 of 1983) and the NEMPAA.

GNR 546, 18 June 2010

16 The construction of: (i) jetties exceeding 10 square meters in size; (ii) slipways exceeding 10 square meters in size; (iii) buildings with a footprint exceeding 10 square meters in size; or

(iv) infrastructure covering 10 square meters or more.

Where such construction occurs within a watercourse or within 32 meters of a watercourse, measured from the edge of a watercourse, excluding where such construction will occur behind the development setback line.

b) In Gauteng:

(i) A protected area identified in terms of NEMPAA, excluding conservancies;

(ii) National Protected Area Expansion Strategy Focus areas;

(iii) Sensitive areas as identified in an environmental management framework as contemplated in chapter 5 of the Act and as adopted by the competent authority;

(iv) Sites or areas identif ied in terms of an International Convention;

(v) Site identif ied as irreplaceable or important in the Gauteng Conservation Plan;

(vi) Any declared protected area including Municipal or Provincial Nature Reserves as contemplated by the Environment Conservation Act, 1989 (Act No. 73 of 1989) and the Nature Conservation Ordinance (Ordinance 12 of 1983);

(vii) Areas zoned for a conservation purpose.

Infrastructure in excess of 10 square metres, in or close to, a watercourse and within sensitive areas.

EIA Guidelines 2.1.1

The EIA Regulations provide clear instructions on the required content of a scoping report and this

report has been prepared in accordance with these regulations. In addition, a number of guidelines to

NEMA and the EIA Regulations have been published to assist in the scoping and EIA process.

Guidelines that have been considered include:




• Integrated Environmental Management Guideline Series (5): Companion to the Environmental

Impact Assessment Regulations, 2010 (DEA, 2012).

• Integrated Environmental Management Guideline Series (7): Public Participation 2010 (DEA,

2010).

• Integrated Environmental Management Guideline Series (9): Draft Guideline on Need and

Desirability in terms of the Environmental Impact Assessment Regulations, 2010 (DEA, 2012).

2.2 National Environmental Management: Waste Act, 2008

• The requirements of the National Environmental Management: Waste Act, 2008, as amended,

came into effect on 1 July 2009. The Act makes provision for the identification of various waste

management activities which may have a detrimental effect on the environment. A waste

management activity identified in terms of the Act may not commence, be undertaken or conducted

except in accordance with published standards or a Waste Management Licence. The NEMWA has

been amended by:

o National Environmental Management Laws Amendment Act, 2013 (Act No. 14 of 2013);

o National Environmental Management Laws Second Amendment Act, 2013 (Act No. 30 of

2013) (influenced NEMWA under NEMA, but no direct change to NEMWA ;

o National Environmental Management Laws Third Amendment Act, 2014 (Act No. 25 of

2014); and

o National Environmental Management Waste Amendment Act, 2014 (Act No. 26 of 2014)

On 3 July 2009 the list of waste management activities requiring a Waste Management Licence from a

competent authority were published (GN R 718). Listed waste management activities are divided into

Category A and Category B in the schedule. Activities identified in Category B require an Environmental

Impact Assessment process, as stipulated in the Environmental Impact Assessment Regulations (GN

R543) of the NEMA, in order to inform an application for a waste management licence.

Where a waste management licence is required for Category B activities, a scoping and environmental

impact assessment process must be undertaken in support of the application. The assessment and

reporting process in support of the waste management licence is being undertaken in accordance with

the 2010 EIA Regulations (GN R543). These Regulations define the requirements for the submission,

processing, consideration and decision of applications for environmental authorisation of listed

activities.




Waste management activities with potential relevance to the Holfontein Extension: IWMF are detailed in

the table below. Note that the Schedule of waste management activities (GNR 718) requiring a waste

management licence in terms of the NEMWA has been replaced (GN R 921) effective 29 November

2013. This update took place after the waste management licence application form was submitted. The

transitional provisions in the Schedule detail the handling of applications pending at the time of the

replacement and apply to this application (see Section 7(2), (3) and (4).

Table 2-2: Waste management activities applicable to the Holfontein Extension: IWMF

CATEGORY AND

ACTIVITY

NO. UNDER GN 718 OF 3 JULY 2009

CATEGORY AND ACTIVITY NO. UNDER GN

921 OF 29 NOVEMBER

2013

DESCRIPTION OF LISTED ACTIVITY

(text as per GN R 921)

APPLICABILITY

A(1) C(1) The storage, including the temporary storage, of general waste at a facility that has the capacity to store in excess of 100 m3 of general waste at any one time, excluding the storage of waste in lagoons.

More than 100 m3 of various general waste streams may be stored on the site as inputs to the various plants.

WML not required, but compliance to the Norms and Standards is.

A(2) C(2) The storage including the temporary storage of hazardous waste at a facility that has the capacity to store in excess of 35 m3 (80 m2 under GN 921) of hazardous waste at any one time, excluding the storage of hazardous waste in lagoons.

More than 80 m3 of various hazardous waste streams may be stored on the site as inputs to the various plants.


A(4) C(3) The storage of waste tyres in a storage area exceeding 500 m2.

The waste tyre storage area may exceed this size.

WML not required, but compliance to the Waste Tyre Regulations is.

A(5) A(2) The sorting, shredding, grinding or bailing of general waste at a facility that has the capacity to process in excess of one ton of general waste per day an operational area in excess of 1000 m2 .

Plants such as the Material Recovery Facility and Plastic Beneficiation Plant may have operational areas in excess of the threshold.

A(7) A(3) The recycling or re-use of general waste of more than 10 tons per month. The recycling of general waste at a facility that has an operational area in excess of 500 m2, excluding recycling that takes place as an integral part of an internal manufacturing process within the same premises.

Plants such as the Material Recovery Facility and Plastic Beneficiation Plant may have operational areas in excess of the threshold.

A(8) A(5) The recovery of waste including the refining, utilisation, or co-processing of the waste at a facility that has the capacity to process in excess of three 10 tons but 100 tons of general waste per day or in excess of 500kg but less than 1 ton of hazardous waste per day, excluding recovery that takes place as an integral part of an internal manufacturing process within the same premises.

Recovery of energy from more than 10 tons of general waste per day may take place at plants such as the Waste to energy, Gasifier and Anaerobic Digester plants.

A(9) A(6) The biological, physical or physico-chemical treatment of general waste at a facility that has the capacity to process in excess of 10 tons of general waste per day. The treatment of general waste using any form of treatment at a facility that has the capacity to process in excess of 10 tons but less than 100 tons.

Various plants will treat more than 10 tons of general waste per day.




A(10) - The processing of waste at biogas installations with a capacity to process in excess of five tons per day of bio-degradable waste.

No listing

A(13) C(5) The extraction, recovery or flaring of landfill gas. Landfill gas from the general waste disposal site will be extracted, recovered and flared. Energy may be generated.


A(18) A(12) The construction of facilities for activities listed in Category A of the schedule.

The construction of all facilities triggering Category A activities.

B(1) B(1) The storage including the temporary storage of hazardous waste in lagoons excluding storage of effluent, wastewater or sewage.

Hazardous wastes and leachate for treatment at various plants will be stored in lagoons.

B(2) B(2) The reuse and recycling of hazardous waste in excess of 1 ton per day, excluding reuse or recycling that takes place as an integral part of an internal manufacturing process within the same premises.

Recycling of various hazardous waste streams, to customer specifications, will be undertaken at the site in excess of 1 ton per day.

B(3) B(3) The recovery of waste including the refining, utilisation or co-processing of waste at a facility with a capacity to process more than 500 kg in excess of 100 tons of general waste per day or in excess of 1 ton of hazardous waste per day excluding recovery that takes place as an integral part of an internal manufacturing process within the same premises or unless the Minister has approved re-use guidelines for the specific waste stream.

Recovery of energy and other materials may be undertaken at facilities that have the capacity to recover in excess of the thresholds. .

B(4) As per B(4) The biological, physical or physico-chemical treatment of hazardous waste at a facility that has the capacity to receive in excess of 500 kg of hazardous waste per day.

B(5) B(4) The treatment of hazardous waste in excess of 1 ton per day calculated as a monthly average; using any form of treatment regardless of the size or capacity of such a facility to treat such waste excluding the treatment of effluent, wastewater or sewage.

Various plants will be used for the treatment of hazardous wastes, which will have the capacity to receive and treat hazardous wastes in excess of the threshold.

B(7) B(7) The treatment of effluent, wastewater or sewage with an annual throughput capacity of 15 000 cubic metres or more.

Not applicable. Now listed under the EIA Regulations with a daily threshold.

B(8) B(8) The incineration of waste regardless of the capacity of such a facility.

The Waste to Energy and HCRW facilities will incinerate waste.

B(9) B(7) The disposal of any quantity of hazardous waste to land.

Hazardous waste will be disposed to land.

B(10) B(8) The disposal of general waste to land covering an area in excess of 200 m2 and with a total capacity exceeding 25 000 tons.

General waste will be disposed to land over an area of more than 200 m2 in size.

B(11) B(10) The construction of a facility for a waste management activity listed in Category B of this schedule.




Various policies, regulations and guidelines relating to the management of waste have been published.

Those that are relevant to the Holfontein Extension: IWMF are described below.

• National Waste Information Regulations (GN R 625 of August 2012);

These regulate the collection of data to fulfil the objectives of the national waste information system and

apply to persons whom undertake waste management activities listed in Schedule 1 of the regulations.

The Gauteng Province has the Gauteng Waste Information System (Gauteng Waste Information

Regulations, 2004. GN R: 3035b) which all waste managers in Gauteng must report to on a monthly

basis.

• Waste Classification and Management Regulations (GN R634 of August 2013);

These regulate the classification of waste in terms of SANS 10234; prescribe the requirements for the

disposal of waste to landfill; prescribe requirements and timeframes for the management of certain

wastes and prescribe the general duties of waste generators, transporters and managers.

• National Norms and Standards for the Assessment of Waste for Landfill Disposal (GN R 635

of August 2013);

These prescribe the requirements for the assessment of waste prior to disposal to landfill.

• National Norms and Standards for Disposal of Waste to Landfill (GN R 636 of August 2013);

These determine the requirements for the disposal of waste to landfill.

• National Norms and Standards for the Storage of Waste (GN R 926 of November 2013);

These provide a uniform approach to the management of waste storage facilities; set out best practice

and provide minimum standards for the design and operation of waste storage facilities.

• National Norms and Standards for the Scrapping and Recovery of Motor Vehicles (GN R 925

of November 2013);

These aim to control the scrapping or recovery of motor vehicles in order to minimise potential impacts

on the bio-physical and socio-economic environment.

• Revised Schedule of Listed Waste Management Activities (GN R 921 of November 2013), as

amended by GN R 332 of 2 May 2014;

• National Norms and standards for the Remediation of Contaminated Land & Soil Quality (GN

R 331 of May 2014).

These provide a uniform approach to determine the contamination status of an investigation area; limit

uncertainties regarding the criteria and methods to apply in assessment of contaminated land and

provide minimum standards for assessing environmental protection measures for remediation activities.




National Waste Management Strategy 2.2.1

The purpose of the National Waste Management Strategy (GN344 of 4 May 2012) (NWMS) is to ensure

that the objectives of the NEMWA are achieved. The NWMS identifies some of the major waste

challenges in South Africa and provides a plan to address these. The NWMS is structured against a

framework of eight goals. An action plan that sets out how the goals and targets will be met forms part

of the strategy, and the actions include the roles and responsibilities for different spheres of

government, industry and the civil society. The eight goals are:

1. Promote waste minimisation, re-use, recycling and recovery of waste.

2. Ensure the effective and efficient delivery of waste services.

3. Grow the contribution of the waste sector to the green economy.

4. Ensure that people are aware of the impact of waste on their health, well-being and the

environment.

5. Achieve integrated waste management planning.

6. Ensure sound budgeting and financial management for waste services.

7. Provide measures to remediate contaminated land.

8. Establish effective compliance with and enforcement of the NEM:WA.

Two of the goals in the NWMS are particularly relevant to the Holfontein Extension: IWMF, these are:

“Goal 1: Promote waste minimisation, reuse, recycling and recovery of waste”, and “Goal 3: Grow the

contribution of the waste sector to the green economy.”

Although disposal is currently the most common method to manage waste in South Africa, the National

Waste Management Strategy (2011) and supporting legislation promotes the implementation of the

waste management hierarchy (WMH). The WMH advocates the minimisation, recycling, recovery and

treatment of waste prior to disposal. In terms of the WMH, the recovery of waste should be undertaken

prior to disposal, but only after minimisation and recycling.

Waste Management Hierarchy 2.2.2

The internationally recognised principles of the Waste Management Hierarchy place strong emphasis

on reduction, recycling and recovery as preferred ways to deal with waste that has been generated.

The waste management hierarchy thus aims to reduce the volume of waste disposed of at landfill sites

as resources are lost and the disposal site poses risk, now and in future years. The key principles of the

waste management hierarchy are to:

• Reduce / minimise waste sources and generation, as a key priority;

• Maximise the re-use and recycling of wastes, where practical;

• Recover energy from the non-recyclable residues, prior to disposal to landfill.




Any reduction, re-use, recycling or recovery of waste must result in the use of fewer natural resources

than production of the materials would, and to the extent possible, be less harmful to the environment

than disposal of such waste. What is also clear is that although waste avoidance and recycling come

before energy recovery in the waste management hierarchy principles, this does not mean that energy

recovery is precluded as a waste management option, but only that waste avoidance and recycling

should be given preference ahead of energy recovery. An integrated approach remains necessary to

practically deal with the full volume of waste.

Figure 2-1: The Waste Management Hierarchy

National Policy on Thermal Treatment of General and Hazardous Waste 2.2.3

The DEA published a National Policy on Thermal Treatment of General and Hazardous Waste (GN R

777, July 2009) to set out the Government’s position on the thermal waste treatment as an acceptable

waste treatment option and to provide the framework within which such waste treatment options should

be implemented. The policy objectives clearly set out to accept and advance the implementation of

waste incineration as means to recover energy from waste and integrate thermal waste treatment

technologies as a key aspect of an integrated waste management system in South Africa. Schedule 4

of the National Policy provides guidance on the conditions that should be applied as a minimum to the

thermal waste treatment technologies. Cognisance will be given to these conditions when undertaking

the environmental impact assessment process for the Holfontein Extension: IWMF.

Prevention and Minimization

Reuse

Recycling

Treatment and

Recovery

Disposal




Environment Conservation Act, 1989 2.2.4

Certain aspects of waste were previously regulated under section 20 of the Environment Conservation

Act, 1989 (Act No. 73 of 1989). The Environment Conservation Act, 1989 is largely repealed and

replaced by the NEMWA. However, the Waste Tyre Regulations (GN R 149 of 2009) remain in effect.

2.3 National Environmental Management: Air Quality Act, 2004

The National Environmental Management: Air Quality Act, 2004 has been promulgated with the

objective of reforming the law regulating air quality in order to protect the environment. It also aims to

comply with general environmental policies and to bring legislation in line with international air quality

management practices. All outstanding sections of the Act came into effect on the 1st of April 2010

(Government Gazette, 26 March 2010). The Act has established a National Framework for Air Quality

Management with standards.

A revised schedule of Listed Activities and Minimum National Emission Standards was published on the

22nd of November 2013 (GN R 893). Listed activities may only be undertaken after an AEL has been

obtained and must comply with the prescribed emissions standards set for that activity. Certain

components of the Holfontein Extension: IWMF will need to be authorised through an AEL that details

each of the point sources at the facility. Emissions activities with potential relevance to the Holfontein

Extension: IWMF are detailed in Table 2-3. An atmospheric emissions licence is required.

Table 2-3: Atmospheric emission activities applicable to the Holfontein Extension: IWMF

Government

Notice

Category No Applicability of the listed activity

GNR 893 of November 2013

Category 8.1: Thermal Treatment of general and hazardous waste. Facilities where general and hazardous waste are treated by the application of heat. (facilities treating 10kg per day of waste)

All of the plants at the Holfontein Extension: IWMF applying heat will require approval. This may include the HCRW plants, Solvent plant, the Waste to Energy plant, the Gasifier and the Pyrolysis facility.

Category 8.2: Crematoria and Veterinary Waste Incineration. Cremation of human remains, companion animals and the incineration of veterinary wastes.

The HCRW plants at the Holfontein Extension: IWMF may require approval.

Applicable Air Quality Guidelines and Standards 2.3.1

Air quality guidelines and standards are fundamental to effective air quality management, providing the

link between the source of atmospheric emissions and the user of that air at the downstream receptor

site. The ambient air quality standards and guideline values indicate safe daily exposure levels for the

majority of the population, including the very young and the elderly, throughout an individual’s lifetime.

Air quality guidelines and standards are normally given for specific averaging or exposure periods.




2.3.1.1 National Minimum Emission Standards

Listed Activities and National Minimum Emission Standards were published on the 22nd of November

2013 (GN R 893). National Minimum Emission Standards applicable to the Holfontein Extension: IWMF

are:

Table 2-4: Minimum emission standards for Sub Category 8.1

Description Facilities where general and hazardous are treated by the application of heat.

Application All installations treating 10kg per day of waste

Substance or mixture of substances Plant

Status

mg/Nm3 under normal conditions of

10% O2, 273 Kelvin and 101.3 kPa Common name Chemical symbol

Particulate Matter N/A New 10

Carbon monoxide CO New 50

Sulphur Dioxide SO2 New 50

Oxides of nitrogen NOx expressed as

NO2

New 200

Hydrogen chloride HCl New 10

Hydrogen fluoride HF New 1

Sum of lead, arsenic,

antimony, chromium,

cobalt, copper,

manganese, nickel,

vanadium

New 0.5

Mercury Hg New 0.05

Cadmium Thallium Cd+Tl New 0.05

Total organic

compounds

TOC New 10

Ammonia NH2 New 10

ng I-TEQ/ Nm3 under normal conditions

of 10% O2, 273 Kelvin and 101.3 kPa

Dioxins and furans PCDD/PCDF New 0.1

2.3.1.2 National Ambient Air Quality Standards for Criteria Pollutants

Criteria pollutants are considered those pollutants most commonly found in the atmosphere, that have

proven detrimental health effects when inhaled and are regulated by ambient air quality criteria.




The South African Bureau of Standards (SABS) was engaged to assist DEA in the facilitation of the

development of ambient air quality standards. This included the establishment of a technical committee

to oversee the development of standards. Standards were determined based on international best

practice for PM10, dustfall, SO2, NO2, O3, CO, lead (Pb) and benzene (C6H6)1. These standards were

published for comment in the Government Gazette on 9 June 2007. The proposed revised national

ambient standards were published for comment in the Government Gazette on the 13th of March 2009.

The final revised national ambient standards, as published in the Government Gazette on the 24th of

December 2009, and applicable to the project, are listed in Table 2-5. In June 2012 the National

Ambient Air Quality Standard (NAAQS) for PM2.5 matter was approved and published in the

Government Gazette No. 486.

Table 2-5: National Ambient Air Quality Standards

Pollutant Averaging Period Limit Value (µg/m³)

Limit Value (ppb)

Frequency of Exceedance

Compliance Date

C6H6 1 year 10 3.2 0 Immediate – 31 Dec 2014

1 year 5 1.6 0 1 Jan 2015

CO 1 hour 30000 26000 88 Immediate

8 hour(a) 10000 8700 11 Immediate

Pb 1 year 0.5 - 0 Immediate

NO2 1 hour 200 106 88 Immediate

1 year 40 21 0 Immediate

PM10

24 hour 120 - 4 Immediate – 31 Dec 2014

24 hour 75 - 4 1 Jan 2015

1 year 50 - 0 Immediate – 31 Dec 2014

1 year 40 - 0 1 Jan 2015

PM2.5

24 hour 65 4 Immediate – 31 Dec 2015

24 hour 40 - 4 1 Jan 2016 – 31 Dec 2029

24 hour 25 - 4 1 Jan 2030

1 year 25 - 0 Immediate – 31 Dec 2015

1 year 20(a) - 0 1 Jan 2016 – 31 Dec 2029

1 year 15 - 0 1 Jan 2030

SO2

10 minutes 500 191 526 Immediate

1 hour 350 134 88 Immediate

24 hour 125 48 4 Immediate

1 year 50 19 0 Immediate

1 SANS 69 - South African National Standard - Framework for setting & implementing national ambient air quality standards and SANS 1929 -

South African National Standard - Ambient Air Quality - Limits for common pollutants.




2.3.1.3 Air Quality Management Plan for the HPA

The Highveld Airshed was declared the second priority area by the Minister in November 2007,

requiring that an Air Quality Management Plan be developed for the area. The plan will include the

establishment of emissions reduction strategies and intervention programs based on the findings of a

baseline characterisation of the area. The implication of this is that all contributing sources in the area

will be assessed to determine the emission reduction targets to be achieved over the following few

years.

In September 2011 the DEA published the Air Quality Management Plan for the Highveld Priority Area.

Included in this management plan are 7 goals, each of which has a further list of objectives that has to

be met. Goal 2 sets out that: By 2020, industrial emissions are equitably reduced to achieve compliance

with ambient air quality standards and dust fallout limit values

The objectives associated with this goal include:

• Emissions are quantified from all sources.

• Gaseous and particulate emissions are reduced.

• Fugitive emissions are minimised.

• Emissions from dust generating activities are reduced.

• Incidences of spontaneous combustion are reduced.

• Abatement technology is appropriate and operational.

• Industrial Air Quality Management (AQM) decision making is robust and well-informed, with

necessary information available.

• Clean technologies and processes are implemented.

• Adequate resources are available for AQM in industry.

• Ambient air quality standard and dust fallout limit value exceedances as a result of industrial

emissions are assessed.

• A line of communication exists between industry and communities.

Each of these objectives is further divided into activities, each of which has a timeframe, responsibility

and indicator. Refer to the DEA (2011) Highveld Priority Management Plan for further details.

It is noted that the Holfontein Extension: IWMF site falls within the extent of the Highveld Priority area

and that the requirements of the Air Quality Management Plan will require consideration when the

application for an AEL is made.

2.3.1.4 Air Quality Management Plan for Ekurhuleni

The Ekurhuleni Metropolitan Municipality developed an Air Quality Management Plan (Scorgie et al,

2005) for the Metropolitan area. The vision of the Air Quality Management Plan was to attain and

maintain acceptable air quality in the Metro for the benefit of present and future generations. The Air

Quality Management Plan set out an emissions reduction programme with source specific actions.




Industry, fuel burning appliances and electricity generation were identified as a key source which

required the reduction of emissions of priority pollutants. The Air Quality Management Plan sets out

short and medium-term measures to ensure the reduction of emissions of priority pollutants.

The application for an AEL for the Holfontein Extension: IWMF will need to ensure that the

methodological approaches used in the estimation, modelling and calculation of emissions are in line

with accepted international practices.

2.3.1.5 National Dust Control Regulations

Particulate matter is classified as a criteria pollutant, with ambient air quality guidelines and standards

having been established to regulate ambient concentrations. National Dust Control Regulations were

published in November 2013. The purpose of the regulations is to prescribe general measures for the

control of dust in all areas including residential and light commercial areas.

The regulations state that: ‘No person may conduct any activity in such a way as to give rise to dust in

such quantities and concentrations that -

The dust, or dustfall, has a detrimental effect on the environment, including health, social conditions,

economic conditions, ecological conditions or cultural heritage, or has contributed to the degradation of

ambient air quality beyond the premises where it originates; or

1. The dust remains visible in the ambient air beyond the premises where it originates; or

2. The dustfall at the boundary or beyond the boundary of the premises where it originates

exceeds -

a. 600 mg/m2-day averaged over 30 days in residential and light commercial areas

measured using reference method ASTM 01739; or

b. 1200 mg/m2-day averaged over 30 days in areas other than residential and light

commercial areas measured using reference method ASTM 01739.’

Dustfall is assessed for nuisance impact and not inhalation health impact.

European Union Emissions Standards 2.3.2

The European Union adopted the Waste Incineration Directive (2000/76/EC) to prevent or limit as far as

practicable negative impacts on the environment, in particular pollution into air, soil, surface water and

ground water, and the resulting risks to human health, from the incineration of waste. The directive sets

stringent operational conditions and technical requirements as well as emission limit values for waste

incineration. The Emission Standards set out in Annex V of the Waste Incineration Directive will be

applied to the MSWtE Plant at Holfontein.

The EU Waste Incineration Directive has been superseded by the Integrated Pollution Prevention and

Control Reference Document on the Best Available Techniques for Waste Incineration published in




August 2006. This reference document for municipal waste incinerators is currently the global standard

for Waste Incineration.

2.4 National Water Act, 1998

Section 21 of the National Water Act, 1998 (No. 36 of 1998) (NWA) lists water uses for which a water

use authorisation must be obtained. Certain uses may be generally authorised while others require

registration and or licensing.

EnviroServ has recently (October 2014) submitted an integrated water use licence application to the

DWS for all of the water uses at the HHWDS. This included all of the current water uses on the

properties adjacent to the HHWDS, but did not include any of the water uses for activities at the

Holfontein Extension: IWMF. Some of the water uses in that application will require to be changed or

removed due to the development of the Holfontein Extension: IWMF.

Certain components of the Holfontein Extension: IWMF will need to be authorised through a WUL that

details each of the facilities on each of the separate property portions. Water using activities with

potential relevance to the Holfontein Extension: IWMF are detailed in Table 2-6. An integrated water

use licence application is required.

Table 2-6: Preliminary water use activities applicable to the Holfontein Extension: IWMF

Property Section 21 Water Use Structure / activity

Holfontein 71 IR, Portion 15 21 g Storage tanks for incoming wastes and effluents

21 g Storage for contaminated storm water

21 c & i Activities within 500 m of a wetland

Holfontein 71 IR, Portion 16 21 g Storage tanks for incoming wastes and effluents


21 g General waste disposal

21 c & i Activities within 500 m of a wetland

Holfontein 71 IR, Portion 28 21 g Storage for contaminated storm water

21 g General waste disposal

21 j Discharge of treated effluent to the watercourse

c & i Activities within 500 m of a wetland

Holfontein 71 IR, Portion 31 21 g Storage for contaminated storm water


Holfontein 71 IR, Portion 32 21 g General waste disposal


Holfontein 71 IR, Portion 39 None

Holfontein 71 IR, Portion 48 21g Hazardous waste disposal





Holfontein 71 IR, Portion 72 21 g General waste disposal


Holfontein 71 IR, Portion 74 21g Hazardous waste disposal


2.5 Other Applicable Legislation

National Heritage Resources Act, 1999 2.5.1

The National Heritage Resources Act, 1999 (25 of 1999) (NHRA) provides for the protection of all

archaeological and paleontological sites and meteorites. Section 38 of the Act defines the categories of

development for which the responsible heritage resources authority must be notified. Under Section 38

(c) ’any development or other activity which will change the character of a site-‘(i) exceeding 5000 m2’

the responsible heritage authority must be informed of a development larger than 0.5 ha.

The footprint of the proposed Holfontein Extension: IWMF is larger than the listed threshold. The

responsible heritage agencies - Provincial Heritage Resources Agency Gauteng (PHRAG) and South

African Heritage Resources Agency (SAHRA) have been notified of the project (see Appendix C).

National Environmental Management: Biodiversity Act, 2004 2.5.2

The National Environmental Management: Biodiversity Act, 2004 (No. 10 of 2004) provides for the

preservation of natural ecological systems (both flora and fauna) of South Africa (within the principles

and obligations of environmental and natural resources protection espoused by the National

Environmental Management Act, 1998. The NEMBA enables the Minister or MEC to list species and

ecosystems which are threatened and in need of protection as well as to identify threatening processes

within these ecosystems.

A list of threatened and protected species and regulations pertaining thereto has been published (GN R

150, 151 & 152, February 2007). The Threatened or protected species Regulations have been variously

updated in 2008, 2009, 2011 and 2014. Threatened Ecosystems have been published in GN R 1002 of

9 December 2011 under Section 52(1)(a) of the NEM:BA.

Critically endangered and endangered ecosystems are afforded protection through the NEMA whereby

environmental authorisation is required from a competent authority prior to disturbing activities above

thresholds within these ecosystems (refer to Listing Notice 3 GN R 546).

Alien and Invasive Species Regulations as well as the Alien and Invasive Species List were published

on 1 August 2014 in GN R 598 and GN R 590 respectively. The Alien and Invasive Species

Regulations are effective from 1 October 2014 and it is therefore necessary for all land owners on

whose land alien and invasive species occur to make the necessary arrangements to be compliant with

these Regulations. This may include studies to identify the existence of alien and invasive species, the

determination of the category in the Alien and Invasive Species List and the implementation of

programmes to combat or control such species.




Conservation of Agricultural Resources Act, 1983 2.5.3

The Conservation of Agricultural Resources Act, 1983 (No. 43 of 1983) defines a list of registered

‘weeds’ and ‘invader plants’, categorises them into different classes and introduces restrictions where

these plants may occur. The Act imposes certain duties on ‘land users’ regarding the prevention or

management of same. The alien and invasive plant control programme as currently applied at HHWDS

will require to be implemented across the Holfontein Extension: IWMF site.

Ekurhuleni Metropolitan Municipality By-laws 2.5.4

2.5.4.1 Waste Water By-Laws (6 March 2002)

The EMM by-law prevents the disposal of any substance into the sewage disposal system which does

not comply with the standards and criteria set out in the by-law. The by-law makes provision for the

discharge of industrial effluent into the sewage disposal system, subject to written permission from the

council.

A discharge permit will be required from the EMM should EnviroServ propose to dispose of any effluent

from the Holfontein Extension: IWMF into the sewage disposal system. Such a permit will set the

standards for the effluent and specify the charges if any.

2.5.4.2 Solid Waste By-Laws (6 March 2002)

The EMM by-law requires that any person generating industrial or hazardous waste notify the council of

such generation. The storage of such industrial or hazardous waste on the generators’ premises must

be in such manner that it cannot become a nuisance, safety hazard or pollute the environment. In

addition such industrial or hazardous waste may not be removed from a premises without the Council’s

written approval of conditions of such removal.

2.5.4.3 EMM Environmental Policy (2006)

The EMM has developed an environmental policy to ensure that environmental issues and

environmental sustainability form part of all decision making processes, the development of strategies

and programmes, the development and planning of land use and the management of resources and

activities.




Regional and Local Land Use Policies and Plans 2.5.5

2.5.5.1 Ekurhuleni Integrated Development Plan

The EMM has developed and updated their Integrated Development Plan (IDP) as a guide to all

planning, budgeting, resource allocation and decision-making within its area of jurisdiction. The IDP

does not specify or outline any planning objectives for the area in which the proposed Holfontein

Extension: IWMF is located (EMM, 2013/2014).

2.5.5.2 Ekurhuleni Spatial Development Framework

The Spatial Development Framework (SDF) is an operational strategy for the development and

planning department of the EMM. The framework manages the use of the land, highlights priority

investment and development areas, provides guidelines for development and serves as a guide for

decision-makers or investors.

The EMM is subdivided into three (3) management regions with Regional Spatial Development

Frameworks compiled for each region.

2.5.5.3 Regional Spatial Development Framework (Eastern Service Delivery Region)

The Regional Spatial Development Frameworks (regional frameworks) are a refinement of the overall

SDF for Ekurhuleni and are therefore more detailed and specific with respect to addressing land use

and development proposals within the region.

The proposed Holfontein Extension: IWMF falls within the Eastern Service Delivery Region of

Ekurhuleni. The regional framework (EMM, 2010) demarcates the area in which the proposed

Holfontein Extension: IWMF is located as an extensive agriculture area, outside of the delineated ‘urban

edge’.

The Daveyton/Etwatwa area has been earmarked as a Service Upgrading Priority Area in which the

EMM should focus its capital expenditure and operational programs to improve service delivery.

2.5.5.4 Victor Khanye Local Municipality

The Victor Khanye Local Municipality in Mpumalanga forms part of the Nkangala District Municipality.

This borders Gauteng in the region of the HHWDS. The 2013/2014 IDP for the Victor Khanye Local

Municipality does not specifically specify or outline any planning objectives for the area adjacent to

which the proposed Holfontein Extension: IWMF is located (VKLM IDP, 2013/2014).

One of the objectives of the SDF is to optimise the economic development potential associated with the

N12 Corridor in the vicinity of the major interchanges. The Eastside Junction Mixed Use Development is

proposed in line with certain of these objectives.




3. Study Approach and Methodology

3.1 Study Objectives

The specific objectives for the Scoping phase of the EIA process are to:

• Collate project information for the Holfontein Extension: IWMF.

• Collate baseline environmental data for the site and surrounds.

• Identify landowners, adjacent landowners, local authorities, environmental authorities, as well

as other stakeholders, which may be affected by the project, or that may have an interest in the

environmental impacts of the project.

• Inform interested and affected parties (IAPs) about the proposed project.

• Engage with IAPs and identify their issues and concerns.

• Document key IAP issues and concerns for consideration in the EIA phase.

• Engage with environmental authorities and confirm legal and administrative requirements.

• Identify and describe existing and/or potential environmental issues associated with the facility.

• Identify the nature and extent of further investigations and specialist input required in the EIA

phase.

3.2 Definition of Study Area

The study area is defined as the EnviroServ owned properties adjacent to the existing Holfontein

Hazardous Waste Disposal Site. This comprises portions 15, 16, 28, 31, 32, 33, 34, 38, 39, 48, 72 and

74 of the Farm Holfontein 71-IR. The study area includes the area of land within 100 m of the subject

property boundaries.

The study areas to be considered in certain of the specialist studies may differ due to the requirements

of the environmental aspect or the assessment methods and will be fully described in those reports.

3.3 Identification of Alternatives

The consideration and assessment of the advantages and disadvantages that potential alternatives to

the proposed activities may have is a key requirement of an EIA process. Alternatives should provide a

different means of achieving the same general purpose of the project, while being both feasible and

reasonable. The basic objectives of the Holfontein Extension: IWMF project are to:

• provide for the management of target waste streams in terms of the principles of the waste

management hierarchy;

• have an integrated facility that can derive the maximum sustainable benefit from target waste

streams;




• provide for the environmentally responsible disposal of Type 1 to Type 4 residual wastes at the

same location;

• build on the infrastructure, services and site knowledge at the HHWDS; and

• supply the waste management services at an economically attractive cost.

Where reasonable and feasible alternatives that match these objectives exist, they will be considered in

the EIA process.

3.4 Baseline Environmental Description

The baseline environment represents the prevailing environmental conditions at the Holfontein

Extension: IWMF and surrounds. It is indicative of the level of environmental impacts due to current

activities at EnviroServ’s HHWDS, and surrounding human activities such as agriculture, quarrying,

industry, infrastructure and naturally occurring phenomena.

Baseline information for this scoping report was gathered through visual inspections of the project area

and surroundings, desktop studies and review of existing reports. The baseline information will aid in

identifying and assessing the potential current and future impacts of operations at the site, specifically

with regards to sensitive receptors in the area. Information was gathered from the following sources,

among others:

• South African National Biodiversity Institute (SANBI);

• Animal Demography Unit (ADU);

• Southern African Bird Atlas Project 2 (SABAP2);

• Vegetation of South Africa, Lesotho & Swaziland, Mucina and Rutherford (2006);

• GDARD C-Plan version 3.3;

• available internet information on the baseline environment and environmental issues related to

the Holfontein area;

• development plans and frameworks within the EMM; and

• topocadastral and geological maps covering the exploration area at scales ranging from

1:50 000 to 1:250 000, and available satellite imagery.

• Site based sampling.

3.5 Existing Reports and Monitoring Data

A number of environmental investigations and monitoring assessments have been completed for the

HHWDS over the course of the past two decades. Some of these reports include information that

relates to the surrounding properties, on which the Holfontein Extension: IWMF is proposed to be

developed. The main data sources used in the scoping assessment are listed below:




Recent monitoring undertaken at the HHWDS:

• Water Quality (surface and groundwater) monitoring reports by Jones & Wagener;

• Air Pathway Analysis System Reports by Geozone Environmental (Pty) Ltd;

Recent environmental reporting includes:

• EIR for Development of Remaining Waste Disposal Cells at Holfontein Hazardous Waste

Disposal Site (Synergistics 2009);

• EIA for Micro-encapsulation of Hazardous Waste at Holfontein Hazardous Waste Disposal Site

(Synergistics 2009);

• Dolomitic Risk Assessment report by Jones & Wagener (2010);

• Groundwater Model: Effectiveness of Upstream Cut-off Trench at the Holfontein Waste Disposal

facility by Jones & Wagener (2010);

• EIA for Treatment Technologies at the Holfontein Hazardous Waste Disposal Site (Synergistics

2013);

• Holfontein Stockpile Environmental Assessment Report (Synergistics, 2013); and

• Specialist reports written for the Holfontein Stockpile Assessment:

o Wetland Specialist Study (Ecotone 2013); and

o Ecological Scan (Eko Info cc & Associates 2013).

A scoping report was recently completed for Interwaste’s proposed Amadwala Integrated Waste

Management Facility and contains baseline information with relevance to the general area for the

Holfontein Extension: IWMF (Golder, January 2014).

3.6 Public Participation Process

On-going participation of IAPs at the HHWDS is facilitated through the Holfontein Monitoring Committee

(HMC) which is run by an independent facilitator employed by EnviroServ.

The public participation process (PPP) for the Holfontein Extension: IWMF is being undertaken by

Synergistics and was commenced on Thursday 27 March 2014. The PPP was conducted as described

in the sections below.




Identification of Potential Interested and Affected Parties 3.6.1

A database of potential IAPs was compiled using an existing contact list for HMC and from information

held by EnviroServ and Synergistics from previous EIA processes. This database of potential IAP

included persons and organisations from neighbouring businesses, farms and residents(refer to

Appendix B). All of the potential IAPs were notified of the project (see next section).

The IAP database was updated with additional information received:

• Telephonically to obtain the correct stakeholder contact details;

• Telephonically to obtain the correct contact details for neighbouring farms and businesses;

Notifications to IAPs 3.6.2

Potential IAPs were notified about the project and the public participation process (PPP) in March 2014

by means of:

• Press advertisements and site notices;

• Delivery of notifications to owners and occupiers of adjacent land (hand delivery);

• Letters to HMC members; and

• Letters to all potential IAPs (Appendix B).

The notifications, BID, site notice and adverts also included invitations to the public information-sharing

meeting. In addition, a response sheet was attached to each BID, requesting written responses and

comments on the project.

3.6.2.1 Press Advertisements

Press advertisements were placed in one local (The Springs Advertiser) and one national paper (The

Star). The advertisements informed IAPs of the application for a WML and environmental authorisation

and provided information on how to register for the project (Appendix ).

3.6.2.2 Site Notices

On Thursday 27 March 2014, site notices were placed at the entrance to the HHWDS, which is also the

primary access point to the properties for the Holfontein Extension: IWMF (Appendix ).

Background Information Document 3.6.3

A notification letter and Background Information Document (BID) were distributed (by email, fax, post or

by hand) to all potential IAPs and neighbours surrounding the proposed Holfontein Extension: IWMF




(Appendix B). The letter and BID provided information concerning the proposed project and invited IAPs

to register. All letters distributed were in English. All IAPs were requested to distribute the documents to

anyone who may be interested or affected by the project.

Public and Stakeholder Meetings 3.6.4

A public meeting was held at Hadida’s Garden Estate on the 15 April 2014 at 17:30 pm in which

Synergistics and EnviroServ members presented information on environmental and technical aspects of

the project. Questions were taken and answered at the meeting where possible. The balance of the

questions were recorded and are addressed in the Comment and Response report (see Appendix B).

The minutes were distributed to all IAPs and commenting authorities, and are provided in Appendix B.

Registered IAPs 3.6.5

Parties whom registered with the project, returned the response sheet or attended a public meeting

were recorded as registered IAPs on the database. The database of registered IAPs is regularly

updated throughout the EIA process based on:

• Responses received by the EAP to the project’s public documents; and

• Attendance at the Public meeting(s).

Only registered IAPs will receive further information and correspondence regarding the project. The

database of registered IAPs is provided in Appendix B and will be updated throughout the EIA process.

Comments and Responses 3.6.6

Copies of comments received from IAPs as well as copies of responses sent by the applicant or EAP to

the IAP are included in Appendix B. All comments and questions raised by IAPs during the process to

date have been documented and are discussed in the Comment and Response report (see appendix

B).

3.7 Authority Consultation

Competent Authorities 3.7.1

The DEA has not indicated any requirements for the assessment beyond what is necessary in terms of

the 2010 EIA Regulations (GN R 543).

The GDARD required that a shape file of the project area be submitted to their biodiversity section. This

was done and the GDARD indicated that specialist biodiversity studies are required to investigate the

following aspects:




• Plants, with specific reference to Habenaria bicolor.

• Birds, with specific reference to Tyto capensis (African Grass Owl).

• Vegetation;

• Wetlands.

All specialist studies must comply with GDARD Requirements for Biodiversity Assessments. The

GDARD also advised that the application site is designated important in the Gauteng Conservation Plan

(Version 3.3), i.e. it is a highly sensitive site, essential for the conservation of biodiversity in Gauteng.

“Based on the biodiversity sensitivities confirmed on this site, it is highly unlikely that any activity will be

supported by Conservation”.

Authority correspondence is included in the Appendix A.

Commenting Authorities 3.7.2

The following organs of state and commenting authorities were notified of the project in writing:

Table 3-1: Relevant Commenting Authorities Notified of the Project

Contact Person Department Email

Khaya Ngema EMM: Municipal Manager [email protected]; [email protected]

Cllr Mondli Gungubele EMM: Mayor [email protected]

Elsabeth van der Merwe

EMM: Environmental Planning & Impact Management [email protected]

P.J.(Flip) Visser EMM - Environmental Health Department [email protected]

Fanie Louw EMM: Solid Waste [email protected]

Sekhonyana Lerotholi EMM: Wetlands Division [email protected]

Jan Bodenstein EMM:(Assistant Chief) Air Quality and Climate Change [email protected]

Masele Madihlaba Ward 67 Councillor [email protected]

Mr Allan Zimbwa Nkangala District Municipality (Acting Municipal Manager)

Minah Maredi Victor Khanye Local Municipality: (Municipal Manager) [email protected]

Diane Bath Victor Khanye Local Municipality: Ward 8 Councillor [email protected]

Zingisa Smale GDARD: Administrative Unit of the Sustainable Utilisation of the Environment (SUE) Branch: Waste Management Directorate

[email protected]

Mr L.B. Cele DARDLA (Director: Nkangala District) [email protected]

Mr S Hlatshwayo MDEDET: Environmental Impact Management (Acting Director)

[email protected]

Mr M.C Theledi cc Gezepi

MDEDET: Pollution and Waste Management (Director) [email protected]; [email protected]

Thya Pather DWS – Gauteng [email protected]

Wilna Moolman DWS Affairs (Resource Protection and Waste Source Co-ordination)

[email protected]




Phyllis Maphakela Gauteng Region: Water Quality Section [email protected]

Andrew Solomon South African Heritage Resources Agency Online Application.

Copies of the notifications and proof of distribution are provided in Appendix B. Correspondence with

commenting authorities is included in the Comment and Response report (see Appendix B).

Authority Meetings 3.7.3

No authority meetings have been held for the process to date. Authorities are aware of the Holfontein

Extension: IWMF through the applications, the notifications and the various on-going forums for the

HHWDS.

3.8 Review of the Scoping Report

The DSR has been made available to registered IAPs and commenting authorities for a 40-calendar

day review period. Hard copies of the DSR will be available at the office at EnviroServ’s HHWDS and at

the Delmas Public Library (cnr Van Riebeeck Lane and Sarel Cilliers Street). The DSR is be published

on the Synergistics website at www.synergistics.co.za from where it can be downloaded.

All registered IAPs have been notified, in writing, of the availability of the DSR for review and will be

requested to comment. Electronic copies of the DSR will be emailed or made available on CD-ROM to

IAPs on request.

Copies of the DSR have been provided to the commenting authorities listed in Table 3-1.

3.9 Scoping Report Finalisation

Following the closure of the review period for the DSR in its draft status, modifications will be made to

the DSR if required and IAPs and commenting authorities will be notified of the final status of the report

along with details of the applicable final commenting process. For further involvement in the public

participation process during the EIA refer to Section 9.6.1.




4. Project Description

4.1 Background

EnviroServ has proposed the development of the Holfontein Extension: Integrated Waste Management

Facility as an addition to, and extension of, the waste management operations at their current

Holfontein Hazardous Waste Disposal Site. The Holfontein: IWMF will provide an integrated, full-

service waste management facility that can receive, store, re-use, recycle, recover and treat Type 0 to 4

wastes, as well as provide for the final disposal of both general and hazardous wastes.

EnviroServ own and operate the HHWDS which is a hazardous waste treatment and H:H waste

disposal facility operated in terms of waste management licences (WML) issued by the Department of

Environmental Affairs. Due to space limitations and restrictions, the facilities proposed for the Holfontein

Extension: IWMF project cannot take place within the HHWDS. Some of the proposed plants will run

concurrently with the HHWDS operations while others are contemplated as replacements once the

equivalent facility at the HHWDS reaches end of life.

4.2 Introduction

The proposed Holfontein: IWMF will provide infrastructure for an integrated waste management facility

that can receive, store, re-use, recycle, recover and treat Type 0 to 4 wastes, as well as provide for the

final disposal of both general and hazardous wastes in disposal sites. Wastes will be managed in

accordance with procedures advocated by the waste management hierarchy and legislation. The facility

is proposed to include some or all of the following:

• Mechano Chemical Destruction facility;

• Bioremediation facility;

• Micro-encapsulation plant;

• Oil Separation plant;

• Health Care Risk Waste Treatment

plants;

• Solvents Recovery plant;

• Treatment and blending pad;

• Pilot Plant test area;

• Waste to Energy plant;

• Gasifier;

• Anaerobic digester;

• Pyrolysis/ Devolatilisation plant;

• Solid fuel plant;

• Minerals upsizing/ downsizing plant;

• Mineral recycling plant;

• General Waste Materials Recovery

facility;

• Tyre Recycling plant;

• Plastic beneficiation plant;

• Board manufacturing;

• Panel manufacturing;

• • Waste Electrical And Electronic

Equipment (WEEE) and battery

recycling plant;

• Landfill gas extraction and utilisation;




• Hazardous Waste (Class A) Disposal

Site; and

• General Waste (Class B) Disposal Site.

The list of facilities/plants included in the proposal is comprehensive and was developed to enable the

management of all of the waste streams that are anticipated to be received at the Holfontein Extension:

IWMF. It is possible that not all of these facilities/plants will be developed.

Common, shared infrastructure for the Holfontein Extension: IWMF is likely to include:

• Access and internal roads;

• Access control facilities and perimeter fencing;

• Weigh bridge and control room;

• Offices and change houses;

• Laboratory;

• Workshops and warehousing;

• Parking and loading areas;

• Waste receiving, holding and transfer areas;

• Waste storage tanks and areas;

• Fuel and chemical storage facilities;

• Waste container storage and maintenance yard(s);

• Wash bays for vehicles, bins and plant;

• Storm water drainage and containment structures; and

• Site services, utilities and associated infrastructure.

Project Location 4.2.1

The Holfontein Extension: Integrated Waste Management Facility will be located immediately adjacent

to the HHWDS on portions 15, 16, 28, 31, 32, 33, 34, 38, 39, 48, 72 and 74 of the farm Holfontein 71 IR

(Figure 1). These properties are all owned by EnviroServ. The site is located north of the N12 highway,

in the Ekurhuleni Metropolitan Municipal area in Gauteng, close to the provincial boundary with

Mpumalanga.

All of the recycling, recovery and treatment plants will be located on portions 15 and 16, within an area

dedicated to this purpose. The Class A landfill site will be sited to the south the HHWDS on portions 48

and 74. The Class B landfill site will be sited to the south west of the HHWDS across portions 16, 28,

32, 33, 34 and 72.

A preliminary layout of the Holfontein Extension: IWMF is shown in Figure 4-1. This layout is

conceptual, being informed largely by the cadastral boundaries of the included properties. The final

layout for the Holfontein Extension: IWMF will be informed and refined through on-going feasibility work

and inputs derived from the EIA process. Updated layouts will be included in the EIA report.





Figure 4-1: Conceptual layout of the Holfontein Extension: IWMF




4.3 Conceptual Activity Description

Project Design Criteria 4.3.1

Each of the facilities and all of the activities to be undertaken at the Holfontein: IWMF will comply with

existing environmental legislation, regulations and guidelines, as well as other requirements as may

relate to waste management facilities. The principles of the waste management hierarchy will be

applied to the management of each waste stream.

It must be noted that waste streams, technologies, market conditions and regulations relating to waste

management are continually developing and changing which has influence on the appropriateness and

feasibility of each of the facilities proposed. More details on the facilities, their capacity and operational

parameters will be provided in the EIA report.

The disposal facilities will be designed and operated in terms of the current National Norms and

Standards for Disposal of Waste to Landfill (GN R 636). Conceptual engineering designs will be

provided for the facilities that require design approval from the Department.

The following section set out a brief, conceptual description of each of the proposed facilities/plants.

Mechano-Chemical Destruction (MCD) 4.3.2

This is a non-thermal treatment method for the destruction of halogenated hydrocarbons, specifically

contaminated soil. The fundamental principle of a mechanical reaction to achieve destruction of toxic

chemicals through impact energy, which is created due to the velocity of special high wear resistant

steel balls being in constant collision with each other, MCD technology is capable of handling large soil

remediation projects.

This low temperature, non-incineration process is capable of attaining a Destruction Efficiency (DE) of

up to 99.99%, and residual contamination of less than 5.0mg/kg. The remediated soils may be returned

to the generator or utilised on site.

Waste types: Hazardous waste

Halogenated organics (POPs, DDT, pesticides etc) and Asbestos contaminated soils.

Bioremediation Facility 4.3.3

Makes use of biological processes to treat organic wastes in a composting facility. Microbes and

bacteria are used to decompose and biologically treat general and certain hazardous waste. A compost

can be generated for downstream use or the facility can be used for the treatment of general and

hazardous wastes, to reduce the toxicity of the waste stream.

Waste types: Hazardous, non-hazardous and general waste

Garden greens, wood waste

Contaminated soils (hydrocarbons)




Micro-encapsulation 4.3.4

This entails the cementation or use of other binders to treat wastes such as brines and sludges to

reduce the leachability of the contaminants. A pan mixer, mobile cement mixer or batch plant can be

used to mix the waste with the required binders and adsorption media. A cementitious product is

achieved that cures over time to bind all the components together. The treated waste is disposed to the

landfill site.

Waste types: Hazardous waste and non-hazardous waste

Brines, sludges, effluents

Oil Separation 4.3.5

Oil can be separated from water and sludges using a variety of means. Gravity settling and ultra-

filtration will be used to separate water from oil. Heated decanter centrifuges will be used to separate oil

from hydrocarbon sludges. The recovered oil can be sold or further recycled. The remaining effluent

can be discharged, disposed or further treated.

Waste types: hazardous waste

Oily water, hydrocarbon sludges

Health Care Risk Waste Facility 4.3.6

Two types of technology may be implemented for the treatment of health care risk waste.

Incineration is required for the destruction of Health Care Risk Waste (HCRW), including anatomical

waste and pharmaceuticals. The HCRW is placed in a primary chamber at 800-1000°C. The waste is

converted to a pyrolysis gas. The combustion is completed in the secondary chamber at 1050-1150°C.

A flue gas clean up system is required to neutralise acidic gases and remove particulates. The resultant

ashes are disposed to landfill.

Hydroclave technology may also be used to treat non-anatomical components of HCRW. The

hydroclave sterilises the HCRW by utilising steam at high pressure. The sterilised waste is then

shredded and disposed of to landfill.

Waste types: HCRW

Solvents Recovery Facility 4.3.7

Distillation is used to selectively recover solvents from water. Solvents have a different evaporation

temperature from water and this difference is used to evaporate the solvent out of water. The resulting

gas is then condensed to recover the target solvent(s). The remaining effluent can be discharged,




disposed or further treated.

Waste types: hazardous waste solvents

Treatment and Blending Pad 4.3.8

Certain wastes require treatment before disposal to landfill. In some cases it is preferable or necessary

to treat the wastes prior to arrival on the landfill. A lined and bunded pad will be established to treat

wastes with the required chemicals and additives. Chemicals such as lime, ash, cement, ferro-sulphate,

sulphur and sodium meta-bisulphate could be used. The chemicals are used to react with contaminants

in the waste or to reduce the leachability of the waste. The treated waste is then managed further or

disposed to the landfill site.

Waste types: Hazardous waste including sludges, dusts

Pilot Plant Area 4.3.9

Many new technologies and treatments require test work and piloting to ascertain whether or not they

are feasible to be implemented on a larger scale. A dedicated, lined and bunded pad, with access to

utilities, will be established as a pilot plant area. In this area pilot plants will be placed and operated to

check the feasibility of technologies under various conditions. Pilot plants are not a permanent facility

and will be utilised only to prove the concept.

Waste types: hazardous, non-hazardous and general waste

Waste to Energy Facility 4.3.10

As access to landfill facilities become more difficult and the cost of landfilling increases, new waste

recovery and disposal technologies become feasible. The recovery of energy from wastes is also

preferable to disposal. A waste to energy (WTE) plant is envisaged for the combustion of the residual

components of municipal solid waste via mass burn or gasification. A WTE plant combusts municipal

solid waste (MSW) in a primary chamber. The heat from the combustion gases is used to generate

electricity and or steam. The off gases are cleaned before being emitted to the atmosphere. The flue

gas clean-up generally consists of acid neutralisation, cooling and particulate filtration/removal. The

produced energy will be used on-site or sold into the grid. The residual ashes will be disposed to

landfill.

Waste types: General waste and municipal solid waste (MSW)




Gasifier Facility 4.3.11

Gasification is the thermal combustion of organic waste in a controlled oxygen deficient environment to

create a producer gas. The producer gas can be used as a heating fuel or for the generation of

electricity. The off gases are cleaned before being emitted to the atmosphere. The waste products will

be disposed to the landfill.

Waste types: General waste including woodchips, nut shells, husks

Anaerobic Digester 4.3.12

An anaerobic digester is a facility that biologically decomposes organic waste to produce a biogas

(methane). The waste is macerated before being place in the digester. The digester is a large tank that

utilises air sparging for mixing. The biogas generated via the decomposition process is captured in the

hood above the digester. The biogas is then extracted for use as a fuel for heating or for the generation

of electricity. The waste products will be further treated or disposed to the landfill.

Waste types: General waste including food waste, agricultural waste, abattoir waste

Pyrolysis / devolatisation Facility 4.3.13

Pyrolysis or devolatisation is the controlled combustion of waste in an oxygen deficient environment.

Pyrolysis is similar to a gasifier, but the pyrolysis process condenses some of the off gases to create a

fuel oil. Dependent on the feed, a solid char is also produced. The off gases are cleaned before being

emitted to the atmosphere. The waste products will be disposed to the landfill.

Waste types: general waste including tyres, organic wastes

Solid Fuel Plant 4.3.14

The solid fuel plant would take organic waste and utilise various materials and handling machines to

create a solid fuel. Granulation, pelletisation or briquetting are used. The solid fuel can be sold for

heating purposes.

Waste types: general waste including organic waste, woodchips, saw dusts, husks

Minerals upsizing/downsizing facility 4.3.15

Mineral waste can be treated in this facility to extract valuable components or to form products.

Crushing and grinding is used to reduce the particle size of the waste. Separation equipment such as

spirals, screens and x-ray are used to separate components. Briquetting and pelletisation are used to

increase the size of fines. The idea is to beneficiate the waste stream by separation of the valuable




components and also to form/recover products that can be utilised in smelter/furnaces. The residual

wastes will be disposed to the landfill.

Waste types: Hazardous and non-hazardous waste including mineral fines, dusts, slags and

granules.

Minerals Recycling Facility 4.3.16

Similar to the upsizing/downsizing facility, the minerals recycling facility focuses purely on the

separation of the different components in the mineral waste stream. X-ray diffraction, screens and

sorters are utilised. The recovered minerals are then sold into the market. The residual wastes will be

disposed to the landfill.

Waste types: Hazardous and non-hazardous waste including mineral fines, dusts, slags and

granules.

Materials Recycling Facility 4.3.17

The Municipal Solid Waste stream consists of many items that can be recycled or recovered. Paper,

plastic, metal (ferrous and non-ferrous) and glass all have a value if recovered. A materials recovery

facility (MRF) consists of various equipment and hand-pickers for the separation of the target products

from the waste stream. Some of these products will be sold in raw form to recyclers while others will be

further upgraded to increase their value. The residual wastes will be direct to the WTE plant or disposed

to landfill.

Waste types: General waste including unsorted or sorted Municipal Solid Waste (MSW)

Tyre Recycling Facility 4.3.18

Waste tyres can be recovered down to individual components. A tyre recycling plant uses a series of

de-beaders, shredders and grinders to produce rubber granules, metal and a nylon fluff. The metal is

recovered from the bead of the tyre. The rubber granules can be utilised to make various products or

sold as is. The fluff can be used as a fuel for heating. The residual wastes will be direct to one of the

WTE plants or disposed to landfill.

Waste types: General waste tyres

Plastic Beneficiation Facility 4.3.19

The plastic recovered from the MRF can be further upgraded to add value. The plastic will be cleaned,




chipped, extruded and pelletised. The plastic pellets may be sold or utilised further to manufacture

products.

Waste types: General waste, recovered plastic from MRF

Board Manufacturing Facility 4.3.20

Waste gypsum can be upgraded and used in the production of boards for ceilings. The gypsum is

specially treated with reagents to create the correct consistency. The gypsum is placed in a mould and

then compressed to manufacture boards. The residual wastes will be disposed to landfill.

Waste types: Hazardous and non-hazardous waste being gypsum (Sodium sulphate and sulphite)

Panel Manufacturing Facility 4.3.21

Waste gypsum can be upgraded and used in the production of panels. The plant is very similar to the

board manufacturing facility. The gypsum is specially treated with reagents to create the correct

consistency. The gypsum is placed in a mould and then compressed to manufacture panels. The

residual wastes will be disposed to landfill.

Waste types: Hazardous and non-hazardous waste being gypsum (Sodium sulphate and sulphite)

WEEE and battery recycling Facility 4.3.22

Waste electrical and electronic equipment (WEEE) and batteries contain many valuable metals.

Electronic waste may be defined as discarded computers, office electronic equipment, entertainment

devices, mobile phones, television sets, and refrigerators. Many metals such as gold, tantalum, mercury

and silver can be recovered from this waste stream. The items are separated and then further

processed to recover the individual metals. The facility will consist of various equipment and hand-

pickers for the separation of the target products from the waste stream. Some of these products will be

sold in raw form to recyclers while others will be further upgraded to increase their value. The residual

wastes will be direct to the WTE plant or disposed to landfill.

Waste types: Hazardous and general waste comprising WEEE




Class B Disposal Site 4.3.23

A Class B landfill site is proposed for the disposal of waste received at the Holfontein Extension: IWMF

as well as that generated from the recycling, recovery and treatment of wastes at the site. The Class B

site will be able to accept Type 2 wastes. The disposal site will be lined with a Class B barrier, designed

as per Norms and Standards for disposal of waste to landfill. This consists of, from the top, a 150mm

thick leachate collection system covered with a separation geotextile, a sand or geosynthetic protection

layer above the geomembrane liner, a 1.5mm HDPE geomembrane, 4 × 150mm compacted clay

layers and an under drainage and monitoring system at the base. See Figure 4-2.

The conceptual proposal is for a Class B disposal facility that covers an estimated 75 ha. The facility

will be implemented in a phases with a series of waste cells being developed as the demand for waste

disposal capacity requires. The overall design and that of each waste cell will be done by registered

professional engineers with consideration for the specific requirements of the expected waste streams

and the local site conditions. All designs will be subject to approvals as stipulated in the WML.

Landfill gas extraction and utilisation 4.3.24

The organic component of the waste stream disposed to a landfill decomposes over time. Vertical or

horizontal gas extraction pipes are placed in the landfill as the waste is being disposed. The gas

generated via the decomposition of the waste is collected via the pipes as a vacuum is applied to the

extraction system. The landfill gas typically consists of a high percentage of methane. The recovered

landfill gas can be flared or combusted in a generator to form electricity. The landfill gas can also be

cleaned and filtered to create a methane fuel for utilisation in vehicles or heating.

Waste types: Landfill gas from organic waste disposed landfill

Class A Disposal Site 4.3.25

A Class A landfill site is proposed for the disposal of waste received at the Holfontein Extension: IWMF

as well as that generated from the recycling, recovery and treatment of wastes at the site. The Class A

landfill will only be developed once the airspace at the HHWDS has been utilised. The Class A site will

be able to accept Type 1 wastes. The disposal site will be lined with a Class A barrier, designed as per

Norms and Standards for disposal of waste to landfill. This is a double composite liner system as it

consists of two geo-membranes both in intimate contact with clay layers. The barrier consists of, from

the top, a 200mm thick leachate collection system covered with a separation geotextile, a sand or

geosynthetic protection layer above the geomembrane liner, a 2mm HDPE geomembrane, 4 × 150mm

compacted clay layers, a 150mm stone leakage detection system with a geotextile separation layer

above or equivalent geosynthetic equivalent, a protection layer of sand or geosynthetic equivalent, a

1.5mm HDPE geomembrane and a 200mm compacted clay liner. See Figure 4-2.




The conceptual proposal is for a Class A disposal facility that covers an estimated 20 ha. The facility

will be implemented in a phases with a series of waste cells being developed as the demand for waste

disposal capacity requires. The overall design and that of each waste cell will be done by registered

professional engineers with consideration for the specific requirements of the expected waste streams

and the local site conditions. All designs will be subject to approvals as stipulated in the WML.





Figure 4-2: Containment Barrier Designs for Different Class Landfills




Storm water and Leachate Management 4.3.26

Storm water originating from outside the boundaries of the site is assumed to be clean and will be

diverted around the site. Drains of various forms will be required to divert the clean storm water and will

be designed to handle the anticipated run-off volumes.

Storm water from contaminated catchments within the site will be diverted and contained in storm water

dams. The dams will be sized to ensure the management of the expected maximum precipitation

resulting from a 24 hour duration rainfall with 1 in 50 year intensity. The dams will be lined with a

primary composite system with a ballast layer that ensures the composite effect but also acts as a

protective layer for prevention of liner damage during periodic de-silting of the dams that may be

required. Subsurface drains may be included beneath the liner where required.

Leachate recovered from the waste disposal cells will be stored in leachate dams that are lined to the

same standard as the waste cells from which the leachate is generated. Instead of a leachate collection

system above the primary composite as per cell layer works, the dams are equipped with a ballast layer

that functions similarly as mentioned above for the storm water dams.

Monitoring Networks 4.3.27

EnviroServ has a number of monitoring programmes in place on the site to detect changes that may be

related to operations and activities at the HHWDS. These networks will be assessed and adapted as

required to be effective for monitoring of the Holfontein Extension: IWMF.

Waste received at the site is documented through waste manifest documents and control authorisation

sheets. All waste loads are weighed. The recorded waste information is reported to the Gauteng Waste

Information System.

Surface and groundwater quality monitoring is undertaken in terms of a Water Monitoring Protocol that

sets out the location, frequency, method and analyses required. This includes monitoring at

background, on-site and down-stream locations.

Air quality (particulates and gases) monitoring is undertaken through a formalised Air Pathway Analysis

System. On and offsite locations are monitored as appropriate. This includes sub-surface gas probes to

monitor for lateral migration of landfill gas from the landfill site. Regular reports are produced.

When discharge from the effluent treatment plants to the environment takes place then the quantity and

quality of the permeate will be monitored. Permeate quantity will be measured and recorded on a daily

basis. The permeate quality will be continuously monitored prior to discharge. The following parameters

will be monitored continuously: pH and electrical conductivity. A complete chemical analysis will be

done monthly on a grab sample of the permeate and compared to the agreed Discharge Standard.




When discharge of permeate from the ETP take place at the HHWDS then aquatic bio-monitoring will

be implemented in the unnamed tributary of the Blesbokspruit. The components, methods and locations

for the aquatic bio-monitoring should be informed by a suitably qualified ecologist. A quarterly frequency

is proposed initially with a reduction to bi-annually if ‘no-effect’ is documented after the 1st year.

4.4 Project Phases

Planning Phase 4.4.1

The project-planning phase is in currently progress and requires the investigation of technical, financial

and environmental parameters to determine the most appropriate and feasible technologies for the

Holfontein Extension: IWMF. Information from each of these investigations will be used to modify the

facility design to ensure the most appropriate design. Little to no intrusive fieldwork is required as the

site is generally well understood. The investigations to date have informed the proposed activities as

set out in Section 4.3.

Construction and Commissioning Phase 4.4.2

Development of the facilities and infrastructure at the Holfontein Extension: IWMF will require activities

typical of most construction, including: vegetation clearance, soil stripping, bulk earth works and

levelling to achieve the required elevations. Topsoil will be preserved from all stripping activities and

stockpiled. Certain of the clays may also be stockpiled for later use.

The common, shared infrastructure will be developed as and where required to ensure accessibility and

functionality of the site. This is likely to include internal roads, electricity and water as well as drainage.

Once the site for each facility has been prepared, the infrastructure will be constructed and or installed

as per the required design specifications. Each plant or facility will be developed as an independent

facility, except where it is directly linked or related to the inputs, outputs or functions of an adjacent

plant.

The initial construction is anticipated to be completed within 12 to 18 months. However, certain of the

facilities are phased and the later phases will only be developed as and when required. In addition,

some of the proposed facilities will only be required, or become feasible at some point in the future as

market conditions and regulations become favourable and the construction of these facilities will only

commence when required.

Each facility will be completed to the design specification and conditions of the respective

authorisation(s) and requirements of the Regulations and Norms & Standards as appropriate. Each

facility will be assessed for quality and functionality before being commissioned.




4.4.2.1 Disposal Sites

Construction of the disposal sites will be implemented in phases with each waste cell being developed

as the demand for waste disposal capacity requires. Construction of each disposal site will be

undertaken in terms of the approved designs which will have considered the local site parameters and

the Norms & Standards as appropriate. This will require site preparation activities such as: vegetation

clearance, soil stripping, bulk earth works and levelling to the required elevations. Additional activities

that may be required where the footprints overlap the quarries includes the draining of the water and

the backfilling of deep excavations.

Construction activities for the liners will include: compaction of the base materials and berms,

excavations for drains and anchor trenches, placement of the liner components, placement of pipes,

aggregates and protection materials. Installation of the liner system is complex and accuracy and

quality control is vital to ensure an effective barrier.

Operations 4.4.3

4.4.3.1 Waste Receipt

The Holfontein Extension: IWMF is proposed to be able to accept all types of general and hazardous

waste. All wastes delivered to the site will be, or will have been, classified where required by the Waste

Classification and Management Regulations (GN R 634). Hazardous waste will only be accepted at the

site on a 24 hour notice basis. All waste will be recorded on a Control Authorisation Sheet (CAS). Site

management will use the information determine the acceptance criteria and how the waste will be

handled, recycled, recovered, treated or disposed. The method of recycling or recovery, the quantities

of treatment chemicals, the type of equipment and the volume of ash etc., which will be required to

effect disposal are also determined.

Vehicles arriving at the site with hazardous wastes must have a Waste Manifest Document and the

volume and type of waste will be verified against the CAS. The waste may then be sampled and

analysed to confirm the information.

The vehicle will be directed to the appropriate off-loading area or to the waste handling area for the

facility/plant where the waste will be handled or to the working face of the disposal site where the

required treatment procedures are applied and the waste disposed of.

4.4.3.2 Waste Management and Disposal

Accepted waste streams will be directed to the most appropriate facility so that the waste can be

recycled, recovered or treated. The principles of the waste management hierarchy will be applied so

that the maximum sustainable benefit is derived from each waste stream. The Holfontein Extension:

IWMF will be operated in terms of the conditions of the WML and other authorisations, the applicable

Regulations and Norms and Standards. Each facility will be operated to its design parameters.




Residual waste that requires disposal will be assessed in term of the National Norms and Standards for

the Assessment of Waste for Landfill Disposal (GN R 635). The waste will be directed to the

appropriate landfill site based on the outcome of the assessment. Each disposal site will be operated in

terms of the conditions of the WML, the applicable Regulations and Norms and Standards. Wastes that

are prohibited for disposal, as per Regulation 5(1) of the aforementioned Norms and Standard will not

be disposed.

Decommissioning and Closure Activities 4.4.4

The recycling, recovery and treatment plants at the Holfontein Extension: IWMF have been variously

designed for a 20 to 25 year operational life. Closure of each of the plants will vary depending on the

requirements of that facility. Decommissioning of the facilities will require the dismantling of the

equipment, the sale and final disposal of all components, the decontamination of any contaminated

areas and the rehabilitation of the site to a condition suitable for an end land use. Such end land-use

will most probably be industrial but will only be determined closer to closure. Additional details will be

provided in the EIA once the site design and assessment is complete.

The disposal sites at the Holfontein Extension: IWMF have been designed for a ~ 25 year operational.

However, the life of the site is directly related to the rate of airspace utilisation which is outside of

EnviroServ’s control. Once the site is near to its final levels a closure plan will be developed. Closure of

each of the disposal facilities will require shaping and capping to achieve the final landform. The final

end land use will be determined through a consultative process. Additional details will be provided in

the EIA once the site design and assessment is complete.

4.5 Development Alternatives

Development alternatives have been considered during the feasibility studies undertaken to define the

project. These investigations, undertaken by EnviroServ, have reviewed many different technologies

and facilities available throughout the world and have resulted in the selection of those that are most

feasible for the anticipated waste streams, regulations and market conditions in South Africa. These are

noted in the project description section and will be discussed in more detail in the EIA.

Location 4.5.1

EnviroServ has invested heavily in the Holfontein area (ie the proposed site) and many of the functions

and facilities of the Holfontein Extension: IWMF will closely integrate with the existing facilities and

infrastructure at the HHWDS. This includes the monitoring networks that EnviroServ has established

around the HHWDS that will also be functional for the Holfontein Extension: IWMF. Through the many

years of monitoring and investigation, EnviroServ has detailed knowledge of the environmental

conditions and receptors around the site, which will enhance design and mitigation over any other site.

The project would not be reasonable or feasible for EnviroServ at any other location. Therefore no

alternative locations have been considered.




Activity Type 4.5.2

EnviroServ operates for the primary purpose of waste management. The activities undertaken and

proposed by the company are thus focussed on managing waste. The activity types proposed for the

Holfontein Extension: IWMF do not only include the traditional disposal activity, but also a wide variety

of alternatives to ensure that waste is managed in an integrated manner in terms of the principles of the

waste management hierarchy. The mix of plants and facilities included in the project has been

proposed in order to ensure that sustainable measures are achieved in the management of waste.

Many of the activities proposed for the project are alternatives to each other or to other activities.

These may or may not be included in the final, integrated suite of activities that comprise the Holfontein

Extension: IWMF.

Layout and Design 4.5.3

The layout of the Holfontein Extension: IWMF and the design of the various facilities as currently

presented is a conceptual plan and is subject to on-going adjustments in order to optimise the facility.

Technical, financial and environmental considerations as identified during the course of this

assessment will inform the final layout and design. The intent will be to arrive at a layout that provides

for efficient and effective integrated waste management operations while minimising the environmental

risks.

Further information on the site layout and design alternatives will be provided once the environmental

specialist studies have been undertaken. The final updated layout will be included in the EIA report.

Where risks are identified the designs will be improved to provide adequate mitigation.

Technologies and Operational Aspects 4.5.4

EnviroServ has, and continues, to investigate many alternative technologies for waste management.

Those proposed, for the Holfontein Extension: IWMF, are, in EnviroServ’s opinion, the most reasonable

and feasible to effect integrated waste management of the anticipated waste streams in light of the

principles of the waste management hierarchy and the Waste Classification and Management

Regulations.

Each of the facilities proposed for the project is an alternative technology, which may or may not be

included in the final, integrated suite of technologies that comprise the Holfontein Extension: IWMF.




No-go Development Alternative 4.5.5

Not developing the Holfontein Extension: IWMF will see the continuation of the approved activities at

the HHWDS for as long as the capacity, functionality and approvals allow. This includes disposal of

hazardous waste to waste disposal cell and the implementation of various treatment technologies.

Any potential impacts that may have occurred due to the Holfontein Extension: IWMF will be avoided,

but any potential benefits that may have been derived will also be lost.

Like all landfills the HHWDS has limited airspace. Once this is depleted, there will be very limited

options for disposal of hazardous wastes in Gauteng. As documented earlier in this report, industry in

South Africa and Gauteng in particular, generates significant volumes of hazardous waste. Despite

various programmes, the volume of hazardous wastes being generated in South Africa continues to

increase. In terms of legislation, such waste must be managed to protect health, well-being and the

environment. Thus appropriate waste management facilities must be developed to keep pace with the

requirements and growth of industry. Although disposal remains a necessary waste management tool,

the recycling, recovery and treatment of wastes must be undertaken and only residual wastes should

be disposed of. It is therefore essential that integrated waste management facilities are developed to

keep pace with the growth of industry and the legislated requirements for waste management,

sustainable development and a green economy.

EnviroServ maintains that the no-go alternative is not appropriate in the context described above and

that the Holfontein Extension: IWMF is in fact appropriate. Nonetheless the no-go alternative will be

considered in the EIA.




5. Description of the Affected Physical Environment

The baseline environment described here represents the current environmental conditions of the area

proposed for the Holfontein Extension: IWMF. It is indicative of pollution and degradation due to the

adjacent HHWDS, human, agricultural and industrial activities in the area and naturally occurring

phenomena. The baseline information serves as a reference point to scientifically measure and

professionally judge future changes to the environment that may occur as a result of the development

of the Holfontein Extension: IWMF.

5.1 Topography

The area is typical of the Highveld and is characterised by a relatively flat, undulating topography. The

region comprises low hills, natural pans and wetland areas. The site is situated close to the watershed

of the Vaal and Olifants River catchments and drains to the south west. The site elevation is between

1580 and 1620 mamsl and is generally flat, with a slight fall to the west and south.

The main modifying features are the excavations for the former brick works quarries on portions 16, 48

and 72, and the clay and topsoil stockpiled on portions 15 and 16 of Holfontein 71-IR.

5.2 Visual Landscape Character

The visual landscape of the area is characterised by extensive agriculture on flat to undulating land.

Due to the topography, most of the views are limited to close to mid-distance with few points with very

distant views. It is evident that the agricultural landscape is adjacent to urban and peri-urban areas and

is subject to a variety of intrusive factors such as quarrying, roads, railways, agro-industry (poultry) and

buildings. The waste body of the HHWDS is the most prominent feature in the local landscape, rising as

much as 35 m above natural ground level.

At a site level the various old clay quarries and the clay and topsoil stockpile are prominent features.

5.3 Land Ownership and Zoning

The properties on which the Holfontein Extension: IWMF is proposed to be located are all owned by

EnviroServ (see Table 5-1). The properties immediately adjacent to the site are privately, commercially

or governmentally owned.

Table 5-1: Affected and Adjacent Properties and Land Ownership

AFFECTED PROPERTY DESCRIPTION Landowner Contact Person

Farm Portion

Holfontein 71 IR 15 EnviroServ Britz Reinders

Holfontein 71 IR 16 EnviroServ





AFFECTED PROPERTY DESCRIPTION Landowner Contact Person

Farm Portion










ADJACENT PROPERTY DESCRIPTION Landowner Contact Person

Farm Portion

Modderfontein 236 8 EnviroServ Britz Reinders

Modderfontein 236 35 Namutoni Boerdery (Pty) Ltd The Directors

Holfontein 71 IR 13 Mr Gideon van Zyl Mr Gideon van Zyl

Holfontein 71 IR 14 Jaco van Zyl Jaco van Zyl

Holfontein 71 IR 22 Wade Properties Mr Alistair McLean

Holfontein 71 IR 23 EnviroServ HHWDS Britz Reinders

Holfontein 71 IR 24 EnviroServ HHWDS

Holfontein 71 IR 27 Jaco van Zyl Jaco van Zyl

Holfontein 71 IR 40 Willem Wynand De Jonge Willem Wynand De Jonge

Holfontein 71 IR 59 Mr Berman Toby Mr Berman Toby

Holfontein 71 IR 64 Mr Berman Toby Mr Berman Toby

Holfontein 71 IR 66 Rossgro Beleggings 3 Pty Ltd The Directors

Holfontein 71 IR 86 Dwarstrek Pty Ltd The Directors

Holfontein 71 IR 97 EMM Ms Elsabeth van der Merwe

Holfontein 71 IR 475 EMM

5.4 Land Use

Current Land Use of the Holfontein Extension: IWMF 5.4.1

The Holfontein Extension: IWMF area comprises:-

• mostly unimproved grassland. This land has several trenches that were used to drain the

wetland for past agricultural practices. No agriculture currently takes place;

• several unused clay quarries;

• remnants of a derelict brickworks facility;

• the Lushoff and Ericson’s dam and a reservoir;

• a few functional and derelict buildings;

• the Holfontein soil and clay stockpile, and




• an unnamed watercourse and wetland.

Surrounding Land Uses 5.4.2

Land use immediately surrounding the proposed Holfontein Extension: IWMF area includes (see Figure

5-1below):

- The HHWDS;

- extensive, dry-land cropping, the properties of which are mostly owned and farmed by Mr JRF

Neuhoff;

- poultry production to the south east at the Daybreak Poultry Farm;

- unimproved grassland and wetland;

- the N12 highway to the south of the site; and

- various small dams on surrounding properties.

There are few residents within a 2 km radius of the proposed Holfontein Extension: IWMF as the

majority of the land is used for extensive agriculture. The residents that are present are found at widely

dispersed agricultural holdings. The closest are residential houses on portion 22 of Holfontein 71-IR.

In relation to established residential areas, the proposed Holfontein Extension: IWMF is:

• ± 1.6 km west of Rietkol AH;

• ± 2.2 km north west of Springs AH;

• ± 2.2 km north of Welgedacht AH;

• ± 3 km south east of Mandela Park (Etwatwa); and

• ± 7 - 8 km east of Daveyton.

Only Mandela Park and Daveyton comprise of reasonably high-density residential suburbs.

5.4.2.1 Proposed Developments

The Eastside Junction Mixed Use Development is proposed in Mpumalanga on the Remaining Extent

of Portion 7 of the farm Modderfontein No. 236 (M DEDET Ref No: 17/2/3N - 229) to the east of the

HHWDS. The development comprises a Casino and retail complex, business premises, offices,

commercial, warehousing and light industry. No residential is currently indicated.

Interwaste’s proposed development of the integrated waste management facility on the Amadwala

properties (Holfontein 17 IR portions 14 and 27) is adjacent to the proposed Holfontein Extension:

IWMF (DEA Ref: 12/9/11/L1257/3 and GDARD Ref: Gaut 002/13-14/E0073).





Figure 5-1: Current Land Use at the proposed Holfontein Extension: IWMF




5.5 Soils and Geology

The following geological information was taken from the specialist geological and geohydrological

report by JAWS (2010 to 2014) written for the proposed expansion of the Holfontein site. Copies of the

report will be included with the EIA report.

Soil 5.5.1

Surface soils across the site consist of clayey colluvial sands of mixed origin. These sands are

gradually ferrunginised with depth, merging into hardpan soft rock ferricrete to a depth of 4.5 m.

Underlying the ferricrete horizon are weathered sedimentary rocks.

The transported soils tend to be sandy and permeable while the pedogenic horizon is often well

cemented and impermeable and hence the development of a perched water table can be expected

during wet periods.

The residual soils within the upper 10 to 15 m of the Karoo cover comprise very stiff, fine grained, relict

laminated, micaceous silty sands to sandy silts that typically exhibit very low permeabilities.

Permeability tests carried out on this material have indicated values in the order of <1 x 10-7 cm/sec.

The transition from the residual soils to bedrock is gradational and a soft rock to medium hard rock is

typically encountered from depths of 15 m. The Karoo bedrock will also exhibit low permeability’s and

hence any seepage down the profile will be limited.

The expected soil profile will provide suitable founding conditions. Consolidation settlement can be

expected within the hillwash horizon but the thickness of this horizon is limited and the underlying

pedogenic and residual horizons have consistencies that are stiff or dense or better and these will

provide suitable founding conditions.

5.5.1.1 Soil Contamination

Concerns have been raised, by Interwaste, that the soils on these properties may be contaminated as a

result of operations at the HHWDS and from incidents at that facility (waste spillages, storm water

flows). There is also a concern that the materials in the Holfontein Soil and Clay Stockpile could be

contaminated as they were derived (at least in part) from the HHWDS.

The surface water monitoring network for the HHWDS provide some direct and some indirect evidence

that the quality of the soils on the project properties have not been significantly contaminated.

Monitoring of surface water quality at the site where most of the soil and clay on the Stockpile was

derived from, immediately before its excavation, also provides no evidence of contamination. This may

require further investigation in the EIA phase to confirm.




Regional Geology 5.5.2

The regional geology is dominated by the Karoo Supergroup that overlies the Transvaal Sequence. The

Karoo rocks are represented by the Dwyka and Vryheid formation of the Ecca Group. These Karoo

rocks are typically 50 to 60 m thick. The Transvaal rocks are represented by dolomites of the Malmani

formation. Post- Karoo dolerite intrusives are also present in the region.

Local Geology 5.5.3

The site is underlain by a relatively thin sequence of weathered siltstones, shales and sandstones from

the Vryheid Formation of the Ecca Group (see Figure 5-2 below). The weathered layers give way to the

fractured Karoo sediments. These sediments are in turn underlain by the Dwyka Formation, which

consists mainly of tillite and diamictite. Below the Dwyka formation lies a chert-rich dolomitic layer that

is intruded by Pilanesberg age dykes and dolerite sills. The geology underlying the HHWDS has been

verified through the drilling of a large number of boreholes and the stratigraphy is as follows:

• Transported sand/Ferruginised soils 0 – 2 m

• Residual to Weathered Karoo Formation 0 - 10 m

• Fractured Karoo Formation 30 – 55m

• Dwyka Formation 55 – 65 m

• Dolomite 65 – 100+ m. (variations in thickness do occur)

Dolomite Stability 5.5.4

Dolomitic land is defined as land underlain by dolomite residuum or bedrock or both, typically at depths

no more than:

• 60 m where no dewatering has taken place and the local authority has jurisdiction, is monitoring

and has control over the groundwater levels; or

• 100 m where dewatering has taken place and the local authority has no jurisdiction or control

over the groundwater.

A detailed dolomite stability assessment for the site is provided in the JAWS report JW156/10/B200.

The risk assessment considered the properties of the overburden; the presence of receptacles and the

trigger mechanisms to move material. The profile conditions are not conducive to sinkhole formation

and the area is categorised as low risk. However, it was noted that groundwater extraction for irrigation

and municipal use does occur and local mining could potentially result in dewatering. Such activities

could increase the potential for sinkhole formation. Monitoring of groundwater levels is required.




Figure 5-2: General Geology at the Proposed Holfontein Extension: IWMF




5.6 Climate

Regional Climate 5.6.1

The site of the Holfontein Extension: IWMF falls within the summer rainfall area of South Africa and is

characterised by thunderstorms in summer, combined with winters that are typified by drought, severe

night frost, and marked diurnal temperature variations. Climate conditions are typical of the Highveld

region where rates of average annual evaporation exceed that of average annual precipitation.

Temperatures 5.6.2

The average daily maximum temperature for the area is 26 °C in midsummer and 18 °C in midwinter.

The average daily minimum temperature for the area is 14 °C in midsummer and -1 °C in midwinter.

5.6.2.1 Precipitation

Rainfall data were sourced from on-site measurements at the HHWDS (since 1998) and the South

African Weather Bureau Station, located at Springs. The mean annual precipitation for the region is 694

mm (Gauge # 476736) with the on-site average at the HHWDS recorded at 678 mm. Rainfall occurs in

high-intensity events that are largely confined to the summer months.

Mean annual evaporation at the HHWDS averages 2 553.19 mm (measured since 2002) and exceeds

average rainfall for each month of the year.

Table 5-2: Annual Rainfall and Evaporation at the HHWDS (source: Jones & Wagener, 2013)

Year Rainfall (mm) Year Evaporation (mm)

Oct 13 to May 2014 586.30 May 13 to Apr 2014 2 692.80

Oct 12 To Sept 13 398.02 May 12 To Apr 13 2 546.85











Oct 01 To Sept 02 669.2




Oct 00 To Sept 01 742.5

Oct 99 To Sept 00. 1 124.0

Oct 98 To Sept 99 741.5

Average 725.95 2 553.19

5.6.2.2 Wind Patterns

The area is dominated by north westerly and easterly winds throughout the year. During the winter

months there is an increase in the frequency of south westerly winds.




Figure 5-3: Annual average and day/night time wind roses

Figure 5-4: Seasonal average wind roses




5.7 Air Quality

Regional Air Quality 5.7.1

Air quality in the eastern Gauteng region is known to be poor. The Holfontein Extension: IWMF site is

located within the Highveld Priority Area which is associated with poor air quality. Frequent

exceedances of national Ambient Air Quality Standards are recorded and are attributed to a

combination of emissions from the concentrated industries, residential fuel burning, power generation,

motor vehicles, mining, and cross-boundary transport of pollutants into the region (DEA, 2010).

Problem pollutants include SOx, NOx, metal oxides and hydrocarbons.

Local Air Quality 5.7.2

Potential sources of air pollution in the vicinity of the Holfontein Extension: IWMF include:

• the HHWDS;

• activities at the Holfontein Stockpile;

• agricultural lands and farming (i.e. ploughing);

• fires on agriculture lands and combustion of products;

• chicken farms;

• household fuel burning;

• vehicle exhaust emissions;

• various industrial sites;

• sewerage facilities; and

• vehicle traffic;

On and off-site sampling of dust fallout and ambient air quality is undertaken at the HHWDS by

Geozone Environmental. Results are reported in the regular Air Pathway Analysis System (APAS)

reports. As demonstrated in the APAS reports over the past decade the impact of activities performed

at the HHWDS in respect of the ‘on-site’ air quality can be significant, particularly along the downwind

site boundaries (east and south-east). This relates mostly to ambient Benzene, ammonia and aldehyde

concentrations. However, air quality along the boundaries of the HHWDS is reported to pose a low non-

cancer health risk to exposed persons, of which there are few. Ambient air quality along the boundaries

of the Holfontein site continues to pose a low cancer risk to exposed persons. The impact of HHWDS

activities on the ‘off-site’ air quality is considered to be minimal. Monitoring of ambient air quality at off-

site locations (Etwatwa, Neuhoff residence, Sundra) records low cancer and non-cancer health risk to

exposed persons.

5.8 Noise

Current ambient noise sources in the Holfontein area include:

• Waste disposal operations at the HHWDS:

– Refuse trucks approaching and leaving HHWDS & Holfontein Stockpile;




– Refuse trucks dumping their contents at the HHWDS;

– Operation of on-site vehicles and equipment (such as, bulldozer, compactor, front

end loader, water truck); and

– Operations at the leachate treatment plant.

• Traffic on the N12 highway;

• General localised traffic; and

• Agricultural activities.

The various residential suburbs in the area (see Section 5.4.2) represent noise sensitive receptors.

5.9 Hydrology

Catchments and River Systems 5.9.1

The Holfontein area falls within the Upper Vaal Water Management Area (WMA, no 8), close to the

watershed of the Vaal and Olifants River basins. The site is situated within the Suikerbosrand tertiary

catchment area C21, within quaternary catchment C21D, near the head of the catchment, and drains to

an unnamed tributary of the Blesbokspruit River, that is ± 5.5 km to the south west (Figure 5-5). The

Blesbokspruit River drains to the Merrivale Wetland, then to the Suikerbosrand River which enters the

Vaal River upstream of the Barrage. The unnamed tributary of the Blesbokspruit River has been subject

to extensive modifications with drainage channels dug in a number of sections. There are also

agricultural lands close to banks in a number of areas.

Surface water resources 5.9.2

The land for the Holfontein Extension: IWMF has two water-filled, abandoned clay mining quarries and

two small dams (Lushoff Dam and Ericson’s Dam). All of the dams or quarries were built/ excavated by

the prior property owners (see Table 5-3 below). These man made water bodies are all mapped as

wetlands in the NFEPA database.

There are also numerous pans and wetlands of various sizes in the region. The most significant of

which are the natural pans to the north, east and west of the HHWDS. These are located upstream of

the site. There are no documented pans on the project properties.

The Blesbokspruit River drains to the Merrivale Wetland, then to the Suikerbosrand River which enters

the Vaal River upstream of the Barrage. The Blesbokspruit River is approximately 81.5 km long with a

catchment area of 150 074 ha.




An unnamed tributary of the Blesbokspruit is shown on various spatial data sources as flowing

southward across the properties proposed for the Holfontein Extension: IWMF. In its upper reaches the

unnamed tributary of the Blesbokspruit is indistinct, but lower in the catena the flow path of this

watercourse is evident in the field with surface water being present in the summer months. In the

NFEPA database the watercourse has extensive wetlands associated with it. These wetlands are

evident in aerial photography and in the field, although they have been subject to extensive

modification.

Approximately 50 ha of wetland is found in the upper reaches of the unnamed tributary to the

Blesbokspruit on the properties below the HHWDS (Ecotone, 2013). The extent of the wetland has

been reduced by various direct disturbances (agriculture, quarries, soil stockpiles).The wetland

comprises of a valley head seep area (HGM 1) and a channelled valley bottom system (HGM 2) (see

Figure 5-5 below).

Table 5-3: Dams and Quarries on the proposed Holfontein Extension: IWMF

Property Name/ description Dam / quarry Approx. centre point Capacity (m3)

Holfontein 71 IR, Portion 48 and 74

(includes portion 37)

Quarry 1 (Brickworks) 26° 9'10.09"S

28°31'5.27"E

±150 000

Holfontein 71 IR, Portion 16 Quarry 2 26° 9'1.42"S

28°30'49.53"E

± 30 000

Holfontein 71 IR, Portion 72 Ericson’s Dam/Quarry 26° 9'16.35"S

28°30'55.42"E

± 15 000

Holfontein 71 IR, Portion 28, 32, 33 & 34

(known collectively as portion 28)

Lushof Dam 26° 9'24.32"S

28°30'33.17"E

?

Quarry 1 and 2 are large quarries that were excavated to supply materials to the former Holfontein

Brickworks. Quarry 1 is ± 230 m by 320 m in dimension and of unknown depth. Quarry 1 stores a

substantial volume of water (estimated at 150 000 m3). Inflows to the quarry are from rainfall, surface

water runoff and sub-soil seepage. Clean water from the upstream groundwater cut-off trench at the

HHWDS flows into the quarry. Outflows are via evaporation, sub-soil seepage and some overflow.

Quarry 2 is ± 100 m x 200 m in dimension and of unknown depth. The walls of the quarry have been

sloped to make it safer. Storage capacity of the quarry is ± 30 000 m3. Inflows to the quarry are from

rainfall, surface water runoff and sub-soil seepage. Overflow and sub-soil seepage from Quarry 1

enters Quarry 2. Outflows are via evaporation, sub-soil seepage and overflow to the unnamed tributary.

The toe-end of Quarry 2 is located almost within the watercourse of the unnamed tributary and is

certainly within the floodlines and associated wetland area. Seepage from the wetland around the

unnamed tributary is also likely to enter the quarry.




Ericson’s Dam may originally have been a small clay quarry or borrow pit. It is ± 130 x 50 m in

dimension and of unknown depth. Storage capacity of the quarry is ± 15 000 m3. Inflows to the quarry

are from rainfall, surface water runoff and sub-soil seepage from Quarry 1. Outflows are via

evaporation, sub-soil seepage and overflow to the unnamed tributary.

Lushoff Dam is an in-stream facility (in the unnamed tributary) with a low earth wall. The wall of the dam

is highly porous meaning that little water is stored in the dam. It was most probably developed for

agricultural use.





Figure 5-5: Surface Water Resources in the Proposed Holfontein Extension: IWMF Area




Figure 5-6: Structure of the Wetland Bodies located at the Holfontein Extension: IWMF (Ecotone Report, 2013).




Present Ecological Status and Sensitivity 5.9.3

The following information was obtained from the Ecotone Report (2013), produced in support of the

environmental assessment for the Holfontein Stockpile (Synergistics, 2013).

The present ecological status (PES) of the wetland within the project site has shown a notable loss in

hydrological integrity in recent years, which may be attributed to trenches, impeding features and

alteration in runoff characteristics at the site. The median Ecological Importance and Sensitivity (EIS)

score for the wetland indicates a moderate EIS with a localised importance and sensitivity. The

biodiversity of such wetland systems is not usually sensitive to flow and habitat modifications. These

wetlands play a small role in moderating the quantity and quality of water in major rivers.

The wetland still has some function even though sections of the wetland were trenched in the past,

presumably to drain it for agricultural activities. However, the on-going functionality of the wetland and

its ecological status are likely to be further influenced by the management measures at the HHWDS.

Surface water management at the HHWDS contains and diverts surface water flow that used to enter

the wetland along its eastern boundary. In addition, the upstream groundwater cut-off trench

implemented at the HHWDS in 2013 is likely to be intercepting much of the near surface groundwater

flow that would have fed the seeps on its eastern side. With the near complete loss of surface and

groundwater inflows from the eastern extent of the catchment the extent and functionality of the wetland

is likely to be reduced.





Figure 5-7: Ecological Sensitivity of the Proposed Holfontein Extension: IWMF Area




Surface Water Quality 5.9.4

5.9.4.1 Regional

Water quality in the Blesbokspruit River system has been severely impacted on. The water quality

problems in the Blesbokspruit sub-catchment include salinity, eutrophication, public health and organic

load (DWAF, 2004). The salinity problems are largely related to mining industry dewatering, seeps from

tailings dams and industrial discharges; the wastewater treatment plants in the sub-catchment can also

contribute to the salinity levels if they receive industrial effluents (DWAF, 2004). At this stage a

Catchment Management Strategy (CMS) has not been developed for this area. C2H177 and C2H150

are monitoring points from the Water Management System water quality database in the Blesbokspruit

River. Water quality at these points has been monitored by the DWS since the mid-1990s.

5.9.4.2 Local

Water quality in the storm water dams at HHWDS are between 664 and 4 190 mS/m. In general, the

quality of the water in the on-site storm water dams is contaminated to the point that it is no longer used

for dust suppression outside the cell areas. Arsenic, antimony, chromium, lead, manganese, nickel,

selenium and vanadium were found to exceed the SANS guidelines in the various dams.

The HHWDS storm water dams have overflowed on occasion during extreme rainfall events. All such

overflows are reported to the authorities as is required in terms of the licence conditions.

Monitoring is undertaken at 5 locations (refer to the table below) off the HHWDS site and has recorded

electrical conductivity (EC) levels of between 60 and 379 mS/m. Water quality on the project properties

is generally good, however the EC levels at some sites have increased in recent times (refer to Figure

4.8) and some now exceed the SANS screening guidelines. Electrical conductivity of water in Quarry 1

(H0-51) is well below the SANS 241 screening guideline. Only fluoride exceeded the screening

guideline. The discharge from the upstream cut-off trench into Quarry 1 is of good quality at 44 mS/m.

Water quality in the Lushoff dam had declined significantly through 2012 and 2013(from 73 to 379

mS/m). But after being dry for a period the water has improved significantly (to 66mS/m) and is now

well below the SANS 241 guideline. The EC increase was likely a result of evapo-concentration as the

dam dried.

Water quality at Quarry 2 has declined since 2010 and now (192 mS/m) exceeds SANS 241 screening

guideline. Seepage water into the quarry and the effect of evapo-concentration are the likely sources.

Electrical conductivity of water in Ericson’s Dam (H0-54) has increased significantly in the past year

(276 mS/m) and is now well above the SANS 241 screening guideline. The decline is most likely

caused by overflow from the HHWDS storm water dam during extreme rainfall events. Inorganic

constituents or trace elements detected above the screening guidelines included ammonia, chloride,

fluoride and sodium (Jones & Wagener 20134).




In 2010 measures were put in place to contain storm water on the access road that was contaminated

by sediments falling from vehicles departing the HHWDS. A drain and sump were constructed and this

water is returned to the on-site storm water dams. A vehicle wash bay has been installed to remove

sediments from the wheels and under carriages of vehicles departing the landfill site. Management at

the HHWDS are working toward the capping of Cells 1, 2 and 3, which will remove these as sources for

the dirty water and reduce the likelihood of overflows from the storm water dams at the HHWDS.





Figure 5-8: Surface water quality results for electrical conductivity (July 2014)




Surface Water Use 5.9.5

The primary use of surface water (other than the ecological use) in the catchment of the unnamed

tributary to the confluence of the Blesbokspruit River some 5.5 km away is dry-land agriculture. There

are a number of natural pans in the region, particularly to the east of the HHWDS. There are no

significant farms dams in the area.

The HHWDS has storm water management measures designed to prevent pollution of the surface

water resource. Run-off water within the HHWDS is contained within storm water dams on-site and is

effectively removed from the flows in the unnamed tributary to the Blesbokspruit. Clean run-off water

from upstream of the HHWDS is diverted around the HHWDS in surface drains and released to the

environment. The Holfontein Soil and Clay Stockpile is surrounded by a berm to stop surface water flow

from carrying sediment into the adjacent wetland system. Run-off in this small portion of the catchment

is temporarily removed from the flows in the unnamed tributary to the Blesbokspruit.

Quarries 1 and 2 on the EnviroServ properties retain surface water and effectively remove some flow

from the unnamed tributary to the Blesbokspruit. However these quarries are not lined and release

water through seepage to unnamed tributary to the Blesbokspruit. EnviroServ does abstract limited

volumes of water from Quarry 1 and occasionally from Quarry 2.

5.10 Groundwater

The geohydrological conditions at and around the HHWDS have been investigated, modelled and are

monitored by Geohydrologists / Geochemists. The information in the sections below has been drawn

from these modelling and monitoring reports compiled by Jones & Wagener.

Characterisation of the Aquifers 5.10.1

Four aquifers are recognised in the geology that underlies the HHWDS and have been described as

(Jones & Wagener, 2008):

• A seasonal, shallow perched aquifer in the ferricrete/sandstone contact. Encountered at a depth

varying from 1.5 to 3 m below surface. This water is the most vulnerable to contamination.

• Weathered Karoo Aquifer: A shallow perched aquifer that occurs in the weathered zone down to

a depth of between 15 m and 20 m below surface. The groundwater level in this aquifer varies

between 4.5 m and 8.0 m below surface. The weathered aquifer has low aquifer parameters

(transmissivity and storativity) and groundwater movement is expected to be slow. This is due to

the nature of the weathered material, which consists mainly of silty sand and clay. The aquifer is

nevertheless vulnerable to contamination.

• Fractured Karoo Aquifer: lies a little deeper than the weathered aquifer and is found in the

fractured Karoo lithologies to a depth of 55 m. The fractured aquifer may or may not be in

hydraulic connectivity with the upper weathered aquifer as clay lenses do divide the two in




places. Water levels are between 6.5 and 12 m below surface.

• Dolomitic Aquifer: underlies both the weathered and fractured Karoo strata. The aquifer has

significant storage capacity as a result of weathering of the upper formations. Water levels are

between 7 and 18 m below surface. The aquifer is confined as a result of the overlying Dwyka

formation which has very low hydraulic conductivities. The Delmas municipality extracts large

volumes of water from this aquifer.

Groundwater Gradient and Levels 5.10.2

The groundwater levels in the area shows seasonal variations although there are differences between

the aquifer systems. The shallow weathered aquifer shows an almost immediate response to rainfall, as

does the deeper fractured aquifer.

A review of the groundwater levels in boreholes at the HHWDS indicates that a general correlation

exists between the topography and the groundwater table. The correlations are generally poor if

groundwater levels are included from all boreholes as abstraction occurs. Such pumping has had an

influence on water levels and flow directions in all aquifers. In general thought he undisturbed flow is

towards the south-west at a gradient of ± 3%. If, however, pumping at Holfontein desists, the flow

direction in all aquifers would mimic the topography.

Flow direction in the weathered Karoo aquifer is toward the south west. Flow pattern has been affected

by the operational dewatering at the HHWDS with inflows toward the site (indicating the success of

these operations). There is no discernable impact on flow direction in this aquifer resulting from water

extraction by any farmer. Flow in the fractured Karoo aquifer was historically to the south west. Current

flow direction has been affected by groundwater abstraction and is now, at least in the northern regions,

toward the north west . Flow in the dolomite aquifer was also historically to the south west. The flow

direction has been similarly altered by groundwater abstraction and is now in a south and south easterly

direction. Abstraction by EnviroServ does not take place from these deeper aquifers and it is postulated

that abstraction by farmers and municipalities are influencing the flow directions.

The boreholes drilled as part of the investigation into the expansion of the site has indicated significant

variations in the dolomitic water levels. The reason for this is believed to be due to the complex

compartmentalisation of the dolomites as a result of the intrusion of a number of dolerite sills and

dykes. As a result it is not possible to determine the local groundwater flow direction within the dolomitic

aquifer.




Groundwater Quality 5.10.3

Groundwater quality of the aquifers below the HHWDS and surrounds is monitored by Jones &

Wagener Consulting Civil Engineers in terms of a Monitoring Protocol (JAWS, W22/14/B200) through

the use of monitoring boreholes, several of which are located within the project properties. The

monitoring network also includes the hydrocensus boreholes on the farms of Mr Neuhoff and Day Break

poultry. Monitoring has been on-going since as far back as 1996. The following information was

extracted from the latest Water Quality Monitoring Report (JW145/14/B200, July 2014):

Water quality downstream of the HHWDS is generally good. However, water quality in boreholes on the

site boundary has been decreasing (The EC of H0-42 has increased from 35 mS/m in 2003 to 375

m/Sm). This is believed to represent the spread of the contamination plume from Cells 1, 2 and 3. The

chloride concentrations were found to exceed the screening guidelines within borehole HO-42 in July

2014. All other downstream boreholes have remained well below the SANS 241 screening guideline

with EC levels under 80 mS/m. There were no inorganic constituents found to exceed the screening

guidelines within any of the other boreholes. Although a number of organic constituents were detected

none were found to exceed the screening guidelines.

No changes have been detected in the water quality of boreholes in the weathered or fractured aquifer

downstream of the other waste cells. This is due to the improvements in design and operation of these

cells.

Currently, analyses show that all other locations on the properties of the Holfontein Extension: IWMF

have an electrical conductivity below the Department of Water Affairs and Forestry (DWSF) drinking

water guideline of 70 mS/m over the monitoring period (Figure 5-9). Inorganic constituents did not

exceed the South African National Standards (SANS) 241 2011 screening guidelines across the

monitoring period. In addition, iron and manganese are the only trace elements that have been

detected at increased concentrations, although these are believed to have originated from the natural

geology. Only low concentrations of organic constituents have been recorded in a few boreholes. This

means that currently, the groundwater quality of the Holfontein Extension: IWMF area has not been

severely negatively impacted due to the presence of the adjacent HHWDS.

Table 5-4: Boreholes located on proposed Holfontein Extension: IWMF

Aquifer Property Borehole number

Borehole depth (m)

Purpose

Weathered Karoo aquifer

Holfontein 71 IR, Portion 16 HO-20 15 Monitoring






Dolomitic aquifer




Holfontein 71 IR, Portion 28 HO10-216 100 Monitoring









Diabase aquifer Holfontein 71 IR, Portion 16 HO10-219 50 Monitoring

Hydrocensus

Boreholes

Holfontein 71 IR, Portion 28 HO-30 >100 current water

supply borehole

Holfontein 71 IR, Portion 32 HO-31 >100 Monitoring





Figure 5-9: Groundwater Quality (electrical conductivity) in weathered Karoo boreholes (July 2014)




Groundwater Use 5.10.4

Groundwater is currently not abstracted directly on the properties associated with the proposed

Holfontein Extension: IWMF. EnviroServ uses two borehole for water supply at the HHWDS at a rate of

~ 100 m3 per day. EnviroServ also operates 11 dewatering boreholes in order to minimise the spread of

contaminated groundwater downstream of Cells 1, 2 and 3 at the HHWDS. An average daily volume of

24 m3 is removed from the dewatering system.

Some groundwater is also extracted at the Neuhoff residence (located upstream of the HHWDS) for

domestic use at a rate of 2 to 3 m3.

There is known to be large-scale groundwater abstraction, particularly from the dolomitic aquifer, by the

Delmas Municipality (24 wells at 4.0 m3 per well per hour i.e. 2300 m3 per day, personal

communication, J Neuhoff), as well as a number of centre pivot based agricultural operations trending

in a north west to south east band approximately 5.0 km to the north of the HHWDS. In addition, there

is approximately 88 m3 per hour abstracted from the three dolomitic aquifer Day Break farm boreholes,

of which 35 m3 per hour is being extracted from Day Break farm borehole, which is located less than

950 m to the south east of Cells 1, 2 and 3. This abstraction of groundwater from the dolomitic aquifer is

believed to be having an impact on the groundwater flow directions in the deeper aquifers at the

Holfontein Waste Disposal Site

5.11 Ecology and Biodiversity

The study area is located within the grassland biome, which is one of the most threatened biomes in

South Africa due to agricultural and mining activities. Approximately 60 to 80% of the grassland biome

is irreversibly transformed, while only 2% is formally conserved.

Site observations and review of aerial photography indicates that most of the Holfontein Extension:

IWMF site has been extensively transformed and degraded through historical agricultural and clay

mining activities. Although the potential exists for pockets of indigenous vegetation, the likelihood of

sites with terrestrial ecological and biodiversity value is considered low.




Flora 5.11.1

In terms of the latest regional vegetation classification, three vegetation units occur in the area: Eastern

Highveld Grassland, Eastern Temperate Freshwater Wetlands and Rand Highveld Grassland (Mucina

and Rutherford 2006) (see Figure 5-10). The Holfontein Extension: IWMF is located within the Eastern

Highveld Grassland. The vegetation is short dense-grassland dominated by the typical Highveld grass

composition (Aristida, Digitaria, Eragrostis, Themeda, Tristachya) with small, scattered rocky outcrops

with wiry, sour grasses and some woody species (Acacia caffra, Celtis Africana, Diospyros lycioides

subsp lycioides, Parinari capensis, Protea caffra, P. welwitschii and Rhus magalismontanum). Eastern

Highveld Grassland has been categorised as endangered due to the transformation of over 44% by

cultivation, plantations, mines, urbanisation and building.

The vegetation on and surrounding the Holfontein Extension: IWMF site consists almost entirely of

regrowth on old agricultural fields with small pockets of grassland, exotic trees and wetlands. The open

spaces are generally highly disturbed; show a high level of habitat transformation, with low species

diversity and a large number of non-indigenous species.

The vegetation of areas that have been identified as wetlands adjacent to the unnamed tributary of the

Blesbokspruit have not been mapped as Eastern Temperate Freshwater Wetlands (Mucina &

Rutherford). Obligate wetland vegetation species found in the region include Leersia hexandra, and

Cyperus spp. Facultative wetland plants include Verbena bonariensis, Senecio spp., Themeda trianda,

Helichrysum spp. Eragrostis spp. and Imperata cylindrical.

5.11.1.1 Protected and Red Data Plant Species

No records exist for the presence of threatened floral species on the site and no evidence of the

presence of any such floral species has been observed during site visits to date.

Two floral species of conservation concern have been recorded in the grid square 2628BA within which

the site is located; these are Kniphofia typhoides (Near-Threatened. IUCN, 2012) and Crinum

bulbispermum (Declining. SANBI, 2012).

Three threatened Red Data wetland plant species, namely Brachycorythis conica subsp.

transvaalensis, Cineraria longipes, and Nerine gracilis could occur within the wetland areas, but due to

the high level of disturbance in the system from overgrazing and other agricultural and industrial

activities, it is highly unlikely that the species are present in the wetland.

No nationally protected plant species in terms of the National Environmental Management: Biodiversity

Act, 2004 (Act No. 10 of 2004) (NEM:BA) are recorded from within the study area but 93 provincially

protected species in terms of the Gauteng Nature Conservation Act, (draft 2012) are documented

(EkoInfo Report, 2013). Of the 93 species:

• Only one genera is associated with a single species (Ammocharis coranica);

• Fifty seven (57) species belong to 25 genera of which all species in the genera are protected; and




• Twenty eight (28) species belong to the Orchidaceae family, of which all of the species within the

family are protected.

Furthermore, 28 species were categorised as either red or orange on the GDARD listed species.





Figure 5-10: Vegetation at the Proposed Holfontein Extension: IWMF




Fauna 5.11.2

No records exist for the presence of protected faunal species on the site and no evidence of the presence

of such species has been observed during any site visit. The likelihood of any protected or Red Data

species occurring on the site is considered to be low due to the high levels of disturbance and

transformation.

The grassland/wetland vegetation could potentially provide suitable habitat for four species of

conservation concern: Serval Leptailurus serval, Forest Shrew Myosorex varius, African Grass-owl Tyto

capensis and the Marsh Sylph butterfly Metisella meninx (EkoInfo Report, 2013). African Grass-owl and

Marsh Sylph have a high probability of occurrence, and are likely to utilise the wetland system based on

the presence of suitable foraging, breeding and roosting habitat.

5.11.2.1 SABAP2

The proposed Holfontein Extension: IWMF is located within the pentad 2605_2830 for SABAP2.

Approximately 130 bird species have been recorded within this pentad. Many of the bird species

commonly recorded were those usually found in disturbed or human-inhabited areas. Species recorded

also comprised a mixture of those associated with wetland habitats (such as Southern Masked-Weaver

Ploceus velatu, Blacksmith Lapwing Vanellus armatus, Marsh Owl Asio capensis, and African Sacred Ibis

Threskiornis aethiopicus) and grassland vegetation types (Red-billed Quelea Quelea quelea, Helmeted

Guineafowl Numida meleagris and African Stonechat Saxicola torquatus).

Of the bird species recorded within the pentad, three are on the IUCN Red List of Threatened Species:

- Black-winged Pratincole Glareola nordmanni (Near-Threatened & Population-decreasing Trend);

- Lesser Flamingo Phoeniconaias minor (Near-Threatened & Population-decreasing Trend); and

- Maccoa Duck Oxyura maccoa (Near-Threatened & Population-decreasing Trend).

The Lesser Flamingo and Maccoa Duck are unlikely to be recorded within the wetlands of the Holfontein

Extension: IWMF area and are more likely to be recorded within open water bodies.

*Note that the African Grass-owl was not recorded within this pentad, neither within the adjacent pentads

thus far during SABAP2 (2605_2825, 2610_2825, 2610_2830). This information does not mean, however,

that the bird species has never been present or does not occasionally use the wetlands for hunting or

other activities.

5.11.2.2 SARCA Project

Currently, there are 21 and 18 species of reptiles that have been recorded within the QDS’s 2628AB and

2628BA respectively for the Holfontein Extension: IWMF Project, many of which overlap. The Coppery

Grass Lizard, Chamaesaura aenea, has been listed as Near Threatened on the IUCN Red List of Species.

This species may occur within the grasslands of the Holfontein Extension: IWMF area.




5.11.2.3 Frog Atlas

Currently, there are 16 and 13 species of frogs that have been recorded within the QDS’s 2628AB and

2628BA respectively for the Holfontein Extension: IWMF Project, many of which overlap. Only one

species, the Giant Bullfrog, Pyxicephalus adspersus, was of conservation concern as it is listed as Near

Threatened on the IUCN Red List of Species. The Giant Bullfrog uses temporary pans for breeding for a

short duration in the summer rainfall period, and therefore may use parts of the wetland area during

periods of inundation.

5.11.2.4 Mammal Map

Currently, there are 17 and 4 species of mammals that have been recorded within the QDS’s 2628AB and

2628BA respectively for the Holfontein Extension: IWMF site, only one of which overlaps. One species,

the White-tailed Rat, Mystromys albicaudatus, is listed as Endangered under the IUCN Red List. Three

species have been listed as Near Threatened on the IUCN Red List. These include serval, Leptailurus

serval, Spotted-necked Otter, Lutra maculicollis, and Welwitsch's Hairy Bat, Myotis welwitschii.

Biodiversity and Conservation Importance 5.11.3

5.11.3.1 Protected and Conservation Areas

There are no formally protected or conserved areas within close proximity to the Holfontein Extension:

IWMF site. The Marievale Bird Sanctuary is located ± 15 km downstream of the confluence with the

unnamed tributary of the Blesbokspruit River. The Marievale Bird Sanctuary is situated in the southern

half of the Blesbokspruit RAMSAR site, an area that is also a designated as an Important Bird Area (IBA

SA021) in South Africa. Although the sanctuary forms part of the same tributary associated with the

Holfontein Extension: IWMF area, it is 15 km from the site and therefore unlikely to be affected by

activities at the proposed Holfontein Extension: IWMF.

5.11.3.2 Threatened Ecosystems

The Holfontein Extension: IWMF is located within the Eastern Highveld Grassland, which has been

categorised as Endangered by Mucina and Rutherford (2006). The Eastern Highveld Grassland (Gm12) is

listed as a Vulnerable ecosystems in terms of the NEM:BA




5.11.3.3 GDARD Conservation Plan

According to the GDARD C-plan (version 3.3), much of portions 15, 16, 33, 34 and 72 are mapped as

ecological support areas (ESA) and is considered to be an important site. Additionally part of portions 16,

28, 32, 33, 34 and 72 are mapped as Critical Biodiversity Areas (see Figure 5-7). The CBA generally

encompasses the areas identified as hill slope seepage wetlands and the related buffer. These areas are

considered highly sensitive sites and essential for the conservation of biodiversity in Gauteng. The

importance of these sites is in terms of the ecological services (groundwater dynamics, hydrological

processes, nutrient cycling and wildlife dispersal) that they provide.

5.12 Cultural and Heritage Resources

The Highveld is an area which did not see much human occupation in pre-colonial times. This had to do

with economic strategies, cultural preferences and climate fluctuations. It was only after white settlers

entered the area that population numbers increased significantly.

The properties on which the Holfontein Extension: IWMF is proposed, comprise unimproved grassland

from previous agricultural disturbances. The area is crossed by trenches dug in order to improve drainage

and enable agricultural use. There is also evidence that sections of the site have been mowed at various

times. As a seasonally inundated area, it is unlikely that any archaeological or heritage material or sites

would be present.

The response from SAHRA has indicated that a Phase 1 heritage assessment is required.

5.13 Traffic

The N12 national highway is a major road, carrying significant traffic volumes between Gauteng and

Mpumalanga and Mozambique. The route to the site is from the N12, briefly along Modder Road and then

onto the site access road. The heavy trucks frequenting the HHWDS and the adjacent truck workshop and

brickworks, form the primary traffic volumes along site access road. On average, ± 130 heavy motor

vehicles visit the HHWDS on a daily basis. The presence of the HHWDS has resulted in higher, heavy-

vehicle traffic on the local roads.

5.14 Socio-Economic Environment

The Holfontein Extension: IWMF is located in Gauteng, near to the provincial boundary with Mpumalanga.

The site falls within the Eastern Service Delivery Region of the Ekurhuleni Metropolitan Municipality

(EMM).




Population Information 5.14.1

The EMM has a population of 3 178 470 million people, which includes 5.4% of the country’s population

and 25.5% of Gauteng’s population (EMM IDP 2013/2014). The EMM has a population density of 1,609.4

persons per km2 compared to Gauteng, which has a population density of 675.1 persons per km2 (EMM

IDP 2013/2014), making Ekurhuleni one of the most densely populated areas in the country and province.

According to the South African Census Statistics data, the total population in the EMM has increased by

24% over 10 years. Population density in EMM is approximately 1,609 people per km², The EMM has

∼1015465 households (EMM IDP 2013/2014).

In Gauteng, the Etwatwa area of the EMM is comprised of over 25 000 houses and nearly 20 00 informal

dwellings with ± 151 000 residents (Census 2011) of which the great majority are African persons. The

majority of households have good access to municipal services such as electricity, water, sewage and

refuse removal. The area has 40 000 employed and 25 000 unemployed persons. This indicates that the

ward is likely to have a high proportion of job seekers. The project site is located in Ward 67 with adjacent

wards being 66, 68, 69 and 72 of the EMM.

On the Mpumalanga side of the provincial border in the Victor Khanye Municipality, there are ± 75 000

residents (Census 2011).

The immediate surrounds of the Holfontein Extension: IWMF is characterised by agricultural land with a

low-density of residents (see Figure 5-1). The number of residents in the areas within 2 km of the site has

not altered significantly in the past decade. The same is not true for areas beyond this with Etwatwa in

particular having expanded and increased in density significantly in the past decade. The agricultural

holding areas of Sundra and Rietkol, while remaining low-density residential areas have experienced

relatively significant increases in population.

Economic Activity 5.14.2

41.5% of the population is economically active and economic contributions from the EMM accounts for ∼ a

quarter of Gauteng’s economy and a third of the national Gross Domestic Product (EMM IDP 2013/2014).

The EMM contributes ∼ 6.1% to national production, and between 1996 and 2011, the EMM’s economy

grew by an estimated average of 3.2% per annum (EMM IDP 2013/2014). EMM is often referred to as

‘Africa’s Workshop’ as it has the largest concentration of industry in the whole of Africa. There are many

plants for the manufacturing and production of goods and commodities in Ekurhuleni. Ekurhuleni is also

the transportation hub of the country, within which major transportation networks and infrastructures are

located, including the OR Tambo International Airport and the largest railway hub, which is located in

Germiston (EMM IDP 2013/2014).




Towns nearby to the Holfontein Extension: IWMF include Etwatwa in Gauteng and Delmas in

Mpumalanga. Etwatwa, ± 3 km to the west, comprises a high-density, low-income residential suburb that

has grown substantially in the past five years. The majority of employed residents here commute to work

in Ekurhuleni or Johannesburg. Delmas, 15 km to the east is an established town that supports the

agricultural and mining industries. The Sundra, Rietkol and Welgedacht agricultural holdings areas are

located to the south and east and comprise low-density smallholdings. The number of persons residing in

these residential areas has increased because of the densification of the agricultural holdings. Agricultural

activity on these small holdings is relatively limited and there are not a lot of employment opportunities.

The few remaining, commercial farms in the Holfontein area do contribute to the employment of local

persons.

Employment trends 5.14.3

According to the data collected in Census 2011 49.4% of the total population of the EMM are employed.

The balance of the population are either unemployed (20%), economically inactive (27%) or actively

seeking work (3.6%). The average household in the EMM has an annual income of R163,676 but as much

as 28.2% of the EMM population is poverty-stricken (EMM IDP 2013/2014). According to the 2011

census, the unemployment rate within the Victor Khanye Local Municipality is 28.19% (VKLM IDP,

2013/2014).

EnviroServ employs ± 130 persons as part of the core staff at HHWDS. An additional 120 persons work

as contractors, undertaking various projects at the HHWDS.

Planning and Proposed Local Development 5.14.4

The Ekurhuleni Metro IDP does not specify or outline any planning objectives for the area in which the

Holfontein Extension: IWMF will be located (EMM, 2013/2014). The regional framework (EMM, 2010)

demarcates the area in which the proposed Holfontein Extension: IWMF is located as an extensive

agriculture area, outside of the delineated ‘urban edge’. The Daveyton/Etwatwa area has been earmarked

as a Service Upgrading Priority Area in which the EMM should focus its capital expenditure and

operational programs to improve service delivery.

The Eastside Junction mixed-use development has been proposed by Sofiline Pty Ltd on the Remaining

Extent of Portion 7 of the farm Modderfontein No. 236 in Mpumalanga. The proposal includes a Casino,

Hotel and entertainment complex as well as shopping centre, motor trade facility and business park. An

EIA is currently in progress to support an environmental authorisation (M DEDET Ref: 17/2/3N - 229). The

property borders the HHWDS at its extreme west and part of the development area is located within the

buffer zone of the HHWDS.

Interwaste Pty Ltd has proposed the development of the Amadwala Integrated Waste Management

Facility. The proposal is for a new general and hazardous waste management facility at portion 14 and 27




of farm Holfontein 71, Breswol AH and farm Holfontein 71-IR, on Inqwelo Street. It is envisaged that the

proposed Site would be able to receive approximately 100 000 tonnes per month of various general and

hazardous, liquid/sludge and solid industrial, commercial and mining wastes when fully operational for

treatment, recycling, recovery and/or disposal. An EIA is currently in progress to support a waste

management licence and an environmental authorisation (DEA Ref No. 12/9/11/L1257/3 and GDARD Ref:

Gaut 002/13-14/E0073).




7. Results of Public Consultation

Issues and concerns relating to the Scoping and EIA process have been captured as outlined in Section

3.6.

7.1 Collation of Issues and Concerns

Issues and concerns relating to the proposed Holfontein Extension: IWMF have been captured by means

of:

• Minutes from the public meeting held at Hadida’s Garden Estate on 15 April 2014 (Appendix B);

and

• Written, email and telephonic responses received following public notification of the project

(Appendix B.

7.2 Summary of Issues raised by Interested and Affected Parties

A summary of issues and concerns raised by IAPs is provided in Table 7-1, with the names of the IAP and

the date the issue or concern was raised. Responses to all concerns are provided.




Table 7-1: Issues and Concerns

No. Date Name Question/ Issue Raised Comment/ Response

Public Participation Process 1 15 April 2014

(public meeting) Skhumbuzo Mathebula

Some attendees cannot understand the technical details and need Synergistics to provide the public with a meaningful opportunity to understand what EnviroServ propose to do. The community need to understand the technical details to be able to communicate the project and issues to other people.

Matthew Hemming (MH) stated that Synergistics is independent and is only employed by EnviroServ to apply for authorisation for the Holfontein Extension: IWMF. MH stated that there is a balance between providing enough technical information in the reports to authorit ies and to present the reports in such a way that the public can understand. MH asked if there is also a language barrier and asked if translations would be helpful. The general consensus was that ‘layman’s terms’ will be useful to understand, and that a ‘layman interpreter’ may assist IAPs to understand the process.

2 15 April 2014 (public meeting)

Hanre Crous of Interwaste

Concern about the relationship between both parties (Interwaste and EnviroServ) being IAPs on each other’s projects.

EG stated that it must be acknowledged that the companies are still competitors. The proximity of the current projects to each other have an impact on this relationship and will affect how much information will be shared between parties, particularly on non-public information. EG indicated that EnviroServ would have to apply its mind to the matter but the immediate answer was that only information in the public domain would be shared.

3 16 September 2014

Mike Nicholls of Interwaste

Requested a copy of an audit report by Mr Baldwin referred to in a November 2013 HMC meeting.

I do not have a copy of the audit report that you are requesting in this email train and don’t know that it has direct relevance to the EIA process for the Holfontein Extension: Integrated Waste Management Facility Project. As such your request for the audit report falls outside of my mandate as the EAP on this project.

4 19 September 2014

Mike Nicholls of Interwaste

I have requested the report to determine the level of compliance at the existing facility. I believe this to be a reasonable request when viewed in the context of the EIA application to extend, by name and nature this facility. Please request this report and the applicable ground and surface water monitoring report, with data from EnviroServ. I would also like copies of the incident reports pertaining to the f ires that are mentioned in the minutes of the HMC.

The 2010 EIA Regulations provide that registered interested and affected parties are entitled to comment on all written submissions, including draft reports, made to the competent authority by the applicant or EAP managing the application (specifically Regulation 56(1)). Regulation 56(3) details what these written submissions/reports are. With regards the authorisation process for the Holfontein Extension: Integrated Waste Management Facility Project this will include a scoping report, environmental impact assessment report and environmental management programmes. Where appropriate these documents may reference or include other reports necessary to substantiate investigations or findings of the assessment process. There is no requirement in the 2010 EIA Regulations to provide interested and affected part ies with documents other than those detailed in Regulation 56(3).

Holfontein Extension: IWMF

15 April 2014 (public meeting)

Elizabeth Khebesi

Is there enough space at the Holfontein site to accommodate all the activities? Is a certain size needed for the facilities?

MH showed the map of the Holfontein site, and showed that all of the area of the current HHWDS will be used to dispose of hazardous waste. EnviroServ need the additional 27 ha to develop the extra facilities to recycle, reuse, recover or treat waste with the proposed treatment technologies. There is enough space for all proposed facilities. Edwin Motebang (EM) added that EnviroServ already own the land.

15 April 2014 (public meeting)

Joseph Khumalo

How many years will it take to do this proposed development? How many years will it take to close the entire operation?

MH stated that they cannot start until approval is obtained. Esme Gombault (EG) stated that there are three components, hazardous waste disposal, general waste disposal and the treatment




No. Date Name Question/ Issue Raised Comment/ Response technologies. These may all run at the same time. Closure of operations depends on the volume of waste accepted at the site as well as the airspace within the landfill sites. The new Class A landfill will only be developed once the cells at the HHWDS are full. The general waste site will be developed and activated when there is a demand. The treatment technologies phase may start sooner than the other 2 phases but will be influenced by timeframes in the Waste Management regulations. The Holfontein Extension: IWMF is a long-term plan. The technologies will be offered when the legislation states that no more of particular wastes may go to landfill, and therefore, the technologies will not be developed immediately but will depend on the market need and legal requirements.


Skhumbuzo Mathebula

EnviroServ previously stated that it will take 10 – 20 years to closure but now the life of the HHWDS has been extended with the new proposal.

This depends on the airspace and the consumption rate at the site. The timeframe to closure will always depend on the consumption rate and the available airspace of the cells at the HHWDS.


Skhumbuzo Mathebula

Queries were raised concerning pilot testing at the proposed facility.

EG stated that in developing or testing new treatment technologies, small-scale tests are done in a laboratory to see if the technology can do what is required. If this is successful, then a small pilot plant will be developed at the site where they will be able to test a scaled up version of the technology. This is key to assessing the efficacy and commercial viability of the technology. If the pilot tests are successful, then EnviroServ will have the technology (and data) to build the full-scale plant at the site. The legislation currently is not sufficient to deal with pilot assessments, therefore, EnviroServ have asked the Department to approve the pilot plant area at Holfontein: IWMF to enable EnviroServ test the technologies.



Interwaste has made an application for a Class A lined site accept type 1 – 4 wastes (and perhaps treat type 0 wastes at the site if possible). The Interwaste facility is proposed to be developed adjacent to EnviroServ site and close to wetlands that are the subject to the 24G. Notwithstanding competitive matters, HC asked if the perspective of EnviroServ has changed with the two EIA running concurrently, particularly on information-sharing, support or no support, and on the appointment of, or collaboration by, specialists doing the same work at the site. Maybe the specialist assessments should be run concurrently from both parties?

EG stated that it must be acknowledged that the companies are st ill competitors. EG indicated that EnviroServ would have to apply its mind to the matter but the immediate answer was that only information in the public domain would be shared.

Licence 8 15 April 2014

(public meeting)

Mike

Nicholls of Interwaste

The name of the project includes ‘Extension’ but the only ‘extension’ is the HHWDS cells. The new 22 technologies are additions, not an extension of the site. By describing the project as an extension, EnviroServ will not adequately assess potential alternatives to the location of these activities or at facilities that already exist, such as at Chloorkop Waste to Energy and the tyre recycling facility in Cape Town.

EG stated that the current Holfontein site does not just consist of a landfill site but also of other treatment facilities as approved as part of their current authorisation and that the proposed project was indeed an “extension” of current activities.

9 15 April 2014 Mike Is the current licence that EnviroServ has a result of the PPP, a MH stated that EnviroServ has more than one licence at the HHWDS. EnviroServ are not amending




No. Date Name Question/ Issue Raised Comment/ Response (public meeting) Nicholls of

Interwaste licence review or an amendment to the current licence. the current licence(s) for the HHWDS but adding facilities to increase the treatment technologies

and disposal capacity at the site. The application is for a new licence for all facilities and operations that will occur outside of the current licensed area. ‘Extension’ is the name of the project, which refers to the extension of the facility itself, and not changes to the current licence.

Waste 10 15 April 2014

(public meeting)


There is a cell for type 1 & 2 waste and then type 1 – 4 waste because there is no longer distinction between general and hazardous waste anymore. This will become relevant particularly with the phasing of the treatment technologies and the treatment depends on the waste type. The waste type becomes relevant in terms of the liner.

The design and operation of the disposal facilities will be undertaken in terms of the relevant Regulations and Norms and Standards governing waste disposal as well as the conditions of the WML.

Holfontein Stockpiles 11 15 April 2014

(public meeting) Mike Nicholls of Interwaste

Where are the stockpiles, part of the S24G for rectification, located? What is the status of this project?

MH indicated the location and stated that the administrative fine has been paid and Synergistics is waiting for a decision on the project.


Mike


Can a further process be authorised on propert ies where there is an application for a 24G?

MH stated that he will have to check this. The answer provided by email was “It is my understanding that there is no consideration of this under Section 24O of the NEMA. It is only pending criminal investigations which may affect/delay the outcome of a 24G application(Section 24G(5)-(7)), but not the 24G application affecting/delaying outcome of a Section 24 process.”

Social Impacts 13 15 April 2014


Concerning medical waste, the community will not want to see body parts for example. How will they be able to respond to this and to raise concerns that they may have? There is a cultural and technical concern on the project, and if medical waste is going to be accepted permanently, the community may get upset.

Brian Gibson (BG) stated that he should submit comments to Synergistics with regards to this as this issue will need to be considered and addressed.


Jannie Neuhoff

EnviroServ may be able to provide employment to several people but may also cause health problems to their children, and therefore the community will need to understand this.

The project will provide some employment. The EIA process will consider the current context of the proposed location and assess whether there are any fatal flaws or high risks for the project in the proposed location. This will include consideration of the health risks to nearby communities.


Jannie Neuhoff

What contamination will occur on the crops surrounding the area?

An air quality impact assessment will be undertaken for the proposed project to assess the potential air quality issues and risks to adjacent areas and receptors.

Environmental Impacts 16 15 April 2014


What are the alternative and mitigation measures that will be implemented to reduce impacts of the Holfontein Extension: IWMF on the environment? Currently, EnviroServ disposes of waste at the HHWDS. In addition, Interwaste were here a few weeks ago giving the same presentation.

MH from Synergistics responded that the EIA process is regulated by law and the first step is to look at the direct positive and negative impacts of the project on the environment. It is also required to consider the cumulative impacts of surrounding facilities together with activities of the applicant’s project. This can be challenging because the EAP/Specialists have to obtain information to conduct the cumulative assessment but this information is not always available or accessible. As far as is possible the EIA will assess both the direct and cumulative impacts. Mitigation measures will be documented in the EIA and prescribed in an environmental management programme.




No. Date Name Question/ Issue Raised Comment/ Response


Pat Msane Air pollution and groundwater results must be presented at the next meeting.

Feedback on results of the specialist studies will be presented at a future meeting.

Cumulative Impacts 18 15 April 2014


Is the specialist study going to assess the cumulative impacts of both companies (EnviroServ and Interwaste) on the environment?

MH stated that the EIA process is regulated by law and the first step is to look at the direct positive and negative impacts of the project on the environment. It is also required to consider the cumulative impacts of surrounding facilities together with activities of the applicants project. This can be challenging because the EAP/Specialists have to obtain information to conduct the cumulative assessment but this information is not always available or accessible. As far as is possible the EIA will assess both the direct and cumulative impacts.


Pat Msane What will the cumulative impacts be of EnviroServ and Interwaste combined?

As far as is possible the EIA will assess both the direct and cumulative impacts.


Francois Neuhoff

Will the Casino in Mpumalanga be considered in the assessment?

MH stated that Synergistics will have to consider the casino because it is in close proximity to the Holfontein site and so will have to be included in the assessment process. EG added that EnviroServ has already communicated with the casino with regards to EnviroServ’s buffer zones and activities and have invited them to join the HMC.

Location and Alternatives


Mike


Will alternatives be assessed in depth? MH stated that there are restrictions on site locality but that alternatives will be assessed as appropriate. Alternatives will be assessed as part of the EIA process, as those that are reasonable or feasible.


Jannie Neuhoff

Is this the correct placement of the site? It have been in the past but now, with the expansion of the adjacent communities, it may not be. It may be a good idea to compare past and current conditions with expansion and developments of communities surrounding the Holfontein Extension: IWMF.

The EIA process will consider the current context of the proposed location and assess whether there are any fatal flaws or high risks for the project in the proposed location.

Air Quality 23 15 April 2014

(public meeting)

Jannie Neuhoff

Air quality has not been adequately addressed. Air quality impact assessments have been done for the current site and air quality is monitored at on and off-site locations. Results are regularly reported to the HMC. Additional air quality impact assessment will be undertaken for the proposed project to assess the potential air quality issues.

Groundwater 24 15 April 2014

(public meeting)

Jannie Neuhoff

If EnviroServ and the surrounding companies contaminate their groundwater, what is the solution? Farmers are reliant on groundwater for farming, and so where will they get replacement groundwater from? Do they have to go to court to sort such issues out?

The NEMA dictates a ‘duty of care’ and the ‘polluter pays’ principle. If contamination is caused then alternatives will have to be provided by the party responsible. Baseline and on-going monitoring are undertaken where there are risks to detect contamination and determine responsibility. The law of the land would have to be applied if there was a dispute between parties.

Environmental Responsibility 25 15 April 2014

(public meeting)

Jannie Neuhoff

If something goes wrong at the site, who is responsible? For example, if there is a problem with a waste stream that they cannot dispose of at a site, it will pile up outside of that site and

The NEMA dictates a ‘duty of care’ and the ‘polluter pays’ principle. The NEMWA places responsibilities on waste generators, waste transporters and waste managers. The ‘green scorpions’ are very active in the waste management sphere and regularly assess




No. Date Name Question/ Issue Raised Comment/ Response become a hazard. What happens if the commitments never happen? The policing is important because EnviroServ should not take him as an ignorant farmer who is unable to understand what the issues are at the site. These assessments take years and even then one sometimes only finds out years later what the negative impacts are.

compliance of operations against the licence conditions. Any assessment makes use of the best available information at the time. It is acknowledged that the state of knowledge changes over time and things which were previously acceptable may not be in future times. NEMA advocates a ‘risk averse and cautious approach’ as a principle in order to take into account the limits of current knowledge.

Specialists 26 15 April 2014

(public meeting) Francois Neuhoff

Will the public have a say in what specialists are chosen to do the different studies?

MH stated that environmental assessment practitioner normally nominates specialists who they are comfortable working with. IAPs will be informed who the specialists are but if IAPs have a particular objection to the specialist, then they should say so and another specialist can be considered. IAPs can also recommend specialist studies and if these studies are relevant, then these can be considered in the process. Also, if findings of a particular specialist are controversial then these assessments can be peer reviewed by another specialist.

HHWDS and contamination of the H:IWMF site 27 16 September

2014

Mike


I am concerned that it is likely that the land which is now subject to this EIA has already become contaminated or can reasonably be expected to be contaminated from the historic activities at the existing Holfontein Hazardous WDS. The Google image from Feb 2005 attached has reference; It appears that leachate has overflowed the containment dam and flowed across the (now excavated and stockpiled) site into the adjacent wetland which is now the subject of the 24G application. Not only this but if the now stockpiled soil had become contaminated by for instance overflowing leachate, storage of contaminated containers, fugitive wastes from the WDS etc., this would lead to further contamination of the site.

I note your concern of the alleged contamination of the soil and clay stockpile and the possible risk that this could pose. This will be documented in the scoping report for the Holfontein Extension: Integrated Waste Management Facility and investigated as appropriate.

16 September 2014

Mike


In addition, how would the EIA process be affected should the Minister issue a written notice to EnviroServ identifying this land as an investigation area ? Would the investigation then form part of the public process or would the EIA be suspended subject to the outcome of the investigation ?

I don’t believe that the EIA process would be affected by a contamination assessment under part 8 of the NEMWA as these are regulated by a separate parts of the Act.

1 October 2014 Mike


I note that section 8 of the attached minutes of the HMC, 18 March 2014 refers to the overflow of storm water containment dams into off site dams; The attached photo taken on the 16th of April, approximately a month later and after further heaving rains appears to indicate that contaminated storm water has flowed through the affected wetland system and into the off-site dam which itself appears contaminated. Please confirm whether fugitive storm water did at any time flow through the soil and clay stockpiles. Were

Thank you for bringing the storm water incident to my attention. As indicated in my previous email, I will be investigating the alleged contamination of the soil and clay stockpile and the soils on-site and the possible risk that this could pose during the course of the assessment for the Holfontein Extension: Integrated Waste Management Facility. As far as I am aware EnviroServ reports all incidents to the authorities in terms of the requirements of their licence and the legislation. I am not currently aware of any criminal investigation relating to the site for the Holfontein




No. Date Name Question/ Issue Raised Comment/ Response there further incidences of fugitive storm water over this period and if so were these reported to the Department ? If the fugitive storm water did indeed f low through the soil and clay stockpiles one can reasonably assume that they would as a consequence be contaminated. Once contaminated and either requiring treatment or disposal as a result they would de facto be considered to be waste and this would trigger a fresh 24G application under NEMWA. Please confirm if there is a criminal investigation currently underway which in any way pertains to the affected site as I understand that such an investigation may delay the outcome of the 24G process that is already underway. Am I right in assuming that a criminal investigation could also delay an EIA process ?

Extension: Integrated Waste Management Facility.




8. Anticipated Environmental Impacts

A scoping-level identification of environmental impacts (physical, biological, social and economic) associated with the operation of the Holfontein Extension:

IWMF are listed in the table below. These impacts will be assessed in detail during the EIA phase. Also included in the table are the requirements for further

investigation during the EIA phase. Details of the scope of work to be undertaken during the EIA phase, including the specialist studies listed below, are

provided in the Plan of study for EIA, presented in Section 9.

Where appropriate the impacts that may result from construction have been identified and considered separately.

Table 8-1: Preliminary identification of potential environmental impacts for the Holfontein Extension: IWMF

*C = construction; O = operation.

IMPACT PHASE*

IMPACT SOURCE FRAMEWORK FOR TASKS TO BE UNDERTAKEN

DURING THE EIA PHASE

TOPOGRAPHY

• Alteration of the local topography C • Cut and levelling for construction.

• Backfilling of quarries.

• Impact likely to be of very low significance. No

investigation considered necessary.

O • Development of waste bodies • Design of waste body profile to consider need for a

final shape that is the least visually intrusive.

VISUAL + LANDSCAPE CHARACTER

• Addition of visual elements resulting in

change to landscape character

C • Removal of vegetation.

• Establishment of buildings and facilities


• Visual Impact Assessment to predict changes to the viewshed from key sensitive receptors.

• Design of waste body profile and final cover to

consider need for a final shape that is the least visually intrusive.

• Consider the visual intrusiveness and alteration in

landscape at day and night

O • Development of waste bodies.

• Dispersal of waste in wind

• Odours from the facility.

• Operation of landfill site, dust emissions and heavy vehicle traffic.

• Industrial infrastructure including buildings and stacks.

• Change to night time views and character.

O • Lighting required to facilitate operations and security at the facility.

ZONING + LAND USE

• Conversion of land with agricultural potential to built facilities and waste

C • Removal of vegetation. • Assessment of agricultural potential to determine potential loss.




IMPACT PHASE*



bodies. • Stripping of soil.

• Establishment of buildings, facilities and landfills

• Soil stripping plan to ensure maximal soil recovery.

• Restriction on zoning and use of land within buffer zone required for facility.

O • Undertaking of waste management activities/emissions that pose a health risk and require a buffer zone for the protection of human health.

• Interaction of buffer zones of various facilities influencing

larger area.

• Air Quality Impact Assessment to assess health risks and determine extent of required buffer zone and permissible land uses.

• Comparative assessment of current land use and

zoning with buffer zone requirements.

• End-use planning to be considered in the context of regional development.

CLIMATE

• Emissions of landfill gas and combustion products with global warming potential

O • Emissions of greenhouse gases from facility (landfill gas as well as plant emissions).

• Air Quality Impact Assessment to quantify potential greenhouse gas emissions.

• Plant design and emissions controls to ensure

minimum emissions.

AIR QUALITY

• Increase in local dust fall levels resulting

in nuisance at receptors

C • Entrainment by heavy vehicles driving over disturbed

surfaces.

• Wind-blown dust from disturbed areas where vegetation is removed and off material stockpiles


• Air Quality Impact Assessment to compile emissions inventory to identify sources; undertake modelling to predict emissions and estimate dispersion plumes for dustfall, particulates and criteria air pollutants.

• Operations methods and emissions controls to


O • As above, plus windblown dust from operational areas of

landfill.

• Wind-blown dust from waste body.

• Particulate emissions from material handling.

• Particulate emissions from plant stacks.

• Air Quality Impact Assessment to be structured per

phase.

• Increase in odours at receptors O • Decomposition of waste resulting in the emission of landfill

gas – in particular the odourous components

• Storage, handling, treatment and disposal of wastes and leachate with strong chemical odours.

• Operation of plants, particularly those with thermal or


• Air Quality Impact Assessment to assess potential for odour generating activities and to consider dispersion of such gases to receptors.

• Operations methods and emissions controls to




IMPACT PHASE*



biological processes resulting in the emissions of odorous

gases.


• Increase in gaseous emissions O • Storage, handling, treatment and disposal of wastes that result in gaseous emissions.

• Operation of plants, particularly those with thermal or

biological processes, resulting in the emission of gases.

• Air Quality Impact Assessment to compile emissions inventory to identify sources; undertake modelling to predict emissions and estimate dispersion plumes for dustfall, particulates and criteria air pollutants.

• Plant design and emissions controls to ensure emissions comply with standards or better.

• Increase in ambient levels of criteria air

pollutants at receptors

O • All processes and plants that result in gaseous emissions of

criteria air pollutants.

• Air Quality Impact Assessment to assess emissions

of criteria air pollutants against legislated limits.

• Plant design and emissions controls to ensure emissions comply with standards or better.

• Health risks to nearby receptors from

inhalable particulates and or pollutants

O • Direct and cumulative risk to health (carcinogenic and non-

carcinogenic) to nearby receptors from site emissions.


• Air Quality Impact Assessment to compare modelling and dispersion results against legislated and best

practice limits to assess health risks to key receptors.

NOISE

• Increase in noise levels at receptors C & O • Heavy vehicles and machinery.

• Material handling operations

• Operations of plant with mechanical or steam processes


• Opinion from Noise specialist on potential change in

ambient noise levels. Upgrade to an impact assessment if issues are identified.

HYDROLOGY

• Increase in runoff and erosion from the

site

C • Removal of vegetation and alteration of surface profile.

• Increased flow velocities over unprotected soils.

• Hydrological assessment to consider potential risks

during construction.

• Management of storm water during construction.

• Increase in sediment loads to the

watercourse

C • Vegetation removal and soil striping.

• Increased flow velocities over unprotected soils. • Management of storm water during construction.

• Reduction in surface water quality in the watercourse/resource

C

• Sediments dispersed from site

• Pollutants from construction machinery as well as materials,

fuels and chemicals used and stored on site.

• Release of contaminants that may be in the soils across the

site during the disturbance or use of these soils.

• Management of materials, fuels and chemicals to minimise risks of contamination.





IMPACT PHASE*



O • Rainwater coming into contact with waste.

• Rainwater coming into contact with materials, fuels and

chemicals.

• Spillage of dirty storm water or leachate from site.


• Sediments on vehicle wheels.

• Dirty water from plant processes.

• Hydrological assessment to consider potential risks

during operations.

• Calculation of hydrological parameters of affected

catchments and floodlines of affected watercourses

• Design of facilities dealing with wastes, materials, fuels and chemicals to minimise risks of contamination.

• Designs of storm water facilities to ensure diversion,

containment of volumes from maximum expected precipitation in 1: 50 year event.

O • Discharge of treated effluents •

• Alteration of flow paths, beds and banks of watercourse

C • Levelling of sites for construction.

• Construction of facilities within or adjacent to watercourse.

• Increased flow velocities over unprotected soils or altered profiles.

• Layout designed to avoid watercourses.


• Reduction in runoff volumes to the

catchment

O • Containment of dirty storm water on site.

• Diversion of runoff water to different areas of the catchment.

• Designs of storm water facilities to ensure maximum

diversion of clean storm water to the environment.

• Return of storm water to be done with minimum

disturbance to natural flow patterns.

• Alteration of flow to and in the watercourse

O • Additional hard surfaces increasing runoff over infiltration.

• Diversion of clean storm water and its reintroduction at points

different from natural.

• Return of storm water to be done with minimum disturbance to natural flow patterns.

SOILS + GEOLOGY

• Loss of topsoil from the site C • Removal of vegetation.


• Erosion and sedimentation by surface water flows.

• Establishment of buildings, facilities and landfills over soils.

• Soils assessment to determine type and depths of

soils across site.

• Assessment of agricultural potential.

• Salvaging of all useable topsoil.

• Loss of clay mineral resource from the site

C • Establishment of buildings, facilities and landfills over mineral resources – particularly clay.

• Soils assessment to identify clay resources that could be used for specific purpose.

• Salvaging of all useable clay.

GROUNDWATER:

• Reduction in infiltration to groundwater

from the site

O • Additional hard surfaces increasing runoff over infiltration. • Impact likely to be of very low significance. No

investigation considered necessary.




IMPACT PHASE*



• Reduction in groundwater quality O • Contaminated surface water infiltrating to groundwater

• Leachate from waste cells infiltrating to groundwater.

• Seepage from leachate and storm water dams infiltrating to groundwater.

• Specialist hydrogeological impact assessment to

determine the contaminant sources, model the dispersion plume and assess impacts on groundwater quality.

• Conceptual design of landfill and dam liners and

protective measures in terms of Norms and Standards.

• Alteration in groundwater flow and

change in seepage contribution to site wetlands

O • Surface water infrastructure, waste bodies altering flow of

shallow groundwater


determine the contribution of groundwater seepage top the wetlands and to determine the likely impacts on wetlands hydrological regime.

• Reduced suitability of water for other users in the region

O • Dispersion of contaminants and reduction in groundwater quality influencing other users.



model the dispersion plume and assess impacts on identified receptors.

BIODIVERSITY: TERRESTRIAL

• Loss of natural habitat of conservation

importance from the site

C • Removal of vegetation.



• Ecological study to confirm status of site and validity

of conservation importance of the habitat.

• Site layout designed to avoid areas of high conservation importance.

• Reduction in connectivity of remnant habitat patches

C • As above in key patches connecting habitat patches • Ecological study to confirm status of site and validity of conservation importance of the habitat.

• Site layout designed to aid connectivity post

development.

• Loss of faunal species of conservation concern from the site

C • Direct disturbances causing loss of habitat.

• Indirect disturbances reducing suitability of habitat to

sensitive species

• Ecological study to confirm Presence/Absence of faunal species of conservation concern likely to occur.

• Loss of floral species of conservation concern from the site

C • Direct disturbances causing loss of habitat and destruction of individual specimens of conservation concern.

• Ecological study to confirm Presence/Absence of floral species of conservation concern likely to occur.

BIODIVERSITY: FRESHWATER ECOSYSTEMS

• Loss of wetland habitat from the site C • Removal of vegetation and establishment of buildings, facilities and landfills over wetlands.

• Reduction in inflows to wetland habitat.

• Wetland assessment to delineate wetlands on and within 100m of the site.

• Site layout designed to avoid wetlands where

possible.




IMPACT PHASE*



• Project to consider commitments to wetland

rehabilitation.

• Decline in PES or EIS of remaining

wetlands

C & O • Sediments in surface water flows.

• Contaminants (waste/ fuels and chemicals/ leachate) in surface water flows.


• Discharge of treated effluents.

• Alteration of volume of surface and ground water in flows to

wetlands.

• Wetland assessment to assess wetland status on

and within 100m of the site. Also to consider the likely impacts on the wetland in light of the proposed development plan.

CULTURE + HERITAGE

• Destruction of heritage resources on the

site

C • Stripping and backfilling for levelling


• Heritage assessment to determine presence of any

resources.

• Conflict with cultural beliefs O • Receipt, treatment and disposal of HCRW may conflict with cultural beliefs of indigent communities.


• Social assessment to consider the implications of the

social concerns over anatomical wastes.

TRAFFIC

• Reduction in road safety C & O • Increased volume of heavy vehicles on the access roads.

• High risk nature of the loads of hazardous waste on the vehicles.

• Traffic Impact Assessment to assess the potential

change in vehicle volumes and the likely impacts on congestion and road safety.

• Increased wear and tear on road

Infrastructure

C&O • Increased volume of heavy vehicles on the access roads. • Traffic Impact Assessment to consider the suitability

of the access roads and intersections for the potential traffic load. Make recommendations on upgrades to infrastructure.

SOCIAL & ECONOMIC ENVIRONMENT

• Employment creation (positive) C & O • Construction, fabrication and installation of plants and

facilities.

• Delivery of construction materials and wastes to the site.

• Operation of the plants and facilities.

• Social plan for the facility to ensure maximum benefit

to local communities and business.

• Skills development and training (positive)

C & O • Training of employees to operate plants and perform duties better.

• Project to consider commitments to skills development and training.

• Economic opportunities in supply, fabrication, construction (positive)

C • Sourcing of materials, • Social plan for the facility to ensure maximum benefit to local communities and business.




IMPACT PHASE*



• Health risks to employees C & O • Occupational exposure to health risk substances during

handling, treatment and disposal of wastes that result in health risks.

• Project to be developed in line with Occupational

Health and Safety Act. Not considered further in the EIA.

• Nuisance impacts to neighbours which

affect quality of life

O • Cumulative impacts on quality of life from noise, visual,

odour, dust and air quality impacts.

• All specialist assessments to identify and consider

impacts to sensitive receptors.

• Assessment to consider cumulative effects of the various aspects on key receptors.

• Identify measures to safeguard neighbours and

landowners from project risks

• Health risks to neighbouring

communities.

O • Dispersion of health risk substances beyond the site

boundaries to public receptors in quantities that result in health risks.


• Specialist assessments, in particular air quality, to identify and assess health risks to sensitive receptors.

• Design of facilities to minimise risks of contamination

and public health risks.

• Buffer zone to be based on the maximum, cumulative

health risk.

• Perceived impacts on property values O • Establishment of waste management facilities altering perception of area and influencing property values.

• Buffer zone restrictions influencing future land use with

resultant influence on values.

• Socio Economic assessment to assess current property values and consider influences on future values.

WASTE MANAGEMENT

• Implementation of the waste

management hierarchy to obtain the most sustainable result from waste streams (positive)

O • Multiple facilities at a single site allow for waste streams to be

managed at the plant (s) where the maximum benefit can be obtained from the waste such that the smallest fraction becomes residual waste requiring disposal.

• Having the various plants located at a single site reduces transport costs and risks.

• Ensure an integrated facility that can derive the

maximum sustainable benefit from target waste streams

• Legal disposal of waste to managed

facility (positive)

O • Disposal of residual waste to a designed facility, operated in

terms of license conditions.

• Ability to comply with future restrictions on disposal of waste.

• Disposal sites designed in terms of the Norms and

Standards.

• Disposal sites operated in terms of licence

conditions.

• • •




Mitigation measures for all of the impacts identified will be included in the draft Environmental

Management Programme.




9. Plan of Study for Environmental Impact Assessment

This Plan of Study describes how the EIA phase of the environmental assessment for the Holfontein

Extension: IWMF will proceed. The Plan of Study includes a description of EIA process and tasks,

specialist studies and consultation to be undertaken during the EIA phase. The Plan of Study presents

a proposed impact assessment methodology and impact assessment and rating criteria. This Plan of

Study has been developed to meet the requirements as set out in section 28(n) of the EIA Regulations.

The nature and extent of the further environmental studies and assessments required during the EIA

phase have been identified through consultation with the authorities, the responses received from

interested and affected parties and input from relevant specialists. The proposed specialist studies and

their respective scopes of work are described in the following sections.

9.1 EIA Process

This EIA will address potential impacts and benefits of the Holfontein Extension: IWMF on the bio-

physical and social environment. Impacts, direct, indirect and cumulative, associated with the project

and all its phases will be assessed. The EIA will also aim to identify appropriate mitigation and

management measures for the significant impacts.

This EIA assessment process has been developed to ensure that it complies with GNR 543 Section 26

to 33 and the associated guidelines. The proposed EIA process and public consultation activities are

illustrated below, with specific reference to the opportunities for consultation and participation for IAPs,

Competent Authorities, and relevant State Departments and Organs of State.

Table 9-1: Simplified EIA Process with Explanation of Opportunities for Consultation and Participation in the EIA Process



Project

Announcement and

Application Phase

Review

Baseline Data

DEA & GDARD

Nov 2013 to Feb 2014

Advertisements and project notifications to potential

IAPs and commenting authorities. Public information meeting

March 2014

April 2014

Scoping Phase DSR to authorities. Review of DSR (40 days, ±6 weeks).

July - August 2014 Focused consultation with authorities if

required. Focused consultation with IAPs or commenting

authorities if required.

Final scoping report to authorities Review and acceptance of final scoping

report (30 days).

Review of final scoping report (21 days, ±3 weeks). September 2014

EIA

Phase

Input

and

Asses Submit draft EIA report to authorities.

Review of draft EIA report (60 days, ±8 weeks). Oct – Nov 2014






Meetings with authorities during EIA if required. Public Feedback Meeting.


Authority review and

Authorisation Phase

Final EIA report to DEA & GDARD. Review of final EIA report (21 days, ±3 weeks).

Dec 2014 – Jan 2015

Authorities Acceptance of EIA report (60 days).

Application Accepted / Refused (45 days). Waste Management Licence &

Environmental Authorisation Granted / Refused (45 days).

Feb - Mar 2015

Notifications to IAPs regarding environmental

authorisation (granted or refused).

Appeal Phase Consultation during processing of appeal if

relevant. Consultants to provide guidance regarding the

appeal process as and when required. variable

9.2 Development Alternatives to be Investigated in the EIA Phase

The EIA will assess alternatives that are both feasible and reasonable in providing a different means of

achieving the same general purpose and requirements of the Holfontein Extension: IWMF.

Locality 9.2.1

For reasons explained in this report (see Section 4.5.1), no locality alternatives will be investigated in

any detail in the EIA.

Activity Type 9.2.2

Additional activity types are not proposed for investigation in the EIA. However, the EIA will consider

each of the proposed activities individually and cumulatively and the assessment may indicate that

certain of the proposed activities are more appropriate or favourable than others.

Layout and Design 9.2.3

Further iterations to the layout and designs will be presented and assessed through the course of the

EIA process. The updates will be informed by information derived from the specialist investigations as

these uncover more accurate information relating to the site.

Technology 9.2.4

The EIA will consider each of the proposed technologies individually and cumulatively and the

assessment may indicate that certain of the technologies are more appropriate or favourable than

others.




No-go Development Alternative 9.2.5

Consequences of the no-go development alternative will be fully assessed in the EIA. This scenario

assumes an unsuccessful application whereby a waste management licence and other authorisations

are not obtained and the Holfontein Extension: IWMF not constructed.

9.3 Environmental Impact Assessment Methodology

The identification and assessment of environmental impacts is a multi-faceted process, using a

combination of quantitative and qualitative descriptions and evaluations. It involves applying scientific

measurements and professional judgement to determine the significance of environmental impacts

associated with the proposed project. The process involves consideration of, inter alia: the purpose and

need for the project; views and concerns of interested and affected parties; social and political norms,

and general public interest.

The methodology used for assessing impacts associated with the proposed project follows the

philosophy of environmental impact assessments, as described in the booklet Impact Significance,

Integrated Environmental Management Information Series 5 (DEAT, 2002b). The generic criteria and

systematic approach that will be used to identify, describe and assess impacts are outlined below.

Identification and Description of Impacts 9.3.1

For each environmental component (i.e. visual, air quality, biodiversity, etc.), impacts will be identified

and described in terms of the nature of the impact, compliance with legislation and accepted standards,

receptor sensitivity and the significance of the predicted environmental change.

9.3.1.1 Current Impacts (Impacts of Existing Developments)

Considering that the project is closely linked to an existing facility with built infrastructure and on-going

operations, the baseline environment may be altered to a less than natural state. In order to explain the

environmental context of the facility, a general assessment of the current impacts at the site will be

provided.

The EIA will consider the current levels of environmental degradation at a defined date and will draw on

existing information from previous assessments. Definition of the current level of degradation

associated with existing developments is essential to understand and enable the assessment of

cumulative impacts.




9.3.1.2 Incremental Impacts (Direct project impacts)

A detailed assessment of the impacts arising directly from the activities proposed for the Holfontein

Extension: IWMF will be undertaken. Incremental impacts will either constitute a new impact at the site

or may alter an existing impact.

9.3.1.3 Cumulative Impacts (Total Impacts)

In assessing the potential impacts arising from the proposed Holfontein Extension: IWMF, cognisance

will be given to the total cumulative impacts, such as, the sum of the existing impacts from current

operations at the HHWDS and surrounding activities plus the incremental impacts anticipated to arise

from the development and operation of the proposed Holfontein Extension: IWMF.

Existing Impacts + Incremental

Impacts

= Cumulative Impacts

Existing impacts

(current level of degradation) associated

with existing developments and

developments under construction

Impacts of the proposed

Chloorkop MSWtE

Project

Existing impacts

(current level of degradation) associated

with existing developments and

developments under construction

combined with the impacts of the

proposed Chloorkop MSWtE Project

Where practical and possible, the assessment will consider the cumulative impacts of the project in

combination with the potential direct impacts of the proposed Amadawala Integrated Waste

Management Facility. This can only be achieved if adequate information on the proposed facility and

the impacts thereof is available in the public domain.

Evaluation of Impacts and Mitigation Measures 9.3.2

The significance of environmental impacts will be rated before and after the implementation of

mitigation measures. These mitigation measures may be existing measures or additional measures that

may arise from the impact assessment and specialist input. The impact rating system considers the

confidence level that can be placed on the successful implementation of the mitigation. The system

used for evaluating impact significance and mitigation failure risks is explained in the table below.

Table 9-2: Impact Rating Criteria and Assessment Process

Impact Rating Criteria (Abbreviation / Symbol / Short Description)

Explanation of Impact Rating Criteria and Assessment Process

Nature of the Environmental Impact Brief description of the effect of human actions and activities on the

environment, and impacts of the environment on development.

Draft Environmental Management Measures designed to avoid, reduce or remedy adverse potential negative






Programme Mitigation Measures impacts, and compensate for residual impacts (mitigation measures), and

measures designed to expand and augment the effect of potential positive impacts (enhancement measures) for consideration during development of the final environmental management programme.

Project Phase

P Planning Activities, impacts and mitigation measures during the planning (or pre-implementation) phase.

C Construction Activities, impacts and mitigation measures applicable to the construction phase, including decommissioning of existing infrastructure.

O Operational Activities, impacts and mitigation measures applicable to the operational phase.

D Decommissioning Activities, impacts and mitigation measures applicable to decommissioning of the project (closure, removal, rehabilitation).

Impact Status

Negative Impacts with a potential negative / adverse effect.

Neutral Neutral, no impact.

Positive Impacts with a potential positive / beneficial effect.

Assessment Confidence

Complete No information gaps exist. Decision-making can go ahead.

Adequate Minor information deficiencies exist but this does not affect decision-making. Decision-making can go ahead.

Incomplete Not enough information for decision-making. Current data to be supplemented with further monitoring or research.

Consequence (C) (Severity + Extent)

Severity (S) (Intensity + Duration + Frequency)

Intensity (

Ne

gativ

e I

mpa

cts)

1 low

Slight change, disturbance or nuisance. Targets, limits and thresholds of concern never exceeded. Impacts are rapidly and easily reversible. Require no or only minor interventions or clean-up actions if these impacts occur. No complaints expected when the impact takes place.

2 moderate

Moderate change, disturbance or discomfort. Real but not substantial. Targets, limits and thresholds of concern may occasionally be exceeded. Impacts are

reversible but may require some effort, cost and time. Sporadic complaints can be expected when the impact takes place.

3 high Prominent change, disturbance or degradation. Real and substantial. May result in illness or injury. Targets, limits and thresholds of concern regularly exceeded. Regular complaints can be expected when the impact takes place.

4 very high

Severe change, disturbance or degradation. May result in illness, injury or death. Targets, limits and thresholds of concern continually exceeded. Interest group / community mobilisation against project can be expected when the impact takes place. May result in legal action if impact occurs.

Intensity (I)

(Pos

itive

Im

pact

s) 1 low Slight change or improvement. Minor benefits.

2 moderate Moderate change or improvement. Real but not substantial benefits.

3 high Prominent change or improvement. Real and substantial benefits. General community support.

4 very high Considerable and large-scale change or improvement. Real and considerable benefit. Widespread support.

Duration (D)

Refers to the total length of time (i.e. number of months or years) that the impact would or the impact source or risk will be present.

1 low Short-term. May occur for weeks or a few months and are rapidly reversible.

2 moderate Medium-term. May occur for the first few years of the project, during construction, up to three years. Impacts reversible within a three year period.

3 high Long-term. May occur throughout the life of the mine, but will cease after operations ceases either because of natural processes or human intervention.

4 very high Permanent and irreversible. Residual impacts will remain after decommissioning and closure

Frequen

cy (F)

Refers to the time intervals and how often (i.e. number of days per year) the impact would manifest over

the entire duration of the impact.

1 low Seldom. Impact would be intermitted, limited to a few days a year (occurs 0-10






% of the time).

2 moderate Occasional. Impact would occur now and again, not more than ten days a month (occurs 10 to 35% of the time).

3 high Often. Impact would be present more than ten days a month (occurs >35% of the time).

4 very high Continuous. Impact would occur all the time (occurs 100% of the time).

Extent / Scale (E)

0 none None. Impact will not occur anywhere.

1 low Site impact. Small area. No sensitive receptors outside servitude / project area affected.

2 moderate Local. May affect immediate neighbours, never nearby townships. Small area or small number of sensitive receptors affected.

3 high Widespread impact. Large area or large numbers of sensitive receptors affected. May affect nearby townships.

4 very high National or international impact. Impacts over a vast area or over vast numbers of receptors.

Probability (P)

0 none Never (0 % likelihood).

1 low Conceivable. Will only happen in exceptional circumstances (<10 % likelihood).

2 moderate Plausible. Could happen and has occurred here or elsewhere (11 to 40 % likelihood).

3 high Probable (>40-80 % likelihood).

4 very high Expected. Highly likely to happen (>80 % likelihood).

Significance (S)

(Consequence + Probability)

Impact significance represents the degree to which the impact may cause irreplaceable loss of a resource

Neg Very High Widespread negative effect. Negative impact that is of the highest order.

Potential fatal flaw. Unacceptable impact / loss of a resource will occur.

Neg High Substantial negative impact.

Neg Moderate Negative impact that is real but not substantial.

Neg Low Low to negligible negative impact with little real effect.

Pos Low Low to insignificant positive impact.

Pos Moderate Positive impact that is real but not substantial.

Pos High Substantial positive impact.

Pos Very High Widespread/substantial beneficial effect. Alternative ways to achieve same benefits not possible.

Mitigation

Failure Risk (FR)

Used to determine the degree to which impacts can be reversed and to calculate residual impacts.

The likelihood of mitigation failure rated based on:

- research and technology limitations,

- long implementation timeframes with associated potential of internal (i.e. personnel changes, project

ownership changes, changing financial situation) and outside (i.e. climate change, economic and political instability) influences occurring over time,

- financial considerations,

- skills and labour availability and potential for human error.

0.1 Very Low Risk Less than 10% likelihood that mitigation measures could fail. Mitigation implemented quickly, mitigation easy to implement, proven technology used, no special labour skills required.

0.2 Low Risk 10-30% likelihood that mitigation measures could fail.

0.4 Moderate Risk >30 to 60% likelihood that mitigation measures could fail.

0.8 High Risk >60 to 80% likelihood that mitigation measures could fail.

1.0 Very High Risk

>80% likelihood that mitigation measures could fail. May need research and new technologies to be developed, and/or may have to take place over many years after closure, and/or may involve exorbitant/prohibitive expenses to implement successfully, and/or may require highly skilled personnel with special training, and/or have a high risk of human error during the execution of the






mitigation. Formula Example Rating Criteria

Impact Rating Methodology

(used to determine both Unmitigated

Impacts and M

itigated Impacts)

I 1.0 Intensity (I)

D 1.0 Duration (D)

F 1.0 Frequency (F)

S=(I+D+F)/3 1.0

Severity (S) = (Intensity + Duration + Frequency) / 3

E 4.0 Scale (Extent) (E)

C=(S+E)/2 2.5 Consequence (C) = (Severity + Extent) / 2

P 3.0 Probability (P).

S1=(C+P)/2

2.7 Significance (S1) = (Consequence + Probability) / 2

FR 0.4 Mitigation failure risk (FR)

RR =S1 x FR

1.35 Residual Risk (RR). Represents a mitigated impact, adapted based on mitigation failure risk.

Formula Level Level

Impact Rating

<= -3.6 Neg Very High

<= -3.0 Neg High

<= -2.0 Neg Moderate

< 0.0 Neg Low

> 0.0 Pos Low

>= 2.0 Pos Moderate

>= 3.0 Pos High

>= 3.6 Pos Very High

Project Phases 9.3.3

Impacts will be considered across the project phases where there is likely to be significantly different

impact between the phases. This could include construction, operations, decommissioning and closure.




9.4 Specialist Studies

Significant information on the environmental conditions at the Holfontein Extension: IWMF site is

available from the investigations that have been conducted for various projects at the HHWDS. In

addition intensive monitoring of a number of different environmental aspects at the site has resulted in a

detailed information database being available. However, the nature of the Holfontein Extension: IWMF

project is such that additional specialist inputs are required in order to provide sufficient information to

complete the EIA. The following terms of reference outline the scope of work based on the outcomes of

the scoping assessment as well as the issues raised by IAPs during the scoping phase, and will be

carried out by each specialist in order to provide input into the EIA. Specialist reports will be structured

in terms of GNR 543 Section 32.

Should it be deemed necessary that additional specialist studies are required; terms of reference will be

drawn up and these will then be included in the EIA report.

Visual assessment 9.4.1

The objectives of the visual assessment will be to determine the baseline and current visual context of

the site and to identify visual receptor groups whom may be influenced by the project. The assessment

will identify the visible components of the project, assess visual impacts, define the sources of such

impacts and investigate potential methods to mitigate these impacts. The assessment will map the

baseline visual resources and the receptors and use photographic assessment and viewshed analysis

to assess the impacts. Recommendations on methods to mitigate the potential impacts will be made.

Soils and agricultural potential assessment 9.4.2

A specialist will be appointed to undertake the classification and mapping of soils across the site at a

scale of 1: 10 000. The work will aim to determine the type of soils, the effective soil depth, the

erodibility index and the agricultural potential of these. Standard methods and techniques will be

applied for the fieldwork on an appropriate grid. The key properties of the representative soil forms will

be describe in terms of the Taxonomical Soil Classification System of South Africa. The mapping will

also document agricultural potential and the current land use. The specialist will be tasked to identify

any areas with clay mineralogy that constitutes material suitable for construction and use in landfill

liners.

The specialist will also need to review the chemical composition of the soil samples to assess these for

potential contamination that may have arisen from the HHWDS. If any significant contamination is

identified then the scope will need to be expanded to ensure understanding of the contamination and

compliance with part 8 of the NEMWA.




The specialist will identify the potential impacts of the project on the known soils and agricultural

potential of the site and propose possible measures to mitigate key impacts. This will include

estimations of volume of soils available and contributions to a differentiated soil utilisation guideline to

inform construction as well as rehabilitation.

Air Quality Impact Assessment 9.4.3

A specialist will be appointed to undertake an air quality impact assessment for the Holfontein

Extension: IWMF. The main focus of the air quality assessment will be to determine the air pollutants

resulting from the project activities and the resultant impacts thereof on the surrounding environmental

and human health. The scope of work will include:

• Baseline characterisation to define the emissions and impacts from the current operations at

HHWDS;

• Review of applicable air quality legislation, policies, standards and guidelines.

• Identification of sensitive receptors.

• Sourcing of meteorological data and characterisation of the ambient air quality

• Compile an emissions inventory for the project.

o Identify and distinguish all emissions sources (physical and chemical properties)

• Identify the change in emissions due to the project.

• Perform dispersion modelling for construction and operation of the activities, plants and landfills.

o Assess a number of different scenarios to consider the most likely and worst cases.

• Predict SO2, NO2, CO, dust fallout and fine particulate (PM10 and PM2.5) concentrations.

• Predict concentrations of other criteria air pollutants for the listed activities being applied for.

• Compare predicted emissions to NAAQS Standards and provide guidance on efficacy of

emissions control equipment.

• Calculate greenhouse gas CO2(e) emissions from MSWtE plant.

• Define dust nuisance (dust fallout) zones.

• Determine odour impact zones.

• Undertake a health risk assessment and identify potential health impact areas.

• Define air quality buffer and management zones around the site (minimum distances to

sensitive receptors).

• Propose emissions and dust control measures for construction and operation of the project.

• Identification of any changes and or additions to the Air Quality Management Plan for the site

that may be required.

• Completion of the application forms for the Atmospheric Emissions Licensing.

The air quality impact assessment will provide important feedback to the design team on the

effectiveness of the operational and emissions controls proposed for the plants and activities. If the

predicted emissions limits are exceeded then additional operational and emissions controls will be

investigated and added to the design specification as required.




Noise assessment 9.4.4

A full noise impact assessment is not proposed as the Holfontein Extension: IWMF site is not located

near to any significant noise sensitive receptors. A specialist may be appointed to provide an opinion

on the potential for noise from the project to create a nuisance or disturbance to any receptors. The

specialist will be provided with design information and available noise survey information reflecting the

current baseline at the HHWDS.

If the specialist is of the opinion that the Holfontein Extension: IWMF will alter the noise levels at the site

and could reasonably influence sensitive receptors, then a specialist will be appointed to undertake a

noise impact assessment. The scope of work will include:

• Undertake a baseline noise survey to determine the existing ambient noise levels in the area.

• Identify sensitive receptors.

• Review legislation and guidelines pertaining to noise control.

• Identify the change in noises due to the project.

• Calculate noise output during construction and operation of the co-generation power plant and

ash disposal facility.

• Define impacts on receptors during construction and operation of the project.

• Define zones of influence for noise.

• The evaluation of estimated noise impacts based on legislation and(or) guidelines.

• Make recommendations for mitigation of noise impacts.

• Write up to be included in the Environmental Impact Assessment Report.

Surface water study 9.4.5

A specialist will be appointed to assess the surface water environment in relation to the Holfontein

Extension: IWMF. The objectives of the work will be to assess the sites hydrology and determine the

potential impacts of the project on the characteristics and quality of the resource. The work will require

the determination of the baseline conditions, water quality and characteristics for all surface water

resources on the site. Much of this is known from the management of the HHWDS and the specialist

will build on the existing information. The 50 and 100 year floodlines will be delineated for the

watercourses on the site.




The specialist will need to identify risks to the water resource and to the project. The specialist will

make contributions to the site layout and development of a storm water management plan that includes

diversions for clean water and containment systems for dirty water. A site wide water balance will be

produced to inform the sizing of the storm water management infrastructure. The specialist will identify

the potential impacts of the project on the surface water resources of the site and propose possible

measures to mitigate key impacts. A surface water monitoring plan and protocol will also be developed.

Geotechnical study 9.4.6

No further geotechnical work is proposed as the area has been subject to previous investigations and

the site is adequately understood for the purposes of design and impact assessment.

Hydrogeological Study 9.4.7

A specialist will be appointed to undertake a hydrogeological impact assessment study for the

Holfontein Extension: IWMF. The objectives of the work will be to determine the hydrogeological

conditions of the site and assess the potential impacts of the project on the resource. Much of the

baseline information is available from the management of the HHWDS and the specialist will build on

the existing information.

The scope of work will include:

• Describe baseline surface and groundwater characteristics.

• Define existing water users in the area (hydro-census data).

• Ensure sufficient borehole and aquifer data to inform a model.

• Identification of geological structures that could act as preferential flow paths for the

movement of groundwater;

• Classification of the aquifer

• Develop and calibrate a numerical groundwater flow and mass transport model;

• Assess risks of groundwater pollution associated with the construction and operation of the

proposed facilities.

• Make recommendations for the:

o management and protection of groundwater resources.

o management and protection of surface water resources as influenced by groundwater.

o monitoring of groundwater resources.




Ecological study 9.4.8

A specialist ecologist with knowledge and experience relevant to the study area will be appointed to

undertake an ecological assessment of the site and surrounds. The objectives of the work will be to

assess the existing ecological condition of the study area and determine the potential ecological

impacts of the project. Baseline data will be compiled for flora as well as mammals, avifauna,

herpetofauna and butterflies using literature review, database queries and fieldwork as appropriate. The

work will focus on potential ecosystems, habitats and species of conservation concern.

The specialist will produce a baseline description of the vegetation communities of the study area, with

a summation of the ecological integrity and conservation importance of each. All potential floral species

of conservation concern will be listed, with details provided on the presence/absence of each as

determined from the fieldwork (GPS co-ordinates). The presence and distribution of alien and invasive

plant species will also be mapped. For the other groups all potential species of conservation concern

will be listed, with details provided on the presence/absence of each as determined from the fieldwork.

Sites of conservation importance such as wetlands and sites supporting key ecological services will be

described and mapped. The specialist will prepare a comparison of the site conditions against the

conservation importance of the site as mapped in relevant databases. The specialist will identify the

potential impacts of the project on the known ecology of the site and propose possible measures to

mitigate key impacts.

A specialist Ecological Impact Assessment Report will be prepared and must include maps indicating

vegetation types, sensitive habitats and location of species of conservation concern. The report will

form an appendix to the EIA Report.

Wetland study 9.4.9

A specialist wetland ecologist with knowledge and experience relevant to the study area will be

appointed to build on the wetland work previously undertaken. The objectives of the work will be to

delineate the wetlands of the study area; to undertake a functional assessment and to determine the

Present Ecological State (PES) and Ecological Importance and Sensitivity (EIS) of for each wetland

hydro-geomorphic (HGM) unit identified. The specialist will need to determine the potential impacts of

the project on wetlands.

The specialist will produce a baseline description of the wetland units of the study area, with a

summation of the PES and EIS of each. The wetlands will be mapped with the presence of any species

of conservation concern demarcated. The specialist will identify the potential impacts of the project on

the known wetlands of the site and propose possible measures to mitigate key impacts.




Culture and Heritage assessment 9.4.10

A Phase I Heritage Impact Assessment study, as required by Section 38 of the National Heritage

Resources Act (No 25 of 1999) will be compiled by a suitably qualified heritage practitioner. The

specialist will aim to determine if any heritage resources as defined in Section 3 of the National

Heritage Resources Act (No 25 of 1999) (except paleontological remains) occur on the site, and if so, to

establish the significance of these heritage resources. The specialist will identify the potential impacts of

the project on the known heritage resources and propose possible measures to mitigate key impacts.

Cognisance will be given to the requirements set out in the letter from SAHRA (see Appendix C).

Traffic Impact Assessment 9.4.11

A specialist will be appointed to undertake a Traffic Impact Assessment for the Holfontein Extension:

IWMF. The main focus of the assessment will be to determine the significance of the project related

traffic on congestion, and the resultant impacts thereof on road safety and infrastructure. The study

area will incorporate the access roads and key intersections on the current routing of motor vehicles

accessing the HHWDS.

The scope of the traffic assessment includes:

• A comprehensive site inspection should be undertaken of the site and of the surrounding

environment. Aspects which must be considered are:

o Topography;

o Road network design and condition;

o Traffic composition, particularly waste trucks versus other trucks and light motor

vehicles;

o Safety, pedestrians;

o Public transport; and

o Other transport methods available.

• Data collection, including:

o Traffic counts at selected key intersections;

o Categorise waste trucks versus other trucks and light motor vehicles;

o Trip making characteristics of local residents;

o Road network status and capacity;

o Road pavement conditions;

o Geometric details of intersections;

o Identification of existing management and control problems; and

o Input from the relevant road authority must be obtained.

• Trip generation characteristics of the project.

• Access requirements of the site must be determined; and

• Road upgrades required for potential traffic load.

• Environmental and community safety risks are to be identified for the access route and each of

the alternatives (if there are alternatives);

• Assessment of impacts to current road conditions due to a potential doubling of waste trucks to

the site;

• Key safety issues and potential bottlenecks to be defined.




• Mitigation measures to alleviate traffic impacts and to ensure safe traffic management are to be

identified; and

• Upgrades to road infrastructure to be recommended where required.

Socio-economic Impact Assessment 9.4.12

A specialist will be appointed to conduct a socio-economic impact assessment of the project. The

objectives of the work will be to define the current social and economic conditions of the site and

surrounds and assess the impacts of the project on these.

The social aspect will include will review literature and data on population statistics, services, regional

and local economic activities and policy and legislation pertaining to socio-economic development. Field

work will be used to determine the receptors and communities that may be impacted on by the project,

their economic status, the housing and basic services in the area, land use and community perceptions

and expectations in terms of current and future land uses. Key land owners and users may be

interviewed. The specialist will determine impacts on social aspects such as housing, health risks,

security risks, social services and infrastructure as well as on employment levels and livelihoods.

The economic aspect will aim to determine the impacts on the local economy relative to current and to

assess changes in property values. This will include review of regional and local economic activities,

labour skills, employment rates and opportunities, land use and capability, policy and legislation. The

work will investigate proposed capital investment and local spend, local employment as well as property

values in the surrounding area. The specialist will undertake a n economic assessment to determine

impacts on the local economy, land use and economic returns therefrom and property values.

Conceptual design of Disposal Sites 9.4.13

A registered professional engineer with appropriate qualification and experience will be appointed to

provide conceptual designs for the Class A and Class B disposal facilities. The work will also extend to

the storm water management plan for the site and the design of key water management infrastructure.

The scope of work will include:

• Review available information including: site survey, soil classification study, geohydrological

impact assessment, hydrological study and geotechnical report.

• Design of basin geometry and final landform models.

• Stability analysis of waste to final height based on assumed barrier design.

• Conceptual storm water management plan for separation of clean and contaminated storm

water.

• Liner designs for disposal sites and dams based on site conditions and current Norms and

Standards.

• Conceptual design of site infrastructure: layout, access roads, weighbridge and site office.




• Conceptual drawings suitable for submission to the DEA for approval.

• Write up to be included in the Environmental Impact Assessment Report.

9.5 Study Team

Synergistics Environmental Services (Pty) Ltd (Synergistics) has been appointed by EnviroServ as

independent environmental assessment practitioner to undertake the environmental authorisation and

associated waste management licensing process.

Matthew Hemming is an Environmental Assessment Practitioner (EAP). His qualifications and

experience include:

• MSc (Conservation Biology)

• 8.5+ years’ environmental management and assessment experience, specifically in the mining,

processing and infrastructure development sectors.

• Member of IAIAsa and IWMSA

The environmental study team members and specialists that will be involved in the EIA are listed below.

Their roles and responsibilities on the project and their qualifications are provided.

Table 9-3: EIA Study Team Name and Affiliation Qualification Role

Environmental Study Team

Kerry Fairley

Synergistics Environmental Services

BSc Hons (Botany) - Review

Matthew Hemming


MSc (Conservation Biology)

- Environmental Assessment Practitioner

- Project Manager

- EIA report and EMPr

Samantha Scott


MSc Ecology, Environment and Conservation

- Project Assistant

- Public consultation

Bheki Khumalo


BSc Geology and Applied Geology

BSc (Hons) Environmental Modelling and Monitoring

- GIS and Mapping




9.6 Consultation Process for EIA

The following opportunities will be provided to IAPs, Competent Authorities, relevant State Departments

and Organs of State for input into the EIA process:

Public Participation Process 9.6.1

9.6.1.1 IAP Responses

IAP responses received by the EAP during the assessment process will continue to be considered and

will be integrated into the EIA report.

9.6.1.2 Public Feedback Meeting during EIA

During the EIA phase of the study, a public meeting will be arranged to present the results of the EIA

and specialist studies. All registered IAPs and members of the HMC will be invited.

9.6.1.3 Public Review of the EIA Report

Both the draft and final EIA report will be made available for public review. IAPs will be provided with 30

calendar day review periods for the draft EIA report. Comments on the DSR should be submitted to the

EAP. A 21 calendar period will be provided for the Final EIA report, comments on the Final report must

be submitted directly to the competent authority, and copied to the EAP.

Electronic versions of the scoping and EIA reports will be published on www.synergistics.co.za and will

be circulated to all landowners and registered IAPs.

Hard copies will be made available at the HHWDS offices and at the Delmas Public Library. Additional

copies can be made available on request.

9.6.1.4 Notification of authorisation

All registered IAPs and members of the HMC will be notified of the grant of each authorisation and

informed of the conditions of the authorisation and appeal procedures.

Consultation with Competent Authority, State Departments and Organs of State 9.6.2

9.6.2.1 Authority Meetings

General authorities meetings will be arranged during the EIA phase of the project. Focused consultation

meetings will be held with the relevant DEA directorates, GDARD, EMM Air Quality and the DWS. The

aim of the meetings will be to discuss the environmental assessment process, the project and

alternatives and to define mitigation measures to be employed.




9.6.2.2 Review of the Scoping and EIA Report

In terms of the requirements of regulation GNR 543, organs of state and state departments will be

allowed eight weeks (60 calendar days)* for review of the draft EIA reports as the DWS is required to

issue a Record of Decision. The review period of final scoping and final EIA report will be three weeks

(21 calendar days). Competent authority review periods for the scoping and EIA report should be in

accordance with GNR 543.

9.7 EIA Report

The EIA Report will be structured in terms of Section 31 of GNR 543.

9.8 Draft Environmental Management Programme (EMPr)

A draft EMPr will be submitted as a supporting document to the EIA Report. The EMPr will be

structured in terms of Section 33 of GNR 543. The EMPs will provide recommendations on how to

construct, operate, maintain and close the facilities and associated infrastructure through all relevant

phases of the project life. The aim of the EMP will be to ensure that the project facilities are managed to

reduce potential negative environmental impacts and enhance potential positive environmental impacts.

The EMP will detail the actions required, the responsibility for implementation and the schedule and

timeframe.

Once approved by the relevant authorities, the provisions of the EMPr are legally binding on the project

applicant and all its contractors and suppliers.

9.9 Atmospheric Emissions Licence

The atmospheric emissions licence application forms will be completed with the final design details and

information from the Air Quality Impact Assessment. The atmospheric emissions licence forms will be

submitted to the Air Quality Officer at the Ekurhuleni Metropolitan Municipality. The atmospheric

emissions licence forms will only be submitted once the environmental authorisation required in terms

of the NEMA and the EIA Regulations has been obtained.

In the interim there will be on-going consultation with the EMM so that the officials remain informed and

the investigations and reporting are appropriate to meet the requirements of the atmospheric emissions

licence application process.

The air quality impact assessment will be undertaken with cognisance of the requirements of the

regulations made under the NEM:AQA.




9.10 Water Use Licence

The required water use licence application forms will be completed with the final design details and

information from the Hydrological and Geohydrological Impact Assessment. The forms and supporting

documentation will be submitted to the Department of Water and Sanitation. The water use licence

forms will only be submitted once the environmental authorisation and waste management licence

required in terms of the NEMA, NEMWA and the EIA Regulations have been obtained.

In the interim there will be on-going consultation with the Department of Water and Sanitation so that

the officials remain informed and the investigations and reporting are appropriate to meet the

requirements of the water use licence application process.

Reporting to the DWS will be in the form of an Integrated Water and Waste Management Plan,

prepared in terms of the Department’s Operational Guideline.




10.Conclusions and Key Findings

This report concludes the scoping phase of the environmental assessment for the Holfontein Extension:

IWMF. It outlines the results of the public participation and authority consultation processes to date,

identifies the potential impacts that may result and defines the plan of study for the Environmental

Impact Assessment phase.

Facilities proposed for the Holfontein Extension: IWMF include means to re-use, recycle, recover and

treat target waste streams as well as to provide for the disposal of general and hazardous waste to

landfill. The project is located on properties owned by EnviroServ and adjacent to the HHWDS in

Ekurhuleni, Gauteng . The proposed facilities will variously complement and/or extend the services of

the HHWDS. EnviroServ’s investment in infrastructure and baseline monitoring provide motivation for

the project’s location.

Operations at the existing HHWDS pose environmental and health risks from the hazardous wastes

handled, treated and disposed there, mostly notably to the surface and groundwater resource and air

quality. Various impacts have been documented and are regularly discussed at the Holfontein

Monitoring Committee forum. There are concerns that the facilities proposed for the Holfontein

Extension: IWMF could: extend the time period over which such risks will occur; add cumulatively to the

existing impacts thereby worsening the current situation; and/or add risks and impacts additional to

those currently experienced.

Re-use and recycling of waste streams is promoted in the waste management hierarchy and are

generally beneficial if undertaken appropriately. When handling general wastes there can be risks

related to surface water quality, odour and litter dispersion, dust generation and proliferation of vermin.

With appropriate facility design and management the risks are anticipated to be low. The recycling of

hazardous wastes can present more significant risks than for general wastes and thus requires more

rigorous design and management. The potential impacts of the various recycling plants to

environmental aspects will be assessed and measures proposed to ensure that the layout, design and

operations are appropriate.

The recovery of materials and energy from wastes are also proposed. These processes are also

generally beneficial and promoted in the waste management hierarchy. However, if improperly

implemented, the various facilities can result in environmental risks similar to and of greater impact than

recycling. Recovery from hazardous wastes is likely to include risks to surface and groundwater and

possibly, air quality. The various thermal treatment plants proposed, as well as the anaerobic digestion

plant, all have the benefit of recovering embodied energy from the waste and reducing the volume of

residual waste. However, the processes can consume wastes that are better suited to recycling;

concentrate the contaminants in the residual waste and result in the release of pollutants to air. An air

quality impact assessment will be necessary to investigate the potential impacts on air quality and any

related health risks. Emitting facilities will need to achieve the emissions limits set by the National

Environmental Management Air Quality Act to ensure that air quality impacts are within the acceptable

range.




Treatment of certain waste streams is necessary to reduce the environmental risk prior to further use or

disposal. Such treatment can remove or alter the contaminants in the waste stream or change the

properties of the waste so that the risks to the environment are reduced. Although the treatment

process may have inherent risks, these are generally far outweighed by the benefits of the treatment.

The treatment of HCRW, and anatomical wastes in particular, is of concern to some IAPs. The concern

is partly related to possible health risks but also due to conflicting cultural beliefs. The potential impacts

of the various treatment plants to environmental aspects will be assessed and measures proposed to

ensure that the layout, design and operations are appropriate.

The disposal of waste to landfill is the least preferred method in the waste management hierarchy, but

is a key tool for waste managers. The disposal of residual waste to appropriately designed and

managed landfills remains an environmentally responsible option. Disposal of waste to land is

associated with many risks, but particularly to the surface and groundwater resource, air quality and

human health. The generation of landfill gas is concern when disposing of general waste. Landfills

disposing hazardous waste potentially pose greater risks to each of the environmental aspects and

particularly to human health. The potential impacts of the Class A and Class B landfills will be assessed

in detail and measures proposed to ensure that the layout, design and operations are appropriate. This

will include hydrogeological and hydrological assessments as well as an air quality impact assessment

to determine risks to human health. Buffer zones to protect receptors will be defined. The disposal

facilities will be designed by experienced professional engineers with due consideration of the

geotechnical conditions, hydrogeological setting, waste classification and other environmental aspects.

The proposed location of Holfontein Extension: IWMF is adjacent to the HHWDS as this has numerous

benefits and synergies for the operator. However, the properties could have various environmental

aspects that render the site as a whole, or the layout of facilities, inappropriate for development.

Potential aspects of concern include soils of high agricultural potential; heritage resources; a

watercourse and associated wetlands; critical biodiversity areas that are necessary to achieve

conservation targets in the province, host species of conservation concern or provide vital ecological

services; and nuisance and health risks to sensitive receptors. Site assessments by appropriately

qualified specialists will be necessary to determine the status of these aspects. The presence of waste

management facilities may have influences on social and economic aspects of the area as well as on

the zoning and permissible use of the adjacent properties. The value of adjacent land may be

influenced. A socio-economic study as well a traffic impact assessment and visual assessment are

advocated to assess these issues.

The development of the Holfontein Extension: IWMF adjacent to the existing HHWDS could result in

cumulative changes to environmental aspects that are above acceptable limits. The potential,

concurrent development of the Amadwala Integrated Waste Facility by Interwaste

(DEA:12/9/11/L1257/3 ,GDARD: Gaut 002/13-14/E0073) on adjacent properties may add further weight

to the impact concerns. The cumulative impact of the Holfontein Extension: IWMF and the neighbouring

facilities will need to be considered by the specialists and throughout the impact assessment, as far as

this is possible.




The Holfontein Extension: IWMF will have benefits in enabling integrated waste management at a

single location in terms of the principles of the waste management hierarchy. This is in line with the

approach advocated by government through legislation and policy and in terms of the goals of the

National Waste Management Strategy. The various plants and facilities proposed will aim to derive the

maximal sustainable benefit from each waste stream through recycling, recovery and treatment before

disposing of the residual waste to landfill. EnviroServ has invested significantly in the infrastructure of

the existing HHWDS and has good knowledge of the environmental parameters and receptors in the

area from decades of monitoring. This data will enable informed design, management and impact

monitoring that could not be easily achieved at any alternate site. EnviroServ maintains that, given

these reasons, the site is the only reasonable and feasible location for the project.

There have been no fatal flaws identified during the scoping phase and the project will proceed to the

EIA phase. The next step will be to conduct the specialist studies and further consultation processes

that will inform the EIA and authority decision-making process. Additional impacts/issues identified

during the EIA phase will be addressed. The EIA reports will incorporate a draft environmental

management programme that will set out the management and mitigation measures required at each

facility to ensure that potential impacts are managed to an acceptable level.




11.Consultant Declaration

Synergistics Environmental Services (Pty) Ltd is an independent environmental consultancy that was

established in South Africa in 2004. Matthew Hemming, the Environmental Assessment Practitioner

responsible for the reporting on this project, has over 8.5 years of experience in the field of

environmental consulting, particularly in the mining and waste management sectors.

I, the undersigned, herewith declare that this scoping report represents an objective and complete

scoping-level assessment of the environmental impacts associated with the Holfontein Extension:

IWMF. Issues and impacts were defined through professional judgement and consultation with

interested and affected parties and authorities.

It is deemed that the environmental assessment process followed to date meets the requirements of

relevant legislation to ensure that the regulatory authorities receive sufficient information to enable an

informed decision to accept the scoping report and approve the Plan of Study for EIA as outlined in

Section 7 of this report.

COMPILED BY:

Matthew Hemming

MSc (Conservation Biology)

Environmental Assessment Practitioner

For Synergistics Environmental Services (Pty) Ltd

P.O. Box 1596,

Cramerview,

2060.




References

(in text)

Department of Environmental Affairs (2011). National Waste Management Strategy. Department of Environmental Affairs, Pretoria, South Africa.

(Department of Environmental Affairs, 2011)

Department of Environmental Affairs (2012). National Waste Information Baseline Report. Department of Environmental Affairs, Pretoria, South Africa.

(Department of Environmental Affairs, 2012)

Department of Water Affairs and Forestry (2004). National Water Resource Strategy.

(DWAF, National Water Resource Strategy, 2004)

Ekurhuleni Metropolitan Municipality. Integrated Development Plan. 2013/2014.

(Ekurhuleni IDP, 2013/2014)

Ekurhuleni Metropolitan Municipality. Spatial Development Framework. 2013/2014.

(Ekurhuleni SDP, 2013/2014)

EkoInfo CC & Associates (2013). Ecological Scan Holfontein Landfill Site, Gauteng Specialist Report: Flora and Fauna Study. Assessment of the Presence of Species of Concern Within a Stockpile Footprint Prior to its Placement.

(EkoInfo, 2013)

Ecotone Freshwater Consultants CC (2013). Wetland Specialist Study: Holfontein Waste Disposal Site Infilling at Portion 15/16 – Farm Holfontein, Ekurhuleni Metropolitan Municipality. Section 24G-Infilling at Portion 15/16- Farm Holfontein.

(EcoTone, 2013)

Golder Associates (2014). Final Scoping Report for the Proposed Amadwala Integrated Waste Management Facility.

(Golder, January 2014)

Jones and Wagener Consulting Civil Engineers (February 2010). Effectiveness of Upstream cut-off trench at the Holfontein Waste Disposal Facility. JW21/10/B200.

(JAWS, 2010)

Jones and Wagener Consulting Civil Engineers (November 2010). Holfontein Expansion Project Dolomitic Risk Assessment. JW156/10/B200-Rev-0.

(JAWS, 2010a)

Jones and Wagener Consulting Civil Engineers (July 2014). Water Quality Monitoring Report for the Holfontein Waste Disposal Facility. JW145/14/B200.

(JAWS, 2014)

Mucina, L., Rutherford, M.C. & Powrie, L.W. (2005). Vegetation Map of South Africa, Lesotho and Swaziland. South African National Biodiversity Institute.

(Mucina et al, 2005)




List of Appendices



B1: BID/Notification letter

B2: Distribution list for BID/Notification letter

B3: Copy of the Adverts

B4: Copy of the Site Notice

B5: Registered IAP database

B6: Comments from IAPs

B7: Responses from Commenting Authorities

B8: Responses from EAP


enviroserv waste management ltd - sahra

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